Rappucci	Petition Page	1

Daniel	Scott	Rappucci

393	Lynetree	Drive

West	Chester,		PA	19380

drappucci@gmail.com,	610-513-0484

July	30th,	2015

U.	S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,

SE	Washington, DC	20590

Exemption	Request Under Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal	

Aviation	Regulations

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

Part	11,	I,	Daniel	Rappucci,	preparing	this	exemption	request	myself,	would	like	to	apply	

for	an	exemption	from	the	following	Codes of	Federal	Regulations	(C.F.R) in	order to	be	

allowed	commercial	operation	of an Unmanned	Aircraft	System (UAS)	for	aerial	imaging	

and	video	of boats	located	on	the	Chesapeake Bay	and	adjacent	rivers.

I	have spent	the	last	two	years	flying	a	DJI	Phantom	2 UAS as	a	recreational	hobby,	and	I	

recently	purchased	a	waterproof	UAS	called	the	“SplashDrone”. The	SplashDrone	is	very	

similar	to	the	DJI	Phantom	in	terms	of	shape,	weight, flight	performance	and	operation	of	

the	controls.	The	primary	difference	is	that	the	SplashDrone	is	completely	waterproof	and

the	frame	is air tight, which	allows	the	SplashDrone to	land	safely	on	the	water	as	opposed	

to	sinking.	The	specifications	of	the SplashDrone	are	as	follows:	weight	3.85	lbs,	maximum	

horizontal	flight	speed	of	13mph,	maximum	vertical	flight	speed	of	9mph,	operating	

frequency	2405	to	2475MHZ,	powered	by	a	14.8	volt	battery, maximum	distance	of	

1,000km	from	the	controller, and	capable of	flying	for	approximately	14	minutes.	The	

SplashDrone	also	has	the	ability	to	carry	a	“GoPro	Hero	3” camera, which	is mounted	to	the	

belly in	between	the	landing	gear.

I	am	submitting	this	request	because	I	would	like	to	provide a	video/photo service	for

customers	such	as local	boat	owners	and	boat	brokerage	firms who	are	interested	in	

obtaining video	and/or	photo footage	of	their	respective	boats. Many	boat	owners	and	

brokerage	firms have	a	desire	for areal	photography	because	they	want	the	footage	for

personal	reasons	or	because	the	footage	is	useful	when	attempting	to	sell	a	boat.	The	

current	method	of	obtaining	areal	footage requires	the	use	of	a	helicopter, and	customers	

typically pay between	one	and	two	thousand of	dollars	for the areal	photography. I	would	

like	to	provide	a	service	in	which the	SplasDrone is	used to	capture	the	footage rather	than

the	need	for a	helicopter.	Operation of	the	SplashDrone	is	obviously much	cheaper than	

that of	a	helicopter,	and	the	significant	cost	savings	would	directly	benefit	the	customers	in	

the	form	of much lower	prices	for	their	desired	footage. Furthermore,	the	use	of	the	

SplashDrone is safer	and	more	environmentally	friendly	than	the	use	of	a	helicopter.
Rappucci	Petition Page	2

In	order	to	safely	capture	areal	footage of	boats I	have	come	up	with	the	following	criteria:

Safety	Precautions

• I	will	operate	the	SplashDrone	while	onboard	the	boat	that	I	am	filming so	that	I	

have	constant	line	of	sight	with	the	UAS

• I	will	employ a	spotter	at	all	times	acting	as	a	second	set	of	eyes,	watching	the	UAS

and	watching	for	any	potential	obstacles	or	obstructions	

• Boats	will	only	be	filmed	in	secluded,	unoccupied,	wide-open areas and	NEVER

filmed	in	shipping	channels, other	marked	channels, or	in	close	proximity	to	

marinas,	land, bridges,	over	head	power	lines, or near any other	obstructions

SplashDrone	Operating	Precautions

• The	drone	will	be	flown	at	an	elevation	less	than	200	feet	and	will	stay	within	200	

feet	of	the	boat	that	is	being	filmed at	all	times

• Preflight	checks	will	be	performed,	including	but	not	limited	to	checking	all	

hardware, wire	connections,	GPS	connection, operation	of motors, operation	of

sensors,	and	flight	controls

• During	flight,	I	will	monitor	battery	life	of	the	UAS,	altitude,	distance	from	the	boat,	

and	GPS	location	via	the	LED	screen	on	the	remote	controller	

Finally,	I	will	abide by all	FAA	requirements	to	ensure	this	exemption	will	provide	a	level	of	

safety	at	least	equal	to	existing	rules	and	will	only	operate	in	a	safe	environment	that	is	

strictly	controlled.

