07/15/2015

Daedalus	Aerial	Imaging

Attn:	Alan	Holland

1095	Rose	Meadow	Court

Santa	Rosa	CA		95407

707.573.1973

daedalusaerialimaging@yahoo.com

TO: Federal	Aviation	Administration	

US	Department	of	Transportation	

Docket	Management	System

1200 New	Jersey Ave. S.E	

Washington,	DC	.	20590

Re:

Exemption	Request	Section	333	of	the	FAA	Reform	Act	Pursuant	to	section	333	of	the	FAA

Modernization	and	Reform	act	of	2012	(The	Reform Act),	and	14	C.F.R.	Part	11,	Daedalus	Aerial	Imaging,	

herby seeks	and	applies	for	an exemption	to	the	Federal	Aviation	Regulations	(FARs)	to	allow	Daedalus

Aerial Imaging to	operate	Small	Unmanned	Aircraft	Systems	(UAS)	commercially	in	airspace	regulated	by	

the	Federal	Aviation	Administration	(FAA)	under	the	conditions	and limitations set	forth	in	this petition.	

The	requested	exemption	would	permit	Daedalus Aerial Imaging to	operate	small,	unmanned	aircraft	

system	(UAS)	for	the	purpose	of	providing	an aerial	photography	and	survey	service	to	Municipalities,	

Utilities	&	Private	consumers.	The areas	of	use will	include	both	photo and	video	in	the	Utilities,	

Communications	industry,	real	estate	industry, surveying	industry,	construction	industry and	agricultural	

industry.	The UAS will	be operated	in	airspace	that	is	1)	limited	2)	predetermined 3)	would	provide	

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

aircraft system”

Exemption	request	to	section	333	of	the	FAA	Reform Act	Plan	11	Specific	to	UAS	operations.

14	CFR	21	subpart	H;	14 CFR	45.23(b); 14	CFR	61.113(a) &	(b); 14	CFR	91.103;14	CFR	91.105;	14	CFR	

91.109:	14	CFR 91.119(c);14	CFR	91.121;	14 CFR	91.151(a); 14 CFR 91.405(a);	14	CFR	91.407(a)(1);	14	

CFR	91.401(a)(1)	&	(2);	14	CFR	91.417(a)	7	(b).
Dear	Sir	or	Madam:

Commercial	operation	of	an	UAS,	as described	herein, which	are	equipped	with camera(s)	and	sensors,	

would	operate	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	inspection/photography	of	residential/commercial	structures	under contract	with	the	owners	

or local	government	authority.

• Aerial	inspection/photography	of	residential/commercial	utility	infrastructure	included	but	not	

limited	to	electrical	power lines,	wind	turbines	and	cell	towers.

• Aerial	video/photography	or	providing	live	video feed	to	assist	with	rescue	operations in	cases	of an	

emergency	or	natural	disaster	only	when	the	local	authorities	or	government	has	requested	it	by	

contract	and/or	donation.

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

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

operation	of	a	UAS	to	enhance	the	safety of	national	aerospace	system (NAS)	as	well	as	for	

protection	of	the	persons	and	property.

As	described	fully	below,	and	to	be	used	as FOM	(exibit#1), the	requested	exemptions 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	such	as	limited	exposure	to	

flight	crew,	climbing crews,	weight	of	vehicles,	speeds	of	usage,	non use	of	volatile	fuels,	ect.	

Approval	of	this	exemption	would	thereby	enhance	safety	and	fulfill	the	Secretary	of

Transportations	(the	FAA	administrators)	responsibilities	to	“....establish	requirements	for	the	safe	

operation	of	such	aircraft	systems	in	the	national	airspace	system.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The	primary	vehicle	to	be	used	will	be	the	DJI	Inspire1	and	or	DJI	Phantom	3.	While	vehicles	may be	

upgraded	as	new	technological	and	safety	advanced	occur	the	bar	for	operation	and	safety	will	be	

set	by	DJI	Inspire	1	and	any	new	vehicles	or	versions	will	exceed	the	current	safety	and	operational	

standards.	No	vehicle	operated	by Daedalus Aerial Imaging will	be modified	from	the	manufacturers	

design	unless	specifically	directed	by	the	same	manufacturer.

