September 3, 2015

Exemption No. 12744

Regulatory Docket No. FAA−2015−1829

Mr. Gerald Svoronos

Icarus Aerial Media Inc.

34 Frostfield Place

Melville, NY 11747

Dear Mr. Svoronos:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated May 7, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Icarus Aerial Media Inc. (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

photography, cinematography, and search and rescue operations.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 3.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 
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aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1

. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Icarus Aerial Media Inc. is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection.

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Icarus Aerial Media Inc. is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3

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.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 
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Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 
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operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 
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(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
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29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
 

5.7.15

Icarus Aerial Media Inc. 

34 Frostfield Place 

Melville, NY 11747

Tel. 516-315-0234

United States Department of Transportation

Docket Management System

1200 New Jersey Ave , SE 

West Building Ground floor Room W12-140

Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 

To Whom it may concern:

Pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained in 14 C.F.R. 11, to 

request that Icarus Aerial Media Inc., an owner and operator of small unmanned aircraft, be exempted from the 

Federal Aviation Regulations ("FARs") listed below so that Icarus Aerial Media Inc. may operate its small 

lightweight unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviation 

Administration ("FAA"); as 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. The conditions identified and proposed by the 

applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-Issue a Certificate of Waiver Aerial 

Photography and Video. 

As identified and described herein, Gerald Svoronos, and his company Icarus Aerial Media Inc., is an experienced 

and avid RC model flyer for over twenty (20) years. Mr. Svoronos is a degreed Architect and is experienced with 

Construction progress photography. Icarus Aerial Media Inc. has fully equipped its small unmanned aircraft for 

aerial photography and cinematography, primarily for use in Real Estate Advertisement, Construction progress 

photography and Construction Inspections. Though given their stability and maneuverability, they may be used for 

other cinematography, by law enforcement personnel, search and rescue and by other first responders. 

To date, Icarus Aerial Media Inc. has not performed any commercial services in Aerial photography on locations 

within the United States to ensure it is in compliance with any applicable FARs. It, like other applicants, has done 

so despite Judge Patrick G. Geraghty's decision in the Raphael Pirker matter and his reasoning that 

no FARs prohibit the use of small unmanned aircraft or lightweight UASs like those flown by other peer companies. 

Icarus Aerial Media Inc. exemption request would permit its operation of lightweight, unmanned “in line of sight”

UASs (DJI Phantom 3 or Similar ) in tightly controlled and limited airspace. Predetermined, specifically marked 

areas of operation, cordoned off locations and corresponding enhancements to current safety controls will allow 

Icarus Aerial Media Inc. to operate within current safety parameters and new ones being implemented. As 

identified, similar lightweight, remote controlled UASs are legally operated by amateurs with no flight experience, 

safety plan or controls in place to prevent catastrophe. Icarus Aerial Media Inc. Utilizes a pre-flight safety and flight 

plan system. 
 

Icarus Aerial Media Inc. respectfully requests the grant of an exemption allowing it to 

operate lightweight, remote controlled UAS's. The Specific Sections of Title 14 of the Code of 

Federal Regulations.

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). 

Exemption Request Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) 

(2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 

91.409 (a) (2);91.417 (a) & (b). 

The Extent of Relief Icarus Aerial Media Inc. Seeks and the Reason It Seeks Such Relief: 

Icarus Aerial Media Inc. 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 

Icarus Aerial Media Inc. contemplated commercial 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. Icarus Aerial Media Inc. lightweight UASs (DJI Phantom 3 or 

similar) meet the definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of 

Icarus Aerial Media Inc. lightweight UASs are expressly contemplated by the Reform Act. Icarus Aerial Media Inc. 

would like to operate its lightweight UASs prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such craft.

The Reform Act guides the Secretary in determining the types of UASs that may operate safely in our national 

airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS; Whether the 

UAS will be operated near airports or populated areas; and, Whether the UAS will be operated by line of 

sight. 112 P.L. 95 § 333 (a). Each of these items militates in favor of an exemption for Icarus Aerial Media Inc. 

Icarus Aerial Media Inc. UASs utilizes four counter-rotating propellers for extreme balance, control and stability. 

They each weigh less than 55 pounds, including cinematic or other equipment. 

Each of Icarus Aerial Media Inc. small unmanned aircraft (DJI Phantom 3 or similar) are designed to primarily hover 

in place and operate at less than a 50 knot maximum speed. They are capable of vertical and horizontal operations 

but operate only within the line of sight of the remote control pilot. Utilizing battery power and not combustible 

fuels, flights generally last between five and twenty minutes. Icarus Aerial Media Inc. does not operate its UASs 

with less than twenty five percent battery capacity. Safety systems in place include a GPS mode that allows Icarus 

Aerial Media Inc. UASs to hover in place if communication with the radio control pilot is lost and then slowly 

descend the UAS at twenty five percent battery capacity. Further, Icarus Aerial Media Inc. fleet is programmed, in 

some instances, to slowly follow a predetermined set of waypoints to return to a safety point if communications 

are lost. Icarus Aerial Media Inc. does not operate its UASs near airports and generally does not operate them near 

populated areas. The UAS operating software and GPS navigation systems do not allow any of the Icarus Aerial 

Media Inc. UAS vehicles to operate near airports or restricted fly zones. The failsafe software will disable the UAS 

vehicles from taking off and also limit the UAS systems from operating within specific GPS preset no-fly zones. 

