' ........ 

Docket Operations, 

M-30 U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. Room W12-140, 

West Building Ground Floor Washington, DC 20590-0001 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act Of 2012 and CFR Part 11, 

DAVIDE CALDA, Videomaker and photographer, owner and operator of Small Unmanned Aircraft 

Systems (UAS's), request to be exempted from the Federal Aviation Regulations (FAR's) listed 

below so may operate UAS's commercially within airspace regulated by the FAA, as long as such 

operations are conducted within and under the conditions outlined here in or as may be 

established by the FAA as required by Section 333. 

As described below, the requested exemption would permit the operation of light weight (less than 

55 lbs. total take off weight) UAS's under controlled conditions for commercial use by myself 

thereby enhancing safety and fulfilling the Secretary of Transportation's responsibility to "establish 

requirements for safe operation of such aircraft systems in national airspace systems." Section 

333(c), of the Reform Act. 

Davide Calda's Drone is rotorcraft weighing less than 55 pounds including payload (DJI Phantom 

3 Quad Copter). They operate at a speed less than 50 knots and have the capability to hover and 

move in the vertical and horizontal plane simultaneously. The DJI Phantom 3 has an auto return to 

the departure point when exceeding the manufacturers recommended distance from the controller, 

when the signal between the controller is lost or when battery power is under 25%. The UAS will 

be operated within "line of sight" in a protected flight area at 200' AGL or less. These operations 

will not create a hazard to users of the nations airspace or the public. 

Davide Calda submits this application in accordance with the Reform Act, 112 P.L. 95 331:334, 

seeking relief from any currently applicable FAR's operating to prevent commercial use of small 

UAS's to operate in the national airspace system as described below. The Reform Act Section 332 

provides for such integration of civil unmanned aircraft into our national airspace system as it is in 

the public's interest to do so. I meet the definition of "small unmanned aircraft" as defined by 

Section 331 and therefor the integration of theses UAS's are expressly contemplated by the 

Reform Act. I would like to operate it's light weight UAS's prior to the time period by which the 

Reform Act requires the FAA to promulgate rules governing such aircraft. The Reform Act directs 

the Secretary of Transportation to consider whether certain unmanned aircraft systems may 

operate safely in national airspace before completion of the rule making required under Section 

332 of the Reform Act. In making this determination, the Secretary of Transportation is required to 

determine which UAS's do create a hazard to users of the national airspace system or the public or 

pose a threat to national security in light of the following. The UAS's size, speed, weight and 

operational capability. 

• Operation of the UAS's in close proximity to airports and populated areas. 

• Operation of the UAS's within visual line of sight of the operator. 

Reform Act 333(a). If the secretary determines that such vehicles "may operate safely in the 

National Airspace System, the secretary shall establish requirements for the safe operation in 

national airspace. 
Davide Calda will be using rotorcraft weighing less than 55 lbs and operate at speeds less than 50 

knots with the ability to operate in the vertical and horizontal plane simultaneously. The UAS's will 

operate only within "line of sight" of the operator within a protected flight area and at 200' AGL or 

less. This will not present a hazard to the national airspace or the public. 

The very small nature of these UAS's combined with the safe guards presented below, will allow 

for the safe operation greater than that envisioned by Congress for the FAA to establish and by 

exemption allow commercial operations of UAS's to commence immediately. Also due to the size 

of UAS's and the areas and altitudes they will operate approval of this exemption presents no 

national security issues and absolutely minimal safety concerns which have been mitigated 

through our rigorous risk management process. Given the clear direction given in Section 333 of 

the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong 

equivalent level of enhanced safety, reduced emissions utilizing UAS's versus traditional aircraft as 

well as the economic impact of greatly reducing the cost of aerial photography thereby benefitting 

the greater public's interest. Accordingly, the applicant requests that the FAA grant the requested 

exemption without delay. 

The following will be considered as the Standard Operating Procedures (SOP) : 

1.Fiights will only occur between sunrise and sunset. 

2.Fiights will be operated in the line of sight of the operator (PIC). 

3.Fiights will be terminated at any time weather and wind deteriorate to "unsafe for flight" based on 

manufacturer's limitations. 

4.The UAS's will weigh less than 551bs. 

5.Fiights will be operated at less than 200' AGL. 

6.The UAS's operator will perform a check of the flight area and make certain of the safety of all 

persons in the area. 

?.Consent will be obtained from all persons within the video capabilities to ensure their privacy. 

8.AII required FAA clearances will be obtained and distances from airports strictly adhered too. 

9.AII UAS's will have the capability to return automatically to the operator in a safe manner with the 

auto return function checked and working. 

1 O.Fiights will only operate in VFR conditions. 

11.UAS controllers display range and remaining battery power. 

12.AII preflight checks will be done prior to each flight. 

13.AII routine inspections and maintenance will be done in accordance as specified by DJI. 

14 CFR, Part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7 (a), 91.203(a)(1) 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of 

operations for Drone View Aerial Photo UAS's flights permits exemption from Part 21 because 

they meet an equivalent level of safety pursuant to Section 333 of the Reform Act. Both pieces of 

legislation permit the FAA to exempt UAS's from airworthiness certificates in consideration of 
weight, size, speed, maneuverability and proximity to areas such as airports and dense 

populations. Davide Calda meets or exceeds each of these items. 

As of March 23, 2015 the FAA has stated that it will automatically grant a "blanket" COA for flights 

at or under 200' AGL to any UAS operators with a Section 333 Exemption. 

14 CFR, Part 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. 

These are inapplicable for the same reasons stated above. The equivalent level of safety will be 

achieved by maintaining such certifications and registrations by Drone View Aerial Photo. 

14 CFR, Part 91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As 

no such certificate will be applicable in the form contemplated by the FAR's this regulation is 

inapplicable. 

14 CFR, Part 91.9(b)(2) requires an "Civil Aircraft Flight Manual" in aircraft. As there are no pilots 

or passengers and given the size of the UAS's this regulation is inapplicable. 

The FAA has previously issued exemptions to this regulation in Exemptions 8607, 8737, 8738, 

9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 332827. 

14 CFR, Part 91.119 Minimum safe altitudes prescribes safe altitudes for operation of civil 

aircraft .. It allows helicopters to be operated at lower altitudes under certain conditions. Davide 

Calda will only operate it's UAS's at or below 200' AGL. They will be operated in a well defined 

area of operation that has been carefully reviewed for hazards and minimizes the presence of any 

persons not essential for these operations. Flights will only be over private property with the 

owner's consent. 

Approval of these 333 Exemptions allowing commercial use of small UAS's in the service of aerial 

photography will greatly enhance safety by reducing the overall risk associated with traditional 

aircraft. Traditional aerial photography requires large aircraft with fuel potentially flying over or in 

close proximity to populated areas. With the use of small battery powered UAS's of 55 lbs or less 

the risk of injury to people on the ground is drastically reduced. 

Granting Davide Calda the above exemption will allow for the expansion of the use of UAS's 

aircraft in the future for the safe conduct of free enterprise. 

Davide Calda respectfully requests the FAA grant it's exemption without delay. The FAA has the 

authority to issue this exemption pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as 

amended (the act). 

Sincerely, 

DAVIDE CALDA VIDEOMAKER & PHOTO 

2725 South Lockwood Ridge Rd 

Sarasota 34239 FL 

Phone (941) 284 2428 

Davide. calda@gmail.com