UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Daedalus Drone Services, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS 

OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 

21 subpart H, 45.23(b), 61.113(a), 91.103, 91.109(a), 91.119(b), 91.119(c), 

91.121, 91.151(a), 91.203(a)&(b), 91.405(a), 91.409(a)(2), 91.417(a)&(b), 

91.7(a)&(b), AND 91.9(b)(2) CONCERING OPERATION OF SMALL 

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on June 19, 2015

Daedalus Drone Services, LLC

PO Box 5206

Austin, Texas 78763-5206

(512) 766-4337

DaedalusDroneServices.com
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 2 June 18, 2015

Table of Contents

0 Preface....................................................................................................................4

0.1 Summary...........................................................................................................4

0.1 Petitioner’s Contact Information ......................................................................5

1 Exemptions ............................................................................................................6

1.1 Regulation Exemptions Sought ........................................................................6

1.2 Equivalent Level of Safety ...............................................................................7

1.2.1 - 14 CFR §91.7(a) – Civil aircraft airworthiness............................................................ 7

1.2.2 - 14 CFR 91.119(b) – Minimum safe altitudes, congested area ..................................... 7

1.2.3 - 14 CFR 91.119(c) – Minimum safe altitudes, other than congested area .................... 7

1.2.4 - 14 CFR 91.121 – Altimeter settings............................................................................. 7

1.2.5 - 14 CFR 91.151(a) and (b) – Fuel requirements for flight in VFR conditions.............. 8

1.2.6 - 14 CFR §91.405(a) – Maintenance required................................................................ 8

1.2.7 - 14 CFR § 91.407 – Operation after maintenance, preventive maintenance, rebuilding, 

or alteration ...................................................................................................................... 8

1.2.8 - 14 CFR §91.409 – Inspections..................................................................................... 8

1.2.9 - 14 CFR 91.417(a) & (b) – Maintenance records.......................................................... 9

2 Operations............................................................................................................10

2.1 Equipment.......................................................................................................10

2.2 Flight and Safety Operations/Procedures .......................................................11

2.2.1 Technology ................................................................................................................... 11

2.2.2 Mechanical.................................................................................................................... 11

2.2.3 Personnel ...................................................................................................................... 11

2.3 Operations.......................................................................................................13

2.4 Level of Safety................................................................................................16

2.5 Public Interest .................................................................................................17

2.6 Privacy ............................................................................................................18

3 Petition Request...................................................................................................19

3.1 Summary (to publish in the Federal Register)................................................19
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3.1.1 Rules from which exemption is sought ........................................................................ 19

3.1.2 Nature of exemption sought ......................................................................................... 19

3.1.3 Additional information ................................................................................................. 19

3.2 Additional Information Provided in Support of the Petition Request............20

3.3 Conclusion ......................................................................................................22

4 Attachments.........................................................................................................23

4.1 Flight Operations and Safety Manual (Confidential) .....................................23

4.2 Safety Management System (Confidential)....................................................23

4.3 DJI Inspire 1 User Manual..............................................................................23

4.4 DJI Phantom 3 User Manual...........................................................................23

4.5 DJI Phantom 2 User Manual...........................................................................23

4.6 DJI S800 User Manual....................................................................................23

4.7 DJI S900 User Manual....................................................................................23

4.8 DJI S1000 User Manual..................................................................................23

4.9 3DR Aero User Manual ..................................................................................23

4.10 PA-01 Vapor User Manual (see http://pulseaero.com/products/vaporhelicopter-uas.php)......................................................................................23
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 4 June 18, 2015

0 Preface

0.1 Summary

RE: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:

This letter is for the purpose of petitioning the Secretary of Transportation and Federal Aviation 

Administration for exemption to the below referenced Federal Aviation Regulations that 

currently apply to Unmanned Aircraft Systems (UAS).

