John A. Van Houten III Thunderbird UAS 7062 Jacks Creek LN SE Owens Cross Roads, Alabama 35763
10/5/2015
U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200NewJersey Ave., SE Washington, DC 20590

Subject: Exemption Request Section 333 ofthe FAA Reform Act ofthe 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 pursuantto 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 ofthe Army Civilian General Engineer, underthe Program Executive Office, Aviation, Aviation Systems, AirTraffic Control (SFAE-AV-ASATC) am an experienced RC multi-copter enthusiast, in the state ofAlabama and intend to use the following UAS, asdescribed herein, equipped with camera(s) and sensors commercially in the following
manner:• Aerial Photography and/ orvideo for public and /orprivate use including, real estate, architecture, land surveying, engineering and other related professional activities.

• Aerial video and/orphotography for public and/orprivate use including television, public/sporting events, cinematography, and news gathering.

• Aerial inspection/photography ofresidential/commercial structures under contract with the
owners orlocal government authority.

• Aerial video/photography orproviding live video feed to assist with search and rescue operations in the cases ofan emergency ornatural disasteronly when the local authorities orgovernment has requested it

• The ability ofoffertraining to persons individually orbelongingto both private and/ orpublic organizationsthat have interests in the use and application ofa UAS for the purpose ofthe safe operation ofa UAS to enhance the safety ofthe National Airspace System (NAS) as well as for the protection ofthe persons and property and safe Airspace Usage.
As described fully below, the requested exemption would permit the operation ofa 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 ofthis exemption would thereby enhance safety and fulfill the SecretaryofTransportation's (the FAA Administrator's) responsibilities to"

.... establish requirements for the safe operation ofsuch aircraft systems in the national airspace system."


### I. ContactInformation:
John A. Van Houten Ill 7062 Jacks Creek Ln SE Owens Cross Roads, AL 35763 J3systems@gmail.com


### II. The Specific Sections ofTitle 14 ofthe Code ofFederalRegulations From WhichJohn A. Van Houten IllRequests 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. 91.15I(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 ofOperation:
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 (ATTI mode, no wind) or49mph


### CRUISING SPEED Ilm/s or25 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 or5700mAh Lithium Polymer battery 

### PROPELLERS Four ofModel OJI 1345


### FLIGHTCONTROL SYSTEM Cl remote controller 2.400GHz-2.483GHz 

### VIDEO FEED Live operating frequency of5.728GHz- 5.850GHz


### MISSION SOFTWARE I 

### FLIGHT DJ! Pilot App 

### SOFTWARE

UASMODEL 30ROBOTICS SOLO 

### AIRCRAFTWEIGHT (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: 10in. (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 11.4cm) 

### FLIGHTCONTROL 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 aquad-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 overthe 3DR Link secure Wi·Fi connection.


### UASMODEL SPEDIX650 CARBON FIBERQUAD 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 (ATT! mode, no wind) or 24mph


### CRUISING SPEED 5m/s or 12 mph


### AIRCRAFT DIMENSIONS 650mm x I80mm x 220mmor25.59 inch x 7.08 inch x 8.66 inch. 

### PROPULSION 4 motors model 4108S-600


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

### PROPELLERS FourCarbon Fiber 13.5x5


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


### VIDEO FEED Live operating frequency of5.728GHz

- 5.850GHz


### MISSION SOFTWARE I 

### FLIGHT APM Mission Planner 

### SOFTWARE

### III.TheExtentofreliefJohnA. Van HoutenIII seeks and the Reason He Seeks Such Relief: I, John 

### A. Van Houten III, submitthis application in accordance with the Refonn Act, 112 P.L. 95 

### §§ 331- 334, seeking relieffrom any currently applicable FARs operatingto 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 ofcivil unmanned aircraft systems into ournational 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 thereforethe integration ofmy ultra-light weight UAS is expressly contemplated by the Refonn Act. I would like to operate my ultra-light weight UAS priorto thetime period by which the Refonn Act requiresthe FAA to promulgate rules governing such craft. The Refonn Act guidesthe Secretary in detennining thetypes ofUAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities ofthe UAS's; Whetherthe UAS will be operated
near airports orheavily populated areas; and, Whetherthe UAS will be operated by line ofsight. 112 P.L. 95 

