8 Oct 2014 

1 | P a g e

3233 NEWMARK DR.  MIAMISBURG, OH 45342

PH 93722 812 25  FX 93 72287 443  www. da ni s.co m

From: Robert A. Mauro

To: Federal Aviation Administration 

Subject: REQUEST FOR ISSUANCE OF EXEMPTION UNDER TITLE 14 CFR, SECTION 333

Ref: (a) FAA Notice 8900.268

 (b) Title 14 CFR

Encl: (1) Explanation of Exemptions from 14 C.F.R.

To Whom it May Concern,

Since 1916, Danis Building Construction Company (DBCC) has been privileged to work on some 

of the most recognizable and high-profile commercial buildings and industrial projects in the Midwest, 

Southeast, and Carolinas. Our work includes partnerships with Fortune 500 Companies, rapidly 

expanding healthcare systems, and distinguished universities.

As a general contractor, DBCC is required to perform many different inspections on the outside 

of existing buildings. These inspections govern and/or validate our construction techniques and 

procedures and often require our employees to be put in situations that require DBCC to accept risk. 

We have found that by using a small unmanned aircraft system “sUAS” with a high resolution camera 

mounted on it, often times we can accomplish the same inspection and alleviate the need to put our 

employees in danger. 

Danis shares Congress’s goal of getting sUAS flying commercially in the United States safely and 

soon. In the FAA Modernization and Reform Act of 2012, Congress directed the FAA “to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace system” and, 

under Section 333 of that law, gave the FAA power to grant innovators “expedited operational 

authorization” to do so. By this petition, DBCC is seeking authorization to conduct sUAS operations on 

our own construction sites in order to improve safety for our employees and ensure quality assurance

for the structures we are creating.

Further, granting this request will do nothing more than allow DBCC to do what thousands of 

hobbyists and manufacturers of model aircraft do every day, except we will abide by much stronger 

safety measures. DBCC has hired an aviation expert and licensed helicopter pilot to manage our sUAS 

program. Under his supervision we would provide a safer level of operation that is superior to current 

regulations. His experience as a FAA licensed commercial pilot gives him an understanding of how 

manned aircraft safely navigate the National Airspace System (NAS), and his recent military aviation 

experience gives him an understanding of UAS operation in conjunction with manned aircraft. This 

invaluable experience applied to DBCC’s UAS program equates to safe sUAS use on our construction 

projects with no confliction with manned aircraft. 

Information Supporting this Petition as Specified in 14 C.F.R. §11.81

A. Mailing address and other contact information:

Danis Building Construction Company

Re: Quad Copter Operations
8 Oct 2014 

2 | P a g e

3233 NEWMARK DR.  MIAMISBURG, OH 45342

PH 93722 812 25  FX 93 72287 443  www. da ni s.co m

3233 Newmark Road

Miamisburg, Ohio 45342

Phone: (937) 228-1225

Fax: (937) 228-7443

B. The specific section or sections of 14 C.F.R from which DBCC seeks exemption.

1. 14 CFR Part 21, Subpart H: Airworthiness Certificates. 

2. 14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

3. 14 CFR 45.23 Display of Marks; General and 45.29 Size of Marks. 

4. 14 CFR 91.9 Civil Aircraft Flight Manual, Marking, and Placard Requirements. 

5. 14 CFR 91.119 Minimum Safe Altitudes. 

6. 14 CFR 91.121 Altimeter Settings. 

7. 14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions.

8. 14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and Alterations. 

9. FAA Notice 8900.227 Paragraph 16(c) (4) PIC Medical and Paragraph 16(e)(1) Observer 

Medical. 

C. The extent of relief DBCC seeks, and the reason DBCC seeks the relief.

DBCC seeks exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 91, and FAA 

Notice 8900.227 to the extent necessary to engage in commercial operations of a sUAS on our own 

construction sites. If granted these exemptions we would operate the sUAS with the property owner’s

written permission. DBCC’s intent is to use a sUAS for the following inspections: 

1. Surveying in hard to reach areas of buildings. 

2. Roof Top Inspections. 

3. Building Exterior Envelope Inspections. 

4. Visual Documentation of Existing Conditions before Demolition of Key Areas. 

5. Quality Control / Quality Assurance Inspections. 

We have detailed, below and in enclosure (1), a significant set of safeguards that will apply to our 

proposed sUAS inspection operations. Operations under these safeguards will provide a level of safety 

exceeding the level of safety required of similar sUAS operations that the FAA authorizes currently. In 

addition, our operations will not create a hazard to users of the national airspace system or the public or 

pose a threat to national security and are thus consistent with the congressional mandate in Section 333 

of the FAA modernization and Reform Act of 2012, which gives the FAA a mechanism to allow certain 

UAS to operate safely in the national airspace system. 

