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 granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the 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 unmanned 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, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested 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 data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption No. 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 specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

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

 They are similar in all material respects to relief previously requested 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 situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant 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) and (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, Inc.is hereafter referred to as the operator. 
3 

Failure to comply with any of the conditions and 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 require a new petition or a petition 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 restriction. 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 PIC 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 permitted 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 ensure 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 discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 
4 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised 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 questions arise regarding updates or 

revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations 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 functional 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. The 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 manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot 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 PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles 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 experience-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 during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants 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 conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility 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 airport 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 private or controlled-access property. 

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

20. The PIC is prohibited from beginning a flight 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 for at least five minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance 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 under the terms of the attached COA. 

22. All aircraft operated in accordance 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 the 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 the Administrator or any law enforcement 

official upon request. 

24. The UA must remain clear and give way 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 protect 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 structures 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 essential persons are not considered 

nonparticipating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller 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 Safety Board (NTSB) per instructions 

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

If this exemption permits operations for the 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 over the area of proposed filming. The 3-day 

notification may be waived with 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 responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N−Number of UAS to be used; 

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

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

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating 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 all 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 Service 

 
Gregory Zonsius, Photographer / Videographer, Chicagoland, IL, USA - Section 333 Exemption Petition

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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. Part 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 Reform 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 operate my small ultra-lightweight 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 

in flying hobby aircraft for recreational purposes. I have added a quad-copter1 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 have 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 their 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 airspace.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 controlled sUASs 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 3to avoid and prevent public hazard, as well as manned 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 operations 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 sUASs into the national airspace system, 

but to “...establish requirements for the safe operation of such aircraft systems [sUASs] in the national 

airspace system” under Section 333(c) of the Reform Act specific to the use of sUASs 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 sUASs for the purposes of acquiring aerial photos & videos, both of which will promote local 

economic growth through increased employment and increased tax base. Both with public 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 Controls 
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I. Contact Information: 

Gregory Zonsius, 

ZonCom Productions, Inc.

15402 S. Michael Dr.

Plainfield, IL 60544

Office: (815) 676-5275

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, 

seeking 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 integration 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 ultralightweight sUAS prior to the time period by which the Reform Act requires the FAA to promulgate rules 

governing such craft. Thereby, providing 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 sUASs that may operate safely in our national airspace 

system. Considerations include: The weight, size, speed and overall capabilities of the sUASs; whether the 

sUAS will be operated near airports or heavily populated areas; and, whether 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. Weighing less than five (5) pounds (far below the 

maximum 55 pound limit); including camera with gimbal. 

I, Gregory Zonsius, consider safety as upmost importance with every flight. My small unmanned aircraft is 

designed to hover in place via GPS and operate in less than a 16 knot (17 mph) wind. For safety, stability 

and fear of financial loss I will not fly 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 modes to 

choose from, I utilize the GPS Mode4 for aerial photography and videography. This is the safest, most 

reliable and stable mode to prevent accidents and hazards. When pilot communication is lost, the sUAS is 

designed to slowly descend to point of take-off. I do not operate my sUAS near airports, Hospitals nor Police 

 

4 GPS Mode includes safe circle for operation, position hold, self-leveling, altitude 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. 
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heliports, and do not operate near areas where general public is within thirty to one hundred (30-100) yards 

depending on location, conditions and weather. I am constantly on alert for any 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 under 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 below the manufacturer

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 hazards. 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 hazards

to the public / property / manned aircraft, and have no desire to lose an investment. I have done scores 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 conditions. I also practice computerized simulated flights to maintain adequate skills and response 

reflex time, all for the sake of safety. 

I, Gregory Zonsius, am extremely cautious when operating of my sUAS / ultra-lightweight unmanned aircraft 

and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b).

Given the small size and weight of my sUAS it falls well within Congress’s contemplated safety zone when 

it promulgated the Reform Act and the corresponding directive to integrate sUASs 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 the 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 larger companies 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 poses 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 sUASs 

into the national airspace system, hence the passing of the Reform Act. Granting my, Gregory Zonsius’, 

exemption request furthers the public interest through academic/visual awareness of the photography and 

videography fields throughout the Chicagoland area. My ultra-lightweights UAS is battery powered and 

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

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. The public’s interest is furthered by minimizing 

ecological and crash threat by permitting aerial photography and videography captured 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, both of which 

serve as a stimulus to the community.

V. Reasons Why Gregory Zonsius’ Exemption Will Not Adversely Affect Safety Or How The 

Exemption 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 airspace, 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 with 
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the FAA. In addition I, Gregory 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 400 feet (within the 400 foot permissible ceiling set by the FAA 

Modernization and Reform Act of 2012); 

My sUAS only operates 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 sources 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 aerial photography and videography. While the safety record of such 

helicopters is remarkably astounding, there has been incidents 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 sUASs carry no people 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 is 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 panning, tilting and zooming.

Accordingly, my sUAS has been experimentally operated for familiarization/competency and will continue 

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 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, 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 pieces of legislation permit the FAA to 

exempt sUASs 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 sUASs 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. 
Gregory Zonsius, Photographer / Videographer, Chicagoland, IL, USA - Section 333 Exemption Petition

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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 sUASs, this Regulation is inapplicable. An equivalent level of 

safety will be achieved by maintaining 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. 

They 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 Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. My sUASs 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-inch lettering is 

difficult to place on such small aircraft with dimensions smaller that minimal lettering requirement. 

Regardless, I will mark the sUASs 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 does 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 in 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 for 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 400 AGL. I, Gregory Zonsius, will however operate my sUAS in safe areas away from 

public 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 between 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 Log
Gregory 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, therefore, 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 exemption 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. § 44701 (f)) 

and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt sUASs from the 

airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and 

proximity to areas such as airports and dense 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 sUASs, this Regulation is inapplicable. An equivalent level of safety will be 

achieved by maintaining 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. Therefore, 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 photography 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 craft does 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 from 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. Formal 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 likelihood 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. 

Respectfully submitted, 

Gregory Zonsius, Photographer / Videographer

ZonCom Productions, Inc.

15402 S. Michael Dr.

Plainfield, IL 60544