Sept 19, 2015

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave,

SE Washington, DC 2059

Richard O. Oexmann is a FAA licensed ATP, MultiEngine, Commercial SEL, RotorcraftHelicopter Pilot Certificate # 1645002

Florida Real Estate Licensed Agent # SL3320779

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

2012

Dear Sir or Madam:

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

and 14 C.F.R. Part 11,

Richard O. Oexmann, operator of Small Unmanned Aircraft Systems (sUAS) equipped to 

conduct aerial photography for Real Estate advertising and other photography and 

videography for civil business purposes in controlled areas, 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 Federal Aviation 

Administration (FAA) as required by § 333. As described more fully below , the 

requested exemption would permit the operation of small, unmanned and relatively 

inexpensive multirotor aircraft under controlled conditions in airspace that is 1) contained 

2) predetermined 3) has on site safety personnel controlling access, and 4) would

provide increased safety and enhancements to clients' business operations. The specific 

sUAS is the DJI Phantom 2 Vision Quad Copter Rotorcraft weighing less than 55 pounds 

including onboard factory mounted DJI camera. It operates at a speed less than 50 knots 

and has the capability to move in the vertical and horizontal plane simultaneously. The 

DJI Phantom 2 Vision has an auto return to launch point when battery power is under 

25% and/or the signal is lost between the rotorcraft and the controller.

The name and address of the applicant is:

Richard O. Oexmann ATP Multi Engine, Commercial SEL, Rotorcraft-Helicopter 

Pilot, certificate # 1645002

Florida Realtor license # SL3320779

Address: 18 Cedarford Ct., Palm Coast, Florida 32137

Richard O. Oexmann phone: 210-413-7717

Email: roexmann7@hotmail.com
I, Richard O. Oexmann respectfully requests a grant of an exemption of the following 

sections of Title 14 of the code of Federal Regulations: 14 CFR 21; 14 CFR 91, et seq.; 

14 CFR 45.23(b); Re: Exemption Request Pursuant To Section 333 of the FAA Reform 

Act of 2012.

14 CFR 61.113 (a) & (b);

14 CFR 407 (a) (1);

14 CFR 409 (a) (2);

14 CFR 417 (a) & (b).

I, Richard O. Oexmann also respectfully requests an Exemption from Section 333 of the 

FAA Reform Act and Part 11 of the Federal Aviation Regulations from:

14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9(b)(2); 

91.103(b); • 91.109; 91.119; • 91.121 ; 91.151(a); 91.203 (a) & (b); 91.405 (a);

• 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b).

The Extent of Relief Richard O. Oexmann Seeks and the Reason It Seeks Such Relief:

Richard O. Oexmann submits this application in accordance with the Reform Act, 112 

P.L. 95 §§ 331334, seeking relief from any currently applicable federal aviation 

regulations FARs pertaining to UASs (unmanned aircraft systems) and operating to 

prevent Richard O. Oexmann contemplated commercial photography, videography and 

other flight operations within the U.S. national airspace system.

The Reform Act in §332 provides for such integration of civil UASs into our national 

airspace system as it is in the public's interest to do so. Richard O. Oexmann lightweight 

UASs meet the definition of "small unmanned aircraft" as set forth in §331 and combined 

with a sterling safety record in similar industries, Richard O. Oexmann light duty UASs 

are ideal recipients of exemption by the intent of the Reform Act Considerations for relief 

include a combination of sUAS’s physical characteristics, safety features, and safe 

practices identified in §333: • sUAS weight, • sUAS overall size, • sUAS speed over 

ground, • sUAS flight zone characteristics, Non operation near airports (civilian or 

military),Tightly controlled operation in populated areas. Specific consideration is 

outlined below.

Operation of the UAS by VLOS by 14 C.F.R. Pa r t 21, Subpart H: Airworthiness 

Certificates 14 C.F. R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, 

establishes the procedural requirements for the issuance of airworthiness certificates as 

required by FAR §91.203 (a) (1) . Given the size and limited operating area associated 

sUAS’s, an exemption from Part 21 Subpart H meets the requirements of an equivalent 

level of safety under Part 11 and §333 of the Reform Act. 1l1e Federal Aviation Act (49 

U.S.C.§44701 (f) and §333 of the Reform Act both authorize the FAA to exempt

aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and populated areas 

of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the 

UAS operated without an airworthiness certificate, in the restricted environment and 
under the conditions proposed will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed.

