Saxon Aerial Drone Services

Leesburg, VA

November 8th, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Ave SE

Washington, DC 20590

SUBJECT: Section 333 of FMRA 2012 sUAS Exemption Request

Dear Sir/Madam,

With safety as our first priority, pursuant to Section 333 of the FAA Modernization and Reform 

Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Saxon Aerial Drone Services, a Virginia

based limited liability company operating a Small Unmanned Aircraft System (sUAS) equipped 

to conduct aerial photography and surveys for various industries, hereby applies for an 

exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our 

sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long 

as such operations are conducted with and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.

The requested exemption would permit Saxon Aerial Drone Services to pursue its commercial 

interests in providing services to consumers interested in aerial data capture using sUAS in 

the following areas:

• Infrastructure Inspections

• Real Estate & Watercraft Photography & Videography

• Agricultural Surveying and Data Collection

• sUAS Operator Training

• Product Demonstration, including Entertainment

• Research and Development

Regulations from which the exemption is requested:

 14 C.F.R. Part 21

 14 C.F.R. 45.23(b)

 14 C.F.R. 61.113(a) and (b)

 14 C.F.R. 91.7(a)

 14 C.F.R. 91.9(b) (2)

 14 C.F.R. 91.109
 14 C.F.R. 91.119

 14 C.F.R. 91.121

 14 C.F.R. 91.151(a)

 14 C.F.R. 91.203(a) and (b)

 14 C.F.R. 91.205(b)

 14 C.F.R. 91.215

 14 C.F.R. (91.401 – 91.417)

We are petitioning for exemption to enable Saxon Aerial Drone Services to operate the 

following sUAS:

 DJI Inspire 1

 DJI Phantom 2 and 3

 PrecisionHawk Lancaster

 3D Robotics Solo

 3D Robotics X8

 Aeryon Labs Sky Ranger

Note: User Manuals for the sUAS proposed in this petition are not included. All of the sUAS 

have been approved in previous Section 333 exemptions and it seemed redundant to attach 

additional manuals. The most recent versions are available on the vendor websites.

Saxon Aerial Drone Services does not currently own each of the sUAS listed above, but 

anticipates purchasing them in accordance to a pre-set business plan.

Saxon Aerial Drone Service pilots place an extraordinary emphasis on safety. It is our first 

priority and crucial to our business as well as the right thing to do.

Saxon Aerial Drone Services at all times will respect the space and privacy of citizens and 

property while keeping our skies safe. 

We respectfully request, without delay, an exemption under Section 333 to enable Saxon 

Aerial Drone Services to operate safe, low-risk commercial sUAS operations for the activities 

stated.

Sincerely,

Ann Carswell

Legal and Insurance Advisor

Saxon Aerial Drone Services

info@saxonaerial.com

1513 Artillery Terrace NE

Leesburg, VA 20176
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Saxon Aerial Drone Services requests an exemption from the following regulations as 

well as any additional regulations that may technically apply to the operation of the sUAS

System:

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While 

the FAA continues to work to develop airworthiness standards for Unmanned Aerial 

Systems, we request an experimental certificate be issued for the DJI Inspire 1, Aeryon 

Labs Sky Ranger, Zero-Tech High One and 3D Robotics AERO sUAS under either or both 

of the following provisions:

21.191 Experimental certificates

Experimental certificates are issued for the following purposes:

(a)Research and development Testing new aircraft design concepts, new aircraft 

equipment, new aircraft installations, new aircraft operating techniques, or new uses for 

aircraft.

(b) Showing compliance with regulations Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market 

surveys, sales demonstrations, and customer crew training, we would expect that an 

experimental certificate would permit our commercial purpose as well. The aircraft will not carry 

persons or property, will not carry fuel, and will only fly under strict operational requirements. 

