Private and Confidential

CRAIG KABRHEL (PLIERHEADS LLC), Brooklyn, NY - Section 333 Exemption Petition

September 22, 2015

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave,

SE Washington, DC 20590 

Re: Exemption Request 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; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 

91.417(a)&(b) 

Dear Sir or Madam, I, CRAIG KABRHEL (PLIERHEADS LLC), am writing pursuant 

to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 

C.F.R. 11, to request that I, CRAIG KABRHEL (PLIERHEADS LLC), an owner and operator of 

small-unmanned aircrafts, be exempted from the Federal Aviation Regulations 

(“FARs”) listed below so that I, CRAIG KABRHEL (PLIERHEADS LLC), may operate my small 

ultra lightweight unmanned aircraft system (“UAS”) in commercially regulated airspace by the 

Federal Aviation Administration (“FAA”). 

Following exemption and approval by the FAA, I, CRAIG KABRHEL (PLIERHEADS LLC), will 

primarily use my professionally built DJI Inspire 1 and DJI Phantom 3 UAS equipped with 

cameras for the following applications: Closed-Set Film Operations on Film and Television 

Productions, as well as aerial videography/cinematography to safely enhance films and 

commercials; augmentation of real estate listing videos; and the creation of visual and 

topography layout videos for Search and Rescue (SAR) missions for state and local agency’s, 

education, agricultural inspections and building and construction zone inspections.

My, CRAIG KABRHEL (PLIERHEADS LLC)’s, exemption request would permit the operation 

of ultra lightweight, unmanned (i.e. piloted by remote control) UAS’s for the development of 

community and government use videos, permissible within property boundaries for individual 

homeowners and within in tightly controlled, limited airspaces predetermined in areas away from 

the general public, airports, heliports and vehicular traffic. 

Currently, unmonitored amateur hobbyists, with no safety plan or controls in place to prevent 

catastrophe, legally operate similar lightweight remote controlled UAS’s. Furthermore, it is my 

intent to assist future FAA safety protocols and regulations exclusive to lightweight UAS's for 

specific video and photography usage by sharing information with the FAA as I, CRAIG 
2

2

KABRHEL (PLIERHEADS LLC), record flight data and other pertinent information gained 

through permitted flight operations. 

In addition, granting my, CRAIG KABRHEL (PLIERHEADS LLC),’s, exemption request will 

comply with the Secretary of Transportation’s (FAA Administrator’s) instructions to not only 

integrate UAS's into the national airspace system, but to “...establish requirements for the safe 

operation of such aircraft systems [UAS's] in the national airspace system” under 

Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor purposes, 

educational videos, Search and Rescue, land/trusts inspections, agricultural field monitoring, 

film/video productions, closed-set motion picture film operations and television, and structure 

inspections, to aid state and local agency’s. 

Further I, CRAIG KABRHEL (PLIERHEADS LLC), will conduct my operations in compliance 

with the protocols described herein or as otherwise established by the FAA. 

For the reasons stated below, I, CRAIG KABRHEL (PLIERHEADS LLC), respectfully request 

the grant of an exemption allowing me to operate ultra lightweight, remote controlled 

UAS’s to aid academic community awareness, to benefit/stimulate attraction to the New York 

metropolitan area and to enhance personal and public video feeds. A grant that will ultimately 

allow UAS’s to play a more positive role in our local community by increasing employment 

opportunities, heightening security measures and decreasing government expenditures by 

reducing the need for heavier manned aircraft, containing costly, combustible fuel- a potential 

public hazard in and of itself. 

I. Contact Information:

CRAIG KABRHEL

PLIERHEADS LLC

BROOKLYN, NEW YORK 11206

Phone: 347-603-6134

Email: craig@plierheads.com

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

CRAIG KABRHEL (PLIERHEADS LLC) 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). 

