CHRIS HOMAYOUNI PHOTOGRAPHY

P.O. BOX 218 CEDARBURG, WI 53012 | CHRIS@CHRISHOMAYOUNI.C OM | 262.424.6018 January 17, 2016

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave

, SE Washington, DC 20590

R e: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act"), Chris

Homayouni

, a Professional in photographer / v ideographer (the "Applicant"), planned operator of Small

Unmanned Aircraft Systems ("sUAS") seeks an exemption from Federal Aviation Regulations ("FARs") listed

below and discussed in Appendix A. Attached, as Appendix C, is a summary of this request.

The requested exemption would allow the Applicant to safely, efficiently and economically use commercial

sUAS in the National Airspace System (N AS), so long as such operations are conducted within and under the

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

As described more fully below, the requested exemption would authorize the Applicant to perform commercial

operations with sUAS that will provide the following benefits:

1. Commercial use of sUAS to perform aerial photography brings a new and more informed perspective to

the end user.

2. The use of sUAS will decrease congestion in the NAS along with reducing the noise and air pollution

generated during traditional manned aircraft flight operations.

3. Operation of sUAS will substantially reduce the risk to life and property in the air, and on the ground,

which is commonly associated with traditional manned aircraft flight operations.

4. Similar to the current manned aircraft flight operations that have been conducted for many decades,

sUAS used for similar tasks will not generate any new privacy issues.CHRIS HOMAYOUNI PHOTOGRAPHY

P.O. BOX 218 CEDARBURG, WI 53012 | CHRIS@CHRISHOMAYOUNI.C OM | 262.424.6018 Approval of this exemption would thereby enhance safety and fulfill the Secretary of

Transportation's (the FAA Administrator's) responsibilities under Section 333(c) of the Reform

Act to "establish requirements for the safe operation of such aircraft systems in the national

airspace system."

The name and address of the applican t are:

Christopher Mason Homayouni

Ph: 262

- 424

- 6018

Email: chris @ chrishomayouni.com

Address: P.O. Box 218 Cedarburg, WI 53012

The regula tions from which the exemption 

### is requested are as follows:

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. 61.133(a);

14 C.F.R. 91.?(a);

14 C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103;

14 C.F.R. 91.109(a);

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. 91.405(a);

14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.41?(a)

Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal

set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public

interest.

Q

ualification for A pproval Under Section 333 of the Reform Act:

The proposed operations in this petition for exemption qualify for expedited approval under Section 333

of the Reform Act. Each of t he statutory criteria and other potentially relevant factors are satisfied.

The proposed operations would permit the use of small and relatively inexpensive UAS under

controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) controlled as to access, and;

(4) would provide an increased level of safety beyond th at existing when fixed or rotor wing aircraft

are used to accomplish the same purpose.CHRIS HOMAYOUNI PHOTOGRAPHY

P.O. BOX 218 CEDARBURG, WI 53012 | CHRIS@CHRISHOMAYOUNI.C OM | 262.424.6018 The sUA S's planned to be operated are D JI Phantom Vision 3 , weighing 4 lbs. or fewer including payload.

It would operate, under normal conditions, at a spee d of no more than 30 knots. The princip al

construction material of the sUAS is plastic. Operations will be performed by Chris Homayouni "Pilot

in Command" (PIG), as outlined below, to insure that the sUAS will "not create a hazard to users of

the nat ional airspace system or the public." Given the small size of the sUAS involved and the pre

planned environment within which they will operate, the applicant believes that these operations fall

squarely within that zone of safety (an equivalent level of sa fety) in which Congress envisioned that

the FAA must, by exemption, allow commercial operations of sUAS to commence immediately. Also,

due to the size of the sUAS and the pre

- defined, restricted area in which the sUAS will operate,

approval of the application presents no national security issue. The operation of sUAS by

knowledgeable professionals will serve to enhance safety, add to the public benefit, and reduce

environmental impacts related to current methods of manned aircraft flight operations.

These limitations and conditions to which the PIG agrees to be bound when co nducting commercial

operations under an FAA issued exemption:

1. Safety will be the first and foremost consideration in any sUAS operation.

2. The sUAS pilot will be considered Pilot in Command (PIC), whether flying or supervising, and will

be responsible for safe operation of the flight.

3. Flights will be opera ted within line of sight of the PIC and/or an observer.

4. The sUAS weigh less then 4lbs. total.

5. Flights will be operated in Class G airspace

.

6. Flights will be operated under visibility and cloud clearance requirements equivalent to Visual

Flight Rules (VFR).

