John A. Van Houten III 

Thunderbird UAS 

7062 Jacks Creek LN SE 

Owens Cross Roads, Alabama 

35763 

10/5/2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Subject: Exemption Request Section 333 of the FAA Reform Act of the Federal 

Aviation Regulations from: 

14 C.F.R. 21 subpart H 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113 (a) & (b) 

14 C.F.R. 61.133 (a) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b)(2) 

14 C.F.R 91.103 

14 C.F.R. 91.109(a) 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R 91.145(b) 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) and (b) 

14 C.F.R. 91.319 (a)(]) 

14 C.F.R. 91.405 (a) 

14 C.F.R. 91.407 (a)(l) 

14 C.F.R. 91.409 (a)(2) 

14 C.F.R. 91.417 (a) & (b) 

Dear Sir or Madam, 

I, John A. Van Houten III, am writing pursuant to the FAA Modernization and Reform Act of 

2012 and the procedures contained within 14 C.F .R. 11, to request that I as an owner and operator of 

Unmanned Aircraft System(s) (UAS), apply for exemption from the Federal Aviation Regulations 

("FARs") listed below, so that I may operate commercially in airspace regulated by the Federal Aviation 

Administration ("FAA"). 

As described herein I, John A. Van Houten III, a Department of the Army Civilian General Engineer, 

under the Program Executive Office, Aviation, Aviation Systems, Air Traffic Control (SF AE-A V-ASA TC) am an experienced RC multi-copter enthusiast, in the state of Alabama and intend to use the 

following UAS, as described herein, equipped with camera(s) and sensors commercially in the following 

manner: 
• Aerial Photography and/ or video for public and /or private use including, real estate, 

architecture, land surveying, engineering and other related professional activities. 

• Aerial video and/or photography for public and/or private use including television, 

public/sporting events, cinematography, and news gathering. 

• Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority. 

• Aerial video/photography or providing live video feed to assist with search and rescue operations 

in the cases of an emergency or natural disaster only when the local authorities or government 

has requested it 

• The ability of offer training to persons individually or belonging to both private and/ or public 

organizations that have interests in the use and application of a UAS for the purpose of the safe 

operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for 

the protection of the persons and property and safe Airspace Usage. 

As described fully below, the requested exemption would permit the operation of a UAS under controlled 

conditions in the NAS that would be A) limited B) controlled C) predetermined and D) will provide 

safety enhancements to the already safe operations in the industry presently using conventional aircraft. 

Approval of this exemption would thereby enhance safety and fulfill 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." 

I. Contact Information: 

John A. Van Houten Ill 

7062 Jacks Creek Ln SE 

Owens Cross Roads, AL 

35763 

J3systems@gmail.com 

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which John 

A. Van Houten Ill Requests Exemption are: 

14 C.F.R. 21 subpart H 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113 (a) & (b) 

14 C.F.R. 61.133 (a) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b)(2) 

14 C.F.R 91.103 

14 C.F.R. 91.109(a) 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R 91.145(b) 

14 C.F.R. 91.15 I(a) 

14 C.F.R. 91.203(a) and (b) 

14 C.F.R. 91.319 (a)( 1) 

14 C.F.R. 91.405 (a) 
14 C.F.R. 91.407 (a)(l) 

14 C.F.R. 91.409 (a)(2) 

14 C.F.R. 91.417 (a) & (b) 

III. Equipment of Operation: 

John A. Van Houten III will operate the following UAS with specifications: 

UASMODEL DJI INSPIRE I, MODEL T600 

AIRCRAFT WEIGHT (BATTERY 2935 g 6.471lbs 

INCLUDED) 

HOVERING ACCURACY (GPS MODE) Vertical: 0.5 m 

Horizontal: 2.5 m 

MAX ANGULAR VELOCITY Pitch: 300°/s 

Yaw: 150°/s 

MAX SPEED 22 mis (A TTI mode, no wind) or 49mph 

CRUISING SPEED I lm/s or 25 mph 

AIRCRAFT DIMENSIONS 438mm x 451mm x 301mm or 17.24 inch x 17.75 inch 

x 11.85 inch. 

