[Type text]

U.S. Department of Transportation, Docket 

Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE., Washington, 

DC 20590

Scott Rokeby

President

Daedalus Imaging, LLC

1324 North Willow Avenue

Broken Arrow, OK 74012

918-346-0832

DaedalusImage@gmail.com

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

Aviation Regulations

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, Daedalus Imaging, LLC seeks an exemption from Federal Aviation 

Regulations (“FARs”) detailed below for the following described Unmanned Aerial System called 

in this application the Daedalus Imaging Unmanned Aerial System (DI UAS), which includes an 

Unmanned Aircraft (UA) and ground station-based equipment and crew:

THE UNMANNED AIRCRAFT (UA):

 A light weight, battery operated, 4 motor rotorcraft commonly known as a "quadcopter" 

that takes off and lands vertically, built on a frame manufactured by Tarot, Ironman650 

model, modified by the applicant to carry the following equipment in flight; 

 An on-board flight computer with GPS navigation and location ability that receives 

signals for flight controls from a ground-based transmitter/controller; 

 An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video; 

 An on-board telemetry system that delivers flight data from the on-board flight 

computer to the on-board radio transmitter including altitude AGL, horizontal and 

vertical speed, compass direction of flight and direction back to its launch site; 

 A 600mW, 5.8GHz on-board radio transmitter that transmits live video from the onboard camera plus all the flight data from the telemetry system described above;

THE GROUND STATION-BASED PART OF THE SYSTEM:

 A Pilot In Command (PIC)/Operator in operational control of the flight operation from 

beginning to end, who controls the UA while the aircraft is in flight;
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 A 100mW, 2.4GHz radio transmitter/controller operated by the PIC/Operator to control 

the UA while in flight;

 A radio receiver to receive live video and telemetry data from the onboard camera and 

flight computer and displays this information on a screen for PIC/Operator reference 

(NOT to be used for First-Person-View flying);

 A computer running Mission Planner software to log telemetry data.

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the above UAV system for aerial video and photography primarily of real 

property and infrastructures.

The UA, powered by batteries is smaller, lighter and more maneuverable than larger aircraft 

powered by internal combustion engines. It operates at much lower altitudes and with no 

persons onboard, eliminating the risk to life onboard and greatly reducing the overall likelihood 

of death or bodily injury. This results in dramatic increases in safety compared to methods of 

obtaining the same photographs and video from a similarly capable camera system carried aloft 

by a traditional rotorcraft required to be crewed by at least a pilot and camera operator. 

The small payload and short flight times, often less than 30 minutes means little to no risk of 

national security.

Aerial photography is often the preferred means by which buyers and sellers of real property 

can most fully evaluate the merits of a transaction and so has value to both buyers and sellers. 

This is traditionally accomplished by hiring a two-seater helicopter which is both cost 

prohibitive and a nuisance to surrounding properties and their owners/inhabitants. The 

benefits of reduced cost, improved presentation value and less obtrusive means of production 

ensure a higher value and greater benefit to our customers. 

Further, infrastructure inspections often require the same helicopter and crew as real estate 

transactions, but with the requirement the flights are made much closer to the infrastructure 

being inspected. This creates an even greater risk to the lives of the crew and increases the risk 

to people and property on the ground. The DI UAS decreases these risks dramatically by 

removing the crew from the air and using a significantly lighter aircraft.

Additionally, Daedalus Imaging would request we be allowed to lend our technology and 

expertise to benefit local first responders who may find our system beneficial. These may 

include fire fighters, local police and sheriff departments, forestry service, et al., while 

remaining under the restrictions and limitations cited in this exemption request.
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The DI UAS will be operated with the following restrictions:

a) No flight will be made with a UA having a gross weight greater than 55 pounds;

b) All operations must be conducted at an altitude no greater than 400 feet AGL, at an 

airspeed not to exceed 25 knots, and no further than 3/4 of a mile from the 

PIC/Operator;

c) All flights over privately owned land must have the permission of the property owners 

over which the intended flight path is to be executed;

d) All PICs/Operators used by Daedalus Imaging will have accumulated and logged in 

accordance with FAR Part 61.51 (b), a minimum of 100 flight cycles and 25 hours of total

time as PIC/Operator of UAS and at least 10 hours of PIC time logged in a rotorcraft UA 

of similar type;

e) All required permits will be obtained from state and local agencies prior to operation;

f) The UA will not be operated at air shows;

g) The UA will not be operated directly over open-air assemblies of people;

h) The UA will not be operated over heavily trafficked roads;

i) The UA will not be operated within Class A airspace, and any flights occurring within 