III. The Extent of relief CRAIG KABRHEL (PLIERHEADS LLC) Seeks and the 

Reason He Seeks Such Relief: 

I, CRAIG KABRHEL (PLIERHEADS LLC), submit this application in accordance with the 

Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs 
3

3

operating to prevent me, CRAIG KABRHEL (PLIERHEADS LLC), 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, CRAIG KABRHEL 

(PLIERHEADS LLC)’s, ultra lightweight 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 related UAS aerial video and photography. The Reform Act guides 

the Secretary in determining the types of UAS's that may operate safely in our national airspace 

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

Whether 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 reflects in favor of an exemption for me, CRAIG KABRHEL (PLIERHEADS 

LLC). My UAS’s utilize four (4) or less rotating propellers for balance, control and stability. My 

UAS’s are equipped with the following via video and data telemetry:

1) Altimeter 

2) Attitude indicator 

3) Ground Speed indicator 

4) Magnetic compass 

5) Heading indicator 

6) Vertical speed indicator 

7) Course deviation indicator 

8) Radio magnetic indicator 

9) GPS location 

10) Battery consumption and Battery Left with approximate time. 

11) Loiter and circle mode. 

12) Auto safety or RTL (Return To Launch) 

13) Auto landing technology. 

Each UAS weighing less than ten (10) pounds (far below the maximum 55 pound limit); 

Including camera(s) with or without gimbal (a camera stabilizer). I, CRAIG KABRHEL 

(PLIERHEADS LLC), consider safety as foremost with each flight. My small-unmanned aircraft 

is designed to hover in place, circle in a specific place or loiter via GPS and can be operated in 

winds up to 30.4 knots (35mph) wind. For safety, stability and fear of financial loss I will not fly in 

winds exceeding 21.7 knots (25 mph). Built in safety systems include a GPS mode that allows 

my UAS to hover/circle in place or land when radio controls are released. 

With three (3) modes to choose from, I will fly with the modes safest to complete the videos for 

aerial videography/photography and have the ability to choose the safest, most reliable and 
4

4

stable mode to prevent accident and hazard. When pilot communication from the radio control is 

lost, UAS is designed slowly descend to point of takeoff and or to land at point of launch after 

ascending to a pre-set altitude to ensure the UAS will clear any obstacles that may be between 

the takeoff point and the current position of the UAS. This failsafe altitude will not be set more 

than 200ft and is determined before each flight. 

I, CRAIG KABRHEL (PLIERHEADS LLC), will not operate my UAS near airports, hospitals nor 

police heliports, and do not operate near areas where general public is within fifty to one 

hundred (50-100) 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’s are capable of vertical and 

horizontal operations, and is flown only within my line of sight, as the remote control pilot. My 

UAS's are also flown with a second operator who aids in watching for any obstacles, including 

manned aircraft, within the flight zone of the UAS. Utilizing battery power rather than 

combustible fuels, flights generally last between three (3) to twenty-five (25) minutes, with an 

altitude under one hundred fifty (150) feet. (3) Smart Mode includes, position hold, self-leveling, 

altitude command, GPS, return home feature, and safety control to return home or land in the 

event of communication interruption between RC transmitter and UAS.

I, CRAIG KABRHEL (PLIERHEADS LLC), 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 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 or hazard. Reserve batteries are at hand with each exercise to insure 

replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a 

crash, which 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 familiarization 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 for the sake 

of safety. 

I, CRAIG KABRHEL (PLIERHEADS LLC), 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. 

CRAIG KABRHEL (PLIERHEADS LLC)’s 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 CRAIG KABRHEL (PLIERHEADS LLC)’s Request Will Benefit the 
5

5

Public As A Whole: Aerial videography for geographical awareness, education, search and 

rescue, land management, structure inspections and for real estate marketing has been around 

for a long time through manned fixed wing aircraft and helicopters. For small budget companies, 

average homeowners and property owners 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 owners and lower budget companies from a 

valuable marketing tool. Manned aircraft pose a threat to the public through potential 

catastrophic crash that the New York community has experienced in the past with military 

aircraft, medical helicopters, and news helicopters crashes within the city of New York, each 

resulting in loss of life. 