PROPULSION 4 motors model DJI 3510 

FUEL SOURCE 6-Cell 4500mAh or 5700mAh Lithium Polymer battery 

PROPELLERS Four of Model OJI 1345 

FLIGHT CONTROL SYSTEM Cl remote controller 2.400GHz-2.483GHz 

VIDEO FEED Live operating frequency of 5.728GHz- 5.850GHz 

MISSION SOFTWARE I FLIGHT DJ! Pilot App 

SOFTWARE 

UASMODEL 30 ROBOTICS SOLO 

AIRCRAFT WEIGHT (BATTERY 3.3 lbs. (1.5 kg) 

INCLUDED) 

MAX DESCEND RATE 5.5 mph (2.5 m/s) 

MAX CLIMB RA TE 11 mph (5.0 m/s) 

MAX SPEED 55 mph {25.5 m/s) 

CRUISING SPEED 5.7 mph (2.5 m/s) 
AIRCRAFT DIMENSIONS Height: 10 in. (25 cm) 

Motor-to-motor dimension: 18 in. (26 cm) 

PROPULSION 880 KV motors, two clockwise rotating motors 

and 

two counterclockwise rotating motors 

FUEL SOURCE Lithium polymer, 5200 mAh, 14.8 Vdc 

PROPELLERS 10 in. x 4.5 in. (25 cm x 11.4 cm) 

FLIGHT CONTROL SYSTEM Autopilot: 3DR Pixhawk 2 

Flight code: ArduPilot Copter 

Control: 3DR Solo Controller 

VIDEO FEED Wireless communication: 3DR Link 1.0 

Frequency: 2.4 GHz 

MISSION SOFTWARE I FLIGHT Solo is a quad-rotor aerial vehicle powered by the 

SOFTWARE 3DR Pixhawk 2 autopilot system and APM:Copter 

flight control software. Solo communicates with 

the controller and Solo app over the 3DR Link 

secure Wi·Fi connection. 

UASMODEL SPEDIX 650 CARBON FIBER QUAD COPTER 

AIRCRAFT WEIGHT (BATTERY 2635 g I 5.8 lbs 

INCLUDED) 

HOVERING ACCURACY (GPS MODE) Vertical: 0.5 m 

Horizontal: 2.5 m 

MAX ANGULAR VELOCITY Pitch: 300°/s 

Yaw: 150°/s 

MAX SPEED 10.79 mis (A TT! mode, no wind) or 24mph 

CRUISING SPEED 5m/s or 12 mph 

AIRCRAFT DIMENSIONS 650mm x I 80mm x 220mm or 25.59 inch x 7 .08 inch x 

8.66 inch. 

PROPULSION 4 motors model 4108S-600 

FUEL SOURCE 6-Cell 8,000mAh or 1 O,OOOmAh Lithium Polymer 

battery 

PROPELLERS Four Carbon Fiber 13.5x5 

FLIGHT CONTROL SYSTEM TARANIS 9XD 2.400GHz-2.483GHz, APM 2.6+ 

VIDEO FEED Live operating frequency of 5.728GHz - 5.850GHz 

MISSION SOFTWARE I FLIGHT APM Mission Planner 

SOFTWARE 
III. The Extent of relief John A. Van Houten III seeks and the Reason He Seeks Such 

Relief: 

I, John A. Van Houten III, submit this application in accordance with the Refonn Act, 112 P.L. 95 

§§ 331- 334, seeking relief from any currently applicable FARs operating to prevent me from 

contemplated commercial cinematic, academic and other flight operations within the national airspace 

system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems 

into our national airspace system as it is in the public's interest to do so. 

My Ultra-light weight UAS meets the definition of"small unmanned aircraft" as defined in Section 331 

and therefore the integration of my ultra-light weight UAS is expressly contemplated by the Refonn Act. 

I would like to operate my ultra-light weight UAS prior to the time period by which the Refonn Act 

requires the FAA to promulgate rules governing such craft. The Refonn Act guides the Secretary in 

detennining the types of UAS's that may operate safely in our national airspace system. Considerations 

include: The weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operated 

near airports or heavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P .L. 

95 § 333 (a). Each of these items reflect in favor of an exemption for me, John A. Van Houten III. 