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	include:
Exhibit #1

• The	UAS	will	weigh	less	than	55	lbs

• The	UAS	will have	a	maximum	operating	speed	of	no	more	than	100 mph

• Flights	will	be	operated	within	line	of	sight	of	the	pilot	in	command	and/or	visual	observer

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

25%	battery	power	reserve	or	30	minutes	of	flight	time	whichever	occurs	first

• Flights	will	be	operated	at	altitude	of	no	more	than	200 feet	above	ground	level	and	no	more	

than	200	feet	above	an	equivalent platform from	which	filming is	planned.

• UAS will	NOT operate.

• 5	nautical	miles	(NM)	from	an	airport	having	an	operational	control	tower;	or

· 3	NM	from	an	airport	with	a	published	instrument	flight	procedure,	but	not	an	operational	tower;	or

· 2	NM from	an airport	without a	published	instrument	flight	procedure	or	an	

operational	tower;	or

· 2 NM	from	a	heliport	with	a	published	instrument	flight	procedure

• Minimum	crew	for	each	operation	will	consist	of	the	UAS	pilot	(PIC),	the	visual	observer (VO) and

may	include	but	not	limited	to	a	camera	operator

• The	UAS	pilot	will	be	designated	pilot	in	command	and	hold at	least	a Light Sport Pilot

Certificate along	with	a	Current	State	Drivers	License. If	the	PIC	feels	another	operator	to	be	

qualified	with	the	necessary	skills	to	be	pilot	in	command	and	possesses at	least	a Light Sport

Pilot Certificate along	with Current	State	Drivers	License, that	person	may	be	designated	PIC	

provided	they	have	a	minimum of	20	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	days	production	activities

• All	flights	will occur	under	visual	flight	rules meteorological	conditions	(VFR	only).

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

operations	and	ensure	only	consenting	persons	will 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	required	under	the	FOM. With	the	advance	permission	of	the	FFDO,	

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	losses	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 and	return	to	designated	landing	area in	case	of	

unpredicted	obstacles,	weather,	or	emergencies.

• VO or	PIC	instructed	to	switch	UAS	to	automatically	return	home	in	event	either	are	

incapacitated.
https://www.faa.gov/uas/legislative_programs/section_333/how_to_file_a_petition/media/

section333_public_guidance.pdf

As of March 23, 2015, the FAA will automatically grant a "blanket" COA for flights at or below

200 feet to any UAS operator with a Section 333 exemption, provided the aircraft weighs less

than 55 pounds, operations are conducted during daytime Visual Flight Rules (VFR) conditions

and within visual line of sight (VLOS) of the pilots, and stay certain distances away from airports

or heliports.

In seeking authorization, petitioners will

require exemptions from regulations with

which they cannot fully comply. The table

below provides guidance regarding

regulations from which a petitioner may

require exemption. However, some

proposed operations may require

exemption from regulations not listed

here, while others may not require

exemption from all regulations listed here.

14 CFR PART

Part 21 Airworthiness Certification

21, Subpart H

91.103(b)(2)

91.105

91.109

91.119

91.121

91.151

91.405

91.407

91.409

91.417

Certification procedures for products and

parts, Airworthiness Certificates

Preflight action

Flight crewmembers at stations

Flight instruction

Minimum safe altitudes

Altimeter settings

Fuel requirements for flights in VFR

conditions

Maintenance required

Operation after maintenance

Inspections

Maintenance
14	C.F.R.	Part	21,	Subpart	H: Airworthiness	Certificates 14	C.F.R.	Sec	91.203(a)(1)

The UAS will operate @ 55lbs or less (Gross), carries neither a pilot or passenger*, carries no explosive

materials or flammable liquid fuels*, and operates in within a secured and pre-determined designated

area, at altitudes not to exceed 200 feet ALT or speeds in access of 100 MPH.