The sUAS to be operated by Richard O. Oexmann is less than 11 kg. with maximal 

payload consisting of remote sensing instrumentation, carries neither no persons, carries 

no explosive or flammable materials including combustible fuels, and operates 

exclusively within a secured area. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the pilot (PIC), whose role is 

designated to act as both the remote sensing controller and secondary monitor for safety

issues, and a technician, which assists in matters related to maintaining the sUAS and 

also monitors for safety concerns and liaisons to the onsite safety officials. These 

enhancements to current safety practices and regulations, which already apply to civil 

aircraft, provide a greater degree of safety to the public and property owners than 

conventional aircraft operations conducted with airworthiness certificates issued

under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria 

demonstrates that there is no intrinsic credible threat to national security posed by the 

UAS, due to its size, speed of operation, location of operation, lack of intrinsic explosive 

materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. §45.23 (b). Marking of the Aircraft The regulation requires: When marks 

include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to 

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches 

high, the words " limited; "restricted; "light sport” "experimental ; or "provisional”; as 

applicable. Even though the sUAS will have no airworthiness certificate, an exemption 

may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on 

which the word "Experimental" can be placed. Given the size of the sUAS, two inch

lettering will be impossible. The word "Experimental" will be placed on the frame in 

compliance with §45.29 (f) at a size suitable for the available space. The equivalent level 

of safety will be provided by having the sUAS marked on its fuselage as required by

§45.29 (f) where the pilot, observer and others working with the sUAV will see the

identification of the UAS as "Experimental." The FAA has issued the following 

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

Further markings include the use of flashing green LED illumination on the underside of 

the sUAS frame which stands at contrast against a blue or white sky.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

14 C.F.R. §61.11 3 (a) & (b): Private Pilot Privileges and Limitations: Pilot in

Command. §61.113 (a) & (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 a 

ground crew member to have a private pilot's license rather than a commercial pilot's 
license to operate this sUAS. Unlike a conventional aircraft that carries the pilot and 

passengers, the sUAS is remotely controlled with no persons on board. The area of

operation is controlled and restricted, and all flights are planned and coordinated in 

advance. The risks associated with the operation of the sUAS are so diminished

from the level of risk associated with commercial operations contemplated by Part 61 

when drafted, that allowing operations as requested with a private pilot in the ground 

crew exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person 

may operate a civil aircraft unless it is in airworthy condition. As there will be no 

airworthiness certificate issued for the aircraft, should this exemption be granted, no

FAA regulatory standard will exist for determining airworthiness. Given the size of the 

aircraft and the requirements contained in the Manual for maintenance and use of safety

check lists prior to each flight, a subset of which are provided in enclosed Supplemental 

material, an equivalent level of safety will be provided. 14 C.F.R. §91.9 (b) (2): Civil 

Aircraft Flight Manual in the Aircraft. §91.9 (b) (2) provides: No person may operate a 

U.S. registered civil aircraft ... (2) for which an Airplane or Rotorcraft Flight Manual is 

not required by §21.5 of this chapter, unless there is available in the aircraft a

current approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. The sUAS, given its size and 

configuration has no ability to carry a physical flight manual on the aircraft. The 

equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the sUAS will have immediate access to it. The FAA

has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737,

8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700. 14 C.F.R. 

§91.103: Preflight action. This regulation requires each PIC to take certain actions

before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will 

not be provided for the aircraft an exemption will be needed. The PIC will take all actions 

including reviewing weather, flight battery requirements, landing and takeoff distances 

and aircraft performance data before initiation of flight. Further, we have manuals 

created with the help of sUAS experts, the manufacturer of the sUAS, to ensure best safe 

practices are adhered to. 14 C.P.R. §91.109: Flight instruction §91.103 provides that no 

person may operate a civil aircraft (except a manned free balloon) that is being used for 

flight instruction unless that aircraft has fully functioning dual controls. sUASs and 

