May 7, 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) Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 

 91.109; 91.119; 91.121; 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, Martin Lachance, 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, Martin Lachance, an owner and operator

of small-unmanned aircraft, be exempted from the Federal Aviation Regulation (“FARs”) listed below

so that I, Martin Lachance, may operate my small unmanned aircraft system (“sUAS”) commercially

in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein, I, Martin Lachance, am a photographer/videographer/cinematographer; experienced

in flying hobby aircraft for recreational purposes. I have added a quad-copter1 and hex-copter2 to my 

inventory equipped with a self-contained camera with intent for aerial photography/videography/

cinematography; following exemption and approval by the FAA.

I have flown small RC electric multi-rotor aircraft models for over five (5) years without incident. In 

addition, I have held a PPL (private pilot license) single engine land and sea for fifteen (15) years, have a 

current FCC operator’s license, and a member of Academy of Model Aeronautics (AMA). I hold a current 

KROC airport ramp access badge, which required vetting by TSA. 

I am committed to safety with each flight. My, Martin Lachances’, exemption request would permit 

operation of ultra-light weight, unmanned (piloted by remote control) and comparatively inexpensive sUAS

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 aerial 

videography/cinematography to enhance academic community awareness for individuals and companies 

unfamiliar with the geographical layout of the metro Rochester and surrounding areas; 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, and building and construction zone inspections.

Granting my, Martin Lachance’ request, comports with the Secretary of Transpiration’s (FAA 

Administrator’s) responsibilities and authority to not only integrate sUASs into the nation airspace system, 

but to “establish requirements for the safe operation of such aircraft systems (sUASs) in the

national airspace system” under Section 333 (c) of the Reform Act specific to the use of sUASs for 

photography and videography purposes. I, Martin Lachance, have personally installed safety protocols

and controls to avoid and prevent public hazard, as well as any catastrophic manned aircraft hazard.

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, Martin 

Lachance, record flight data and other pertinent information gained through permitted flight operations.

For the reason stated below, I Martin Lachance, respectfully request the grant of an exemption allowing me 

to operate ultra lightweight, remote controlled, sUAS’s to aid academic community awareness, to 

benefit/stimulate attraction to the Rochester metro area and to enhance personal and public video feeds. A 

grant that will ultimately allow sUAS’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 highly, combustible fuel, which is a potential

 1 Appendix A - 3D Robotics Manual

2 Appendix B – DJI F550 Manual
public hazard in and of itself.

I Contact Information

 Martin Lachance

 696 Mendon Ionia Road

 Honeoye Falls, New York 14472

 Mobile – (585) 698-8652

 Email – mrlbristol@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations from which Martin 

 Lachance Requests Exemption are:

 14 CRE 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 Martin Lachance Seeks and the Reason he Seeks Such Relief: 

I, Martin Lachance, 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, Martin Lachance, 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, Martin Lachance’, sUAS meets 

the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my 

ultra-lightweight sUASs is expressly contemplated by the Reform Act. I would like to operate my sUASs

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 sUAS aerial photography and videography. The Reform Act guides the Secretary in 

determining the types of sUASs that may operate safely in our national airspace system. Considerations 

include: The weight, size, speed, and overall capabilities of the sUASs; whether the sUAS will be operated 

near airports or heavily populated areas; and whether the sUAS will be operated by VLOS (visual line of 

sight).. 112 P.L 95 § 333 (a).

Each of these items reflects in favor of an exemption for me, Martin Lachance. My sUAS’s utilize four (4)

or six (6) rotating propellers for sustained flight. Accelerometers and gyros for balance, control, and 

stability. My sUAS’s are equipped with the following via video and data telemetry:

. Altimeter, AGL

. Attitude Indicator

. Auto Landing Technology

. Auto Safety or RTL (Return To Launch)

. Course Deviation Indicator

. Direction “Home”

. Fuel Consumption and Fuel Remaining with Approximate Time

. Heading Indicator

. GPS Location

. Ground Speed Indicator

. Magnetic Compass

. Loiter and Circle Mode

. Radio Magnetic Indicator

. RSSI (Received Signal Strength Indicator)

. UA Distance From “Home”

. Vertical Speed Indicator
Each sUAS weighing less than six (6) pounds, which is far below the maximum 55 pound limit; including

Camera(s) with or without gimbal (a camera stabilizer).

