December 17, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave. SE Washington, DC 20590 

### RE: Exemption Request for Section 333 ofthe FAA Reform Act of2012 Dear Sir or Madam : 

### I. Operator's Name and Address: Vaughn's Flying Service Wayne Vaughn; Owner 110 HollyTrail Brandon, MS 39047 601.416.4599 

### II. Regulations from which exemption is requested: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act), and 14 C.F.R. Part 11, Vaughn Flying Service, afull service aerial photography and site seeing company, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed belowto allow operation of ourSmall Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and underthe conditions outlined herein or as may be established by the FAA as required by Section 333. 14C.F.R. Part 21 14C.F.R. 45.23(b) 14C.F.R. 61.113(a) 

### & (b) 14C.F.R. 91.7(a) 14C.F.R. 91.9(b) (2) 14C.F.R. 91.109 14C.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 ofsafety Safety is job numberone and Vaughn Flying Service's operations adhere tothe Reform Act's safety requirements. The chief pilot holds an FAA Commercial Pilot license and is an Advanced Ground Instructor. Ourdedication to legal integration into the National Airspace System demonstratesVaughn Flying Service's high regard for safe operations. Each Pilot and Observer has an understanding of FARs, preflight inspections, knowledge ofoperations 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 petitionerwill only operate its sUAS in line-of-sight ofa pilot and/orobserver and will operate at sites that are 'sufficient distance' from populated areas within the sterile areadescribed in the FOPM. Such operations will ensure thatthe sUAS will "notcreate a hazard to users ofthe national airspace system orthe public." • When flying the sUAS within five (5) miles ofan airport, airportoperators will be notified and the operatorwill give the right-of-wayto avoid flying in the proximity offull-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 400feet AGL. • Minimum crewfor each operation shall consist of: sUAS pilotand avisual sUAS observer

. • The sUAS PIC will be an FAA licensed airman holding a minimum ofaSport Pilot. • The sUAS operated by the petitionerweighs less than 25 pounds, including all payload (i.e. camera, lens, and stabilized gimbal). • The sUAS will operate atspeeds 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 abilityto get into position to take many "shots" too dangerous for manned aircraft because ofsafety concerns eithertothe pilot orthe 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 awider 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 protectingthe environment by using electric motors in the place of carbon fueled engines, reducing noise pollution and reducing the time overtarget. 

### V. Our Proposed Operation: The requested exemption would permitVaughn 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 • ReaI 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, aSport Pilots License. The ownerand Chief Pilot is an Advanced Ground Instructor and will insure that ifobservers are notqualified pilots, theywill attend aground school to understand the proper roles ofan observer, communication procedures, propervisual scan techniques, operations at non-towered airports and appropriate sections ofthe Aeronautical Information Manual (AIM).Underthe 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; Weatherfactors; Airmanship and Decision-making and Safe Operations Procedures. It is Vaughn Flying Service's intentto respect the public's privacy. All sUAS flights will occurwith the consent ofthe propertyownerorauthority havingjurisdiction. 

### VI. Unmanned Aircraft System Vaughn Flying Service is petitioningfor an exemption to operate a homebuiltTBS 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 aGPS safety features which gives the operatorthe abilityto limit the height itflies above ground level (AGL), and to limitthe radius ofthe distance itflies from the operator. Flights within designated Class B, Cand Dairspace will always be coordinated withthe controlling authority and any flight in Temporary Fight Restricted airspace will only be conducted atthe invitation and in coordination withthe controlling authority. Ouraircraft also has afailsafe function that is triggered in the event communication is lost between the sUAS and the main controllertransmitter. At thattime, the sUAS will return to its point oftakeoffand land safety. Ifthe connection is 

### restored, the PIC can regain control offlight and land manually. We respectively request exemption underSection 333 to enable Vaughn Flying Service to operate efficient, limited, low-risk commercial sUAS operations forthe activities stated; respecting at all times the space and privacy ofcitizens and propertywhile keeping airspace safe. Sincerely, 

# {rJ

**Wayn ~**  Vaughn Flying Service 110 HollyTrail Brandon, MS 39047 601-416-4599