Drone Inspired, LLC

118 N. Peters Rd., Suite 325

Knoxville, TN 37923

Email: Mile sHolley82@gmail.com

Business Line: 865

- 240

- 3658

Cell Line: 225

- 439

- 3281

May 13, 2015

US D epartment Of Transportation

Federal Aviat ion Administration

800 Independence Ave SW

Washington DC 20591

Dear Sir or M adam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the reform act) and CFR Part 11, Drone Inspired, LLC , owner and operator of Small

Unmanned Air craft Systems (UASs), request to be exempted from the Federal Aviation Regulations (FAR) listed below so that Drone Inspired, LLC may operate UASs commercially in airspace regulated by the FAA., as long as suc h operations are

conducted with in and under the conditions outlined herein or as maybe established by the FAA as required by Section 333.

Drone Inspired, LLC is co

- owned by Miles Holley and Chris Berrong . Both are successful Knoxville Entrepreneurs with extensive experience in ethical business operations as well as operating both drones as well as RC aircraft . Both have Tennessee

drivers licenses

. Miles Holley has extensive experience in maintaining manned aircraft and has logged over 20 hours in the air as a co

- pilot. He has observed proper etiquette, and understands that the same level of preparation and safety is paramount in operating

an unmanned drone

. All operations will be performed with the public’s safety and right to privacy safe guarded at all times. Any persons that would appear i n any videography taken by UAS would have given prior approval in the form of a release document.As described below, the requested exception would permit the operation of light weight (less than 55 lbs. total takeoff weight) UASs under controll ed conditions for

c ommercial use by a competent operator thereby enhancing safety and fulfilling the Secretary of Transportation’s ( the FAA Administrator’s) responsibility to” establish requirements for safe operation of such aircraft systems in national airspace systems.” Section 333(c) , o f the Reform Act.

Drone Inspired, LLC UASs are quad prop dji Inspire 1 weighing less than 55 pounds including payload. ( The DJI Inspire 1 is recognized by authorities in UAS fields as one of the most advanced, s afest UAS on the market

. ) They operate at a speed less than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. Both have an auto return to launch point when battery power is under
25%. The UAS will operat e within the line of sight with in a protected flight area as

described be low and at 200 feet AGL or less with an observer located close at hand as to make voice communication possible. These operations will not create a hazard to users of the nation airsp ace, public nor the environment.

Drone Inspired, LLC respectfully requests the grant of an exception to the following specific sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for commercial use,

14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b)

, 91.109, 91.119, 91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(1), 91.409(a)&(b).

Drone Inspired, LLC submits this application in accordance with the Reform Act ,112

P.L. 95 331

- 334, seeking relief from any currently applicable FAR’S operating to prevent Drone Inspired, LLC future commercial use of small UASs to operate in the national airspace system as described below. The reform Act section 332 provides for such

in tegration of civil unmanned aircraft into our national airspace system as it is in the public’s interest to do so. Drone Inspired, LLC s UASs meet the definition of “small unmanned aircraft” as defined in Section 331 and therefor the integration of these UA Ss are expressly contemplated by the Reform Act. Drone Inspired, LLC would like to operate its light weight UASs prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft.

The Reform Act directs the S ecretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion of the rule making required under Section 332 of the reform Act. In making this determination, the Secretary of Trans portation is required to determine which UASs do create a hazard to users of the national airspace system or the public or pose a threat to national security in light of the following:

The UASs size, speed, weight and operational capability

Op eration of the UASs in close proximity to airports and populated areas

Operation of the UASs within visual line of sight of the operatorReform Act 333(a). If the secretary determines that such vehicles “may operate safely in National Airspace S ystem, the secretary shall establish requirements for the safe operation in national airspace.

Drone Inspired, LLC are rotorcraft weighing less than 55 lbs. and the y operate at speeds less than 50 knots and have the capability to operate in the verti cal and horizontal plane simultaneously. The UASs will operate only within the lin e of sight of the operator with in a protected flight area and at 200 feet AGL or less. These will not present a hazard to the national airspace nor the public.

