Caruso – Petition Addendum

March 17, 2016

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE Washington, DC 20590

Dear Sir or Madam:

On August 12, 2015, Stephen W. Caruso filed a Petition (1jz-8kik-z6wg) for a Section 333 exemption for 

the operation of a commercial unmanned aircraft system (UAS).

On November 06, 2015, the FAA posted my petition on the Public Docket, number 2015-5827-0001, 

with the notation “disposition pending”.

In a letter dated February 19, 2016, the FAA sent Caruso a letter stating that Caruso’s petition did not 

comply with the requirements of 11.81 and requested the following information:

 The reasons why the exemption would not adversely affect public safety or how the exemption 

would provide a level of safety at least equal to that provided by the rule which you seek an 

exemption.

 Any additional information, views or arguments available to support your request.

Writer believes writer’s petition fully complies with the requirements of 11.81. Writer bases his belief 

on the fact that the FAA previously approved Docket Number FAA-2015-2074 which has the same 

material information as writer’s petition. 

Attached is an addendum to writer’s previously filed petition to address the public safety issue.

Stephen Wayne Caruso is requesting an exemption from the listed Federal Aviation Regulations to allow 

commercial operation of its Unmanned Aircraft Systems ("UAS") for Aerial data collection, to include but 

not limited to aerial photography, videography, pipeline patrols, mapping, crop surveying, 

demonstration flights, inspections, film and movie production and other flight operations that could be 

performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. 

national airspace system as compared to a manned aircraft. 

In light of the fact that it has been seven months since the FAA has received petitioner’s exemption 

petition, and that the FAA has previously approved a petition containing the same material information, 

petitioner respectfully requests the FAA expedites petitioner’s request.

Thank you for your time and consideration, and please let me know if you have any questions.

Very truly yours,

Stephen Wayne Caruso

Email: stevecaruso100@gmail.com
Caruso – Petition Addendum

The UAS 

The DJI Phantom 3 Professional plus is a recently released successor to the DJI Phantom 2 series, a 

consumer grade small rotorcraft in the quadcopter configuration with an advertised weight of less than 

46 Ounces (1280g) designed primarily to carry aloft a high definition camera. It has an advertised 

maximum speed of less than 32 knots (16m/s) and a maximum climb rate of less than 1000 feet per 

minute (5 m/s). 

It is powered by four electric motors with a distance between motors of less than 12 inches (289.5mm) 

It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with 

global positioning system (GPS) to maintain its geospatial orientation and position. It is controlled 

primarily through an FCC certified radio control (RC) unit. Real time video and telemetry information is 

transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, 

GPS signal strength, altitude (AGL), and distance from PIC, camera imagery, and control camera angle. It 

has failsafe modes of operation for either loss of RC or GPS signal. The onboard flight controller can limit 

altitude and maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to 

approximately 23 minutes. The onboard flight controller will warn the pilot via telemetry and external 

lighting cues before reaching a low battery state. An automatic termination of flight and landing will be 

initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually 

last less than 10 minutes. 

http://www.dji.com/product/phantom3 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 and Part 11of the Federal Aviation 

Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 

91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) &(b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 

91.417 (a) & (b).

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11, Stephen Wayne Caruso, hereinafter referred to as petitioner, hereby applies for an 

exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its 

Unmanned Aircraft Systems (''UAS") Aerial data collection, to include but not limited to aerial 

photography, videography, pipeline patrols, mapping, crop surveying, demonstration flights, 

inspections, film and movie production and other flight operations that could be performed safely and 

more cost effectively with the use of small UAS at low altitude within the U.S. national airspace system 

as compared to a manned aircraft, 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. Operation 

of the UAS would fall under the supervision of FAA commercial pilot Stephen Wayne Caruso. As detailed 

in this document and the attached Manual, the requested exemption would permit the operation of

UAS under controlled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to 

access. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 
Caruso – Petition Addendum

Transportation's (the FAA Administrator's) responsibilities to"...establish requirements for the safe 

operation of such aircraft systems in the national airspace system." Section 333(c) of the Reform Act. 