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight 

control is accomplished through the use of a control box that communicates with the 

aircraft via radio communications. The FAA has approved exemptions for flight training 

without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of 

safety is provided by the fact that neither a pilot nor passengers will be carried in the 

aircraft and by the size and speed of the aircraft. Enhancing this safety is the technology

inherent in the remote controls utilizing digital communications which is paired to the 

sUAS making it nearly impossible to unintentionally or intentionally have the control 

communications interrupted.
14 C.F.R. §91.119: Minimum safe altitudes §91.119 establishes safe altitudes for 

operation of civil aircraft. §91.119 (d) allows helicopters to be operated at less than the 

minimums prescribed, provided the person operating the helicopter complies with any

route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS 

that closely mimics the behavior of a helicopter, and the exemption requests authority to 

operate at altitudes up to 400 AGL, an exemption may be needed to allow such 

operations. As set forth herein, the UAS will never operate at higher than 400 AGL or 

beyond unaided visual line of sight, whichever is closer. It will however be operated in a 

restricted area with security officials tasked with ensuring public safety, and where 

buildings and people will not be exposed to operations without their pre obtained consent 

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

of the UAS as well as the location where it is operated. No flight operation will be taken 

without the permission of the property owner in the case of private property or local 

officials In the case of public property or private property with public interests. Because 

of the advance notice to the property owner and participants in the remote sensing 

activity, all affected individuals will be aware of the planned flight operations. Compared 

to flight operations with aircraft or rotorcraft weighting far more than the maximum 11kg 

of Richard O. Oexmann sUASs proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with

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

operations of the sUAS will ensure separation between these small UAS operations and 

the operations of conventional aircraft that must comply with §91.119. 14 C.F.R. §91.121 

Altimeter settings §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 the sUAS may not 

have a barometric altimeter, but instead a GPS altitude read out. An equivalent level of

safety will be achieved by the operator, confirming the altitude of the launch site shown 

on the GPS altitude indicator before flight. The operator will also ensure effective pairing 

with multiple GPS sources to guarantee accurate detection of height. 14 C.F.R. §91.15l 

(a): Fuel Requirements for Flight in VFR Conditions §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; or (2) At night, to fly after that for at least 45 minutes: The battery

powering the sUAS provides approximately 25 minutes of powered flight in hover mode 

without payload. Richard O. Oexmann sUAS will not be able to meet the 30 minute 

reserve requirement in 14 CFR §9 1.151. Operating the small UAS, in a tightly controlled 

area where only people and property owners or official representatives who have signed 

waivers will be allowed , with less than 30 minutes of reserve power , does not engender 

the type of risks that Section 9l.l51(a) was intended to alleviate give n the size and

speed of the small UAS. Richard O. Oexmann believes that an equivalent level of safety

can be achieved by limiting flights to 15 minutes or 50% of battery power whichever

happens first. This restriction would be more than adequate to return the sUAS to it’s 
planned landing zone from anywhere in its limited operating area. Similar exemptions 

have been granted to other operation s, including Exemptions 2689F, 5745, 10673, and

1080.

14 C.F.R. §91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration the 

regulation provides in pertinent part:

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it

has within it the following: (1) An appropriate and current airworthiness certificate . ..

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under

§91. 715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or

crew. The sUAS fully loaded weighs no more than ll kg and is operated without an 

onboard pilot. As such, there is no ability or place to carry certification and registration 

documents or to display them on the sUAS . An equivalent level of safety will be 

achieved by keeping these documents at the ground control point where the pilot flying 

the sUAS will have immediate access to them, to the extent they are applicable to the 

sUAS. The FAA has issued numerous exemptions to this regulation. A representative 

sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 

9797A, 9816A, and 10700. 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 section and Part 43 

apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. Maintenance will be accomplished by the operator and recorded in a log book. 

An equivalent level of safety will be achieved because these small UASs are very limited 

in size and will carry a small payload and operate only in restricted areas for limited 

periods of time. If mechanical issues arise the UAS can land immediately and will be 

operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log of 

any maintenance performed. Moreover, the operator is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety.

