Jayme Evans

6400 NE Hwy 99, Suite G

PMB 350

Vancouver, WA 98665

June 10, 2015

U.S. Department of Transportation Docket 

Management System 1200 New Jersey Ave., SE 

Washington, DC 20590

RE: Exemption Request under Section 333 of the FAA Modernization 

and Reform Act and 14 C.F.R. Part 11

To Whom It May Concern,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and CFR Part 11, I, 

Jayme Evans owner of Evans Above Imaging and operator of small, Unmanned Aircraft Systems, 

request exemption from the FAA regulations listed below so that I may commercially operate UASs 

in furtherance of a business and in FAA-controlled airspace, for the purposes of aerial data 

collection.

I am a software engineer and aerial/astrophotographer.

I will utilize a 3DRobotics Solo UAS. The Solo is a state-of-the-art, quad-rotor UAS weighing less 

than 55 pounds including payload. It operates at a maximum speed of 55 mph, has a flight time of 20

minutes with optical payload, and employs numerous safety systems, which meet or exceed those 

contemplated by the FAA, including autopilot, the ability to orbit, a "safety net" feature to program a

fixed altitude ceiling, the ability to set and follow way-points and program the entire flight into the 

autopilot as well as computer-assisted image-acquisition, allowing the PIC to keep full attention on 

flying, rather than being distracted by the image capture process.

The Solo UAS will be used for various commercial activities including civil search and rescue, 

seismic, geological, archaeological, mining, forestry and civil surveys, structural inspection, 

cinematography, promotional photographs and videos, enhancing real estate listings and other forms 

of data collection.

Considering the redundant safety features of the Solo UAS, its use to perform the activities I have 

outlined above will pose no threat to national security, national airspace (NAS) or the general public.

To ensure this, I will adhere to the following restrictions:

1. Flights will be preceded by a pre-flight inspection and terminated by a post-flight inspection.

2. Flights will only occur in the day time hours.

3. Flights will be operated in the line of sight of the operator( PIC) and Observer,(VSO) at 

all times.

4. Flights will be canceled any time weather or visibility deteriorate, or wind increases to 

level exceeding manufacturer's recommendations for safe operation.
5. The UAS will weigh less that 55 lbs at all times, including payload.
6. PIC and VSO will remain in both visual and voice contact during the flight operation.

7. The PIC will perform a check of the flight area and ensure all non-involved persons 

have cleared the area.

8. Consent will be obtained from all photographic subjects, both to enhance safety and 

ensure privacy.

9. All required FAA clearances, will be obtained and distances from airports strictly observerd.

10. At no time will flights be conducted above 400 feet AGL.

In consideration of the size, weight, speed, payload, safety features and operating characteristics of 

the UAS I have described, along with the restrictions I have voluntarily set, I respectfully request 

exemption from the following:

14 CFR part 21, Certification procedures for products and parts, Subpart H concerning

Airworthiness Certificates. The size, weight, speed, altitude, safety features and operating

characteristics of my UAS permits exemption from Part 21 because it meets an equivalent level of

safety pursuant to Section 333 of the Reform Act.

14 CFR 61.23(a) and (c) concerning Medical certificates: Requirement and Duration. Since my UAS

carries no crew, no passengers and no combustible fuel, an airline transport pilot certificate will be 

inapplicable in the context of the proposed regulations. Therefore I request exemption.

14 CFR 61.101(e)(4) and (5) concerning Recreational pilot privileges and limitations. The 

restrictions that no recreational pilot may act as PIC of an aircraft for compensation or in furtherance

of a business will be inapplicable in the context of the proposed regulations. Therefore, I respectfully

request exemption.

14 CFR 61.113(a) - Private pilot privileges and limitations. Considering that my UAS will carry no 

passengers, this limitation will be inapplicable in the context of the proposed regulations. Since 

property will be limited to optical, navigational, or safety-related payloads under 55 lbs., it meets an 

equivalent level of safety. For these reasons and for the same reasons cited above regarding 

compensation, I respectfully request exemption.

