**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 Am**  **ir Homay ounpour**  **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 o f relief**  **Am ir Homay** **ounpour 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 t hat 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 a reas 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 charg ed battery with each flight as a safety precaution; full flight time limit for each battery is twelve (12) to wenty

two (22) minutes as tested. I do not operate my UAS at or below
manufacture recommend minimum charge levels for operation; preferring to rem ain 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 numerouspractice flights in remote areas as a hobbyist simu lating 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, u sed 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 re al 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 compani es 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 captu re 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 repre sentations 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 man ufactured 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 of2012); 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 stri ctly 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, the re 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 onl y 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. 2 1 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
airwort hiness 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 regul ation 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 se nsor. 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, bydefinition, 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 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 exempti ons 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 othe r 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, AmirHomayounpour's, UAS. However, as a safety precaution I carefully

and thoroughly inspect my UAS before and af ter 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 re al 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.
Granti ng 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 compi le 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 poundsand 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 requ est 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