Jan 12 Centrat Home 9895448007 

### ,,:::;t·, ..**,.~f['' ~~·** .. :· page 2

## ·,.~_;**11**

## d:rtffk4~!~ru_~J2tP~I1111'11J.Qf.Ir.i!h~P.ortation Exemptlon.·Reqoest Pursuant

## to Section 

### 333 of 

### the FAA

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### Jan_uary 10, 2016

Michael Raines Central Home 

### Inspections 9780 Green Rd Farwell, Ml 48622**.t.n•P~(;~~~.b** 

### ..**t~."Q-~_,,@g_m~J.t.~~om**

U.S 

### Department of 

## Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14 CFA 21 subpart H; 14 CFA 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFA 91.119(c); 14 CFR 91.121; 14 CFR 91.151 (a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14CFR 91.417(a) and (b)

The exemption is in the public interest. Pursuant to the authority contained in 49 U.S.C. 106(1), 40113, and 44701.



### Dear Sir or 

### Madam:

Pursuant to

### S~tioQ 333 of the FAA Modernization and 

### Reform Act of 2012 (the**.•.!R~form** Act 11)**an~** 14 CFA Part 11 of Unmanned Aircraft Systems (UAS),

### Mlcha~l**A,alne~ h~reby**  applies

### for~**e~tlf11Ption** from the listed

### F,~cleral Aviation 

### Regulations (11

## .Ej\Rsi 1) to allow 

### commerciai operation of Designated

## IJAS, provideq

### s.1.1c.~ 

### operations are conducted .Within and underthe conditions outlined

### herein_~r**~~. !.r'~Y**  be established

### ~y**'h~** FAA as required by Section 333.12 2016 :**:;~W~~i";'t~~** Home Inspections"'

..**~~95448007**

..**~ "~:~·-~\~** 



### Thank you in 

### advance for your 

### consideration. page 3

_ll!:**de?;~~~pt;'··"'**•..**:~,~~e~n'fGP.mrnerciat~pe~l\t~_Q,,Of.E~:n** 

### UAS,**a~ describ~** **h~rein, ~hich_**  are**equipp~d** with**virh~;-i:,t.rife~;-.** ,**~-**..**:f.~ ~~t:~t~amtra(s)** **~~nd** 

### sensgrs, would provtde**profes~ional** servrces 

### 1n the folloWing



### · · ·... · ·areas: ·· ..··

· · ·

1. Real Estate 2. Education 

### and Special Events 3. Vldeography I Photography 

### 4. Search and Rescue 5. Roof Inspections 6. Construction 

### SiteWork 7. Residential/ Commercial Building Inspections 8. Weddings 9. Public and Private Events


### As described fully below, the 

### requested exemption would permit the operation of. designated UAS as set forth in this document under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) safe. Approval of this exemption would Increase public awareness of UAS operations and enhance safety to aid in fulfilling the Secretary of Transportation's (the FAA Administrator's) 

### responsibilities to

...... establish requirements for the safe 

### operation of 

### such aircraft systems in the national airspace 

### system."

The name and address ofthe applicant is

Michael Raines Central Home Inspections 9780 Green Rd Farwell, Ml 48822**1nspe~tth9.?hou~J*_mail.c.~m**

from which the exemption Is requested: 14 CFR Part 21 subpart H 14 

### CFR 45.23 (b)



### _· · 14 CFA 

### 61.113 (a) 

### &(b)'

: 14 CFR 91.7 (a)

14 CFR 91.9 (b) {2)

.c "-"'"·-<.tlr'**,~- ·:0?&-.tt~~H:,+;'**  i 

### 14 CFR 91 ;1 03

. ·. ··14 CFR 91.1 09

. '•"' ,.,,,...,,,,,i•f!i···

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....**···(~ ·-~i,l-;,.** **~** ...,**--·--,..~~""~"i'""',**4 CFR 91. 119 (c)**~'~'~":Ah"'"·"·**



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# ..**,~~\,**12:27PM <**'!:~j~~~;;;t~:~·~~'~.j~** Inspections 9895448007··"."

