Contact Info:

Edmund Taylor

22017 SE 240th Pl

Maple Valley, WA 98038

toddtaylor@johnlscott.com

http://www.toddtaylor.johnlscott.com/

Exemption Request 

Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from: 

 14 CFR 21 subpart H 

 14 CFR 45.23(b) 

 14 CFR 61.113(a) and (b) 

 14 CFR 91.7(a) 

 14 CFR 91.9(b)(2) 

 14 CFR 91.103 

 14 CFR 91.109 

 14 CFR 91.119(c) 

 14 CFR 91.121 

 14 CFR 91.151(a) 

 14 CFR 91.203 (a) and (b) 

 14 CFR 91.405 (a) 

 14 CFR 91.407 (a) (1) 

 14 CFR 91.409 (a)(1) and (2) 

 14 CFR 91.417(a) and (b) 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR 

Part 11, Edmund Taylor, operator of Unmanned Aircraft Systems (UAS), hereby applies for an exemption 

from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of designated UAS, 

provided such operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333. 

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

and sensors, would provide professional services in the following areas: 

1. Aerial photography and/or video for public and/or private use including real estate, 

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

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

owners or local government authority. 

As described fully below, the requested exemption would permit the operation of designated 

UAS as set forth in this document under controlled conditions in the NAS that would be a) 

limited b) controlled c) predetermined and d) safe. Approval of this exemption would increase 

public awareness of UAS operations and enhance safety to aid in fulfilling the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “....establish requirements 

for the safe operation of such aircraft systems in the national airspace system.” 
I plan to operate a UAS, the DJI PHANTOM 3 Professional which is comprised of an unmanned aircraft 

(UA or Phantom 3) and a transportable ground station. The Phantom 3 is referred to as a quad-copter 

with a maximum gross weight of about 3 pounds. It is equipped with four rotors that are driven by 

electric motors powered by batteries. The UA has a maximum airspeed of 16 m/s. 

Also, given the small size of the UAS’s involved and the restricted controlled environment within 

which they will operate, the applicant fits within that zone of safety (an equivalent level of safety) 

in which Congress envisioned that the FAA must, by exemption, allow commercial operations of 

UASs to commence immediately. Also due to the size of the UASs and the controlled areas in 

which the relevant UASs will operate, approval of the application presents no national security 

issue. 

Given the following, the grant of the requested exemptions is clearly in the public interest: 

 Edmund Taylor proposes that the exemption requested herein apply to civil aircraft that have 

the characteristics and that operate with the limitations listed herein. 

 These limitations provide for an exceptional level of safety to operations. 

 These limitations and conditions to which Edmund Taylor agrees to be bound when conducting 

commercial operations under an FAA issued exemption including: 

1. The UAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of operator. 

3. Maximum total flight time for each operational flight will be 30 minutes. 

4. Flights will be terminated at 15% battery power reserve. 

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

6. UAS operator will be trained and certified in the proper safety and operations of the UAS. 

7. The UAS will only operate within a controlled area as defined in the Procedures. 

8. The operator will post advisor notice around the controlled area. 

9. The operator will have been trained in operation of UAS generally and received up-to-date 

information on the particular UAS to be operated as required. 

10. If the UAS loses communications or loses its GPS signal, the UAS will have capability to 

return to a pre-determined location within the Security Perimeter and land. 

11. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and 

are prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. We look forward to working with your office. Please contact us at any time if 

additional information or clarifications are needed. 

Sincerely, 

Edmund Taylor