Chad Piazzo – Section 333 Exemption Petition

Mar 03, 2016

Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation 

Regulations from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 91.7(a); 91.9(b) (2); 

91.103(b); 91.109; 91.119(a)(b), 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 

91.409(a) (2); 91.417(a)&(b); 14 C.F.R. 407(a)(1); 14 C.F.R. 409(a)(2); and 14 C.F.R. 

417(a)&(b)

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 C.F.R. Part 11, Chad Piazzo, the owner and operator of the 3DR IRIS quad-copter 

Unmanned Aircraft System (UAS), seeks an exemption from the Federal Aviation Regulations 

(“FARs”) listed below so that Chad Piazzo can operate our small ultra-light weight UAS 

commercially in airspace regulated by the Federal Aviation Administration (“FAA”). Chad 

Piazzo will utilize an experienced, licensed pilot holding an FAA third-class airman medical 

certificate as the operator (1) (Pilot in Charge [PIC]) and a visual observer (VO) (2) that can 

perform the functions prescribed in the operating manual for all flights under this Exemption, if 

granted.

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the system to perform aerial mapping to enhance academic community

awareness, augment real estate listing videos, filmmaking, golf course mapping, agricultural 

mapping, and photogrammetry for various industries.

Use of the 3DR IRIS UAS for aerial mapping reduces the need to operate conventional aircraft 

for the same purpose and provides very high quality imagery at a fraction of the dollar cost and 

danger to human life (3) of using conventional aircraft. By approving these exemptions,

1. See Appendix A for PIC qualifications and certifications. 

2. Note; the VO will not be operating the UAS. 

3. See National Aeronautics and Space A dministration.2000.U.S. Civil Rotorcraft Accidents,1963 Through

1997.http://www.ihst.org/portals/54/industry_reports/NASA%20TP%20209597.pdf 2
the FAA will create benefits through safer survey methods by UAS, resulting in decreased 

potential for loss of life and enhanced efficiency and productivity for the affected activities, as 

well as environmental benefits, which are all ultimately in the public interest.

Committed to safety with each flight, Chad Piazzo’s exemption request would permit operation 

of ultra-light weight, unmanned (piloted by remote control) and comparatively inexpensive UAS 

in tightly controlled and limited airspace. Currently, similar lightweight, remote controlled 

UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in 

place to prevent catastrophe. In addition, Mr. Christopher C. Knight, Dark Technologies, 

(Exemption No. 12368) and - Steve Fincher Photography (Exemption No. 11859) were granted 

exemptions for these types of surveys with the 3DR IRIS.

Chad Piazzo has created and will follow its UAS Flight Protocols and Controls for safe operation 

to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act 

to further safety protocols exclusive to lightweight UAS's specific video and photography usage 

as Chad Piazzo’s records flight data and other information gained through permitted flight 

operations to share with the FAA through any required FAA reports to assist with future protocol 

and safety regulation.

Granting Chad Piazzo’s request comports with the Secretary of Transportation’s (FAA 

Administrator’s) responsibilities and authority to not only integrate UAS's into the national 

airspace system, but to “...establish requirements for the safe operation of such aircraft systems 

[UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the 

use of UAS's for real estate/Realtor purposes. Further, Chad Piazzo, will conduct its own 

operations in compliance with the protocols described herein or as otherwise established by the 

FAA.

For the reasons stated below, Chad Piazzo, respectfully request the grant of an exemption 

allowing Chad Piazzo to operate ultra-light weight, remote controlled UAS’s for community

awareness, enhance real estate listing videos for homeowners, filmmaking, golf course mapping, 

agricultural mapping, and photogrammetry for various industries. All of which will promote 

local economic growth through increased employment and increased tax base. Both with public 

safety in mind by keeping heavier manned aircraft containing combustible fuel that that poses 

potential public hazard.

4. See Helicopter Accident Analysis Team. 1998. The Final Report of the Helicopter Accident Analysis Team. June

1998.http://www.ihst.org/portals/54/industry_reports/HAATFinalReport.pdf

5. See Appendix B. for Chad Piazzo UAS Flight Protocols and Safety Controls. Applicant submits this manual as a confidential document under

14CFR11.35(b). The manual contains proprietary information that the applicant does not wish to be shared publically. The manual contains

operating. Requirements and procedures that are not available to the public and are protected from release under the Free domo Information Act

5USC552.
I. Contact Information, Chad Piazzo

7777 Lakeside Dr, Reno, Nevada, 89511 

Mobile: (775) 240-1220 Email: ChadPiazzo@Yahoo.com
II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Chad 

Piazzo Requests Exemption are: 

14 CFR Part 21;14 C.F.R. 45.23(b);14 C.F.R. 91, et seq.;14 CFR 407 (a) (1);14 CFR 409 (a) (2); 

and, 14 CFR 417 (a) & (b).

