United States Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE West Building Ground Floor Room W12-140

Washington, DC 20590 

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

Dear Entitled FAA Representative, 

I am writing regarding to the FAA Modernization and Reform Act of 20121 (the "Reform Act") to respectively 

request that Kyle Joseph Brow, be exempted from the Federal Aviation Regulations ("FARs") listed below so 

that he shall operate his small unmanned aircraft ("UAS") commercially in airspace regulated by the Federal 

Aviation Administration ("FAA"); as 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. Kyle has extensive remote 

control UAS experience and knowledge. He has over 25 years experience operating RC aircraft’s and vehicles. 

In addition, he has extensive experience with duel thumb joystick controllers. 

The need for UAS approval is for commercial and residential aerial photos. Total UAS flight time would be 25 

minutes or less. The height required for aerial photos is on average 400 ft or less. The UAS would not fly near or

around airports. 

The operating UAS utilizes four counter-rotating propellers for optimal balance, control and stability. The UAS 

weighs less than 55 pounds. It hovers and stabilizes in place and can operate at less than a 50 knot maximum 

speed. The UAS is capable of vertical, horizontal and 360 degree operations. The UAS utilizes a personal tablet 

for viewing flight with on-board camera for added safety. 

The remote control pilot (named above), uses a spotter when available and a technician, so that a safe flight can 

be achieved at all times. In addition, a pre-flight check is always done before every flight. The UAS is checked 

for cracks, wire frays, battery life, propeller condition, power test, motor calibration, remote controller batter 

life, remote controller functionality, viewing tablet battery life, verify connection UAS camera, and operating 

and connected to tablet.

Safety precautions include:

• The UAS only operates UAS below 400 feet.

• The UAS only operates for 5-25 minutes per flight.

• Remote control pilot operates the UAS by camera connected to personal tablet and line of sight.

• The UAS has GPS flight modes where it shall hover and then slowly land if communication with the remote 

control pilot is lost or battery power is below 25%.

• Pre-Flight checks are done before every flight. (detailed above)

•The UAS weighs less than 55 pounds. 

• The UAS only operates in secured areas that are strictly controlled, and are away from airports.

• Analysis of electronic flight data and other sources of information are used to constantly update and enhance 

safety protocols.

• The UAS will land safe when it reaches 25% battery power.

Kyle respectfully requests that the FAA grant its exemption request. The FAA has the authority to issue the 

exemption sought by Kyle Joseph Brow regarding the Federal Aviation Act, 85 P.L. 726 (1958) amended (the 

"Act").

With Regards, Kyle Joseph Brow

Kyle Joseph Brow 3086 W. Cook Rd.

(810) 223-1747 Grand Blanc, MI 48439

kbrow109@gmail.com