October	29,	2015

Wolverine Aerial	Imagery LLC 2808	St	Aubin,	Detroit,	MI

48207	Phone:	(609)	792-1097 Email:	

genedavis6641@gmail.com

U.S.	Department	of	Transportation	(DOT)	Docket	Operations,	

M-301200	New	Jersey	Avenue	SERoom	W12-140,	West	

Building, Ground	Floor	Washington,	DC	20590-0001

Subject:	Request	for	Issuance	of	Exemption	under	Title	14	CFR,	

Section 333

To	whom it	may	concern,

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	

Act	of	2012	and	14	CFR	Part	11,	Wolverine	Aerial	Imagery	LLC,	

and	Eugene	Davis	IV together	with	Wolverine	Aerial	Imagery,

hereby	applies	for	exemption	from	certain	Federal	Aviation	

Regulations	to	allow	for	the	commercial	operation	of	small	

Unmanned	Aircraft	Systems	(sUAS)	so	long	as	the	proposed	

operations	are	conducted	within	and	under	the	conditions	

outlined	herein	or	as	may	be	established	by	the	FAA	as	

required	in	accordance	with	Section	333.

If	granted,	it	is	my	intention	to	engage	in	the	commercial	

operation	of	sUAS	in	order	to	offer	services	to	multiple	

industries	including	but	not	limited	to:

-Aerial	surveying	and	mapping	-Cell	tower	inspections

-Energy	Systems	inspections

-Pipeline	inspections

-Aerial data	collection-Residential	Real	Estate	sales	
presentations	

-Public	safety	support	operations

The	requested	exemption	would	permit	the	operations	of	sUAS	

by	the	applicant	under	controlled	conditions	in	airspace	that	is	

1)	limited,	2)	predetermined,	3)	controlled	as	to	access,	4)	

would	provide	safety	and	environmental	enhancements	not	

possible	with	larger,	manned	aircraft,	and	5)	mitigate	the	

inherent	risk	associated	with	the	deployment	of	men	and	

women	in	climbing	and	/or	rappelling	operations	as	may	often	

times	be	required.

Additionally,	the	applicant	holds	an Instructor	and ATP pilot	

certificate	and	a	current	1st class	medical	certificate,	and	has	

more	than	3500	hours	of	total	time	in	both	single, multi-engine	

and	jet	aircraft,	thereby	demonstrating	an	intimate	

understanding	of	how	manned	aircraft	safely	navigate	the	

National	Airspace	System.

Finally,	the applicant	will	ensure	that	all	flights	will	be	

operated	in	class	G	airspace	within	visual	line	of	sight	(VLOS)	

of	the	pilot	and/or	a	visual	observer	(VO)	under	daytime	VFR	

flight	conditions	as	defined	in	FAR	91.155.	For	flights	in	other	

than	class	G	airspace,	the	controlling	agency	will	be	notified	at	

least	24	hours	in	advance,	and,	if	required,	any	necessary	

permission	will	be	obtained.	The	sUAS	will	be	limited	to	a	

maximum	altitude	of	400	feet	AGL	or	100	feet	above	an	

elevated	launch	site.	The	applicant	will	keep	the	sUAS	clear	of	

and	yield	the	right	of	way	to	all	manned	operations	and	

activities	at	all	times	(including	but	not	limited	to	ultra	light	

crafts,	skydiving	activities,	parasailing	activities,	hang	gliders,	

and	hot	air	balloons.
Name	and	address of	Applicant:

Wolverine	Aerial	Imagery	LLC	Eugene	Davis	IV,	17725 George	

Washington,	Southfield,	MI	48075	

Ph:	(609)	792-1097Email:	genedavis6641@gmail.com

Regulations	from	which	this	exemption	is	requested:

-14	CFR	Part	21	Subpart	H-14	CFR	Section	45.23(b)-14	CFR	

Section	61.113(a)	and	(b)	-14	CFR	Section	91.7(a)-14	CFR	

Section 91.9(b)(2)-14	CFR	Section	91.103-14	CFR	Section	

91.109-14	CFR	Section	91.119-14	CFR	Section	91.121-14	

CFR	Section	91.151(a)-14	CFR	Section	91.405(a)-14	CFR	

Section	91.407(a)(1)-14	CFR	Section	91.409(a)(1)	and	(2)	-

14	CFR	Section	91.417(a)	and	(b)

Description	of	proposed	sUAS

The	applicant	proposed	to	utilize	the	Inspire	1	Pro	

manufactured	by	DJI.	The	rotorcraft	weighs	6.4 pounds	

including	the	payload	that	consists	of	a	Sony	camera	sensor.	It	

is	operated	from	the	ground	utilizing	a	remote	controller	

operating	at	a	frequency	of	2.400Ghz-2.483Ghz.	The	maximum	

airspeed	is	42 kts.	It	has	a	maximum	ascent	speed	of	1114 ft.	

