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Mark Sherwood Sr.

Mark Sherwood Forensic Photographer

265 School Lane

Springfield, PA 19064

610-506-1933

marksherwoodsr@gmail.com

November 18, 2015

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 

91.7 (a); 91.9(b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203(a) & (b); 

91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b) 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11, Mark Sherwood Sr., owner and operator of small Unmanned Aircraft Systems 

("sUAS") / small Unmanned Aerial Vehicle (“sUAV”) equipped to conduct aerial Search and Rescue 

Operations in the US to get higher success rates on (SAR) on operations and to help prevent 

contamination of lands if there was a manned aircraft accident. Along with municipal services for 

Delaware County Emergency Services Support, with the collection of motor vehicle accident scene

data, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow 

commercial operation fits sUAS, so long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333. 

As described more fully below, the requested exemption would permit the operation of small 

Unmanned and relatively inexpensive UAS under controlled conditions in airspace that is 1) limited 

2) predetermined 3) controlled as to access and 4) would provide safety enhancements to the 

already safe operations in the Emergency Services / SAR presently using conventional aircraft. 
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Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA Administrator's) responsibilities to "... establish requirements for the safe 

operation of such aircraft systems in the national airspace system for public safety." 

The name and address of the applicant is: 

Mark	Sherwood	Forensic	Photographer

Attn:									Mark	Sherwood	Sr.

Phone: 				610-506-1933

Email:			 		marksherwoodsr@gmail.com

Address:	265	School	Lane

																		Springfield,	PA	19064

The conditions proposed by the applicant are drawn from order 8900.1 CHG 0. Similar exemptions 

have been previously granted to a private, volunteer search and rescue group in Exemption #11282 

and this request largely reflects those exemptions. 

Regulations from which the exemption is required 

14	C.F.R.	Part	21	Subpart	H	

14	C.F.R.	45.23(b)

14	C.F.R.	61.113	(a)	&	(b)	

14	C.F.R.	91.7	(a)	

14	C.F.R.	91.9	(b)	(2)	(c)	

14	C.F.R.	91.103

14	C.F.R.	91.109

14	C.F.R.	91.119	

14	C.F.R.	91.121

14	C.F.R.	91.151	(a)

14	C.F.R.	91.155

14	C.F.R.	91.203	(a)	&	(b)	

14	C.F.R.	91.215

14	C.F.R.	91.405	(a)

14 C.F.R. 91.407 (a) (1) 

14 C.F.R. 91.409 (a) (2) 

14 C.F.R. 91.417 (a) & (b) 
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This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of sUASs do not create a hazard 

to users of the NAS or the public or pose a threat to national security in light of the following: 

•The UASs size, weight, speed, and operational capability• Operation of the UAS in close proximity 

to airports and populated areas; and • Operation of the UAS within visual line of sight of the 

operator. 

Reform Act Section 333 (a). Lastly, if the Secretary determines that such crafts "may operate safely 

in the national airspace system, the Secretary shall establish requirements for the safe operation of 

such aircraft in the national airspace system." ID Section 333(c) (emphasis added) 

The Federal Aviation Act expressively grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined under 

section 40101 of the Act that includes sUASs, from the requirement that civil aircraft must have a 

current airworthiness certificate. 

Applicant interprets this provision to place the duty on the Administrator not only process 

applicants for exemptions under section 333, but for the administrator to craft conditions for the 

safe operation of the UAS, if it should be determined that the conditions set forth herein do not 

fulfill the statutory requirements for approval. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator 

finds the exemption in the public interest. 49 U.S.C. Section 44701(f) see also 49 USC Section 

44711(a); 49 USC Section 44704; 14 CFR Section 91.203 (a) (1). The Administrator has recently 

granted such an exemption under very similar circumstances (Exemption #11282). 

Mark Sherwood’s multirotor / quad copter sUAS’s weigh less than 55 lbs. including payload. They 

operate, under normal conditions at a speed of no more than 30 knots (34 mph) and in the case of 

our multirotors have a capability to hover, and move in the vertical and horizontal plane 

simultaneously. They will operate in a line of sight and will operate only within the area made up of 

forest, county parks and open space, rural land, suburban land and power utility grid and towers. 

Given the small size of the sUASs involved and restricted sterile environment within which they will 
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operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in 

which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs 

to commence immediately. Also due to the size of the sUASs and the restricted areas in which the 

relevant sUASs will operate, approval of the application presents no national security issue. Given 

the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation 

Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and 

the significant public benefit, including enhanced safety, reduction in environmental impacts, 

including reduced emissions and chemical spills, exemptions associated with allowing UASs for 

emergency service / public safety operations, the grant of the requested exemptions is in the public 

interest. Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay. 