14 CFA 91.405 (a) 14 CFR 91.407 (a) 

### 14 QFR 91.409 (a) 

### 14CFR91.417 (a) < '**.~~** page 4



### As in Grants of Exemption Nos. 11062

### to Astraeus 

### Aerial (see Docket No.

·FAA-2014-0352), 11109

### to Clayco, Inc. (see Docket No. FAA-2014-0507),

11112

### to VDOS Global, LLC (see Docket No. FAA-2014-0382), 11213 to 

### Aeryon labs, 

### Inc. (see Docket No. FAA-2014-Q642), and 12645 to Allied Drones (see Docket No. FAA-2014-0804), There is enhanced safety achieved using an unmanned 

### aircraft (UA) with 

### the specifications described by

### the petitioner and 

### carrying no 

### passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition

### to flammable**fuel~** gives the FAA good cause to find thatthe UAS operation enabled by this exemption is in the pubUc interest.

Michael Raines Will operate one or more ofthe Following model UAS

DJI Phantom 3 Pro Safety requirements. The 

### approval of this application presents 

### no national security issues. Regarding the level ofsafety surrounding the proposed

. 

### operations and the 

### public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofthe 

### requested exemption is in the public Interest. Accordingly, the applican1 

### graciously requests that the FAA grant the requested.exemption.

AlRCRAFT AND EQUIVALENT LEVEL OF SAFETY

"'

.

Tt)e 

### operation limitations proposed for an 

### equivalent or higher level of safety ;because operations 

### wUI further enhance the safety of the persons and/or property 

### ,using conventional aircraft. These limitations and conditions to which the



### .,

...fipp,icant**ag~~~s** to 

### adher.e to when conducting commercial operations under the



### ·--**"''"'i!~~~·:;:~:FAA,.issLied** exemption 

## as set forth in the Flight Operations Manual (FOM)

... ; )f1Pilfctf;!:

, ,•- .<;· j '**'•'"*'~'-"~·;~"·'•'1·'''**Home**~·** . .. .· ''

### '·:·.~~~1**~erTb~~ Y~S,;dep~nding**  

### oh the 

### mOdel In 

### operation. will 

### have 

### a maximum


## ·. operat!ng speed of no rriore than 50mph.



### 3. Flights will be 

### operated within line of sight of

### the Pilot in Command (PIC) 

### and/or Visual Observer (VO).

4. Maximum flight time for each operational 

### flight will be depending on the UAS 

### model in operation, but will not exceed 30 minutes. Flights will 

### be terminated at 25% battery power 

### reserve or 30 minutes offlight time whichever occurs first.

5. Flights will be operated 

### at an altitude of no more than 400 feet Above Ground Level {AGL) and not more than 200 feet above an elevated plaHorm from which fflm.ing is planned.

6. Minimum crew for each operation will consist ofthe UAS Pilot and at least one 

### Visual Observer (VO), and may include a third, but separate, Camera Operator**(CO)~**

7. The UAS pilot will be a 

### designated Pilot in Command (PIC). The PIC will have logged a minimum of 20 hours on the designated UAS.



## a. A safety briefing will be performed prior to each day1s flights consisting of all the days• Production activities.

9. All flight aCtivities witl be logged.

10. All flights will occur under Visual Flight Rules 

### Meteorological Conditions 

### .(VMC) only.

,,:;·' 11. The flights will occur in Class G airspace no closer than a mile radius of the ,·:r·>:Q!Q_Qraphic**ce~t~,~/Airport J1efere11c~** 

### ..**~()int** (ARP) of

### a tower controlled or



### ..**~.;~~uncontroiiE§(fairJ)Ort.;<~** ,.€ :**··~** '· , ·**.;)~~ '•0\~** **·~·** •. ·'. • ; 

## 12. Flights· 

### Wiu'n6fiie"closer than 

## as mile 

## radius of the geographic center/Airport.

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### ~~-::·:ltt~·~l~}~~;~

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### ;·~;·;:~,){r(-'
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# . ' 2016 12:27PM ';.'·**;y~f;~::iif'~~~-~:·}"**·, page 

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.**13.~The,operatorwill** 

### do a pre check 

### of aircraft prior 

### to each flight. And log each



### fli(Jht.

.. .. . .**~-** 

### .1:4.**T~t(Qper~tc>cwill** obtain 

### verballwrtnen consent 

### of all persons 

### involved with the "''"",

...., ••.,.,.r:.1:.,."

...**~~/:irPianned** 

### operation and ensure that only consenting persons 

### wllf be 

### allowed within 100 feet of the flight operation, and the radius 

### may be reduced to 30 feet based upon an equivalent level of safety determination, as U.S. Department of Transportation required under the FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved.