An exemption is requested in order for Daedalus Drone Services, LLC to operate small 

unmanned aircraft systems (sUAS) commercially in airspace regulated by the Federal Aviation 

Administration (FAA) for the purposes of; aerial photography/videography/surveying, 

structural/utility inspections/patrolling, real estate marketing/surveying, remote sensing, 

precision agriculture, public entity support operations, construction site inspection and 

monitoring, wildlife and forestry monitoring, education and research operations, flare stack 

inspections, and other flight operations that could be performed safely and more cost effectively 

with the use of sUAS, at low altitude, within the U.S. national airspace system as compared to a 

manned aircraft.

Daedalus Drone Services, LLC is a company founded by aviation enthusiasts dedicated to a safe 

and legal integration of unmanned aircraft systems into the national airspace system. The 

members bring significant experience in; traditional aviation, aviation safety, model aircraft 

design, build and operation, computer science, aerial photography, engineering, and many related

disciplines. Safety is a primary concern for Daedalus Drone Services, LLC therefore all 

operations will strictly follow the comprehensive Flight Procedures and Operations Manual and 

the Safety Management System (confidential, attached).

The UAS operations proposed in this petition will be consistent with previously granted UAS 

Section 333 exemptions and FAA guidance. 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), and 11213 

to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA has found that the 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 that the UAS operation enabled by this exemption is in the public interest. This petition is 

consistent with the aforementioned grants of exemption. 
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 5 June 18, 2015

0.1 Petitioner’s Contact Information

Daedalus Drone Services, LLC

PO Box 5206

Austin, Texas 78763-5206

(512) 766-4337

DaedalusDroneServices.com
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 6 June 18, 2015

1 Exemptions

1.1 Regulation Exemptions Sought

Various regulations have been previously determined by other granted exemptions either not to 

be applicable or not to require relief, so these will not be specifically addressed. Daedalus Drone 

Services, LLC will accept any conditions and limitations as previous exemptions for the 

following regulations

 14 CFR part 21 – Certification procedures for products and parts 

 14 CFR 45.23(b) – Display of marks 

 14 CFR 61.113(a)&(b) – Commercial pilot privileges and limitations 

 14 CFR 91.7(b) – Civil aircraft airworthiness 

 14 CFR 91.9(b)(2) – Civil aircraft flight manual, marking, and placard requirements 

 14 CFR 91.103 – Preflight action 

 14 CFR 91.109(a) – Flight instruction; simulated instrument flight and certain flight tests

 14 CFR 91.203(a) and (b) – Civil aircraft: Certifications required

In addition relief is requested from the following the FARs. 

 14 CFR 91.7(a) – Civil aircraft airworthiness 

 14 CFR 91.405(a) – Maintenance required 

 14 CFR 91.409(a)(2) – Inspections 

 14 CFR 91.417(a) and (b) – Maintenance records 

 14 CFR 91.119(b) – Minimum safe altitudes, over congested areas 

 14 CFR 91.119(c) – Minimum safe altitudes, over other than congested areas 

 14 CFR 91.121 – Altimeter settings 

 14 CFR 91.151(a) – Fuel requirements for flight in VFR conditions
 FAA Modernization and Reform Act Section 333 Petition for Exemption

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1.2 Equivalent Level of Safety

1.2.1 - 14 CFR §91.7(a) – Civil aircraft airworthiness 

 The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. Because no airworthiness certificate has been issued for the aircraft, no FAA 

regulatory standard exists for determining airworthiness. Given the size of the aircraft 

and the requirements contained in the Operations Manual for the use of an inspection 

checklist prior to each flight, an equivalent level of safety will be provided. 

1.2.2 - 14 CFR 91.119(b) – Minimum safe altitudes, congested area 

 Paragraph (b) of this section states that the minimum safe altitude “over any congested 

area of a city, town, or settlement, or over any open air assembly of persons, [is] an 

altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet 

of the aircraft.” Daedalus Drone Services, LLC proposes to conduct flights on private 

property that may lie in areas considered to be “congested”. Operational data will be 

collected at or near zero ground speed, and at altitudes below 400’ AGL. They will be 

conducted entirely over private property with permission granted, and at an altitude and 

in a fashion that should a power unit fail, procedures that will ensure that an emergency 

landing can be made without undue hazard to persons or property on the surface and 

without leaving the private property.

