November 17, 2015

Submission by: Steven Craemer

2421 SW Malibu Way

Stuart, Florida 34997

(719) 237-4306

Craemer87@gmail.com

U.S. Department of Transportation Docket Management System

1200 New Jersey Ave. SE Washington, DC 20590

Exemption request under section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations.

Dear Sir or Madam,

 I request an exemption from 91.7(a), 91.119, 91.121, 91.151(a), 91.405, 91.407(a)(1), 91.409(a)(2) 

and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14CFR) as was granted in exemption 

numbers 11138, 11395, 11428, and 11434.

I will be operating a multi rotor UAS (hexa-copter) of my own design constructed with existing DJI 

components of high quality and reliability weighing less than 14 pounds at takeoff. Its intended purposes 

of operation are aerial imaging/videography and data collection. And a small UAS (quadcopter) of my own 

design constructed from high quality off the shelf components weighing less than 5 pounds.

I implore that the use of this UAS for these intended operations (Aerial Photography, Data 

collection, Structure inspection or Aerial Surveying) is in the publics best interest for several reasons:

 Increased safety due to lack of personal exposed to risks inherent in flying, climbing or traveling 

to reach the intended vantage point achieved with the UAS.

 Reduced environmental impact due to lack of fuel handled or burned by aircraft and lower noise 

emissions compared to conventional helicopter operations.

 Reduced risk to property, under or around operations, being damaged or disturbed by 

downwash of vehicle.
 A substantial decrease in cost of data collection by UAS compared to the high operating cost of 

manned aircraft. 

Operations under this exemption will be conducted as outlined in the proposed rule set in motion on 

02/23/2015 in docket FAA-2015-0150

Operational limitations

 Visual Line-of-sight (VLOS) only; the UAS must remain within VLOS of the operator or visual 

observer.

 At all times the UAS must remain close enough to the operator for the operator to be capable of 

seeing the aircraft with vision unaided by any device other than corrective lenses.

 Small UAS may not operate over any persons not directly involved in the operation.

 Daylight-only operations (official sunrise until official sunset, local time)

 Must yield right-of-way to other aircraft, manned or unmanned.

 May use visual observer (VO) but not required.

 First Person View (FPV) camera cannot satisfy “see and avoid” requirement but can be used as 

long as requirement if satisfied in other ways.

 UAS airspeed not to exceed 100 mph (87 knots).

 UAS altitude not to exceed 500 ft. Above Ground Level (AGL).

 Minimum weather visibility of 3 miles around control station.

 No operations in Class A airspace (12,000 and above)

 Operations in class B, C, D and E are allowed with the required permission of Air Traffic Control 

(ATC)

 Operations in class G airspace (5 miles or greater from controlled airport) are allowed without 

ATC permission.

 No person may act as an operator or VO for more than one UAS operation at one time.

 No careless or reckless operation.

 Preflight inspection is required by the operator prior to each operation.

 A person may not operate a UAS if he or she knows or has reason to know of any physical or 

mental condition that would impair the operator or otherwise interfere with the safe operation of 

the UAS.
I request exemption from 91.405(a), 91.407(a) (1), 91.409(a) (2) and 91.417(a) and (b) maintenance 

requirements since they apply to aircraft with an airworthiness certificate. I will provide similar safety 

requirements by performing a detailed preflight inspection prior to each operation and promptly remedying 

and deficiency unfit for continued operation and performing a maintenance test flight in a safe area prior 

to returning UAS to service.

I request exemption from 91.151. The pilot in command will abide by the following personal protocols and 

controls.

 Operator will only operate in reasonably safe environments that are strictly controlled, are away 

from power lines, elevated lights and airports. Operator will conduct extensive preflight 

inspections to ensure safe flight operations.

 Operator will maintain the UAS below 400 feet AGL and within 1500 foot radius from the 

operators location. The operator will maintain direct visual line of sight (VLOS) at all times during 

the operation.

 Manage the UAS reserve battery requirements to maintain a reserve power required for safe 

return to takeoff point. 

 Use the UAS GPS flight controller safety feature whereby the UAS will climb to a safe altitude and 

return to its take off point if operators control communication is lost.

 Contact appropriate controllers/personnel and /or Flight Standards District Office if operations 

will be within 5 miles of airport to advise them of intended UAS flight operations including flight 

time, duration, altitude and any pertinent information about the flight.

 Have suitable procedures in place to manage inflight emergencies and to abort flight operations if 

safety is compromised or any potential danger arises.

91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I assert that since there 

are currently no standards for airworthiness applicable to my operation of UAS, this regulation is not 

applicable. 

91.119 prescribes safe altitudes for the operation of civil aircraft but it allows helicopters to be operated at 

lower altitudes in certain conditions. Operator of UAS will: not operate the UAS above 400 feet above 

ground level (AGL), only operate away from areas of public and traffic and use and use a see and avoid 

methodology for providing at least equivalent safety to those guidelines for minimum safe altitude.
91.121 Altimeter setting is inapplicable since my UAS utilizes electronic position location via GPS and is 

recalibrated at each startup for operation and is displayed in feet above ground level (AGL)

Steven Craemer