Veterans Home Inspection Services LLC

Henrey Dee Jetty 28 Larchwood Drive Pittsford NY 1

4534 Email: hjetty@roc hester.rr.com 585

-363

-2848 (Call or text) NY Home Inspector Lie# 1 6000044801 June 1,2015

US Department Of Transportation Federal Aviation Administration 800 Independence Ave SW Washington DC 20591 Subject: Exemption Application FAA Modernization and Reform Act of2012 (Public Law 1 12

- 95). Section 333 of Public Law 1 12

-95
DearSir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the reform act) and CFR Part 11Veterans Home Inspection Services LLC, owner and operator of a Small Unmanned Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations (FAR) listed below so that Veterans Home Inspection Services LLC may operate UASs commercially in airspace regulated by the FAA

., as long as such operations are conducted within and under the conditions outlined herein or as maybe established by the FAA as required by Section 333

. Veterans Home Inspection Services LLC is a small business owned by Henrey D. Jetty

. Retired CSM, US Army, Special Forces

. I have a Class C FAA License as a Parachutist, Sky Diver and a NAUI Scuba license

. I also hold a valid New York Drivers licenses for both a car and a motorcycle. Conducting safe operations has always been paramount in both my professional and private life style. All operations with the UAS will be performed with the public's safety and right to privacy safe guarded at all times

. As described below, the requested exception would permit the operation of light weight (less than 55 lbs. total takeoff weight) UASs under controlled conditions for commercial use by a certified private pilot thereby enhancing safety and fulfilling the Secretary ofTransportation's ( the FAA Administrator's) responsibility to" establish requirements for safe operation ofsuch aircraft systems in national airspace systems." Section 333(c), ofthe Reform Act

.Veterans Home Inspection Services LLCvideo UASs are · rotorcraftweighing lessthan 55 pounds including payload. Veterans Home Inspection Services LLC usesthe OJI Phantom 2Vision PlusVersion 3 Quad Copter Model PV331 serial # DH645440916. It operates at a speed less than 50 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously. The UAS has an auto return to launch point when battery power is under 25%. The UAS will operate within the line of sight with in a protected flight area as described below and at 200 feet AGL or less with a trained operator and observer located in close vicinity as to make voice communication possible

. These flight operations will not create a hazard to users ofthe nation airspace, public nor to the environment. Veterans Home Inspection Services LLC respectfully requeststhe grant ofan exception to the following specific sections ofthe Title 1 4 Code of Federal regulations allowingitto operate lightweight UASs for commercial use, 1 4 CFR 21,subpart H, 1

4 CFR 45.23 (b) 1

4 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109, 91.11 9, 91.121,91.151,(a), 91.203(a) &(b),91.405(a),91.407(a)(l ), 91.409(a)&(b)

. Veterans Home Inspection Services LLC submits this application in accordance with the Reform Act ,1 12 P.L. 95 331

-334, seeking relief from any currently applicable FAR'S operating to prevent Veterans Home Inspection Services 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 integration of civil unmanned aircraft into our national airspace system as it is in the public's interest to do so. Veterans Home Inspection Services LLC UAS meets the definition of a "small unmanned aircraft" as defined in Section 331 and therefor the integration ofthe UAS are expressly contemplated bythe Reform Act

. Veterans Home Inspection Services LLC would like to operate its lightweight UAS priorto the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft. The Reform Act directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion ofthe rule making required under Section 332 of the reform Act. In making this determination, the Secretary ofTransportation 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 ofthe following: The UAS's size, speed, weight and operational capability, operation ofthe UAS in close proximity to airports and populated areas, operation ofthe UASs within visual line of sight of the operator Reform Act 333(a). lfthe Secretary determines that such vehicles "may operate safely in National Airspace System, the Secretary shall establish requirements forthe safe operation in national airspace. Veterans Home Inspection Services LLC UASwill onlyoperate within the line of sight of the operator within a protected flight area and at 200 feet AGL or less

. Most flight times are less than 1 0 minutes. These flights ofthe UAS will not present a hazard to the national airspace northe public

.The very small nature of this UAS combined with the safe guards presented below,will allow for the safe operation greater than that envisioned by Congress for the FAAto 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 ofthis exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management process

. Given the clear 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 verses traditional aircraft as well as the economic impact ofgreatly reducing the cost of aerial photography thereby benefiting the greater public's interest. Accordingly, Veterans Home Inspection Services LLC respectfully requests that the FAA grant the requested exemption without delay. The following will be considered as the binding limitations on flight operations of any Veterans Home Inspection Services LLC UAS: 1. Flights will only occur in the day time hours. 2. Flights will be operated in the line of sight of the Pilot in Command (PIC) and Visual Safety Observer, (VSO)

. 3. Flights will be terminated at any time weather and wind deteriorate to "unsafe for flight" by manufacturers recommendations

.4.The UASs will weigh less than 55 lbs..

