wrightUAS

(A	Division	of	S.W.	Wright	Associates,	LLC)

42791	Klondike	Ct

Ashburn,	VA.

20148

swright@wrightuas.com

540-687-1645

Aug 25,	2015	

U.	S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Dear	Sir	or	Madam:	

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	0f	2012	and	CFR	

Part	11,		wrightUAS (a	division	of	S.W.	Wright	Associates,	LLC),	owner	and	operator	

of	Small	Unmanned	Aircraft	Systems	(UAS’s),		request	to	be	exempted	from	the	

Federal	Aviation	Regulations	(FAR’s)	listed	below	so	that	wrightUAS may	operate	

UAS’s	commercially	for	aerial	data	collection	within	airspace	regulated	by	the	FAA,		

as	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.	

wrightUAS is	owned	by	myself,	Steven	W.	Wright		I	am	a	former	military	pilot	and	

current FAA	Commercial rated	pilot		in	both	fixed	wing	and	rotorcraft	(with	a	

Sikorsky	S70 Type	Rating),	with	over	3,300	hours	to		date.		I	have	been	flying	small	

UAS	rotorcraft	for over	1 year.	I	will	hold	a	current	FAA	airman	medical	certificate	

or	a	valid	U.S.	driver’s	license	issued	by	the state of	Virginia. I	will	be	the	sole	

manipulator	of	the	aircraft.		All	operations	to	be	conducted	with	the	public’s	safety	

and	right	to	privacy	strictly	adhered	to	at	all	times.	

As	described	below,	the	requested	exemption	would	permit	the	operation	of	light	

weight	(less	than	55	lbs.	total	take	off	weight)	UAS’s	under	controlled	conditions	for	

commercial	use	by	myself	thereby	enhancing	safety	and	fulfilling	the Secretary	of	

Transportation’s	responsibility	to	“establish	requirements	for	safe	operation	of	such	

aircraft	systems	in	national	airspace	systems.”		Section	333(c),	of	the	Reform	Act.	

wrightUAS UAS’s	are	rotorcraft	weighing	less	than	55	pounds	including	payload		

(DJI	Phantom	3	Professional	Quad	Copter).		They	operate	at	a	speed	less	than	50	

knots	and	have	the	capability	to	hover	and	move	in	the	vertical	and	horizontal	plane	

simultaneously.		The	DJI	Phantom	3	has	an	auto	return	to	the	departure	point	when	

exceeding	the	manufacturers	recommended	distance	from	the	controller,	when	the	

signal	between	the	controller	is	lost	or	when	battery	power	is	under	25%.		The UAS	
will	be	operated	within	“line	of	sight”	in	a	protected	flight	area	at	200’	AGL	or	less.		

These	operations	will	not	create	a	hazard	to	users	of	the	nations	airspace	or	the	

public.	 Multiple	exemptions	have	been	previously	granted	for	the	DJI	Phantom	3

quad	copter.

wrightUAS submits	this	application	in	accordance	with	the	Reform	Act,	112	P.L.		95	

331:334,	seeking	relief	from	any	currently	applicable	FAR’s	operating	to	prevent	

wrightUAS’s future	commercial	use	of	small	UAS’s	to	operate	in	the	national	

airspace	system	as	described	below.		The	Reform	Act	Section	332	provides	for	such	

integration	of	civil	unmanned	aircraft	into	our	national	airspace	system	as	it	is	in	the	

public’s	interest	to	do	so.		wrightUAS UAS’s	meet	the	definition	of	“small	unmanned	

aircraft”	as	defined	by	Section	331		and	therefore the	integration	of	theses	UAS’s	are	

expressly	contemplated	by	the	Reform	Act.			wrightUAS would	like	to	operate	it’s	

light	weight	UAS’s	prior	to	the	time	period	by		which	the	Reform	Act	requires the	

FAA	to	promulgate	rules	governing	such	aircraft.	