per	minute	and	a	maximum	descent	speed	of	787	ft.	per	

minute.	The	Inspire	1 has	the	ability	to	hover,	and	move	in	the	

vertical	and	horizontal	plane	simultaneously.	It	is	equipped	

with	integral	GPS	and One touch	auto-return	home	technology.	

It	is	also	equipped	with	an	intelligent	battery,	which will	

provide	approximately	18 minutes	of	flight	time,	and	will	cause	

the	unit	to	return	to	the	takeoff	point	upon	detection	of	low	

battery	power	or	the	loss	of	connection	with	the	remote	

control	unit.	Please	see	the	manufacturer’s	specifications	

attached	in	Appendix	“A”.

Safety
The	following	operating	procedures	will	apply	during	the	sUAS	

and	operations	under	this	exemption	request:

1. Any	and	all	required	permissions	and	permits	will	be	

obtained	from	appropriate	state,	county,	or	city	

jurisdictions,	including	local	law	enforcement,	fire,	or	

other	appropriate	governmental	agency.	

2. Approval	will	be	obtained	from	relevant	property	owners	

prior	to	an	operation.	

3. The	sUAS	to	be	deployed	by	the	applicant	is	the	Inspire	1	

by	DJI,	which	has	a operational	weight	of	6.4 pounds.	

See	the	complete	specifications	attached	herewith.	

4. The	sUAS	Pilot	in	Command	(PIC)	will	be	trained	in	

advance	for	the	safe	operation	of	the	sUAS	to	be	operated.	

This	will	include	operation	of	the	sUAS	in	both	normal	

and	failsafe	modes	of	operation,	and	will	include	

familiarization	with	the	operation	manual	as	published	by	

the	manufacturer	attached	as	Appendix	“C”	

5. All	operations	will	be	conducted:

i. Within visual	line	of	sight	of	the	PIC	

ii. Utilizing a	visual	observer	(VO)	if	the	sUAS	will	be	flown	

beyond	the	line	of	site	of	the	PIC	

iii. At less	than	400	feet	AGL	or	100	feet	above	an	elevated	

launch	area	

iv. Within class	G	airspace	unless	permission	is	received	at	

least	24	hours	in advance	of	the	planned	flight.	

v. Under daytime	VFR	conditions	as	defined	by	FAR	
91.155.	

vi. At least	5	miles	from	any	airport,	heliport,	or	seaplane	

base.	

6. If	a	VO	is	required,	two-way	communications	between	the	

PIC	and	the	VO	must	be	maintained	for	the	duration	of	the	

flight.	

7. The	flight	area	of	the	sUAS	will	be	observed	for	best	

takeoff	and	landing	locations.	Desired	conditions	include	

flat	and	level	surfaces	clear	of	debris,	at	least	15’	from	

power	lines	and	structures,	and	a	minimum	of	12’	from	

PIC	and	VO.	

8. The	sUAS	will	be	equipped	with	GPS	to	insure	accuracy	of	

the	vehicle	during	all	operations.	

9. All	batteries	will	be	fully	charged	before	each	flight	and	

each	flight	will	be	terminated	when	the	battery	has	20%	

power	level	remaining.	

10. A	visual	safety	inspection	will	be	conducted	before	each	

flight	to	ensure	the	airworthiness	of	the	sUAS	in	

accordance with	the	manufacturer’s	operating	

instructions	and	the	open	pilot	preflight	checklist	(see	

appendix	“B”).	This will	include	checking	the	security	of	

propellers	ensuring	their	tightness,	and	remote	controls.	

11. A	preflight	briefing	will	be	issued	by	the	PIC	to	all	

personnel	included	in	the	operation	prior	to	launch.	All	

personnel	who	will	be	performing	duties	for	the	

operation	will	be	present	for	the	briefing.	

12. If	appropriate,	for	the	operation,	the	sUAS	will	utilize	GPS	
navigation,	failsafe,	and	return-to-home	(RTH)	and/or	

flight	abort	safety	features.	

