211	Abshire	Cir	

Ardmore,	OK		73401	

580-465-7253	

06/30/2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Texoma Drone and Rescue (TD&R) for an Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 

To whom it may concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 

14 C.F.R. Part 11, Texoma Drone and Rescue, hereby applies for an exemption from the Federal 

Aviation Regulations ("FARs") identified below, to allow commercial operations of small 

unmanned aerial vehicles (i.e., "small unmanned aircraft" or "UAS"). 

This exemption is made based on the information in this petition, as well as the accompanying 

Texoma Drone and Rescue, Maintenance and Safety Manual ("Operations Manual") Petitioner 

submits this supporting material as confidential documents under 14 C.F.R. § 11.35(b), as they 

contain confidential commercial and proprietary information that the Petitioner has not and will 

not share with others. Similarly, these documents contain operating conditions and procedures 

that are not available to the public and are protected from release under the Freedom of 

Information Act, 5 U.S.C. § 552 et seq., and any other requirements established by the FAA 

pursuant to Section 333 of the FAA Reform Act. 

This exemption request will permit Texoma Drone and Rescue to operator commercially for the 

purpose of collecting aerial photography and videography used to support a broad variety of 

inspection and ground truth operations. Also to assist local government agencies in search and 

rescue operations using thermal imagining. 

We request a summary grant, as we have designed our petition, operations, and chosen UAV to 

not set precedent over previously approved exemptions. 
Texoma Drone and Rescue seeks the requested exemptions in order to provide optical and 

thermal sensor data acquired from UAS platforms to perform light industrial inspection, search 

and rescue, survey and ground truth photography and videography. 

TD&R employs a DJI s900 with DJI A2 flight controller. A complete description of the system is 

included in the attached operations manual. The S900 has received approval for use in 

Exemption 11326 (PPL Electric Utilities Corp), and Exemption 11400 (McKenna Long & 

Aldridge LLP). Our proposed use is similar in all material respects as those being used in 

Exemption Nos. 11062, 11109, 11112, and 11213. 

Public Interest 

Commercial use of UAS to perform aerial data gathering in support of the following industries: 

Construction site photography and mapping, precision agriculture, pipeline/power line 

transmission/distribution towers, tower inspection, manmade/natural disaster damage 

assessment, support to first responders, security, construction, research, wildlife and wildfire 

monitoring, real estate, local infrastructure such as bridges, surveying, scientific studies, 

insurance functions, training, mining and UAS research and development. All of these activities 

are critical to the well-being of the general public. 

The use of an UAS provides much improved data for decision making. The technical 

combination of platform, sensor and software, allows us to rapidly acquire and organize data that 

previously had to be obtained by manned inspection, such as roof or tower inspection. 

This petition for exemption is submitted in accordance with the Section 333(a) through (c) of the 

FAA Modernization and Reform Act of 2012. Congress has directed the FAA "to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace system." 

Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned 

aircraft systems to operate in the National Airspace System ("NAS") where it is safe to do so 

based on the following considerations: 

The UAS's size, weight, speed, and operational capability; 

Operation of the UAS in close proximity to airports and populated areas; and 

Operation of the UAS within the visual line of sight of the operator. 

Additionally, the FAA Administrator has general authority to grant exemptions from its safety 

regulations and minimum standards when the Administrator decides a requested exemption is in 

the public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 

U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a), (b) and§§ 44702-44716, et seq.). A 

party requesting an exemption must explain the reasons why the exemption: (1) would benefit 

the public as a whole, and (2) would not adversely affect safety (or how it would provide a level 

of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). 

III. Texoma Drone and Rescue Proposed UAS Operations Meet the Requirements of Section 333 

of the Reform Act. 
The proposed operations in this petition for exemption qualify for expedited approval under 

Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are 

satisfied. 

a. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability 

Texoma Drone and Rescue will employ the DJI S-900, DJI Inspire 1, DJI Phantom 2/3 for its 

infrastructure inspection operations. This UAS all fall under the altitude, weight and speed 

restrictions set by the FAA. All flights will be flown in such a way that they can be safely 

terminated with a reserve battery power of 25% maximum charge. This UAS do not carry any 

flammable propellant or fuel. 

