U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE Washington, DC 20590 

Exemption Request Section 333 of the FAA Reform Act 

To Whom It May Concern, 

11/11/2015 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, William 

A Latocki, hereby applies for exemptions from the following Federal Aviation Regulations (FARs) in order to 

operate a Small Unmanned Aircraft System (sUAS) for commercial applications in airspace that is governed by 

the Federal Aviation Administration {FAA). All flight operations will be conducted under the conditions and 

boundaries outlined herein or as established by the FAA in accordance with Section 333. 

The exemptions, as requested by William A Latocki, would permit the provision of commercial services to 

customers that are in need of aerial data capture from a sUAS. William A Latocki requests these exemptions in 

order to perform commercial flights in the following areas: 

I 

1. Aerial photography and/or video for public and/or private use including real estate, architecture, 

agriculture, land surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, public events, and 

cinematography. 

3. Aerial inspection/photography of residential/commercial structures under contract with the owners 

or local government authority. 

All flights will be conducted over private or controlled access property with the consent and knowledge of the 

property owner or controlling party. All flight operations will maintain a 500 foot buffer from all nonparticipating 

persons, vessels, vehicles, and structures unless sufficient barriers are in place to protect nonparticipating 

persons from undue harm. Flight operations will also only be operated near vessels, vehicles, and structures 

where the property owner/controller has granted permission and a safety assessment has been made. 

Regulations from which an exemption is requested: 

14 CFR 61.113(a) 

14 CFR 91.7(a) 

14 CFR 91.119(c) 

14 CFR 91.121 

14 CFR 91.151{a) 

14 CFR Subpart E (91.401- 91.417) 

FAR Section 333 Exemption Request- William A Latocki 

Page 1 of 5 
THE UNMANNED AIRCRAFT SYSTEM 

Due to the low cost of operation, increased safety to surrounding persons and property, reduced noise and 

environmental impact, and the versatility of the sUAS platform, we believe that a sUAS can be a great solution to 

consumers who would, otherwise, have to hire a larger aircraft, such as a helicopter, in order to capture the 

data that they need. 

William A Latocki is seeking this exemption in order to operate a 3DR Solo Quadcopter [2015] Manufactured by: 

3D Robotics, 1608 4th Street, Suite 410, Berkeley, CA 94710. The 3DR Solo Quadcopter is equipped with a 3-axis 

gimbal and 1080p camera. 3DR safety failsafe features equipped ensuring safe operations include: 

• Geo-fence capability that will limit the height and horizontal distance that the 3DR Solo Quadcopter can 

fly from the operator. 

• RTL mode- In the case of low battery or lost communication between the Phantom and the operator, 

the 3DR Solo Quadcopter will return to the point of takeoff and land itself. This mode can be manually 

turned on by the operator at any point in the flight. 

• Land mode- Loss of GPS signal will engage land mode. The 3DR Solo Quadcopter will land automatically 

at its current position if in a flight mode that requires GPS signal. 

• Telemetry radio communication provides real time feedback of flight data, including current altitude, 

latitude, altitude change rate, and GPS coordinates. 

Aforementioned safety features have undergone rigorous testing procedures by 3DR as well as William A 

Latocki. Logs and descriptions of each safety test flight performed by William A Latocki are available upon 

request. These safety features combined with the PIC's knowledge obtained during flight training will 

successfully mitigate operation safety risks. 

FLIGHT OPERATIONS 

The operator and PIC will guarantee that operations adhere to strict standards as set below: 

• The PIC must show that they are able to safely operate the UAS in a safe manner before proceeding with 

operations. 

• The UA will be operated at airspeeds below 29 knots. 

• The UA will be operated below 400 feet above ground level (AGL) at all times. 

• The UA will be operated within visual line of sight (VLOS) at all times. 

• All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight 

(VLOS) of the PIC and VO at all times. 

• The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding traffic and 

other ground based obstacles. 

• Proper preflight inspections will take place before each flight. 

• The UA may not operate within 5 nautical miles of an airport reference point unless a letter of 

agreement with that airport's management is obtained. 

Page 2 of 5 

FAR Section 333 Exemption Request- William A Latocki 
• The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud 

or when visibility is less than 3 statute miles from the PIC. 

• The PIC must maintain a battery reserve that allows the UA to return to point of landing at normal cruise 

speed and land with 30% battery poWer. 

• The UA must remain clear of and yield to all other air traffic. 

• Flight operations will remain 500 feet from all nonparticipating persons, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the 

event of an accident. b. All participating persons will be made aware of the dangers of flying a UA and 

the safety precautions and features that are in place. c. The aircraft is operated near vessel, vehicles, or 

structures where the property owner/controller has granted permission and the PIC has made a safety 

assessment in regard to the close operation to these objects. d. Operations near the PIC or VO do not 

present an undue hazard to the PIC or VO per 91.119(a). 

