William Adams, Commerce Twp, MI Section - 333 Exemption Petition 

May 13,2015 

William B. Adams 

1105 Addington Drive 

Commerce Twp., MI 48390 

William-Adams@comcast.net 

(248) 330-0836 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, S E 

Washington, DC 20590 

Re: Exemption R~uest Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 

14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 

91.109; ll9.121; 91.1SI(a); 91.203(a)&(b); 91.405(a); 91.407(•) (1); 91.409(a) (2); 91.417(a)&(b) 

Dear Sir or Madam, 

William Adams hereby petitiOns the Secretary of Transportation and Federal Aviation 

Administration for exemption to the above referenced and below more fully described Federal 

Aviation Regulations ("FARs"), that currently may or may not apply to the recreational/business 

operations of model aircraft including small unmarmed aerial systems ("UASs). 

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

contained within 14 C.F.R. II, Petition that I, William Adams, an owner and operator of small 

unmarmed aircraft, be exempted from the Federal Aviation Regulations ("F ARs") listed below so 

that 1, William Adams, may operate my small ultra lightweight unmanned aircraft system 

("UAS") commercially in airspace regulated by the Federal Aviation Administration ("FAA"). 

As described herein I, William Adams, am a licensed Private Pilot (Certificate #38 1569777); 

Experienced in flying hobby helicopters and fixed wing aircraft for recreational purposes for 

over 25 years. I have added a hobby grade OJ! Phantom 3 quadcopter UAS to my inventory with 

intent to conduct aerial photography/Inspection! included but not limited to the following; 

Business Operations: over land, waterways, and oceans; Operation over/in non-restricted 

National Parks, National Forests, flight in non-navigable airspace, using nonintrusive recording 

devices, operation in othenvise unrestricted U.S. Statesfferritories for aerial 

videography/cinematography for commercial operation and to enhance academic community 

awareness for those individuals and companies unfamiliar with the geographical layout of such 

areas. 

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

under controlled conditions in airspace that is I) limited; 2) predetennined in areas away from 

general public, airports, heliports and vehicular traffic for community videos, and within 

property boundaries for individual homeowner real estate listing videos/photos; and 3) controlled 

as to access. The exemption would also provide safety enhancements to the already safe 
William Adams, Commerce Twp, Ml Section- 333 Exemption Petition 

operations within the aerial photography, film and television industry presently using 

conventional aircraft and small, unmanned and relatively inexpensive VASs. 

Currently, similar lightweight, remote controlled VAS's are legally operated by urunonitored 

amateur hobbyists with no safety plan or controls in place to prevent catastrophe. I operate my 

UAS within all safety protocols and controls

1 to avoid and prevent public hazard, as well as 

ma•med aircraft hazards/catastrophe. This will act to further safety protocols exclusive to 

lightweight VAS's specific to aerial video and photography usage as I record 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 my request comports with the Secretary of Transportation's (FAA Administrator's) 

responsibilities and authority to not only integrate VAS's into the national airspace system, but to 

" ... establish requirements for the safe operation of such aircraft systems [VAS's] in the national 

airspace system" under Section 333(c) of the Reform Act specific to the use of VAS's for 

commercial purposes. Further I will conduct my operations in compliance with the protocols 

described herein or as otherwise established by the FAA. 

For the reasons stated below I respectfully request the grant of an exemption allowing me to 

operate ultra lightweight, remote controlled VAS's for academic community awareness, 

benefit/stimulate tourism within Michigan, general aerial photography, and to enhance real estate 

listing videos for homeowners who cannot afford expensive manned aircraft for the same 

purpose, all of which will promote local economic growth through increased employment and 

increased tax base. Both with public safety in mind by keeping heavier manned aircraft 

containing combustible fuel that that poses potential public hazard. 