The DJI S-900 / DJI Phantom 2 or 3 / Inspire 1 also has redundant motor capabilities, and the 

vehicle is still capable of flight in the event a motor fails unexpectedly. The vehicle is capable of 

compensating for an engine loss automatically and action is not required by the PIC. 

The DJI S-900 / DJI Phantom 2 or 3 / Inspire 1 also has features that can alert the PIC to the 

possibility of a lost link before it occurs. Because the video link is at a shorter wavelength than 

the control links, it is more susceptible to loss than the control link. Loss of the video signal 

warns the PIC that action should be taken to ensure continued control. In the event the control 

link is lost, the UAS is also equipped with a failsafe setting that permits the vehicle to return to a 

preselected home point. 

Given the small size of the selected UAS and the restricted environment within which they will 

operate, this petition for exemption falls within the zone of safety, i.e., an equivalent level of 

safety, in which Congress directed the FAA to permit commercial UAS operations by exemption 

pending completion of formal rule making. 

b. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations 

Manual 

c. Manufacturer’s maintenance and flight manuals contain all of the procedures and limitations 

necessary to successfully perform the proposed operation. To assist the FAA in its safety 

assessment of TD&R’s operations, below is a summary of operational limitations and conditions 

which will ensure an equivalent or higher level of safety for operations conducted under current 

regulatory guidelines: 

1. The UAS will adhere to it published maximum takeoff weight as outlined in in the operations 

manual. 

2. The radio frequencies used for operations and control of the UAS will comply with the Federal 

Communications Commission ("FCC") or other appropriate government oversight agency 

requirements. 

3. Minimum crew for each operation will consist of a pilot, who will be Pilot-in Command 

("PIC") of the UAS, and one or more Visual Observers ("VO") necessary to safely conduct the 

mission. 
4. The UAS shall be operated within Visual Line of Sight ("VLOS") of the PIC and VO at all 

times. The PIC will use human vision unaided by any device other than corrective lenses. 

5. The VO designated for any operation will be in constant voice contact with the PIC. 

6. The additional requirements identified in the exemption grant shall be added to the TD&R 

Operations Manuals. The Operations Manual will be maintained and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and limitations in the 

granted exemptions and the TD&R Operations Manuals, the conditions and limitations in the 

granted exemptions shall take precedence and must be followed. Otherwise, TD &R must follow 

the procedures outlined in their Operations Manuals. 

7. Maximum total flight time for each operational flight will be limited to the amount of time the 

UAS can be flown and still maintain a reserve battery power of no less than 25%. 

8. Flights will be operated at an altitude of no more than 400 feet AGL and will not be conducted 

within navigable airspace. 

9. Flights will be operated at a lateral distance of at least 500 feet from any inhabited structures, 

buildings, vehicles or vessels, or from people not associated with the operation who have not 

given permission in advance of the operation. 

10. The Pilot will have a private pilot's license, will be trained in accordance with the Operations 

Manual and will pass a company imposed flight evaluation. 

11. The Visual Observer designated for any operation will be required to complete the training 

course as set forth in the Operations Manual before performing his duties on any flight. 

12. The UAS will operate in accordance with the safety and operational requirements of the 

Operations Manual and manufacturer’s flight manual. 

13. Prior to the operation, a Mission Plan will be created setting forth the limitations for the 

flight as well as contact and hazard information provided by the utility. 

14. A NOTAM will be issued not more than 72 hours in advance of flight, but not less than 48 

hours before flight. 

15. The PIC and Visual Observer will at all times be able to communicate by voice. 

16. A Certificate of Authorization will be obtained prior to flight. 
17. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 

18. The operator will coordinate all flights with the appropriate Flight Standards 

District Office. 

19. If the UAS loses communications or loses its GPS signal, the UAS will have the capability to 

return to a pre-determined location within the operational area and land. 

20. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the pilot and the observer. 

21. The UAS will have the capability to safely abort flight in the case of unpredicted obstacles or 

emergencies. The PIC will abort the flight in the event of unpredicted obstacles or emergencies 

in accordance with the TD&R’s Operations Manuals. 