My UAS fleet, utilizes four (4) counter-rotating propellers for balance, control and stability. My UAS are 

equipped with GPS and auto return safety technology. Each UAS, Weighing less than five (7) pounds (far 

below the maximum 55 pound limit); including camera with gimbal. I, John A. Van Houten III, consider 

safety as foremost with each flight. My UAS is designed to hover in place via GPS and operate in less 

than a 20 knot wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 10 

KPH. Built in safety systems include a GPS mode that allows my UAS to hover in place when radio 

controls are released. If pilot communication is lost my UAS is designed slowly return at safe altitude to 

point of takeoff. I do not operate my UAS near airports, Hospitals nor Police heliports, and do not operate 

near areas where the general public is within fifty to one hundred (50-100) yards depending on location, 

conditions and weather. 

Utilizing battery power rather than combustible fuels, flights generally last between three (3) to 

15 minutes ( 15) minutes, with an altitude under one hundred fifty ( I 50) feet AGL. I, John A. Van Houten, 

will operate my UAS with fully charged batteries and will ensure there is enough power to return to 

the original starting destination with 2 minutes reserve on a battery as tested lasting 22 minutes. I also 

conduct a specific UAS technical journey log and maintenance regimen in which all flight hours, 

conditions, and remarks are recorded and addressed after each flight. 

IV. How John Van Houten's Request Will Benefit the Public As A Whole: 

Aerial videography is traditionally achieved using small single engine aircraft equipped with large 

cameras. In order to achieve a clear picture, the pilot is tasked with performing ground reference 

maneuvers at around 1 OOOft AGL. By utilizing a UAS for this function, pilots reduce the risk of damages 

to persons or property in the event of an in flight emergency. Congress has already proclaimed that it is in 

the public's interest to integrate commercially flown UAS's into the national airspace system, hence the 

passing of the Reform Act. 

V. Reasons Why John Van Houten's Exemption Will Not Adversely Affect Safety 

Or How The Exemption Will Provide a Level of Safety At Least Equal To 

Existing Rule: 

I, John Van Houten, believe that by allowing this exemption, it will create the beginning framework for 

other UAS enthusiasts to operate their aircraft in a much more regulated and safer environment. 

By creating laws and regulations for commercial UAS use, it will legitimize the industry and create a 

clear path for safer aviation. Additionally, my UAS is equipped with fail safe programming that allows it 
to fly and return safely if the pilot were to become incapacitated, or the connection was lost. Furthermore 

my UAS systems are enabled with automatic Geo-fencing to assist in safe operation within the NAS. 

The operation limitations proposed for an equivalent or higher level of safety because operations will 

further enhance the safety of the persons and/or property using conventional aircraft. 

These limitations and conditions to which the applicant agrees to adhere to when conducting commercial 

operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 

• The UAS will weigh less than 55 lbs. 

• The UAS will have a maximum operating speed ofno more than SOmph. 

• Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer 

(VO). 

• Maximum flight time for each operational flight will be 20 minutes. Flights will be terminated at 30% 

battery power reserve or 20 minutes of flight time whichever occurs first. 

• 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 platform from which filming is planned. Typical Operations will 

occur within 150 AGL. 

• Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may 

include but not limited to a Camera Operator. 

• The UAS pilot will be a designated Pilot in Command (PIC) and have a minimum of 50 hours of flight 

time with the UAS. 

• A briefing will be performed regarding the planned UAS operations prior to each day's flight consisting 

of all the days' production activities. 

• All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. In addition, an 

anemometer will be used prior to flight to measure wind speed, and atmospheric pressure in current flight 

location. 

• The flights will occur no closer than a 5 mile radius of the geographic center/ Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport. 

• If operations will be within a 5 mile radius of the geographic center/ Airport Reference Point (ARP) of a 

tower controlled or uncontrolled airport the respective airports will be contacted advising them of the 

estimated flight time, flight duration, elevation of flight and other pertinent information. 

• The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the requested 

exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but 

no less than 48 hours from planned operation. 

• The operator will obtain verbal/written consent of all persons involved with the planned operation and 

ensure that only consenting persons will be allowed within I 00 feet of the flight operation, and the radius 

may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the 

FOM. With the advanced permission of the FSDO, operations at closer range may be approved. 

• 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. 

• The PIC and VO will be able to communicate by voice, radio, and/or text at all times. 

• Written and/or verbal permission and permits will be obtained from territorial, state, county or city 

jurisdictions, including law enforcement, fire or other appropriate governmental agencies. 

• If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the 

capability to return to a pre-determined location within a designated location and land autonomously. 

• The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies. 