I, Martin Lachance, consider safety as foremost with each flight. My small sUASs are designed to hover in 

place, circle in a specific place or loiter via GPS and can be operated in winds up to 17 knots (20 mph). For 

safety, stability, and fear of financial loss I will not fly in winds exceeding 13 knots (15 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 six (6) 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 stable mode to 

prevent accident and hazard. If pilot communication, the “Link” is lost, UAS is designed to slowly

descend to point of takeoff or land at point of launch. With an onboard flight controller – 3D Robotics 

Pixhawk and DJI Naza M V2 flight controllers, it has the capabilities of geofencing, which will prevent the 

craft from exceeding a set altitude or distance. No matter what causes the craft to breach those boundaries –

the craft is forced back within boundary limits via the onboard controller and will take over the craft to keep 

it within those boundaries.

I, Martin Lachance, will not operate my UAS near airports, hospitals, or 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, VLOS, as the remote control 

pilot. Utilizing battery power rather than combustible fuels, flights generally last between five (5) to fifteen

(15) minutes, with an altitude under three hundred (300) feet. Six (6) Smart Mode includes safe circle for 

operation, 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 sUAS.

I, Martin Lachance, utilize a fully charged battery with each flight as a safety precaution; full flight

time limit for each battery is eight (8) 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

auto activation of “Return Home”, 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 risks that may 

create a 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. All for the sake of safety. I, Martin Lachance, am extremely cautious when 

operating my sUAS 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 sUAS 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 

nation airspace system. I, Martin Lachance’s sUAS, used in hobby flight, has a demonstrable safety record 

and does not pose any threat to the general public or national security.

IV How Martin Lachance’s Request Will Benefit the Public As A Whole

Aerial videography for geographical awareness, education, search and rescue, land management, structure 

inspections and for real estate marketing, historically, has been achieved by 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 upscale realtors or luxury homeowners can 

afford to absorb such expense. SARs (Search and Rescue) is often a time-critical event. We may find a 

reduction in the logistics time required, to deploy a sUAS, than conventional aircraft, to fly the mission. 

Manned aircrafts pose a threat to the public through potential catastrophic crash with combustible fuels. My, 

Martin Lachance’s sUAS, 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, Martin Lachance’s, exemption request furthers the public interest through academic/visual awareness of 

the geographical benefits in and around the Rochester metro area. My sUAS is battery powered and creates 
no emissions that can harm the environment. The consequence of my sUAS 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 sUAS’s. Permitting me, Martin Lachance, 

to immediately fly within national air space furthers economic growth. Granting my exemption request 

substantially furthers the economic impact for the Rochester metro and surrounding community for 

companies looking to build around the Rochester metro 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 Martin Lachance’s Exemption Will Not Adversely Affect Safety and How the

 Exemption Will Provide a Level of Safety at Least Equal to Existing Rule:

My, Martin Lachance’s exemption will not adversely affect safety. Quite the contrary, for the reasons stated 

permitting me, Martin Lachance, 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 structure owners and for the development in cooperation 

with the FAA. In addition, I, Martin Lachance, submit the following representation of enhancements to 

current aerial videography and photography:

. My sUAS weighs less than 6 pounds complete with a small camera;

. I only operate my sUAS below 300 feet (within the 400 feet permissible ceiling set by the FAA 

 Modernization and Reform Act of 2012);

. My sUAS only operates for five (5) to fifteen (15) minutes per flight;

. I land my sUAS prior to manufacturer recommended minimum level of battery power;

. I pilot my sUAS through remote control only by VLOS (Visual Line of Sight);

. My sUAS has a flight safety feature whereby in the event of “lost communication” with the sUAS,

 it returns to “Launch Point” which, in effect, brings the sUAS closer to pilot/RC controller, where the

 “Link” can be re-established. If “Link” is not re-established”, sUAS “Auto Lands”.