D. The reasons why granting DBCC’s request would be in the public interest; that is, how it would 

benefit the public as a whole.

This would benefit the public by giving DBCC a capable risk mitigated inspection platform. The 

proposed sUAS gives DBCC an alternative to sending our employees into dangerous situations or placing 

large equipment next to occupied building spaces in order to accomplish necessary and required 

construction inspections. This in turn could prevent accidents and/or construction related deaths. This 

would have a positive trickledown effect to families of our employees and people that work on site 

which ultimately benefits the public.
8 Oct 2014 

3 | P a g e

3233 NEWMARK DR.  MIAMISBURG, OH 45342

PH 93722 812 25  FX 93 72287 443  www. da ni s.co m

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 DBCC seeks 

the exemption.

DBCC sUAS operations will provide a level of safety that far exceeds the level of safety required by 

the FAA for hobbyists and manufacturers of model aircraft. The following operating procedures will 

apply during the sUAS inspection operations under this exemption request. 

1. The sUAS that DBCC has chosen to work with has an operational weight of 2.6 pounds and 

will be powered via a battery source. DBCC will only use sUAS that are below 4.4 pounds 

now and in the future if these exemptions are granted. 

2. DBCC inspection operations will be conducted:

i. within the visual line of sight of the Pilot in Command (PIC) and one or more Visual 

Observers (VO).

ii. at less than 400 feet AGL 

iii. within Class G airspace. 

3. DBCC inspection operations will be conducted in a confined area over isolated private 

property located at least 5 miles away from any airport, heliport, seaplane base, spaceport 

or other location with aviation activities, and any military or U.S. government installations or 

airfields. If we are within the 5 mile radius of any of the above installations DBCC will seek 

written approval from that installation’s owner before sUAS inspection operations take 

place. If said installation owner requires stricter guidelines for operation then DBCC will 

comply. 

4. All sUAS operations will remain within the lateral and vertical boundaries of the operating 

area, taking into account all factors, including wind, gross weight and glide distances, that 

may affect the capability of the sUAS to remain within the airspace boundary; moreover, the 

ceiling height will be no more than 400 feet AGL. 

5. DBCC sUAS inspection operations under this exemption will be conducted under the 

supervision designated PIC who ultimately has final responsibility for the operation in 

accordance with 14 C.F.R. 91.3 and either holds a current FAA private pilot certificated, a 

higher FAA pilot certification, or a FAA-recognized equivalent or has completed FAA private 

pilot ground instruction and passed the FAA private pilot written exam. 

6. PIC will maintain the sUAS system in a condition for safe operation, and conduct a pre‐flight 

inspection prior to each flight so as to ensure that the sUAS, control station, data link 

equipment, camera, and support equipment are in a condition for safe operation and in a 

configuration appropriate for the purpose of the intended flight.

7. The PIC and VO will maintain two‐way communications with each other during all 

operations; if unable to maintain two‐way communications, or if any condition occurs that 

may otherwise cause the operation to be unsafe, the operator will immediately conclude 

the operation.
8 Oct 2014 

4 | P a g e

3233 NEWMARK DR.  MIAMISBURG, OH 45342

PH 93722 812 25  FX 93 72287 443  www. da ni s.co m

8. Each sUAS that DBCC will employ under this exemption will safely return automatically to a 

home location designated by the PIC if the communications link is lost. 

9. The aircraft documentation required by 14 C.F.R. §§ 91.9 and 91.203(b), as applicable, will 

be available to the PIC referred to above at any time DBCC sUAS are operating.

DBCC will effectively operate under our own standard operating procedures that will provide 

additional safeguards that go far beyond the level of safety for public model airplane fields.

F. A summary the FAA 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.

1. Petitioner: Danis Building Construction Company.

2. Sections of 14 C.F.R. Affected: §§ Part 21, Subpart H; 91.203; 45.23; 91.9; 91.119; 91.121; 

91.151; Subpart E; and 8900.227 para(16)(4). 

3. Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §§

Part 21, Subpart H; 91.203; 45.23; 91.9; 91.119; 91.121; 91.151; Subpart E; and 8900.227 

para(16)(4)in order to conduct commercial small unmanned aircraft system operations on 

supported construction sites with owner approval subject to operating procedures that 

meet or exceed those that FAA requires for similar operations.

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

Please see the introduction to this exemption request.

H. If you want to exercise the privileges of your exemption outside of the United States, the reason 

why you need to do so.

DBCC does not wish to exercise the privileges of this exemption outside of the United States at this 

time.

Thank you for your consideration and I look forward to your response. I can be contacted directly 

via email or cell phone at your convenience. 

Respectfully,

Robert Mauro

MEP Coordinator

3233 Newmark Drive

Miamisburg, Ohio, 45342

M: 937-607-9815

rob.mauro@danis.com

www.danis.com