To: Ms. Brittany Newton, 

Program Analyst, Airmen and Airport Rules Division 

US Department of Transportation, Federal Aviation Administration 

800 Independence Ave, S.W. 

Washington, D.C.20591 

From: Ron Davison 

4265 Chickadee Circle 

Jackson, WY 83001 

307-690-5720 

ron@rondavison.com 

July 31 5

t, 2015 

Dear Ms. Newton. 

Thank you for your letter dated July 14th. Per your request for additional supporting 

documentation, please consider the following points: 

I sincerely believe that that granting this request will benefit the public as a whole 

because of the following: 

Supporting local business: Low level oblique photos and video from several angles 

are far more effective than ground-based imagery for displaying the characteristics of 

large, complex properties with several buildings and large trees. The alternative could 

be to charter a full-sized helicopter for this purpose, which has proven more costly than 

many potential clients are able to afford. The benefits of reduced cost and improved 

quality of presentation from the UA will be valuable to and benefit many buyers and 

sellers of real property and marine property. 

Helping the community: I am a member of the Teton County CERT (Community 

Emergency Response Team, a FEMA organized, federally recognized organization). I 

report to Rich Ochs, GEM, MEP, Coordinator, Teton County Emergency Management, 

Chairman of the Teton County Local Emergency Planning Committee (LEPC). Rich and 

I are currently drafting a proposal to integrate the use of my unmanned aerial vehicle 

with local emergency responders, search and rescue, and fire fighting operations. Mr. 

Ochs sees the benefit of having a UAV on call to assist with providing live aerial video 

imagery where possible. To put this in context: this past winter, a serious gas explosion 

occurred in town, and the use of a UAV to provide live video of the incident would have 
proved valuable. Although no lives were lost, Rich is of no doubt that having live aerial 

video provided by a UAV would have saved time, allowed for the more effective 

deployment of available resources, and may well have resulted in less property being 

destroyed. The utilization of this UAV would be strictly integrated into the chain of 

incident command, with Incident Operations requesting flight time, directing flight paths, 

and coordinating with existing emergency operations. 

I am willing to provide such UAV support, however, this is contingent upon our being 

granted the exemption from Title 14, Code of Federal Regulations (14 CFR). We 

therefore respectfully request that we be allowed to use our system to benefit first 

responders nearby who might require assistance, including fire fighters, the police, the 

sheriff, et al., while remaining subject to all limitations cited in this application as we do 

so. Should you wish to contact Mr. Ochs, his contact information is listed at the end of 

this letter. 

Safety: The UAV, powered by batteries, is smaller, lighter and more maneuverable than 

larger aircraft running on combustible fuel, it operates at lower altitudes with no people 

on board and will thereby reduce current risk levels and thereby enhance safety and 

diminish the likelihood of death or serious bodily injury. With a small payload and 

maximum flight time of only 18 minutes, this is offers little or no risk to national security. 

I would like to thank you in advance for the time you are devoting to our request. Your 

help is sincerely appreciated. 

Best regards, 

\~~-------- Ron Davison 

Inquiries can also be directed to: 

Rich Ochs, CEM, MEP 

Coordinator, Teton County Emergency Management 

Chairman, Teton County Local Emergency Planning Committee (LEPC) 

PO Box 4458 

3240 S Adams Canyon Drive 

Jackson, WY 83001 

o: (307) 732-8594 

c: (307) 413-5040 

f: (307) 732-5799 

rochs@tetonwyo.org 

www.tetonwyo.org/em 
US Department 

of Transportation 

Federal Aviation 

Administration 

July 14, 2015 

Mr. Ron Davison 

4265 Chickadee Circle 

Jackson, WY 83001 

Dear Mr. Davison: 

800 Independence Ave .. S W 

Washington. DC 20591 

Title 

This letter is to inform you that we are unable to process your request for an exemption from 

14, Code of Federal Regulations (14 CFR). It explains why we can not process your 

request and what you should do in the next 30 days. 

Why We Can Not Process Your Request 

We entered your July 1st 2015, exemption request into the public docket (No. FAA-2015-

2628), but we are unable to process your request any further. The infmmation you sent does 

not comply with the requirements of§ 11.81 (copy enclosed). For us to consider the request 

any further, you must send us all of the following: 

• The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole. 

• Any additional information, views, or arguments available to support your request. 

What You Should Do 

If you want us to process your request any further, you must send the information described 

earlier to reach us within 30 days. Please note that § 11.63( d) requires you to send your 

petition for exemption at least 120 days before the proposed effective date of the exemption. 

Please use the Comment Now Button on the Regulations.gov page to upload any additional 

information to the public docket. 
If We Do Not Hear From You 

If we do not hear from you within 30 days, we will close the docket without notifying you 

further. If you have any questions or require additional time, you may call (202) 267-9677. 

Sincerely, 

-

Brittany 

~~ Newton 

Program Analyst, Aitmen and 

Airport Rules Division 

Enclosure 

2 
eCFR- Code of Federal Regulations 

ELECTRONIC CODE OF FEDERAL REGULATIONS 

e-CFR Data is current as of March 2, 2015 

Title 14- Chapter I -Subchapter 8 -+Part 1'1 -+Subpart A-> §11.81 

Title 14: Aeronautics and Space 

PART 11-GENERAL RULEMAI<ING PROCEDURES 

Subpart A-Rulernaking Procedures 

§11.81 What information must I include in my petition for an exemption? 

Page I of I 

You must include the following information in your petition for an exemption and submit it to FAA 

as soon as you know you need an exemption. 

(a) Your name and mailing address and, if you wish, other contact information such as a fax 

number, telephone number, or e-mail address; 

# (b) The specific section or sections of 14 CFR from which you seek an exemption; 

' (c) The extent of relief you seek, and the reason you seek the relief; 

~'• (d) The reasons why granting your request would be in the public interest; that is, how it would 

benefit the public as a whole; 

,.,. (e) The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from which you 

seek the exemption; 

(f) A summary we can publish in the FEDERAL REGISTER, stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

(g) Any additional information, views or arguments available to support your request; and 

(h) If you want to exercise the privileges of your exemption outside tt1e United States, the reason 

why you need to do so. 

For questions or comments regarding e-CFR editorial conlenl, features, or design, email ecfr@nara.gov. 

For questions concerning e-CFR programming and delivery issues, email webteam@gpo.gov. 

http://www.ecfr.gov/cgi-bin/text-idx?SJD=eee7bb3943bc0292a08fb8b9feb89c23&node=sc... 3/4/2015 

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