Classes B, C, D, or E airspace require prior contact and coordination with Air Traffic 

Control (ATC). Operations in Class G airspace further than three miles from the nearest 

controlled airport will not require notifying ATC;

j) Operations are restricted to day time only and conditions equivalent to VFR;

k) In cases where a visual observer (VO) is used, such as heavily forested properties, the 

PIC/Operator will brief the VO on the intended operation and risks prior to to the first 

flight at each new location, or new intended operation at the same location;

l) The PIC/Operator will brief the property owners of the intended flight operation and 

any risks involved;

m) No flight may be made without a Pre-Flight Check performed by the PIC/Operator from 

a checklist to ascertain the UA is in safe flying condition. (See Addendum A)

The PIC/Operator will meet the requirements outlined in FAA Policy N 8900.227 Section 16 

personnel qualifications. Additionally the PIC/Operator will perform maintenance on the UAS 

and record all maintenance activities in their pilot log book. 

We submit that the combination of the UA's light weight, flight performance and ability, fully 

qualified flight crew, and strict adherence to the restrictions and limitations created by the 

guidance found in 8900.227, and under all restrictions listed in (a) thru (m) above, the FAA can 

have full confidence that Daedalus Imaging operations will be conducted with an equivalent or 

greater level of safety than manned aircraft performing the same missions.
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The regulations from which the exemption is requested are listed below, each with an 

associated Addendum page where on which may be found equivalent or greater levels of 

safety.

-14 CFR 21

-14 CFR 91.203

-14 CFR 45.23

-14 CFR 45.29

-14 CFR 91.9

-14 CFR 61.113

-14 CFR 61.133

-14 CFR 91.109

-14 CFR 91.119

-14 CFR 91.121

-14 CFR 91.151

-14 CFR Subpart E 91.401 thru 91.417

FAA Policy 8900.227, 16 (c)(4) and (e)(1)

Addendum Page 1

Addendum Page 2

Addendum Page 2

Addendum Page 2

Addendum Page 3

Addendum Page 3

Addendum Page 3

Addendum Page 4

Addendum Page 4

Addendum Page 4

Addendum Page 4

Addendum Page 5

Addendum Page 5

Contact information of the applicant:

Daedalus Imaging LLC

Scott Rokeby - President

Ph. 918-346-0832

Email: srokeby@gmail.com

We understand that this initial contact may be followed by a request from the FAA to modify or alter 

any part or segment of the exemption request and look forward to working with the FAA to meet or 

exceed an equivalent level of safety.

Best Regards,

Scott Rokeby, President

Daedalus Imaging LLC

Private Pilot Certificate No. 2793324 
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Addendum

Exemption Request and Equivalent Level of Safety

Daedalus Imaging, LLC, requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the DI UAS:

14 CFR Part 21, Subpart H: Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we 

request an experimental certificate be issued for the DI UAS System under either or both of the 

following provisions: 

21.191 Experimental certificates. 

Experimental certificates are issued for the following purposes:

(a) Research and Development. Testing new aircraft design concepts, new aircraft equipment, 

new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and customer crew training, we would expect that an experimental 

certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict 

operational requirements. Combined with the UA’s light weight, being constructed primarily of 

carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a 

conventionally certificated aircraft performing the same mission.

If an experimental airworthiness certificate is not appropriate for this application, then we 

request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness 

certificate in general, citing the equivalent level of safety outlined in the previous paragraph. 
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14 CFR 90.203(a) and (b) Civil aircraft: Certifications required

The regulation provides that an airworthiness certificate, with the registration number assigned 

to the aircraft and a registration certificate must be aboard the aircraft. Additionally, 

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or 

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

At a maximum gross weight of 5.3 pounds, the UA is too small to carry documentation, does 

not have an entrance, and is not capable of carrying passengers or crew. To obtain an 

equivalent level of safety and meet the intent of 91.203, we propose that documents deemed 

appropriate for this aircraft by the FAA will be co-located with the crew at the ground control 

station and available for inspection upon request. In order to identify the aircraft, we propose 

that the equivalent and appropriate information found on airworthiness and registration 

certificates be permanently affixed to the aircraft via placard containing the following 

information plus the word “EXPERIMENTAL” to satisfy the requirement of 14 CFR 45.23, which 

follows immediately after the proposed placard description below:

EXPERIMENTAL

Assembled by: Daedalus Imaging, LLC

1324 N Willow Ave

Broken Arrow, OK 74012

Unmanned Aerial System No. 001

If found please contact: (918) 346-0832

14 CFR 45.23 Display of marks; general and 45.29 Size of marks

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The UA does not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by the FAA. 