Regulations from which the exemption is requested: 14 C.F.R. Part21 14 C.F.R.45.23(b) 14C.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 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) & (b) 14 C.F.R. 91.405 (a) 14 C.F.R. 407 (a) (1) 14 

C.F.R. 409 (a)(2) 14 C.F.R. 417 (a) & (b)

I.STATUTORYAUTHORITYFOR EXEMPTIONS The Federal Aviation Act expressly grants the FAA authority 

to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined 

under §40101 of the Act, including UAS, from the requirement that all civil aircraft must have a current 

airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the 

Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §4471 l(a); 

49 USC §44704; 14 CFR §91.203(a)(l). Section 333(b) of the Reform Act assists the Secretary in 

determining whether UAS may operate in the National Airspace System (NAS) without creating a hazard 

to the user, the public, or a threat to national security. In making this determination, the Secretary must

consider: 

• The UAS's size, weight, speed, and operational capability; 

• Whether the UAS operates within the visual line of sight of the operator 

• Whether the UAS operates outside of highly populated areas and away from close proximity to 

airports Reform Act §333(a).

If the Secretary determines that a UAS "may operate safely in the national airspace system, the 

Secretary shall establish requirements for the safe operation of such aircraft in the national airspace 

system." Id. §333(c). Petitioner’s UAS are multirotor vehicles, weighting 55 or fewer lbs. including 

payload. They operate under normal conditions at a speed of no more than 50 knots and have the 

capability to hover, and move in the vertical and horizontal plane simultaneously. The UAS will operate 

only in the pilot's visual line of sight at all times and will operate only within a controlled area, free of 

manned aircraft. Such operations will insure that the UAS will "not create a hazard to users of the 

national airspace system or the public." Reform Act Section 333 (b). Given the small size of the UAS

involved and the restricted and controlled environment within which they will operate, our application 

falls squarely within the zone of safety (an equivalent level of safety) in which Congress envisioned that 

the FAA must, by exemption, allow commercial operations of UAS to commence immediately.

Also due to the small size of the UASs and the low altitudes and controlled areas in which our UAS will 

operate, approval of the application presents no national security issue. Given the clear direction in 

Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the 

strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, 

including enhanced safety, the grant of the requested exemptions is in the public interest.

Accordingly, petitioner respectfully requests that the FAA grant the requested exemption without delay.
Caruso – Petition Addendum

Public Safety

The reasons why the exemption would not adversely affect public safety or how the exemption would 

provide a level of safety at least equal to that provided by the rule which petitioner seeks an 

exemption are set forth below:

II. PUBLIC INTEREST

The enhanced safety achieved by replacing significantly larger manned aircraft carrying crew and 

flammable fuel with small UAS aircraft not carrying passengers or crew and operated under the specific 

guidelines and procedures proposed by Petitioner give the FAA good cause to find that the UAS 

operations enabled by the instant Petition are in the public interest. Moreover, as the FAA has already 

recognized, “UAS provides an additional tool for the filmmaking industry, adding a greater degree of 

flexibility, which supplements the current capabilities offered by manned aircraft.” See Exemption No, 

11062, Regulatory Docket No. FAA-2014-0352, at p. 22.

III. EQUIVALENTLEVEL OF SAFETY 

Petitioner proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least 

an equivalent or even higher level of safety to operations under the current regulatory structure 

because the proposed operations represent a safety enhancement to the already safe protocols 

followed on aerial photography and videography operations conducted with helicopters and other 

conventional aircraft.

1"Commonly Used Statistics", Occupational Safety & Health Administration. Available at: 

https://www.osha.gov/oshstats/commonstats.html

Petitioner will be bound by the following limitations when conducting its UAS operations under an FAA 

issued exemption: 

1. The UAS will be less than 55pounds. 

2. Flights will be operated within visual line of sight of a FAA certified pilot. 

3. Maximum total flight time for each operational flight will be 20 minutes or less. The UAS calculates 

battery reserve in real time, and will return to its ground station with at least 15% battery power reserve 

should that occur prior to the 20 minute limit. 

4. Flights will be operated at an altitude up to 400 feet AGL. 

5. Crew for each operation will consist of the UAS pilot who will keep the UAS within his visual line of 

sight at all times. 

6. The UAS pilot will be trained in flight, operations, and safety procedures as detailed in the aircraft 

Manual. 

7. The UAS will only operate away from heavily populated areas and not in the immediate vicinity of 

airports. 
Caruso – Petition Addendum

8. A briefing will be conducted in regard to the planned UAS operations prior to each day's photography 

activities. 

9. The proposed flight area will be inspected and cleared of persons prior to the commencement of UAS 

operations. 