I. Contact Information: 

William Adams 

I I 05 Addington Drive 

Commerce Twp., Ml48390 

Mobile: (248) 330-0836 

Email: William-Adams@comcast.net 

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

William Adams Requests Exemption are: 

!4CFR21; 

14 C.F.R. 45.23(b); 

14 CFR 61.1 J3 (a) & (b): 

14 C.F.R. 91.7 (a); 

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

14 C.F.R. 91.103: 

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); 

1 Safecy Protocols & Controls Phantom 3 Usee Manual in addirion co Minimum VFR regulations 
William Adams, Commerce T wp, Ml Section - 333 Exemption Petition 

14 C.F.R. 91.203 (a) & (b); 

14 C.F.R. 91.405 (a); 

14 CFR 407 (a)( I); 

14 CFR 409 (a) (2); and, 

14CFR417(a)&(b). 

III. The Extent of relief William Adams seeks and the Reason He Seeks Such Relief: 

I, William Adams, submit this application in accordance with the Reform Act, 112 P.L. 

95 §§ 33 1334, seeking relief from any currently applicable FARs operating to prevent 

me, William Adams, 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 ultra light weight UAS meets the definition of 

"small unmanned aircraft" as defined in Section 331 and therefore the integration of my 

ultra light weight UAS is expressly contemplated by the Reform Act. I would like to 

operate my ultra lightweight UAS prior to the time period by which the Reform Act 

requires the FAA to promulgate rules governing such craft. Thereby, providing direct 

experience and valuable information for formal regulation that can be administered 

uniformly to all UAS aerial video and photography. 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's; 

\1/hether 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 

reflect in favor of an exemption for me, William Adams. My UAS utilizes four (4) 

counter-rotating propellers for balance, control and stability. My UAS is equipped with 

GPS, obstacle avoidance sensors and auto return safety technology. Weighing less than 

seven (7) pounds (far below the maximum 55 pound limit); including camera with 

gimbal. 

I consider safety as foremost with each flight. My small unmanned aircraft is designed to 

hover in place via GPS and operate in less than a II m/s wind knot (approx 23 mph) 

wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 7 

mls (15 mph). Built in safety systems include a GPS mode that allows my UAS to hover 

in place when radio controls are lost. With three modes to choose from, I utilize the 

Positioning Modi for aerial videography/photography. 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 takeoff, or near the control transmitter when 

utilizing Dynamic Mode. I do not operate my UAS near airports, Hospitals nor Police 

heliports, and do not operate near areas where general public is \vithin fifty to one 

hundred (50-1 00) 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 is capable of vertical and horizontal operations, and are flown only within my line 

2 Positing Mode inclt~Ms GPS, Vision PO$itioning Sensors. and BarolllC'tcr for position hold. sclf·levcling. ahitude command. GPS. 

rttum home and dynamic rccum to home: feature. and safety comrol to return home or land in the event of communication interruption 

bel\\•ee1t RC transminer and UAS. Set' "Flight Mode" in Phamom 3 User Manual 
William Adams, Commerce Twp, M1 Section- 333 Exemption Petition 

of sight, as the remote control pilot. I also use a spotter and clear the airspace we are 

working in. 

Utilizing battery power rather than combustible fuels, flights generally last between eight 

(8) to twelve (12) minutes, with an altitude under two hundred fifty (250) feet. I utilize a 

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

each battery is eighteen ( 18) to twenty-two (22) minutes as tested. I do not operate my 

UAS 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 and 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 fami liarization 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. 

I am extremely cautious when operating of my UAS/ultra lightweight unmanned aircraft 

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 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. My UAS, 

the DJI Phantom 3, used in hobby flight, has a demonstrable safety record and does not 

pose any threat to the general public or national security. 

IV. How William Adams's 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. 

The public's interest is additionally furthered by allowing small businesses in the tourism 

industry to afford the currently cost prohibitive aerial photography used by large 

international corporations. With drone technology small businesses have the opportunity 

to level the marketing playing field and become more competitive by utilizing state of the 

art drone cinematography. Additionally, smaller private hotels/resorts are harmed by 

international resorts and their ability to market using such aerial videography drawing 

business outside the economic benefit of the United States. 

