RC Control Setting

Captain Ron's Drone Flying Service

601 Alans Way

Forked River, NJ.

08731

ronstrac@gmail.com

 June 15, 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

Dear Sir or Madam,

I, Ronald Strac., owner of Captain Ron's Drone Flying Service, 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 , Captain Ron's Drone Flying Service a drone business specializing in Aerial

photography for Real Estate, data collection, demonstration flights, videography and movie

production, agriculture, and flight training be exempted from the Federal Aviation Regulations

(“FARs”) listed below so that we may operate a small ultra-lightweight unmanned aircraft system

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

As described herein, Ronald Strac, is a retired United Airlines B777 captain and a FAA licensed

Airline Transport Pilot with over 28,000 hours of flight experience. He has type ratings in the

Boeing 777, Boeing 767, Boeing 757, Boeing 737, Airbus A300, DC9-30 and Citation Jet .

Ronald Strac is currently a contract consultant for the FAA, working closely on UAS

traffic simulation projects at the FAA Technical Center at Atlantic City Airport.

Captain Ron's Drone Flying Service , will be operating a DJI Inspire 1 and a Phantom 3 and

Phantom 2 Vision+ "V1.0" Quadcopter with FPV HD Video Camera with intent to operate them

for commercial aerial photography / videography following exemption and approval by the FAA.

Ronald Strac is an FAA licensed Airline Transport Pilot. Ronald Strac will be chief pilot at

Captain Ron's Drone Flying Service for the proposed use of the sUAS.

Exemption request would permit operation of ultra-light weight, unmanned (piloted by remote

control) and comparatively inexpensive sUAS(s) in tightly controlled and limited airspace

photographing or videoing within property boundaries for individual property owners with their

permission as well as the professional realtor’s permission.

I, Ronald Strac, owner of CRDFS, will detail in this petition the specific regulations for which we

seek relief, offering alternate and equivalent ways of providing a level of safety at least equal to

the existing rules. This petition focuses on public safety and public benefit.

Appendix A – Captain Ron’s Drone Flying Service Operating Procedures
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Captain Ron's Drone Flying Service, Forked River, NJ. 08731 - Section 333 Exemption Petition

I. Contact Information:

Ronald Strac

Captain Ron's Drone Flying Service

601 Alans Way

Forked River, NJ 08731

Phone: 609-839-4100

Email: ronstrac@gmail.com

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

Captain Ron's Drone Flying Service Requests Exemption are:

14 C.F.R. Part 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);

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)

III. The Extent of relief Captain Ron's Drone Flying Service seeks and the Reason He

Seeks Such Relief:

I, Ronald Strac, 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 Captain Ron's

Drone Flying Service ’ contemplated commercial use of an sUAS for photographic and

videographic use 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. Captain Ron's Drone Flying Service ’ ultra- lightweight sUAS

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

integration of my ultra-lightweight sUAS is expressly contemplated by the Reform Act. I would

like to operate my ultra lightweight sUAS 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 & 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

line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for

Captain Ron's Drone Flying Service . My sUAS utilizes four (4) counter- rotating propellers for

balance, control and stability. My sUAS is equipped with GPS and auto return safety technology.

Weighing less than five (5) pounds (far below the maximum 55 pound limit); including camera

with gimbal. I, Ronald Strac , consider safety the utmost importance with every flight. My small

unmanned aircraft is designed to hover in place via GPS and operate in less than a 16 knot (17

mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 12 knot

(13 mph). Built in safety systems include a GPS mode that allows my sUAS to hover in

place when radio controls are released. When pilot communication is lost, the sUAS is designed

to slowly descend to the point of take-off. Captain Ron's Drone Flying Service will not operate
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Captain Ron's Drone Flying Service, Forked River NJ, USA - Section 333 Exemption Petition

sUAS near airports, Hospitals nor Police heliports, and will not operate near areas where

general public is within thirty to one hundred (30-100) yards depending on location, conditions

and weather. We utilize a crew of two (2), a pilot (“PIC”), and a

spotter who are 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 the area of operation. Our sUAS is capable of vertical and horizontal

operations, and is flown only within line of sight of the PIC. Utilizing battery power rather than

combustible fuels, flights generally last between ten (10) to fifteen (15) minutes, with an altitude

under two hundred (200) feet. Captain Ron's Drone Flying Service will utilize a fresh fully

charged battery with each flight as a safety precaution; full flight time limit for each battery is

twenty (20) to twenty-five (25) minutes as tested. Captain Ron's Drone Flying Service will not

operate sUAS at or below the manufacturer recommend minimum charge levels for operation;

preferring to remain well within a safe operating range to insure adequate communication

between radio control and sUAS to eliminate potential for crash, loss of control or hazards.