Each with combustible fuel that exploded and burned on impact. Police helicopters have made 

emergency hard landings within city limits. My, CRAIG KABRHEL (PLIERHEADS LLC), UAS 

poses no such threat since size and lack of combustible fuel alleviates any potential threat to 

the public. 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, CRAIG KABRHEL (PLIERHEADS LLC)’s, exemption request furthers the 

public interest through academic/visual awareness of the geographical benefits in and around 

the New York metropolitan area. My ultra lightweight UAS is battery powered and creates no 

emissions that can harm the environment. The consequence of my ultra lightweight 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. The public’s interest is 

furthered by minimizing ecological and crash threat by permitting aerial video/photo capture 

through my battery operated ultra lightweight UAS's. 

Permitting me, CRAIG KABRHEL (PLIERHEADS LLC), to immediately fly within national air 

space furthers economic growth. Granting my exemption request substantially furthers the 

economic impact for the New York metropolitan area and surrounding community for 

companies looking to relocate or build around the New York metropolitan area 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 CRAIG KABRHEL (PLIERHEADS LLC)’s Exemption

Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At 

Least Equal To Existing Rule: My, CRAIG KABRHEL (PLIERHEADS LLC)’s, exemption will not 

adversely affect safety. Quite the contrary, for the reasons stated permitting me, CRAIG 

KABRHEL (PLIERHEADS LLC), 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 Realtors, land and structured owners 

for development in cooperation with the FAA. In addition I, CRAIG KABRHEL (PLIERHEADS 

LLC), submit the following representations of enhancements to current aerial videography and 

photography: My UAS’s weigh less than ten (10) pounds complete with an DJI Inspire 1 

integrated camera, DJI Phantom 3 integrated camera, and the DJI Inspire 1 Zenmuse X5R 

camera; I only operate my UAS below 200 feet (well within the 400 foot permissible ceiling set 

by the FAA Modernization and Reform Act of 2012); My UAS only operate for 3-22 minutes per 

flight; I land my UAS prior to manufacturer recommended minimum level of battery power; I pilot 
6

6

my UAS through remote control only by line of sight; and have live video feed for a secondary 

pilot to monitor video recording; I receive a live telemetry feed from my UAS during all flights 

which include remaining battery voltage, distance, altitude, and any anomalies that may occur 

during flight;

My UAS’s Command and Control utilizes spread spectrum 2.4Ghz-2.485Ghz frequencies in 

accordance with CFR 47, Part 15 for model aircraft use.

My UAS’s camera system utilizes 5.725Ghz-5.875Ghz frequencies in accordance with CFR 47, 

Part 15.

My UAS’s have a GPS controlled flight controller- a flight safety feature whereby it hovers or 

circles and then lands at the GPS takeoff point if communication with the remote control pilot is 

lost; I actively record and analyze flight data through the DJI Inspire 1 and DJI phantom 3 flight 

controller app to constantly update and enhance safety protocols; I only operate in reasonably 

safe environment that are strictly controlled, are away from power lines, elevated lights, airports 

and actively populated areas; I conduct extensive preflight inspections and protocol, during 

which safety carries primary importance; I always obtain all necessary permissions prior to 

operation; and, I have procedures in place to abort flights in the event of safety breaches or 

potential danger. My, CRAIG KABRHEL (PLIERHEADS LLC)’s, safety protocols 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, structured 

inspections, land management and search and rescue. While the safety record of such 

helicopters is remarkably astounding, there has been local incident involving loss of life as well 

as extensive property damage; it is far safer to operate a battery powered ultra lightweight UAS. 

First, the potential loss of life is diminished because UAS's carry no people on board and I only 

operate my 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 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. Lastly, given its small size and weight, even when close enough to 

capture amazing images, my 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. Accordingly, 

my UAS has been experimentally operated for familiarization/competency and will continue to 

operate at and above current safety levels. 

