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Stephen C. Denty

8810 Leeshire Lane

Raleigh, NC 27615

919.669.7286

sdenty@nc.rr.com

To: Brittany Newton, Program Analyst and Airspace Rules Division

From: Stephen C. Denty

Subject: Additional Information Requested FAA Letter

Date: August 6, 2015

REFERENCE: ATTACHED LETTER FROM THE FAA DATED JULY 30, 

2015 REQUESTING FURTHER INFORMATION.

Files: 2015-1507-0001, 2015-1507-0002

ENCLOSURES: 

 July 30, 2015 letter from the US DEPARTMENT OF TRANSPORTATION 

/FAA

 Original Exemption Request Paperwork.

In response to your communication to Stephen C. Denty dated July 30, 2015

attached, I am seeking an exemption from the FARs listed below:

14 C.F.R § 61.113(a) & (b);

14 C.F.R § 61.133(a)

14 C.F.R §91.7(a)

14 C.F.R §91.119(c.)

14 C.F.R §91.151

14 C.F.R §91.405(a)

14 C.F.R §91.407(a)(1)

14 C.F.R §91.409(a) &(b)

ANWSER TO THE QUESTION IN YOUR LETTER:

Why will granting the request for an exemption be in the public interest and 

benefit the public as a whole?
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Stephen C. Denty is seeking the exemption set forth in original exemption request 

(attached) to operate commercially a small unmanned vehicle (55 

lbs. or less) in aerial survey operations. Approval of this exemption for commercial 

aerial survey operations will enhance safety by reducing risk. Conventional 

operations, using jet or piston powered aircraft, operate at extremely low altitudes 

just feet from the subject being inspected and in extreme proximity to people and 

structures. Such manned operations present the risks associated with vehicles that 

can weigh in excess of 6,000 lbs., carrying large amounts of jet A or other fuel. 

Such aircraft must fly to and from the project location. In contrast, a sUAS 

weighing fewer than 4lbs. or less and powered by batteries eliminates virtually all 

of that risk given the reduced mass and lack of combustible fuel carried on board. 

The sUAS is carried to the target area and not flown. The sUAS will carry no 

passengers or crew and, therefore, will not expose them to the risks

associated with manned aircraft.

Other reasons why a grant of the exemption would be in the public interest:

 The operator would be able to have access and therefore supply the public 

with more complete data on buildings, aerial surveys, news gathering, 

topography, agriculture and other target areas.

 The general public will gain large amounts of data at a much lower cost than 

with manned aircraft in a shorter period of time.

 Greatly reduced risk in comparison to manned aircraft of all types.

 The risk to onboard pilot and crew during an accident is eliminated with the 

use of a sUAS.

The use of a sUAS increases safety, reduces cost and provides a detailed data 

source and therefore is in the publics best interest as discussed above. 
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Safety

The risk of any proposed sUAS operation in the request for exemption attached 

interfering with manned aircraft is minimized by the low altitude at which the 

sUAS will operate, the location and the FAA airspace requirements. 

Additionally, the petitioner is a certified flight instructor, instrument rated, 

helicopter, airplane with many years of experience both teaching low level 

flight, airspace and safety.

Summary that can be published in the Federal Register proposal:

Docket No. FAA-2015_________

Petitioner: Stephen C. Denty

Sections of 14 CFR: 61.113(a) and (b), 9.7(a), 91.119(b) and (c), 91.121, 91.15, 

91.405(a), 91.407(a)(1) and (2), and 91.417(a)and (b)

Sections of Relief Sought: Petitioner seeks exemption to conduct small UAS 

commercial operations for Aerial Surveying, collect analyse, conduct aerial 

photography, remote sensing, structure assessment, land survey 

photogrammetry, news gathering, construction site inspection and monitoring, 

and industry survey.

Proposed Conditions and Limitations

The small UAS operations previously proposed in the attached Petition is 

consistent with previously granted small UAS Section exemptions and FAA 

guidance. 

All small UAS operation will:

 Have a gross weight less than 55 lbs including all pyload, energy sources 

and equipment.

 Ground speed less than 55 knots
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 Maximum flight time of 25 minutes

 The sUAS will be identified by its serial number and registered with the 

FAA in accordance with FAR Part 47.

 The sUAS will have identification markings (N number) in accordance 

with FAR 45 being as large as practicable.

 The sUAS will operate in accordance with applicable sUAS airspace 

regulations. 

sUAS Manuals

Petitioner is in possession of all operational manuals both printed and 

electronically, also published by DJI the manufacture. The manuals include 

preflight inspections, safe operations and the like. As a licensed pilot, Petitioner 

will follow the required weather minimums and forecasts as published by the FAA 

in METAR, TAF, current radar views, wind, altimeter setting, and other available 

weather information. 

This response to additional information is respectfully submitted.

Stephen C. Denty