### April 17, 2015

Exemption No. 11381 Regulatory Docket No. FAA

− 2015

− 0056

Mr. Gregory Zonsius ZonCom Productions, Inc.

15402 South Michael Drive Plainfield, IL 60544

Dear Mr. Zonsius:

This letter is to inform you that we have gran ted your request for exemption. It transmits our decision, explains its basis, and gives you th e conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated January 1, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of ZonCom Productions, Inc. for an exemption. The exemption would allow the petitioner to operate an unma nned aircraft system (UAS) to conduct aerial photography, videography, and cinematography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2 Vision +.

### 2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, a nd limited operating area associated with the aircraft and its operation, the S ecretary of Transportation has de termined that this aircraft meets the conditions of Section 333. Therefore, th e FAA finds that the re quested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates, and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial da ta collection. The FAA has issued grants of exemption in circumstances similar in all materi al respects to those pr esented in your petition. In Grants of Exemption N o. 11062 to Astraeus Aerial ( see Docket No. FAA

− 2014

− 0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA

− 2014

− 0382), and 11213 to Aeryon Lab, Inc. ( see Docket No.

FAA

− 2014

− 0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifica tions described by the petition er and carrying no passengers or crew, rather than a manned aircraft of signi ficantly greater proporti ons, carrying crew in addition to flammable fuel, gi ves the FAA good cause to find th at the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for re questing an exemption, I find that—

 They are similar in all material respects to relief previously re quested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situ ation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a gr ant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S. C. 106(f), 40113, and 44701, delegated to me by the Administrator, ZonCom Productions, Inc.is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a )(1), 91.409(a)(1) an d (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, ZonCom Productions, In c.is hereafter referred to as the operator.

### 3

Failure to comply with any of the conditions an d limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 Vision + when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will re quire a new petition or a peti tion to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restricti on. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PI C and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not perm itted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must en sure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepa ncy exists between the conditions and limitations in this exemption and the pro cedures outlined in the operating documents,

the conditions and limitations herein ta ke precedence and must be followed. Otherwise, the operator must follow the pr ocedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and pr esent updated and revised

### 4

documents to the Administrator or any la w enforcement official upon request. The operator must also present updated and revise d documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) may be contacted if questi ons arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or flight characteristics, e .g. replacement of a flight cr itical component, must undergo a functional test flight prio r to conducting further opera tions under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functi onal test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. Th e pre-flight inspection must account for all potential discrepancies, e .g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manu facturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exempti on must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pi lot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.

14. The operator may not permit any PIC to ope rate unless the PIC demonstrates the ability to safely operate the UAS in a ma nner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehi cles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

### 5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and e xperience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted dur ing dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditi ons (VMC). Flights under special visual flight rule s (SVFR) are not authorized.

16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facil ity Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the ai rport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the pr ivate or controlled-access property.

19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a f light unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that fo r at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Author ization (COA). All operations shall be conducted in accorda nce with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted unde r the terms of the attached COA.

22. All aircraft operated in accord ance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

### 6

23. Documents used by the operator to ensure th e safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These

documents must be made available to th e Administrator or any law enforcement official upon request.

24. The UA must remain clear and give wa y to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently pr otect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or struct ures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or es sential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/cont roller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Sa fety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for th e purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM)

as documented in this grant of exemption.

### 7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction ove r the area of proposed filming. The 3-day notification may be waived w ith the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person res ponsible for the on-s cene operation of the UAS;

d. Make, model, and serial or N

− Number of UAS to be used;

e. Name and certificate number of UAS PI Cs involved in the aerial filming;

f. A statement that the operator has obtain ed permission from property owners

and/or local officials to conduct the filming production event; the list of those who gave permission must be made av ailable to the inspector upon request;

g. Signature of exemption holde r or representative; and

h. A description of the flight activity, includi ng maps or diagrams of any area, city, town, county, and/or state over which film ing will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer th an 500 feet from pa rticipating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with al l applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

This exemption terminates on April 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards ServiceGregory Zonsius, Photographer / Videographer, Chicagoland , IL, USA

- Section 333 Exemption Petition

Gregory Zonsius, Photographer / Videographer, Chicagoland, IL USA

- Section 333 Exemption Petition Page 1 of 16 January 01, 2015

U . S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations

from 14 C.F.R. 45.23(b); 14 C.F.R. Par t 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

I, Gregory Zonsius , am writing pursuant to the FAA Modernization and Refo rm Act of 2012 and the procedures contained within 14 C.F.R

. 11, to request that I, Gregory Zonsius , an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Gregory Zonsius , may o perate my small ultra

- lightweigh t unmanned aircraft system (“ sUAS ”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein I, Gregory Zonsius , am a photographer / videographer / cinematographer ; experienced

i n flying hobby aircraft for recreational purposes. I have added a quad

- copter 1 sUAS to my inventory equipped with a self

- contained camera with intent for aerial photography / videography / cinematography ; following exemption and approval by the FAA

.

