Matthew G Norris

313 Rowley Street, Agawam, MA 01001

(413)786-2599

MGNorrisPhotos@gmail.com

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 CFR 61.113 (a) & (b) 14 CFR 91.9 (b) (2) 14 C.F.R. 

91.103 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.405 (a) 14 

CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and 14 C.F.R. Part 11, Matthew G Norris., operator of Small Unmanned Aircraft 

Systems (“sUASs”) equipped to conduct aerial photography and videography for the 

real estate, construction, and film industries, hereby applies for an exemption from the 

listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its 

sUASs, so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333.1

Matthew G Norris request permission to use a small commercially-available quadcopter 

in the course of aerial real estate photography, 

construction-site-progress-documentation, and land survey applications, as well as 

exploring the possibility of closed-set motion picture asset generation.

Current aerial video and photography projects require the hire of full size aircraft at a 

considerably higher level of risk and cost. The equipment we will be using weighs less 

than 10lbs and has various safety systems and overrides that in the event of loss of 

signal, guarantee that the aircraft return to the point of launch and safely land. Also, the 

equipment weighs considerably less than traditional aircraft and crew.

My partner and I are members of the class of responsible hobbyist operators and 

well-understand the safety procedures and how important check lists and well 

maintained aircraft are for public safety. Our time spent flying UAS has always abided 

by all FAA regulations and the pilots we hire will all be licensed, well-trained fliers with a 

history of responsible operation. We intend the business that your authorization will 

make possible to transition into a national brand, and as such take the requirements of 

conducting it in accordance with the most stringent safety and regulatory adherences to 

be of the utmost importance. In short, we are responsible, details-oriented people and 

risk-avoiders intent on building a lasting business with full regulatory compliance as a 

major selling-point.

The equipment we are using is maintained to the highest standards. We perofrm 

preflight checks on batteries, airframe, motors and all equipment associated with the 

aircraft. We limit my flights to below 400 feet AGL and within line of sight. Our UAS is 

equipped with an auto pilot system in the event of loss of signal or loss of sight. The 

UAS is also equipped with an FPV camera that can be used in the event there is an 
emergency situation or disorientation. Your timely consideration of this application is 

most appreciated.

Sincerely Matt Norris

Regulations from which the exemption is requested: 14 CFR 61.113 (a) & (b) 14 CFR 

91.9 (b) (2) 14 C.F.R. 91.103 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 

CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

sUASs operated by Matthew G Norris weigh less than 15 pounds, including the payload 

(i.e. camera, lens, and gimbal). They operate at speeds of no more than 35 knots, can 

hover, and can simultaneously move vertically and horizontally. Matthew G Norris will 

only operate its sUASs in line of sight and will operate only within the secure area 

described in the FOPM. Such operations will insure that the sUAS will “not create a 

hazard to users of the national airspace system or the public.”

The small size of UASs and the restricted secure environment within which they will 

operate, Matthew G Norris UAS operations adhere to the Reform Act’s safety 

requirements. Additionally, due to the size of the UASs, permission from relevant 

property owners or other applicable parties, and the limited areas in which they will 

operate, approval of this application presents no national security issues.

Based on the substantial level of safety surrounding the proposed operations, and the 

significant public benefit (enhanced safety), reduction in environmental impacts, the 

grant of the requested exemption is in the public interest. Accordingly, Matthew G Norris 

respectfully requests that the FAA grant the requested exemption.

Aircraft And Equivalent Level Of Safety

The operating limitations proposed by Matthew G Norris provide for at least an 

equivalent or higher level of safety because operations further enhance safety of aerial 

image collection using conventional aircraft.

The limitations and conditions include:

• The sUASs will weigh less than 10 pounds (the relevant DJI Inspire-1 clocks in at 

under 7).

• Flights will be operated within line of sight of a pilot and/or observer.

• Maximum flight time for each operational flight will be no more than 22 minutes. Flights 

will be terminated at no less than 30% battery power reserve should that occur prior to 

the 22 minute limit.

