December 17, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590 

RE: Exemption Request for Section 333 of the FAA Reform Act of 2012 

Dear Sir or Madam : 

I. Operator's Name and Address: 

Vaughn's Flying Service 

Wayne Vaughn; Owner 

110 Holly Trail 

Brandon, MS 39047 

601.416.4599 

II. Regulations from which exemption is requested: 

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

C.F.R. Part 11, Vaughn Flying Service, a full service aerial photography and site seeing company, hereby 

applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of 

our Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal Aviation 

Administration (FAA) so long as such operations are conducted with and under the conditions outlined 

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

14 C.F.R. Part 21 

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) 

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. 91.203(a) & (b) 

14 C.F.R. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401-91.417 

Ill. How Vaughn Flying Service will maintain an equivalent level of safety 

Safety is job number one and Vaughn Flying Service's operations adhere to the Reform Act's safety 

requirements. The chief pilot holds an FAA Commercial Pilot license and is an Advanced Ground 

Instructor. Our dedication to legal integration into the National Airspace System demonstrates Vaughn 

Flying Service's high regard for safe operations. Each Pilot and Observer has an understanding of FARs, 

preflight inspections, knowledge of operations and differences in airspace classifications, maintenance 

and repair, as well as being trained to high safety standards. Each pilot and observer is trained on the 

following Standard Operating Guidelines: 

• The petitioner will only operate its sUAS in line-of-sight of a pilot and/or observer and will 

operate at sites that are 'sufficient distance' from populated areas within the sterile area 
described in the FOPM. Such operations will ensure that the sUAS will "not create a hazard to 

users of the national airspace system or the public." 

• When flying the sUAS within five (5) miles of an airport, airport operators will be notified and 

the operator will give the right-of-way to avoid flying in the proximity of full-scale aircraft. 

• Maximum flight time for each operation will be 30 minutes. 

• Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time 

to safely land the sUAS. 

• The sUAS will not be operated at an altitude that exceeds 400 feet AGL. 

• Minimum crew for each operation shall consist of: sUAS pilot and a visual sUAS observer. 

• The sUAS PIC will be an FAA licensed airman holding a minimum of a Sport Pilot. 

• The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. 

camera, lens, and stabilized gimbal). 

• The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously 

move vertically and horizontally. 

IV. This service will serve the Public's interest in 3 ways: 

1. Improved safety in comparison to manned aircraft 

sUAVs have the ability to get into position to take many "shots" too dangerous for manned 

aircraft because of safety concerns either to the pilot or the public at large. 

2. Making the service available to a much wider population 

Because the devices are smaller, much less expensive to purchase and maintain and personnel 

c.:ust can be reduced, the service is available to a wider market. 

3. Protecting the environment 

Because of reduced noise, less time on target and electric motors, sUAS's have a much smaller 

environmental impact 

The public interest is served by improving safety in and around the photo site, increasing the service 

availability by decreasing costs and protecting the environment by using electric motors in the place of 

carbon fueled engines, reducing noise pollution and reducing the time over target. 

V. Our Proposed Operation: 

The requested exemption would permit Vaughn Flying Service to pursue its commercial interests in 

providing services to clients using a small advanced sUAV in the following areas: 

• Emergency Management • Industrial 

• Marketing • Rea I Estate 

• Surveying • Special Events 

Additionally, Vaughn Flying Service's sUAS chief pilot holds an FAA Commercial License with Multi 

Engine and Instrument Ratings and any pilots employed by Vaughn Flying Service tb pilot our sUAS will 

hold at a minimum, a Sport Pilots License. The owner and Chief Pilot is an Advanced Ground Instructor 

and will insure that if observers are not qualified pilots, they will attend a ground school to understand 

the proper roles of an observer, communication procedures, proper visual scan techniques, operations 

at non-towered airports and appropriate sections of the Aeronautical Information Manual (AIM). 
Under the requested exemption, Vaughn Flying Service ensures all pilots have completed sUAS 

education and training programs including all applicable regulations and guidance documents; including 

aeronautical background information such as charts, NOTAMS and Aircraft Circulars; Radio 

Communications Procedures; Human Factors and Crew Resource Management; Basic sUAS 

Aerodynamics; Weather factors; Airmanship and Decision-making and Safe Operations Procedures. 

It is Vaughn Flying Service's intent to respect the public's privacy. All sUAS flights will occur with the 

consent of the property owner or authority having jurisdiction. 

VI. Unmanned Aircraft System 

Vaughn Flying Service is petitioning for an exemption to operate a homebuilt TBS Discovery quad copter 

with a FPV camera complete with full flight telemetry and a separate high quality camera mounted on a 

two axis gimbal. The aircraft also has a GPS safety features which gives the operator the ability to limit 

the height it flies above ground level (AGL), and to limit the radius of the distance it flies from the 

operator. Flights within designated Class B, C and D airspace will always be coordinated with the 

controlling authority and any flight in Temporary Fight Restricted airspace will only be conducted at the 

invitation and in coordination with the controlling authority. Our aircraft also has a failsafe function that 

is triggered in the event communication is lost between the sUAS and the main controller transmitter. 

At that time, the sUAS will return to its point of takeoff and land safety. If the connection is restored, the 

PIC can regain control of flight and land manually. 

We respectively request exemption under Section 333 to enable Vaughn Flying Service to operate 

efficient, limited, low-risk commercial sUAS operations for the activities stated; respecting at all times 

the space and privacy of citizens and property while keeping airspace safe. 

Sincerely, 

{rJ 

Vaughn 

Wayn~ Flying Service 

110 Holly Trail 

Brandon, MS 39047 

601-416-4599