Reserve batteries are at hand with each mission to insure replacement for sufficient safe level of

operation. We do not believe in taking risks that may cause a crash, which could create hazards

to the public / property / manned aircraft, and we have no desire to lose our investment. The

crew will always include an FAA licensed and current pilot. The crew at Captain Ron's Drone

Flying Service have done scores of practice flights in remote areas on private property as

hobbyists simulating flights for future commercial use to gain familiarization with the

characteristics of this specific sUAS’s performance under different temperature and weather

conditions.

Captain Ron's Drone Flying Service chief pilot will be Ronald Strac , an FAA licensed Airline

Transport Pilot with over 28,000 hours of flight experience. He has type ratings in the Boeing

777, Boeing 767, Boeing 757, Boeing 737, Airbus A300, DC9-30 and Citation Jet. He is

extremely cautious when operating our sUAS / 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 sUAS it falls well within Congress’s contemplated safety

zone when it promulgated the Reform Act and the corresponding directive to integrate sUASs

into the national airspace system. My DJI Inspire 1 and Phantom 3 and Phantom 2 sUAS, used

in hobby flight, has a demonstrated safety record and does not pose any threat to the general

public.

IV. How Captain Ron's Drone Flying Service Request Will Benefit the Public As A Whole:

Captain Ron's Drone Flying Service is a small business serving realtors and news outlets in

South-East Pennsylvania and Central New Jersey. Aerial photography has been around for a

long time through manned fixed wing aircraft and helicopters and some of these missions can

be replaced with more cost effective, safer, and more environmentally friendly sUAS missions.

In addition, for many small budget productions the expense of such aerial photography and

videography using manned aircraft is cost prohibitive. We operate in a very competitive

environment, competing with large nationwide photography and videography suppliers. We are

able to compete on quality and service. The advent of sUAS’s used in this business

environment, and their ability to produce unique images will not only help our small business
compete with larger businesses, but also provide our realtor customers with their own new

business value, thus promoting commerce and economic development. Permitting Captain

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Captain Ron's Drone Flying Service, Forked River NJ, USA - Section 333 Exemption Petition

Ron's Drone Flying Service to immediately fly within national air space furthers economic

growth in our South-East Pennsylvania and Central New Jersey area, and provides a definite

benefit to the Realtors and news outlets looking to use aerial photography and videography,

both of which increase commerce and serve as a benefit and stimulus to the area economy and

community.

V. Reasons Why Captain Ron's Drone Flying Service ’ Exemption Will Not Adversely

Affect Safety or How The Exemption Will Provide a Level of Safety At Least Equal To

Existing Rule:

Captain Ron's Drone Flying Service has the utmost respect for everyone’s safety and comfort.

Our chief pilot, Ronald Strac , has a Airline Transport Pilot License and is currently a contract

consultant for the FAA, working closely on UAS traffic simulation projects at the FAA Technical

Center at Atlantic City Airport. He has a solid understanding of the National Airspace System,

and a reputation and track record of conservative decisions concerning safety. As it concerns to

sUAS operations:

Our sUAS DJI Inspire 1 and Phantom 3 (DJI Phantom 2 Vision+ "V1.0" Quadcopter with FPV

HD Video Camera) weighs less than 5 pounds;

. Each mission will consist of a crew of 2: one PIC and one spotter;

. At least one of the crew is an FAA licensed pilot with a current medical certificate or drivers

license.

. The PIC will have a minimum of 50 logged flights and 20 total hours in the make and model of

the operating sUAS, including at least 3 flights in the last 90 days;

. We only operate our sUAS below 200 feet in day VFR conditions (well within the 400 foot

permissible ceiling set by the FAA Modernization and Reform Act of 2012);

. We will not operate the sUAS in Class A, B, C, or D airspace without written approval from the

FAA;

. We will not operate within 3 nautical 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 will be

made available to the Administrator upon request;
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Captain Ron's Drone Flying Service, Forked River NJ, USA - Section 333 Exemption Petition

· During operation of the sUAS, signs will be posted warning the public that: “Caution: Small

Unmanned Aircraft Operation in Progress”;

· If any unauthorized person moves within 200 feet of the operating sUAS, the mission will be

aborted immediately;

· Our sUAS only operates for five (5) to ten (10) minutes per flight, severely limiting the

exposure of any safety concerns towards the public or property;

· We pilot our sUAS through remote control only by visual line of sight, keeping the sUAS within

500 feet of the operator at all times;

· Our sUAS has GPS controlled failsafe, a flight safety feature whereby it hovers and then

slowly lands if communication with the remote control pilot is lost;

· We actively record and analyze flight data and other sources of information to constantly

update and enhance safety protocols;

· Before each flight we assess the environment and we only proceed to operate in reasonably

safe environments that are controlled, are away from power lines, elevated lights, airports and

actively populated areas;

· We conduct extensive pre-flight inspections and protocol, during which safety carries primary

importance;

· We always obtain all necessary permissions prior to operation; and we have procedures in

place to abort flights in the event of safety breaches or potential danger.