15. The PIC and VO will have been trained in operation of UAS and receive up to date Information for the particular UAS to be operated.

16. The PIC and VO will be able to communicate by voice and/or radio at atl 

### times.

17. The PIC will abide by all rules

18. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a predetermined location wlthJn a designated 

### location and land autonomously.

19. The UAS will have the 

### capability to abort a flight in case of emergencies with 

### an automated

..Return Home and Land 11 

### function.

20. The UAS will have the capability to abort a flight in case of unpredicted obstacles, 

### weather, 

### or emergencies such as low battery.

21. Any incident, accident, or flight operation that transgresses the lateral or

,**verti9~""~Q.~ndaries** of the operational area as defined by the applicable COA :must bereported to the FAA's UAS Integration Office (AFS-80) within 24 hours

.



### . '.Accidents must be reported to the 

### National Transportation Safety Board 

### (NTSB) ,per instructions contained on the 

### NJSB Web site: www.ntsb.gov.**-~;:t;:~~r~~~,f)··~.** c ,**'\~~~-~,** <.". '/''

.

,.,,·.u·",,-•.

### ~··.·.·" 

### <**,.rlt-:~~1fiMJ%R·;,f~~~ Part·2t,_.~~~p~Q,Jj}:~~Jr~orthiness** **Certlfl~aJ~~.14** C.F.R. §91.203 (a)



### ..,**i:i·:~ii.~(~.~.~~~QP~~:t-i, ent1tl~~d** **AJr~~~~.lJ.!!~Certlflcates, ~stabll~hes**  the procedural



### . ::

### ":~··**~tirequlrements** for the 

## issuaficEf'ot airworthiness eertificates as required by FARJan 12 2016 12:28PM Centrat Home

## ~~~Ncins 9895448007 page 7**"~;§9t.203** (a) (1). Given,the size and limited operating area associated with the 

### r:r·aircraft to 

### be utilized 

### by the Applicant, an exemption from Part 21 Subpart H

.,- ."".-.,_,.,,•. <J,**,j.;lif"zfiyffi~@ts t~~** **~~qulr.~ments** 

### ot an equivaltnt level of safety under Part 11 and**~u;H~,<,zteitn ;''i~ec1iOIJ** **~,S~,of** the"Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f))**.~ ~~nd**  

### Seet1Qn33s of the ·Reform Act both authorize the FAA to 

### exempt aircraft from

. ·**-~ 'r~** **·•~""·n** 

### "'.the req'uirement ,for an ain.vorthlness certificate, upon consideration of the size. weight, speed, operational capability. and proximity to airports and 

### populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate 'In the res1ricted environment and under the conditions proposed will be at least as safe, or 

### safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 551bs. fully 

### loaded. carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuelsJ and operates exclusively 

### within asecured and designated 

### area. Unlike other civil aircraft, operations under_this exemption 

### will be tightly controlled and monitored by.both the operator and under the requirements and in compliance with local public safety requirements. These safety 

### enhancements provide a greater degree of safety to the pubtic and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.A. Part 

### 21, Subpart H. 

### Lastly, application ofthese same criteria demonstrates that there is no credible threat 1o national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid 

### fuels, and tnability 

### to carry asubstantial external load.

14 

### C.F.R. § 45.23 (b). Marking of the Aircraft The**reg~lation** requires:**~hen** marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft or experimental or provisionally certificated aircraft. the opera1or must also display on that aircraft near each entrance to the cabin, cockpit, 

### or pilot station, in tatters not less than 2 inches nor more than 6 inches high, the words "limitedr ••restricted! 111ight sport/' "experimental/' or "provisional! as applicable.