I hav e flown small RC electric helicopters for over three (3) years without incident. In addition I have flown multiple sUAS quadcopters for over a year without incident continually practicing to become proficient in the flight characteristics and dynamics of t heir operations. Committed to safety with each flight. My, Gregory

Zonsius ' , exemption request would permit operation of ultra

- light weight, unmanned (piloted by remote control) and comparatively inexpensive sUAS (s) in tightly controlled and limited airspa ce. 2 Predetermined in areas away from general public, airports, heliports and vehicular traffic for community videos, and within property boundaries for individual homeowner for aerial photography/videography

. Currently, similar lightweight, remote contro lled sUAS s are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. I, Gregory Zonsius , have personally instilled safety protocols and controls 3 to avoid and prevent public hazard, as well as ma nned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight sUAS 's specific to photography & videography usage as I, Gregory Zonsius , record flight data and other information gained through permitted flight operati ons to share with the FAA through any required FAA reports to assist with future protocol and safety regulation.

Granting my, Gregory Zonsius ’

, request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate sUAS s into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [ sUAS s] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of sUAS s for photography & videography purposes

. Further I, Gregory Zonsius , will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA. For the reasons stated below I, Gregory

Zonsius , respectfully request the grant of an exemption allowing me to operate ultra

- light weight, remote

controlled sUAS s for the purposes of acquiring aerial photos & videos, b oth of which will promote local economic growth throu gh increased employment and increased tax base. Both with p ublic safety in mind by keeping heavier manned aircraft containing combustible fuel that that poses potential public hazard.

1 Supplemental File

– Phantom 2 Vision Plus (User Manual 1.6) & Appendix A

2 Appendix B

– Aeronautical Charts

3 Appendix C

- Personal Protocols and ControlsGregory Zonsius, Photographer / Videographer, Chicagoland , IL, USA

- Section 333 Exemption Petition

Gregory Zonsius, Photographer / Videographer, Chicagoland, IL USA

- Section 333 Exemption Petition Page 2 of 16 I. Contact Information:

Gregory Zonsius

, ZonCom Productions, Inc.

15402 S. Michael Dr. Plainfield, IL 60544 Office: ( 815) 676

- 5 275 Mobile: ( 815 ) 676

- 5271

Email: greg@zonsius.com



### II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Gregory

Zonsius Requests Exemption are:

14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq. ; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).



### III. The Extent of relief Gregory Zonsius seeks and the Reason He Seeks Such Relief:

I, Gregory Zonsius , submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334,

s eeking relief from any currently applicable FARs operating to prevent me, Gregory Zonsius , contemplated commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integrat ion of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. My, Gregory Zonsius ’

, ultra

- lightweight sUAS meets
the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my

ultra

- lightweight sUAS is expressly contemplated by the Reform Act. I would like to operate my ultra

lightweight sUAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, pro viding direct experience and valuable information for formal regulation that can be administered uniformly to all related sUAS aerial photography & videography . The Reform Act guides the Secretary in determining the types of sUAS s that may operate safely i n our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the sUAS s; whether the
sUAS will be operated near airports or heavily populated areas; and, w hether the sUAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, Gregory

Zonsius . My sUAS utilizes four (4) counter

- rotating propellers for balance, control and stability. My sUAS is equipped with GPS and auto return safety technology. Weigh ing less than five (5) pounds (far below the maximum 55 pound limit); including camera with gimbal.

I, Gregory Zonsius , consider safety as u pmost import ance with e very flight. My small unmanned aircraft is designed to hover in place via GPS and op erate in less tha n a 16 knot (17 mph) wind. For safety, stability

and fear of financial loss I will not f ly in winds exceeding 14 knot (15 mph). Built in safety systems include a GPS mode that allows my sUAS to hover in place when radio controls are released. With three mo des to choose from, I utilize the GPS Mode 4 for aerial photography and videography . This is the safest, most reliable and stable mode to prevent accident s and hazard s . When pilot communication is lost , the sUAS is designed to s lowly descend to point of ta ke

- off. I do not operate my sUAS near airports, Hospitals nor Police

4 GPS Mode includes safe circle for operation, position hold, self

- leveling, al titude command, GPS, return home feature, and safety control to return home or land in the event of communication interruption between RC transmitter and sUAS . See Appendix A

- Operator Manual.Gregory Zonsius, Photographer / Videographer, Chicagoland , IL, USA

