June 7th, 2015

U.S. Dept. ofTransportation, Docket Operations VVest Building Ground Floor, Room w12-140 1200 NewJerseyAvenue, SE., VVashington, DC 20590 Ron Davison LLC 4265 Chickadee Circle

Jackson, VVY 83001

VIA FEDERAL DOCUMENT MANAGEMENTSYSTEM

Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam:
Pursuantto Section 333 ofthe FAA Modernization and Reform Act of 2012 (the "ReformAct") and 14 C.F.R. Part 11, Ron Davison LLC, seeks an exemption from Federal Aviation Regulations ("FARs") detailed below for the following described UnmannedAerial System called in this application the ME System, which includes an UnmannedAircraft (UA) and ground station-based equipment and crew: THE UNMANNEDAIRCRAFT (UA):**[~]A** lightweight (20 lb gross weight with all on-board equipment), manufactured by DJI, Inspire 1- t-600, that includes the following equipment in flight; 

### [¥] An on-board flight computerwith GPS navigation and location abilitythat receives signalsfor flight controls from a ground-based transmitter/controller;**[~]An** on-board camera capable of capturing imagery in the form offull color, high definition still photos and video;**[~** An on-board telemetry system that deliversflight datafrom the on-board flight computerto the on-board radio transmitter including altitudeAGL, horizontal and vertical speed, compass direction offlight and direction backto its launch site;**~** A2.4GHz on-board radio transmitterthattransmits live video from the on-board camera plus all the flight datafrom the telemetry system described above;
THE GROUD STATION -BASED PART OFTHE SYSTEM:**t~]** A Pilot in Command (PIC) in operational control of aflight operation from beginning to end and who controls the UAwhile in the air;**[~A**2.4GHz radio transmitter/controller operated bythe PIC to control the UAwhile in flight; 

## ["?J A radio receiver receiving live video and flight datafrom the on-board camera and computer projects it all together onto a screen for the PIC to view during flight; 

## t?.J AVisual Observer (VO) is a person who provides a second pair of eyesto visually track the UAwhile in flight.The requested exemption would support an application for a commercial Certificate of Authorization to use the above described ME System to support Production of promotional materials (video and/or still images) for Real Estate sales Production of promotional materials, (video and/or still images) forTravel and Tourism industriesProduction of promotional materials, (video and/orstill images) for commercial businesses,Photography and videography of social events, such as weddings neveroperating over persons not directly involved with the ME system. The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time of only 18 minutes, this is offers little or no risk to national security.
Low level oblique photos and video from several angles are far more effective than groundbased imageryfor displaying the characteristics of large, complex propertieswith several buildings and largetrees. The alternative could be to charter a full-sized helicopterforthis purpose, which has proven more costlythan many potential clients are ableto afford. The benefits of reduced cost and improved quality of presentation from the UAwill be valuable to and benefit many buyers and sellers of real property and marine property. Additionally, we requestthatwe be allowed to use our system to benefitfirst responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subjectto all limitations cited in this application as we do so. The ME System will be operated in the field with both a PIC and aVO in accordance with FAA Policy N8900.227 Section 14 "Operational Requirements for UAS" and with the following Restrictions: a) No flight will be made with a UAGross weight exceeding 55 pounds; b) All operations must occur in FAA Class G airspace at no more than 400ftAGL, at an airspeed of no morethan 50 knots and no furtherthan 3/4 NM from the PIC; c) All operations must utilize avisual observer (VO). The VO and PIC must be able to communicate by voice at all times during aflight operation; d) Operationswill be restricted to flights over property with the permission ofthe property owner; e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UAtype; f) All required permits will be obtained from state and local government priorto operation; g) The ME System will not be operated overdensely populated areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over any open-air assembly of people; j) The ME System will not be operated over heavilytrafficked roads; k) The ME System will not be operated within 5 NM of an airport or heliport; I) Operations will be restricted to day only and weather conditions equivalentto VFR; m) The PIC will briefthe VO and property owner aboutthe operation and risk before the first flight at each new location; n) No flight may be made without a Pre-Flight Inspection bythe PIC before each operation to ascertain thatthe UA is in a condition safe forflight (see AppendixA).The PIC and VO will meetthe requirements outlined in FAA Policy N8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction as part of their initial training.
We submitthat the combination of the UA's light weight, flight performance and ability, fully qualified flight crew and strict operation underthe guidelines established in 8900.227, and under all ofthe Restrictions (a) through (n) listed above, the FAA can have full confidence thatthe operation will have an equivalent or greater level of safetythan manned aircraft performing the same mission. The name and contact information ofthe applicant are: dba Ron Davison LLC : Ron Davison Ph: 307-690-5720 Email: ron@rondavison.com
The regulations from which the exemption is requested are listed below. Beside each regulation number is the page ofthe attached Addendum upon which each may be found togetherwith our proposed equivalent level of safetyfor each regulation:

