U.S. Department of Transportation

Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
AXT. INC Evan Numeroff 17 Sassi Dr. Croton on Hudson NY 10520 917

– 592

– 2672 evannumeroff@gmail.com RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Federal Aviation Administration, Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012, I Evan Numeroff, operator of a light we ight Unmanned Aircraft System (“UAS”) seek an exemption from the Federal Aviation Regulations (“FARs”) to allow for commercial operation for aerial and video imaging of real estate properties using the DJI Phantom 2 quad

- copter in accordance with FAA UAS Regulations & Policies. **Regulations from which the exemption is requested:** 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 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)(1) and (2), 14 C.F.R. 91.417(a) and (b).

**14 C.F.R. Part 21: Airworthiness Certificates** Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, I re quest exception. In the restricted environment and under the conditions proposed operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without said restrictions. **14 C.F.R. 45.23(b): Display of marks**  The UAS has no cabin, cockpit, pilot station, fuselage, boom, or tail on which to mark certain words or phrases. The two inch lettering is problematic to place on such a small aircraft with dimensions smaller than the minimal lettering requiremen t. **14 C.F.R. 91.7(a): Civil aircraft airworthiness** As there will be no airworthiness certificate for the UAS in question, this regulation is irrelevant. **14 C.F.R. 91.9(b)(2): Civil aircraft flight manual ̈ marking ̈ and placard requirements**  Given the size a nd configuration, the UAS has no ability to carry a flight manual on the aircraft. The same level of safety will be achieved by keeping the flight manual with the pilot on the ground level.**14 C.F.R. 91.119(c): Minimum safe altitudes**

Evan Numeroff agrees that the UAS will not operate higher than 400 feet at ground level, and won’t be flown over highly populated areas

. **14 C.F.R. 91.121: Altimeter settings** The UAS has live telemetry with a GPS altitude read out. Also included in the tel emetry is UAS battery power, speed, distance, and available satellite lock (incase UAS needs to return home autonomously .) An equivalent level of safety is achieved by the operator receiving live flight data displayed on a monitor. **14 C.F.R 91.405(a): Maintenance Required**  **14 C.F.R 91.407 (a)**  **(1) :**  **Operation after maintenance, preventive maintenance, rebuilding, or alteration**  **14 C.F.R 91.409(a)(1) and (2): Inspections & 14 C.F.R 91.417(a) and (b): Maintenance records**  Given these sections only apply to aircraft with an airworthiness certificate, these sections do not apply to this applicant. Safety inspections will take place pre

- flight as well as post

- flight to ensure the UAS is in proper working order. **Summary I, Evan Numeroff a**  **m seeking exemption**  **from the following FARs:**  14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 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)(1) and (2), 14 C.F.R. 91.417(a) and (b). With exemption of the rules mentioned, I , Evan Numeroff, will be able to successfully begin my business in aerial photography and videography with emphasis in the real estate field. By of

fering these services to the public using small UAS ’s instead of full sized helicopters and aircraft, a great er level or safety as well as positive environmental impact will be achieved. **Safety** Additionally: 1. UA S will never be operated within 5 miles of an airport unless prior arrangements have been made with air traffic control management 2. UA S will always be controlled within visual line of sight at all times 3. Proper visual inspection of UAS will be done before and after flights 4. Follow all local laws and ordinances before flying over private property 5. UA S will always fly below 400 feet 6. Land UAS within manufacturer recommended minimum level of battery power 7. Always check and analyze flight telemetry data to make in formed decisions 8. Always have a set failsafe plan ready prior to each flight incase or UA S failure

**Public Interest**The use of UAS ’s in real estate will provide the public with a more affordable , faster,

and efficient way to capture aerial photography and videography. Manned aircraft can weight upwards of 5,000 lbs and carry 100s of gallons of fuel . They are also very expensive to maintain and create extreme emissions and noise. Light weight UAS’s such as the Phanto m 2 by DJI have no on board p ilot or crew members, create zero emissions, and are extremely silent giving them a huge advantage in the field

. Sincerely,

Evan Numeroff President

- AXT INC.