In	order	to	pursue	my	goal	of	areal	photography	I	am	requesting	that	I	be	exempt	from	the	

following:

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates and 14	C.F.R.	Part	91,	Subpart	

C, §	91.203:	Equipment,	Instrument,	and	Certificate	Requirements

Given the	size,	weight,	speed,	and	limited	operating	area	associated	with	my	UAS, and	the	

fact	that	my	UAS	does	not	have	an	official	identification	number I	am	asking	exemption	

from	14 CFR part21, Subpart	H(Airworthiness	Certificates)and§91.203	(a)(1),	(a)(2) and	

(b)	(Certifications	required).		I	will	meet	the	level	of	safety	associated	with	the	issuance	of	

Airworthiness	Certificates	by	adhering to	the	criteria	listed	at	the	top	of	this	page. I	will	

also	keep	a	logbook	of	each	flight	and	perform	all	maintenance	in	accordance	with	the	

manual	provided	with	the	SplashDrone.

14	C.F.R.	Part	45,	Subpart	C:	Nationality	and	Registration	Marks

I	request	an	exemption	from	each	item	within	Part	45,	Subpart	C:	Nationality	and	

Registration	Marks.	Given	the	small	size	and	design	of	my	UAS	there	is	no	place	for	marks	

to	be	visibly	seen	by	other	aircraft.	Also,	my	UAS	does	not	have	a	registration	number	so	
Rappucci	Petition Page	3

nothing	can	be	presented.	I	have,	however,	marked	the	front	of	the	UAS	with	red	tape	and	

LED	lights.	This	allows	anyone	near	the	UAS	to	quickly	identify	the	front	and	determine	the	

flight	path	of	the	UAS	thus	adding	a	level	of	safety.	

14	CFR Part	61,	Subpart	B:	Aircraft	Ratings	and	Pilot	Authorizations

I	request	an	exemption	from	each	item	within	Part	61,	Subpart	B. I	am	unable	to	obtain	any	

of	the	criteria	for	pilot	authorizations because	the	criteria	within	subpart	B	calls	for	a	

minimum	number	of	hours	to	be	logged	using	a	flight	simulator	or	other	training	device,	

but	there	are	no	flight	simulators	for	UASs.	I	have	had	approximately	75	hours	of	

recreational	flight	time	with	my	UAS,	and	I	have	spent	most	of	that	time	practicing	the	skills

needed	to	master	maneuvering	the UAS.	Also,	I	would	be	happy	to	take	a	class	for	UAS	

flight	if	provided	by	the	FAA	or	another	sanctioned governing	body. To	ensure	that	I	uphold	

a	proper	level	of	safety	I	will	continue	to	log	additional	hours	of	flight time that	are	

dedicated	to	practicing	simple	and	complex	maneuvers.	These	“practice”	flights	will	take	

place	on	my	property	at	an	altitude	less	than	50	feet.	

14	C.F.R. Part 91,	Subpart	B,	§91.105:	Crew	Members	at	Stations

I	request	an	exemption	from	item	§91.105	which	states	that	all	crew	members	must	be	

safely	fastened	at	crew	stations.	My	UAS	does	not	have	anyone	onboard,	but	I	will	employ	a	

crew	member to	work	with	me	as	a	spotter	to	monitor	the	UAS. I	believe	that	this	system	of	

employing	a	spotter	will	ensure	that	I	uphold	a	level	of	safety	that	meets	the	general	

requirements	outlined	within	Part	91.	

Below	is	a	brief	summary	of	the	exemptions	that	I	am requesting	along	with	a	brief	

description	of	the	nature	of	the	exemptions:

I,	Daniel	Rappucci,	seek	exemption	from	the	requirements	of	14	C.F.R.	sections:

• Part	21,	Subpart	H,	every	item	within	subpart	H

• Part	91,	Subpart	C,	91.203

• Part	45,	Subpart	C,	every	item	within	subpart	C

• Part	61,	Subpart	B,	every	item	within	subpart	B

• Part	91,	Subpart	B,	91.105

This	exemption	will	allow	me	to	commercially	operate	a	UAS	for	the	purposes	of	

conducting	areal	photography	of	boats	located	on	the	Chesapeake	Bay	and	adjacent	rivers. I	

will	offer	this	areal	photography	service	to	customers	such	as	boat	owners	and	boat	

brokerage	firms	who	are	seeking	affordable	areal	footage	of	their	respective	boats. This	

will	benefit	the	customers	because	the	footage	will	be	significantly	cheaper	than	the	

current	method	of	using	a	helicopter	to	capture the photos. Also,	the	community	as	a	whole	

will	benefit	from	the	zero	emissions	UAS as compared	to	a	helicopter	which	runs	on	jet	fuel.	
Rappucci	Petition Page	4

Respectfully	submitted,

__________________________________________

Daniel	Scott	Rappucci

393	Lynetree	Drive

West	Chester,	PA	19380

drappucci@gmail.com

610-513-0484