Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations

To whom it may concern:

I respectfully request exception under Section 333 of the FAA Modernization Reform Act of 

2012 and 14 CFR Part 11 of the Federal Aviation Regulations to allow commercial operation of 

a small UAS, so long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by section 333.  I have flown for over 

15 years as a private, commercial, and now ATP in the U.S airspace system and many years 

flying remote controlled aircraft as a hobby.  I will draw on my many years of experience to 

operate a UAS commercially in the safest way possible.

Petitioner:

Taylor Davis

34 Lockwood Lane

Norwalk, Ct 06851

(203) 559­2810

I intend to use an Unmanned Aircraft System for various projects which may include but are not 

limited to aerial surveying; aerial photography and filmmaking; real estate; search and rescue; 

construction management; agricultural projects, etc.

Sections Seeking exemption:

14 CFR 61.23(a) 

14 CFR 61.101(e)(4)(5)

14 CFR 61.113(a)

14 CFR 61.315(a)

14 CFR 91.7(a)

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(a)(1)

14 CFR 91.405(a)

14 CFR 91.407(a)(1)

14 CFR 91.409(a)(1)(2)

14 CFR 91.417(a)(b)

Extent of relief requested:

To permit commercial operation of small unmanned aircraft systems for operations conducted 

within and under the conditions outlined herein or as may be established by the FAA as required 

by Section 333.

Said exemption would permit the operation of UAS under controlled conditions in limited, 

predetermined and controlled airspace. Upon granting of this proposed exemption request, I 
would conduct commercial operations of UAS meeting or exceeding all operational and safety 

requirements per Section 333.

Public Benefit:

1) Project and construction management, inspections and monitoring. The use of UAS on 

construction sites may improve the safety of workers, local residents and general public by 

assessing potential dangerous situations. Falls and injuries may be reduced or eliminated 

through a more thorough review of the construction sites. In some cases, UAS may reduce the 

reliance of helicopters or small aircraft to monitor said sites. This may improve safety as well  as 

reduce environmental impact by reducing energy usage;

2) Aerial surveying. The use of UAS in connection with aerial surveying of smaller areas may 

eliminate the use of helicopters or aircraft. This could provide a more cost effective, safer and 

more energy efficient product;

3) Agricultural projects. Wildlife and Forestry projects. The use of UAS could assist with 

surveying agricultural projects as well as wildlife and forestry projects by providing information 

when problems occur, vermin infestation, fire hazards, etc.;

4) Remote Sensing projects. The use of UAS could provide views and information for remote 

and inaccessible areas. This could promote worker safety as well as reduce the reliance on 

helicopters and aircraft;

5) Educational and Research projects. The use of UAS could provide information for said 

projects in a more cost effective and efficient manner than other available options;

6) Aerial filmmaking, photography and real estate purposes. The use of UAS may provide a 

point of view previously unavailable through other means. They would be more cost effective, 

efficient and more safely than helicopters and aircraft; and

7) Search and rescue. The use of UAS may provide assistance to local law organizations during 

search and rescue missions. UAS may reach areas unattainable or viewable with helicopters 

and aircraft. UAS may be implemented quicker as time is of the essence during search and 

rescue operations.

Reasons why the exemption would not adversely affect safety or how the exemption 

would provide a level of safety at least equal to the existing rule.

Proposed operations using UAS provide increased safety enhancement especially when

compared with helicopters and aircraft for the following reasons:

1. The UAS will weigh less than ten (55) pounds;

2. Flights will be operated within the visual line of sight of the pilot;

3. Maximum total flight time for each operational flight will be thirty (30) minutes. Flight

times may be less than thirty (30) minutes as the UAS will continuously monitor battery reserve 

and return to the ground station with at least 20% battery power reserved;

4. Flights will be operated at an altitude of 200 feet AGL. Flights will never exceed 400 feet AGL;

5. Minimum crew for each operation will consist of the UAS pilot in command, the visual 

observer when needed and may include but not limited to a camera operator;

6. A briefing will be conducted daily by all personnel working with said UAS;
7. All onsite personnel and client employees will be required to execute a waiver. Verbal/written 

consent will be required of all persons within 100 feet of flight operation;

8. Written and/or oral permission from relative property owners will be obtained prior to 

operating the UAS;

9. All permits, permissions, etc. will be obtained from local government offices as required;

10. The UAS operated will weigh less than 55 pounds including payload (camera, lens,

gimbal, etc.); and

11. The UAS will operate at speeds less than 50 knots, hover and simultaneously move

vertically and horizontally;

12. The UAS will have the capability to return and land at the predetermined location with

the Security Perimeter should the UAS lose communication or GPS signal during any 

operations;

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

emergencies;

14. Operations will not be conducted over densely populated areas or heavily traffic

highways; and

15. Operations will not be conducted within five (5) NM of an airport or heliport.

I will abide by all regulations including the following:

1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. Airworthiness

Certificates;

2. 14 C.F.R. 45.23 Display of marks; general and 45.29 Size of marks;

3. 14 C.F.R. 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133

Commercial pilot privileges and limitations;

4. 14 C.F.R. 91.7 Civil aircraft airworthiness;

5. 14 C.F.R. 91.9 Civil aircraft flight manual, marking and placard requirements;

6. 14 C.F.R. 91.109 Flight instruction; Simulated instrument flight and certain flight tests;

7. 14 C.F.R. 91.119 Minimum safe altitudes: general;

8. 14 C.F.R. 91.121 Altimeter settings;

9. 14 C.F.R. 91.151 Fuel requirements for flight in VFR conditions;

10. 14 C.F.R. 91.203 Civil aircraft: Certifications required;

11. 14 C.F.R. 91.205 Powered civil aircraft with standard category U.S. airworthiness 

certificates: Instrument and equipment requirements;

12. 14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use;

13. 14 C.F.R. 91.401 Applicability;

14. 14 C.F.R. 91.403 General;

15. 14 C.F.R. 91.405 Maintenance required;

16. 14 C.F.R. 91.407 Operation after maintenance, preventive maintenance, rebuilding or 

alteration;

17. 14 C.F.R. 91.409 Inspections;

18. 14 C.F.R. 91.411 Altimeter system and altitude reporting equipment tests and inspections;

19. 14 C.F.R. 91.413 ATC transponder tests and inspections;

20. 14 C.F.R. 91.415 Changes to aircraft inspection programs; and

21. 14 C.F.R. 91.417 Maintenance records.
Privileges of exemption outside the United States.

I may wish to exercise the privileges of this exemption outside the United States should a 

contract with a governmental office require same. All required rules and regulations will be 

followed should this occur.

Equipment and Specifications

.3DR SOLO KIT ~ 3DR solo, 3DR Solo Gimbal, 3DR Solo Controller, 3DR Solo Propeller Set –  

Black, 3DR Solo Battery Charger, 3DR Solo Controller Charger

Specifications:

Up to 26 minutes of flight time (20 with camera and Solo Gimbal),

HD video streaming to mobile

Top speed: 55 mph

Max Altitude: 400ft, per FAA rules

Weight: 1600 g; 1760 g with Solo Gimbal and GoPro

Wifi range: up to a half a

mile, depending on environment

Controller with color screen and live flight data

Pixhawk 2 flight controller software

Customizable color LEDs for orientation

Solo Battery: 14.8 V LiPo (5200mAh)

Rechargeable controller batter: 2600 mAh/7.2 Vdc; lasts 4 hou

rs (extendable battery available)

10x4.5 self tightening props

880 kV motors

Plug and play with 3 ­ axis Solo Gimbal from 3DR

Please feel free to contact our office if there are any additional questions or concerns.