Stevenson R Kapur – President

Wolfpack Air Group

5 Quarterhorse Crossing

Sparta, NJ 07871

sting@wolfpackairgroup.com

Steve Kapur cell: 412-915-2777

US Department of Transportation

Federal Aviation Administration

800 Independence Ave SW

Washington DC 20591

Dear Sir or Madam:

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

Reform Act) and CFR Part 11 Wolfpack Air Group, owner and operator of Small Unmanned 

Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations 

(FAR) listed below so that Wolfpack Air Group may operate UAS’s commercially in 

airspace regulated by the FAA., as long as such operations are conducted within and 

under the conditions outlined herein or as maybe established by the FAA as required by 

Section 333.

Wolfpack Air Group is owned by Stevenson Kapur. UASs operators will include Stevenson 

Kapur and Karly Kapur. Both are still and video certified Camera operators and

experienced Drone pilots. Both have New Jersey Drivers licenses. Stevenson has a 

commercial pilot’s license and will be the PIC. All operations will be performed with the 

public’s safety and right to privacy safeguarded at all times.

As described below, the requested exception would permit the operation of light weight 

(less than 55 lbs. total takeoff weight) UASs under controlled conditions for commercial 

use by a certified commercial pilot thereby enhancing safety and fulfilling the Secretary of 

Transportation’s (the FAA Administrator’s) responsibility to ”establish requirements for 

safe operation of such aircraft systems in national airspace systems.” Section 333(c), of 

the Reform Act.

Wolfpack Air Group UASs are rotorcraft weighing less than 55 pounds including payload,

(The DJI Phantom 3 Quad Copter and DJI Inspire 1 Quad Copter) and they operate at a

speed less than 50 knots and have the capability to hover and move in the vertical and

horizontal plane simultaneously. Both have an auto return to launch point when battery

power is under 25%. The UASs will operate within the line of sight with in a protected

flight area as described below and at 200 feet AGL or less with an observer located close

at hand as to make voice communication possible. These operations will not create a

hazard to users of the national airspace, public nor the environment.

Wolfpack Air Group respectfully requests the grant of an exception to the following 

specific sections of the Title 14 Code of Federal regulations allowing it to operate 

lightweight UASs for commercial use,
14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 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)&(b).

Wolfpack Air Group submits this application in accordance with the Reform Act, 112 P.L. 

95 331-334, seeking relief from any currently applicable FAR’s operating to prevent 

Wolfpack Air Group future commercial use of small UASs to operate in the national 

airspace system as described below. The reform Act section 332 provides for such 

integration of civil unmanned aircraft into our national airspace system as it is in the 

public’s interest to do so. Wolfpack Air Group UASs meet the definition of “small

unmanned aircraft” as defined in Section 331 and therefor the Reform Act expressly

contemplates the integration of these UASs. Wolfpack Air Group would like to operate its 

light weight UASs prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such aircraft.

The Reform Act directs the Secretary of Transportation to consider whether certain

unmanned aircraft systems may operate safely in national airspace before completion of 

the rule making required under Section 332 of the Reform Act. In making this

determination, the Secretary of Transportation is required to determine which UASs do

create a hazard to users of the national airspace system or the public or pose a threat to

national security in light of the following:

The UASs size, speed, weight and operational capability

Operation of the UASs in close proximity to airports and populated areas

Operation of the UASs within visual line of sight of the operator

Reform Act 333(a). If the secretary determines that such vehicles “may operate safely in 

National Airspace System, the secretary shall establish requirements for the safe

operation in national airspace.

Wolfpack Air Group UAS’s are rotorcraft weighing less than 55 lbs. and they operate at 

speeds less than 50 knots and have the capability to operate in the vertical and horizontal 

plane simultaneously. The UASs will operate only within the line of sight of the operator 

within a protected flight area and at 200 feet AGL or less. These will not present a hazard 

to the national airspace nor the public. The very small nature of these UASs combined 

with the safeguards presented below, will allow for the safe operation greater than that 

envisioned by Congress for the FAA to establish and by exemption allow commercial 

operations of UASs to commence immediately. Also due to the size of UASs and the areas 

and altitudes they will operate approval of this exception presents no national security 

issues and absolutely minimal safety concerns which have been mitigated through our 

rigorous risk management process. Given the clear direction given in Section 333 of the 

Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong 

equivalent level of enhanced safety, reduced emissions utilizing UASs verses traditional 

aircraft as well as the economic impact of greatly reducing the cost of aerial photography 

thereby benefiting the greater public’s interest. Accordingly, the applicant requests that 
the FAA grant the requested exemption without delay.