### § 333 (a). Each ofthese items reflect in favor ofan 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 camerawith 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 offinancial 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. Ifpilot communication is lost my UAS is designed slowly return at safe altitudeto point oftakeoff. 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 ( I50) feet AGL. I, John A. Van Houten, will operate my UAS with fully charged batteries and will ensurethere 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 technicaljourney log and maintenance regimen in which all flight hours, conditions, and remarks are recorded and addressed after each flight.



### IV. HowJohn Van Houten'sRequestWill BenefitthePublic As A Whole:
Aerial videography is traditionally achieved using small single engine aircraftequipped with large
cameras. In orderto achieve a clearpicture, 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 ofdamages to persons orproperty in the event ofan inflight 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 passingofthe Reform Act.



### V. Reasons Why John Van Houten's Exemption Will NotAdversely Affect Safety OrHowThe Exemption Will Provide a Level ofSafety AtLeast Equal To Existing Rule:
I, John Van Houten, believe that by allowingthisexemption, it will create the beginning framework for other UAS enthusiasts to operate their aircraft in a much more regulated and saferenvironment. 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 itto fly and return safely ifthe pilot were to become incapacitated, orthe connection was lost. Furthermore my UAS systems are enabled with automatic Geo-fencingto assist in safe operation within the NAS.
The operation limitations proposed for an equivalent or higher level ofsafety because operations will further enhance the safety ofthe persons and/or property using conventional aircraft.
These limitations and conditions to which the applicant agrees to adheretowhen conducting commercial operations under the FAA issued exemption as set forth in the FlightOperations Manual (FOM) include:
• The UAS will weigh less than 55 lbs.
• The UAS will have a maximum operating speed ofnomore than SOmph.
• Flights will be operated within line ofsightofthe 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 powerreserve or 20 minutes offlight time whichever occurs first.
• Flights will be operated at an altitude ofno 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 ofthe UAS Pilot, the Visual Observer (VO) and may include but not limited to a Camera Operator.
• The UAS pilotwill bea designated Pilot in Command (PIC) and have a minimum of50 hours offlight time with the UAS. • A briefingwill be performed regarding the planned UAS operations priorto each day's flight consisting ofall the days' production activities.
• All flights will occurunder Visual Flight Rules Meteorological Conditions (VMC) only. In addition, an anemometerwill be used prior to flight to measure wind speed, and atmospheric pressure in current flight location.
• Theflights will occur no closerthan a 5 mile radius ofthe geographic center/ Airport Reference Point (ARP) ofa tower controlled oruncontrolled airport.
• Ifoperationswill be within a 5 mile radius ofthe geographic center/ Airport Reference Point (ARP) ofa towercontrolled oruncontrolled airportthe respective airports will be contacted advisingthem ofthe estimated flight time, flight duration, elevation offlight and otherpertinent information.
• The operatorwill file FAA Form 7711-1, or its equivalent, as modified in light ofthe 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 operatorwill obtain verbal/written consent ofall persons involved with the planned operation and
ensure that only consenting persons will be allowed within I00 feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level ofsafety determination, asrequired under the FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved.
• The PIC and VO will have been trained in operation ofUAS and receive up-to-date information for the particular UAS to be operated.
• The PIC and VO will be able tocommunicate by voice, radio, and/ortext at all times.
• Written and/or verbal permission and permits will be obtained from territorial, state, county orcity jurisdictions, including law enforcement, fire or other appropriate governmental agencies. • Ifthe 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 caseofunpredicted obstacles, weather, or emergencies.


### VI. A Summary The FAA May Publishin the Federal Register:
14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and TheLike.