Regulations from which exemption is requested and equivalent level of safety 

a. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) 

The regulation requires: 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 

of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of 

these criteria demonstrates that the UAS operated without an airworthiness certificate, in the 

rural sparsely populated environment and under the conditions proposed will be at least as safe, 

or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness 

certificate without the restrictions and conditions proposed. 

Equivalent Level of Safety: 

The UAS to be operated is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials, and operates exclusively within a secured area as set out in the 

Manual. Unlike other civil aircraft, the proposed operations in this petition for exemption will be 

controlled and monitored by the operator, pursuant to the Manual's requirements. Moreover, the 

FAA will have advance notice of all operations conducted under this exemption. 
These safety enhancements, which already apply to civil aircraft operated in connection with 

existing inspection operations, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UAS, due to its size, speed of operation, location 

of operation, lack of explosive materials, and inability to carry a substantial external load. 

b. 14 C.F.R. Part 27: Airworthiness Standards: Normal Category Rotorcraft. 

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent the Petitioner's UASs would otherwise require certification 

under Part 27, as a rotorcraft, Petitioner requests an exemption from Part 27’s airworthiness 

standards for the same reasons identified in the exemption request from 14 C.F.R. Part 21, 

Subpart H. 

c. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements 

The regulation requires: 

14 C.F.R.§ 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides 

that: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with Part 45 of this chapter. 

14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

When marks include only the Roman capital letter "N" and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light-sport, "experimental," or "provisional," as applicable. 

14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the 

cabin, fuselage, boom, or tail the marks required by§ 45.23. In its previous Grant of Exemption, 

the FAA determined that exemption from these requirements was warranted provided that the 

aircraft "have identification (N-Number) markings in accordance with 14 CFR part 45, Subpart 

C if the markings are as large as practicable." FAA Docket No. FAA-2014-0352. 

Note: 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the 

UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the UAS, two-inch lettering will be impossible. 

The word “Experimental” will be placed on the vehicle frame in compliance with §45.29 (f). 

Equivalent level of safety: 
The equivalent level of safety will be provided by marking the sUAV’s appropriate identification 

with lettering as large as practicable. The FAA has issued the following exemptions to this 

regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

d. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. 

The regulation provides: 

14 C.F.R. § 91.9(b)(2), which states: 

(b) No person may operate a U.S.-registered civil aircraft 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved airplane or Rotorcraft Flight 

Manual, approved manual material, markings, and placards, or any combination thereof. 

Given its size, configuration, and load capacity, the UAS has no ability to carry such a manual on 

the aircraft, not only because there is no pilot on board, but because there is simply no room or 

capacity to carry such an item on the aircraft. 

Equivalent Level of Safety

The safety related purpose of this manual requirement can be equally satisfied by maintaining the 

UAS flight manual at the ground control point where the pilot flying the UAS will have 

immediate access to it. Accordingly, Petitioner requests an exemption from §91.9(b)(2)'s flight 

manual requirements, on the condition that the UAS flight manual be available at the control 

point during each operation. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

e. 14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration. 

The regulation provides: 

14 C.F.R. § 91.203 (a) and (b). 

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it 

the following: 

(1) An appropriate and current airworthiness certificate 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew. 

In addition to the fact that Petitioner is seeking an exemption from the airworthiness certificate 

requirements, an exemption to this regulation is necessary because (a) the UAS’s load capacity 

and size does not allow it to carry certification and registration documents; (2) the UAS does not 

have a cabin or cockpit entrance at which the documents could be displayed; and (3) there are no 

passengers or crew for whom the certificates need be displayed. 

Equivalent Level of Safety: 

To the extent these regulations are applicable to the proposed UAS operations, an equivalent 

level of safety will be achieved by keeping these documents at the ground control point where 

the pilot flying the UAS will have immediate access to them. 
The FAA has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 

10700. 

f. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness. 

The regulation provides: 

14 C.F.R. § 91.7(a), which requires that a civil aircraft be in an airworthy condition to be 

operated. 