- Section 333 Exemption Petition

Gregory Zonsius, Photographer / Videographer, Chicagoland, IL USA

- Section 333 Exemption Petition Page 3 of 16 heliports, and do not operate near areas where general public is within thirty to one hundred ( 3 0

- 100) yards depending on location, conditions and weather. I am constantly on alert for an y manned aircraft (Police/Medical helicopters, etc.) and prepared to land / abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. My sUAS is capable of vertical and horizontal operations, and are flown only within my line of sight of me, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last

between ten (10) to fifteen (15 ) minutes, with an altitude u nder two hundred ( 200 ) feet. I, Gregory Zonsius

, utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery

is twenty ( 20) to twenty

- five (25 ) minutes as tested. I do not operate my sUAS at or bel ow the manufacture r recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and sUAS to eliminate potential for crash, loss of

control or hazard s . Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash, which could create hazard s to the public / property / manned aircraft, and have no desire to lose an investment. I have done s cores of practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of this specific sUAS ’ s performance under different temperature and

weather condi tions. I also practice computerized simulated flights to maintain adequate sk ills and response reflex time, a ll for the sake of safety.

I, Gregory Zonsius , am extremely cautious when operating of my sUAS / ultra

- lightweight unmanned aircraft
and will not “c reate 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 my sUAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding dire ctive to integrate sUAS s into the national airspace system. My, Gregory Zonsius ’ sUAS , used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.



### IV. How Gregory Zonsius ’ Request Will Benefit t he Public As A Whole:

Aerial photography and has been around for a long time through manned fixed wing aircraft and helicopters. For small budget productions the expense of such aerial photography and videography is cost prohibitive. Only large r companie s can afford to absorb such expense. Manned aircraft pose a threat to the public through the potential of a catastrophic crash. My, Gregory Zonsius '

, sUAS pose s no such threat since size and lack of combustible fuel alleviates any potential threat to the public.

C ongress has already proclaimed that it is in the public’s interest to integrate commercially flown sUAS s into the national airspace system, hence the passing of the Reform Act. Granting my, Gregory Zonsius ’

, exemption request furthers the public interest t hrough academic/visual awareness of the photography and videography fields throughout the Chicagoland are a. My ultra

- lightweights UAS is battery powered and

creates no emissions that can harm the environment. The consequence of my ultra

- lightweights UAS

cr ashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible

fuel and can cause catastro phic devastation to the public. The public’s interest is furthered by minimizing ecological and crash threat by permitti ng aerial photography and videography capture d through my battery operated ultra

- lightweights UAS 's. Permitting me, Gregory Zonsius , to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact
for the Chicagoland area for companies looking to use aerial photography and videography, b oth of which serve as a stimulus to the community.



### V. Reasons Why Gregory Zonsius ’ Exemption Will Not Adversely Affect Safety Or How The Exemptio n Will Provide a Level of Safety At Least Equal To Existing Rule:

My, Gregory Zonsius ’ , exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Gregory Zonsius , to log more flight time in FAA controlled airspac e, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for photographers and videographers for development in cooperation withGregory Zonsius, Photographer / Videographer, Chicagoland , IL, USA

- Section 333 Exemption Petition

Gregory Zonsius, Photographer / Videographer, Chicagoland, IL USA

- Section 333 Exemption Petition Page 4 of 16 the FAA. In addition I, G regory Zonsius , submit the following representations of enhancements to current aerial photography/videography.

My sUAS weighs less than 5 pounds complete with a small ultra

- lightweight high quality camera;
I only operate my sUAS below 4 00 feet (wit hin the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); My sUAS only operate s for ten (10) to fifteen (15) minutes per flight; I land my sUAS prior to manufacturer recommended minimum level of battery power;

I pilot my sUAS through remote control only by visual line of sight; My sUAS has GPS

, a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost; I actively analyze flight data and other sour ces of information to constantly update and enhance safety protocols; I only operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas;

I conduct extensive pre

- flight inspections and protocol, during which safety carries primary importance; I always obtain all necessary permissions prior to operation; and, I have procedures in place to abort flights in the event of safety breaches or potential danger

.

My, Gregory Zonsius ’ , safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial sUAS into our national airspace system, helicopters are the primary means of aeria l photography and videography

. While the safety record of such helicopters is remarka bly astounding, there has been incident s involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra

- lightweight sUAS

. First, the potential loss of life is diminished because sUAS s carry no peo ple on board and I only operate my sUAS in specific areas away from mass populations. Second, there is no fuel on board a sUAS and thus the potential for fire or explosions i s greatly

diminished. Third, the small size and extreme maneuverability of my sUAS allow me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my sUAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan ning, tilting and zoom ing

. Accordingly, my sUAS has been experimentally operated for familiarization/competency and will co ntinue to operate at and above current safety levels.

