David Edwards (Daveedwardstv@gmail.com) ·. 

2504 Wynnefie1d Dr 

Havertown. PA 19083 

US DeparblLl·:mt Of Transportation 

Federal Aviation Administration 

800 Independence Ave SW 

Washington DC 20591 

Dear Sir or Madam: 

610 823 4699 

page 1 of7 

October 7. 2015 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012(the reform act) and 

CFR Part 11 Da:¥id Edwards (Daveedwardstv@gmail.com), owner and operator of Small Aircraft 

Systems(UAS's):. request to be exempted from the Federal Aviation Regulations listed below so that 

Daveedwardstv Iil.ay operate VAS's commercially in airspace regulated by the FAA~ as long as such 

operations are c·onducted within and under the conclitions outlined herein or as established by the FAA as 

required by SecliL>n 333. 

Daveedw-ardstv (Daveedwardstv.com) is owned by David Edwards. David Edwards is an award 

'Winning photojollmalist and conunercial videographer certified in ENG operations and experienced 

Drone pilot witb ·housands of hours flying ~n-connnercially. He is a member of the Academy Of Model 

Aeronautics(AN.L\) and monitors FAA flight restrictions before operating UAS's. David Edwards also 

has a valid Pennsylvania Drivers License and insu.rance. All operations will be performed with the 

public's safety a:nd right to privacy safeguarded at all times. 

8080 38!.:1.:10 X3Q3.:1 1Et:'Z968019 
page2of7 

As descrlbc:d below~ the :requested exemption would permit the operation of light weight (less tha.n 55 

lbs. total takeo:fl' weight) UAS's under controlled conditions for commercial use by pilot David Edwards 

and a trained spotter, thereby enhancing safety and fulfilling the Secretary ofTransportation~s (the FM 

Administrator'·s) responsibility to '~establish requirements for safe operation of such aircraft systems in 

national airspaee systems." Section 333(c), of the Reform Act. 

David Edwards (Daveedwardstv.com) UAS's are rotorcraft weighing less than 55 lbs. including 

payload. David ndwards owns a DJI Inspire 1 and a Phantom Quadcopter. Each operate at a speed less 

- 50 knots and have the capability to hover and move in the vertical and horizontal plane 

simultaneously . .Both have an auto return. to launch point when battery power is under 25%. The UAS will 

opeJ:ate within lhe of sight within a protected flight area as described below and at 200 feet AGL or less 

wifb an observc:r(spotter) located close at hand as to make voice communication possible, These 

operations willli.ot create a hazard to users of the nations airspace~ public, nor environment. 

David Edwards (Daveedwardstv.com) respectfully requests the grant of au exemption to the 

following specific sections of the Title 14 Code· of Federal regulations allowing it to operate lightweight 

UASs for commm'Cial use, 

. 14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109~ 91.119, 

91.121. 91.151, (a), 91.203(a) &(b), 91.405(a)(l). 91.409(a)&(b). 

David Edwards (Da.veedwardstv) submits this application in accordance with the Refonn Act, 112 P. 

L. 95 331-334, f;c~king relief from any currently applicable FAR'S operating to prevent David Edwards 

(Daveedwardstv) future commercial use of small UASs to operate in the national airspace system as 

described below~ The Refonn Act section 332 provides such integration of civil unmanned aircraft into 

our national airst::ace system as it is the public's interest to do so. David Edwards (Daveedwardstv) UASs 

meet the definiti.cn of''sm.all umnanned aircraft" as defined in Section 331 and therefor the Reform Act 

expressly conternplates the integration of these UASs. David Edwards (Daveedwardstv) would like to 

operate it's light weight UASs prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such aircraft. 

E0 39'v'd 8080 38I.:l.:IO X3Q3.:1 1Et>6968019 
page 3 of7 

The Refor:trt Act directs the Secretary of Transportation to consider whether certain Ulllll.anned aircraft 

systems may O:Perate safely in national airspace before completion of the mle making required under 

Section 332 of tlle Reform Act. In making this determination, the Secretary of Transportation is required 

to determine which UASs do create a hazard to users of the national airspace system or the public, or pose 

a threat to national security in light of the following: 

The U.A~;s size~ speed, weigh~ and operational capability 

Operation of the UASs in close proximity to airports and populated areas 

Operation ofUASs within visual line of sight of the operator 

Reform Act 333(a). If the secretary determines that such vehicles ~~ay operate safely in National 

A..irspace SysteJr.;, the secretary shall establish requirements for safe operation in national airspace.'' 