1.2.3 - 14 CFR 91.119(c) – Minimum safe altitudes, other than congested area 

 Paragraph (c) of this section states that the minimum altitude allowed “over other than 

congested areas [be] 500 feet above the surface, except over open water or sparsely 

populated areas. In those cases, the aircraft may not be operated closer than 500 feet to 

any person, vessel, vehicle, or structure.” 

 The operations proposed by this exemption require that operations be conducted in close 

proximity to structures. Under section (c), it is requested that no restrictions with regard 

to minimum distances from structures, vessels, and vehicles, and a 200-foot minimum 

distance from persons not associated with the operation be granted. Daedalus Drone 

Services, LLC further requests that with regard to crew required for the operation of the 

UAS, no minimum distance be required. 

 Under certain conditions a single flight of as long as a mile might be required. In this 

instance, in order for the PIC to maintain the necessary spatial orientation and for the 

Visual Observer to assure situational awareness, the crew proposes to follow the UAV 

from a safe distance in a moving vehicle.

1.2.4 - 14 CFR 91.121 – Altimeter settings 

 This regulation requires the pilot to set the altimeter to the current “altimeter setting” or 

ground elevation along the route of flight. This regulation does not pertain to the 

operation of UAS because the altimeter is specifically intended to be read by the onboard 
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 8 June 18, 2015

pilot. Neither the pilot nor altimeter are onboard the UAV. Operations will typically be 

avoided around airports, so there will not be a local altimeter setting available. Also, 

there is no “route of flight”, as all operations will be within visual range of the PIC. The 

PIC will need to know the height of the aircraft above the ground primarily to keep from 

venturing into airspace used by manned aircraft. That information is sent to the pilot in 

real time via telemetry, and is rendered in feet AGL. This arrangement satisfies the intent 

of the regulation and provides for an equivalent degree of safety. 

1.2.5 - 14 CFR 91.151(a) and (b) – Fuel requirements for flight in VFR conditions 

 Paragraph (a) of this regulation states in pertinent part, “no person may begin a flight in 

an airplane unless there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed...during the day, to fly after that for at least 30 minutes.” 

This part pertains to airplanes, and while a sUAS is not certificated and is therefore 

neither an airplane nor rotorcraft, its flight characteristics can be associated with a 

rotorcraft or airplane, so paragraph (b) rotorcraft would also be appropriate. Paragraph 

(b) requires the craft to be able to fly to the point of intended landing and thereafter for 20 

minutes. 

 Daedalus Drone Services, LLC proposes to employ battery-powered sUAS that cannot 

comply with the requirements of 91.151(a) or (b). However, telemetry provides a 

constant indication of remaining power, along with a low-voltage visual and audible 

warning when the power gets critically low. In this event, the sUAS can be landed safely 

within a minute or two while maintaining some power in reserve. The Petitioner requests 

that the reserve requirement be set at 20% battery life instead of a metered amount of 

minutes. 

1.2.6 - 14 CFR §91.405(a) – Maintenance required 

 This section requires periodic inspections, repairs made as necessary, and those 

procedures documented. Inspections will be performed before the first flight of each day 

and repairs completed in accordance with the appropriate operations manuals, thus 

assuring an equivalent level of safety. 

1.2.7 - 14 CFR § 91.407 – Operation after maintenance, preventive maintenance, 

rebuilding, or alteration 

 This section requires that after maintenance, proper entries be made in the aircraft record, 

and that necessary certain checks, including flight checks be performed. Flight checks 

will be performed prior to the first flight of the day in accordance with the appropriate 

operations manuals to ensure proper functionality of all systems and components. 

1.2.8 - 14 CFR §91.409 – Inspections 

 This section requires that annual and 100-hour inspections be performed on certain 

aircraft, and that they be returned to service by properly authorized personnel. Daedalus 
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Page | 9 June 18, 2015

Drone Services, LLC asserts that the personnel that operate the sUAS have received 

training on its proper care and maintenance, and are as qualified to determine that it is in 

condition for safe flight as the personnel authorized by 43.7, thereby achieving an 

equivalent level of safety. 

