David Edwards (Daveedwardstv@gmail.com) ·. 2504 Wynnefie1d Dr 

### Havertown. PA 19083

US DeparblLl·:mt OfTransportation Federal AviationAdministration 800 Independence Ave SW Washington DC 20591



### Dear Sir or Madam: 610 823 4699 page 1 

### of7

October 

### 7. 2015

Pursuant 

### to Section 333 

### ofthe FAA Modernization and ReformAct of2012(the reform act) and CFR Part 11 Da:¥id Edwards (Daveedwardstv@gmail.com), owner and operator ofSmall 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 inENG operations and experienced 

### Drone pilot witb ·housands ofhours flying**~n-connnercially.** He is a member of

### the Academy OfModel 

### 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 oflight 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 ofsuch aircraft systems in national airspaee 

### systems." Section 333(c), ofthe ReformAct.



### 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

- 50knots andhave the capability to hover and move inthe 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 lheofsight within a protected flight area as described below and at200 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 ofthe nations**airspace~** public, nor environment.

David Edwards (Daveedwardstv.com) respectfully requests the grant ofauexemption 

### to the following specific sections ofthe Title 14 Code· ofFederal regulations allowing itto operate lightweight UASs for commm'Cial use,

. 14 CFR 21, subpart H, 14 CFR45.23 (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** relieffrom any currently applicable FAR'S operating to prevent David Edwards (Daveedwardstv) future commercial use ofsmall UASs to operate inthe national airspace system as described**below~** The Refonn Act section 332 provides such integration ofcivil unmanned aircraft into
our national airst::ace system as itis 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 ReformAct expressly conternplates the integration ofthese UASs. David Edwards (Daveedwardstv) would like to operate it's light weight UASs priorto the time period by which the Reform Act requires the FAAto promulgate rules governing such aircraft.

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

### The Refor:trtAct directs 

### the Secretary ofTransportation to consider 

### whether certain 

### Ulllll.anned aircraft systems may 

### O:Perate safely in national airspace before completion ofthe mle

### making required under Section 332 oftlle Reform Act. In making this determination, the Secretary ofTransportation is required to determine which UASs do create a hazard to users ofthe national airspace system 

### or the public, orpose
a threat to national security in light ofthe following: 

### The**U.A~;s size~**  

### speed,**weigh~** 

### and operational 

### capability Operation ofthe UASs in close proximity to airports 

### and populated areas Operation ofUASs within visual 

### line ofsight 

### ofthe operator



### Reform Act 333(a). Ifthe secretary determines that such

### vehicles**~~ay** operate 

### safely in

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

DavidEd"'uds (Daveedwardstv) have rotorcraft weighing less than 

### 55 lbs., they operate at speeds less than 50 kno1sj and have the capability to operate inthe horizontal and vertical plane simultaneously. The UASs will operate only 

### within the line ofsight**ofth~** operator 

### within a 

### protected flight area and at 

### 200ft AGL or lE:ss. 

### These will not present 

### a hazard to the national airspace northe public.

The very small nature ofthese UASs combined with the safe guards presented below, will allow for the safe operatic:m greater 1:hanenvisioned by Congress for the FAAto establish and by 

### exemption allow commercial 

### ope•rations ofUASs to commence immediately. Also due to the size ofthe UASs and the
areas and**altitudE~s** they will 

### ope:.-ate. approval ofthis 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 ofthe ReformAct, the 

### authority contained inthe Federal 

### Aviatio11 Act, as amended the strong equivalent level ofenhanced safety, reduced emissions utilizing UASs 

### vc)rses traditional aircraft as well as 

### the economic impact ofgreatly reducing the cost of aerial photography, thereby benefiting the public's interest. Accordingly, the applicantrequests 

### that the FAA grant the rEl([uested exemption without delay.

1:'0 38'\:ld 8080 38I.:L:l0 X3G3.:l tEP2:9680t9page 4 of7 The following will be considered as a binding limitation on operations ofDavid Edwards (Daveedwardst\i),
1) Flights wi.:.l only occur inVFR conditions 

### 2) Flights wi:-.1 be operated in 

### line ofsight 

### ofthe 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 ofoperator(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 ofthe 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 ofthe units to further reduce the chance ofviolating 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** inconjunction 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 ifthe 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 waterthe 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:%8019page 

### 5of7

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


### Subpart tl, 

### entitledAirworthiness Certificates, sets forth requirements for procurement of necessary certificates 

### in relation to FAR 91.203(a)(l). The size, weight. and defined area ofoperations for David**Edward~:** (Daveedwardstv), UASs flight permits exception from Part 21 because the meet an equivalentlevel ofsafety pursuantto Se'*on 333 ofthe 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 ofthe RefoxmAct Bothpieces oflegislation permit the FAA to exempt UASs from airworthiness certificates in**(~onsideration** ofweight,**si~e~** maneuverability, and proximity to areas such as airports and dense populatiottS. DavidEdwards (Daveedwardstv) meets or exceeds each ofthese elements.

As ofMarch 23, 2015 the FAA has stated that itwill 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 ofcivil aircraft certifications and registrations. These are inapplicable for 1he same reasons stated above. The equivalent level ofsafety 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 ofan aircraft without an airworthiness certificate. As no such certificate will he applicable inthe form contemplated by FAR's, this regulation is inapplicable.

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

### inAircraft

14 CFR 9l.9(b)(2) requires an aircraft flight manual inaircraft. As there are no pilots/passengers, and given the size of1he UASs, this regulation is inapplicable. Anequivalent level ofsafety will be achieved by maintaining s:tch certifications andregistrations by David Edwards (Daveedwardstv). The FAA haH previously issued exemptions to this regulation inExemptions No's 8607,8737,8738S 1 299,9299A,9565,9565B,l0167,10167A,10602,10700, and 32827.

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

### 6 of7 14 CFR 91. ll9 Minimum safe altitudes, prescribes safe altitudes for operation ofcivil 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

### tluthas 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 ofconventional and civil aircraft orrotorcraft weighing far more than 50 lbs.• and operating below 500AGL with flanunable fuel) UA.Ss operations present a 

### far smallerrisk to the public.
Approval ofthese 333 Exemptions allowing commercial operations ofsmall UASs inthe service of aerial photography will greatly enhance**s~ety** by reducing the overall risk associated withtraditional aircraft. Traditional aerial photography requires large 

### aircraft 'With tlanunable fuel to fly in close proximity ofpoJmlated areas andpeople ingeneral. With the use ofsmall UASs of55 lbs. or less, battery operated and 

### fly::.ng less than 200 feet 

### AGL. the**~sk** ofinjury to people on the ground or the crewhaas been greatly reduced or almost erased. The granting ofthe use ofthese 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 offree enterprise and the enjoyment ofthe masses. David Edwards (Davee:tlwardstv) is currently, andhas plans in the future to train and promote safe operation of UASs with all

### pi.ots ofunmanned aircraft. David Edwards has also**engag~** conversation with local emergency officials and offered aerial services ifever needed. It is also the responsibility and duty of David Edwards (.)aveedwardstv) to report anyone suspected ofviolating any laws or safety protocol in association with lJASs, as itis importantto maintain a structure ofsafety 

### in the future piloting ofUASs.

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

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page 7 of 7

David Edwards (Da:veedwardstv) respectfully requests the FAAto grant its 

### exemption without delay. 

### The FAAhas the 

### authority to 

### issue the exemption sought by 

### David Edwards (Daveedwatdstv) 

### pursuant to 

### 1he Federal Aviation Act. 85 P.L. 726 (1958) as amended (theACT).

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~**  

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