AIRCRAFT AND EQUIVELANT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to aircraft that have the 

characteristics and that operate within the limitations listed herein. These limitations provide for at 

least an equivalent or even higher level of safety to operations under the current regulatory 

structure because the proposed operations represent a safety enhancement to the already safe 

agricultural services and crops dusted currently being used with conventional aircraft. 

1. The sUASs will weigh less than 55 lbs. 

2. Flights will be operated within visual line of sight of a pilot in command (PIC) and/or visual 

observer (VO). 

3. Maximum total flight time for each operational flight will be 60 minutes for sUAS operations.  

Flights will be terminated at 25% battery power reserve. 

4. Flights will be operated at an altitude of no more than 300 feet at speeds not to exceed 20 

knots (34 miles per hour) or the maximum operating airspeed recommended by the aircraft 

manufacturer, whichever is less. 

5. Minimum crew for each operation will consist of the sUAS Pilot and a Visual Observer. 

6. The UAS will only operate within a confined "safe area" and have a "Security Perimeter” with in 

the flight operations area. 

7. A briefing will be conducted in regard to the planned sUAS operations prior to each day's 
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mission activities. It will be mandatory that all personal that will be performing duties within 

boundaries of the safety perimeter be present for this briefing. 

8. The operator will obtain the consent of all persons involved in the flying area and ensure that 

only consenting persons be allowed within 100 feet of the flight operation, and this radius 

may be reduced to 30 feet based upon an equivalent level of safety and determination. With 

the advanced permission of the FSDO, operations at closer range can be approved. 

9. The operator will notify a Plan of Activities to the FSDO prior to proposed flights. 

10. Pilot and observer will have been trained in the operation of UAS generally and received upto-date information on the particular UAS. Visual Observer and PIC will at all times be able to 

communicate by voice or radio. 

11. Forensic Aerial Data & SAR operations will be launched from and/or oral permission from the 

relevant property holders or public safety officials will be obtained. 

12. If the sUAS loses communications or it loses its GPS signal, the UAS will have capability to 

return to a pre-determined location within the Security Perimeter and land. 

13. The sUAS will have the capability to abort flight in case of unpredictable obstacles or 

emergencies. 

14. The owner shall follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

15. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in 

a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a 

condition that affects the safe operation of the UAS, the aircraft is prohibited from operating 

until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. 

16. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight prior to conducting further operations under this exemption. Functional 
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test flights may only be conducted by a PIC with a VO and must remain at least 250 feet from 

other people. The functional test flight must be conducted in such a manner so as to not 

pose an undue hazard to persons or property. 

17. PIC qualification flight hours and currency must be logged in a manner consistent with 14 

CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, 

proficiency, and experience-building) and determining the PIC’s ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under this exemption are 

permitted under the terms of this exemption. However, training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered nonparticipants, 

and the PIC must operate the UAS with appropriate distance from nonparticipants in 

accordance with 14 CFR § 91.119. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

predetermined location within the private or controlled-access property. 

19. The UA must remain clear and give way to all manned aviation operations and activities at all 

times. 

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness certificates	14	C.F.R.	Section	91.203	(a)	(1)	

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

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

and	limited	operating	area	associated	with	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	both	authorize	the	FAA	to	exempt	aircraft	from	the	

requirement	for	an	airworthiness	certificate,	upon	consideration	of	the	size,	weight,	speed,	

operational	capability,	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	a	restricted	environment	and	under	the	conditions	proposed	will	

be	at	least	as	safe,	or	safer,	than	conventional	aircraft	(fixed	wing	or	helicopter)	operating	with	

an	airworthiness	certificate	without	the	retractions	and	conditions	proposed.	

The	sUAS	to	be	operated	here	under	is	less	than	55	lbs.	fully	loaded,	carries	neither	a	pilot	nor	

passenger,	carries	no	explosive	materials	or	flammable	materials	liquid	fuels,	and	operates	

exclusively	within	a	secured	area	as	set	out	in	manual.	Unlike	other	civil	aircraft,	operations	
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under	this	exemption	will	be	tightly	controlled	and	monitored	by	both	the	operator	and,	

pursuant	to	the	requirements,	and	in	compliance	to	local	public	safety	requirements.

The	FAA	will	have	advance	notice	of	all	operations.	These	safety	enhancements,	which	already	

apply	to	civil	aircraft	operated	in	connection	to	agricultural	aerial	applicators,	provide	a	greater	

degree	of	safety	to	public	and	property	owners	than	conventional	operations	conducted	with	

airworthiness	certificates	issued	under	14	C.P.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	or	

flammable	liquid	fuels,	and	inability	to	carry	a	substantial	external	load.	

14 C.F .R. Section 45.23 (b). Marking of the aircraft 

The regulation requires: 

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

displayed on limited, restricted or in a light-sport category aircraft or experimental or 

provisionally certified aircraft, the operator must also display on the 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 spot," "experimental," or "provisional," as 

applicable. 

