Page 1 of 9 Dear Sir or Mada m,

I, Jeremy Glass dba Glass Group PA , 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, Jeremy Glass , an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Jeremy Glass , may operate my unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein I, Jeremy Glass , an insured member of the AMA (Academy of Model Aeronautics) am experienced in flying hobby helicopters/planes for recreational purposes. Currently using a DJI Phantom 2 & DJI Phantom 3 Professional Quadcopter with intent for aerial videography/cinematography to enhance academic community awareness for individuals and companies unfamiliar with the geographical layout of the South Florida area, and augment real estate listing videos

, provide precision aerial surveys and all aerial photography ; following exemption and approval by the FAA. Thereby enhancing their academic research experience for the So uth Florida Area. I have flown RC Helicopters/Planes for over three ( 3 ) years without incident and hold a

Federal Aviation Private Pilot license

. I attended and obtained a Bachelor of Science in Aeronautics from Embry- Riddle Aeronautical University with high honors. I am

c ommitted to safety with each flight. My exemption request would permit operation of ultra light weight, UAS(s) in tightly controlled and limited airspace

. Predetermined 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. Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. Jeremy Glass, Glass Group P.A. – Section 333 Exemption Petition

July 8th , 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 Ac t 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)Page 2 of 9 Name and Address of the Petitioner

Jeremy Glass dba “Glass Group PA”

Ph: 772-370-9637 Address: 1734 Sw Buttercup Ave Port St Lucie FL 34953 Email: Jeremy@JeremyAGlass.com

Regulations Petitioner Petitions for Exemption, If Such Regulations Apply to SUAVs

14 CFR Part 21 14 C.F.R. 91.109 14 CFR 91.405 (a) 14 C.F.R. 45.23(b) 14 C.F. R. 91.119 14 CFR 407 (a) (1) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.121 14 CFR 409 (a) (2) 14 C.F.R. 91.7 (a) 14 CFR 91.151 (a) 14 CFR 417 (a) & (b) 14 CFR 91.9 (b) (2) 14 CFR 91.203 (a) & (b)

14 C.F.R. 91.103

_________________________ Jeremy Glass, Glass Group P.A. – Section 333 Exemption Petition

I follow safety protocols exclusive to lightweight UAS's specific to real estate video and photography usage as I, Jeremy Glass

, 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 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 Cinematography/Photo purposes. Further I, Jeremy Glass , will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below I, Jeremy Glass , respectfully request the grant of an exemption allowing me to operate ultra lightweight, remote controlled UAS’s for academic community awareness to benefit/stimulate attraction to the South Florida area and to enhance real estate listing videos for homeowners who cannot afford expensive manned aircraft for the same purpose. Both 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.Page 3 of 9 ___________________________________
4 Smart Mode includes GPS Geofence radius for operation, position hold, s e lf

- leveling, altitude command, return home feature or land in the event of communication interruption between RC transmitter and UAS. Jeremy Glass, Glass Group P.A. – Section 333 Exemption Petition

The Extent of relief sought and the Reason He Seeks Such Relief: I, Jeremy Glass , submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent

me, Jeremy Glass , to pursue 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, Jeremy Glass ’ , 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 real estate 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 reflect in favor of an exemption for me, Jeremy Glass . My UAS utilizes four (4) counter-rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Weighing less than ten (10) pounds (far below the maximum 55 pound limit); including camera with gimbal.

I, Jeremy Glass , considers safety as foremost with each flight. My small unmanned aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place when radio control inputs are released. With three modes to choose from, I

utilize the Smart Mode 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 take off. I do 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 is capable of vertical and horizontal operations, and are flown only within my line of sight of me, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last between eighteen (18) to twenty (20) minutes, with an altitude under one hundred fifty (150) feet.Page 4 of 9 Jeremy Glass, Glass Group P.A. – Section 333 Exemption Petition

I, Jeremy Glass , 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 (20) minutes as tested. I do not operate my UAS at or below manufacturer recommend ed 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, that could create hazard to the public/property/manned aircraft. I practice computerized simulated flights to maintain adequate skills and response reflex time. I, Jeremy Glass , am extremely cautious when operating of my UAS/ultra light weight 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. The UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.

How Jeremy Glass ’ s Request Will Benefit the General Public:

Aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. However, 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 expenses. Depriving non-luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic crash that the community has experienced in the past with military, medical and news/tourism helicopter crashes

, e ach 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 UAS pose 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, Jeremy Glass , exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around the South Florida area. My ultra lightweight 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

.• My UAS weighs less than 10 pounds comp lete with a small ultra light weight high 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 18

- 20 minutes per flight;

• I land my UAS prior to manufacturer recommended minimum level of battery

power;

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

• My UAS has GPS a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost;

• I actively analyze flight data and other sources of information 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 pre

- flight inspections and protocol, during which safety carries primary importance;

• I always obtains all necessary permissions prior to operation; and,

• I have procedures in place to abort flights in the event of safet y breaches or potential danger.

Page 5 of 9 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, Jeremy Glass , to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the South Florida community for companies looking to relocate or build in the

South Florida 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.

Reasons Why Jeremy Glass ’ Exemption Will Not Adversely Affect Safety And How The Exemption Will Provide a Level of Safety At Least Equal To Existing

Rule:

My, Jeremy Glass , exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Jeremy Glass , 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 UAS Pilots that can be embraced for development in cooperation with the FAA. In addition I, Jeremy Glass s, submit the following representations of enhancements to current aerial videography and photography: Jeremy Glass, Glass Group P.A. – Section 333 Exemption Petition• First, the potential loss of life is diminished because UAS's carry no people on board and only operated 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.

A Summary The FAA May Publish in the Federal Register:

Page 6 of 9 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 and real estate. 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 light weight

UAS. Jeremy Glass, Glass Group P.A. – Section 333 Exemption Petition

A. 14 C.F.R. 21 & 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, Jeremy Glass ’, 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 airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My, Jeremy Glass , 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. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor.

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 are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot st ation on which to mark certain words or phrases. Further,

two

- inch lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs in the largest possible lettering by plac ing the word “EXPERIMENTAL” on its fuselage as required by 14

C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV

will see the markings. 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.

D. 14 C.F.R. 91.119: Minimum Safe Alt itudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows

_______________________

Page 7 of 9 Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to

non

- commercial operations. I, Jeremy Glass , can achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less

than the ri sk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Jeremy Glass , to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). 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. Jeremy Glass, Glass Group P.A. – Section 333 Exemption Petition

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, Jeremy Glass

.E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected a s 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. . . .”

Page 8 of 9 Jeremy Glass, Glass Group P.A. – Section 333 Exemption Petition

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Jeremy Glass , 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, Jeremy Glass ’, 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. helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 200 AGL; safely below the standard of 400 AGL. I, Jeremy Glass, 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 h igher level of safety will be achieved.Glass Group PA

1734 SW Buttercup Ave

Port St Lucie FL 34953

Page 9 of 9 Jeremy Glass

, Realtor & Photographer Jeremy Glass, Glass Group P.A. – Section 333 Exemption Petition

In summary, Jeremy Glass, 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 smal l unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, Cinematography, and to develop economic platforms for real estate to enhance the experience of those seeking to relocate to the South Florida area. 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 craft do es not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional video and 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 air fields. I, Jeremy Glass , have been informally analyzing flight information and have compiled safety protocols and the implementation of a flight operations manual for UAS 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 UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. Operation of my UAS, weighing less than 10 pounds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, Jeremy Glass , 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,