VI. A Summary The FAA May Publish in the Federal Register: 

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 

14 C.F.R. 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 my, CRAIG KABRHEL (PLIERHEADS LLC)’s, UAS 

permits exemption from Part 21 because my UAS 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 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 
7

7

airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability 

and proximity to areas such as airports and dense populations. My, CRAIG KABRHEL 

(PLIERHEADS LLC)’s, current and projected UAS'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 UAS'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. 

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. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor or controlled GPS “geofencing” 

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, CRAIG KABRHEL (PLIERHEADS LLC). 

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. My UAS can be marked with the 

appropriate “N” number once this “N” number has been given.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 

61.113 (a) & (b), private pilots are limited to non-commercial operations. I, CRAIG KABRHEL 

(PLIERHEADS LLC), The sUAS Pilot in Command must possess at least a sport pilot certificate 

and a driver's license. The PIC must also meet the flight review requirements specified in 14 

CFR § 61.56 in which the PIC is rated on his/her pilot certificate as outlined in 14 C.F.R. § 61.

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 300fclose AGL; safely below 

the standard of 400 AGL. I, CRAIG KABRHEL (PLIERHEADS LLC), 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) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.1,2,

Manual
8

8

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 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, apply to my, CRAIG KABRHEL 

(PLIERHEADS LLC)'s, UAS. However, as a safety precaution I inspect my UAS before and 

after each flight. 

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 Like. 14 C.F.R. 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 

my UAS permits exemption from Part 21 because my, CRAIG KABRHEL (PLIERHEADS 

LLC)’s, UAS meets 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 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. My 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 pilots or passengers, and given the size of the UAS's, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The 

FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 

9299, 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, CRAIG KABRHEL (PLIERHEADS LLC) 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)(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 commercially operate my, 

CRAIG KABRHEL (PLIERHEADS LLC)'s, small unmanned vehicle/lightweight unmanned 

aircraft vehicle in community awareness, education, structural inspection land management, 

search and rescue and real estate operations, and to develop economic platforms for the 

aforementioned to enhance the experience of those seeking to relocate, rebuild, reevaluate and 

to find in the New York metropolitan area. 
9

9

F. Additional FAA Required Operating Conditions and Limitations

When not covered elsewhere in this Operations Manual, the following conditions and 

limitations apply:

1. The UA must weigh less than 55 pounds (25kg), including energy source(s) 

and equipment

2. The UA may not be flown at a speed exceeding a ground speed of 85 knots.

3. Flights must be operated at an altitude of no more than 500 feet above ground level 

(AGL), as indicated by the procedures specified in the operator's manual. All 

altitudes reported to ATC must be in feet AGL.

4. The UAS 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 state driver’s license.

5. All operations must utilize a visual observer (VO). 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.

6. If a discrepancy exists between these limitations and any procedure outlined elsewhere 

in this operations manual, the conditions and limitations herein take precedence and 

must be followed.

7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe 

flight. 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. The Ground 

Control Station, if utilized, must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records.

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 in accordance with the operator's manual. The PIC who conducts 

the functional test flight must make an entry in the UAS aircraft records of the flight.

9. The operator must follow the manufacturer's UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft 
10

10

maintenance/component/overhaul, replacement, and inspection/maintenance

requirements must be established and identified in the operator's manual. At a minimum, 

the following must be included in the operator's manual:

a. Actuators / Servos

b. Transmission (single rotor)

c. Powerplant (motors)

d. Propellers

e. Electronic speed controller 

f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used)

j. Any other components as determined by the operator

10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a 

current state driver’s license. 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/her pilot 

certificate.

11. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14

CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a UAS 

rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single 

blade or multi-rotor). Prior documented flight experience that was obtained in compliance 

with applicable regulations may satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under this grant of exemption to 

accomplish the required flight cycles and flight time. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are considered 

non-participants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

12. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14
11

11

CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS 

to be utilized for operations under the exemption and three takeoffs and three landings in the 

preceding 90 days. Training, proficiency, experience building, and takeoff and landing currency 

flights can be conducted under this grant of exemption to accomplish the required flight time 

and 90 day currency. During training, proficiency, experience building, and takeoff and landing 

currency flights, all persons not essential for flight operations are considered non-participants, 

and the PIC must operate the UAS with appropriate distance from non-participants in 

accordance with 14 CFR § 91.119.