Even though the UAS will have no airworthiness certificate, and 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 sUAV, the two-inch lettering will be impossible. The word 

"experimental" will be placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAS marked on it fuselage as required 

by §45.29 (f) where the pilot, observer and others working with the sUAS will see the identification 

of the 

sUAS as "Experimental." The FAA has issued the following exemptions to this regulation to 

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167A. 

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

Sections 61.113 (a) & (b) limit pilots to non-commercial operations. Because the UAS will not carry a 

pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have a sport pilot's Certificate rather than 

have than a commercial pilots Certificate to operate this small UAS. Unlike a conventional aircraft 

that carries a pilot and passengers, the sUAS is remotely controlled with no living sole onboard. The 
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area of operation is controlled and restricted, and all flights are planned and coordinated in advance 

as set forth by in the S.O.P. The level of safety provided by the requirements included in the S.O.P 

exceeds that provided by a single individual holding a commercial pilot's certificate operating a 

conventional aircraft. The risks associated with the operation of the sUAS are so diminished from 

the level of risk associated with the operation of a commercial operations contemplated with Part 

61 when drafted, that allowing operations of the sUAS as requested with a recreational pilot as the 

PIC exceeds the present level of safety achieved by 14 C.P.R. §61,113 (a) & (b). 

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

The regulation requires that no person may operate a civil aircraft unless it is in an airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft. Should this should this 

exemption be granted, no FAA regulatory standard would exist for determining airworthiness. Given 

the size of the aircraft and the requirements contained in the SOP for maintenance and use of safety 

check lists prior to each flight and equivalent level of safety will be provided. 

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

Section 91.9 (b) (2) provides: 

No person may operate a U.S. registered civil aircraft 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 placard, or 

any combination thereof. The sUAS, given its size and configuration has no ability or place to carry 

such a flight manual on the aircraft, not only because there is no pilot onboard, but because there is 

no room or capacity to carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at the ground control 

point where the pilot flying the sUAS will have access to it. The FAA has issued the following 

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

10602, 32827, and 10700. 

14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of the flight. As the FAA approved rotorcraft flight manuals will not be provided as set forth in 

sections of the SOP.

The PIC will take all actions including reviewing weather, flight battery requirements, landing and 
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takeoff distances and aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight instruction 

Section 91.103 provides that no 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. 

sUASs and remotely controlled aircraft, by their design do not have fully functioning dual controls. 

Flight control is accomplished through the use of a control box that communicates with the aircraft 

via radio communications. The FAA has approved exemptions for flight training without fully 

functioning dual controls for a number of aircraft and for flight instruction in experimental aircraft. 

See exemption Nos.5778K & 9862A. The equivalent level of safety provided by that neither a pilot 

nor passengers would be carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operations of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As exemption 

is for the sUAS that is a helicopter and the exemption requests authority to operate at altitudes of 

up to 400 AGL, or not more than 200 above an elevated platform such as radio towers, an 

exemption may be needed to allow such operations. As set forth by herein, except for the limited 

conditions stated in the SOP, the UAS will never operate higher than 400 AGL rotorcraft. It will 

however be operated in a restricted area with a security perimeter, where buildings and people will 

not be exposed to operations without their pre-obtained consent. 

The 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. No flight will be taken without the permission of the property 

owner or local officials. Because of the advance notice to the property owner and participants in the 

activity, all affected individuals will be aware of the planned flight operations as set forth in the SOP. 

Compared to flight operations with aircraft or rotorcraft weighing more far more than the maximum 

55lbs. proposed herein and the lack of flammable fuel, any risk of associated with these operations 

is far less than those presently presented with conventional aircraft operating at or below 500 AGL. 

In addition, the low- altitude operations of the sUAS will ensure separation between these small 

UAS operations and the operations of conventional aircraft that must comply with Section 91.119. 
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14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference 

to an altimeter that is set “... to the elevation of the departure airport or an appropriate altimeter 

setting available before departure." As the sUAS may not have a barometric altimeter, but instead a 

GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved 

by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch 

site shown on the GPS altitude indicator before flight. 

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

Section 91.151 (a) prohibits and individual from beginning "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." 