The	Reform	Act	directs	the	Secretary	of	Transportation	to	consider	whether	certain	

unmanned	aircraft	systems	may	operate	safely	in	national	airspace	before

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

making	this	determination,	the	Secretary	of	Transportation	is	required	to	determine	

which	UAS’s	do	create	a	hazard	to	users	of	the	national	airspace	system	or	the	public	

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

					The	UAS’s	size,	speed,	weight	and	operational	capability.	

					Operation	of	the	UAS’s	in	close	proximity	to	airports	and	populated	areas.	

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

Reform	Act	333(a).		If	the	secretary	determines	that	such	vehicles	“may	operate	

safely	in	the	National	Airspace	System,	the	secretary	shall	establish	requirements	

for	the	safe	operation	in	national	airspace.	

wrightUAS	will	be	using	rotorcraft	weighing	less	than	55	lbs	and	operate	at		speeds	

less	than	50	knots	with	the	ability	to	operate	in	the	vertical	and	horizontal	plane		

simultaneously.		The	UAS’s	will	operate	only	within	“line	of	sight”	of	the	operator	

within	a	protected	flight	area	and	at	200’	AGL	or	less.		This	will	not	present	a	hazard	

to	the	national	airspace	or	the	public.	The	very	small	nature	of	these	UAS's	

combined	with	the	safe	guards	presented	below,	will	allow	for	the	safe	operation	

greater	than	that	envisioned	by	Congress	for	the	FAA	to	establish	and	by	exemption	

allow	commercial	operations	of	UAS’s	to	commence	immediately.		Also	due	to	the	

size	of	UAS’s	and	the	areas	and	altitudes	they	will	operate	approval	of	this	

exemption	presents	no	national	security	issues	and	absolutely	minimal	safety	

concerns	which	have	been	mitigated	through	our	rigorous	risk	management	

process.		Given	the	clear	direction	given	in	Section	333	of	the	Reform	Act,	the	

authority	contained	in	the	Federal	Aviation	Act,	as	amended,	the	strong	equivalent	
level	of	enhanced	safety,	reduced	emissions	utilizing	UAS’s	versus	traditional	

aircraft	as	well	as	the	economic	impact	of	greatly	reducing	the	cost	of	aerial	

photography	thereby	benefitting	the	greater	public’s	interest.		Accordingly,	the	

applicant	requests	that	the	FAA	grant	the	requested	exemption	without	delay.	

The	following	will	be	considered	as	the	Standard	Operating	Procedures	(SOP)	of	

wrightUAS.	

1.	Flights	will	only	occur	between	sunrise	and	sunset.	

2.	Flights	will	be	operated	in	the	line	of	sight	of	the	operator	(PIC).	

3.	Flights	will	be	terminated	at	any	time	weather	and	wind	deteriorate	to	“unsafe	for	

flight”	based	on	manufacturer’s	limitations.	

4.	The	UAS’s	will	weigh	less	than	55	lbs.	

5.	Flights	will	be	operated	at	less	than	200’	AGL.	

6.	The	UAS’s	operator will	perform	a	check	of	the	flight	area	and	make	certain	of	the	

safety	of	all	persons	in	the	area.	Additionally,	wrightUAS	follows	Unmanned	

Operational	Risk	Management	principles	in	its	work.	wrightUAS	UORM	principles	

are	derived	from	the	U.S.	Naval	Aviation	ORM	program.	UORM	principles	will	be	

applied	at	two	different	points	in	the	sUAS	aviation	job	process.	First	prior	to	

accepting	any	job,	hazards	are	identified,	assessed,	and	risk	decisions	are	made.	

Finally	prior	to	launching	an	sUAS	aircraft	the	day	of	a	job,	hazards	are	identified,	

assessed,	risk	decisions	are	made,	controls	are	put	in	place,	an	supervision	is	

applied.	Safety	is	our	number	one	priority.