13. Prior to any flight operations authorized by this grant of exemption, the PIC and visual 

observer (VO) must have successfully completed a qualification process, as outlined in the 

operator’s manual. As this is a requirement stipulated by the operator, the test must be 

developed and implemented by a qualified person designated at the sole discretion of the 

operator. A record of completion of this qualification process must be documented and made 

available to the Administrator upon request.

14. Prior to operations conducted for the purpose of motion picture filming (or similar

operations), a flight demonstration, administered by an operator-approved and -qualified pilot 

must be successfully completed and documented. This documentation must be available for 

review upon request by the Administrator. Because the knowledge and airmanship test 

qualifications have been developed by the operator, and there are no established practical 

test standards that support a jurisdictional FAA FSDO evaluation and approval of company 

designated examiners, the petitioner will conduct these tests in accordance with the operator’s 

manual.

15. The UAS may not be operated directly over any person, except authorized and consenting 

production personnel, below an altitude that is hazardous to persons or property on the surface 

in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting production personnel. At all times, those persons 

must be essential to the closed-set film operations. Because these procedures are specific to 

participating persons, no further FSDO or Aviation Safety Inspector (ASI) approval is 

necessary for reductions to the distances specified in the petitioner’s manuals. This is 
12

12

consistent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1 

Issue a Certificate of Waiver for Motion Picture and Television Filming.

17. Regarding distance from non-participating persons, the operator must ensure that no 

persons are allowed within 500 feet of the area except those consenting to be involved and 

necessary for the filming production. This provision may be reduced to no less than 200 feet 

if it would not adversely affect safety and the Administrator has approved it. For example, an 

equivalent level of safety may be determined by an aviation safety inspector’s evaluation of 

the filming production area to note terrain features, obstructions, buildings, safety barriers, 

etc. Such barriers may protect non-participating persons (observers, the public, news media, 

etc.) from debris in the event of an accident. This is also consistent with the same FAA Order 

8900.1, V3, C8, S1. 18. If the UAS loses communications or loses its GPS signal, the UA 

must return to a pre-determined location within the security perimeter and land or be 

recovered in accordance with the operator’s manual.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance 

with the operator’s manual.

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

accordance with the operator’s manual.

20. Each UAS operation must be completed within 30 minutes flight time or with 25%

battery power remaining, whichever occurs first.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this grant of exemption. This 

COA will also require the operator to request a Notice to Airman (NOTAM) not more than 

72 hours in advance, but not less than 48 hours prior to the operation.

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 (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. The operator must develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the UAS. These procedures must be 

added to the operator’s manual.
13

13

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

Bulletins.

25. The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual.

26. The preflight inspection section in the operator’s manual must be amended to include the 

following requirement: The preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in the relevant preflight 

inspection sections of the operator’s manual.

27. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.

28. At least three days before scheduled filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local 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 person responsible for the UAS filming 

production 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 the UAS to be used

e. Name and certificate number of the UAS PIC's involved in the filming 

production event 

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

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
14

14

29. The 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.

30. The UAS must remain clear and yield the right of way to all other manned operations 

and activities at all times (including, but not limited to, ultra light vehicles, parachute 

activities, parasailing activities, hang gliders, etc.).

31. 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.

32. The UAS cannot be operated by the PIC from any moving device or vehicle.

33. The UAS 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.

34. The UAS may not operate in Class B, C, or D airspace without written approval from the 

FAA. The UAS may not operate within 5 miles of the geographic center of a non-towered 

airport as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of agreement 

with the airport management must be made available to the Administrator upon request.

35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

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

the Federal Aviation Administration’s (FAA) 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. Further flight operations may 

not be conducted until the incident, accident, or transgression is reviewed by AFS-80 and 

authorization to resume operations is provided.

