## Chad Piazzo

**– Section 333 Exem**  **ption 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 operato r of the 3DR IRIS quad

- copter Unmanned Aircraft Sy stem (UAS), seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below so that Chad Piazzo can operate our small ultra

- light weight UAS commerciall y in airspace regulated b y 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 [PI C]) 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 sy stem to perform aerial mapp ing 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 2the 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 b y 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 sy stem, but to “...establish requirements for the safe operation of such aircraft s ys tems [UAS's] in the national airspace s ys tem” 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 b y 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 emplo yment 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. 199 8. The Final Repor t 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 . R equirements and procedures that are not available to the public and are protected from release under the Free do mo In formation Act 5USC552.**I. Contact Information**  **, Chad Piazzo** 

**7777 Lakeside Dr , Reno, Nevada, 895**  **11 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 natio nal airspace sy stem. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft s ys tems into our national airspace s ys tem 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 33 1 and therefore the integration of Chad Piazzo ’s ultra

- light weight UAS is expressly contemplated b y 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. Thereb y, providing direct experience and valuable information for formal regulation that can be administered uniformly to all agriculture, mapping, and real estate related UAS a erial video and photograph y. The Reform Act guides the Secretary in determining the types of UAS's that may operate safel y in our national airspace sy stem. Considerations include: The weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operated near airports or heavil y populated areas; and, Whether the UAS will be operated b y 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 Fl y Zone7 software default setting to force the device to abide b y 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 o f 29 knots (15 m/s). Built

- in safety sy stems 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 aerialvideograph y/ photography . T his is the safest, most reliable and stable mode to prevent accident and hazard. When PI C 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, Hosp itals, 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 PI C and VO will be on constant alert for any manned aircraft (Polic e/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 l ocation. 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 full y 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 op erate 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 o r 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 hobb yi st simulating flights for future commercial use to gain familiarization with the characteristics of this specific UAS's performance under di fferent 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 “creat e a hazard to users of the national airspace s ys tem 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 IRI S ’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 GP S 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 sy stem 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 wi ll 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 s ys tem. 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 videograph y for geographical awareness in real estate, filmmaking, golf course mapping, agricultural mapping, an d 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
c ompanies 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 privat e and public officials involved in crashes in recent years. Congress has already proclaimed that it is in the public’s interest to integrate commerciall y flown UAS's into the national airspace s ys tem, hence the passing of the Reform Act. Granting C had Piazzo ’s ex emption 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 co nsequence of my ultra

- light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heav y, contain combustible fuel and can cause catastrophic devastation to the public. The public’s interest is furthered b y 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 cost

effective 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 ex emption will not adversel y 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 ofenhancements 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

- l ight weight high quality GoPro 3 Black camera;

 Chad Piazzo will only operate this UAS below 400 feet, as recommended by the FAA Modern ization and Reform Act of 2012;

 Chad Piazzo ’s UAS will only oper ate 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 thi s UAS through r emote control by line of sight;

 Chad Piazzo ’s UAS has GPS

- controlled autopilot sy stem 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 whereb y Chad Piazzo ’s UAS automatically hovers and then slowl y lands if communication with the remote control pilot is lost;

 Chad Piazzo will actively anal yz e flight data and other sources of information to constantly update and enhance safety protocols;

 Chad Piazzo will only operates in reasonabl y safe environments that are strictly controlled and are away

from: power lines, elevated lights, airport s 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 wor k;

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

- to

- airmen (N OTAM) prior to operations; and,

 Chad Piazzo will have procedures in place to abort flights in the event of safety breaches or potential d anger. In recognition of the FAA’s Exemption No. 11304A , and specificall y Exemption No. 12368 for the same UAS model ( 3DR IRI S ); prior to conducting operations for the purpose of aerial photograph y/videography , Chad Piazzo ’s PI C 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 PI C 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 take

offs and landings in the preceding 90 day s (for currency purposes).Chad Piazzo ’s safety protocols provide a level of safety equal to or exceeding existing rules. It is i mportant to note that absent the integration of commercial UAS into our national airspace sy stem, helicopters are the primary means of aerial video and photography for community awareness and real estate. While the safety record of such helicopters is asto unding, 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 greatl y diminished.

 Third, the small size and extreme maneuverability of Chad P iazzo ’s UAS allow the PI C to remotely

pilot away

from and avoid hazards quickly and safel y. 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. Accordingl y, Chad Piazzo ’s UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels. Furthermore, Cha d Piazzo ’s PI C has accumulated 40 hours of total time as a UAS multi

- rotor pilot. Chad Piazzo ’s PI C has also accumulated more than 20 hours as a UAS pilot operation the 3DR IRI 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 L ike. 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 ex empt 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 airworthine ss certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. However, Chad Piazzo ’s PI C will still ensure that the UAS is in an airworthy condition based on compliance with the operating d ocuments 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 b e achieved b y m aintaining 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 PI C. 14 C.F.R. § 91.103 regarding preflight action. Chad Piazzo ’s PI C will take certain actions before flight to ensure safety of the flight. These will i nclude 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 e lectronic 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 require d certifications and registrations by Chad Piazzo in a location accessible by Chad Piazzo ’s PI C. ( 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, two

inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. The FAA has previousl y 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 b y 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 Progres s

– Remain Back 150 Feet”. Chad Piazzo will operate its UAS in accordance with Exemption No. 11109, which mayrequire the UAS be operated closer than 500 feet to essential persons. Non

- participating persons

must remain at appropriate distances (500 feet) f rom 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 sp eed 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 ope rators 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, appl y to Chad Piazzo ' s UAS. However, as a safety precaution Chad Piazzo ’ s PI C and VO will inspect Chad Piazzo ’ s UAS before and after each flight. ( 10 ) See Appen dix B

. A Summary

the FAA May

Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthi ness Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of neces sary 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 th e 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 airworthi ness 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 p ilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved b y m aintaining a manual. The FAA has previousl y issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9 299, 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 follow ing 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 commerciall y 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 primaril y 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 thereb y enhance safety. Chad Piazzo ’s UAS craft does not contain potentially explosive fuel, is smaller, lighter and more maneuverabl e 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 Pi azzo has been informally

anal yz ing 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 infor mation 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 bo dily

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. Accordingl y, Chad P iazzo 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, 895**  **11 Mobile: (775)**  **240**

**- 1220** 
**Email: ChadPiazzo@Yahoo.com**