5. Flights will be operated at 200 feet AGL or less. 6. The crew will be at a minimum of operator (PIC) and an observer and/or camera operator (VSO). 7. Operator and crew will remain in contact during the flight operation

. 8. The UAS 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 owners of respective properties within the photography area to further reduce the chance ofviolating anyone's privacy. 10.All required FAA clearances, will be obtained and distances from airports and other restricted airspace areas will be strictly observed. 11.All UASs will have the capability to return automatically to the operator in a safe manner with the auto return function checked and working. 12. Flights will only operate in highly favorable weather conditions and adequate flying space from any obstructions. 13.The UAS has 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 the use oftwo

-way radio ifthe area is too big to hear an operator's normal voice from all observer members. 15.The UAS will be used to take pictures and videos of real estate property. 16.When operating over or near water the UAS will be equipped with flotation devices so that recovery can be made as to prevent lithium battery exposure to the water table. 17.All flights will have a pre-flight check and a functions check of platform stability and control prior to elevating the UAS to required heights. This will be in compliance with the manufacturer's pre-flight instructions

. 18.All required permission s and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement,fire, or other appropriate governmental agencies. 19. The UAS has been registered with the FAA as required

. In regards to 1

4 CFR part 21 Subpart H: Airworthiness Certificate 1 4 CFR 91.7(a), 91.203(a)(l) Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in relation to FAR 91.203(a)(l)

.The size, weight and defined area of operationsforVeterans Home Inspection Services LLC UASflights permits exception from Part 21 because they meet an equivalent level of safety pursuant to Section 333 ofthe 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 ofthe Reform Act. Both pieces of legislation permit the FAAto exempt UASs from airworthiness certificates in consideration ofweight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Veterans Home Inspection Services LLC meets or exceeds each of these requirements. 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 UAS operator with a section 333 exemption

. 1 4 CFR 91.203 (a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable for the same reasons stated above

.The equivalent level of safety will be achieved by maintaining such certifications and registrations as required at the Veterans Home Inspection Services LLC home office

. 1 4CFR91.7 (a) prohibits the operation of an aircraftwithout an airworthiness certificate. As no such certificate will be applicable in the form

contemplated by FAA's this regulation is inapplicable: 1 4 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft 1

4 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As 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 the Veterans Home Inspection Services LLC home office. The FAA has previously issued exemptions to this regulation in Exemptions No's 8607,8737,8738,9299,9299A,9565,9565B, 10167, 1 0167A, 1 0602,10700 and 32827

. 1 4 CFR 91.11

9 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Veterans Home Inspection Services LLCwill only operate its UASs at or below 200AGL. Theywill 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

. Flights will only be over private property that the owner has consented and all persons within 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 negligible risk to the public. Approval ofthese 333 Exemptions allowing commercial operations of small UASs in the service of aerial photography will greatly enhance safety 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 small UASs of 55 lbs. or less, 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 ofthe use ofthese small UASs byVeterans Home Inspection Services LLC will give my company a safe venue to provide my clients a top down viewpoint of the property being inspected. Inspections of properties with high pitch roofs that are multiple stories is a hazardous endeavor that has limitations for the inspector. This application of drone technology is a critical component of providing essential information in real time. An aerial view provides visual information of the property not readily available with observation from the ground. These pictures and videos will provide my clients with accurate information to make decisions intheir real estatetransactions. Granting Veterans Home Inspection Services LLCthe above exemption will allow for the expansion of UAS systems in the Rochester, NY area and for future for the safe conduct of free enterprise and providing my clients with safely acquired same day photography of real estate. Veterans Home Inspection Services LLC respectfully requests the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by Veterans Home Inspection Services LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended.

InspectionServices LLC

# HENREYJETIY DRONE SERIAL NUMBERAND MODEL Veterans Home Inspection Services Pittsford NY 1

4534 585

-362

-2848