Relief	requested

Part	21,	Certification	Procedures	for	Products	and	Parts,	

prescribes,	in	pertinent	part,	the	procedural	requirements	for	

issuing	and	changing	design	approvals,	production	approvals,	

airworthiness	certificates,	and	airworthiness	approvals.

Applicant	requests	an	exemption	from	14	CFR	Part	21,	

Subpart	H	and	the	requirement	for	an	airworthiness	

certificate	in	general

Section	45.23(b)	prescribes,	in	pertinent	part,	that	when	marks	

include	only	the	Roman	capital	letter	“N”	and	the	registration	

number	is	displayed	on	limited,	restricted,	or	light-sport	

category	aircraft	or	experimental	or	provisionally	certificated	

aircraft,	the	operator	must	also	display	on	that	aircraft	near	

each	entrance	to	the	cabin,	cockpit,	or	pilot	station,	in	letters	

not	less	than	2	inches	nor	more	than	6	inches	high,	the	words	

“limited,”	“restricted,”	“light-sport,”	“experimental,”	or	

“provisional,”	as	applicable.

Due	to	the	small	size	of	the	sUAS,	applicant	requests	an	

exception	from	14	CFR	45.23(b)	that	would	allow	the	sUAS	

to	display	the	registration	number	in	letters	and	numbers	

as	large	as	practical	on	it’s	fuselage.

Section	61.113(a)	and	(b)	prescribes	that:

. (a)	No person	who	holds	a	private	pilot	certificate	may	act	as	

a	pilot	in	command	(PIC)	of	an	aircraft	that	is	carrying	

passengers	or	property	for	compensation	or	hire;	nor	

may	that	person,	for	compensation	or	hire,	act	as	PIC	of	

an	aircraft.	
. (b)	A private	pilot	may,	for	compensation	or	hire,	act	as	PIC	of	

an	aircraft	in	connection	with	any	business	or	

employment	if—

(1)	The	flight	is	only	incidental	to	that	business	or	

employment;	and

(2)	The	aircraft	does	not	carry	passengers	or	property	for	

compensation	or	hire.

Because	the	sUAS	is	incapable	of	carrying	a	pilot	or	

passengers,	and	due	to	the	controlled	area	of	operation,	

applicant	seeks	an	exemption	from	this	regulation.	

Applicant	is	the	holder	of	an	ATP pilot	certificate.	We	

believe	that	the	ATP pilot	certification	coupled	with	

appropriate	training	as outlined	in	the	user manual	for	

this	sUAS	(attached	in	Appendix	“C”)	exceeds	the	level	of	

safety	provided	by	a	single	pilot	holding	a	commercial	

pilot’s	certificate	operating	in	a	conventional	aircraft.

Section	91.7(a)	prescribes	that	no	person	may	operate	a	civil	

aircraft	unless	it	is	in	an	airworthy	condition.

Given	that	if	this	exemption	is	granted,	there	will	be	no	

airworthiness	certificate,	and	no	standard	exists for	an	

aircraft	of	this	type,	we	propose	to	utilize	the	

manufacturer’s	operating	and	maintenance	manual	in	

conjunction	with	the	open	pilot	preflight	checklist to	

assess	the	airworthiness	of	the	sUAS.

Section	91.9(b)(2)	prescribes,	in	pertinent	part,	that	no	person	

may	operate	a	U.S.-registered	civil	aircraft	unless	there	is	

available	in	the	aircraft:	(i) a	current	approved	Airplane	or	

Rotorcraft	Flight	Manual,	 (ii)	approved	manual	material,	

markings,	and	placards,	or	any	combination	thereof.

Due	to	the	size	and	configuration	of	the	sUAS,	there	is	no	
room	or	capacity	to	carry	such	an	item	on	the	aircraft.	We	

propose	maintaining	and	equivalent	level	of	safety	by	

keeping	the	manual	at	the	ground	control	point	where	the	

pilot	flying	the	sUAS	will	have	immediate	access	to	it.