- 14 CFR Part 21

.................................Addendum Page 1

- 14 CFR 91.203

.................................Addendum Page 1

- 14 CFR 45.23, 45.29

..........................Addendum Page 2

- 14 CFR 91.9

....................................Addendum Page 2

- 14 CFR 61.113,61.133

.......................Addendum Page 2

- 14 CFR 91.109, 91.119, 91.121

..............Addendum Page 3

- 14 CFR 91.151

.................................Addendum Page 3

- 14 CFR Subpart E (91.401

- 91.417)

......Addendum Page 3

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

...Addendum 1
We are prepared to modify or amend any part ofthis request to satisfythe need for an equivalent level of safety. Please contact us at anytime ifyou require additional information or clarification. We lookforward to working with your office. Sincerely, 

# Cl23J**~-------** Ron Davison, Ron Davison LLC Addendum containing Exemption Requests and Equivalent Level of SafetyAppendixA- Flight Manual's Appendix B

- Owner's Manual for UAADDENDUM EXEMPTION REQUESTSAND EQUIVALENT LEVELOF SAFETY
Ron Davison LLC requests an exemption from the following regulations as well as any additional regulations that maytechnically applyto the operation ofthe ME System:
14CFR Part 21, Subpart H: Airworthiness Certificates This part establishesthe procedures forthe issuance of an airworthiness certificate. While the FAAcontinuesto workto develop airworthiness standardsfor UnmannedAerial Systems, we request an experimental certificate be issued forthe ME System undereitheror both ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued forthe following purposes: (a) Research and development. Testing new aircraft design concepts, newaircraft equipment, newaircraft installations, newaircraft operating techniques, or new usesfor aircraft. (b) Showing compliance with regulations. Conducting flighttests and other operationsto show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate majordesign changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expectthat an experimental certificate would permit ourcommercial purpose as well.
The aircraftwill not carry persons or property, will not carry fuel, and will onlyfly understrict operational requirements. Combined with the UA's lightweight, being constructed primarily of carbon fiber and plastic, we proposethatthe UAwill 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 forthis 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 ofsafety outlined in the previous paragraph.
14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation providesthat an airworthiness certificate, with the registration numberassigned to the aircr..aft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) providesthatthe airworthiness certificate be "displayed atthe cabin or cockpit entrance so that it is legible to passengers orcrew." At a maximum grossweight of 6.5 pounds, the UAis too small to carry documentation, does not have an entrance, and is not capable of carrying passengers orcrew. To obtain an equivalent level ofsafety and meetthe intent of91.203, we propose that documentsdeemed appropriate forthis aircraft bythe FAAwill be co-located with the crew atthe ground control station and available for inspection upon request. In orderto identifythe aircraft, we propose thatthe information found on airworthiness and registration certificates be permanently affixed to the aircraftvia placard containing the following information plusthe word "EXPERIMENTAL"to satisfythe requirement of 14 CFR 45.23, which follows immediately afterthe proposed placard description below:AppendixA EXPERIMENTAL Manufacturer: OJI Innovations, Inc. 950 E BaselineAve. Ste. 210Apache JunctionAZ 85119 Models: Inspire 1- t-600,
14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display 11N'' and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must displaythe word

11EXPERIMENTAL11 in letters at least 2 inches high nearthe entrance to the cabin, cockpit, or pilot station. The UAdoes not have an entrance in which the word 11EXPERIMENTAL11 can be placed, and may not have a registration numberassigned to it bythe FAA.
We propose to achieve an equivalent level of safety by including the word 11EXPERIMENTAL11 in the placard on the top ofthe aircraft, as shown above, where the PIC, VO and others in the vicinity ofthe aircraft while it is preparing for launch will be ableto see the designation. Additionally, we feel thatthe 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 bannerthat contains the words**~~unmanned** Aircraft Ground Station 11 in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM ofthe ground station, the banner should be visible to anyone that observesthe aircraft and choosesto investigate its point of origin.
14CFR 91.9 Civil aircraftflight manual, marking, and placard requirements. This regulation providesthat no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume thatthe intent ofthis requirement is to ensure thatflight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not onlytoo small to carry documentation, the documentation would not be available to the crew during flight operations.
To obtain an equivalent level of safety and meetthe intent of 91.9, we propose that a current, approved UA Flight Manual (AppendixA) 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 providesthat 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 pilotto 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 oremployment; and (2) The aircraft does not carry passengers or propertyfor compensation or hire. Our proposed operations require thatthe PIC must either
1. Hold a Sport Pilot Certificate issued by the FAA, and have logged 25 hours offlight experience in this type of UA, or 2. Meetthe requirements of 8900.227 para 16(c)(2)(c) 110perationswithout a pilot**certificate~~** in which the PIC is required to complete 11FAA private pilot ground**instruction~~** and pass 11the FAAPrivate Pilot written**examination.~~** Since there are currently no means available forthe pilot of a UAS to gain the experience in an equivalent category and class in orderto applyfor a commercial pilot's license, we propose to generate an equivalent level of safety by requiring our pilots to complete, at a minimum, FAAcommercial pilot ground instruction and pass the FAA Commercial Pilot written examination in addition AppendixA to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel we meetthe intent of 61.113 Subparagraph (b) even though the intent ofthis application is to conduct a business.
14 CFR 91.109 Flight Instruction; Simulated instrumentflight and certain flight tests The regulation states that 11No person may operate a civil aircraftthat is being used forflight instruction unlessthat aircraft hasfully functioning dual controls."
The ME System ground-based control station consists of a small hand-held radio transmitter and while it does not offer a second set of 11COntrols11