VI. A Summary The FAA May Publish in the Federal Register: 

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The 
Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary airworthiness certificates in relation to FAR § 9 l .203(a)( I). The size, weight and enclosed 

operational area of my, John Van Houten's UAS permits exemption from Part 21 because my VAS meets 

(and exceeds) 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 U.S.C. 

§ 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt 

UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. The UAS to be operated 

hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive 

materials or flammable liquid fuels, and operates exclusively within a secured 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 public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart 

H. Lastly, application of these same criteria demonstrates that there is no credible threat to national 

security posed by the VAS, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and inability to carry a substantial external load. My, John Van 

Houten's current and projected UAS's meet or exceed each of the elements. 

14 C.F.R. 91.7(a) This 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 exist for determining airworthiness. 

Given the size of the aircraft for maintenance and use of safety check lists prior to each flight an 

equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots 

or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of 

safety will be achieved by maintaining safety/flight manual delineating areas of where safety can be 

defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.103: Preflight Action. 

This regulation requires each pilot in command to take certain actions before flight to insure the safety of 

flight. As FAA approved rotorcraft flight manuals will 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. Before the aircraft takes flight, a home GPS 

location will be set for any reason the aircraft becomes disoriented in flight, and return safely to home. 

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction 

These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that 

is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS's are 

remotely piloted aircraft and by design and do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates 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. See Exemption Nos. 

5778K & 9862A. Additionally, in the absence of previous training requirements, John Van Houten is a 

seasoned UAS pilot having flown hobby grade and professional grade UAS's for a number of years 

without incident. 
14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS 

Utilizes electronic global positioning systems with a barometric sensor to determine altitude. In the 

absence of GPS signal, barometric pressure is used and calculated at point of UAS arming. 

14 C.F.R §91.145(b) Management of aircraft operations in the vicinity of aerial 

Demonstrations and major sporting events 

CFR 91.145 states: 

(b) In deciding whether a temporary flight restriction is necessary for an aerial demonstration or 

major sporting event not listed in paragraph (a) of this section, the FAA considers the following 

factors: 

( 1) Area where the event will be held. 

(2) Effect flight restrictions will have on known aircraft operations. 

(3) Any existing ATC airspace traffic management restrictions. 

( 4) Estimated duration of the event. 

(5) Degree of public interest. 

(6) Number of spectators. 

(7) Provisions for spectator safety. 

(8) Number and types of participating aircraft. 

(9) Use of mixed high and low performance aircraft. 

( 10) Impact on non-participating aircraft. 

(11) Weather minimums. 

( 12) Emergency procedures that will be in effect. 

If John Van Houten intends to use the UAS to cover sporting events from outside the activity, 

coordination will be completed by contacting the FSDO prior to the event to ascertain the presence of any 

other unmanned activities. Flight activity will be conducted based on safety and with particular attention 

to the avoidance of overflight of large concentrations of people. However, specific relief from this 

regulation is still necessary to ensure compliance with F ARs. 

14 C.F.R. § 91.203 (a) and (b) Carrying 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 a civil aircraft unless the airworthiness certificate required by paragraph (a) of 

this 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 no more than 55 lbs. 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, to the extent they are applicable to 

the UAS. 

14 C.F.R. § 45.23: Marking of the Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. 

My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on 

which to mark certain words or phrases. Further, two-inch lettering is difficult to place on such small 

aircraft with dimensions smaller that minimal lettering requirement. Regardless, each UAS shall be 

marked in the largest possible lettering by placing the word "EXPERIMENT AL" on its fuselage as 
required by 14 C.F .R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UA V will 

see the markings. The FAA has previously issued exemptions to this regulation through Exemptions 

Nos. 8738, 10167, 10167A and I 0700. 

14 C.F.R. § 61.113; 14 C.F.R. § 61.133: Private Pilot Privileges and Limitations; PIC; Commercial 

Pilot Privileges and Limitations: 

Pursuant to 14 C.F .R. §§ 61.113 (a) & (b ), private pilots are limited to noncommercial operations. Section 

61. l 33(a) requires an individual with a commercial pilot's license to be pilot in command of an aircraft 

for compensation or hire. I shall achieve an equivalent level of safety as achieved by current regulations 

because my UAS does not carry any pilots or passengers. The risks attended to the operation of my VAS 

is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus 

allowing me to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) 

& (b) and 14 C.F .R §61.133 (a) Additionally, the PIC will have a minimum of 50 hours flight time on the 

VAS in operation. 

