To: Whom it may concern:

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

Act) and 14 C.F.R. Part 11, Paul M. Hem, Jr., an employee of Block Communications 

Inc. a media company employee and operator of Small Unmanned Aircraft Systems 

(“sUASs”) equipped to conduct aerial photography and videography, hereby applies for 

an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of his sUASs, so long as such operations are conducted within and under the 

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

333.1

As described more fully below, the requested exemption would permit the operation of 

small, unmanned and relatively inexpensive sUAS under controlled conditions in 

airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, 

if granted, would allow Paul M. Hem, Jr. to conduct commercial news operations of small 

unmanned aircraft systems (“UAS”) meeting or exceeding all of the operational and 

safety requirements Congress has set

forth in Section 333.

Paul M. Hem, Jr. is a news-media/technology professional who plans to exploit the 

capabilities of Unmanned Aerial Systems to offer a multitude of services, including:

- News reporting

- Remote sensing

- Event Photography /Videography

- Aerial filmmaking and photography

- Educational and research operations

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil

UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if

certain unmanned aircraft systems may operate safely in the national airspace system

before completion of the (comprehensive) plan and rulemaking required by section

332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section

332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited

operation authorization” if several factors are met. Petitioner meets all requirements to

permit FAA approval of commercial UAS operations.

The Petitioner Requests Relief From the Following:

Regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

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) & (b)

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215
14 C.F.R. (91.401 - 91.417)

The specifications, above and on previous pages, meet with the Model Aircraft 

Operating Standards as set below:

• Mr. Hem will only operate his sUAS in line of sight of a pilot and/or observer

and will operate at sites that are a 'sufficient distance' from populated areas within the 

sterile area described in the FOPM. Such operations will insure that the sUAS will "not 

create a hazard to users of the national airspace system or the public."

• When flying sUAV within 3 miles of an airport, airport operators will be notified and the

operator will give the right of way to avoid flying in the proximity of full-scale aircraft.

• Maximum flight time for each operational flight will be 30 minutes.

• Flights will be terminated at no less than 25% battery power reserve should that occur prior to the

30 minute limit.

• The sUAV will be programmed so that it will be operated at an altitude not exceed 400 

feet AGL, and not more than 200 feet above an elevated platform from

which filming is planned.

• Minimum crew for each commercial news operation will consist of the sUAS Pilot, and 

Visual Observer.

• The sUAS operated by the petitioner weighs less than 55 pounds, including the

payload (i.e. camera, lens, and gimbal).

• The sUAV will operate at speeds of no more than 50 knots, can hover, and can

simultaneously move vertically and horizontally.

• Given the small size of the sUAS and the restricted sterile environment within which

he will operate, his sUAS operations adhere to the Reform Act's safety

requirements.

The sUAS equipment that Mr. Hem will operate are small multi-rotor helicopters 

manufactured by DJI, 3D Robotics and others. Any sUAS used will be strictly limited to 

those sUAS having a Gross weight exceeding 55 pounds.

The sUAV Mr. Hem flies have a built- in capability to limit the height that they fly above 

the ground, to limit the radius of the distance it flies from the operator and to exclude it 

from Class B, C and D airspace including a no fly zone feature. All sUAS flown will also 

has the failsafe function of the autopilot system which means when the communication 

between the Main Controller and the transmitter is disconnected, the outputs of all 

command sticks from controller will go to the center position. If the GPS signal is good 

enough, the system will automatically trigger Return to Home and will and safely.

Paul M. Hem, Jr. (hereinafter, Mr. Hem) is an employee of Block Communications, Inc., 

a holding company that owns newspaper, radio and television properties. Mr. Hem will 

be acting as the program leader for Block Communications, Inc. to evaluate the news

reporting potential for sUAS devices. If the sUAS technology is useful for news reporting 

purposes, Mr. Hem will train and assist each television station, radio station, newspaper, 

or other news organization, owned by Block Communications, Inc. Each news 
organization will be trained to abide by federal regulations regarding the safe use of sUAS and the 

submission to the FAA all federal licensing applications, and exemption requests from 

certain Code of Federal Regulations, is necessary. Each news organization will make 

their requests for exemption or licensing separately. This application only applies to Mr. 

Hem.

News organizations currently are limited to the use of manned helicopters that use a 

tremendous amount of energy as compared with a battery-powered sUAS. A 

catastrophic failure of a full-sized helicopter would cause much more harm to the public 

and property than the sUAS. The public will benefit from better, more complete news 

coverage through the use of these sUAS multi-rotor helicopters. sUAS provide views of 

news events unattainable without them. A more informed citizenry is the goal of all First 

Amendment-protected organizations. The sUAS will allow more complete information to 

appear in newspapers, television news, radio, social media and yet-to-be-developed 

forms of the Press.

The Small, Unmanned Aerial System

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger 

aircraft running on combustible fuel, it operates at lower altitudes with no people on 

board and will thereby reduce current risk levels and thereby enhance safety and 

diminish the likelihood of death or serious bodily injury. With a small payload and 

maximum flight time of only 30 minutes, this is offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than 

ground based imagery for displaying the characteristics of news event. The applicant in 

the past have chartered 2-seat full-sized helicopters for this purpose, which has proven 

more costly than many small news organizations can afford. The benefits of reduced 

cost and improved quality of presentation from the UA will be valuable to and benefit 

many buyers and sellers of real property.

Additionally, I request that I be allowed to use our system to benefit first responders

nearby who might require assistance, including fire fighters, the police, the sheriff, et al.,

while remaining subject to all limitations cited in this application as I do so.

(a) No flight will be made with a Gross weight exceeding 55 pounds;

(b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at

an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC;

(c) All news operations must utilize a visual observer (VO). The VO and PIC must be 

able to communicate by voice at all times during a flight operation;

(d) Operations will be restricted to flights over private property with the permission of

the property owner;

(e) All required permits will be obtained from state and local government prior to 

operation;

(f) Mr. Hem will not be operate over densely populated areas;
(g) Mr. Hem will not be operating over any open-air assembly of people;

(h) Mr. Hem will not be operating over heavily trafficked roads;

(i) Mr. Hem will not be operating within 5 NM of an airport or heliport;

Mr. Hem is a member in good standing of the Academy of Model 

Aeronautics (AMA # 1045758) the largest model aviation association in the world. The 

AMA is a world class association consists of more than 170,000 modelers and 2394 clubs 

throughout the United States. The AMA offers numerous competitions, educational programs, 

advocacy, liability protection, outstanding publications and the world’s largest model 

aviation museum.

I respectfully request exemption under Section 333 to enable Mr. Hem

to operate efficient, limited, low-risk commercial sUAV operations for the activities

stated respecting at all times the space and privacy of citizens and property and dedicated to

the safe use of the National Airspace.

Sincerely, 

Paul M. Hem, Jr 

.