We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" 

in the placard on the top of the aircraft, as shown above, where the PIC/Operator and others in 

the vicinity of the aircraft while it is preparing for launch will be able to see the designation. 

Additionally, we feel that the permanent placard discussed in the previous paragraph will 

provide the aircraft's registration information at the ground station. Finally, we will display at 

the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft 

Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM 
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of the ground station, the banner should be visible to anyone that observes the aircraft and 

chooses to investigate its point of origin.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements

This regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that 

flight manual information is available to the aircrew while operating the aircraft. We request an 

exemption to this requirement since the aircraft is not only too small to carry documentation, 

the documentation would not be available to the crew during flight operations. 

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, 

accepted UA Flight Manual (Appendix A) must be available to the crew at the ground station 

anytime the aircraft is in, or preparing for, flight.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 

61.133 Commercial pilot privileges and limitations

The regulation provides that no person that holds a private pilot certificate may act as pilot in 

command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to 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.

Our proposed operations require that the PIC/Operator must either 

1. Hold a private pilot certificate issued by the FAA, and have logged 25 hours of flight 

experience in this type of UA, or 

2. Meet the requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot 

certificate" in which the PIC is required to complete "FAA private pilot ground 

instruction" and pass "the FAA Private Pilot written examination." Since there are 

currently no means available for the pilot of a UAS to gain the experience in an 

equivalent category and class in order to apply for a commercial pilot's license, we 

propose to generate an equivalent level of safety by requiring our pilots to complete, at 

a minimum, FAA private pilot ground instruction and pass the FAA private pilot written 

examination in addition to completing the private pilot requirements. Since the aircraft 

cannot carry passengers or property, we feel we meet the intent of 61.113 

Subparagraph (b) even though the intent of this application is to conduct a business.
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14 CFR 91.109 Flight instruction; Simulated instrument flight and certain flight 

tests

The regulation states that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls."

Part of the DI UAS ground-based control station consists of a small hand-held radio transmitter 

and in the form of a "buddy box" input jack located on the rear of the controller in which a 

second hand-held radio transmitter can be connected for use by the student while overriding 

control remains with the primary radio held by the instructor. With both student and instructor 

having "hands-on" the controls during flight, we feel that this technique meets the intent 

91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General

The regulation states that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at 

a maximum of 400 feet AGL, we cannot comply with this requirement. 

In order to provide an equivalent level of safety, when flying over private property, the 

permission of the owner/s of the property shall be obtained. The aircraft will not be operated 

over congested areas or over any open air assembly of persons. The property owner/s will be 

briefed on the planned route of flight and the associated risks to persons and property on the 

ground. The aircraft will be operated at a low altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. Therefore we 

maintain that due to the small size of the UA, the hazard to persons, vehicles and structures is 

minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. 

The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in 

order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement 

above the takeoff point is transmitted via radio from the UA on-board computer to the display 

screen held by the PIC/Operator, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions

The regulation provides that no person may begin a flight in an airplane under day-VFR
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conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

that for at least 30 minutes.

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for

delays to landing. The UA is battery operated and the maximum duration of flight from a single

battery charge is 40 minutes with a 20% reserve. Since the aircraft will never fly more than 3/4

NM from the point of intended landing, a full battery charge at launch will ensure that we meet

the reserve energy requirement of this paragraph. We request an exemption to the word "fuel"

and ask for an equivalent interpretation with the word "energy".

14 CFR Subpart E (91.401 thru 91.417) Maintenance, Preventative Maintenance, 

Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and

91.409 require that the aircraft be "approved for return to service by a person authorized under

43.7" after maintenance and inspection. 

It is our intention that the PIC/Operator perform minor maintenance and inspection of the 

aircraft and "be authorized to approve the aircraft for return to service." As provided in the PreFlight Checklist in Appendix A, the PIC/Operator will ensure that the aircraft is in an airworthy 

condition prior to every flight and in addition conduct detailed inspections after every five

hours of flight. Maintenance performed by the PIC/Operator is limited to repairing small cracks, 

replacing a propeller, checking electrical connections and updating software and firmware for 

the on-board computer. As this UAS was fully constructed from readily available parts by the 

President of Daedalus Imaging, any repairs beyond the scope allowed by the PIC/Operator will 

be performed by the President of DI LLC. This may include such items as replacing motors, 

recalibrating the onboard flight computer, replacement of faulty electronic speed controllers

(ESCs), or replacement of various antenna and transmitters. In every case maintenance 

performed will be documented in accordance with 91.417. We feel that due to the size,

construction, and simplicity of the aircraft, the this will ensure an equivalent level of safety.