14 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 VAS 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 allow such operations. As set forth herein, the VAS will never operate at higher than 400 

AGL with the exception that in circumstances where the VAS 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 be operated in a restricted area with security perimeter, where 

buildings and people will not be exposed to operations without their pre-obtained consent. It also may be 

operated over open water close to shore keeping a distance of 500 feet as indicated in Section 91.119 ( c ). 

The equivalent level of safety will be achieved given the size, weight, 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 of the advance notice to the property owner and participants in the filming activity, all 

affected individuals will be aware of the planned flight operations. Compared to flight operations with 

aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of 

flammable fuel, any risk associated with these operations is far less than those presently presented with 

conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the VAS 

will ensure separation between these UAS operations and the operations of conventional aircraft that must 

comply with Section 91. 1 19. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

This regulation prohibits an individual from beginning "a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed -(1) During the day, to fly after that for at least 30 

minutes; or (2) At night, to fly after that for at least 45 minutes." I will be operating a VAS utilizing 

battery power rather than combustible fuels, flights generally last between three (3) to fifteen ( 15) 

minutes, with an altitude under one hundred fifty (150) feet AGL. I will operate my VAS with a fully 

charged battery and will ensure there is enough power to return to the original starting destination with 2 

minutes reserve on a battery as tested lasting 22 minutes. 

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

Inspections. 

These regulations require that an aircraft operator or owner "shall 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 part 43 of this chapter ... ," and 

others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight 

manual and operating handbook. An equivalent level of safety will 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 of 

time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 

400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform 

required maintenance, and keep a log of any maintenance performed. Most importantly, the operator is 

the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition 

to provide the equivalent level of safety. An equivalent level of safety will be achieved because 

maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. 

As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating 

flight and perform required maintenance needed. 

In summary John A. Van Houten III seeks an exemption from the following 

Regulations: 

14 C.F.R. 21 subpart H 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113 (a) & (b) 

14 C.F.R. 61.133 (a) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b)(2) 

14C.F.R 91.103 

14 C.F.R. 91.109(a) 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R 91.145(b) 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) and (b) 

14 C.F.R. 91.319 (a)(I) 

14 C.F.R. 91.405 (a) 

14 C.F.R. 91.407 (a)(I) 

14 C.F.R. 91.409 (a)(2) 

14 C.F.R. 91.417 (a) & (b) 

to commercially operate my UAS. I, John A. Van Houten Ill, have written pursuant to the FAA 

Modernization and Reform Act of2012 and the procedures contained within 14 C.F.R. 11, to request that 

I as an owner and operator of Unmanned Aircraft System(s) (UAS), apply for and be granted exemption 

from the Federal Aviation Regulations ("FARs") listed above, so that I may operate commercially in 

airspace regulated by the Federal Aviation Administration ("FAA"). 

As described herein I, John A. Van Houten III, a Department of the Army Civilian General Engineer, 

under the Program Executive Office, Aviation, Aviation Systems, Air Traffic Control (SFAE-AV-ASA TC) am an experienced RC multi-copter enthusiast, in the state of Alabama and intend to use the my 

UAS, as described herein, equipped with camera(s) and sensors safely and commercially. I have been 

involved in building and the piloting of remote controlled aircraft for over 5 years. I have logged more 

than 204 hours on RC helicopters, planes, and UGS. I have flown over 700 sorties in my youth with 

Microsoft Flight Simulator. As a Government Civilian under PEO A VN, Air Traffic Control with over 

16 years of Airspace De-confliction and Airspace Management technical experience, I have a great 
appreciation for, and understanding of the capabilities and safety concerns involved in the use of UAS 

and the evolving associated technologies and how through proper application and use, these platfonns can 

be an asset to the community. I intend to contribute to the benefit of the community as a whole, by 

educating future pilots in a safe environment and via the application of safe flight and practices. The 

satisfaction of criteria provided in Section 333 of the Reform Act of2012 provides a level of safety that 

should be satisfactory to the FAA and general public. In view of the beneficial advantages to public 

safety, I respectfully submit my Section 333 exemption request for allowing the commercial operation of 

the applicant's UAS. 

Thunderbird UAS 

Attn: John Van Houten 

7062 Jacks Creek LN SE 

Owens Cross Roads, AL 35763 

J3systems@gmai I .com