The FAA has the authority to issue the exemption to Icarus Aerial Media Inc. pursuant to the 

Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). Commercial and Public Benefits Granting Icarus 

Aerial Media Inc. exemption request furthers the public interest. First, Congress has already pronounced that it is 

in the public's interest to integrate commercially flown UASs into the national airspace system, hence the passing 
 

of the Reform Act. Second, Icarus Aerial Media Inc. conducts research into safe UAS operations every time it flies 

one of its UASs. Flight data, visual inspections, recorded observations and flight analyses are compiled to 

further enhance current safety protocols. Allowing Icarus Aerial Media Inc.to log more flight 

time directly relates to its research and its ability to further enhance current safety measures. 

The public has an interest in reducing the danger and emission associated with current 

aerial cinematic capture methods, namely, full size helicopters. Icarus Aerial Media Inc. UASs 

are battery powered and create no emissions. If an Icarus Aerial Media Inc. UAS crashes there is 

no fuel to ignite and explode. The impact of Icarus Aerial Media Inc. lightweight UASs is far 

less than a full size helicopter, notwithstanding the statistically noteworthy safety record of 

full size helicopters used in motion picture capture. The public's interest is furthered by minimizing 

ecological and crash impacts by permitting motion picture capture through Icarus Aerial Media Inc.

Services lightweight UASs. 

Progression of the arts and sciences has been fundamental to our society since its inclusion 

in the United States Constitution. Indeed, Congress mandated the integration of 

UASs into our national airspace system, in part, to achieve progression in this noteworthy, and inevitable, field. 

Permitting Icarus Aerial Media Inc.to immediately fly within the United States furthers these 

goals. Whether it is the advancements in publicly usable technologies or advancements in equipment available to 

law enforcement personnel I first responders that does not cost millions of dollars, granting Icarus Aerial Media 

Inc. exemption request substantially furthers the public's interest in ways known and currently unknown. 

Reasons Why Icarus Aerial Media Inc. Exemption Will Not Adversely Affect Safety Or How 

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

Icarus Aerial Media Inc. exemption will not adversely affect safety. Quite the contrary, for 

the reasons stated, supra, permitting Icarus Aerial Media Inc.to log more flight time in FAA 

controlled airspace will allow Icarus Aerial Media Inc.to innovate and implement new and as of 

yet undiscovered safety protocols. In addition, Icarus Aerial Media Inc. submits the following 

enhanced safety protocols to current aerial photography capture techniques: 

Safety protocols:

• Icarus Aerial Media Inc. UASs weigh less than 55 pounds complete with 4k Resolution Motion picture quality 

Camera.

• Icarus Aerial Media Inc. only operates its UASs below 200 feet; 

• Icarus Aerial Media Inc. UASs only operate for 5-25 minutes per flight; 

• Icarus Aerial Media Inc. lands its UASs when they reach 25% battery power; 

• Icarus Aerial Media Inc. remote control pilots operate UASs by Visual Line of Sight (VLOS) and will operate under 

daytime VFR conditions;

• Icarus Aerial Media Inc. remote control pilots have video backup should they somehow 

 lose sight of the UAS; 

• Icarus Aerial Media Inc. UASs have GPS flight modes whereby they hover and then 

 slowly land if communication with the remote control pilot is lost or battery power is below25%; 

• Icarus Aerial Media Inc. actively analyses electronic flight data and other sources of 

 information to constantly update and enhance safety protocols; 

• Icarus Aerial Media Inc. only operates in secured areas that are strictly controlled, are away from airports and 

highly populated areas; 

• Icarus Aerial Media Inc. conducts extensive inspections of equipment prior to flight, during which safety 

 carries primary importance; maneuverability and speed of Icarus Aerial Media Inc. UASs, an equivalent level of 

 safety will be achieved. 
 

Icarus Aerial Media Inc. will not operate within 5NM of an airport having an operational control tower or:

 3 NM from an airport with a published instrument flight procedure, but not an operational tower

 2 NM from an airport without a published instrument flight procedure or an operational tower

 2 NM from a heliport with a published instrument flight procedure

Summary 

Icarus Aerial Media Inc. seeks an exemption from the following Regulations: 14 C.F.R. 

21, subpart H; 14 C.P.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.P.R. § 91.409 (a)(2); 14 C.P.R. § 91.409 (a)(2); and, 14 C.P.R. §§ 91.417 (a) 

& (b) to commercially operate its fleet of small unmanned vehicles and lightweight unmanned 

aircraft vehicles in Construction progress video/ photography and Real Estate video/photography, to conduct its 

own research and to develop economic platforms for law enforcement and or search and rescue operations. 

Granting Icarus Aerial Media Inc. request for exemption will reduce current risk levels and 

thereby enhance safety. Currently, Aerial Construction and Real Estate photography’s use of 

larger aircraft running on combustible fuel. Icarus Aerial Media Inc. craft do not contain 

potentially explosive fuel, are smaller, lighter and more maneuverable than conventional motion 

picture aircraft. Further, Icarus Aerial Media Inc. operates at lower altitudes and in controlled 

airspace. 

Icarus Aerial Media Inc . will be analyzing flight data and other information in 

compiling safety protocols and the implementation of a flight operations manual that 

exceeds currently accepted means and methods of safe flight. 

There are no people on board Icarus Aerial Media Inc. UASs and therefore the likelihood 

of death or serious bodily injury is significantly limited. Icarus Aerial Media Inc. operation of 

its UASs, weighting less than 55 pounds and traveling at speeds lower than 50 knots in cordoned off 

areas will provide at least an equivalent level of safety as that achieved under current FARs. 

I thank you for your attention to this matter. If you should have any questions, please do not hesitate to contact 

me.

Sincerely,

Gerry Svoronos

Gerald Svoronos