VI. 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 Captain Ron's Drone Flying Service sUAS permits

exemption from Part 21 because our 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
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Captain Ron's Drone Flying Service, Forked River NJ, USA - Section 333 Exemption Petition

and proximity to areas such as airports and dense populations. Captain Ron's Drone Flying

Service ' 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 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, 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 our sUAS utilizes

electronic global positioning systems with a barometric sensor, and altitude information will be

provided to the pilot via a digitally encoded telemetric datalink to a realtime display.

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

Captain Ron's Drone Flying Service.

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 sUASs 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. Elevated Images will mark the sUAS 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 the PIC, or anyone assisting the PIC as a spotter 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. Pursuant to 14 C.F.R. §§

61.113 (a) & (b), private pilots are limited to non-commercial operations. Elevated Images can

achieve an equivalent level of safety as achieved by current Regulations. The PIC will have a

Commercial Pilot certificate with a current Medical, and will meet the flight review requirements

specified in 14 CFR § 61.56.

D. 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. Our sUAS will never operate

at an altitude greater than 200 feet AGL, only in safe areas away from the public and traffic.

Given the small size and weight of the sUAS, its maneuverability and speed profile, we can

achieve an equivalent level of safety.
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Captain Ron's Drone Flying Service, Forked River NJ, USA - Section 333 Exemption Petition

E. 14 CFR § 91.151(a) requires a thirty (30) minute fuel reserve for flight in VFR conditions.

Since maximum flight time is limited to battery capacity, and is less than 30 minutes for our

sUAS, we will operate our sUAS for no longer than ten (10) to fifteen (15) minutes on a full

charge. A full charge would allow for a flight time of at least twenty (20) minutes, providing a

25% to 50% safety margin. The FAA has previously issued exemptions for manned aircraft to

operate at less than the minimums prescribed in 14 CFR § 91.151(a), including Exemption Nos.

2689, 5745, and 10650. In addition, similar UAS-specific relief has been granted in Exemption

Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) conditions.

F. 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. . . .”

To comply with this regulation, the PIC, before each mission, will check the manufacturers’

internet service pages, and ensure applicable software and hardware is up to date as required,

and ensure compliance with any safety bulletins posted. In addition, the Operators Manual as

provided by the sUAS manufacturer will be revised to include specific operating procedures and

limitations to comply with the exemptions sought as described in section V (see appendix A).

The revised Operators Manual will be in possession of the crew during operation of the sUAS,

and must be made available to the Administrator or any law enforcement official upon request.

Captain Ron's Drone Flying Service NJ, USA - Section 333 Exemption Petition

In summary, Captain Ron's Drone Flying Service 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); and, 14 C.F.R. § 91.417(a) & (b) to commercially

operate Captain Ron's Drone Flying Service ’ small unmanned vehicle/lightweight unmanned

aircraft vehicle in community awareness and aerial photography and videography operations.

Captain Ron's Drone Flying Service will utilize safety protocols and the implementation of a

flight operations manual that exceeds currently accepted means and methods for safe flight.

Captain Ron's Drone Flying Service will conduct formal collection of information of its operation

of the sUAS, which will be shared with the FAA, and will contribute to the enhancement of the

FAA's internal efforts to establish protocols for complying with the FAA Modernization and

Reform Act of 2012. Captain Ron's Drone Flying Service ’ operation of the sUAS, weighing less

than 5 pounds and travelling at low speeds within limited controlled areas will provide an

equivalent level of safety as that achieved under current FARs. Accordingly Captain Ron's

Drone Flying Service respectfully requests that the FAA grant our exemption request.
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Captain Ron's Drone Flying Service, Forked River NJ, USA - Section 333 Exemption Petition

Respectfully submitted,

Captain Ron Strac Owner

Captain Ron's Drone Flying Service

601 Alans Way

Forked River NJ. 08731

Phone: 609-839-4100
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Captain Ron's Drone Flying Service, Forked River NJ, USA - Section 333 Exemption Petition

Appendix A – Captain Ron’s Drone Flying Service 

Operating Procedures 

Safety	is	our	main	concern.	Owner	and	crew	will	operate	all	aircraft	with	strict	

adherence	to	the	manufacturers	operation	manual	and	limitations	and must	be	

familiar	with,	and	follow	these	operating	procedures:

1)	 Owner	must:

a.	Document	all	maintenance,	alterations,	and	updates	in	the	aircraft	

records.	

b.	Any	maintenance	or	alterations	that	affect	the	sUAS	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.	