Currently, the aforementioned aerial videography/photography relies primarily on the use of 

larger aircraft running on combustible fuel. Posing potential risk to the public. Granting my, 

CRAIG KABRHEL (PLIERHEADS LLC)’s, request for exemption will reduce current risk levels 

and thereby enhance safety. My UAS craft do not contain potentially explosive fuel, is smaller, 

lighter and more maneuverable than conventional video and photographic aircraft with much 

less flight time. 
15

15

Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk 

flying to and from established airfields. I, CRAIG KABRHEL (PLIERHEADS LLC), have been 

informally analyzing and recording flight information and will compile safety protocols and the 

implementation of a flight operations manual for usage that exceeds currently accepted means 

and methods for safe flight. Formal 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 of 2012. There are no personnel on board my, CRAIG KABRHEL (PLIERHEADS 

LLC)’s, UAS and therefore the likelihood of death or serious bodily injury is significantly 

diminished. My, CRAIG KABRHEL (PLIERHEADS LLC)’s, operation of my UAS, weighing less 

than ten (10) pounds and traveling at lower speeds within limited areas low to the ground will 

provide an equivalent level of safety as that achieved under current FARs. Accordingly I, CRAIG 

KABRHEL (PLIERHEADS LLC), respectfully request that the FAA grant my exemption request 

and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, 

and the general public at large. 

Respectfully submitted, 

CRAIG KABRHEL (PLIERHEADS LLC)

168 Scholes Street Apt 2B

Brooklyn, NY 11206

10

Appendix A

List of Aircraft

No. Make and Model Description Serial No. Registration

No.

1 DJI Inspire 1 Electric powered, 4 rotor, small 

unmanned multi-rotor helicopter

W18DCA10

011868

Pending

2 DJI Phantom 3 Electric powered, 4 rotor small 

unmanned multi-rotor helicopter

P78DCE22

032084

Pending
16

16

1. DJI INSPIRE ONE

The operation of the DJI INSPIRE ONE system is as follows.

1. Build Materials

I. Plastic

II. Aluminum 

2. Motor Configuration

I. The DJI INSPIRE 1 is a 4 motor quad-copter setup.

3. Payload 

I. The DJI INSPIRE ONE flies it’s own lightweight integrated camera. 

II. Maximum All-up weight- 6lbs

4. Maintaining the DJI INSPIRE ONE

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 

5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as 

necessary. 

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. 

4. Check for cuts, and/or cracks on propellers. Replace if propeller is questionable. 

5. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

6. Check for updates to flight controller firmware. If available, install and perform a minimum of 

15 test flights before conducting commercial work.

Appendix B 

2. DJI Phantom 3

The operation of the DJI Phantom 3 system is as follows.

1. Build Materials

I. Plastic

II. Aluminum 
17

17

2. Motor Configuration

I. The Phantom 3 is a 4 motor quad-copter setup.

3. Payload

I. The Phantom 3 it’s own integrated camera. 

II. Maximum All-up Weight- 4lbs

4. Maintaining the Phantom 3

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 

5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as 

necessary. 

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. 

4. Check for cuts, and/or cracks on propellers. Replace if propeller is questionable. 

5. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

6. Check for updates to flight controller firmware. If available, install and perform a minimum of 

15 test flights before conducting commercial work.

Appendix C

Personal Protocols/Controls/Flight Manual 

Protocols and Controls 

CRAIG KABRHEL (PLIERHEADS LLC), BROOKLYN, NY.

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. As such, safety protocols and controls must be 

implemented through preflight preparation and during flight. PreFlight Protocol: 

Check batteries with voltage meter to insure fully charged and ready for use. 

Inspect batteries for damage or leakage that may affect proper operation. 

Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or 

unmanageable/uncontrolled flight. 
18

18

Check all GPS and Telemetry connections prior to flight. 

Check weather forecasts for wind advisory or other conditions that my impact flight. 

Consult Sky Vector aeronautical Charts (Skyvector.com) for airport vicinity and flight paths of 

possible air traffic.