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 exemption request furthers the public interest through 

academic/visual awareness of the geographical benefits in and around the State of 
William Adams, Commerce Twp, Ml Section - 333 Exemption Petition 

Michigan. My ultra light weight UAS is battery powered and creates no emissions that 

can harm the environment. The consequence of my ultra light weight UAS 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. 

Manned aircraft can pose a threat to the public through potential catastrophic crash that 

many local communities have experienced in the past with military aircraft and 

medicaVpolice helicopter crashes. These have resulted in a loss of life and endangered the 

public with combustible fuel that burned on impact. My UAS poses no such threat since 

size and lack of combustible fuel alleviates any potential threat to the public. 

Additionally, this actually furthers the public's interest by making it safer for business to 

conduct aerial photography and videography without such risks. 

The public's interest is furthered by minimizing ecological and crash threat by permitting 

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

Permitting me to immediately fly within national air space furthers economic growth. 

Granting my exemption request substantially furthers the economic impact within the 

State of Michigan for companies looking to relocate or build in Michigan 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 Willinm Adams's Exemption Will Not Adversely Affect Safety Or 

How The Exemption Will Provide a Level of Safety At Lenst Equal To Existing 

Rule: 

My exemption will not adversely affect safety. Quite the contrary, for the reasons stated 

pennitting me 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 development in cooperation with 

the FAA. In addition I submit the following representations of enhancements to current 

aerial videography and photography: 

A. My UAS weighs less than 7 pounds complete with a small ultra light weight high 

quality camera; 

B. I only operate my UAS below 300 feet (well within the 400 foot permissible 

ceiling set by the FAA Modernization and Reform Act of2012); 

C. My UAS only operates for 18- 22 minutes per flight; 

D. I land my UAS prior to 20% Battery Remaining; 

E. I pilot my UAS through remote control only by line of sight; 

F. I pilot my UAS only with a visual observer; 

G. My UAS has Failsafe RTH, a flight safety feature whereby it hovers and then 

slowly lands if communication with the remote control pilot is lost for 3 seconds; 

H. My UAS has GPS and a Vision Positioning System utilizing two sonar sensors 

and one monocular camera for positioning and to identify the current aircraft's 

position; 

I. My UAS has a flight recorder and I actively analyze flight data and other sources 

of information to constantly update and enhance safety protocols; 
William Adams, Commerce Twp, M1 Section - 333 Exemption Petition 

J. l only operate in reasonably safe environment that are strictly controlled, are 

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

K. I conduct extensive preflight inspections and protocol per the Phantom 3 User 

Manual; 

L. I always obtain all necessary permissions prior to operation; 

M. I immediately abort flights in the event of potential danger; 

N. I only operate my UAS well within "flight environment requirements4

" & visual 

meteorological conditions (VMC). 

0. I will not operate my UAS 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. 

P. Only I, William Adams, a licensed Private Pilot (Certificate #381569777, act as 

Pilot in Command during flights; 

Q. I follow the UAS manufacturer's aircraft/component, maintenance; overhaul, 

replacement, inspection, and life limit requirements. 

R. The operating documents/manual will be accessible during UAS operations and 

made available upon request. 

S. My UAS has a vision detection system that allows it to land automatically even 

when GPS signal is lost 

U. I will be carrying $1,000,000 CSL Property and Liability commercial insurance 

My safety protocols5 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, real estate, and marketing purposes. While the safety record of 

such helicopters is remarkably astounding, there have been 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 I only operates my UAS in specific areas away from mass populations. 

• Second, there is no fuel on board a VAS and thus the potential for fire or explosions 

is greatly diminished. 

• Third, the small size and extreme maneuverability of my UAS allow me to remotely 

pilot away from and avoid hazards quickly and safely. 

• Fourth, given its small size and weight, even when close enough to capture amazing 

images, my VAS 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 has been experimentally operated for fami liarization and 

competency and will continue to operate at and above cunent safety levels. 