7. The sUAS will at all times give way to any aircraft carrying persons

.

8. Chris Homayouni (owner) be at all flights

9. Prior to a sUAS flight , an area of operation will be established. This area of operation will include a

defined latera l and vertical area, where the sUAS will operate. Safety procedures will be established for

p ersons, property and applicable airspace within the area of operation.

10. The sUAS shall operate from on

- site takoff/landing locations directly next to the PIC and/or

Observer.

11. Flight planning will include flight completion w ith at least 20% battery power remaining as

measured by the sUAS o r appropriate timing.CHRIS HOMAYOUNI PHOTOGRAPHY

P.O. BOX 218 CEDARBURG, WI 53012 | CHRIS@CHRISHOMAYOUNI.C OM | 262.424.6018 12. The sUAS will be equipped with an autopilot system. For example, the sUAS will utilize GPS

navigatio n for stability and reliability, failsafe's, return

- to

- home (RTH}, PIC will have control of the flight at

all times. F eat ures, amon g other built

- in safety features.

13. A Ground Station will be connected, by radio communication, to the sUAS during the entire flight,

which will give the PIC flight information such as GPS Position, Altitude, Battery Remaining, and other

telemetry information.

14. A briefing will be conducted in regard to the planned sUAS operations prior to operation at each

new location. All personnel who wi ll be performing duties within the boundaries of the area of operation

will be present for this briefing.

15. All requir ed permissions and permits will be obtained from appropriate state, county or city

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

16. Written

, to include electronic, and/or oral permission from the relevant property owners

will be obtained prior to an operation.

17. The sUAS pilot will be trained in advance for the safe operation of the sUAS to be operated.

This will include operation of the sUA S both in normal and emergency modes of operation, and will

include familiarization with the operation manual (or similar) if published by the sUAS manufacturer.

Training will also include ty pes of maneuvers to be performed and the safe operation in relation to

p ersons, property and applicable airspace.

It is the applicant's belief that the size, weight, speed, operating environment, and operating

capabilities provide an " equivalent level of safety" or better when operating a sUAS for the public

interest as outlined in Section 333 of the Reform Act. It is requested that the FAA Issue an exemption

to permit safe, legal, commercial sUAS operation by the applicant as soon as p ossible.

Respectfully submitted,

·

Chris Homayouni

P.O. Box 218 Cedarburg, WI 53012

262.424.6018

chris@chrishomayouni.comCHRIS HOMAYOUNI PHOTOGRAPHY

P.O. BOX 218 CEDARBURG, WI 53012 | CHRIS@CHRISHOMAYOUNI.C OM | 262.424.6018 Appendix A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

The applicant requests an exemption from the following regulations as well as any additional regulations

that may technically apply to the operation of sUAS's:

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1)

Section 91.20 3(a)(1) requires all civil aircraft to have a certificate of

airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural

requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a)(1 ) . Given the

size of the aircraft (less than 15 lbs.) and the limited operating area associated with its ut ilization, it is

unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or

exceed current safety leve ls.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section

333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the

FAA to exempt aircraft from the r equirement for an airworthiness certificate, u pon consi deration of the

size, weight, speed, operational capability, and proximity to airports and populated areas of the sUAS

involved.

In this case, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness

certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional

aircraft (fixed win g or rotorcraft) with an airworthiness certificate. The sUAS weighs less than 15 lbs.

fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate

exclusively within an area pre

- disclosed and in compliance with conditions set forth herein.

Operations under this exemption will be tightly controlled and monitored by both the operator,

pursuant to the conditions set forth above, and by local public safety requirements. The FAA will

have advance notic e of all operations through the filing of NOTAMs. Receipt of the prior permission

of the land owner, the size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is

carried to the location and not flown there all establish the equiv alent level of safety. The sUAS

provides at least an equivalent, and most likely exceeds, level of safety to that of such operations

being conducted with conventional aircraft that would be orders

- of

- magnitude larger and would be

carrying passengers, cargo

, and flammable fuel.

14 CFR. § 45.23 & 91.9(c): Marking of the Aircraft Regulation 45.23 provides:

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital

letter "N" (denoting United States registration) followed by the registration number of the aircraft.

Each suffix letter used in the marks displayed must also be a Roman capital letter.CHRIS HOMAYOUNI PHOTOGRAPHY

P.O. BOX 218 CEDARBURG, WI 53012 | CHRIS@CHRISHOMAYOUNI.C OM | 262.424.6018 (b) When marks include only the Roman capital letter "N" and the registration number is displayed on

limited, restricted or light

- sport category aircraft or experimental or provisionally certi ficated aircraft, the

operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot st ation, in

letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

sport," "experimental," or "provisional," as applicable.