Section	91.103	prescribes	that	each	PIC	shall,	before	beginning	

a	flight,	become	familiar	with	all	available	information	

concerning	that	flight,	to	include:

. (a)	For a	flight	under	instrument	flight	rules	(IFR)	or	a	flight	

not	in	the	vicinity	of	an	airport,	weather	reports	and	

forecasts,	fuel	requirements,	alternatives	available	if	the	

planned	flight	cannot	be	completed,	and	any	known	

traffic	delays	of	which	the	PIC	has	been	advised	by	air	

traffic	control	(ATC);	

. (b)	For any	flight,	runway	lengths	at	airports	of	intended	use,	

and	the	following	takeoff	and	landing	distance	

information:	(1)	For	civil	aircraft	for	which	an	approved	

Airplane	or	Rotorcraft	Flight	Manual	containing	takeoff	

and	landing	distance	data	is	required,	the	takeoff	and	

landing	distance	data	contained	therein;	and	

(2) For	civil	aircraft	other	than	those	specified	in	paragraph	

(b)(1)	of	this	section,	other	reliable	information	appropriate	to	

the	aircraft,	relating	to	aircraft	performance	under	expected	

values	of	airport	elevation	and	runway	slope,	aircraft	gross	

weight,	and	wind	and	temperature.

We	request	an	exemption	from	14	CFR	91.103	as	FAA	

approved	flight	manuals	will	not	be	used.	In	the	absence	of	

the	flight	manuals,	the	PIC	will	take	all	pre-flight	actions	

including	but	not	limited	to	reviewing	weather,	flight	

battery	requirements,	launch	and	landing	area	

assessments,	and	aircraft	performance	data	before	

commencing	a	flight.
Section	91.109	prescribes,	in	pertinent	part,	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.

We	request	an	exemption	from	14	CFR	91.109	as	evidence	

is	inconclusive	that	a	person	with	a	private	pilot	certificate	

can successfully	maneuver	or	train someone	in	the	safe	

operation	and	maneuvering	of	a	sUAS	without	first	hand	

flight	experience	with	the	particular	sUAS.	Therefore	the	

training	we	will	offer	will	provide	an	equivalent	level	of	

safety.

Section	91.119	prescribes	that,	except	when	necessary	for	

takeoff	or	landing,	no	person	may	operate	an	aircraft	below	the	

following	altitudes:

(a)	Anywhere.	An	altitude	allowing,	if	a	power	unit	fails,	an	

emergency landing	without	undue	hazard	to	persons	or	

property	on	the	surface.

(b)	Over	congested	areas.	Over	any	congested	area	of	a	city,	

town,	or	settlement,	or	over	any	open-air	assembly	of	persons,	

an	altitude	of	1,000	feet	above	the	highest	obstacle	within	a	

horizontal	radius	of	2,000	feet	of	the	aircraft.

(c)	Over	other	than	congested	areas.	An	altitude	of	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.

(d)	Helicopters,	powered	parachutes,	and	weight-shift-control	

aircraft.	If	the	operation	is	conducted	without	hazard	to	

persons	or	property	on	the	surface—

. (1)	A helicopter	may	be	operated	at	less	than	the	minimums	
prescribed	in	paragraph	(b)	or	paragraph	(c)	of	this	

section,	provided	each	person	operating	the	helicopter	

complies	with	any	routes	or	altitudes	specifically	

prescribed	for	helicopters	by	the	FAA;	and	

. (2)	A powered	parachute	or	weight-shift-control	aircraft	may	

be	operated	at	less	than	the	minimums	prescribed	in	

paragraph	(c)	of	this	section.	

We	request	an	exemption from	14	CFR	91.119	as	we	

believe	an	equivalent	level	of	safety	will	be	achieved	given	

the	size,	weight,	and	speed	of	the	sUAS.	No	flights	will	be	

taken	without	proper	notices	given,	and	permission	being	

received	from	the	property	owners,	therefore	adequate	

notice	will	be	provided	for	any	individuals	that	may	be	

affected	by	the	operation.	Additionally,	since	there	is	no	

flammable	fuel	load,	any	potential	risk	associated	with	

these	operations	is	far	less	than	those	presently	presented	

utilizing	conventional	aircraft	operating	below	500	ft.	AGL.	

Finally,	the	low- altitude	restriction	of	the	sUAS	operations	

will	ensure	separation	between	the	sUAS	and	conventional	

aircraft	that	must	comply	with	this	section.

Section	91.121	prescribes,	in	pertinent	part,	that	each	person	

operating	an	aircraft	shall	maintain	the	cruising	altitude	by	

reference	to	an	altimeter	that	is	set	when	operating	below	

18,000	feet	mean	sea	level	(MSL)	to	the	elevation	of	the	

departure	airport	or	an	appropriate	altimeter	setting	available	

before	departure.