14

### C.F.R. § 

### 45.23 (b). Marking 

### of the Aircraft The regulation requires: When

..., 'Y'· marks include only**~he** Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft or experimental or provisionally 

### certificated aircraft, the 

### operator must also display on that aircraft**:~"'7··· 11f:i~r,.,~,Oh.~oJranp~** -to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches 

### high, the 'NOrds 111imitedf 11restricted1 111igh1**sp()rtf 11** **S}Cp~rlrnentalf** or "provisional/as applicable. Even though the UAS will**haveJl~~:(~rthiness** certificate, 

### an**~xemption** may be needed as the UAS will have**~ ie.nJr~nce**  to the cabin, -cockpit or pilot station on which the word**"Experirm~nt,aP•,**can 

### be, placed. 

### Givenjhe size ofthe UAS, two inch lettering.will be impossible. The word

..Experimental

.. will be placed on the fuselage in,., Jan 12 2016 '''12:29PM Centrat Home Inspections 9895448007 page 8**·;~;i:,~®.mpliance** with §45.29·(f). US Department of Transportation February 20,2015 ·.r;r"fh$ equivalent level of safety will be provided by having the UAS marked on its ;;)i·ii\Jt. >:;**·~>~~Ju$~1~ge** as**r~qui,r~d** by;§45.29 (f) \Vhere the pilot, observer and others working



### ·**~**

### ...**~A:~i:.Pu~·~~;:W~thJhe UA~·wiU**  

### lee the identification 

### of the UAS 

### as "Experimental." 14C.F.A. § .'fif.113 

### (a)**~lld** (b The 

### pro"posed UAS operations may 

### achieve an equivalent level
·l!•tr·**·~1f~'~.)** :Of safety as 

### ,achieved by current 

### Regulations because the applicant's UAS do not carry any pilots or passengers nor property. The risks attendant to the It is believed that the operation and limitations set forth in the FOM will equate to the sate operation of the UAS.

14 C.F.R. §91.7{a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. 

### As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size of the aircraft for maintenance and use ofsafety checktists prior to each flight, an 

### equivalent level of safety will be 

### provided. 14 C.F.R. 

### § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) {2) provides: No person may operate a U.S. registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manuat is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manuat materiat markings, and placards. or any combination thereof. The UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, no1 only because there is no pilot on board, but 

### because there is no room or capacity to 

### carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it.
14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take cenain actions before flight to insure the safety of flight. As**F:~A** _approved rotorcraft flight manuals witl not be provided for the aircraft an exemption will be needed. The PIC will take.all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 

### C. F.A. §91.109: Flight Instruction. Section 91.103 provides that no person**maY.PP,~r~t~;~~**

### ,c;ivil aircraft (except a manned free baltoon) that is being used for flight instruction unless that aircraft has fully 1unctioning dual controls. UAS and remotely,**pl~ot~d** aircraft, bytheir design do not have fully functional dual controls. 

### Flight qo_ntu>l. is accomplished through the use of a control box that**communic$t~s** 

### :With the aircraft via radio 

### communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The**equi~alent** tevet ofJan 12 

# 26:**~r! ')>~':ft1;~~&** **.'~"""~~·** Centrat Home

### Inj~~g~dns 9895448007 ,;**-;;;~j>,** ,,,· page 9

..,.,."••**~,,;~;** tJ('>··**,:-~;safety** is provided by the fact that neither a pilot nor passengers will be carried in

· · the aircraft and by the size and speed of the aircraft

.

.. :1.4**C.F R:.~§91.119::Minimum**  

### Safe Altitudes. Section 91.119 establishes safe 

### ·,.:·altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be

operated at less than 

### the minimums prescribed, 

### provided the 

### person operating the helicopter complies with any route or altitudes prescribed for helicopters 

### by the FAA. As this exemption Is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption 

### may be 

### needed to aflow such operations. As set forth herein, the 

### UAS will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to 

### survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however beoperated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre obtained 

### consent. The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where 

### it is operated. No flight will be taken without the permission of the property owner or local officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to 

### flight operations with aircraft or rotorcraft weighting far more than the maxi mum SSibs. Proposed herein and the lack of flammable 

### fuel, any risk associated with these operations is tar less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low altitude operations ofthe UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F. R. §91.121 Altimeter Settings. This regulation requires each person

. pperating an aircraft to maintain cruising altitude 

### by reference to an altimeterthat

is set "

...

### tothe elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read 

### out, an U.S. exemption may be needed. An**equival~nt** level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the attitude of the launch site shown on the GPS altitude indicator before flight.
14

### C.FJ=t~.§**9~1'·:~-151** (a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (atprohibits an individual from beginning "a flight in an airplane under**VFR.®,nijllJQ.r:l~unless** (considering 

### wind and forecast weather conditions) there is**enougtiihl~ttp** fly to the first point

## ·ol intended landing, 

### and. assuming normal**cruis~~g~p.~~(t~:{1)** Du_r.ing the day. 

### tcffly· after that for at least 30 minutes; or (2) At night, to 

### ·ny after that for at least 45 minutes. 11 The applicant believes that anJan 12 page 10

<·'"·.•**~>exemption** from 14 

### CFR §91.151 

### (a) falls within the 

### scope of prior 

### exemptions

.