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 ofmy, John Van Houten's UAS permits exemption from Part 21 because my 

### VAS meets (and exceeds) an equivalent level ofsafety pursuantto Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement underboth the Act (49 U.S.C. 

### § 44701 (f)) and Section 333 ofthe Reform Act. Both pieces oflegislation permitthe FAA to exempt UAS's from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximityto areas such as airports and dense populations. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot norpassenger, carries no explosive materialsorflammable 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 operatorand under the requirements and in compliance with local public safety requirements. These safety enhancements provide a greaterdegree ofsafetyto the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part21, Subpart H. Lastly, application ofthese samecriteriademonstratesthat there is no credible threat to national security posed by the 

### VAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials orflammable liquid fuels, and inability to carry a substantial external load. My, John Van Houten's current and projected UAS's meet orexceed each ofthe 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. Asthere 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 ofthe aircraft for maintenance and use ofsafety check lists priorto each flight an equivalent level ofsafety 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
orpassengers, and given the size ofthe UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining safety/flight manual delineating areas ofwhere 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 takecertain 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 takeoffdistances and aircraft performance data before initiation offlight. Before the aircrafttakes flight, a home GPS location will be set for any reason the aircraft becomes disoriented in flight, and return safelytohome.


### 14 C.F.R. 

### § 91.109(a) & 

### 91.319(a)(1): Flight Instruction Theseregulations providethat 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 nothave fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training withoutfully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. Additionally, in the absence ofprevious training requirements, John Van Houten is a seasoned UAS pilot having flown hobby grade and professional grade UAS's for a number ofyears 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 sensorto determine altitude. In the absence ofGPS signal, barometric pressure is used and calculated at point ofUAS arming.


### 14 C.F.R §91.145(b) Management ofaircraftoperations in thevicinity ofaerial Demonstrations and major sportingevents CFR 91.145 states: (b) In deciding whether a temporary flight restriction is necessary for an aerial demonstration or major sportingevent not listed in paragraph (a) ofthis 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 ofthe event. (5) Degree ofpublic interest. (6) Numberofspectators. (7) Provisions for spectatorsafety. (8) Number and types ofparticipating aircraft. (9) Use ofmixed high and low performance aircraft. ( 10) Impact on non-participating aircraft. (11) Weatherminimums. ( 12) Emergency procedures that 

### will be in effect.
IfJohn Van Houten intends to use the UAS to coversporting events from outside the activity, coordination will be completed by contacting the FSDO prior to the eventto ascertain the presence ofany other unmanned activities. Flight activity will be conducted based on safety and with particular attention tothe avoidance ofoverflight oflarge concentrations ofpeople. However, specific relieffrom this regulation is still necessary to ensure compliance with FARs.


### 14 C.F.R. 

### § 91.203 (a) and (b) Carrying Aircraft Certification andRegistration Theregulation 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 atthe cabin orcockpit entrance so that it is legible to passengers orcrew. The UAS fully loaded weighs no morethan 55 lbs. and is operated without an onboard pilot. As such,there is no ability orplace to carrycertification and registration documents orto display them on the UAS. An equivalent level ofsafety will beachieved by keeping these documents at the ground control point where the pilotflying the UAS will have immediate access to them, to the extent they are applicable to the UAS.


### 14 C.F.R. 

### § 45.23: Markingofthe Aircraft. Applicable Codes ofFederal Regulation require aircraft to be marked accordingto certain specifications. My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit orpilot station on which to mark certain words orphrases. 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 placingthe word "EXPERIMENT AL" on its fuselage asrequired by 14 C.F.R. §45.29 (f) so that I the pilot, oranyone assisting me as a spotterwith the UAV will
seethe markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and I0700.


