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Dear Sir or Madam,

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 South 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 

committed 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 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)
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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. 
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___________________________________

4Smart Mode includes GPS Geofence radius for operation, position hold, self-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. 
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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 recommended 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, 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 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 complete 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 safety breaches or

potential danger.

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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 Glasss, 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:

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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 station 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 placing 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 Altitudes.

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

_______________________

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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 risk 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 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. . . .”

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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 higher level of safety will be achieved.
Glass Group PA

1734 SW Buttercup Ave

Port St Lucie FL 34953		

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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 small 

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 does 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,