III. The Extent of relief Chad Piazzo seeks and the Reason Chad Piazzo Seeks Such Relief:

Chad Piazzo submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-

334, seeking relief from any currently applicable FARs operating to prevent Chad Piazzo

contemplated commercial cinematic, academic and other flight operations within the national 

airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned 

aircraft systems into our national airspace system as it is in the public’s interest to do so. Chad 

Piazzo’s ultra-light weight UAS meets the definition of “small unmanned aircraft” as defined in 

Section 331 and therefore the integration of Chad Piazzo’s ultra-light weight UAS is expressly

contemplated by the Reform Act. Chad Piazzo would like to operate its ultra-light weight UAS 

prior to the time period by which the Reform Act requires the FAA to promulgate rules 

governing such craft. Thereby, providing direct experience and valuable information for formal 

regulation that can be administered uniformly to all agriculture, mapping, and real estate related 

UAS aerial video and photography.

The Reform Act guides the Secretary in determining the types of UAS's that may operate safely 

in our national airspace system. Considerations include: The weight, size, speed and overall 

capabilities of the UAS's; Whether the UAS will be operated near airports or heavily populated 

areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of 

these items reflect in favor of an exemption for Chad Piazzo. Chad Piazzo’s UAS utilizes four 

(4) counter-rotating propellers for balance, control and stability. Weighing less than five (5) 

pounds (far below the maximum 55 pound limit); including camera with gimbal. This UAS is 

equipped with a compass, GPS, auto return safety technology if communication is lost between 

the UAS and the controller, Real-Time Fight Data Display6, and a No Fly Zone7 software 

default setting to force the device to abide by International Civil Aviation Organization 

regulations.

Chad Piazzo considers safety as foremost with each flight. Chad Piazzo small UAS is designed 

to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability 

and fear of financial loss, Chad Piazzo will not fly in winds exceeding 16 kph (10 mph) nor 

exceed an indicated airspeed of 29 knots (15 m/s). Built-in safety systems include a GPS mode 

that allows Chad Piazzo’s UAS to hover in place when radio controls are released. With three 

modes to choose from, Chad Piazzo will utilize the Smart Mode for aerial 
videography/photography. This is the safest, most reliable and stable mode to prevent accident 

and hazard. When PIC communication is lost, Chad Piazzo’s UAS is designed to slowly descend 

to point of take-off (Return to Home). Chad Piazzo will not operate the UAS near Airports, 

Hospitals, nor Police heliports, and will not operate near areas where general public is within 

fifty to one hundred (50-100) yards depending on location, conditions and weather. Chad 

Piazzo’s PIC and VO will be on constant alert for any manned aircraft (Police/Medical 

helicopters, etc.) or other UAS, and prepared to land/abort immediately to the nearest and safest 

ground point should a manned aircraft or UAS approach Chad Piazzo’s location, or Chad Piazzo

suspects manned aircraft or UAS may approach near our location. Chad Piazzo’s UAS is capable 

of vertical and horizontal operations, and is only flown within the line of sight of both the PIC 

and VO.

Utilizing battery power rather than combustible fuels, flights with Chad Piazzo’s UAS generally 

last between five (5) to seven minutes, with an altitude under 400 feet. Chad Piazzo will utilize a 

fresh fully charged battery with each flight as a safety precaution; full flight time limit for each 

battery is nine (9) to 12 minutes as tested. Chad Piazzo will not operate our UAS at or below 

manufacturer recommend minimum charge levels for operation; preferring to remain well within 

a safe operating range to insure adequate communication between radio control and UAS to 

eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each 

exercise to insure replacement for sufficient safe level of operation.

Chad Piazzo does not believe in taking risk that may cause a crash that could create hazard to the 

public/property/manned aircraft, and have no desire to lose an investment. Chad Piazzo has 

clocked numerous practice flights in remote areas as a hobbyist simulating flights for future 

commercial use to gain familiarization with the characteristics of this specific UAS's 

performance under different temperature and weather conditions. Chad Piazzo also practices 

computerized simulated flights to maintain adequate skills and response reflex time, for the sake 

of safety.