1.2.9 - 14 CFR 91.417(a) & (b) – Maintenance records 

 This section describes requirements for maintenance recordkeeping. Daedalus Drone 

Services, LLC will maintain records of all inspections, maintenance, alterations, and 

repairs. They will be kept on site by the PIC and will be available to the Administrator or 

his representative. 
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Page | 10 June 18, 2015

2 Operations

2.1 Equipment

Daedalus Drone Services, LLC will use the following aircraft and equipment according to the 

procedures detailed in the respective safety, operation, maintenance and user manuals:

 DJI (S1000, S900, S800, Inspire 1, Phantom 3, Phantom 2, Phantom 2 Vision/+)

o Manuals attached

 3DR Aero

o Manual attached

 PA-01 Vapor

o Manual link provided

Design and operational characteristics for each aircraft (e.g. aircraft performance and 

performance limitations, operating procedures, and aircraft loading information) can be found in 

the attached User and Operations Manuals.

Each aircraft listed above is an industry leading consumer product with a proven track record for 

safe operation. The equipped automatic flight components compliment manual control and 

enhance the safe operation under various operating conditions. During all phases of flight, the 

PIC will remain the ability to directly control the flight path of the sUAS. 

The Radio Frequency (RF) spectrum used for control of the sUAS and associated equipment is, 

5.8gHz. 2.4gHz., 915mHz., and 72mHz., and complies with all government oversight 

requirements, including the Federal Communications Commission.
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2.2 Flight and Safety Operations/Procedures

2.2.1 Technology

 Auto descent (landing) if communication signal is lost. If the sUAS loses 

communications, the sUAS will have the capability to return to a pre-determined location 

within a secure perimeter and land.*

 Auto descent (landing) if battery were to drop lower than nominal level.*

 Flights will be terminated at 20% batter power reserve.

 Live video for operator gives real-time positioning feedback. Surrounding can be 

monitored via on-board cameras to assist with collision avoidance and maintaining 

spatial orientation (Note: the PIC will always maintain VLOS capability).*

 The sUAS will have the capability to abort a flight in the case of unpredicted obstacles or 

emergencies.

 On-Screen-Display (OSD) contains operating information to ascertain equipment status 

at all times: speed, altitude, GPS satellites, heading, and voltage.*

 Altitude information will be provided to the sUAS PIC via a digitally encoded telemetric 

data feed. This altitude information will be generated using GPS triangulation, digitally 

encoded barometric altimeter, radio altimeter, and/or a ground-based digital rangefinder.*

*Not available on all equipment

2.2.2 Mechanical

 Flight operations will be VLOS.

 The sUAS will weigh less than 55 lbs and travel at a speed less than 100mph.

 Batteries will be charged and tested to ensure enough power exists for the flight operation 

+20%.

 Flights will be operated at an altitude no more than 400 feet AGL.

 Lithium Polymer batteries will be stored and transported via fireproof bags.

 The equipment operated under this exemption will be registered and marked according to 

guidelines in the grant of exemption.

2.2.3 Personnel

 Visual observers will ensure safe operation and may satisfy the VLOS for the PIC as long 

as the PIC maintains VLOS capability.

 Radio spectrum analysis will be performed to check for interference on the frequencies 

utilized for equipment control/communication.

 A pre-flight briefing will be conducted before planned sUAS operations prior to flight 

activity. Participation is mandatory for all personnel who will be performing duties 

within the boundaries of the safety perimeter.
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 12 June 18, 2015

 Consent will be obtained for all personnel involved in the sUAS operation and no nonconsenting individuals will be restricted access to the safety perimeter.

 PIC and VO will maintain the capability of unaided oral communication.

 Permission will be obtained from the property owner in advance of flight operations.

 PIC and VO will receive appropriate training and practice in advance of commercial 

flight operations for all equipment proposed. Additionally, recurrent training will be 

provided in conjunction with advancements in hardware and software.
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 13 June 18, 2015

2.3 Operations

Pursuant previously granted exemptions, equipment operated by Daedalus Drone Services, LLC, 

will only be operated under the following conditions:

 At a gross weight that is under 55 lbs.