8900.227 Paragraph 16(c)(4) PIC Medical

This policy provides that the PIC must have a valid FAA second-class medical

certificate issued under part 67 in order to perform as a pilot or observer.

The UA maximum gross weight is 5.3 pounds, it is constructed of carbon fiber and plastic and

the PIC/Operator is not on board. The PIC/Operator is required to be in VLOS. Given the unlikely

event that the PIC/Operator becomes medically incapacitated while the aircraft is in flight, the

UA will return autonomously to the site of launching and land without crew intervention.

Therefore, requiring the PIC/Operator to meet the same medical requirements as a commercial
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pilot carrying passengers in a large aircraft is an unnecessary burden.

We propose that the minimum medical requirements for the PIC/Operator be vision corrected 

to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that 

the PIC/Operator can see and avoid air traffic; a light sport pilot with a drivers license is 

medically qualified to operate a much larger vehicle.

APPENDIX A - FLIGHT MANUAL

FLIGHT RESTRICTIONS

a) No flight will be made with a UA Gross weight exceeding 55 pounds;

b) All operations not performed in conjunction with local ATC must occur in FAA Class G 

airspace at no more than 400' AGL, at an airspeed of no greater than 25 knots and no 

further than 3/4 mile from the PIC/Operator;

c) Flights done in air space Classes B, C, D, and E require prior coordination with local ATC.

d) No flights are permitted in Class A airspace.

e) No flight will be made over people that are not directly involved in the operation of the 

DI UAS;

f) The PIC/Operator must have accumulated and logged, in a manner consistent with 14 

CFR § 61.51 (b), a minimum of 100 flight cycles and 25 hours of total time as a UA 

rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type;

g) All required permits will be obtained from state and local government prior to 

operation;

h) The DI UAS will not be operated over densely populated areas;

i) The DI UAS will not be operated at air shows;

j) The DI UAS will not be operated over any open-air assembly of people;

k) The DI UAS will not be operated over heavily trafficked roads;

l) The DI UAS will not be operated within 3 NM of an airport or heliport without first 

notifying ATC of the intended operation;

m) Operations will be restricted to day time only and weather conditions equivalent to VFR;

n) The PIC/Operator will brief the property owner/s about the operation and risk before the 

first flight at each new location; 

o) No flight may be made without a successful Pre-Flight Inspection by the PIC/Operator

before each operation to ascertain that the UA is in a condition safe for flight. 

p) All flights will be made with Failsafe mode enabled.
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PRE-FLIGHT CHECKLIST

1. Use voltmeter to determine that UA battery is fully charged in order to prevent 

unexpected premature descent; 

2. Check all wiring connections are tight; 

3. Check all propellers are undamaged and no cracks exist in any structural members of the 

UA;

4. Turn on radio controller, check for adequate voltage, set it to connect to the UA, move 

all control switches to forward or down position and throttle control stick full back 

position;

5. Connect UA main battery, check for radio contact with UA’s radio receiver; 

6. Verify solid blue LED on flight computer to indicate GPS and compass lock; 

7. Turn on transmitter, gimbal and camera. 

TO REGAIN CONTROL AFTER LOST RADIO CONTACT

1. Mode - POS HOLD

2. Throttle - 50%

3. Move toward aircraft until radio contact regained

4. Verify positive control by looking for appropriate UA responses to PIC/Operator inputs

5. Mode - Stabilize.

If radio contact is not reestablished, 

the UA will automatically climb to 50 

ft above its last established AGL 

altiude before returning to its initial 

takeoff point and descending for 

landing.
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Controller function and Flight Controls

3 position 

mode switch

Camera pitch 

control

4-way stick. 

Move 

forward, move 

backward, 

move left, 

move right.

4-way stick. 

Throttle up, 

throttle 

down, yaw 

left, yaw 

right

Note: Switches and control features left unmarked 

have no function in the current configuration and do 

not impact flight.

Power ON, 

OFF
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Electronic Speed Controller Operations
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Specifications

Propellars (4) 15 inch x 5.5 inch pitch

Electronic Speed Controllers (4) HK Blue Series 30 amp

Motors (4) 480 rpm/volt

Frame diagonal 650mm

Frame Height 290mm

Battery (1) or (2) 4S LiPo 6000mah