We	request	an	exemption	from	14	CFR	91.121	as	the	sUAS	

is	not	equipped	with	a	barometric	altimeter,	but	instead	

outputs	GPS	altitude	data.	An	equivalent	level	of	safety	will	

be	achieved	by	the	PIC	verifying	the	altitude	at	the	launch	

site	prior	to	and	during	the	flight.
Section	91.151(a)	prescribes	that	no	person	may	begin	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.

We	seek	an	exemption	from	14	CFR	151, as	we	believe	we	

can	achieve	an	equivalent	level	of	safety	by	requiring	an	

operation	to	be	terminated	when	the	indicated	battery	

power	reaches	20%.	This	would	provide	more	than	

sufficient	time	for	the	sUAS	to	return	to	it’s	planned	

landing	zone	from	anywhere	in	the	limited	VSOL	operating	

area.

Section	91.203(a)	prescribes,	in	pertinent	part,	that	no	person	

may	operate	a	civil	aircraft	unless	it	has	within	it:

(1)	An	appropriate	and	current	airworthiness	certificate;	and

(2)	An	effective	U.S.	registration	certificate	issued	to	its	owner	

or,	for	operation	within	the	United	States,	the	second	copy	of	

the	Aircraft	Registration	Application	as	provided	for	in	section	

47.31(c).

Section	91.203(b)	prescribes,	in	pertinent	part,	that	no	person	

may	operate	a	civil	aircraft	unless	the	airworthiness	certificate	

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.

We	request	an	exemption	from	14	CFR	203(a)	and	(b).	

Since	the	UAS	weighs	less	than	3	pounds	carries	no	pilot	or	

crew,	and	has	no	cockpit	or	cabin.	We	propose	to	keep	
these	documents	at	the	ground	control	point	where	the	

PIC	will	have	immediate	access	to	them; to	the	extent	they

are	applicable	to	the	sUAS.

Section	91.405(a)	prescribes,	in	pertinent	part,	that	each	

owner	of	an	aircraft	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,	Maintenance,	Preventive	Maintenance,	Rebuilding,	and	

Alteration.

Section	91.407(a)(1)	prescribes	that	no	person	may	operate	

any	aircraft	that	has	undergone	maintenance,	preventive	

maintenance,	rebuilding,	or	alteration	unless	it	has	been	

approved	for	return	to	service	by	a	person	authorized	under	

section 43.7	of	this	chapter.

Section	91.409(a)(2)	prescribes,	in	pertinent	part,	that	no	

person	may	operate	an	aircraft	unless, within	the	preceding	12	

calendar	months,	it	has	had	an	inspection	for	the	issuance	of	an	

airworthiness	certificate	in	accordance	with	part	21.

Section	91.417(a)	and	(b)	prescribe,	in	pertinent	part,	that:

(a)	Each	registered	owner	or	operator	shall	keep	the	following	

records	for	the	periods	specified	in	paragraph	(b)	of	this	

section:

(1)	Records	of	the	maintenance,	preventive	maintenance,	and	

alteration	and	records	of	the	100-hour,	annual,	progressive,	

and	other	required	or	approved	inspections,	as	appropriate,	

for	each	aircraft	(including	the	airframe)	and	each	engine,	

propeller,	rotor,	and	appliance	of	an	aircraft.

The	records	must	include:
. (i)	A description	(or	reference	to	data	acceptable	to	the	

Administrator)	of	the	work	performed;	

. (ii)	The date	of	completion	of	the	work	performed;	and	

. (iii)	The signature	and	certificate	number	of	the	person	

approving	the	aircraft	for	return	to	service.	

(2)	Records	containing	the	following	information:

. (i)	The total	time	in	service	of	the	airframe,	each	engine,	each	

propeller,	and	each	rotor.	

. (ii)	The current	status	of	life-limited	parts	of	each	airframe,	

engine,	propeller,	rotor,	and	appliance.	

. (iii)	The time	since	last	overhaul	of	all	items	installed	on	the

aircraft	that	are	required	to	be	overhauled	on	a	specified	

time	basis.	

. (iv)	The current	inspection	status	of	the	aircraft,	including	

the	time	since	last	inspection	required	by	the	inspection	

program	under	which	the	aircraft	and	its	appliances	are	

maintained.	

. (v)	The	current	status	of	applicable	airworthiness	directives	

(AD)	and	safety	directives	including,	for	each,	the	method	

of	compliance,	the	AD	or	safety	directive	number	and	

revision	date.	If	the	AD	or	safety	directive	involves	

recurring	action,	the	time	and	date	when	the	next	action	

is	required.	

