Adam Kalita

229 W Lincoln Ave

Barrington, IL 60010

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

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act, Adam Kalita,

operator of an Unmanned Aircraft System (UAS), hereby applies for an exemption from

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

UAS, 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.

Commercial operation of an UAS, as described herein, which are equipped with

camera(s) and sensors, would operate in the following manner:

• Aerial photography and/or video for public and/or private use including real

estate, architecture, land surveying, engineering and other related professional

activities.

• Aerial video and/or photography for public and/or private use including television,

public events, cinematography and news gathering.

• Aerial inspection/photography of residential/commercial structures under contract

with the owners or local government authority.

• Aerial inspection/photography of residential/commercial utility infrastructure

including but not limited to electrical power lines, wind turbines and cell towers.

• Aerial video/photography or providing live video feed to assist with search and

rescue operations in cases of an emergency or natural disaster only when the

local authorities or government has requested it by contract or donation.

• The ability to offer training to persons individually or belonging to both private
and/or public organizations that have interests in the use and application of a

UAS for the purpose of the safe operation of a UAS to enhance the safety of the

National Airspace System (NAS) as well as for the protection of the persons and

property.

As described fully below, the requested exemption would permit the operation of a UAS

under controlled conditions in the NAS that would be a) limited b) controlled c)

predetermined and d) will provide safety enhancements to the already safe operations

in the industry presently using conventional aircraft. Approval of this exemption would

thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “....establish requirements for the safe operation of

such aircraft systems in the national airspace system.”

The name and address of the applicant is:

Adam Kalita/Chief Pilot

Ph: 847-846-4821

Email: adam@kalita.tv

Address: 229 W Lincoln Ave, Barrington, IL 60010

Adam Kalita will operate the DJI S900 Hexacopter with DJI A2 flight controller, Vulcan Octocopter with 

DJI A2 flight controller and Sky Hero Little Spyder Quadcopter with DJI Naza V2 flight controller

Under still air the maximum speed is no more than 22m/s or 49mph with a

cruising speed of 11m/s or 25mph. The 3 aircraft have the ability to hover and move

along a vertical and horizontal plane simultaneously. The applicant will operate the UAS in line of sight 

within a closed off and predetermined area owned and/operated by the property representative. Given 

the small size of the UAS and the controlled environment provided the proposed operations

will adhere to the Reform Act’s safety requirements. The approval of this application

presents no national security issues. Regarding the level of safety surrounding the
proposed operations and the public benefit, reduction in environmental impacts,

including but not limited to reduced emissions and noise, the grant of the requested

exemption is in the public interest. Accordingly the applicant requests that the FAA grant

the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because

operations will further enhance the safety of the persons and/or property using

conventional aircraft. These limitations and conditions to which the applicant agrees to

adhere to when conducting commercial operations under the FAA issued exemption as

set forth in the Flight Operations Manual (FOM) include:

• The UAS will weigh less than 55 lbs.

• The UAS will have a maximum operating speed of no more than 50mph.

• Flights will be operated within line of sight of the Pilot in Command (PIC) and/or

Visual Observer (VO).

• Maximum flight time for each operational flight will be 30 minutes. Flights will be

terminated at 25% battery power reserve or 30 minutes of flight time whichever

occurs first.

• Flights will be operated at an altitude of no more than 400 feet Above Ground

Level (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 UAS Pilot, the Visual

Observer (VO) and may include but not limited to a Camera Operator.
• The UAS will be a designated Pilot in Command (PIC) and if the PIC feels another operator to be 

qualified that person may be designated PIC provided they have a minimum of 20 hours 

of flight time with the UAS.

• A briefing will be performed regarding the planned UAS operations prior to each

day’s flight consisting of all the days’ production activities.

• All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

• The flights will occur no closer than a 5 mile radius of the geographic

center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.

• The PIC and VO will have been trained in operation of UAS and receive up-to-date

information for the particular UAS to be operated.

• The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

• Written and/or verbal permission and permits will be obtained from territorial,

state, county or city jurisdictions, including law enforcement, fire or other appropriate

governmental agencies as required.

• If the UAS loses communications with the remote controller or loses GPS signal,

the UAS will have the capability to return to a pre-determined location within a

designated location and land autonomously.

14 C.F.R. Part 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 with the aircraft to be utilized by the

Applicant, an exemption from Part 21 Subpart H meets the requirements of an
equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal

Aviation Act (49 U.S.C.§44701 (f)) and Section 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 UAS. 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 UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and

operates exclusively within a secured and designated area. Unlike other civil aircraft,

operations under this exemption will be tightly controlled and monitored by both the

operator and under the requirements and in compliance with local public safety

requirements. The FAA will have advance notice of all operations. These safety

enhancements provide a greater degree of safety to the public and property owners

than conventional 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 credible threat to national security posed by the UAS, due to its size, speed

of operation, location of operation, lack of explosive materials or flammable liquid fuels,

and inability to carry a substantial external load.

Maintenance will be accomplished by the operator pursuant to the flight manual and

operating handbook. An equivalent level of safety will be achieved because the UAS is

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

a limited period 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 equivalent level of safety will be achieved because maintenance and inspections will

be performed in accordance with the UAS Manufacturer's User Manual.

As provided in the FOM, the operator will ensure that the UAS is in working order prior

to initiating flight and perform required maintenance needed.

Additional Information

The applicant, Adam Kalita, has been involved in the building and piloting of remote controlled “First 

Person View” (FPV) aircraft for 7 years and is a member of the Academy of Model Aeronautics (AMA). 

Also the primary pilot, Adam Kalita, has an in-depth understanding of the capabilities and safety 

concerns involved in using this technology as an asset to the community. Adam Kalita has also 

completed Private Pilot Training up to the point of several solo flights including an approximate 100 

hours of additional left and right seat flying with an FAA Certified Flight Instructor.

Satisfaction of criteria provided in Section 333 of the Reform Act provide more than

adequate justification for the grant of the requested exemptions allowing the commercial

operation of the applicant’s UAS.

Sincerely,

Adam Kalita