An exemption granted to Richard O. Oexmann would permit its operation of lightweight, 

unmanned, remotely controlled, sUASs in a tightly controlled environment with limited 

airspace. Richard O. Oexmann utilizes local business' safety officers in specifically

determined areas (designed flight zone) to mitigate injury and property damage while 

fulfilling clients' goals. Technical enhancements to current safety controls will allow 

Richard O. Oexmann to operate exceeding current safety specifications, and stay ahead 

of, or meet, new ones being implemented by the FAA and Department of Transportation. 

Further, Richard O. Oexmann conducts its operations in compliance with protocols 

described here in or as otherwise established by the FAA.
II. Commercial and Public Benefits;

I Richard O. Oexmann believe that granting this exemption request furthers the 

public interest by providing safe (by way of an unmanned system) and efficient 

means to Richard O. Oexmann’s customer base are typically small to medium 

sized business' looking to increase their awareness of respective properties. 

Aerial videography and photography for real estate marketing has been around 

for a long time through manned fixed wing aircraft and helicopters, but for

small business owners and homeowners its expense has been cost prohibitive.

Granting this exemption to the petitioner would allow him to provide this 

service at a much lower cost. Further, the petitioner indicates his small

UAS will pose no threat to the public given its small size and lack of 

combustible fuel when compared to larger manned aircraft. The petitioner also 

states that the operation of his UAS will minimize ecological damage and 

promote economic growth by providing information to small businesses and 

individuals looking to relocate or build in the Palm Coast, St. Augustine, 

Daytona Beach, and Northeast Florida area.

By photographic or videography. By moving these functions onto sUAS based aircraft, 

the potential for loss of life or property is diminished due to the greater control in a 

smaller and safer aircraft that holds no persons. Second, there are no reactive or 

combustible materials on board the sUAS and thus the potential for fire or explosions is 

greatly diminished. Third, the small size and extreme maneuverability Richard O. 

Oexmann’s UASs allow the PIC to avoid hazards. Accordingly, Richard O. Oexmann’s

UASs have operated and will continue to operate at and above current safety levels.

A. The costs and benefits of your proposed action to society in general and specific 

groups within society. As described above, Richard O. Oexmann’s past customers have 

been small to medium business seeking Aerial videography for geographical awareness 

and for real estate marketing has been around for a long time through manned fixed wing 

aircraft and helicopters. For small budget real estate companies and average homeowners 

the expense of such aerial videography is cost prohibitive. Only large companies and high 

end Realtors or luxury homeowners can afford to absorb such expense. Depriving non

luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned 

aircraft pose a threat to the public through potential catastrophic rash that the various 

communities have experienced in the past with military aircraft and medical helicopter 

crashes within even cities. Each resulting in loss of life, each with combustible fuel that 

exploded and burned on impact.

My, Richard O. Oexmann's, sUAS pose no such threat since size and lack of combustible 

fuel alleviates any potential threat to the public. Congress has already proclaimed that it 

is in the public’s interest to integrate commercially flown UAS's into the national 

airspace system, hence the passing of the Reform Act. Granting my, Richard O. 
Oexmann’s, exemption request furthers the public interest through academic/visual 

awareness of the geographical benefits in and around the NE Florida area. My ultra light 

weight sUAS is battery powered and creates no emissions that can harm the environment. 

The consequence of my ultra light weight sUAS crashing is far less than a full size 

helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can 

cause catastrophic devastation to the public. Utilizing sUASs minimizes the requirement 

for conventional aircraft. This eliminates the need for an on board pilot, time consuming 

adherence to regulations surrounding bookkeeping and submission of flight paths to local 

civilian or military airports, and detrimental effects to the environment caused by

operating a combustible fuel based, large scale aircraft, with restrictions on the proximity

to the target for remote sensing.

Flight Capabilities and Characteristics of Richard O. Oexmann s UASs Pursuant to 112 

P.L. 95 §333 (a), concerns for public safety are mitigated by the overall capabilities and

characteristics of the sUAS. Richard O. Oexmann UAS s utilizes four (4) rotating 9 inch 

plastic propellers paired oppositely to each other for balance, control and stability. The 

total span of the sUAS is less than 1.2 m allowing for stable flight or landing even with 

the sudden onset of detrimental environmental conditions. Richard O. Oexmann sUAS 

is designed to primarily hover in place to capture photographic data and then operate at 

less than a 35 knot maximum speed to the next point of interest. They are capable of 

vertical and horizontal operations but, in practice, is operated only within VLOS by the 

PIC. In addition the PIC, Richard O. Oexmann is a licensed ATP Multi Engine 

Commercial SEL, Rotorcraft-Helicopter rated Pilot with a current medical and with 

current flight hours having an impeccable safety record.