10. Written and/or oral consent and/or notification will be given to the relevant property owners or 

applicable persons. 

11. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

12. If the UAS loses communications or loses its GPS signal, it will have capability to return to a predetermined landing point. 

13. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

IV. DESCRIPTION OF SPECIFICREGULATIONS

14 CFR Part 21, Sub part H: Airworthiness Certificates 14 C.F.R.§91.203(a)(l) 

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 petitioner, 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. Our small UAS will be operated at low speed in a controlled environment. Petitioner will ensure 

that no persons are allowed within 500 feet of the operating area except those consenting to be 

involved and necessary for the filming production, with the possibility of reducing this distance to no 

less than 200 feet if it would not adversely affect safety and the Administrator has approved it. 

Petitioner will not conduct UAS operations within 5 nautical miles of the geographic center of a nontowered airport unless the airport’s management is given prior notice and the operation is conducted in 

accordance with a Notice to Airmen (“NOTAM”), where applicable. Petitioner’s UAS will remain clear 

and yield the right of way to all manned operations and activities at all times (including, but not limited 

to, ultra light vehicles, parachute activities, parasailing activities, and hang gliders.) 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 helicopter) operating with an airworthiness certificate without the restrictions and 

conditions proposed.

The UAS to be operated hereunder is less than 55lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels. Like other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the operator, and under the requirements and in 

compliance with local public safety requirements.

These safety enhancements, which already apply to civil aircraft, provide a greater degree of safety to 

the public and property owners than conventional operations conducted with airworthiness 
Caruso – Petition Addendum

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 

ability to carry an external load no greater than two lbs.

14C.F.R.45.23(b): Marking of the Aircraft

This regulation requires certain experimental, provisionally certificated aircraft, or lightsport category 

aircraft to be marked with letters between 2 inches and 6 inches high "limited," "restricted," "lightsport," "experimental," or "provisional," near each entrance to a cabin, cockpit, or pilot station.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS 

will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be

placed. Given the size of the UAS, two-inch lettering will be impossible. The word "Experimental" will be 

placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the 

UAS as "Experimental." The FAA has issued the following exemptions to this regulation: Exemptions Nos. 

10700, 8738, 10167 and 10167A.

14CFR 61.113 (a) & (b):Private pilot privileges and limitations: Pilot in command

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the pilot operating the aircraft to have reviewed the operation manual for the 

specific aircraft and demonstrate necessary flight skills. Unlike a conventional aircraft that carries the 

pilot and passengers, the UAS is remotely controlled with no living thing or cargo on board. The area of 

operation is controlled and restricted, and all flights are planned and coordinated in advance. The risks 

associated with the operation of the UAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations of the UAS as 

requested, exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.7 (a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained in the User Manual for maintenance and use of safety checklists prior to each 

flight, an equivalent level of safety will be provided.

14CFR 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements

The UAS, given its size and configuration has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry 

such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the ground control 

point where the pilot flying the UAS will have immediate access to it. The FAA has issued the following 
Caruso – Petition Addendum

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

10167A, 10602, 32827, and10700. 14 C.F.R. 91.103: Pre-flight Action

This regulation requires each pilot in command take certain actions before flight to ensure the safety of 

flight. An exemption is needed from this requirement as the pilot will take separate preflight actions, 

including checking for weather conditions, checking flight battery requirements, checking takeoff and 

landing distances, and all other actions in the Preflight Checklist in the User Manual. These actions will 

provide an equivalent level of safety.

14C.F.R.91.109: Flight Instruction Section 91.103 provides that no person may operate a civil aircraft 

(except a manned free balloon) that is being used for flight instruction unless that aircraft has fully

functioning dual controls.

By design, UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has previously approved exemptions for aircraft without fully functional dual 

controls. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that 

neither a pilot nor passengers will be carried in the aircraft, the ability to control the UAS via radio 

signals from the controller, and by the size and speed of the aircraft.