VI. A Summary : The FAA May Publish in the Federal Register:

A. 14 C. F. R. 21 and 14 C. F. R. 91: Airworthiness Certificates, Manuals and the Like.

14 C. F. R. 21, Subpart H, entitled Airworthiness Certifi cates, 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, Gregory Zonsius ’

, sUAS permits exemption from Part 21 because my sUAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 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 pi eces of legislation permit the FAA to exempt sUAS s from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My, Gregory

Zonsius ’ , current and projected sUAS s meet s or exceed s 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 inappli cable.Gregory Zonsius, Photographer / Videographer, Chicagoland , IL, USA

- Section 333 Exemption Petition

Gregory Zonsius, Photographer / Videographer, Chicagoland, IL USA

- Section 333 Exemption Petition Page 5 of 16 14 C. F. R. § 91. 9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the sUAS s, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintai ning a safety/flight manual delineating areas of where safety can be

defined. 5 The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C. F. R. § 91. 121 regarding altimeter settings is inapplicable insofar as my sUAS utilizes electronic global positioning systems with a barometric sensor.

14 C. F. R. § 91. 203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations.

The y are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, Gregory Zonsius

.

B. 14 C. F. R. § 45. 23: Marking of the Aircraft.

Applicable C odes of Federal Regulation require aircraft to be marked according to certain specifications. My sUAS s are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inc h lettering is difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. Regardless, I will mark the sUAS s 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 I the pilot, or anyone assisting me as a spotter with the UAV 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 non

- commercial operations. I, Gregory Zonsius , can achieve an equivalent level of safety as achieved by current Regulations because my sUAS do es not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my sUAS is far

less than the risk levels inherent in the commercial activities outlined i n 14 C. F. R. § 61, et seq. Thus, allowing me, Gregory Zonsius , to operate my sUAS meet and 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 fo r the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My sUAS will never operate at an altitude greater than 4 00 AGL. I, Gregory Zonsius , will however operate my sUAS in safe areas away from pub lic and traffic, providing a level of safety at least equivalent to or below those in relation to

minimum safe altitudes. Given the size, weight, maneuverability and speed of my sUAS , an equivalent or higher level of safety will be achieved.

E. 14 C. F. R. 91. 405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above

- cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall betw een required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter.

. . . ”

5 Appendix D

– Flight LogGregory Zonsius, Photographer / Videographer, Chicagoland , IL, USA

- Section 333 Exemption Petition

Gregory Zonsius, Photographer / Videographer, Chicagoland, IL USA

- Section 333 Exemption Petition Page 6 of 16 These Regulations only apply to aircraft with an airworthiness certificate. They will not, theref ore, apply to

my, Gregory Zonsius '

, sUAS

. However, as a safety precaution I thoroughly inspect my sUAS before and after each flight.Gregory Zonsius, Photographer / Videographer, Chicagoland , IL, USA

- Section 333 Exemption Petition

Gregory Zonsius, Photographer / Videographer, Chicagoland, IL USA

- Section 333 Exemption Petition Page 7 of 16 A Summary

The FAA May Publish in the Federal Register: A. 14 C. F. R. 21 and 14 C. F. R. 91: Airworthiness Certificates,

Manuals and The Like. 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 sUAS permits ex emption from Part 21 because my, Gregory Zonsius ’

, sUAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U. S. C. § 4 4701 (f))
and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt sUAS s from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and d ense populations. My sUAS 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 sUAS s, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintain ing a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Theref ore, an equivalent level of safety will be achieved.

In summary, Gregory Zonsius 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; 14 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 my, Gregory Zonsius ' , small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness and aerial photography and videography operations. Currently,

area awareness and aerial photograph y and videography relies primarily on the use of larger aircraft running

on combustible fuel. Posing potential risk to the public. Granting my, Gregory Zonsius ’ , request for exemption will reduce current risk levels and thereby enhance safety. My sUAS craf t do es not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and f rom established air fields. I, Gregory Zonsius , have been informally analyzing flight information and will compile safety protocols and the implementation of a flight operations manual that exceeds currently accepted means and methods for safe flight. Form al collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA
Modernization and Reform Act of 2012. There are no personnel on

- board my, Gregory Zonsius ’

, sUAS and
therefore the li kelihood of death or serious bodily injury is significantly diminished. My, Gregory Zonsius ’

, operation of my sUAS , weighing less than 5 pounds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, Gregory Zonsius

, respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfu lly submitted,

Gregory Zonsius

, Photographer / Videographer ZonCom Productions, Inc.
15402 S. Michael Dr. Plainfield, IL 60544