May 18, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor Room W12­140

Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of

2012

Dear Sir or Madam:

I am writing pursuant to the FAA Modernization and Reform Act of 2012 ( the "Reform Act")

and the procedures contained in 14 C.F.R. 11, to request that Electric Head, LLC, owned and

operated by Allen M. Gottfried and as owners and operators of small unmanned aircraft

be exempted from the Federal Aviation Regulations ("FARs") listed below so that Electric Head,

LLC may operate its small unmanned aircraft/lightweight unmanned aircraft systems )"UAS")

commercially in airspace regulated by the Federal Aviation Administration ("FAA").

Primary uses will be low altitude aerial photography for use on websites, print pieces and HD

aerial videography for promotional and client use in a variety of productions but not limited to

Real Estate, Music Videos, Commercials, Independent Films, Construction, and more.

Allen Gottfried has operated and without incident a variety of UAS on many occasions for

non­commercial purposes. The UAS utilizes battery power, not combustible fuels. Flight time ranges

between five and twenty minutes depending on battery used. The UAS has GPS functionality to hover

in place as well as a return to home function in case of loss of contact with the radio. The firmware

and controller software will disable the UAS from taking off and also limit the UAS system from

operating within specific GPS preset no­fly zones.

Electric Head, LLC exemption request would permit its operation of lightweight, unmanned (piloted by

remote control) and comparatively inexpensive UASs in tightly controlled and limited airspace.

Electric Head, LLC will conduct its operations in compliance with the protocols described herein or as

otherwise established by the FAA.

For the reasons stated below, Electric Head, LLC respectfully request the grant of an exemption

allowing it to operate lightweight, remote controlled UASs.
1. Contact Information:

Allen M. Gottfried

15 Olivia Way

Jackson, NJ 08527

Tel: 732­903­4418

email:

Allengot@gmail.com

2. The Specific Sections of Title 14 of the Code of Federal Regulations from Which We Request

Exemption is:

14CFR 21:

14 C.F.R. 45.23 (b):

14 CFR 61m113 (a) & (b):

14 C.F.R. 91, et seq.:

14 CFR 407 (a) (1): 14

CFR 409 (a) (2):

14 CFR 417 (a) & (b). U.S

Dep't of Trans.

3. The Extent of Relief Electric Head, LLC Seeks and the Reason It Seeks Such

Relief:

Electric Head, LLC submits this application in accordance with the Reform Act, 112 P.L.

95§§ 331­334, seeking relief from any currently applicable FARs operating in cinematic,

research 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. Our lightweight UAS meets

the definition of "small unmanned aircraft" as defined in Section 331 and therefore the

integration of our lightweight UAS is expressly contemplated by the Reform Act. We

would like to operate our lightweight UAS prior to the time period by which the Reform Act requires

the FAA to promulgate rules governing such craft.

The Reform Act guides the Secretary in determining the types of UASs that may operate

Safely in our national airspace system. Considerations include:

• The weight, size, speed and overall capabilities of the UAS:

• Whether the UAS will be operated near airports or populated areas: and,

• Whether the UAS will be operated by line of sight.

112 P.L. 95 § 333 (a). Each of these items militates in favor of an exemption for Electric Head,

LLC.
Our UAS utilizes four counter­rotating propellers for extreme balance, control and stability. It

weighs less than 5 pounds, including battery and all equipment. This small unmanned aircraft

is designed to primarily hover in place and operate at less than a 50 knot maximum speed. It is

capable of vertical and horizontal operation but operate only within the line of sight of the

remote control pilot.

Utilizing battery power, flights generally last between five and twenty minutes. We do not operate the

UAS with less than twenty five percent battery capacity.

Safety systems in place include a GPS mode that allows the UAS to hover in place or return to takeoff

location if communication with the radio control pilot is lost. We generally do not operate the UAS near

airports or near populated areas unless contracted and cleared and authorized by such business. To

date, we have only operated the UAS in a non­commercial manner. Additionally, Electric Head, LLC

carries a $1­Million General Liability Insurance policy if in the unlikely case where any unforeseen

accidents should occur.

Our operation of this small unmanned aircraft 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 the

UAS, combined with its operation in designated and well­controlled fly zones, which falls within

Congress's contemplated safety zone when it promulgated the Reform Act and the

corresponding directive to integrate UASs into the national airspace system. Indeed, our UAS

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

The FAA has the authority to issue the exemption sought by Electric Head, LLC pursuant to

the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

4. How this Request Will Benefit the Public As A Whole:

Granting this exemption request furthers the public interest. Congress has already pronounced

that it is in the public's interest to integrate commercially flown UASs into the national airspace

system, hence the passing of the Reform Act. Electric Head, LLC conduct research into safe UAS

operations every time it flies its UAS. Flight data, visual inspections, recorded observations and flight

analyses are compiled to further enhance current safety protocols. Allowing us to log more flight time

directly relates to our research and our ability to further enhance current safety measures.

Our UAS is battery powered and creates no emissions. If our UAS crashes there is no fuel to ignite

and explode. The impact of our lightweight UAS is negligible when compared to

a full size aircraft.