Regulation 91.9(c) provides:

No person may operate a U.S.

- registered civil aircraf t unless that aircraft is identified in accordance with

part 45 of this chapter.

The sUAS has no entrance to the cabin, cockpit, or pilot station on which the markings can be

placed. Given the size of the sUAS, two

- inch lettering will be impossible. Off icial marking systems for

sUAS have not yet been established for operations inside the NAS. The applicant is prepared to mark

the sUAS with the name of the organization and location or origin and fulfill any other request by the

FAA to this topic in accordance to § 45.29(1) where the pilot, observer, and others working with the

sUAS will see the identification of the sUAS.

The FAA has issued the following exemptions to this regula tion; see Exemption Nos. 8738, 10167,

10167Aand 10700.

14 CFR § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command;

Commercial Pilot Privileges and Limitations

Section 61.113{a) & {b) limit private pilots to non

- commercial operations. Unlike a conventional

aircraft that carries a pilot, passengers, and cargo, the sUAS in this ca se is remotely controlled with

no passengers or property of others on board.

Section 61.133{a) requi res an individual with a commercial pilot's license to be pilot in command of

an aircraft for comp ensation or hire. The applicant respectfully proposes that operator requirements

should take into account the characteristics of the particular sUAS. Most sU AS autopilot's have a

h igh degree of pre

- programmed control and various built

- in technical capabilities that strictly limit

the potential for operation outside of the operating conditions set forth in the exemption

application. Hands

- on experience with th e sUAS are a far more effective guarantee of flight safety

than a commercial pilot certificate would be, until the FAA Pilot Certificate requirements catch up

to the sUAS technology.CHRIS HOMAYOUNI PHOTOGRAPHY

P.O. BOX 218 CEDARBURG, WI 53012 | CHRIS@CHRISHOMAYOUNI.C OM | 262.424.6018 The sUAS autopilots have an all

- digital software platform with advance d features previously

restricted to full size unmanned aircraft. Automated features and advanced fly

- safe controls enable

safe, reliable operation, as well as a dvanced networking capabilities and system extensibility.

• The system can autonomously fly a pr ogrammed flight path or fly in manual

mode

• Flight time and battery minutes are displayed at all times. The system will return home and

land automatically if user

- configurable li mits are reached. Flight safety is a priority, no ma tter the

operating environment or project. sUAS offer superior safety over manned aircraft by removing the

need for people to be onboard in potentially dangerous situations. With multiple built

- in safety

features, sUAS platforms lead manned operations with respect to safety.

• The sUAS automatically detects potential issues

- with configurable automated response

behavior such as a return

- home

- and

- land routine

• The sUAS self

- calibrate all of their sensors and perform required failsafe pre

- flight test s prior

to takeoff to check for errors

• The sUAS have the ability to set up visual no

- fly zones or create a virtual fence so the sUAS

can't fly horizontally or v ertically beyond the preplanned flight area

• The sUAS have battery minutes and flight time displayed at all times. The system will return

home and land automatically if user

- configurable limits are reached

• The sUAS auto detect a lost GPS, warns the pilot and initiates an immediate landing.

• Low battery on the sUAS triggers a Non

- Fatal Warning alarm to return home, land and replace

the battery

• If sUAS detect a lost

- link to the Ground Station the vehic le will perform its pre

- defined Non

Fatal Condition Response.CHRIS HOMAYOUNI PHOTOGRAPHY

P.O. BOX 218 CEDARBURG, WI 53012 | CHRIS@CHRISHOMAYOUNI.C OM | 262.424.6018 Given these safety features, the applicant proposes that operators of s U A S with these features

should not be required to hold a comm ercial or private pilot certification. Instead, operators should

be required to:

• H ave completed a training pro gram for operation of the sUAS, if available.

• have completed 15 hours (or 150 flights) of training on the sUAS and/or simulator before

commencing commercial operations. The applicant notes that the FAA has found that safety

factors permitted operation of sUASs by operators with these qualifications in the case of

operations pursuant to public COAs where the mandatory operating conditions specified above

are present. See Federal Aviation Administration, Notice N

- 8900.227, Unmanned Aircraft Systems

(UAS) Operational Approval, at 20

- 21 (July 30, 2013). The FAA has the statutory authority, granted

at 49 U.S.C.§44701 (f) to waive t he pilot requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing

operation of the sUAS without a private pilot's certificate or a commercial pilot' s certificate,

under the conditions set forth herein.