 Operations for the purposes of closed-set motion picture and television filming will not 

be conducted without a separate waiver/authorization permitting such activities.

 At speeds not to exceed 100 miles per hour or the aircraft manufacture recommended 

maximum airspeed.

 At an altitude below 400 feet AGL.

 Within VLOS of the PIC at all times. Where the PIC is able to maintain VLOS with 

human vision unaided by any device other than corrective lenses, as specified on the 

PIC’s FAA-issued airman medical certificate or U.S. driver’s license.

 Will utilize a visual observer (VO) where the aircraft is operated within the visual line of 

sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement, but the PIC will always maintain VLOS capability. The VO and PIC will be 

able to communicate verbally at all times; electronic messaging or texting will not 

permitted during flight operations. The PIC will be designated before the flight and will 

not transfer his or her designation for the duration of the flight. The PIC will ensure that 

the VO can perform the duties required of the VO.

 The operating documents will be accessible during UAS operations and made available to 

the Administrator upon request. If a discrepancy exists between the conditions and 

limitations in the exemption and the procedures outlined in the operating documents, the 

conditions and limitations of the exemption take precedence and will be followed. 

 Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g., replacement of a flight critical component, will undergo a 

functional test flight prior to conducting further operations. Functional test flights will 

only be conducted by a PIC with a VO and will remain at least 500 feet from other 

people. The functional test flight will be conducted in such a manner so as to not pose an 

undue hazard to persons and property.

 The operator will be responsible for maintaining and inspecting the UAS to ensure that it 

is in a condition for safe operation.

 Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is 

in a condition for safe flight. The pre-flight inspection will account for all potential 

discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals 

a condition that affects the safe operation of the UAS, the aircraft will be prohibited from 

operating until the necessary maintenance has been performed and the UAS is found to 

be in a condition for safe flight.
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 14 June 18, 2015

 The operator will follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

 Each UAS operated will comply with all manufacturer's safety bulletins.

 The PIC will hold either an airline transport, commercial, private, recreational, or sport 

pilot certificate. The PIC will also hold a current FAA airman medical certificate or a 

valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a 

territory, a possession, or the Federal Government. The PIC will meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his 

or her pilot certificate.

 The operator will not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under 

the operations manuals, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). 

Training operations will only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC will operate the UA with 

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

 UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All 

operations will be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) will not authorized.

 The UA will not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport’s management is 

obtained or otherwise permitted by a COA issued to Daedalus Drone Services, LLC The 

letter of agreement with the airport management will be made available to the 

Administrator or any law enforcement official upon request.

 The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC.

 If the UAS loses communications or loses its GPS signal, the UA will return to a predetermined location within the private or controlled-access property.

 The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

 The PIC will not begin a flight unless (considering wind and forecast weather conditions) 

there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least 5 minutes or with the reserve power recommended by the 

manufacturer if greater.

 All operations will be conducted in accordance with an ATO-issued COA.

 All aircraft operated by Daedalus Drone Services, LLC be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N−Number) 
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 15 June 18, 2015

markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as 

practicable.

 Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at 

the Ground Control Station of the UAS any time the aircraft is operating. These 

documents will be made available to the Administrator or any law enforcement official 

upon request.

 The UA will remain clear and give way to all manned aviation operations and activities at 

all times.

 All Flight operations will be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

o Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator will ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations will cease immediately in a manner ensuring the safety 

of nonparticipating persons.

o The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not present 

an undue hazard.

 All operations will be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each 

flight to be conducted.

 Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be reported to 

the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents will be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 
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Page | 16 June 18, 2015

2.4 Level of Safety 

The proposed operation under this requested exemption will be performed at a level of safety 

equivalent to, or exceeding that required under FARs. For many proposed operations, the current 

procedures employed are more dangerous and less efficient; we believe that the lightweight, fuelless aircraft remotely piloted from a safe distance, is a much safer and more practicable means of 

conducting these operations. 