61.315(a) - concerning Sport pilot privileges and limitations. No such sport pilot certificate, 

nor limitations will be applicable as contemplated by Section 333, therefore, I respectfully 

request exemption from.

14 CFR 91.119(c)- Concerning Minimum safe altitudes. The FAA-mandated flight ceiling is 400 

feet. Therefore, since I am limited to this ceiling, I respectfully request exemption. An equivalent 

level of safety will be achieved by adhering to FAA-mandated altitude and airspace restrictions.

14 CFR 91.121 - Concerning Altimeter settings. Since I operate a UAS, this regulation is 

inapplicable. Therefore, I respectfully request exemption. An equivalent level of safety is already 

achieved with my UAS's instrumentation and advanced software capabilities.

14 CFR 91.151(a)(1) - Concerning Fuel Requirements for flight in VFR conditions. Since I operate a

UAS that carries no fuel, this requirement is inapplicable, therefore I respectfully request exemption.

My UAS already possesses an equivalent level of safety, with it's "auto-return" feature, when the 

battery level reaches 25%.
14 CFR 91.405(a) - Concerning Maintenance Required. Since I operate a UAS, this regulation is 

inapplicable, therefore I respectfully request exemption. An equivalent level of safety will be 

achieved by performing inspections of my UAS at regular intervals and maintaining maintenance 

logs myself.

14 CFR 91.407(a)(1) - Concerning Operation after maintenance. Since I operate a UAS, this 

regulation is inapplicable, therefore I respectfully request exemption. An equivalent level of safety 

will be achieved by performing a test flight whenever UAS components are repaired, replaced or 

altered in any way.

14 CFR 91.409(a)(1) and (2) - Concerning Inspections. Since I operate a UAS, such inspections are 

inapplicable, therefore I respectfully request exemption. An equivalent level of safety will be 

achieved by performing regular UAS inspections myself and repairing or replacing any damaged or 

worn components.

14 CFR 91.417(a) and (b) - Concerning Maintenance records. Since I operate a UAS, such records

are inapplicable, therefore I respectfully request exemption. An equivalent level of safety will be

achieved by maintaining such records myself.

14 CFR 45.23 (b) Concerning Display of marks. Since I operate a UAS, addition of such marks is 

not possible on such a small craft, so this regulation is inapplicable, therefore I respectfully request 

exemption.

14 CFR 91.9 (b) (2) - Concerning Civil aircraft flight manual in aircraft. Since I operate a UAS, it is

not possible to carry flight manuals on such a small craft, so this regulation is inapplicable, therefore

I respectfully request exemption. An equivalent level of safety will be achieved by maintaining all 

operating documents and manuals myself.

14 CFR 91.103 (b) - Concerning Pre-flight action. Since I operate a UAS, it requires no runway and

can take off in the near-vertical, so this regulation is inapplicable, therefore I respectfully request 

exemption. An equivalent level of safety will be achieved by performing a pre-flight inspection of 

the area of operation, to ensure there are no obstacles, safety hazards, non-participants or other 

impediments to safe takeoff/landing.

14 CFR 91.109 Concerning Flight instruction. Since I operate a UAS, it has no such instrumentation

or controls and cannot carry a pilot or instructor, so this regulation is inapplicable, therefore I 

respectfully request exemption. An equivalent level of safety will be achieved by utilizing the Solo's

integrated flight simulator and regular, dedicated training flights.

14 CFR 91.203(a) &(b) - Concerning Civil aircraft certifications. Since I operate a UAS, no such 

airworthiness certificates are applicable, therefore I respectfully request exemption.

In several similar cases, exemptions to the above rules were granted. Considering the size, weight, 

speed, maneuverability, operating characteristics and prescribed altitudes, along with the restrictions

I have set forth, this request is materially similar to numerous other exemptions, notably 11062, 

11109, 11112, 11213 and 11623. I respectfully request similar consideration without undue delay.