. (vi)	Copies of	the	forms	prescribed	by	section	43.9(d)	for	

each	major	alteration	to	the	airframe	and	currently	

installed	engines,	rotors,	propellers,	and	appliances.	

(b)	The	owner	or	operator	shall	retain	the	following	records	

for	the	periods	prescribed:
. (1)	The records	specified	in	paragraph	(a)(1)	of	this	section	

shall	be	retained	until	the	work	is	repeated	or	superseded	

by	other	work	or	for	one year	after	the	work	is	

performed.	

. (2)	The records	specified	in	paragraph	(a)(2)	of	this	section	

shall	be	retained	and	transferred	at	the	time	the	aircraft	is	

sold.	

. (3)	A list	of	defects	furnished	to	a	registered	owner	or	

operator	under	section 43.11	of	this	chapter	shall	be	

retained	until	the	defects	are	repaired	and	the	aircraft	is	

approved	for	return	to	service.	

We	request	an	exemption	from	14	CFR	91.405(a),	

91.407(a)(1),	91.409(A)(2),	and	91.417(a)	and	(b)	as	we	

believe	these	sections	apply	only	to	aircraft	with	an	

airworthiness	certificate.	The	applicant	will	meet	all	

maintenance	requirements	as	prescribed	by	the	

manufacturer	in	accordance	with	the	operating	manual.	

This	will	provide	an	equivalent	level	of	safety	given	the	

small	size	of	the	sUAS,	the	proximity	to	the	PIC	during	

flight,	the	short	duration	of	flights	and	the	low	altitude.

In	the	event	of	a	mechanical	issue,	the	sUAS	can	land	

immediately.	The	PIC	will	ensure	the	sUAS	is	in	proper	

working	order	prior	to	initiating	flight,	perform	all	

required	maintenance,	and	keep	a	log	of	any	maintenance	

performed.

Attachments:

-Appendix	“A”	DJI	Inspire	1 Series	Specifications	

-Appendix	“B”	Inspire 1	User	Manual
October	25,	2015

Wolverine Aerial	Imagery,	2808	St.	Aubin,	Detroit,	MI	48207	

Phone:	(609)	792-1097 Email:	genedavis6641@gmail.com

Eugene	Davis	IV

Public	Interest:

Given	the	small	size	of	the	UA	involved	and	the	limited	

environment	within	which	it	will	operate,	its	proposed	

operation	“falls	squarely	within	that	zone	of	safety	(an	

equivalent	level	of	safety)	in	which	Congress	envisioned	that	

the	FAA	must,	by	exemption,	allow	commercial	operations	of	

sUAS	to	commence	immediately.”	Also	because	of	the	size	of	

the	sUAS and	the	restricted	areas	in	which	the	sUAS	will	

operate,	the	petitioner	asserts	approval	of	the	application	

presents	no	national	security	issue.	Additionally,	the	ability	to	

conduct	the	types	of	missions	outlined	in	the	Wolverine	Aerial	

Imagery petition	by	a	craft	significantly	smaller	than a	manned	

aircraft and	carrying	no	passengers,	crew	or	flammable	fuel	

significantly	enhances	safety	to	the	general	public	as	well	as	

those	involved	with	the	mission.

Granting	the	requested	exemptions	is	in	the	public	interest	

because	of	(1)	the	clear	direction	in	section	333	of	Public	Law	

112–95,	(2)	the	strong	equivalent	level	of	safety	surrounding	

the	proposed	operations,	and	(3)	the	significant	public	benefit,	

including	enhanced	safety	and	reduction	in	environmental	

impacts	(such	as	reduced	emissions	associated	with	allowing	

sUAS	for	photography	and	inspection	operations).

Additional	consideration:

The	FAA	has	set	precedence	in	granting	petitions	to	other	

entities	that	propose	to	engage	in	the	same	or	similar	types	of	

activities	under	essentially	the	same	operating	parameters.	
Below	is	a	list	of	exemptions	granted	which	we	believe	engage	

in	operations	similar	to	those	we	propose.

-11062	Astraeus	Aerial

-11109	Clayco	Inc.-11112	VDOS Global

-11213	Aeryon	Labs,	Inc

-11969	High	Ground Images,	LLC	

-11941	soaring	Sky,	LLC

-11940	Aerial	Associates	Photography,	Inc.

-11947	Daniel	C.	Augspurger