Equivalent Level of Safety: 

As there will be no airworthiness certificate issued for the aircraft, should this exemption be 

granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of 

the aircraft and the requirements contained in the DJI S900 & S1000 User’s Manual for 

maintenance and use of safety check lists prior to each flight. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

g. 14 C.F.R. § 91.103: Preflight Action 

The regulation provides: 

14 C.F.R. §91.103, which requires a PIC to become familiar with specific information before 

each flight, including information contained in the FAA-approved Flight Manual on board the 

aircraft. While the PIC will be familiar with all information necessary to safely conduct the 

flight, an exemption is requested to the extent that an FAA-approved Flight manual is required. 

Equivalent Level of Safety: 

An equivalent level of safety will be provided by following the Aircraft Operations Manual and 

flight manual provided by the manufacturer. The PIC will take all required preflight actionsincluding performing all required checklists and reviewing weather, flight battery requirements, 

landing and takeoff distance, aircraft performance data, and contingency landing areas - before 

initiation of flight. The Aircraft Operations Manual and manufacturer's flight manual will be kept 

at the ground station with the operator at all times. 

h. 14 C.F.R. § 91.109(a): Flight Instruction 

The regulation provides: 

14 C.F.R. § 91.109(a): which provides that "[n]o person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls." UASs and remotely piloted aircraft, by their design, do not have 

functional dual controls. Instead, flight control is accomplished through the use of a device that 

communicates with the aircraft via radio communications. 

Equivalent Level of Safety[DA1]: 

Given the size and speed of the UAS, an equivalent level of safe training can still be performed 

without dual controls because no pilot or passengers are aboard the UAS, and all persons will be 

a safe distance away in the event that the UAS experiences any difficulties during flight 

instruction. 
The FAA has approved exemptions for flight training without fully functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K 

& 9862A. 

i. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

The regulation provides: 

14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft 

may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, 

or structure in non-congested areas. See 14 C.F .R. § 91.119( c). Section 91.119( d) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated "without 

hazard to persons or property on the surface," provided that "each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA." 

Equivalent Level of Safety: 

Risk is significantly reduced compared to flight operations with rotorcraft weighing far more 

than the maximum UAS weight proposed herein, and given the lack of flammable fuel, any risk 

associated with these operations is far less than those that presently exist with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the 

UAS, as well as the location where it is operated. In order to avoid any risk to aircraft, flight 

operations will be restricted to 400' AGL or below. As set forth in the Manual, the UAS will be 

operated in a restricted area, away from persons or structures not involved in the operation. 

j. 14 C.F.R. § 91.121: Altimeter Settings 

The regulation provides: 

14 C.F.R.§ 91.121: which requires a person operating an aircraft to maintain cruising altitude or 

flight level by reference to an altimeter that is set to the elevation of the departure airport or 

barometric pressure. An exemption is required to the extent that the UAS does not have a 

barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Safety: 

The FAA has stated that an equivalent level of safety can be achieved if the UAS will be 

operated at 400' or below and within visual line-of-sight in addition to GPS based altitude 

information relayed in real time to the operator. See Grant of Exemption to Astraeus Aerial, 

Docket No. FAA-2014-0352. As the attached Operations Manual indicates, the chosen UAS 

meets these requirements, and a zero altitude initiation point will be obtained prior to flight. 

k. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

The regulation provides: 

14 C.F.R.§ 91.151(a) fuel requirements for flight in VFR conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to the first point of intended landing 

and, assuming normal cruising speed – 

(1) During the day, to fly after that for at least 30 minutes; or 
(2) At night, to fly after that for at least 45 minutes. 

Here, the technological limitations on UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30 minute reserve. Texoma Drone and 

Rescue proposes that all flights comply with this requirement by mandating that the aircraft be 

safely landed with no less than 25% of battery life remaining. 

Equivalent Level of Safety: 

The FAA has stated that an equivalent level of safety is provided if the UAS flight is terminated 

with at least 25% reserve battery power still available. See Grant of Exemption to Astraeus 

Aerial, Docket No. FAA-2014-0352. The Operations Manual conforms to this limit, providing an 

equivalent level of safety. 

l. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b):Maintenance Inspections. 