• Flights will be operated at an altitude below 400 feet AGL, and not more than 200 feet 
above an elevated platform from which filming is planned.

• Minimum crew for each operation will consist of the sUAS Pilot (with a minimum of a 

Sport pilot license) and the Visual Observer.

• A sUAS pilot will be Pilot in Command (PIC).

• The sUAS will only operate within a confined secure area as defined in the FOPM. 

Page 2 of 6

• A briefing will be conducted for planned sUAS operations prior to each day’s flight. All 

personnel performing duties within the boundaries of the safety perimeter are required 

to attend.

• The operator will obtain consent of all persons involved in the filming and ensure that 

only consenting persons will be allowed within 500 feet of the flight operation.

• The Pilot and observer must be trained in sUAS operations and have received current 

information on the particular sUAS to be operated, prior to the day of filming.

• The Observer and pilot will be able to communicate in both directions at all times 

during each flight.

• Written and/or oral permission from the relevant property holders will be obtained prior 

to flight operations.

• If the sUAS loses communications or loses its GPS signal, the sUAS will have the 

capability to return to the point of launch using the RTL safety future of the flight 

controller

14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations:

Pilot in Command Sections 61.113 (a) and (b) limit private pilots to non-commercial 

operations. Because the sUAS will not carry a pilot or passengers, the proposed 

operations can achieve the equivalent level of safety of current operations by requiring 

the PIC operating the aircraft to have a private pilot’s license rather than a commercial 

pilot’s license to operate a sUAS. Unlike a conventional manned aircraft, a sUAS is 

remotely controlled by a ground-based operator. The operational area is controlled and 

restricted, and all flights are planned and coordinated in advance. The level of safety 

exceeds that provided by a single individual holding a commercial pilot’s certificate 

operating a conventional aircraft. The risks associated with the use of a sUAS are so 

diminished from the level of risk associated with commercial operations contemplated 

by Part 61 allowing sUAS use by a sport pilot as the PIC exceeds the present level of 

safety sought by 14 C.F.R. §61.113 (a) and (b).

14 C.F.R. § 91.103:
Preflight Action Section 91.103 requires each pilot to preflight an aircraft before flight 

Page 3 of 6 to insure the safety of flight. As FAA approved rotorcraft flight manuals will 

not be used, an exemption is requested. However, an equivalent level of safety will be 

provided. The PIC will take all actions, including reviewing weather, flight battery 

requirements, landing and takeoff distances, and aircraft performance data before 

commencement of flight.

14 C.F.R. §91.119(c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 

provides, in pertinent part, that: “except when necessary for takeoff or landing, no 

person may operate an aircraft below the following altitudes: .....

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.”

Because Matthew G Norris requests authority to operate at altitudes no higher than 400 

AGL, and not more than 200 above an elevated platform from which filming is planned, 

an exemption is needed to allow such operations. Except for the limited conditions 

stated in the FOPM, the sUAS will never operate higher than 400 AGL. It will, however, 

be operated in a restricted area within a security perimeter, where buildings and people 

will not be exposed to operations without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, and speed of the 

sUAS as well as the location where it is operated. No flight will be taken without the 

permission of property owners or local officials. Because of the advance notice to the 

property owners and participants in the filming activity, all affected individuals will be 

informed of the planned flight operations. Compared to flight operations for conventional 

aircraft, any risk associated with the proposed sUAS operations is far less than 

conventional aircraft operating at or below 500 AGL. In addition, the low-altitude 

operations and light weight of the DJI Inspire-1 will ensure separation between a sUAS 

and conventional aircraft.

14 C.F.R. §91.121: Altimeter Settings

Section 91.121 requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As a sUAS may not have a 

barometric altimeter, but instead a GPS altitude data, an exemption is needed.

