Brian	Dellis

11633	N.	30th	Place

Phoenix,	Arizona	85028	

dellisbrian@yahoo.com

epicphotollc.com

ExempDon	Request	Pursuant	to	SecDon	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal	AviaDon	RegulaDons	from:	

14	CFR	21	subpart	H	

14	CFR	45.23(b)	

14	CFR	61.113(a)	and	(b)	

14	CFR	91.7(a)	

14	CFR	91.9(b)(2)	

14	CFR	91.103	

14	CFR	91.109	

14	CFR	91.119(c)	

14	CFR	91.121	

14	CFR	91.151(a)	

14	CFR	91.203	(a)	and	(b)	

14	CFR	91.405	(a)	

14	CFR	91.407	(a)	(1)	

14	CFR	91.409	(a)(1)	and	(2)	

14	CFR	91.417(a)	and	(b)	

Pursuant	to	SecDon	333	of	the	FAA	ModernizaDon	and	Reform	Act	of	2012	(the	“Reform	Act”)	and	14	CFR	Part	11,	Brian	

Dellis,	operator	of	Unmanned	AircraY	Systems	(UAS),	hereby	applies	for	an	exempDon	from	the	listed	Federal	AviaDon	

RegulaDons	(“FARs”)	to	allow	commercial	operaDon	of	designated	UAS,	provided	such	operaDons	are	conducted	within	and	

under	the	condiDons	outlined	herein	or	as	may	be	established	by	the	FAA	as	required	by	SecDon	333.	

Commercial	operaDon	of	an	UAS,	as	described	herein,	which	are	equipped	with	camera(s)	

and	sensors,	would	provide	professional	services	in	the	following	areas:	

1.	Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	estate,	

architecture,	and	other	related	professional	acDviDes.	

2.	Aerial	video	and/or	photography	for	public	and/or	private	use	including	television,	public	

events,	cinematography	and	newsgathering.	

3.	Aerial	inspecDon/photography	of	residenDal/commercial	structures	under	contract	with	the	

owners	or	local	government	authority.	

4.	Training	to	persons	individually	or	belonging	to	both	private	and/or	public	organizaDons	to	

increase	awareness	and	improve	safety	for	current	and	future	UAS	operaDons	within	the	

NAS.	

As	described	fully	below,	the	requested	exempDon	would	permit	the	operaDon	of	designated	

UAS	as	set	forth	in	this	document	under	controlled	condiDons	in	the	NAS	that	would	be	a)	

limited	b)	controlled	c)	predetermined	and	d)	safe.	Approval	of	this	exempDon	would	increase	

public	awareness	of	UAS	operaDons	and	enhance	safety	to	aid	in	fulfilling	the	Secretary	of	

TransportaDon’s	(the	FAA	Administrator’s)	responsibiliDes	to	“....establish	requirements	

for	the	safe	operaDon	of	such	aircraY	systems	in	the	naDonal	airspace	system.”	

I	plan	to	operate	a	UAS,	the	Turbo	Ace	Matrix	which	is	comprised	of	an	unmanned	aircraY	and	a	transportable	ground	

staDon.	The	Turbo	Ace	Matrix	is	referred	to	as	a	quad-copter	with	a	maximum	gross	weight	of	about	8	pounds.	It	is	

equipped	with	four	rotors	that	are	driven	by	electric	motors	powered	by	baaeries.	The	UA	has	a	maximum	airspeed	of	

40mph.

Also,	given	the	small	size	of	the	UAS’s	involved	and	the	restricted	controlled	environment	within	

which	they	will	operate,	the	applicant	fits	within	that	zone	of	safety	(an	equivalent	level	of	safety)	
in	which	Congress	envisioned	that	the	FAA	must,	by	exempDon,	allow	commercial	operaDons	of	

UASs	to	commence	immediately.	Also	due	to	the	size	of	the	UASs	and	the	controlled	areas	in	

which	the	relevant	UASs	will	operate,	approval	of	the	applicaDon	presents	no	naDonal	security	

issue.	Given	the	following,	the	grant	of	the	requested	exempDons	is	clearly	in	the	public	interest:	

Brian	Dellis	proposes	that	the	exempDon	requested	herein	apply	to	civil	aircraY	that	have	the	

characterisDcs	and	that	operate	with	the	limitaDons	listed	herein.	These	limitaDons	provide	for	an	

excepDonal	level	of	safety	to	operaDons.	These	limitaDons	and	condiDons	to	which	Brian	Dellis	

agrees	to	be	bound	when	conducDng	commercial	operaDons	under	an	FAA	issued	exempDon	

including:	

1.	The	UAS	will	weigh	less	than	55	lbs.	

2.	Flights	will	be	operated	within	line	of	sight	of	operator.	

3.	Maximum	total	flight	Dme	for	each	operaDonal	flight	will	be	30	minutes.	

4.	Flights	will	be	terminated	at	15%	baaery	power	reserve.	

4.	Flights	will	be	operated	at	an	alDtude	of	no	more	than	400	feet	AGL	

5.	UAS	operator	will	be	trained	and	cerDfied	in	the	proper	safety	and	operaDons	of	the	UAS.	

6.	The	UAS	will	only	operate	within	a	controlled	area	as	defined	in	the	Procedures.	

7.	The	operator	will	post	advisor	noDce	around	the	controlled	area.	

8.	The	operator	will	have	been	trained	in	operaDon	of	UAS	generally	and	received	up-to-date	

informaDon	on	the	parDcular	UAS	to	be	operated	as	required.	

9.	If	the	UAS	loses	communicaDons	or	loses	its	GPS	signal,	the	UAS	will	have	capability	to	

return	to	a	pre-determined	locaDon	within	the	Security	Perimeter	and	land.	

10.	The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles	or	

emergencies.	

Accordingly,	the	applicant	respecfully	requests	that	the	FAA	grant	the	requested	exempDon	and	

are	prepared	to	modify	or	amend	any	part	of	this	request	to	saDsfy	the	need	for	an	equivalent	

level	of	safety.		I	look	forward	to	working	with	your	office.	Please	contact	me	at	any	Dme	if	

addiDonal	informaDon	or	clarificaDons	are	needed.	

Sincerely,	

Brian	Dellis