July 6, 2015

Mr. William R. Aylard

29 Paces Run

Lugoff, SC 29078

Dear Mr. Aylard:

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

part 21, subpart H and §§ 61.113(a) and (b) , 91.7(a) 91.121 , 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) and (2) and 91.417(a) and (b) of Title 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 exemption request into the public docket (No. FAA−2015−0954) on April 9, 

2015, but we are unable to process your request any further. The information 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.

 The reasons why 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 an exemption.

 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.
2

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,

/s/

Brenda Robeson

Program Analyst, Airmen and 

 Airspace Rules Division

Enclosure
7/2/2015 Regulations.gov ­ Other Document

http://www.regulations.gov/#!documentDetail;D=FAA­2015­0954­0001 1/2

William R. Aylard - Exemption/Rulemaking

This Other document was issued by the Federal Aviation

Administration (FAA)

For related information, Open Docket Folder

Content

PETITION FOR EXCEPTION

SECTION 333 FOR UNMANNED AERIAL SYSTEMS

Pursuant to Section 333 of the FAA Modernization and Reform

Act of 2012, Public Law 112­95 (the Reform Act) and 14 CFR

Part 11, William R Aylard of 29 Paces Run, Lugoff, SC 29078 ,

operator of an Unmanned Aircraft System (UAS), hereby

petitions for an exemption from part 21, Subpart H and sections

61.113(a) and (b) , 91.7 (a) 91.121 , 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2) and 91.417(a) and (b) of Title

14, Code of Federal Regulations (14 CFR) Section 333 of the

FAA Modernization and Reform Act of 2012 (Public Law 112­95).

The DJI Phantom 2 + will be used for roof inspections, real

estate, special events and search & rescue at altitudes at or less

than 200 feet.

PETITIONER'S BACKGROUND:

In reference to aviation, I worked as an Air Traffic Control trainee

at The Ohio State University's Don Scott Airport tower during the

summer of 1968. In addition, I hold a Private Pilot's License

4435642 for single land airplane that was issued on 07/27/87 and

logged more than 200 hours flight time over a period of 3 years.

My medical is not current for which I seek an exception. I also

request exception to the flight instruction requirement 14 CRT

91.109.

As a licensed pilot, I understand the need to apply safe operating

procedures for the protection of humans, property, wildlife, and

the environment. Before each unmanned aircraft (AV) flight, I

perform a visual inspection of the area, noting natural and manmade obstructions. In addition, I perform a preflight checklist

provided by DJI owner's manual V1.8, 2015.1. At least 1

additional observer will be used during the entire operation to

provide visual contact.

For more than 35 years, I was a field claim representative for

several different companies that included professional

photographic presentations showing the cause and extent of

damage for each claim assigned. Roof inspections were

mandatory for windstorm and hail claims. The use of an UAV for

Comment Period Closed

ID: FAA­2015­0954­0001

Document Information

Date Posted:

Apr 9, 2015

Show More Details

Submitter Information

Submitter Name:

Bill Aylard

Mailing Address:

29 Paces Run

City:

Lugoff

Country:

United States

State or Province:

SC

ZIP/Postal Code:

29078

Comments

0

Docket Information

This document is contained in

FAA­2015­0954

Related Dockets:

None

Related RINs:

None

Comments Received*
7/2/2015 Regulations.gov ­ Other Document

http://www.regulations.gov/#!documentDetail;D=FAA­2015­0954­0001 2/2

inspections will greatly reduce the potential for human injury and

property damage.

UAS APPLICATIONS:

I will use a DJI Phantom 2 + limited to roof inspections,

real estate, special events, and search and rescue operations

(possible expense compensation only). Flight operations will be

confined to the State of South Carolina and adjacent states of

North Carolina and Georgia and will conform to the 200 foot

altitude restriction and restricted distances from airports and

cities as proposed in the FAA website article FAA Streamlines

UAS COAs for Section 333. The restricted areas are

programmed in the DJI Phantom 2 + AUS software and will not

allow entrance into these areas. Using an UAV for these

operations will reduce exposure to the environment from the use

of full sized aircraft, such as fixed wing or helicopters, thereby

reducing the exposure to fossil fuels, noise and potential injury to

humans and damage to property. I, therefore, request relief from

from 14 CER part 21 and any associated noise certification and

testing requirements of part 61.

DESCRIPTION OF UAS:

The Unmanned Aircraft System is DJI Phantom 2 +. The

FAA has accepted the DJI Phantom 2 for Exemption No. 11218,

Regulatory Docket No. FAA­ 2014­0953 and Mr. Michael Singer,

Singer's Creations, Regulatory Docket No. FfAA­2014­0915, etc.

The DJI weighs less than 7 lbs, is 16long x 16wide and 8 high

with maximum speed of 29 knots. The built­in distance and

altitude limitations enhances the safety capability and greatly

minimizes the exposure to to physical harm and/or property

damage. I, therefore, request exemptions as previously granted

for the maintenance (14 CRT 91.405), operations after

maintenance (91.407), inspections (91.409), maintenance record

requirements (91.317).

Respectfully submitted for consideration by:

William R. Aylard

email: billaylard@gmail.com

mailing address: 29 Paces Run

Lugoff, SC 29078

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