Some of the operations proposed by this exemption request require that operations be conducted 

in close proximity to structures. Daedalus Drone Services, LLC understands the need to keep 

aircraft at a safe distance from the general public, but 500 feet is the minimum for student pilots 

operating a 10,000-pound multiengine airplane with 200 gallons of highly flammable fuel 

onboard. Even a 10,000-pound helicopter operated by a student pilot can fly closer than that to 

persons on the surface. Daedalus Drone Services, LLC argues that sUAS weighing less than 55 

lbs., operating under 100 mph would pose much less of a hazard than either of these previous 

examples. 

The Petitioner requests that no restrictions with regard to minimum distances from structures, 

vessels, and vehicles, and a 200-foot minimum distance from persons not associated with the 

sUAS operation be granted. Petitioner further requests that with regard to the crew required for 

the operation of the UAS, no minimum distance be required. 

With respect to operating the UAS from a moving vehicle, Daedalus Drone Services, LLC

believes that it has been demonstrated using model aircraft that the closer the PIC is to the 

aircraft, the more precise control he has over the craft. Additionally the closer he is to the aircraft 

the earlier he can detect an anomaly, and can react to it therefore mitigating any potential adverse 

effects. Control of the aircraft from a moving vehicle enhances operational safety; therefore we 

request that we not have this restriction. 
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 17 June 18, 2015

2.5 Public Interest

Daedalus Drone Services, LLC believes that relief from the aforementioned regulations will 

benefit the public interest in the following manners;

 Removal of human risk from flight operations

 Reduction in air and noise pollution associated with powered flight

 Improvement upon cost efficiencies associated with manned flight

 And various other economic and safety benefits of aerial operations using sUAS

 Reduction in airspace congestion

 Advance the United States’ experience and innovation related to UAS, helping the 

country to remain a leader in aerospace technology

Whether helping to protect the public, inspecting infrastructure or acquiring aerial imagery, 

sUAS provide real-time situational awareness, enabling better decision-making. Better decisionmaking saves lives and protects property.
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Page | 18 June 18, 2015

2.6 Privacy

All flights will occur over private or controlled access property with the property owner's prior 

consent and knowledge. Images taken will be of individuals who have also consented to being 

filmed or otherwise have agreed to be in the area where aerial photography will take place.
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Page | 19 June 18, 2015

3 Petition Request

3.1 Summary (to publish in the Federal Register)

3.1.1 Rules from which exemption is sought

 14 CFR part 21, 45.23(b), 61.113(a), 91.103, 91.109(a), 91.119(b), 91.119(c), 91.121, 

91.151(a), 91.203(a)&(b), 91.405(a), 91.409(a)(2), 91.417(a)&(b), 91.7(a)&(b), and 

91.9(b)(2)

3.1.2 Nature of exemption sought

 An exemption is requested in order for Daedalus Drone Services, LLC to operate small 

unmanned aircraft systems (sUAS) commercially in airspace regulated by the Federal 

Aviation Administration (FAA) for the purposes of; aerial 

photography/videography/surveying, structural/utility inspections/patrolling, real estate 

marketing/surveying, remote sensing, precision agriculture, public entity support 

operations, construction site inspection and monitoring, wildlife and forestry monitoring, 

education and research operations, flare stack inspections, and other flight operations 

that could be performed safely and more cost effectively with the use of sUAS, at low 

altitude, within the U.S. national airspace system as compared to a manned aircraft.