Chad Piazzo is extremely cautious when operating any UAS and will not “create a hazard to 

users of the national airspace system or the public.” 112 P.L. 95 § 333 (b).

6. Real-Time Flight Data includes UAS flight height, horizontal speed, vertical speed, and distance from the PIC. 

7. 3DR’s “NoFlyZone” : Two classes in this mode limit the 3DR IRIS’s ability to fly near restricted airport air space. Class A will not allow the

UAS to take off within 1.5 miles of the GPS location of an airport. Class B will has incorporated an increasing height limit from 35 feet AGL at

1.5 miles from an airport, increasing to 400 feet at 5 miles an airport. The UAS control system will also automatically warn the PIC when the

UAS has approached within 330 feet of the 5-mile buffer zone around an airport. This software will also not allow the user to set GPS waypoints

within 5 miles of the 5-mile No Fly Zone around an airport. For further details, visit http://www.3dr.com/fly-safe/iris/category-mc. 
Given the small size and weight of Chad Piazzo’ UAS, it falls well within Congress’s 

contemplated safety zone when it promulgated the Reform Act and the corresponding directive 

to integrate UAS's into the national airspace system. Chad Piazzo UAS, used in hobby flight, has 

a demonstrable safety record and does not pose any threat to the general public or national 

security.

IV. How Chad Piazzo Request Will Benefit the Public As A Whole:

Aerial videography for geographical awareness in real estate, filmmaking, golf course mapping, 

agricultural mapping, and photogrammetry for various industries has been around for a long time 

through manned fixed wing aircraft and helicopters. For small budget companies, farms and 

average homeowners, the expense of manned aerial videography is cost prohibitive. Only large 

companies can afford to absorb such expense, this depriving the remainder of the public from a 

valuable marketing and mapping tool. Manned aircraft pose a threat to the public through 

potential catastrophic crash that Nevada has experienced in the past with private and public 

officials involved in crashes in recent years. 

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown 

UAS's into the national airspace system, hence the passing of the Reform Act. Granting Chad 

Piazzo’s exemption request furthers the public interest through academic/visual awareness of the 

geographical benefits around Nevada. Chad Piazzo’s ultra-light weight UAS is battery-powered 

and creates no emissions that can harm the environment. The consequence of my ultra-light 

weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are 

heavy, contain combustible fuel and can cause catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial 

video/photo capture through our battery operated ultra-light weight UAS's. Permitting Chad 

Piazzo to immediately fly within national air space furthers economic growth by offering costeffective videography and mapping products.

V. Reasons Why Chad Piazzo Exemption Will Not Adversely Affect Safety Or How The 

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

Chad Piazzo’s exemption will not adversely affect safety. Quite the contrary, for the reasons 

stated, permitting Chad Piazzo to log more flight time in FAA controlled airspace, with 

communication with the FAA, will allow us to contribute to the innovation and implementation 

of new and novel techniques for realtors, filmmaking, golf courses, agricultural mapping, and 

photogrammetry for various industries as well as continuing to educate the public through 

publishing articles. In addition, Chad Piazzo submits the following representations of 
enhancements to current aerial videography and photography for real estate, filmmaking, golf 

courses, agricultural mapping, and photogrammetry for various industries:

 Chad Piazzo UAS weighs less than 5 pounds complete with a small ultra-light weight 

high quality GoPro 3 Black camera;

 Chad Piazzo will only operate this UAS below 400 feet, as recommended by the FAA 

Modernization and Reform Act of 2012;

 Chad Piazzo’s UAS will only operate for 10 minutes per flight;

 Chad Piazzo will land this UAS prior to manufacturer recommended minimum level of 

battery power, 30% battery power remaining. Also, Chad Piazzo UAS has an automated 

function which results in immediate landing when a low battery is detected;

 Chad Piazzo will pilot this UAS through remote control by line of sight;

 Chad Piazzo’s UAS has GPS-controlled autopilot system to maintain UAS stability and 

control,

 Chad Piazzo’s UAS has an Auto Return-to-Home & Landing function to increase safe 

return of the UAS to the ground, 

 A pre-programmed flight safety feature whereby Chad Piazzo’s UAS automatically 

hovers and then slowly lands if communication with the remote control pilot is lost;