. 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, airport, and actively populated areas;

. I conduct extensive pre-flight 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, Martin Lachance’, safety protocols provide a level of safety equal to or exceeding existing rules. It is 

important to note that absent the integration of commercial sUAS into our national airspace system, 

helicopters and fixed wing aircrafts are the primary means of aerial photography and videography. While the 

safety record of such aircrafts is remarkably astounding, there has been incidents involving loss of life as 

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

. First, the potential loss of life is diminished because sUASs carry no people on board and I only operate

 my sUAS in specific areas away from mass populations;

. Second, there is no fuel on board a sUAS and thus the potential for fire or explosions is greatly reduced;

. Third, the small size and extreme maneuverability of my sUAS allows me to remotely pilot away from

 and avoid hazards quickly and safely.

Accordingly, my sUAS 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:

A. 14 C.F.R. 21 and C.F.R. 91: Airworthiness Certificates, Manual 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 operation area of my, Martin Lachance’, sUAS permits exemption from Part 21 because my 

sUAS 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 sUASs from the Airworthiness Certificate requirement in consideration of the 

weight, size, speed, maneuverability, and proximity to areas such as airports and dense populations. 

My, Martin Lachance’, current and projected sUASs 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 on-board

pilots or passengers, and given the size of the sUASs, 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, 8738, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700, 

32827, 11371, and 11381.

14 C.F.R. § 91. 121 regarding altimeter settings are inapplicable insofar as my sUAS utilized 

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,

Martin Lachance.

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 sUAS 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 a small aircraft with dimensions smaller than minimal lettering requirement. 

Regardless, I will mark the sUASs 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 sUAS will see the markings. The FAA has previously 

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

10700.

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, Martin Lachance, can achieve an equivalent level of safety as achieved by current Regulations

 because my sAUS 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 sUAS is far 

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

 Thus, allowing me, Martin Lachance, to operate my sUAS and meet and exceed current safety levels

 in relation to 14 C.F.R. § 61.113 (a) & (b). 

D. 14 C.F.R. 91.119: Minimum Safe Altitudes

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

to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude 

greater than 300 AGL. I, Martin Lachance, will however operate my sUAS 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 sUAS, 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.

The above-cited Regulations require 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, Martin Lachance’, sUAS. However, as a safety precaution, I inspect my sUAS 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, Martin Lanchance’s, sUAS 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 sUAS 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, Martin Lachance, 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. § 91.405 (a); 14 C.F.R. § 91.407 (a) (1); 14 C.F.R. § 

91.409 (a) (2); and 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Martin Lachance’s, smallunmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, education, structural 

inspection, land management, search and rescue, real estate operations, and to develop economic platforms 

for the aforementioned to enhance the experience of those seeking to find, relocate, repair, rebuild, and 

evaluate in the metro Rochester area.

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

operating on combustible fuel, which poses potential risk to the public. Granting my, Martin Lanchance’s, 

request for exemption will reduce current risk levels and thereby enhance safety. My sUASs do not contain 

potentially explosive fuel, is smaller, lighter, and more maneuverable than conventional video and 

photographic aircrafts.

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

from established airfields. I, Martin Lachance, have been informally analyzing and recording flight 

information and will compile safety protocols and the implementation of a flight operation 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, Martin Lachance’s sUAS, and 

therefore the likelihood of death or serious bodily injury is significantly diminished. My, Martin Lachance,

operation of my sUAS, weighing less than six (6) pounds and traveling at lower speeds within limited areas 

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

Lachance, 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,

Martin Lachance

696 Mendon Ionia Road

Honeoye Falls, New York 14472

Cell: (585)698-8652

Email: mrlbristol@gmail.com