I. Name and Information

Amirhomayoun Homayounpour

Address: 851 Lake Carolyn Pkwy

Apt 262

Irving, Texas 75039

Phone: 469-826-7578

Email: a_homayounpour@yahoo.com

II. The Specific Sections of Title 14 of the Code of

Federal Regulations From Which Amir Homayounpour 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 Amir Homayounpour seeks and the 

Reason He Seeks Such Relief:

I, Amir Homayounpour, 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, Amir Homayounpour, 

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, Amir Homayounpour's, ultra light 

weight UAS meets the definition of “small unmanned aircraft” as 

defined in Section 331 and therefore the integration of my ultra light 

weight UAS is expressly contemplated by the Reform Act. I would like 

to operate my ultra light weight UAS 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 UAS 

aerial video and photography. The Reform Act guides the Secretary 

in determining the types of UAS's that may operate safely in our 

national airspace system.

Considerations include: The weight, size, speed and overall

capabilities of the UAS's; Whether the UAS will be operated near 

airports or heavily populated areas; and, Whether the UAS 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,

Amir Homayounpour. My UAS utilizes four (4) counter-rotating

propellers for balance, control and stability. My UAS 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, Amir Homayounpour, consider safety as foremost with each flight.

My small unmanned aircraft is designed to hover in place via GPS 

and operate in less than a 24 knot (15 mph) wind. For safety, stability 

and fear of financial loss I will not fly in winds exceeding 16 kph (10 

mph). Built in safety systems include a GPS mode that allows my 

UAS to hover in place when radio controls are released. With three 

modes to choose from, I utilize the GPS Mode for aerial 

videography/photography.

This is the safest, most reliable and stable mode to prevent accident 

and hazard. When pilot communication is lost UAS is designed slowly 

descend to point of take off. I do not operate my UAS near airports, 

Hospitals nor Police heliports, and do not operate near areas where 

general public is within fifty to one hundred (50-100) 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 UAS is capable of vertical and horizontal operations, and are 

flown only within my line of sight of me, as the remote control pilot, or 

with my licensed PIC. Utilizing battery power rather than combustible

fuels, flights generally last between three (3) to twelve (12) minutes, 

with an altitude under two hundred (200) feet. I, Amir Homayounpour, 

utilize a fresh fully charged battery with each flight as a safety 

precaution; full flight time limit for each battery is twelve (12) to wentytwo (22) minutes as tested. I do not operate my UAS at or below 

manufacture recommend minimum charge levels for operation; 

preferring to remain well within a safe operating range to insure 

adequate communication between radio control and UAS to eliminate

potential for crash, loss of control or hazard. 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, 

that could create hazard to the public/property/manned aircraft, and

have no desire to lose an investment. I have clocked numerous 
practice flights in remote areas as a hobbyist simulating flights for 

future commercial use to gain familiarization with the characteristics 

of this specific UAS'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, Amir Homayounpour, am extremely cautious when operating of my

UAS/ultra light weight 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 UAS it falls well within 

Congress’s contemplated safety zone when it promulgated the 

Reform Act and the corresponding directive to integrate UAS's into

the national airspace system. Amir Homayounpour’s UAS, used in

hobby flight, has a demonstrable safety record and does not pose 

any threat to the general public or national security.

IV. How Amir Homayounpour’s Request Will Benefit the Public As

A Whole:

Aerial videography for geographical awareness and for real estate 

marketing has been around for a long time through manned fixed 

wing aircraft and helicopters. For small budget real estate companies 

and average homeowners the expense of such aerial videography is 

cost prohibitive. The same is also true for construction sites, land 

surveying, and even location historical documentation. Only large 

companies and high end Realtors or luxury homeowners can afford 

to absorb such expense. Depriving non-luxury homeowners and 

lower budget Realtors and other such companies with needs from a

valuable marketing and analysis tool. Manned aircraft pose a threat to 

thepublic through potential catastrophic crash in the North Texas 

community. Each resulting in loss of life. Each with combustible fuel 

that exploded and burned on impact. Police, TV and radio helicopters 

have made emergency hard landings within city limits. My, Amir 

Homayounpour’s, UAS pose 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 UAS's into the national airspace system, 

hence the passing of the Reform Act. Granting my, Amir 

Homayounpour’s, exemption request furthers the public interest 

through academic/visual awareness of the geographical benefits in 

and around the North Texas area.
My ultra light weight UAS is battery powered and creates no

emissions that can harm the environment. The consequence of my 

ultra light weight 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 video/photo capture through my battery 

operated ultra light weight UAS's.

Permitting me, Amir Homayounpour, to immediately fly within national

air space furthers economic growth. Granting my exemption request 

substantially furthers the economic impact for the North Texas 

community for companies looking to relocate or build in the North 

Texas area as well as individuals looking to relocate for career 

advancement through academic and geographical awareness. Both 

of which serve as a stimulus to the community.