Granting this request will also allow small business owners, independent filmmakers and

homeowners to be able to afford high quality aerial images and video that they would otherwise

have no access to due to several factors, cost being the biggest.
5. Reasons Why Electric Head, LLC Exemption Will Not Adversely Affect Safety

• Our UAS weighs less than 5 pounds complete with all mounted equipment and

battery:

• We only operate our UAS below 400 feet:

• Our UAS only operates for 5­20 minutes per flight:

• We land our UAS when it reaches 25% battery power:

• Our remote control pilot operates the UAS by line of sight:

• Our remote control pilot has video backup and GPS override should sight of the

UAS be lost.

Additional Notes:

The potential loss of life is diminished as no people on board.

There is no fuel on board a UAS and thus the potential for fire or explosions is greatly

diminished.

The small size and extreme maneuverability of our UAS allows our remote control pilot to

avoid hazards.

6. Summary:

A. 14 C.F.R. 21 and 14 C>F>R> 91: Airworthiness certificates and Manuals.

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 Electric Head, LLC UAS permits exemption

from Part 21 because Electric Head, LLC

UAS meets an equivalent level of safety pursuant to Section333 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 UASs from the airworthiness certificate requirement in

consideration of the weight, size speed, maneuverability and proximity to areas such as

airports and dense populations. Electric Head, LLC 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 UASs, this Regulation is inapplicable. An equivalent level of

safety will be achieved by maintaining a manual at the flight operations center. The FAA has

previously issued

exemptions to their regulation in Exemption Nos 8607, 8737, 8738, 9299, 9299A, 9565, 9565B,

10167, 10167A, 10602, 10700 and 32827.

14C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as Electric Head, LLC

utilizes

electronic global positioning systems and internal gyroscopes to provide spatial

coordination.

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 such certifications and registrations at Electric Head,

LLC flight operations center.

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. Electric Head, LLC UAS is, by definition, unmanned. It therefore does not have a

cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two­inch lettering is

difficult to place on such small aircraft. Regardless, Electric Head, LLC will mark its UAS 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 pilot, technician, spotter and others working with the UAS 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 non­commercial operations. Electric Head, LLC can

achieve an equivalent level of safety as achieved by current regulations because Electric Head,

LLC UAS does not carry any pilots or passengers. Furthermore, while helpful, a pilot license will

not ensure remote control piloting skills. The risks attendant to the operation of Electric Head, LLC

UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R.§ 61,

et seq. Thus, allowing Electric Head, LLC to operate its UAS

with a private pilot as the pilot in control will 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. Electric Head, LLC will never

operate at an altitude greater than 400 AGL. Electric Head, LLC will, however, operate its UAS in

cordoned off areas with security perimeters, providing a level of safety at least equivalent to those in
relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of Electric

Head, LLC UAS, an equivalent level of safety will be achieved.

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

The above cited Regulations require, amongst other things, aircraft owners and operators to

"have aircraft inspected as prescribed in subpart E of this part and shall between required

inspection, except as provided in paragraph © of this section, have discrepancies repaired as

prescribed in part 43 of this chapter...."

These Regulations only apply to aircraft with an airworthiness certificate. Therefore, they will

not apply to Electric Head, LLC should its requested exemption be granted. Electric Head, LLC

conducts as extensive maintenance program that involves regular software updates and curative

measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

F. Summary

Electric Head, LLC 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; 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 its lightweight unmanned aircraft in motion picture or photography operations and to

conduct its own research. Granting Electric Head, LLC request for exemption will reduce current

risk levels and thereby enhance safety. Currently motion picture image capture relies primarily on

the use of larger aircraft running combustible fuel. Electric Head, LLC aircraft does not contain

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

picture aircraft. Electric Head, LLC operates at lower altitudes and in controlled airspace. Electric

Head, LLC has been analyzing flight data and other information in compiling novel safety protocols

and the implementation of a flight operations manual that exceeds currently accepted means and

methods of safe flight. There are no people on board Electric Head, LLC UAS and therefore the

likelihood of death or serious bodily injury is significantly limited. Electric Head, LLC operation of

its UAS, weighing less than 5 pounds and travelling at speeds lower than 50 knots in cordoned off

areas will provide at least an equivalent level of safety as that achieved under current FARs.

Accordingly, Electric Head, LLC respectfully requests that the FAA grant its exemption request

without delay. The FAA has the authority to issue the exemption sought by Electric Head, LLC

pursuant to the Federal Aviation Act, 85 P.L. 726(1958), as amended (the "Act").

In closing, Electric Head, LLC would like to state that it would be very easy to ignore the FAA

and operate a UAS commercially without applying for any consideration from them. We have

seen and spoken with several people who are already doing so. We hope the simple fact that

someone such as ourselves who operate a very small business and will be operating a UAS on

a very small scale is applying for this exemption shows how serious we are about safety and

doing things properly. Thank you for your time and consideration.
Respectfully submitted,

Allen M. Gottfried

Owner, Electric Head, LLC

www.electricheadonline.com