 Chad Piazzo will actively analyze flight data and other sources of information to 

constantly update and enhance safety protocols;

 Chad Piazzo will only operates in reasonably safe environments that are strictly 

controlled and are away from: power lines, elevated lights, airports and actively

populated areas;

 Chad Piazzo will conduct extensive pre-flight inspections and protocol review, during 

which safety carries primary importance;

 Any maintenance or alterations of Chad Piazzo’s UAS that could affect operation or 

flight characteristics will require a functional test flight before returning to work;

 Chad Piazzo will always obtain all necessary permissions prior to operation, including 

issuing a notice-to-airmen (NOTAM) prior to operations; and,

 Chad Piazzo will have procedures in place to abort flights in the event of safety breaches 

or potential danger. 

In recognition of the FAA’s Exemption No. 11304A, and specifically Exemption No. 12368 for 

the same UAS model (3DR IRIS); prior to conducting operations for the purpose of aerial 

photography/videography, Chad Piazzo’s PIC will have accumulated 25 hours of total time as a 

UAS rotorcraft pilot including at least 10 hours as a UAS pilot with a multi-rotor UAS. Prior to 

operations, Chad Piazzo’s PIC must also have accumulated a minimum of 5 hours as a UAS pilot 

operation the 3DR IRIS 2. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).
Chad Piazzo’s safety protocols provide a level of safety equal to or exceeding existing rules. It is 

important to note that absent the integration of commercial UAS into our national airspace 

system, helicopters are the primary means of aerial video and photography for community

awareness and real estate. While the safety record of such helicopters is astounding, there has 

been local incidents involving loss of life as well as extensive property damage; it is far safer to 

operate a battery powered ultra-light weight UAS.

 First, the potential loss of life is diminished because UAS's carry no people on board and 

Chad Piazzo will only operate its UAS in specific areas away from mass populations.

 Second, there is no fuel on board a UAS and thus the potential for fire or explosions is 

greatly diminished.

 Third, the small size and extreme maneuverability of Chad Piazzo’s UAS allow the PIC 

to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small 

size and weight, even when close enough to capture amazing images, Chad Piazzo’s UAS 

need not be so close to the objects they are focused on through the technology and use of 

post editing software allowing pan and zoom.

Accordingly, Chad Piazzo’s UAS has been experimentally operated for 

familiarization/competency and will continue to operate at and above current safety levels. 

Furthermore, Chad Piazzo’s PIC has accumulated 40 hours of total time as a UAS multi-rotor 

pilot. Chad Piazzo’s PIC has also accumulated more than 20 hours as a UAS pilot operation the 

3DR IRIS.

VI. A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 

C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. Part 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, 

weight and enclosed operational area of Chad Piazzo’s UAS permits exemption from Part 21 

because Chad Piazzo’s UAS meets (and exceeds) an equivalent level of safety pursuant to 

Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform 

Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness 

certificate requirement in consideration of the weight, size, speed, maneuverability and proximity

to areas such as airports and dense populations. Chad Piazzo’s current UAS meets or exceeds 

each of the elements.

14 C.F.R. 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 FARs, this Regulation is 

inapplicable. However, Chad Piazzo’s PIC will still ensure that the UAS is in an airworthy

condition based on compliance with the operating documents prior to every flight.
14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board 

pilots or passengers, and given the size of the UAS, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a safety/flight manual delineating 

areas where safety can be defined9. The FAA has previously issued exemptions to this regulation 

in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 

and 32827. However, Chad Piazzo’s UAS operations manual will be kept in a location accessible 

by Chad Piazzo’s PIC.

14 C.F.R. § 91.103 regarding preflight action. Chad Piazzo’s PIC will take certain actions before 

flight to ensure safety of the flight. These will include reviewing weather, flight battery

requirements(9), landings, and takeoff distances and aircraft performance data before initiation 

of the flight.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as Chad Piazzo’s UAS 

utilizes electronic GPS with a barometric sensor. According to the manufacturer of Chad 

Piazzo’s UAS, the GPS sensor is accurate to 2.6 feet Vertical and 8.2 feet Horizontal. These 

accuracies are adequate for Chad Piazzo to safely operate the UAS for its exempted purposes.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level 

of safety will be achieved by maintaining any such required certifications and registrations by

Chad Piazzo in a location accessible by Chad Piazzo’s PIC. (9)SeeAppendix B. and C.