7.	Consent	will	be	obtained	from	all	persons	within	the	data	collection capabilities	to	

ensure	their	privacy.	

8.	All	required	FAA	clearances	will	be	obtained	and	distances	from	airports	strictly	

adhered	too.	

9.	All	UAS’s	will	have	the	capability	to	return	automatically	to	the	operator	in	a	safe	

manner	with	the	auto	return	function	checked	and	working.	

10.	Flights	will	only	operate	in	VFR	conditions.	

11.	UAS	controllers	display	range	and	remaining	battery	power.	

12.	All	preflight	checks	will	be	done	prior	to	each	flight.	

13.	All	routine	inspections	and	maintenance	will	be	done	in	accordance	as	specified	

by	DJI.	

As	of	March	23,	2015	the	FAA	has	stated	that	it	will	automatically	grant	a	“blanket”	

COA	for	flights	at	or	under	200’	AGL	to	any	UAS	operators	with	a	Section	333	

Exemption.	

14	CFR,	Part	91.203(a&b)	provides	for	carrying	of	civil	aircraft	certifications	and	

registrations.			These	are	inapplicable	for	the	same	reasons	stated	above.		The	

equivalent	level	of	safety	will	be	achieved	by	maintaining	such	certifications	and	

registrations	by	wrightUAS.	

14 CFR,	Part	91.7	(a)	prohibits	the	operation	of	an	aircraft	without	an	airworthiness	

certificate.			As	no	such	certificate	will	be	applicable	in	the	form	contemplated	by	the	

FAR’s	this	regulation	is	inapplicable.	
14	CFR,	Part	91.9(b)(2)	requires	a “Civil Aircraft	Flight	Manual”	in	aircraft.		As	there	

are	no	pilots	or	passengers	and	given	the	size	of	the	UAS’s	this	regulation	is	

inapplicable.	

The	FAA	has	previously	issued	exemptions	to	this	regulation	in	Exemptions	8607,	

8737,	8738,		9299,	9299A,	9565,	9565B,	10167,	10167A,	10602,	10700	and	332827.	

14	CFR,	Part	91.119	Minimum	safe	altitudes	prescribes	safe	altitudes	for	operation	

of	civil	aircraft..	It	allows	helicopters	to	be	operated	at	lower	altitudes	under	certain	

conditions.		wrightUAS will	only	operate	it’s	UAS’s	at	or	below	200’	AGL.		They	will	

be	operated	in	a	well	defined	area	of	operation	that	has	been	carefully	reviewed for	

hazards	and	minimizes	the	presence	of	any	persons	not	essential	for	these	

operations.		Flights	will	only	be	over	private	property	with	the	owner’s	consent.	

Approval	of	these	333	Exemptions	allowing	commercial	use	of	small	UAS’s	in	the	

service	of	aerial	data	collection will	greatly	enhance	safety	by	reducing	the	overall	

risk	associated	with	traditional	aircraft.		Traditional	aerial	data	collection requires	

large	aircraft	with	fuel	potentially	flying	over	or	in	close	proximity	to	populated	

areas.		With	the	use	of	small	battery	powered	UAS’s	of	55	lbs	or	less	the	risk	of	

injury	to	people	on	the	ground	is	drastically	reduced.	

Granting	wrightUAS	the	above	exemption	will	allow	for	the	expansion	of	the	use	of	

UAS’s	aircraft	in	the	future	for	the	safe	conduct	of	free	enterprise.	wrightUAS

respectfully	requests	the	FAA	grant	it’s exemption	without	delay.		The	FAA	has	the	

authority	to	issue	this	exemption	pursuant	to	the	Federal	Aviation	Act,	85	P.L.	726		

(1958)	as	amended	(the	act).	

Sincerely,	

Steven	W.	Wright

swright@wrightuas.com

wrightUAS

42791	Klondike	Ct.	

Ashburn,	VA.	20148

540-687-1645

www.wrightuas.com