V. Reasons Why Amir Homayounpour’s Exemption Will Not

Adversely Affect Safety Or How The Exemption Will Provide a Level 

of Safety At Least Equal To Existing Rule:

My, Amir Homayounpour’s, exemption will not adversely affect safety.

Quite the contrary, for the reasons stated permitting me, Amir 

Homayounpour, 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 Realtors, construction sites, land 

surveying, location historical documentation, and infrastructure 

inspections that can be embraced by the NAR, AAR, and TAR for

development in cooperation with the FAA. In addition I, Amir 

Homayounpour, submit the following representations of

enhancements to current aerial videography and photography for real 

estate, construction sites, land surveying, location historical 

documentation, infrastructure inspections, athletic field marketing and 

maintenance:

My UAS, a Phantom 2 manufactured by DJI weighs less than 5 

pounds complete with a small ultra light weight high quality GoPro 3+ 

Black camera;

§I only operate my UAS below 200 feet (well within the 400 foot 

permissible ceiling set by the FAA Modernization and Reform Act of 
2012); my UAS only operates for 12-16 minutes per flight;

§I land my UAS prior to manufacturer recommended minimum level 

of battery power;

§I pilot myUAS through remote control only by line of sight;

§My UAS 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 obtains 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, Amir Homayounpour’s, safety protocols provide a level of safety

equal to or exceeding existing rules. It is important to note that absent 

the integration of commercial UAS into our national airspace system, 

helicopters are the primary means of aerial video and photography for 

community awareness and application. While the safety record of 

such helicopters is remarkably astounding, there have been local 

incidents involving loss of life as well as extensive property damage; 

it is far safer to operate a battery powered ultra light weight UAS.

§First, the potential loss of life is diminished because UAS's carry no 

people on board and I only operate my UAS in specific areas away 

from mass populations. 

§Second, there is no fuel on board a UAS and thus the potential for 

fire or explosions is greatly diminished.

§Third, the small size and extreme maneuverability of my UAS 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 UAS need not be so close to the objects 

they are focused on through the technology and use of post editing 

software allowing pan and zoom.

Accordingly, my UAS 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, Amir 

Homayounpour's, UAS permits exemption from Part 21 because my

UAS 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 UAS's from the

airworthiness certificate requirement in consideration of the weight,

size, speed, maneuverability and proximity to areas such as airports 

and dense populations. My, Amir Homayounpour, current and 

projected UAS's meet or exceed 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 on board pilots or passengers, and given the 

size of the UAS's, 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. 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 UAS 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, Amir Homayounpour.

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 UAS are, by
definition, unmanned. They therefore do not have a cabin, cockpit or 

pilot station on which to mark certain words or phrases. Further, twoinch lettering is difficult to place on such small aircraft with 

dimensions smaller that minimal lettering requirement. Regardless, I 

will mark its UASs 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.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots arelimited to 

non-commercial operations. I, Amir Homayounpour, can achieve an 

equivalent level of safety as achieved by current regulations because 

my UAS 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 UAS is far less than the risk 

levels inherent in the commercial activities outlined in 14 C.F.R. § 61, 

et seq. Thus, allowing me, Amir Homayounpour, to operate my UAS 

meet and exceed current safety levels in relation to 14 C.F.R. 

§61.113 (a) & (b).

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 UAS will never operate at an altitude greater 

than 200 AGL; safely below the standard of 400 AGL. I, Amir 

Homayounpour, will however operate my UAS 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 UAS, an equivalent or 

higher level of safety will be achieved.

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. . . .” 

These Regulations only apply to aircraft with an airworthiness 

certificate. They will not, therefore, apply to my, Amir 
Homayounpour's, UAS. However, as a safety precaution I carefully 

and thoroughly inspect my UAS before and after each flight.

In summary, Amir Homayounpour 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, Amir Homayounpour, small unmanned

vehicle/lightweight unmanned aircraft vehicle in community 

awareness, grounds and building maintenance, infrastructure 

inspections, real estate operations, and to develop economic 

platforms for real estate to enhance the experience of those seeking 

to relocate to the North Texas area. Currently, such aerial

videography/photography relies primarily on the use of larger aircraft 

running on combustible fuel. Posing potential risk to the public. 

Granting my, Amir Homayounpour, request for exemption will reduce 

current risk levels and thereby enhance safety.

My UAS craft do not contain potentially explosive fuel, is smaller, 

lighter and more maneuverable than conventional video and 

photographic 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, Amir Homayounpour, 

have been informally analyzing flight information and will compile 

safety protocols and the implementation of a flight operations manual 

for aerial video and photographic usage 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, Amir Homayounpour, UAS and therefore the likelihood of 

death or serious bodily injury is significantly diminished. My, Amir 

Homayounpour's, operation of my UAS, weighing less than 5 pounds 
and traveling at lower

speeds within limited areas will provide an equivalent level of

safety as that achieved under current FARs. Accordingly I,

Amir Homayounpour, 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,

Amir Homayounpour