The risks associated with the operation of the sUAS (given its size, speed, operational capabilities,

and lack of combustible fuel) are so diminished from the level of risk associated with private pilo t

operations or commercial operations contemplated by Part 61 with conventional aircraft (fixed

wing or rotorcraft), that allowing operations of the sUAS as set forth above meets or exceeds the

present level of safety provided under 14 C.F.R. § 61.113 (a) & (b) and does not rise to the level of

requiring a commercial pilot to operate the aircraft under § 61.133(a).

14 CFR § 91.?(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. Should the exemption be granted allowing commercial operation of sUAS without an

airworthiness certificate, no standard will exist for airworthiness of the sUAS. Given the size of

the sUAS and the previous COAs issued for similar sUAS, an equivalent level of safety will be

achieved by ensuring compliance with the given sUAS manuals and use of safety checklists prior

to each flight.

14 CFR § 91.9(b){2): Civil Aircraft Flight Manual in the Aircraft.

The regulation provides: No person may operate a U.S.

- registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless

there is available in the aircraft a current approved airplane or Rotorcraft Flight Manua l, approved

manual material, markings, a nd placards, or any combination thereof.CHRIS HOMAYOUNI PHOTOGRAPHY

P.O. BOX 218 CEDARBURG, WI 53012 | CHRIS@CHRISHOMAYOUNI.C OM | 262.424.6018 Given the size of sUAS, they have no ability or place to carry such a flight manual on the

aircraft, not only because there is no pilot on board, but be cause there is no room or capacity to

carry such an item on the aircraft. The equivalent level of safety will be achieved by keeping the

flight manual at the ground control point where the pilot flying the sUAS will have immediate

access to It. The FAA has issued to others the following exemptions to this regulation:

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 1 0167, 10167A, 10602, 32827, and

10700.

14 CFR § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an

exemption will be needed. An equivalent level of safety will be provided by following a

compreh ensive preflight checklist. The PIC will take all actions including reviewing weather, flight

battery requirements, landing and takeoff distances and aircraft performance data before initiation

of flight.

14 CFR § 91 .109(a) & 91.319(a)(1): Flight Instruction

These regulations provide that no person may operate a civil aircraft (except a manned free balloon)

that is being used for flight instruction unless that aircraft has fully functioning dual controls.

The s UAS are remotely piloted aircraft and by design, do not have fully functional dual controls.

Flight control is accomplished through the use of a control box that communicates with the aircraft

via radio communications. The flight plan is either manually c ontrolled through point

- and

- click

navigation or preprogrammed as way points into the auto pilot before or during flight and only in

unusual circumstances will the pilot input control functions to alter the pre

- programmed flight.

Given the size and speed of the sUAS, an equivalent level of safe training can still be performed

without dual controls because no pilot or passengers are aboard the sUAS, and all persons will be a

safe distance away should the sUAS experience any difficulties during fli ght instruction. The FAA has

approved exemptions for flight training without fully functional dual controls for a num ber of airc raft

and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A.

14 CFR § 91.119: Minimum Safe Al titudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c)

limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the

surface, except over open water or sparsely populated areas. In those cases, the aircraft may

not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

Because aerial survey, mapping and inspection work must be accomplished at relatively low

altitudes and at altitudes less than 5 00 feet AGL, an exemption from Section 91.119(c) is needed.CHRIS HOMAYOUNI PHOTOGRAPHY

P.O. BOX 218 CEDARBURG, WI 53012 | CHRIS@CHRISHOMAYOUNI.C OM | 262.424.6018 The equivalent level of safety will be a chieved given the size, weight, speed, and

material with which sUAS are built. Also, no flight will be taken without the permission of the land owner

or those who control the land. Because o f the advance notice to the landowner, all affected individuals

will be aware o f t h e f Ii g h t s

. Compared to aerial survey operations conducted with aircraft or

rotorcraft weighing far more than 15 lbs. and carrying flamm able fuel, any risk associated with these

operations will be far less than those currently allowed with conventional aircraft operating at or below

500 feet AGL. Indeed, the low

- altitude operations of the sUAS wil l maintain separation between these

sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 CFR § 91.121: Altimeter Settings

Section 91.121 requires a person operating an aircraft to maintain cruising altitu de or flight level by

reference to an altimeter that is set to the elevation of the departure airport or barometric pressure.

Some sUAS have a barometric pressure sensor, while others only use GPS for elevation or altitude.