3.1.3 Additional information

 This Petition is made pursuant the FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333, which directs the Secretary of Transportation to determine if certain sUAS 

may operate safely in the NAS. As such, Daedalus Drone Services, LLC’s request for 

exemption may be granted pursuant the authority of FMRA Section 333 and 14 CFR Part 

11, as set forth above. FMRA Section 333 sets forth the requirements for considering 

whether a sUAS will create a hazard to users of the NAS or the public, or otherwise pose 

a threat to national security; and further, provides the authority for such sUAS to operate 

without airworthiness certification. As discussed in detail above, Daedalus Drone 

Services, LLC will conduct operations safely in the NAS, without creating a hazard to 

users of the NAS, the public, or otherwise pose a threat to national security.
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 20 June 18, 2015

3.2 Additional Information Provided in Support of the Petition Request

The knowledge and experience which the members of Daedalus Drone Services, LLC bring to 

the UAS industry is significant. Flight Operations and Safety Director, Douglas MacIver brings 

over 33 years of flight experience and a passion to advance safety in aviation. Chief Pilot, 

Stephen Harrison, brings significant and diverse experience which will ensure safe and 

successful flight operations under a grant of exemption. Below is a list of certificates and 

experience provided in support of this petition for exemption.

 Douglas MacIver, Flight Operations and Safety Director

o FAA Designated Pilot Examiner – Rotorcraft Helicopter

 DPE: #E65-208

 Authorizations

 GIE

 PE

 CIRE

 FIRE

 FIE

o Flight Instructor

 Certificate: #2327066CFII

o Commercial Pilot

 Certificate: #2327066

o Total Flight Time: Over 14,000 hours

 5,000 hours multi-engine helicopter

o Army Aviation Experience and Training

 20 years active duty, retired CW4 instructor pilot for the Apache Longbow

o Additional Accolades

 Gold Seal Flight Instructor

 Airplane Single Engine

 Airplane Multi-Engine Land

 Rotorcraft Helicopter

 Instrument Airplane & Helicopter

 Ground Instructor

 Advanced

 Instrument

 FAAST Team Representative

 Stephen Harrison, Chief Pilot

o Private Pilot Certificate: #3382579

 Total Flight Time: 63.7 hours
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 21 June 18, 2015

 Acquired certificate and studied Aeronautical Engineering at Embry 

Riddle Aeronautical University in Prescott, AZ

o Academy of Model Aeronautics Membership (AMA): #715136

 Total Flight Time: 300 hours (conservative estimate since 2001)

 Member since 2001

 Began experimenting with aerial photography via RC aircraft as a hobby 

in 2005 using 35mm cameras

 This interest was complemented by an aerial photography course 

taken at the University of New Hampshire

 Began experimenting with RC telemetry systems in 2009

o Aircraft Owners and Pilots Association (AOPA): #07075386

 Member since 2013

 Constant exposure to aviation industry advancements and safety 

information
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 22 June 18, 2015

3.3 Conclusion

The purpose of the proposed exemption is for the operation of sUAS weighing less than 55 

pounds for the purposes of aerial photography/videography/surveying, structural/utility 

inspections/patrolling, real estate marketing/surveying, remote sensing, precision agriculture, 

public entity support operations, construction site inspection and monitoring, wildlife and 

forestry monitoring, education and research operations, flare stack inspections, and other flight 

operations that could be performed safely and more cost effectively with the use of small UAS, 

at low altitude, within the U.S. national airspace system as compared to a manned aircraft. These 

aircraft will be operated by visual line of sight with the pilot. Additionally, a visual observer will 

maintain a vigil for other aircraft and incursions into the proposed flight area. All flights will be 

conducted in daytime VMC by pilots holding at least aforementioned certificates and a minimum 

of a current Class 3 Medical Certificate. Additionally, the Pilot In Command will maintain 

currency requirements of FAR 61.56 and 61.57. 

Respectfully submitted,

Conner MacIver, President

Daedalus Drone Services, LLC.
 FAA Modernization and Reform Act Section 333 Petition for Exemption

Page | 23 June 18, 2015

4 Attachments

4.1 Flight Operations and Safety Manual (Confidential)

4.2 Safety Management System (Confidential)

4.3 DJI Inspire 1 User Manual

4.4 DJI Phantom 3 User Manual

4.5 DJI Phantom 2 User Manual

4.6 DJI S800 User Manual

4.7 DJI S900 User Manual

4.8 DJI S1000 User Manual

4.9 3DR Aero User Manual

4.10 PA-01 Vapor User Manual (see http://pulseaero.com/products/vapor-helicopteruas.php)