November 23, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor Room W12-140

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 I, Jeffrey Hackl, as owner and

operator of a small unmanned aircraft be exempted from the Federal Aviation Regulations ("FARs")

listed below so that I may operate my small unmanned aircraft/lightweight unmanned aircraft

systems ("UAS") consisting of the Parrot Bebop series drones (Bebop & Bebop 2) and DJI Phantom 

series drones (Phantom 1, Phantom 2 Vision & Vision+, Phantom 3 Standard, Professional, & 

Advanced) 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, Construction, and more.

I have operated and without incident a variety of UAS on many occasions for non-commercial

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 no-fly zones.

My exemption request would permit my operation of lightweight, unmanned (piloted by remote control)

and comparatively inexpensive UASs in tightly controlled and limited airspace.

I will conduct my operations in compliance with the protocols described herein or as otherwise

established by the FAA.

I currently have a Private Pilot Certificate and Instrument Rating.

For the reasons stated below, I respectfully request the grant of an exemption allowing me to

operate lightweight, remote controlled UASs.
1. Contact Information:

Jeffrey Hackl

2757 S Memorial Dr

Green Bay, WI 54313

Tel: 920-609-4420

email: jnh62@yahoo.com

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

Exemption is:

14 C.F.R. 21:

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

14 C.F.R. 61m113 (a) & (b):

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

14 C.F.R. 407 (a) (1):

14 C.F.R. 409 (a) (2):

14 C.F.R. 417 (a) & (b).

U.S Dep't of Trans.

3. The Extent of Relief Jeffrey Hackl Seeks and the Reason He Seeks Such Relief:

I, Jeffrey Hackl submit this application in accordance with the Reform Act, 112 P.L. 95§§ 331-334,

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. My lightweight UAS meets the definition of "small unmanned aircraft" as defined in

Section 331 and therefore the integration of my lightweight UAS is expressly contemplated by the

Reform Act. I would like to operate my 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 Jeffrey Hackl.

The UAS utilizes four counter-rotating 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 will be operated only within the

line of sight of the remote control pilot.

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

UAS with less than twenty 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 is lost. I do not operate the UAS near airports

or near populated areas unless contracted and cleared and authorized for such business. To date, I

have only operated the UAS in a non-commercial manner.

The operation of my 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 well-controlled 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, my UAS 

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

The FAA has the authority to issue the exemption sought by me 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. I will conduct research into safe UAS operations every time I

flies my UAS. Flight data, visual inspections, recorded observations and flight analyses are compiled

to further enhance current safety protocols. Allowing me to log more flight time directly relates to my

research and my ability to further enhance current safety measures.

My UAS is battery powered and creates no emissions. If my UAS crashes there is no fuel to ignite 

and explode. The impact of my lightweight UAS is negligible when compared to a full size aircraft.

Granting this request will also allow small business owners, 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 Jeffrey Hackl’s Exemption Will Not Adversely Affect Safety

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

battery:

•I will only operate my UAS below 200 feet for commercial purpose:

• My UAS only operates for 5-20 minutes per flight:

•I land my UAS when it reaches 20% battery power:

•I operate the UAS by line of sight:

• My remote control 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 my UAS allows me to avoid hazards.
6. Make and model of UAS:

Parrot Bebop

Parrot Bebop 2

DJI Phantom 1

DJI Phantom 2 Vision

DJI Phantom 2 Vision+

DJI Phantom 3 Standard

DJI Phantom 3 Advanced

DJI Phantom 3 Professional

7. 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 my UAS permits exemption from Part 21

because I meet 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. My 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 the UAS 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 my 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. My 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, two-inch lettering is difficult

to place on such small aircraft. Regardless, I will mark my UAS in the largest possible lettering by

placing the identification number (N-number) 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.
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 can achieve an

equivalent level of safety as achieved by current regulations because my 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 my UAS is far less than the risk levels

inherent in the commercial activities outlined in 14 C.F.R.§ 61, et seq. Thus, allowing me to

operate my 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. I will never operate at an altitude greater than 200

AGL for commercial purposes. I will, however, operate his 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 my 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 (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. Therefore, they will not apply to me should his requested exemption

be granted. I conduct an 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

Jeffrey Hackl 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

his lightweight unmanned aircraft, Parrot Bebop series drones (Bebop & Bebop 2) and DJI 

Phantom series drones (Phantom 1, Phantom 2 Vision & Vision+, Phantom 3 Standard, 

Professional, & Advanced). Granting Jeffrey Hackl’s request for exemption will reduce current risk

levels and thereby enhance safety. Currently picture image capture relies primarily on the use of

larger aircraft running combustible fuel. Jeffrey Hackl’s UAS does not contain potentially explosive

fuel, is smaller, lighter and more maneuverable than conventional aircraft. The UAS operates at

lower altitudes and in controlled airspace. Jeffrey Hackl possesses a Private Pilot Certificate and 

Instrument Rating. Jeffrey Hackl 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 the UAS and therefore

the likelihood of death or serious bodily injury is significantly limited. Jeffrey Hackl’s operation of his

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, Jeffrey Hackl respectfully requests that the FAA grant his exemption request 

without delay. The FAA has the authority to issue the exemption sought by Jeffrey Hackl

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

In closing, I would like to state that I hope the simple fact that someone such as myself who

operates a very small business and will be operating a UAS on a very small scale is applying

for this exemption shows how serious I am about safety and doing things properly. Thank you

for your time and consideration.

Respectfully submitted,

Jeffrey Hackl