An equivalent level of safety will be achieved by the operator, pursuant to the FOPM 

and Safety Check list, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight.
14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions

Page 4 of 6 Section 91.151(a) prohibits an individual from beginning “a flight in an 

airplane under VFR conditions unless (considering wind and forecast weather 

conditions) there is enough fuel to fly to the first point of intended landing, and, 

assuming normal cruising speed – (1) During the day, to fly after that for at least 30 

minutes . . . .” The typical battery powering the Matthew G Norris sUASs provides less 

than 22 minutes of powered flight. To meet the 30-minute reserve requirement in 14 

CFR §91.151, sUAS flight would not be possible. Given the limitations on the sUAS’s 

proposed flight area and its proposed operations within a predetermined location, a 

longer time frame for flight in daylight VFR conditions is reasonable. Furthermore, 

operating the sUASs in a tightly controlled area where only people, property owners, or 

official representatives who have signed waivers will be allowed, less than 30 minutes of 

reserve fuel does not engender the type of risk that §91.151(a) was intended to 

address.

I believe that safety can be achieved by limiting flights to 15 minutes or 30% of battery 

power, whichever occurs first. This restriction would be more than adequate to return 

the sUAS to the point of launch from anywhere in its limited operating area.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner shall “have that 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...,” and others shall inspect or maintain the aircraft 

in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft 

with an airworthiness certificate, these sections will not apply to Matthew G Norris 

operations.

Maintenance will be accomplished by the operator. An equivalent level of safety will be 

achieved because the DJI Inspire-1 are limited in size, will carry a small payload and 

operate only in restricted areas for limited periods of time. If mechanical issues arise, 

the sUAS can land immediately and will be operating from no higher than 400 feet AGL. 

As provided in the FOPM, the operator will ensure that the sUAS is in working order 

prior to flight, perform any required maintenance, and keep a log of any maintenance 

performed. Moreover, the operator is the person most familiar with the sUAS and best 

suited to maintain it in an airworthy condition.

Summary for Publication Pursuant to 14 C.F.R. Part 11,

The following summary is provided for publication in the Federal Register, should it be 

determined that publication is needed: Matthew G Norris seeks an exemption from the 

following rules:

14 C.F.R. §§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 
91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) to operate Page 5 of 6 commercially a 

small unmanned vehicle (55 pounds or less) in commercial image acquisition 

operations.

As established by the sUAS exemptions already granted by the FAA, allowing 

commercial operations of sUASs in agriculture, real estate, inspection, S & R, and film 

industries will enhance safety by reducing risk. Conventional survey, agricultural, 

mapping, inspection, and film operations, using turbine aircraft, operate at low altitudes 

and present the risks associated with aircraft that weigh around 4,000 pounds, and 

which carry large amounts of Jet A fuel. Such aircraft must also fly to and from the 

target location. In contrast, a sUAS weighing fewer than 55 pounds and powered by 

batteries eliminates virtually all of that risk given the small size and lack of combustible 

fuel. The sUAS is carried, and not flown, to target site. The DJI Inspire-1 sUAS carries 

no passengers or crew and, therefore, will not expose them to the risks associated with 

manned flights.

The operation of sUASs conducted in the strict conditions outlined in the FOPM will 

provide an equivalent level of safety supporting the grant of the exemption requested 

herein. The sUASs operate at slow speeds, close to the ground, and in a secure 

environment. As a result, they are far safer than conventional operations conducted with 

turbine helicopters flying near the ground and people.

Privacy

All flights will occur over private or controlled access areas with the property owner’s 

prior consent and knowledge. Recognizable images will only be recorded of people who 

have given their consent or otherwise have agreed to be in the area where active image 

acquisition will take place.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security) provide more than adequate 

justification to grant Matthew G Norris requested exemption, allowing for Matthew G 

Norris sUAS commercial operations for the listed industries pursuant to the included 

FOPM.

I can be reached at (413)786-2599 or MGNorrisPhotos@gmail.com if further information 

is needed. Thank you.