B. 14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. Chad Piazzo’s UAS, by definition, is unmanned. Therefore the UAS does not 

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, twoinch lettering is difficult to place on such small aircraft with dimensions smaller that minimal 

lettering requirement. The FAA has previously issued exemptions to this regulation through 

Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119(a) and (b) prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. Chad Piazzo’s UAS will never 

operate at an altitude greater than 400 AGL; safely within the standard 400 AGL as 

recommended by the FAA Modernization and Reform Act of 2012. Chad Piazzo will however 

operate its UAS in safe areas away from areas depicted in “yellow” on VFR charts, providing a 

level of safety at least equivalent to or below those in relation to minimum safe altitudes. Chad 

Piazzo will conduct all operations under Chad Piazzo’s Protocols and Controls10, including 

posting a warning sign reading: “Attention Aerial Photography in Progress – Remain Back 150 

Feet”. Chad Piazzo will operate its UAS in accordance with Exemption No. 11109, which may
require the UAS be operated closer than 500 feet to essential persons. Non-participating persons 

must remain at appropriate distances (500 feet) from the UAS, and if they need to be closer than 

500 feet, non-participating persons will remain behind barriers or structures that can sufficiently

protect them from the UAS debris in the event of an accident. Given the size, weight, 

maneuverability and speed of Chad Piazzo’s UAS, an equivalent or higher level of safety will be 

achieved.

D. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above-cited Regulations require, amongst other things, aircraft owners and operators to 

“have [the] aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to Chad Piazzo's UAS. However, as a safety precaution Chad Piazzo’s PIC and 

VO will inspect Chad Piazzo’s UAS before and after each flight.

(10)See Appendix B.

A Summary the FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: 

Airworthiness Certificates, Manuals and the Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, 

weight and enclosed operational area of Chad Piazzo’s UAS permit exemption from Part 21 

because Chad Piazzo’s UAS meets an equivalent level of safety pursuant to Section 333 of the 

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both 

pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability and proximity to areas 

such as airports and dense populations. Chad Piazzo’s UAS meets or exceeds each of the 

elements. 14 C.F.R. 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 FARs, this 

Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the 

aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA 

has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and 

curative measures for any damaged hardware. Therefore, an equivalent level of safety will be 

achieved.
In summary, Chad Piazzo seeks an exemption from the following Regulations: 14 C.F.R. 21, 

subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 

91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119 (a)(b); 14 C.F.R. § 91.121; 14 C.F.R. § 

91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 

C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to 

commercially operate Chad Piazzo’s small unmanned vehicle/lightweight unmanned aircraft 

vehicle in community awareness, real estate operations, filmmaking, golf course mapping, 

agricultural mapping, and photogrammetry for various industries and to develop economic 

platforms for real estate and golf courses.

Currently, area awareness, filmmaking, real estate aerial videography/photography, golf course 

mapping, agricultural mapping, and photogrammetry for various industries relies primarily on 

the use of larger aircraft running on combustible fuel, posing potential risk to the public. 

Granting Chad Piazzo request for exemption will reduce current risk levels and thereby enhance 

safety. Chad Piazzo’s UAS craft does not contain potentially explosive fuel, is smaller, lighter 

and more maneuverable than conventional real estate video and photographic aircraft with much 

less flight time. Further, Chad Piazzo will operate at lower altitudes and in controlled airspace 

eliminating potential public risk flying to and from established air fields. Chad Piazzo has been 

informally analyzing flight information and will compile safety protocols and the 

implementation of a flight operations manual for real estate usage that exceeds currently

accepted means and methods for safe flight. Formal collection of information shared with the 

FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA 

Modernization and Reform Act of 2012.

There are no personnel on board Chad Piazzo’s UAS and therefore the likelihood of death or 

serious bodily injury is significantly diminished. Chad Piazzo’s operation of its UAS, weighing 

less than 5 pounds and travelling at lower speeds within limited areas will provide an equivalent 

level of safety as that achieved under current FARs. Accordingly, Chad Piazzo respectfully 

request that the FAA grant Chad Piazzo’s exemption request and Chad Piazzo is willing to 

cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general 

public at large.

Respectfully submitted,

Chad Piazzo

7777 Lakeside Dr, Reno, Nevada, 89511 

Mobile: (775) 240-1220 

Email: ChadPiazzo@Yahoo.com