The flight zone will restricted to operators and safety observers to minimize pedestrian 

access in the flight zone of the client's grounds. In the event of loss of visual of the UAS, 

the PIC can change flight controls from cartesian (X,Y,Z) based controls to radial (r,a,h) 

based controls which allows the PIC to utilize one controller axis to recall the UAS to the 

PIC's position without concern to the current heading of the sUAS. In the event of loss of 

sight of the sUAS into an area containing hazards or possible hazards, the spotter has a 

heads up display containing a live video feed which can be used to locate the UAS while 

it maintains it's position in hover mode. The sUAS has demonstrated it's ability to 

maintain it's position by GPS coordinates in hover mode in 25 kts or greater wind gusts at 

rvr less than 25 feet representing an extreme environmental condition beyond the range

of conditions within the scope for sUAS operation.

All of Richard O. Oexmann’s sUASs utilize LiPo (lithium polymer) battery based power 

sources, decreasing safety risks from more easily combustible, fuel based, power sources. 

Flight times generally last between eight (8) to ten (10) minutes allowing the staff to 

work with small flight areas per phase. The maximum flight time without payload is 25 

minutes, however practical safe operation limits this to 10 to give ample time to control 

the sUAS to a safe landing zone. Richard O. Oexmann further restricts flight time by not 

operating it’s sUASs with less than twenty five percent battery capacity. Further safety
management systems in place include a GPS mode that allows Richard O. Oexmann’s 

sUAS to hover in place if communication with the PIC is lost and optionally follow a set 

of waypoints at a set speed and height to a 'home base' predesignated safe

landing zone. In the event of unforeseen motor(s) failure, the system will enter into a 

controlled descent while allowing full use of all UAS flight controls by the PIC. All 

commands sent via remote controller received during a controlled descent are

translated to an 'as meant' paradigm meaning the flight control package will use it's real 

time 3 dimensional position and compensate rotors control the sUAS regardless of spin 

velocity. This assures that if one system is compensated a safe and successful landing can

still occur.

IV. Reasons Why an Exemption to Richard O. Oexmann Will Not Adversely 

Affect Safety Standards

Richard O. Oexmann contends that operation of it's sUASs will not "create a hazard to 

users of the national airspace system or the public:' as stated in 112 P.L. 95 §333 (b). 

Given the diminutive size and weight of Richard O. Oexmann’s sUASs, combined with 

their operation in cordoned off and well controlled areas, Richard O. Oexmann’s sUASs 

falls within Congress's contemplated safety zone.

Richard O. Oexmann’s sUASs have an established safety record bolstered by multipoint

Preflight check list, awareness of their surroundings and intimate knowledge of the 

behavior of the sUAS platform in many weather conditions. This safety record and 

implemented operational practices demonstrate an awareness of public safety. Richard O. 

Oexmann’s operations routinely provide a level of safety at least equal to existing rules, 

and in nearly every instance, exceeds existing rules.

Richard O. Oexmann does not operate its UASs on or near airports and generally has

only operated on private grounds with cordoned off areas or areas under the control of 

the property owner I client. Richard O. Oexmann determines the areas needed to fulfill 

the clients' goals and only operates its UASs in these flight zones and only

in compliance with well regarded safety protocols set forth initially by the RC UAS trade 

and hobby groups and recently codified by relevant FARs.