### 14 C.F.R. 

### § 61.113; 14 C.F.R. 

### § 61.133: PrivatePilot Privileges and Limitations; PIC; Commercial PilotPrivileges and Limitations: Pursuantto 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limitedto noncommercial operations. Section 61.l33(a)requires an individual with a commercial pilot's licenseto be pilot in command ofan aircraft for compensation orhire. I shall achieve an equivalent level ofsafety as achieved by current regulations because my UAS does notcarry any pilots orpassengers. The risks attended to the operation ofmy VAS is far less than therisk 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 of50 hours flight time onthe 

### VAS in operation.


### 14 C.F.R. 91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operatingthe helicopter complies with any route oraltitudes prescribed for helicopters by the FAA. Asthis exemption is for a VAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, ornot more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As setforth herein, the VAS will neveroperate at higher than 400 AGL with the exception that in circumstances wherethe 

### VAS is used to surveyorphotograph a structure whose height exceeds400 feet AGL, the UAS will not be operated more than 200 feet above the highest pointonthe structure. Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations withouttheir pre-obtained consent. It also may be operated overopen waterclose to shore keeping a distance of500 feet as indicated in Section 91.119 ( c). The equivalent level ofsafety will be achieved given the size, weight, speed ofthe UAS as well asthe location where it is operated. No flight will be taken without the permission ofthe property owneror local officials. Because ofthe advance notice to the propertyowner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft orrotorcraft 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 atorbelow 500 AGL. In addition, the low-altitude operations ofthe VAS will ensure separation between these UAS operations and the operations ofconventional aircraftthat must comply with Section 91.119.


### 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 pointof intended landing and, assuming normal cruising speed -(1) Duringthe day, to fly afterthat for at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes." I will be operating a VAS utilizing battery powerratherthan combustible fuels, flights generally lastbetween 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 ensurethere is enough powerto return to the original startingdestination 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. Theseregulations require thatan aircraft operatororowner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided inparagraph (c) ofthis section, have discrepancies repaired asprescribed in part43 ofthis chapter

...," and others shall inspect ormaintain the aircraft in compliance with Part43. 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 pursuantto theflight manual and operating handbook. An equivalent level ofsafety 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. Ifmechanical issues arise the UAS can land immediately and will be operatingfrom no higherthan 400 feet AGL. The operatorwill ensure that the UAS is in working orderpriorto initiating flight, perform required maintenance, and keep a log ofany 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 providethe equivalent level ofsafety. An equivalent level ofsafety 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 ensurethatthe UAS is in working orderprior to initiating flight and perform required maintenance needed.


### In summaryJohn 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 pursuantto 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 operatorofUnmanned 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 Departmentofthe Army Civilian General Engineer, under the Program Executive Office, Aviation, Aviation Systems, AirTraffic Control (SFAE-AV-ASATC) am an experienced RC multi-copterenthusiast, in the state ofAlabama and intend to use the my UAS, asdescribed herein, equipped with camera(s) and sensors safely and commercially. I have been involved in building and the piloting ofremote controlled aircraft for over 5 years. I have logged more than 204 hours on RC helicopters, planes, and UGS. I have flown over700 sorties in my youth with Microsoft Flight Simulator. As a Government Civilian under PEO AVN, AirTraffic Control with over 16 years ofAirspace De-confliction and Airspace Management technical experience, Ihave a greatappreciation for, and understanding ofthe capabilities and safety concerns involved in the use ofUAS andthe evolving associatedtechnologies and how through properapplication and use, these platfonns can be an asset to the community. I intend to contribute to the benefit ofthe community as a whole, by educatingfuture pilots in a safeenvironment and via the application ofsafe flight and practices. The satisfaction ofcriteria provided in Section 333 ofthe Reform Act of2012 provides a level ofsafetythat should be satisfactory to the FAA and general public. In view ofthe beneficial advantagesto public safety, I respectfully submitmy Section 333 exemption request for allowing the commercial operation of the applicant's UAS.

Thunderbird UAS Attn: John Van Houten 7062 Jacks CreekLN SE Owens Cross Roads, AL 35763 J3systems@gmaiI.com