The very s mall nature of these UASs combined with the safe guards presented below, will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow commercial operations of UASs to commence immediately. Also due to the size of UASs and the areas and altitudes they will operate approval of this exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management process. Given the c lear direction given in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced emissions utilizing UASs verse s traditional aircraft as well a s the economic imp act of greatly reducing the cost of aerial photography thereby benefiting the greater public’s interest. Accordingly, the applicant requests that the FAA grant the requested exemption without delay.

The following will be considered as the binding l imitation on operations of Drone Inspired, LLC

,

1. Flights will only occur in the day time hours,

2. Flights will be operated in th e line of sight of the operator ( PIC ) and Observer, (VSO)

3. Flights will be terminated at any time weather and wind deteriorate to “un safe for flight” by manufacturers recommendations,

4. The UASs will weigh less that 55 lbs.,

5. Flights will be operated at 200 feet AGL or less.

6. Crew w ill be at a minimum of operator (PIC) and an observer and/or camera

operator (VSO)

, 7. Operator and crew will re main in contact during the flight operation,

8. The UASs operator will perform a check of the flight area and make certain of the safety of all persons in the area,

9. Consent will be obtained from all persons with in the video capabilities of the units to

furth er reduce the chance of violating anyone’s privacy.

10. All required FAA clearances, will be obtained and distances from airports strictly

observed.

11. All UASs will have the capability to return automatically to the operator in a safe

manner with the auto ret urn function checked and working.

12. Flights will only operate in VFR conditions.

13. UASs have a function on the control to tell operator the distance away from the operator and its battery power remaining.

14. Flight team will communicate by voice and the use of t wo

- way radio if the area is too big to hear voice from all team members.14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement

of necessa ry certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for Drone Inspired, LLC UASs flights permits exception from Part 21 because they meet an equivalent level of safety pursuant to Section 333 of the Reform

Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness

certificates in consid eration of weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Drone Inspired, LLC meets or exceeds

each of these elements

As of March 23, 2015 the FAA has stated that it will automatically grant a “blanket” COA

for flights at or under 200 AGL to any UASs operator with a section 333 exemption.

14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable for the same reasons stated above. The equivale nt level of safety will be achieved by maintaining such certifications and registrations at Drone Inspired, LLC operations center.

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness

certificate. As no such certificate will b e applicable in the form contemplated by FAR’s this regulation is inapplicable.

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft

14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. A s there are no pilots or passengers, and given the size of the UASs this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such certifications and registrations at Drone Inspired, LLC operations center.

The FAA has previously issued exemptions to this regu lation in Exemptions No’s 8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and 32827.

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Drone Inspired, LLC will only operate its UASs at or below 200AGL. They will be operated on a will defined AOR that has been carefully reviewed for hazards and minimizes the presence of any persons not essential for these operations. F lights will only be over private property that the owner has consented and all persons with in this video area also give consent for this filming. Compared to flight operations of conventional and traditional aircraft or rotorcraft weighing far more than 50 lbs. , operating below 500 AGL with flammable fuel UASs operations present a far smaller risk to the public.Approval of these 333 Exemption s allowing commercial operations of small UASs in the service of aerial photography will greatly enhance safe ty by reducing the overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraft with flammable fuel to fly in close proximity of populated areas and people in general.

With the use of sma ll UASs of 55 lbs. or le ss, battery operated and fling below 200 feet AGL the risk of injury of people on the ground or the crew has been reduced or almost erased. The granting of the use of these small UASs by Drone Inspired, LLC will give the people another avenue to express th emselves and to have a video record to share with family and friends forever.

Granting Drone Inspired, LLC the above exemption will allow for the expansion of UAS systems into the future for the safe conduct of free enterprise and the enjoyment of the

mass es.

Drone Inspired LLC will als o have all necessary liability coverage at $1,000,000.00 level

to begin operations and will amend the coverage as needed or required by the governing body.

Drone Inspired, LLC respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by Drone Inspired, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).

Sincerel y

Miles Holley

Drone Inspired, LLC

118 N. Peters Rd.

,

Suite 325

Knoxville, TN 37923

MilesHolley82@gmail.com

_____________________ Date:

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