14 C.F. R. 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is 

for a quad-rotor craft that flies similarly to a helicopter, with vertical take-off and vertical landing, which 

will typically operate at altitudes up to 400 AGL, so an exemption may be needed to allow such 

operations. The equivalent level of safety will be achieved given the size, weight, speed of theUAS aswell 

as the location where it is operated. No flight will be taken without the consent and/or the notification

of/to the property owner and/or onsite persons where required. Because of the advance notice, all

affected individuals will be aware of the planned flight operations. Compared to flight operations with 

aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and carrying 

flammable fuel, any risk associated with our operations is far less than those presently presented with 

helicopters and other conventional aircraft operating at or below 500AGL. In addition, the low altitude 

operations of the UAS will ensure separation between these UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. 14 C.F.R. 91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set "...to the elevation of the departure airport or an appropriate altimeter setting 

available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the User Manual and Safety Check list, confirming the altitude of the launch site shown on 

the GPS altitude indicator before flight.

14CFR 91.151 (a): Fuel requirements for flight in VFR conditions

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. Our UAS is limited 

to operations in controlled environments, and has a limited range and flight time which require an 
Caruso – Petition Addendum

exemption from 14CFR91.151(a). The battery powering the UAS provides approximately 20 minutes of 

powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be 

limited to approximately 15 minutes in length. Given the limitations on the UAS proposed flight area and 

the location of its proposed operations within a predetermined area, a longer time frame for flight is

reasonable.

Eastman believes that an exemption from 14 CFR §91.15l(a) falls within the scope of prior exemptions. 

See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 

91.151 (a)).Operating the small UAS, in a tightly controlled area where prior consent/notification has 

been received/given, with less than 30 minutes of reserve fuel, does not engender the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, 

limiting UAS flights to 15 minutes would greatly reduce the utility for which the exemption will be

granted.

An equivalent level of safety can be achieved by limiting flights to 40minutes, or enough battery reserve 

to ensure that the UAS lands at the ground station with at least 15% of battery power (as determined by 

the onboard monitoring system and the pilot), whichever happens first. This restriction would be more 

than adequate to return the UAS to its planned landing zone from anywhere in its limited operating

area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 

and 10808. 14CFR 91.203 (a) &(b): Carrying civil aircraft certification and registration

The regulation provides in part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following: (1)An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. Therefore 

there is no ability or place to carry certification and registration documents or to display them on the 

UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground flight control 

point where the pilot flying the UAS will have immediate access to them, to the extent they are 

applicable to the UAS. The FAA has issued numerous exemptions to this regulation. A representative 

sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 

10700. 14 CFR 91.405 (a); 407 (a)(l); 409 (a)(2); 417 (a) & (b): Maintenance inspections

These regulations require that an aircraft operator or owner "shall have that 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 ...," and 

others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to UAS. Maintenance will be accomplished by the operator pursuant to the 
Caruso – Petition Addendum

Manual. An equivalent level of safety will be achieved because these small UASs are very limited in size 

and will carry a small payload and operate only in controlled areas for limited periods of time. If 

mechanical issues arise the UAS can land immediately and will be operating from no higher than 400

feet AGL. As provided in the User Manual, 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.

*******

Pursuant to 14C.F.R. Part 11,the following summary is provided for publication in the

Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:14 C.F.R. §21, subpart H;14 C.F.R 45.23(b);14 

C.F.R. §§ 61.113( a) & (b);91.7

(a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 

91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle 

(55lbs or less) in aerial photography. Approval of exemptions allowing commercial operations of UAS for 

aerial photography/videography and inspection of buildings, towers etc enhances safety while reducing 

risk. Traditional aerial photography creates a greater risk because the craft are much larger, have 

combustible fuel, and carry an onboard human pilot. In contrast, a UAS weighing fewer than 55 lbs. and 

powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible 

fuel carried on board. The UAS will carry no passengers or crew and, therefore, will not expose such to 

the risks associated with manned aircraft flights.

The operation of small UASs, weighting less than 55 lbs., conducted in a controlled structure as outlined 

above, will provide an equivalent level of safety supporting the grant of the exemptions requested 

herein, including exempting the applicant from the requirements of Part 21 and allowing commercial 

operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a controlled 

environment and, as a result, are far safer than conventional operations conducted with turbine 

helicopters operating in close proximity to the ground and people.

Privacy All flights will occur over controlled property with the appropriate party’s consent and/or 

knowledge. Images taken will typically be of company owned assets and flown over company owned 

property or property of individuals who have consented to being overflown or otherwise have agreed to 

allow petitioner to be in the area where aerial photography operations will take place. ******* 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012, i.e. size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line of sight 

and national security, provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of applicant's UASs for airborne photography, videography, 

and inspection pursuant to the Manual link attached in this document.