Richard O. Oexmann’s standardized on the following practices to ensure safe operation 

of it's UASs:

• Work with onsite personnel to plan the flight goals, 

• Work with onsite personnel to restrict access to non essential persons, 

• Operation by unaided VLOS operation only,

● Operation in phases 10 minutes in length

● Operation to minimal 25% battery power

● Operation of device to GPS aided readout to 390 ft at maximum, Numerous

pre programmed fail safes that ensure specific behavior per issue

● Preform a site check day(s) before flight to identify potential issues, Subscribe to 

relevant local weather and safety alerts,

● Expertly choose data collection instruments and accessories to minimize flight

requirements or expertise,
● Richard O. Oexmann has experience in similar fields and has adapted this experience 

in it's use of UASs to increase safety. In combination to the ever expanding knowledge

from hobbyists and experts alike, Richard O. Oexmann is constantly evolving it's 

practices when there is a clear benefit to operations or increased safety element.

A. Summary

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:

Richard O. Oexmann (applicant) seeks an exemption from the following rules: 14 C.P.R. 

§21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. §§61.113( a) & (b); 91.7 (a); 91.9 (b) (2); 

91.103{b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) 

(1); 91.4 09 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small 

unmanned vehicle (11 kg or less) in elevated photographic and remote sensing 

operations. Approval of exemptions allowing commercial operation s of sUASs in the 

the media industry will enhance safety by reducing risk associated with conventional 

aircraft operations and other means of elevated remote sensing involving persons. The 

public benefit served by approval of this petition is increased awareness of characteristics 

of difficult imaging targets. A sUAS weighing fewer than 11 kg and powered by sealed 

batteries eliminates virtually all associated risk inherent in operating conventional aircraft 

in close proximity to buildings or persons or otherwise elevating persons to a position 

they would be able to collect needed data. The operation of small UASs, weighing less 

than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent 

level of safety supporting the grant of the exemptions requested herein, including 

exempting the applicant from the requirements of Part 21 and allowing commercial 

operations.

As identified and described herein, Richard O. Oexmann is an experienced licensed ATP

Multi Engine, Commercial SEL, Rotorcraft-Helicopter rated Pilot certificate #1645002 

for over 50 years presently living in Florida; Also experienced in flying Unmanned 

Aircraft Systems (U.A.S) for recreational purposes. Recognized by the community as a 

professional realtor experienced in the various photographic industries. Mr. Oexmann 

has a spotless safety record with over 17,000 flight hours of which over 15,000 were 

NBAA Safety Award. 800 of those hours were in U.S. Army helicopters including a 

combat zone (Viet Nam), and as a BellSouth Corporate Aviation Falcon 900EX Captain 

was one of the first to be certified to fly into and out of KDCA after 9/11 as a Corporate 

Aircraft Captain for BellSouth.

The FAA has been given the authority to issue the exemption to Richard O. Oexmann

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek 

your consideration and approval of this petition.
VI. Emergency Procedures • Loss of Remote Signal

The flight package features an optional enhanced failsafe which returns the

UAS to the home base waypoint via the same path taken to point of lost signal.

The UAS will then perform a hover over this waypoint and then a controlled landing. 

• Loss of GPS signal

The system will operate in GPS assisted mode with three (3) satellites. At loss of three 

(3) GPS satellites, manual mode can be activated or the flight package can be

programmed to perform a controlled landing to the home base waypoint. Ground

based height ranging is performed by a separate system and so loss of GPS will not 

impact controlled landing in a safe manner. 

• Loss of Engine Power

In the event of one (1) (or to two oppositely positioned) rotor or motor failure the

system will enter into controlled spin where all controls are translated based on current

orientation and will behave as normal operation to the PIC to ensure a safe landing,

In the event of multiple rotor or motor failures the flight package can be

configured to perform a safe landing or attempt operation to home base waypoint. 

Note: Behavior of the landing location is highly dependent on the position and number of

rotors/motors that are affected.

• Loss of Ground Control Software 

This will not affect operation of the flight. The unit will be piloted to a safe landing area 

and then landed so that examination of the link can be made.

DJI Phantom Info:

http://www.dji.com/product/phantom2vision/spec

Phantom 2 Vision User Manual (EN) v1.8

Phantom 2 Vision Pilot Training Guide (EN) v1.1

Smart Flight Battery Safety Guidelines (EN, FR, DE and JP)

Phantom 2 Vision Quick Start Guide (EN)

http://download.dji-innovations.com/downloads/nazam-v2/en/NAZAM_Quick_Start_Guide_v1.26_

en.pdf