Combined with the UA's light weight, being constructed primarily of foam, carbon fiber, and/or 

plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally 

certificated aircraft performing the same mission. If an experimental airworthiness certificate is 

not appropriate for this application, then we request an exemption of 14 CFR Part 21, Sub part 

H, and the requirement for an airworthiness certificate in general, citing the equivalent level of 

safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

“EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The sUAS does not have an entrance in which the word "EXPERIMENTAL" can 

be placed, and may not have a registration number assigned to it by the FAA. We propose to 

achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard 

on the top of the aircraft, as shown above, where the PIC, VO and others in the vicinity of the 

aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel 

that the permanent placard discussed in the previous paragraph will provide the aircraft's 

registration information at the ground station. Finally, we will display at the ground station a 

high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in 

letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground 
station, the banner should be visible to anyone that observes the aircraft and chooses to 

investigate its point of origin.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 

61.133 Commercial pilot privileges and limitations

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in 

Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act 

as pilot in command of an aircraft in connection with any business or employment if: (1) The 

flight is only incidental to that business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire. Our proposed operations require that the PIC 

must hold at least a Private Pilot Certificate issued by the FAA and since the aircraft cannot 

carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even 

though the intent of this application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate

As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements

This regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that 

flight manual information is available to the aircrew while operating the aircraft. We request an 

exemption to this requirement since the aircraft is not only too small to carry documentation; 

the documentation would not be available to the crew during flight operations. To obtain an 

equivalent level of safety and meet the intent of 91.9, we propose that a current, approved 

sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is 

in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." The sUAS System groundbased control station consists of a small hand-held radio transmitter and while it does not offer 

a second set of "controls", both the student and instructor can, and will, operate the single set 

of controls simultaneously. With both student and instructor having "hands-on" the controls 

during flight, we feel that this technique meets the intent 91.109 and provides an equivalent 

level of safety.

14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely 

populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, 

vehicle, or structure. Since the typical mission of the sUAS would be photography or survey of 

persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet 

to the items listed. Operations will only be flown over property or persons where permission has 

been obtained and careful pre-planned has been performed. The aircraft will be operated at a 

low altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. Therefore we maintain that due to the small size of the 

sUAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, 

which should be considered in granting the exemption.
14 CFR 91.121 Altimeter settings The regulation requires that aircraft shall maintain cruising 

altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS 

will always fly below 500 feet AGL and will not need to maintain cruising altitudes in order to 

prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the 

takeoff point is transmitted via radio from the sUAS on-board computer to the display screen 

held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy 

reserve as a safety buffer for delays to landing. The sUAS are battery operated and the 

maximum duration of flight from a single battery charge is 12-45 (depending on which sUAS) 

minutes with a 20% reserve. Since the aircraft will never fly more than 1/2 NM from the point of 

intended landing, a full battery charge at launch will ensure that we meet the reserve energy 

requirement of this paragraph. We request an exemption to the word "fuel" and ask for an 

equivalent interpretation with the word "energy". We also request exemption from the 30 min 

reserve and ask that our reserve will be to fly the mission to the point of intended landing and 

have at least a 20% battery reserve after that.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required

The regulation provides that an airworthiness certificate, with the registration number assigned 

to the aircraft and a registration certificate must be aboard the aircraft. Additionally, 

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew." With our largest vehicle, the 3D 

Robotics AERO, at a maximum gross weight of 13 pounds, the sUAS is too small to carry 

documentation, does not have an entrance, and is not capable of carrying passengers or crew. 

To obtain an equivalent level of safety and meet the intent of 91.203, we propose that 

documents deemed appropriate for this aircraft by the FAA will be co-located with the crew at 

the ground control station and available for inspection upon request. In order to identify the 

aircraft, we propose that the information found on airworthiness and registration certificates be 

permanently affixed to the aircraft via placard containing the following information plus the 

word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance 

and inspection of the aircraft and "be authorized to approve the aircraft for return to service." 

The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in 

addition, conduct detailed inspections after every two hours of flight. Maintenance performed by 

the PIC is limited to repairing small cracks, replacing a propeller, checking electrical 

connections and updating software and firmware for the on-board computer. All other 

maintenance will be performed by the manufacturer or their designated repair facility. The PIC 

will document work performed in accordance with 91.417. We feel that due to the size, 

construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.