14	C.F.R.	Sec	91.105	Flight	crew	members	at	station

Exemption may be required, the PIC may not leave his station nor shall VO leave station. In event that

PIC or VO become incapacitated, UAS is to automatically return to designated landing area, as outlined

in FOM

14	CFR	Sec	91.109 Flight	Instruction	(Dual	Controls)

Requiring that no person shall operate a civil aircraft for flight instruction unless the aircraft has fully

functioning dual controls. UAS and Remote controlled aircraft by design do not have dual controls, to

do so on a radio controlled aircraft would lower the ability to safely operate the UAS. This section

cannot reasonably apply

14	C.F.R.	Sec	45.23(b). Marking of	the	Aircraft

Although exemption from said section cannot benefit nor exceed current stipulations, physical

limitations of UAV are reality, such as cabins, letter size, ect. The UAV will operate under my control with

registration lettering sized to fit fuselage in compliance of said section 45.23(b) under conditions and or

limitations deemed mandatory by FAA. My	colleges	and	I must be held responsible for compliancy, on

behalf of Public’s safety and shared air space, as well as its need to identify and enforce the

accountability and of this growing industry.

14	C.F.R.	Sec	61.113(a) and	(b):	Private	Pilot	Privileges and	Limitations:	Pilot	in	Command

By current regulations because the applicants UAS does not carry passengers, or property. The use of

UAS is far less dangerous (weight, speed, Fuel) than the inherent usage of commercial activities

outlined in 14 CFR.16. The pilot in command shall have a current Private pilots license as well as a

current state drivers license which will equal if not exceed safety regulations outlined in 14 CFR

16.113.(a) & (b).

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

Exemption is requested due to fact that FAA rotor flight manuals are not available for UAV. The PIC will

take all actions as stated in FOM, under normal procedures included but not limited to review of

weather, examination of batteries for flight time analysis, landing and takeoff distances as well as flight

and aircraft performance in flight.
14	C.F.R.	Sec	91.119; Minimum	Safe	Altitudes

Mandates safe altitude for operation of civil aircraft and allow helicopter to operates less then

minimums prescribed, providing the person operating helicopter complies with any route with and or

altitudes prescribed for Helicopter’s by FAA. Being that UAV is of Helicopters standards and operation a

request for exemption to operate at altitude’s not to exceed 200 AGL or not more than 200 ft above any

elevated platform from which take off is necessary to achieved filming. In the event of such particular

flight plan, property owners, filming crews and other personnel would all be briefed as to safety and

conduct procedures during flight. FOB or ATC having jurisdiction in such area would have notification

and briefing as mandated.

14	C.F.R.	Sec	91.121 Altimeter	Settings

The requirement of PIC is to use altimeter as means to navigate aircraft to cruise altitudes to and from

corresponding airports as predetermined in flight plan, unless ordered otherwise. As the UAS has no

barometric altimeter, but instead uses GPS altitude read out, an exemption would need be applied. Per

a pre flight checklist and live flight data monitoring, the altitude of launch site will be predetermined

and therefore calculated into the UAS- GPS indicator before flight.

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

Fuel requirements for flight. The maximum flight time under ideal conditions is 30 minutes with the

current manufacturers battery pack. The proposed rule under this exemption would require the UAS to

return to its point of launch if its battery reaches less than 25% provides a higher standard of safety

when applied to UAS.

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

Referring to maintenance, preventive maintenance, and alterations to the UAS. The operator will

provide minor maintenance and inspection to the UAS, documented as outlined in the operational

and safety guidelines. Given the size and simplicity of the UAS combined with the operational and

safety guidelines outlined in this petition the operator can maintain or exceed the required level of

safety.

Sincerely

Alan	Holland

Daedalus	Aerial	Imaging