David Ed"'uds (Daveedwardstv) have rotorcraft weighing less than 55 lbs., they operate at speeds 

less than 50 kno1sj and have the capability to operate in the horizontal and vertical plane simultaneously. 

The UASs will operate only within the line of sight ofth~ operator within a protected flight area and at 

200ft AGL or lE:ss. These will not present a hazard to the national airspace nor the public. 

The very small nature of these UASs combined with the safe guards presented below, will allow for 

the safe operatic:m greater 1:han envisioned by Congress for the FAA to establish and by exemption allow 

commercial ope•rations ofUASs to commence immediately. Also due to the size of the UASs and the 

areas and altitudE~s they will ope:.-ate. approval of this exception presents no national security issues and 

absolutely m.iniJ.r:al safety concems which have been mitigated through my rigorous risk management 

process. Given tJ:.e clear direction given in Section 333 of the Reform Act, the authority contained in the 

Federal Aviatio11 Act, as amended the strong equivalent level of enhanced safety, reduced emissions 

utilizing UASs vc)rses traditional aircraft as well as the economic impact of greatly reducing the cost of 

aerial photography, thereby benefiting the public's interest. Accordingly, the applicant requests that the 

FAA grant the rEl([uested exemption without delay. 

1:'0 38'\:ld 8080 38I.:L:l0 X3G3.:l tEP2:9680t9 
page 4 of7 

The following will be considered as a binding limitation on operations of David Edwards 

(Daveedwardst\i ), 

1) Flights wi.:.l only occur in VFR conditions 

2) Flights wi:-.1 be operated in line of sight of the operator (PIC) and Observer (VSO) 

3) Flights will be terminated at ~y.time weather and wind deteriorate to '~safe for flight'" by 

manufact-..:rers recommendations 

4) The UASs 'Will weigh less than 55lbs 

5) Flights will be operated at 200 feetAGL or less 

6) Crew willl ·:.e at a minimwn of operator(PIC) and an observer and/or camera operator(VSO) 

7) Operator ,£t:tld crew will remain in contact during the flight operation 

8) The UASs operator will perform a check of the flight area and make certain the safety ofall persons 

in that an:::a. 

9) Consent ·~ill be obtained by all persons within the video capabilities of the units to further reduce 

the chance of violating anyone's privacy 

1 0) All requind FAA clearances will be obtained and distances from airports strictly observed. 

11) All UASs will have the capability to return automatically to operator in a safe manner with the 

auto return function checked and working 

12) When op~~ating in conjunction with fishing vessels, a chase boat will be assigned to operate the 

UAS at a safe distance from the main boat. 

13) UASs have a function on the control to tell the operator distance, altitude~ and battecy levels 

14) Flight team will communicate by voice and the use of two-way radio if the area is too large to hear 

voice fron all team members 

15) UASs will be used to video private outings and functions~ boating, sports events from a safe 

distance, and real estate properties. 

16) When OJ~·nting over or near water the UASs will be equipped with flotation devices so recovery 

can be made as to prevent lithium battery exposure to the water. 

90 39\l'd 8080 38!..:!..:10 X3Q3.::l lEPZ:%8019 
page 5 of7 

14 CFR21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(l) 

Subpart tl, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary certificates in relation to FAR 91.203(a)(l). The size, weight. and defined area of operations for 

David Edward~: (Daveedwardstv), U ASs flight permits exception from Part 21 because the meet an 

equivalent level of safety pursuant to Se'*on 333 of the Reform Act. The FAA is authorized to exempt 

aircraft from th.e airworthiness certificate requirement under both the Act( 49 USC 4470(£) and Section 

333 of the Refoxm Act Both pieces oflegislation permit the FAA to exempt UASs from airworthiness 

certificates in (~onsideration of weight, si~e~ maneuverability, and proximity to areas such as airports and 

dense populatiottS. David Edwards (Daveedwardstv) meets or exceeds each of these elements. 