• All operations will be conducted over private or controlled-access property with prior permission from 

the property owner/controller or authorized representative. 

By following the strict safety standards set by William A Latocki, the FAA, and the physical safety properties 

of the sUAS, will allow for safe and efficient operations. 

William A Latocki hereby requests exemption under Section 333 in order to pursue commercial sUAV 

applications wi~e intent to provide customers with the safest, highest quality platform available. 

/ 

/ 

Sincerelyr \ 

/ 

William A La ocki 

166 Orchard Street 

Michigan Center, Ml 49254-1227 

FAR Section 333 Exemption Request- William A Latocki 

Page 3 ofS 
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

William A Latocki requests an exemption from the following regulations as well as any additional regulations 

found by the FAA to be necessary for safe and efficient UAS flight operations. 

14 CFR 61.113(a), Private pilot privileges and limitations: Pilot in command 

This regulation states that no person holding a private pilot certificate may act as pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as pilot in command of an aircraft. We believe that a PIC with a private pilot 

license has sufficient skill and knowledge to complete operations, especially after completing a sUAS 

knowledge and training course. We do not think that a commercial pilot license will significantly improve a 

PIC's performance while operating a UAV. Therefore, we ask for an exemption from 14 CFR 61.113(a) in 

order to operate commercially with the minimum of a private pilot license. 

14 CFR 91.7(a) Civil aircraft airworthiness 

As a UAS will not require an airworthiness certificate, we believe that this regulation is not applicable. 

Therefore, we request exemption from this regulation. 

14 CFR 91.119(c) Minimum safe altitudes 

This regulation states that no person may operate an aircraft below 500 feet above the surface as well as 

within 500 feet of any person, vessel, vehicle, or structure. We believe that, because of the nature of most 

UAS operations, an exemption is required in order to allow operation closer than 500 feet to vessels, 

vehicles, or structures as long as permission is granted from the owning/controlling parties and an 

assessment is made to assure that people and property are safe from undue harm. We also request that 

operations be allowed over congested areas as long as the operations stay within the following standards: 

• Flight operations will remain 500 feet from all nonparticipating persons, vehicles, and structures 

unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in 

the event of an accident. 

b. Participating persons are made aware of the dangers of the UAS operation and the safety 

precautions that have been put into place. 

c. The aircraft is operated near vessel, vehicles, or structures only where the property 

owner/controller has granted permission and the PIC has made a safety assessment in regard to the 

close operation to these objects. 

d. Operations near the PIC or VO do not present an undue hazard to the PIC or VOiJer 91.119(a). 

e. All operations will be conducted over private or controlled-access property with prior permission 

from the property owner/controller or authorized representative. 

Page 4of 5 

FAR Section 333 Exemption Request- William A Latocki 
14 CFR 91.121 Altimeter settings 

As our UAS does not utilize a standard barometric altimeter, we request exemption from 91.121 to the extent 

necessary to comply with applicable conditions and limitations. The altimeter reading for our UAS is calculated 

by GPS. The accurate and continuous readings that we receive from this GPS system allow us to operate our 

drone below set minimums at all times. 

14 CFR 91.151(a) Fuel requirements for flight in VFR conditions 

This regulation states 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, after that, fly for an additional30 minutes. This 

regulation is intended to create a safe flying environment by creating sufficient fuel reserves. Therefore, we do 

not request an exemption from this regulation but, instead, request that the term "fuel" be changed to "battery 

power." We also request that our battery power reserve for our UAS operations be 30%. 

Our UAS has capabilities that allow the PIC to monitor battery power levels as well as a return to land feature 

that will engage when battery levels reach a critical level, therefore returning the UAS automatically to the point 

of takeoff. 

14 CFR Subpart E (91.401- 91.417) 

l 

William A Latocki requests an exemption from the stringent maintenance regulations that are designed to 

increase the safety of the flying environment by ensuring adequate inspections and servicing of aircraft. We are 

requesting exemption from these regulations because we believe that, due to the simplicity and the ease of 

repair, general and preventive maintenance can be performed by the PIC. The PIC is required to make a 

thorough preflight inspection before each operation. In the case of a discovery of faulty equipment, most 

replacement and repair can simply be done on site as long as repairs are of an airworthy manner. Major repair 

will still have to be performed by a licensed repair facility which will be logged in the UAS records. We believe 

that our comprehensive preflight inspection, the simplicity of the UAS itself, the nature of the UAS's operations, 

and the fact that no passengers are on board the aircraft make our operations eligible for exemption from CFR 

Subpart E (91.401- 91.417). 

Thank you for the consideration of these exemptions. 

Sincerely, 

William A Latocki 

166 Orchard Street 

Michigan Center, Ml49254-1227 

FAR Section 333 Exemption Request- William A Latocki 

Page 5 of 5