When a barometric pressure senso r is on the sUAS, it is typically "zeroed" at the point of take

- off;

this is right next to the PIC and not at a departure airport. The altitude reading will be relative to

that point and not a known elevation. The equivalent level of safety will be achieved by the PIC

confirming the elevation or altitude of the launch site. The altitude of the sUAS will also be displayed via

telemetry on the Ground Station and will be constantly monitored by the PIC during the entire flight

operation.

14 CFR § 91 .151(a): Fuel Requirements for Flight In VFR Conditions

This regulation prohibits an indi vidual from beginning "a flight in an airplane under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to the first point of

intended landing and, assuming normal cruising speed

- (1) During the day, to fly after that for at least

30 minutes; or (2) At night, to fly after that for at least 45 minutes." The differen t sUAS batteries

provide a variety of powered flight times. An exemption from § 14 CFR 91.151 is therefore required.

The applicant believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior

exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance

with 91.151(a)). Operating the sUAS, without 30 minutes of reserve fuel does not engender the type of

risks that Section 91.151(a) was meant to prevent given the size and speed at which the sUAS operates.

The fact that it carries no pilot, passenger, or cargo also enhances its safety. In the unlikely event that

the sUAS should run out of fuel, it would simply land. Given its weight and construction material, the

r isks are less than contemplated by the current regulation.

The applicant believes that an equivalent level of safety can be achieved by maintaining 20% of

reserve fuel (or battery), which would be more than adequate to return the sUAS to its planned

landing zone from anywhere in its operating area.

The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and

10808.CHRIS HOMAYOUNI PHOTOGRAPHY

P.O. BOX 218 CEDARBURG, WI 53012 | CHRIS@CHRISHOMAYOUNI.C OM | 262.424.6018 14 CFR § 91.203 (a) & {b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

(a)

... no person may operate a civil aircraft unless it has

... an appropriate and current airworthiness

certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph

(c) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or

cockpit entrance so that it is legible to passengers o r crew.

The sUAS fully loaded weigh le ss than 15 lbs. As such, there is no ability or place to carry certifica tion

and registration documents or to display them on the sUAS. In addition, there is no pilot on board the

aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground control point

where the pilot flying the sUAS will have immediate access to them. The FAA has issued numerous

exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos.

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections Section 91.405(a) requires that

an aircraft operator or owner " shall have that 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 ..." Section 91.40 7 similarly makes

reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance

of an air worthiness certificate. Section 91.417(a) requires the owner or operator to keep records

showing certain maintenance wo rk that has been accomplished by certificated mechanics, under Part 43,

or licensed pilots and records o f approval of the aircraft for return to service.

The sUAS are nearly maintenance free, they perform automatic pre

- flight checks and the failure of an y

check will prevent take

- of f. Checks which cannot be done by the system will be performed by a qualified

person prior to each flight and at predefined intervals as part of a maintenance schedule.

Pre

- flight checklist includes: 1. Visual inspection o f the airframe 2. Visual inspections of rotor integrity

3. Check charge of all batteries (aerial vehicle, command station, radio repeater station)

An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external

payl oad, will operate only in restricted predetermi ned areas and is not a complex m echanical devise. The

operator of aUAS will ensure that it is in working order prior to initiating flight, perform required

maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the

person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy

condition and to ensure an equivalent level of safety.CHRIS HOMAYOUNI PHOTOGRAPHY

P.O. BOX 218 CEDARBURG, WI 53012 | CHRIS@CHRISHOMAYOUNI.C OM | 262.424.6018 If mechanical issues arise, the UAS can land immediately due to the predetermined a rea of o peration.

Moreover, the UAS's small size, carrying capacity,

and the fact that flight operations will only take place in restricted areas for limited periods of time,

create less risk than the same factors associated with conventional fixed

- wing aircraft and rotorcraft

performing the same operation.

APPENDIX C

SUMMARY OF SECTION 333 EXEMPTION REQUEST

Steven Zeets, a Professional Land Surveyor, hereby provides pursuant to Part 11 a

summary of its exemption application to allow commercial operation of sUAS for

aerial acquisition and research in support of government entities, agriculture industry,

utility companies, local infrastructure, scientific stud ies, wildlife monitoring, mining,

surveying, forestry, and much more. All of which are critical to the well

- being of the

general public. An exemption is requested from the following regulations:

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. 61.133(a};

14 C.F.R. 91.?(a);

14 C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103;

14 C.F.R. 91.109(a);

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. 91.405(a);

14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a).