The following will be considered as the binding limitation on operations of

Wolfpack Air Group:

1. Flights will only occur in VFR conditions.

2. Flights will be operated in the line of sight of the operator (PIC) and Observer (VSO)

3. Flights will be terminated at any time weather and wind deteriorate to “unsafe for

flight” by manufacturers recommendations,

4. The UASs will weigh less than 55 lbs.,

5. Flights will be operated at 200 feet AGL or less.

6. Crew will be at a minimum of operator (PIC) and an observer and/or camera operator

(VSO),

7. Operator and crew will remain in contact during the flight operation,

8. The UASs operator will perform a check of the flight area and make certain of the safety 

of all persons in the area.

9. Consent will be obtained from all persons with in the video capabilities of the units to

further reduce the chance of violating anyone’s privacy.

10. All required FAA clearances, will be obtained and distances from airports strictly 

observed.

11. All UASs will have the capability to return automatically to the operator in a safe

manner with the auto return function checked and working.

12. When operated in conjunction with vessels over water, a chase boat will be assigned 

to operate the UASs at a safe distance from the main boat.

13. UASs have a function on the control to tell operator the distance away from the

operator and its battery power remaining.

14. Flight team will communicate by voice and the use of two-way radio if the area is too 

large to hear voice from all team members.

15. UASs will be used to photograph and/or video private outings and functions, real 

estate, automobile racing, boating, jet skiing, kayaking, fishing trips and sporting events 

from a safe distance. 

16. When operating over or near water the UASs will be equipped with flotation devices

so that recovery can be made as to prevent lithium battery exposure to the water table.

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement

of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined

area of operations for Wolfpack Air Group UASs flights permits exception from Part 21 

because they meet 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 USC 4470(f) and Section 333 of the Reform Act. Both 

pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in 

consideration of weight, size, speed, maneuverability and proximity to areas such as 

airports and dense populations. Wolfpack Air Group, meets or exceeds each of these 

elements

As of March 23, 2015 the FAA has stated that it will automatically grant a “blanket” COA

for flights at or under 400 AGL to any UASs operator with a section 333 exemption.
The Federal Aviation Administration has established an interim policy to speed up 

airspace authorizations for certain commercial unmanned aircraft (UAS) operators who 

obtain Section 333 exemptions. Under the new policy, the FAA will grant a Certificate of 

Waiver or Authorization (COA) for flights at or below 200 feet to any UAS operator with a 

Section 333 exemption for aircraft that weigh less than 55 pounds, operate during 

daytime Visual Flight Rules (VFR) conditions, operate within visual line of sight (VLOS) of 

the pilots

14 CFR 91.203: (a)&(b) provides for carrying of civil aircraft certifications and

registrations. These are inapplicable for the same reasons stated above. 

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness

certificate. As no such certificate will be applicable in the form contemplated by FAR’s

this regulation is inapplicable.

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft - 14 CFR 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 UASs this regulation is inapplicable. An equivalent level of safety will be 

achieved by maintaining such certifications and registrations at Wolfpack Air Group 

offices.

The FAA has previously issued exemptions to this regulation in Exemptions No’s 8607,

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700, and 32827.

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil

aircraft. It allows helicopters to be operated at lower altitudes in certain conditions.

Wolfpack Air Group will only operate its UASs at or below 200 AGL. They will be operated 

on a well-defined AOR that has been carefully reviewed for hazards and minimizes the 

presence of any persons not essential for these operations. Flights will only be over 

private property that the owner has consented and all persons within this video area also 

give consent for this filming. Compared to flight operations of conventional and 

traditional aircraft or rotorcraft weighing far more than 50 lbs., operating below 500 AGL 

with flammable fuel UASs operations present a far smaller risk to the public.

Approval of these 333 Exemptions allowing commercial operations of small UASs in

the service of aerial photography will greatly enhance safety by reducing the overall risk

associated with traditional aircraft. Traditional aerial photography requires large aircraft

with flammable fuel to fly in close proximity of populated areas and people in general.

With the use of small UASs of 55 lbs. or less, battery operated and flying below 300 feet

AGL the risk of injury of people on the ground or the crew has been reduced or almost

erased. The granting of the use of these small UASs by Wolfpack Air Group, will give the 

people another avenue to express themselves and to have a photographic and/or video 

record to share with family and friends forever.

Granting Wolfpack Air Group, the above exemption will allow for the expansion of UAS 

systems into the future for the safe conduct of free enterprise and the enjoyment of the 
masses.

Wolfpack Air Group, has in the past, and plans in the future to train, promote safe 

operation and safe flight operations to all pilots of unmanned aircraft in this category 

private and commercial, and will support law enforcement agencies and local FAA officials 

in apprehending safety violators.

Wolfpack Air Group, respectfully requests the FAA grant its exception without delay. The 

FAA has the authority to issue the exemption sought by Wolfpack Air Group pursuant to 

the Federal Aviation Act, 85 P.L. 726 (1958) as amended (the ACT).

Sincerely,

Stevenson R Kapur and Karly S Kapur

Wolfpack Air Group