VI. A S ummary 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. 

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WiiJiam Adams, Commerce Twp, MI Section - 333 Exemption Petition 

14 C.F.R. 21, Subpart H, entitle:<! Airworthiness Certificates, sets forth requirements 

for procurement of necessary air.vorthiness certificates in relation to FAR § 

91.203(a)(l). The size, weight and enclosed operational area of my VAS permits 

exemption from Part 21 because my 

VAS meets (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 V.S.C. § 44701 (t)) and Section 333 of 

the Refom1 Act. Both pieces of legislation permit the FAA to exempt VAS's from the 

air.vorthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. My 

current and projected VAS'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 VAS'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. I 0 The FAA 

has previously issued exemptions to this regulation in Exemption Nos. 8607, 873 7, 

8738,9299, 9299A, 9565,95658, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable in so far as my VAS 

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, William Adan1s. 

B. 14 C.F.R. § 45.23: Marking ofThe Aircraft 

Applicable Codes of Federal Regulation require aircraft to be marked according to 

certain specifications. My VAS are, by definition, wlffianned. 

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 dinlensions smaller that minimal lettering requirement. The FAA has previously 

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

and 10700. 

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. 
William Adams, Commerce Twp, MI Section - 333 Exemption Petition 

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

noncommercial operations. I, William Adams, can achieve an equivalent level of 

safety as achieved by current Regulations because my UAS does not carry any pilots 

or passengers. The risks attended to the operation of my UAS is far less than the risk 

levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, 

allowing me to operate my UAS meet and exceed current safety levels in relation to 

14 C.F.R. §61.113 (a) & (b). In addition, Grant of Exemption No. 11062 to Astraeus 

Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate 

operating the Astraeus UAS would not adversely affect operations in the NAS or 

present a hazard to persons or property on the ground. 

D. 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 

will never operate at an altitude greater than 300 AGL; safely below the standard of 

400 AGL. I will however operate my UAS 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, an equivalent or higher level of safety will be achieved. 

E. 14 C.F.R. 91.405 (a); 407 (a) (I); 409 (a) (2); 41 7(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 berween required inspections, 

except as provided in paragraph (c) of this section. have discrepancies repaired as preseribed in pan 43 

of this chapter .... " 

These Regulations only apply to aircraft with an airworthiness certificate. 

They will not, therefore, apply to my UAS. However, as a safety precaution I inspect 

my UAS before and after each flight and maintained per the manufacturer's 

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit 

requirements. 

In summary, William Adams 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)(l); 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 

conunercially operate my lightweight unmanned aircraft system for aerial 

photography/Inspection/included but not limited to the following; Business 

Operations: over land, waterways, and oceans; operation over/in nonrestricted 

National Parks, National Forests, flight in notmavigable airspace, using nonintrusive 

recording devices, operation in otherwise unrestricted U.S. States/Territories for 

aerial videography/cinematography for commercial operation and to enhance 
William Adams, Commerce Twp, Mr Section - 333 Exemption Petition 

academic community awareness for those individuals and companies unfamiliar with 

the geographical layout of such areas. 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 request for 

exemption will reduce current risk levels and thereby enhance safety. My UAS does 

not contain potentially explosive fuel, is smaller, lighter and more maneuverable than 

conventional 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 have been analyzing flight information and will 

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

exceeds currently accepted means and methods for safe flight. Fonnal 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 of2012. There 

are no personnel on board my UAS and therefore the likelihood of death or serious 

bodily injury is significantly diminished. The operation of my UAS, weighing less 

than 7 pounds and travelling at lower speeds within limited areas will provide an 

equivalent level of safety as that achieved under current F ARs. Accordingly I 

respectfully request that the FAA grant my exemption request and am willing to 

cooperate in sharing infom1ation to benefit tile FAA, safety of manned aircraft, and 

the general public at large. 

i 

William Adams