The regulation provides: 

14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b): 

These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 

43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft “[s]hall 

have that aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections . . . have discrepancies repaired as prescribed in part 43 of this chapter”). An 

exemption to these regulations is needed because Part 43 and these sections apply only to aircraft 

with an airworthiness certificate, which the UAS will not have. 

Equivalent Level of Safety: 

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the Aircraft Operations Manual as referenced in the available 

Manual. As provided in the Manual, the operator will ensure that the UAS is in working order 

prior to initiating flight, perform required maintenance, and keep a log of any maintenance 

performed. The operator is the person most familiar with the aircraft and best suited to maintain 

the aircraft in an airworthy condition to provide the equivalent level of safety. 

If mechanical issues arise, the UAS can land immediately and will be operating from no higher 

than 400 feet AGL. Moreover, the UAS's small size, carrying capacity, and the fact that flight 

operations will only take place in restricted areas for limited periods of time, create less risk than 

the same factors associated with conventional fixed-wing aircraft and rotorcraft performing the 

same operation. 

m. 14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in 

Command. 

The regulation provides: 

§§ 61.113 (a) and (b), which states: 

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds 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. 

(b) A private pilot may, for compensation or hire, 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. 

Equivalent Level of Safety: 

As required by the Manual, Petitioner's UAS operators acting as PIC will hold either an airline 

transport, commercial, private, recreational, or sport pilot certificate. Because the UAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety to 14 C.F.R. §§ 61.113 (a) and (b). 

Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely 

controlled with no passengers on board. Moreover, the area of operation is controlled and 

restricted, and all flights are planned, coordinated, and briefed to the appropriate official in 

advance as set forth in the Manual. 

Texoma Drone and Rescue can achieve an equivalent level of safety as achieved by current 

Regulations because the UAS do not carry any pilots or passengers. Further, while helpful, a 

pilot license will not ensure remote control piloting skills, though Texoma Drone and Rescue’s 

training program will ensure the PIC has substantial experience on the airframe. The risks 

inherent to the operation UAS are far less than the risk levels in the commercial activities 

outlined in 14 C.F.R. § 61, et seq. Thus, allowing TD&R to operate its UASs as proposed will 

exceed current safety levels in relation to 14 C.F.R. §§ 61.113 (a) and (b). 

DRUG AND ALCOHOL POLICY 

Texoma Drone and Rescue will have policies in place to ensure that no person may participate in 

UAS flight operations if they are under the influence of alcohol or any drug. 

PRIVACY 

All TD&R operations will be conducted in accordance with applicable federal, state, or local 

laws regarding privacy. All operations conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. 

VIII. SUMMARY OF SECTION 333 EXEMPTION REQUEST 

Texoma Drone and Rescue hereby provides pursuant to Part 11 a summary of its exemption 

application to allow commercial operation of the above listed unmanned aircraft in precision 

aerial survey work. An exemption is requested from the following regulations: 

•	_14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 91.203 

•	_14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

•	_14 C.F.R. § § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements 

•	_14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft 

•	_14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration. 

•	_14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

•	_14 C.F.R. § 91.103: Preflight Action 

•	_14 C.F.R. § 91.109(a): Flight Instruction 

•	_14 C.F.R. § 91.119: Minimum Safe Altitudes 

•	_14 C.F.R. § 91.121: Altimeter Settings 

•	_14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 
•	_14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections 

•	_14 CFR § 61.113 Private Pilot Privileges and Limitations 

CONCLUSION 

Texoma Drone and Rescue petition for exemption satisfies the criteria articulated in Section 333 

of the Reform Act of 2012. The proposed UAS operations set forth in this petition not set 

precedent with previously approved exemptions. Approving this exemption, will benefit the 

public as a whole by improving safety, efficiency, cost and reducing the overall risk across a 

wide number of activities. 

Thank for your consideration. If you have any questions or need additional information to 

support the requested exemptions, please do not hesitate to contact me at: 

Bryan Marr 

bryanmarr@me.com

580-465-7253 

credit: docket ID: FAA-2015-2422 for processes and some verbiage