U.S. Department of Transportation 

Docket Management System

1200 New Jersey Avenue, SE

Washington, D.C. 20590

Wolfgang Weber

1517 E Garfield Ave. 

Unit# 33

Glendale, CA 91205

(941)-448-8374

Email weberact@hotmail.com 

To whom it may concern, 

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which 

Wolfgang Weber Requests Exemption are: 

14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (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 Wolfgang Weber seeks and the Reason He Seeks Clearance: 

Requesting exemption to safely operate the DJI Inspire 1, DJI Inspire 1 Professional,

DJI Phantom 3, and 3DRobitics Solo when weighing less than 55 pounds including 

payload. Proposed operations of any other aircraft will require a new petition or a petition 

to amend this exemption. 

I, Wolfgang Weber, submit this application in accordance with the Reform Act, 112 P.L. 

95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent 

me, Wolfgang Weber, 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. My, Wolfgang Weber, ultra lightweight UAS’s

meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore 

the integration of my ultra lightweight UAS’s is expressly contemplated by the Reform 

Act. I would like to operate my ultra lightweight UAS’s prior to the time period by which 

the Reform Act requires the FAA to promulgate rules governing such crafts. Thereby, 

providing direct experience and valuable information for formal regulation that can be 

administered uniformly to all 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 reflects in favor of an exemption for me, Wolfgang 

Weber. My UAS’s utilizes four (4) counter-rotating propellers for balance, control and 

stability. My UAS’s are equipped with GPS and auto return safety technology. Weighing 

less than five (8) pounds (far below the maximum 55lbs limit); including camera with 

gimbal. 

I, Wolfgang Weber, consider safety the most important with each flight. My smallunmanned aircraft’s are 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 I will not fly in winds 

exceeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows my 

UAS’s to hover in place when radio controls are released. This is the safest, most

reliable and stable mode to prevent accident and hazard. When pilot communication is 

lost UAS is designed slowly descend to point of take off. I do not operate my UAS near 

airports, Hospitals nor Police heliports, and do not operate near areas where general 

public is within fifty to one hundred (50-100) yards depending on location, conditions and 

weather. I am constantly on alert for any manned aircraft (Police/Medical helicopters, 

etc.) and prepared to land/abort immediately to the nearest and safest ground point 

should a manned aircraft approach my location or I suspect manned aircraft may 

approach near my location. My UAS’s are capable of vertical and horizontal operations, 

and are flown only within my line of sight of me, as the remote control pilot. Utilizing 

battery power rather than combustible fuels, flights generally last between five (5) to 10

(10) minutes, with an altitude under two hundred (200) feet. I, Wolfgang Weber, utilize a 

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

each battery is fifteen (15) to twelve (23) minutes as tested. I do not operate my UAS’s

at or below manufacture 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. I do 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. I have 

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. I also practice 

computerized simulated flights to maintain adequate skills and response reflex time. All 

for the sake of safety of others and myself. 

I, Wolfgang Weber, am extremely cautious when operating of my UAS’s/ultra light weight 

unmanned aircraft’s and will not “create a hazard to users of the national airspace 

system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my 

UAS’s 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. Wolfgang Weber’s UAS’s, used in hobby flight, has a demonstrable safety 

record and does not pose any threat to the general public or national security. 

IV. How Wolfgang Weber Request Will Benefit the Public As A Whole: 

Aerial videography for geographical awareness and for real estate marketing has been 

around for a long time through manned fixed wing aircraft and helicopters. For small 

budget real estate companies and average homeowners the expense of such aerial 

videography is cost prohibitive. Only large companies and high end Realtors or luxury 

homeowners can afford to absorb such expense. Depriving non-luxury homeowners and 

lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to 

the public through potential catastrophic crash that of the residents of Southern 

California. Which could result in the loss of life. Each with combustible fuel that exploded 

and burned on impact. Police helicopters have made emergency hard landings within 

city limits. My, Wolfgang Weber’s, UAS’s pose no such threat since size and lack of 

combustible fuel alleviates any potential threat to the public. 

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 my, Wolfgang Weber’s, exemption request furthers the public 

interest through academic/visual awareness of the geographical benefits in and around 

the Los Angeles County area. My ultra lightweight UAS’s are battery powered and 

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

weight UAS’s 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. Minimizing ecological furthers the public’s interest and crash threat by permitting 

aerial video/photo capture through my battery operated ultra lightweight UAS's. 

Permitting me, Wolfgang Weber, to immediately fly within national air space furthers 

economic growth. Granting my exemption request substantially furthers the economic 

impact for the Los Angeles County for companies looking to relocate or build in the Los 

Angeles area as well as individuals looking to relocate for career advancement through 

academic and geographical awareness. Both of which serve as a stimulus to the 

community. 