The battery powering the sUAS provides approximately 20-40 minutes of powered flight. To meet 

the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to 

approximately 10 minutes in length at the most. Given the limitations on the UAS's proposed flight 

area and the location of its proposed operations within a predetermined area, a longer time frame 

for flight in daylight or night VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR (a) falls within the scope of prior exemptions. See 

Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 

91.151(a)). Operating the small UAS, in a tightly controlled area where only people and property 

owners or official representatives who have signed waivers will be allowed, with less than 30 

minutes of reserve fuel, does not engender the type of risk that Section 91.15l(a) was intended to 

alleviate given the size speed of the small UAS. Additionally, limiting sUAS flights to 10 minutes 

would greatly reduce the utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes 

or 25% of battery power whichever happens first. This restriction would be more than adequate to 

return the sUAS to its planned landing zone from anywhere in its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808. 
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14 C.F.R. §91.155: Basic VFR weather minimums 

Section 91.155 establishes safe distances from clouds for flight visibility. All flights will be made in 

visual line of sight from the ground to an altitude of no more than 400 feet. The sUAS will never fly 

into or above the clouds while remaining within visual line of sight. If cloud-cover drops below the 

500-foot minimum, a sUAS can operate safely at a lower altitude. Given the size and speed of the 

small UAS, operating under these conditions should be sufficient to mitigate risk. 

Similar exemptions have been granted to other operations, including Exemptions 5357, 11208, 

11112. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and RegistrationThe regulation

Provides in pertinent part: 

(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 cockpit 

entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 55lbs and is operated without an onboard pilot. As such, 

there is no ability or place to carry certification and registration documents or display them on the 

sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the sUAS will have immediate access to them, to the extent they 

are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exemptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9816A, and 10700. 

14 C.F.R. §91.215: ATC transponder and altitude equipment and use. 

Section 91.215 requires transponder equipment for aircraft within Class A, B and C airspace or 

within 5 nautical miles of an airport listed in Appendix D, section 1. MS intends to operate within the 

county, a portion of which lies within 5 nautical miles of Philadelphia International Airport (PHL). At 

it’s nearest.
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All sUAS operations within Delaware County at an altitude of 400 feet AGL will not enter any Class A, 

B or C airspace. Additionally, ATC transponder equipment would exceed the payload capacity for the 

sUAS and make flight impossible. Given the size, speed and altitude restriction of 400 feet AGL, the 

sUAS can operate safely within Delaware County without entering or affecting aircraft in class A, B 

or C airspace. 

14 C.F.R. §91.405 (a); 407 (a) (2); 417 (a) & (b) 

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. .. 

," and others shall inspect or maintain the aircraft in compliance with part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the application. Maintenance will be accomplished by the operator 

pursuant to the flight manual and operating handbook as referenced in the Manual. An equivalent 

level of safety will be achieved because these small UASs are very limited in size and will carry a 

small payload and operate only in restricted areas for limited periods of time. If mechanical issues 

arise the UAS can land immediately and will be operating from no higher than 400 feet. As provided 

in the SOP, 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 preformed. Moreover, 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. 

Pursuant to 14 C.F.R Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14	C.P.R.	§21,	subpart	H;	14	C.F.R	45.23	(b);	14	C.P.R.§§	61.113	(a)	&	(b);	91.7	(a);	91.9	(b)	

(2);	91.103 (b);	91.109;	91.119;	91.121;	91.151 (a);	91.203	(a)	and	(b);	91.405	(a);	91.407	

(a)	(1);	91.409	(a)	(2)	and	91.417	(a)	&	(b)	to	operate	commercially	a	small	unmanned	

vehicle	(55lbs	or	less)	Data	Collection	and	Emergency	Services/Public	Safety.
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Approval of exemptions allowing commercial operations of sUASs in the Emergency Services will

enhance safety by reducing risk. Conventional operations using aircraft to operate at extremely low 

altitudes just feet from the equipment and structures; and present the risks associated with vehicles 

that weigh in the neighborhood of 3,000-5,000 lbs., carrying large amounts of jet A or other fuel in 

most cases helicopters operating with 140 gallon fuel tanks. The sUAS will carry no passengers or 

crew and, therefore, will not expose them to the risks associated with manned aircraft flights. 

The operations of small UASs, weighing less than 55 lbs., conducted in the strict conditions outlined 

above, will provide an equivalent level of safety supporting the grant of the Part 21 and allowing 

commercial operations. These lightweight small UAVs operate at slow speeds, close to the ground 

and in sterile environment and, as a result, are far safer than conventional operations conducted 

with a piston and or turbine aircraft operating close to the ground.

Public Acknowledgement/PrivacyAircraft that are going to be covered are seen in Appendix A

Appendix A. DJI Phantom 3 Pro & Inspire 1

DJI Phantom 3 Pro
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DJI Inspire 1

Controllers Times 2 
15

Ground Control Station 

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	of	2012	- size,	weight,	

speed,	operating	capabilities,	proximity	to	populated	areas	and	or	close	proximity	to	airports	

and	operations	within	visual	line	of	sight	provides	more	than	adequate	justification	for	the	

grant	of	the	requested	exemptions allowing commercial operation of applicant's UAS in the data 

imaging services industry. 

Sincerely, 

Mark Sherwood Sr.

Mark Sherwood Forensic Photographer

Delaware County Emergency Support Services