2)	 Prior	to	each	mission:

The	PIC	must	familiarize	him/herself	with	all	possible	safety	aspects	of	the	

mission.		This	includes	but	is	not	limited	to:

Software	versions	required	(manufacturers	web	site)

Weather

Wind	(less	than	12	knots)

NOTAMS

Proximity	of	airports	or	SUA

3)	Prior	to	each	flight:

the	PIC	must	inspect	the	sUAS	and	Ground	Station	to	ensure	they	are	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	
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Captain Ron's Drone Flying Service, Forked River NJ, USA - Section 333 Exemption Petition

necessary	maintenance	has	been	performed	and	the	UAS	is	found	to	be	in	a	

condition	for	safe	flight.	This	includes	but	is	not	limited	to:	

i. Batteries	(full	sUAS	battery	required	for	each	flight,	check	battery	levels	for	

transmitter	and	range	extender)	

ii. Inspect	propellers,	motors,	wings	and	lights	

iii. The	documents	required	under	14	CFR	§91.9	and	§91.203	must	be	available	

to	the	PIC	at	the	Ground	Control	Station	of	the	sUAS	any	time	the	aircraft	is	

operating.	These	documents	must	be	made	available	to	the	Administrator	

or	any	law	enforcement	official	upon	request.	

The	PIC	performs	a	safety	assessment.	This	includes	but	is	not	limited	to:	

If	operating	within	3	miles	of	an	uncontrolled	airport,	check	that	a	letter	of	

agreement	that	covers	the	current	mission	with	the	airport	manager	is	

available	to	the	PIC,	and	that	the	operation	is	conducted	under	a	current	

NOTAM.	

Inspect	flight	area	for	light	poles,	trees,	utility	wires,	proximity	to	helipads,	

hospitals,	schools,	busy	roadways,	gatherings	of	people,	SUA.	

The	PIC	provides	a	safety	briefing	to	the	spotter.	An	agreement	is	made	

under	which	conditions	the	flight	must	be	aborted.	

Check	placement	of	warning	signs:	“Caution:	Small	Unmanned	Aircraft	

Operation	in	Progress”	
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Captain Ron's Drone Flying Service, Forked River NJ, USA - Section 333 Exemption Petition

Identify	take	off	and	landing	area.	

The	PIC	performs	pre-flight	checks:

i. Check	all	controls	neutral	

ii. Turn	on	Power	transmitter	first,	then	on	sUAS,	and	Range	

Extender	

iii. Perform	GPS	alignment	according	to	manufacturers	operating	

manual

iv. 	If	alignment	successful,	flight	can	start	from	a	safe	take-off	

point	

v. Immediately	after	takeoff	perform	the	following	checks:	

a.		Hover	5-10	feet	

b.		Check	data	link	

C.		Check	video	link	

d.		Check	altimeter	

e.		Check	GPS

	f.		Check	time	

4,	 During	each	flight:

a. The	sUAS	may	not	be	operated	by	the	PIC	from	any	moving	device	or	

vehicle.
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Captain Ron's Drone Flying Service, Forked River NJ, USA - Section 333 Exemption Petition

b. The	sUAS	may	not	be	operated	at	an	altitude	exceeding	200	feet	

AGL.

c. The	sUAS	may	not	be	operated	at	night	or	at	altitude	less	than	

500	feet	below	or	less	than	2,000	feet	horizontally	from	a	cloud	

or	when	visibility	is	less	than	3	statute	miles.

d. The	sUAS	must	remain	clear	and	yield	the	right	of	way	to	all	

other	manned	operations	and	activities	at	all	times	(including,	

but	not	limited	to,	ultralight	vehicles,	parachute	activities,	

parasailing	activities,	hang	gliders,	etc.).	

e. Flight	time	is	limited	to	maximum	fifteen	(15)	minutes.	

f. sUAS	must	remain	within	line	of	sight	and	within	500	feet	of	PIC.	

5)	 Emergency	during	flight.	This	could	include	but	is	not	limited	to:	

i. Pilot	distracted	

ii. Spotter	signals	abort	

iii. Sudden	change	in	weather	or	wind	

iv. Manned	aircraft	in	the	vicinity	

v. People	getting	within	safety	perimeter	
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Captain Ron's Drone Flying Service, Forked River NJ, USA - Section 333 Exemption Petition

vi. Birds	

Immediately:	

																			b.	Determine	closest	safe	landing	location	to	sUAS

																			c.	Land	

6)	After	each	flight:	

a. Check	and	log	flight	time	and	remaining	battery	level.	

b. Turn	off	power	to	sUAS	first,	then	turn	off	power	to	transmitter	and	

range	extender	

c. Inspect	sUAS	for	any	damage	

d. Remove	warning	signs