V. Reasons Why Wolfgang Weber Exemption Will Not Adversely Affect Safety Or How 

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

My, Wolfgang Weber’s, exemption will not adversely affect safety. Quite the contrary, for 

the reasons stated permitting me, Wolfgang Weber, to log more flight time in FAA 

controlled airspace, with communication with the FAA, will allow me to contribute to the 

innovation and implementation of new and novel, as of yet undiscovered safety protocols 

for Realtors that can be embraced by the NAR, AAR, and TAR for development in 

cooperation with the FAA. In addition I, Wolfgang Weber, submit the following 
representations of enhancements to current aerial videography and photography for real 

estate: 

My UAS’s weigh less than 5 pounds complete with a small ultra light weight high quality 

Dji 4K camera; I only operate my UAS’s below 200 feet (well within the 400 foot 

permissible ceiling set by the FAA Modernization and Reform Act of 2012); my UAS’s

only operate for 10-17 minutes per flight; I land my UAS’s prior to manufacturer 

recommended minimum level of battery power; I pilot my UAS’s through remote control 

only by line of sight; My UAS’s has GPS a flight safety feature whereby it hovers and 

then slowly lands if communication with the remote control pilot is lost; I actively analyze 

flight data and other sources of information to constantly update and enhance safety 

protocols; I only operate in reasonably safe environment that are strictly controlled, are 

away from power lines, elevated lights, airports and actively populated areas; I conduct 

extensive pre-flight inspections and protocol, during which safety carries primary 

importance; I always obtains all necessary permissions prior to operation; and, I have 

procedures in place to abort flights in the event of safety breaches or potential danger. 

My, Wolfgang Weber’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 remarkably astounding, there has been local incident involving loss of life 

as well as extensive property damage; it is far safer to operate a battery powered ultra 

lightweight UAS. 

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

I only operate my UAS’s 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 my UAS’s allow me 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, my UAS’s 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, my UAS’s has been experimentally operated for familiarization/competency 

and will continue to operate at and above current safety levels. I have also recently 

taken/passed a test to obtain a certificate that states that I am a certified UAS operator, 

from the Nation Drone School. (See Attached) To further educate myself on UAS’s. 

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. 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 my, Wolfgang Weber’s, UAS’s

permits exemption from Part 21 because my UAS’s meet (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. My, Wolfgang Weber, current and projected UAS's meet or exceed 

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 

on board 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 safety/flight 

manual delineating areas of where safety can be defined. 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. 

14 C.F.R. § 91.121 regarding altimeter settings are inapplicable insofar as my UAS’s 

utilizes electronic global positioning systems with a barometric sensor. 

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 me, Wolfgang Weber. 

14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation 

require aircraft to be marked according to certain specifications. My UAS’s are, by 

definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on 

which to mark certain words or phrases. Further, two-inch lettering is difficult to place on 

such small aircraft with dimensions smaller that minimal lettering requirement. 

Regardless, I will mark its UASs in the largest possible lettering by placing the word 

“EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the pilot, 

or anyone assisting me as a spotter with the UAV will see the markings. The FAA has 

previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 

10167A and 10700. 

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. 

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial 

operations. I, Wolfgang Weber, can achieve an equivalent level of safety as achieved by 

current Regulations because my UAS’s do not carry any pilots or passengers. Further, 

while helpful, a pilot license will not ensure remote control piloting skills. The risks 

attended to the operation of my UAS’s are far less than the risk levels inherent in the 

commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Wolfgang 

Weber, to operate my UAS’s meets and exceeds current safety levels in relation to 14 

C.F.R. §61.113 (a) & (b). 

14 C.F.R. 91.119: Minimum Safe Altitudes. 
14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

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

operate at an altitude greater than 200 AGL, safely below the standard of 400 AGL. I, 

Wolfgang Weber, will however operate my UAS’s in safe areas away from public and 

traffic, providing a level of safety at least equivalent to or below those in relation to 

minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS’s, 

an equivalent or higher level of safety will be achieved. 

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 my, Wolfgang Weber, UAS’s. However, as a safety precaution I 

calibrate my UAS’s before each flight and inspect my UAS’s before and after each flight

as well. 

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 my UAS’s permits exemption from Part 21 because my, 

Wolfgang Weber’s, UAS’s 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. My 

UAS’s 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, Wolfgang Weber 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. §§ 61.113 (a) & (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; 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 my, 

Wolfgang Weber, small unmanned vehicle/lightweight unmanned aircraft vehicle in 

community awareness and real estate operations, and to develop economic platforms 

for real estate to enhance the experience of those seeking to relocate to the Los Angeles 

area. Currently, area awareness and real estate aerial videography/photography relies 

primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to 

the public. Granting my, Wolfgang Weber, request for exemption will reduce current risk 

levels and thereby enhance safety. My UAS’s crafts do 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, I operate at lower altitudes and 

in controlled airspace eliminating potential public risk flying to and from established 

airfields. I, Wolfgang Weber, have 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 my, Wolfgang Weber, UAS’s and therefore the 

likelihood of death or serious bodily injury is significantly diminished. My, Wolfgang 

Weber’s, operation of my UAS’s, 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 I, Wolfgang Weber, respectfully request that the FAA 

grant my exemption request and am willing to cooperate in sharing information to benefit

the FAA, safety of manned aircraft, and the general public as a whole. 

Respectfully Submitted, 

Wolfgang Weber