Contact respective airport to advise of estimated flight time, estimated flight duration, estimated 

elevation of flight, and any other pertinent information. 

Inspect flight area for 

Vicinity of public safety helipads/heliports

Vicinity of medical helipads/heliports 

Vicinity of light poles vicinity or utility wires 

Vicinity of trees flocks of birds that may cause interference and potential flight impact 

Vicinity of any elevated obstructions that may pose potential flight hazard 

Vicinity of roadways with moderate to heavy traffic that can be distracted public 

Gatherings that may attract viewers optional point of control for best visual site of UAS 

while in flight 

Emergency landing areas

Takeoff and landing 

Inspect area for best and safest point of takeoff and landing 

If in a subdivision or area that is within 150 feet of a residential street, post warning 

Sign(s)/stand(s) "Attention Aerial Photography In Progress  Remain Back 150 Feet " 

Flight Protocol: takeoff and land from same location ( have alternate landing areas in case of 

emergencies) remain alert to birds, sound or aircraft, curious public, and approaching vehicles 

do not allow anyone to engage in conversation or distract the remote control pilot restrict flight to 

minimal elevation sufficient to acquire desired results remained prepared for emergency landing 

at all times pay attention to flight time – warning meter for low voltage. 

Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and shut 

down propulsion immediately following landing – priority of disconnecting batteries 

Post flight: 

1. a) Disconnect battery to prevent accidental activation of propulsion system 

2. b) Secure UAS in a safe location 

c) Remove all warning signs from public access areas Emergency or Suspected Hazard: 
19

19

Immediate land UAS at safest and closet ground location in the event 

Manned aircraft is heard or seen in vicinity of flight 

There is a public gathering within established safety boundary wanting to observe flight 

Pilot is being distracted from focusing on flight and safety 

Sudden change in weather (wind bursts) 

Sudden increase in vehicular traffic in vicinity of flight 

Birds enter into proximity of flight 

Any sudden unsafe event that can cause collision, distraction or interruption of control 

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. 

Maintaining a record of safe flight for FAA request and for determining future UAS safety 

protocols is imperative. 

Date:____________________ 

Location:___________________________________________________ 

preflight Inspection: 

o Yes o No 

Comment: _________________________________________________ 

Elements 

Proximity to airport: _________________ (see attached map pinpointing approximate location 

of flight) 

Airport notified: No Yes 

Date:_______________ Time: ______________ 

Phone Number: _______________________ 

Contact Name:___________________________________ 

Nearest major intersection: 

______________________________________________________________ 
20

20

Proximity to medium traffic road: 

_________________________________________________________

Proximity to heavily traveled roadway road: 

_________________________________________________ 

Proximity to congested population: 

________________________________________________________ 

Approx. Takeoff Time : GMT: 

Weather Good Fair Poor Comment : 

Visibility Good Fair Poor Comment : 

Wind Speed ___mph ___Gusts/MPH ___avg/MPH Comment : 

Approx. Landing Time: GMT: Estimated Elevation Ground level: 

Safety Concerns: 

Additional Comments: 

sea level: 

Appendix 'D'

Aircraft Manuals

This Appendix includes UAS manufacturer's user manuals, maintenance instructions, and 

illustrated parts catalogs. These manuals may be attached to the docket when submitted. 

Information regarding design, aircraft performance, fail-safe features, operating limitations, 

normal and emergency procedures, and maintenance and inspection procedures is contained 

within the manuals and supplemental information documents listed below:

1. DJI Inspire Manual V1.0

2. Inspire 1 Maintenance Manual v1.0

3. Intelligent Flight Battery Safety Guidelines v1.4

4. Inspire 1 Safety Guidelines

5. Phantom 3 Professional Manual V1.0

6. Phantom 3 Intelligent Flight Battery Safety Guidelines v1.0 (EN)
21

21

For more information or questions about this manual please contact:

Plierheads LLC

Craig Kabrhel

168 Scholes apt 2b

347-603-6134