, both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having

11hands-On 11 the controls during flight, we feel thatthis technique meetsthe intent 91.109 and provides an equivalent level of safety.
14 CFR 91.119 Minimum safe altitudes: General. The regulation statesthat over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraftwill be operating at a maximum of400 feetAGL, we cannot comply with this requirement.
In orderto provide an equivalent level of safetywe will onlyfly over private propertywith a size of at leasttwo acres with the permission ofthe ownerofthe propertyflown over. The aircraftwill not be operated over congested areas or over any open air assembly of persons. The property ownerwill be briefed on the expected route offlight and the associated risks to persons and property on the ground. The aircraftwill 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 ofthe 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 ofthe aircraft.
The UAwill always fly below 400 feetAGL and will not need to maintain cruising altitudes in orderto prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UAon-board computerto the display screen held bythe PIC, providing a constantly updatedAGL readout.
14 CFR 91.151 Fuel requirements forflight in VFR conditions. The regulation providesthat no person may begin aflight in an airplane underday-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly afterthatfor at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety bufferfor delaysto landing. The UA is battery operated and the maximum duration offlight from a single battery charge is 18 minutes with a 20°/o reserve. Since the aircraftwill neverfly more than 

### 314 NM from the point of intended landing, afull battery charge at launch will ensure that we meetthe reserve energy requirement ofthis paragraph. We request an exemption to the word "fuel" and askfor an equivalent interpretation with the word "energy".
14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, Alterations The regulation providesthat 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 thatthe PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraftfor return to service." As provided in the Pre-Flight Checklist in AppendixA, the PIC will ensure that the aircraft is in an airworthy condition priorto everyflight and in addition conduct detailed inspections after everytwo hours offlight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All other maintenance will be performed by the manufacturer ortheir designated repairfacility. The PIC will documentwork performed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level of safety.
8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer Medical. This policy provides that both the PIC and VO must have avalid FAAsecond-class medical certificate issued under part 67 in orderto perform as a pilot or observer. The UAmaximum gross weight is 6.5 pounds, it is constructed of carbon fiber and plastic and the PIC is not on board. Both the PIC and the VO are required to be in VLOS. Given the unlikely eventthat both the PIC and VO become medically incapacitated while the aircraft is in flight, the UAwill return autonomouslyto the site of launching and land without crew intervention. Therefore, requiring the PIC and VO to meetthe same medical requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden.
We propose thatthe minimum medical requirements for the PIC and VO be vision corrected to 20/20 and avalid, state issued driver's license. The 20/20 vision requirement will ensure thatthe PIC and VO can see and avoid airtraffic; a licensed driver is medically qualified to operate a much largervehicle.APPENDIXA- FLIGHT MANUAL FLIGHT RESTRICTIONS a) No flight will be made with a UAGrossweight exceeding 55 pounds; b) All operations must occur in FAA Class G airspace at no more than 400'AGL, at an airspeed of no morethan 50 knots and no furtherthan 3/4 NM from the PIC; c) All operations must utilize avisual observer (VO). The VO and PIC must be able to communicate verbally at all times during a flight operation; d) Operations will be restricted to flights over propertywith the permission ofthe property owner; e) The PIC must have accumulated and logged, in a mannerconsistent with 14 CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UApilot with a similar UAtype; f) All required permits will be obtained from state and local government priorto operation; g) The ME System will not be operated overdensely populated areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over any open-air assembly of people; j) The ME System will not be operated over heavilytrafficked roads; k) The ME System will not be operated within 5 NM of an airport or heliport; I) Operations will be restricted to day only and weather conditions equivalentto VFR; m) The PIC will briefthe VO and property owner aboutthe operation and risk before the first flight at each new location; n) No flight may be made without a successful Pre-Flight Inspection bythe PIC before each operation to ascertain thatthe UA is in a condition safe for flight. PREFLIGHT CHECKLIST 1. Remote controller, aircraft battery, and mobile device are fully charged. 2. Propellers are mounted correctly and firmly. 3. Micro-SO card has been inserted if necessary. 4. Gimbal is functioning as normal. 5. Motors can start and are functioning as normal. 6. DJI Pilot app connected to the aircraft. TO REGAIN CONTROLAFTER LOST RADIO CONTACT If radio contact is lost and not restored within 3 seconds, an automatic Return to Home feature is activated and will bring the UAV backto the PIC.