July 25th 2015

Petitioner:

Daytona Beach Kennel Club Inc.

Jonathan Grimm, Information Technology Manager

960 S Williamson Blvd

Daytona Beach, FL 32114

Tel.: 386.947.3330

Email: jgrimm@delawarenorth.com

Website: www.daytonagreyhound.com

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 

11.81, Daytona Beach Kennel Club Inc., hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of small, unmanned multirotor aircraft for the purpose of low 

altitude competitive racing and video photography of said races. All operations shall be conducted within and 

under the conditions and limitations outlined previously by the FAA as required by Section 333 and conducted in 

compliance with the attached operator’s manuals.

1. Sections from which exemptions are sought: Application is hereby made for exemption from:

a. 14 CFR Part 21, subpart H

b. 14 CFR Part 61.113(a) and (b)

c. 14 CFT Part 91:

i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417

2. Relief sought:

a. Daytona Beach Kennel Club Inc. wishes to operate small unmanned multirotor aircraft for commercial 

purposes to include (but not be limited to) competitive drone racing and video photography.

This relief is sought because commercial use of small unmanned aircraft is currently prohibited by law 

unless performed under an exemption.

b. This exemption will cover use of the following airframes, all of which will weigh less than 55 pounds 

including payload and energy sources:

i. QAV 250 Class Multirotor Drones

ii. Other models to be added by future amendment to this exemption.

3. Public benefit:

a. Use of the Multirotor Aircraft in Racing Events has the following public benefits:

i. Provides a safe and legal environment for Multirotor Aircraft operators to race drones, thereby 

reducing the number of drone racing events held in public and populated areas by small groups 

of operators.
ii. Garners public interest in multirotor racing / operation and provide ongoing education on safe 

operation by qualified community experts.

iii. Races will utilize existing greyhound race track for operation, thereby eliminating the 

environmental noise pollution such racing might bring to other locations such as public parks or 

soccer fields.

4. Safety not adversely affected:

a. Unmanned Multirotor racing events will be contained to our greyhound track (pictured here).

b. During all multirotor aircraft racing events, netting will be in place in front of and above spectator areas 

to ensure the safety of any and all guests.

c. Multirotor aircraft will never exceed an altitude of 100 feet, usually racing around an altitude of 30 feet.

d. Multirotor aircraft will never exceed groundspeed of 70 knots.

e. The Multirotor aircraft races, while adjacent of (Within 5 miles) a local airport, will always be in 

accordance with and hold valid Certificates of Authorization from the FAA as well as seeking additional 

special permission from the Daytona Beach International Airport / Volusia County Airport Control Tower.

f. All flight operations will comply with the following:

i. The manufacturers’ user manuals.

ii. PIC and VO will maintain VLOS at all times.

iii. Pre-flight safety inspections will be performed on multirotor aircraft before events and logged 

by the pilot.

g. Aircraft will use FCC compliant 2.4 GHz for command & control of the multirotor aircraft with welldefined and tested lost link procedures.

h. If a multirotor aircraft loses connection to its transmitter or PIC for any reason, its motors are 

programmed to stop and the multirotor aircraft will fall to the ground. Use of GPS based fail-safes are 

strictly prohibited.

Please advise us of any additional information or changes that may be required.

Sincerely,

Jonathan Grimm

Information Technology Manager, Daytona Beach Kennel Club Inc.