As of March 23, 2015 the FAA has stated that it will automatically grant a "ibJ.anket" COA for flights 

at or under 400 AGL to any UAS operator with a section 333 exemption. 

14 CPR 91.2,J3(a&b) provides for canying of civil aircraft certifications and registrations. These are 

inapplicable for 1he same reasons stated above. The equivalent level of safety will be achieved by 

maintainittg sud:. certifications and registTations by David Edwards (Daveedwardstv.com) at his 

operations centt~l~ 

14 CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As no such 

certificate will he applicable in the form contemplated by FAR's, this regulation is inapplicable. 

14 CFR 91.9·0) )(2) Civil Aircraft Flight Manual in Aircraft 

14 CFR 9l.9(b )(2) requires an aircraft flight manual in aircraft. As there are no pilots/passengers, and 

given the size of 1he UASs, this regulation is inapplicable. An equivalent level of safety will be achieved 

by maintaining s:tch certifications and registrations by David Edwards (Daveedwardstv). 

The FAA haH previously issued exemptions to this regulation in Exemptions No's 

8607,8737,8738S1

299,9299A,9565,9565B,l0167,10167A,10602,10700, and 32827. 

90 38\:td 8080 3:JI.:l.:l0 X303.:1 1Et>Z%8019 
page 6 of7 

14 CFR 91. ll9 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It 

allows helicopitt:l!S to be operated at lower altitudes in certain conditions. David Edwards 

(D~veedwardst\'), will only operate its UASs at or below 200 AGL. They will be operated on a well 

defmed AOR tlut has been carefully reviewed for hazards and minimizes the presence of any persons not 

essential for tbe ~e operations. Flights will only be performed on private property when the owner has 

consented and all persons within the video area have consented to this fihning. Compared to fight 

operations of conventional and civil aircraft or rotorcraft weighing far more than 50 lbs .• and operating 

below 500 AGL with flanunable fuel) UA.Ss operations present a far smaller risk to the public. 

Approval of these 333 Exemptions allowing commercial operations of small UASs in the service of 

aerial photography will greatly enhance s~ety by reducing the overall risk associated with traditional 

aircraft. Traditional aerial photography requires large aircraft 'With tlanunable fuel to fly in close 

proximity of poJmlated areas and people in general. With the use of small UASs of 55 lbs. or less, battery 

operated and fly::.ng less than 200 feet AGL. the ~sk of injury to people on the ground or the crew haas 

been greatly reduced or almost erased. The granting of the use of these small UASs by David Edwards 

(Daveedwardstv), will give people anotJurr aven\fe to express themselv~s and to have a video to share with 

family, friends, and customers forever. 

Granting David Edwards (Daveedwardstv) the above exe;mption will allow for further expansion of 

UAS systems DJ\tJ the future for safe conduct of free enterprise and the enjoyment of the masses. David 

Edwards (Davee:tlwardstv) is currently, and has plans in the future to train and promote safe operation of 

UASs with all pi.ots of unmanned aircraft. David Edwards has also engag~ conversation with local 

emergency officials and offered aerial services if ever needed. It is also the responsibility and duty of 

David Edwards (.)aveedwardstv) to report anyone suspected of violating any laws or safety protocol in 

association with lJASs, as it is important to maintain a structure of safety in the future piloting ofUASs. 

L0 39'\i'd 8080 38 I..:L:IO X3Q3..:1 1Et>l968019 
....... ----------------

page 7 of 7 

David Edwards (Da:veedwardstv) respectfully requests the FAA to grant its exemption without delay. 

The FAA has the authority to issue the exemption sought by David Edwards (Daveedwatdstv) pursuant to 

1he Federal Aviation Act. 85 P.L. 726 (1958) as amended (the ACT). 

Sincerely, 1\ 

David Edwards ~ (Daveed\vardstv@gmail.com) 

2504 Wy1mefield Dr 

Haverto'\1\n. PA 19083 

lEt>Z%8019 

80 3Sl'V'd 8080 __________________ 381~~0 X3G3~ ..........