.

### :'qp~r.@,~ng the l)AS inatightly 

### controlled area where only people 

### and property

_..,...,u"''·'·'··.·**"'t;,:;i~~~.f1~~;d**

### ..**~~·OWIJ~f:~:'orotticj~ll~Pr~ntatives** 

### who have 

### signed waivers will 

### be 

### allowed does

, t.:<;**·~~: ~,~~}** **~~"t;OQ(~figenderJt:te typ~,** 

### of risks .tha1 Section 91.151 (a) 

### was intended to 

### alleviate

· · ·. ·.given,the siz• and 

### speed ofthe 

### small UAS. The applicant believes that 

### .an

··h··,,,,,H,equivalent level of safety can be achieved by limiting flights to 30 minutes or 

### 25o/o of battery power· whichever happens first. This 

### restriction would be more than adequate to return the 

### UAS to 

### its planned 

### landing zone from anywhere in its limited 

### operating area.

14 C.F.R. §91.203 (a) and {b): Carrying Civil Aircraft Certification and 

### Registration The regulation provides In 

### pertinent part: (a) Except as provided 

### in§ 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate acivil aircraft 

### unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight authorization issued 

### under §91.715 is displayed 

### at the cabin or cockpit entrance so that it Is legible to passengers or crew. The UAS fully loaded weighs well underthe proposed 551 b limit and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level of safety will be achieved 

### by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them. tothe extent they are applicable to the UAS.

14 C. F.A. §91.405 (a); 407 (a) (1 ); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These regulations require that an aircraft operator or owner 

### "shan have that aircraft inspected as prescribed in subpart E of this part and shall between required**inspections~** 

### except as provided in paragraph (c) of this 

### section,

. have discrepancies repaired as prescribed in part43 of this chapter

...," and**~,others.sh~U** inspect pr maintain the aircraft in compliance with Part 43. Given that

, .. these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished bythe operator pursuant to the flight manual and operating handbook. An equivalent level of safety wiU be achieved because the 

### UAS is very limited in size ··and will 

### carry a small payload and 

### operate only in restricted areas for a limited

period oftime. If mechanical issues arise the UAS 

### can land 

### immediately and will**~,,>~'** .. ·;'"""·**:,,,~;~.~**•.•K«**·"'')';·'";~lbe op~~~Jjng**  

### f!9.r!l rtQ.nigher than 400 feet AGL. The operator will ensure 1hat the

· · · ·**·~** UAS

## is in working order prior to initiating flight, perform required maintenance, .and keep a I()Q,Qtany maintenance performed. Moreover, the operator Is the

.pen:;on**mq§t!.@mili~r** with the aircraft**~ndbest** suited to maintain the 

### aircraft in 

### an airworthy

## CQflQitJ9n**~o** provide the equivalent level of safety. An equivalent level of ,safety will**~,La~ieved** because maintenance and Inspections will be performed



## .,_,....,., in accordancEf'With the 

### UAS Manufacturer's User Manual. As provided in theJan 12 2016**,·,~~i~)?~~1):·,:'_:,** Centrat Home**Inspec~qns:~** '9895448007

1.'**:~}** :.**-~,.** - page 11



### :FO..,t and a fink on last 

### P.age, the operator 

### Will ensure 

### thatthe 

### UAS is in working

,- o_rder prior to initiating flight and perform required maintenance needed.

Addttlonallnformatlon.

The applicant Michael Raines believes this exemption request and associated safety considerations adequately satisfy criteria provtded in Section 333 ofthe Reform Act of 2012, providing sufficient justification for the granting of commercial operations of the applicant's UAS. I also feel its in 

### the public's interest on granting the exemption, as we can educate them at the same time. And all the positive sides ofthe newtechnology and the level of safety.

The applicant Michael Raines requests your. respective approval of this Section 333 exemption petition request.

Thank you for your attention in this matter. Please notify Michael Raines of your actions. and or approvals. Thank you, for your interest in this request.

Michael Raines