August 26, 2015

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Exemption Request under § 333 of the FAA Modernization and Reform Act of 2012 of the Federal 

Aviation Regulations from 14 CFR Part 21; 14 CFR §§ 45.23(b); 61.113 (a) & (b); 61.315(a) & (c); 91.7(a); 

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

91.417(a) & (b).

Dear Sir or Madam, 

Pursuant to § 333 of the Federal Aviation Administration (“FAA”) Modernization and Reform Act 

of 2012, Pub. L. No. 112-95 (2012), 126 Stat. 11 (the “Reform Act”), the FAA’s general exemption 

authority under 49 USC § 44701(f), and 14 CFR Part 11, Jason Lauzer (hereinafter, the “Petitioner”), an 

owner and operator of small Unmanned Aircraft Systems (“UAS”), hereby petitions for exemptions from 

14 CFR Part 21, Subpart H (Airworthiness Certificates), 14 CFR §§ 45.23(b), 61.113(a) & (b), 61.315(a) & 

(c), 91.7(a), 91.9(b)(2), 91.103(b)(1), 91.109(a), 91.119(c), 91.121, 91.151, 91.203(a) & (b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b). The proposed exemptions, if granted, would allow 

Petitioner to conduct commercial operations of small UAS for purposes to include: aerial photography, 

aerial videography (marketing), precision agriculture, real estate, exterior structure inspections, UAS 

training, and volunteer search and rescue missions under the conditions outlined herein and as may be 

established by the FAA in granting the above requested exemptions. 

As described more fully below, based on the small size of Petitioner’s UAS, the qualifications and 

experience of Petitioner’s pilot, and the limited, controlled-access environments within which Petitioner 

will operate, the requested exemptions clearly fall within the safety parameters envisioned by Congress 

as set forth in § 333 of the Reform Act. Additionally, the enhanced safety achieved by replacing 

significantly larger manned aircraft carrying crew and flammable fuel with small UAS weighing less than 

55 pounds under the specific guidelines and procedures proposed by Petitioner gives the FAA good 

cause to find that the UAS operations enabled by this petition are in the public interest. Thus, the 

requested exemptions should be granted.

THE NAME AND ADDRESS OF PETITIONER: 

Jason Lauzer

720 Redfin Drive

Atlantic Beach, FL 32233

904-599-5568

jlauzer@gmail.com
BACKGROUND OF PETITIONER

Petitioner is a multifaceted digital media, video photographer and pilot with over fifteen years’ 

experience. Jason Lauzer is a FAA licensed commercial pilot and holds an instrument and multi-engine 

ratings. Mr. Lauzer has extensive experience as a hobbyist UAS pilot. Mr. Lauzer’s background in 

aviation, film, video, and photography production, and his knowledge and experience with UAS and 

wireless communications provide a level of trust that will ensure the integrity and safety of all UAS 

operations conducted by Petitioner pursuant to the requested exemptions.

Petitioner has a long standing reputation for excellence and safety and serves as an entryway for 

their clients to attain a dedicated and award winning team that serves much like an in-house media 

department with unprecedented, world-class production capabilities. Petitioner seeks to build on its 

years of safe and successful productions and leverage Mr. Lauzer’s aviation skills and knowledge to offer 

the widest possible range of UAS services in a manner consistent with the parameters set forth in § 333 

of the Reform Act. Petitioner seeks the requested exemptions to permit Petitioner to offer commercial 

UAS services for a variety of industries and applications, including:

 Aerial surveying and mapping

 Precision Agriculture inspections

 Aerial photography

 Aerial videography and video marketing

 Real estate marketing and inspections

 Exterior structure inspections

 Public entity support operations

 UAS training, and

 Volunteer search and rescue operations

Petitioner plans to conduct operations under the requested exemptions using the DJI 

Phantom 3 small UAS. 

REQUESTED EXEMPTIONS

Petitioner requests relief from the following regulations:

 14 CFR Part 21;

 14 CFR § 45.23(b);

 14 CFR § 61.113(a) & (b);

 14 CFR § 61.315(a) & (c);

 14 CFR § 91.7(a);

 14 CFR § 91.9(b)(2);

 14 CFR § 91.103(b)(1);

 14 CFR § 91.109(a);

 14 CFR § 91.119;

 14 CFR § 91.121;

 14 CFR § 91.151(a);

 14 CFR § 91.203;

 14 CFR § 91.405(a);
 14 CFR § 91.407(a)(1);

 14 CFR § 91.409(a)(2);

 14 CFR § 91.417(a) & (b)

EXTENT OF RELIEF SOUGHT BY PETITIONER AND REASONS FOR SEEKING SUCH RELIEF 

14 CFR Part 21, Subpart H: Airworthiness Certificates 

This section establishes the procedural requirements for the issuance of airworthiness 

certificates and other airworthiness approvals. Given the size, weight, speed, and limited operating area 

associated with the UAS to be utilized by Petitioner, an exemption from 14 CFR Part 21, Subpart H 

(Airworthiness Certificates), subject to certain conditions and limitations, is warranted, and meets the 

requirements for an equivalent level of safety under 14 CFR Part 11 and § 333 of the Reform Act. 49 USC 

§ 44701(f) and § 333 of the Reform Act both authorize the FAA to exempt aircraft, including UAS, from

the requirement for an airworthiness certificate upon consideration of the size, weight, speed, 

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

sight.

The UAS operated without an airworthiness certificate in the restricted environment and under 

the conditions and limitations proposed by Petitioner will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate issued under 

14 CFR Part 21, Subpart H, and not subject to the proposed limitations and conditions. The UAS to be 

operated by Petitioner (DJI Phantom 3 ) weighs much less than 55 lbs. fully loaded, will be operated at a 

speed of no more than 50 knots, will carry neither a pilot nor passengers, will carry no explosive or 

flammable materials or fuel, and will be operated exclusively in predetermined, controlled-access 

environments. Petitioner’s UAS will use a radio frequency spectrum for operation and control that 

complies with Federal Communications Commission (“FCC”) requirements, and will be operated only in 

accordance with the procedures proposed herein and as may be established by the FAA.

Petitioner’s UAS will be equipped with redundant safety mechanisms allowing safe operation 

after experiencing certain in-flight failures. If a lost-link event occurs, including loss of ground 

communications or loss of GPS signal, Petitioner’s UAS will have the ability to perform a precoordinated, predictable, automated flight maneuver and return to a predetermined location within a 

designated security perimeter for landing.

Unlike operations of other civil aircraft, operations under the requested exemptions will be 

tightly controlled and monitored by both the pilot in command (“PIC”) and a Visual Observer (“VO”) in 

order to ensure the Petitioner’s UAS remains within operational limitations and to ensure the safety of 

operations. These enhancements to current safety practices and regulations provide a greater degree of 

safety to the public and property owners than conventional aircraft operations conducted by aircraft 

with an airworthiness certificate. Lastly, there is no intrinsic credible threat to national security posed by 

UAS due to the size, speed, restricted operational environments, lack of explosive materials and 

flammable fuels or other liquids, and inability to carry passengers or a substantial external load.
14 CFR § 45.23(b): Display of Marks 

This section requires that “[w]hen marks include only the Roman capital letter “N” and the 

registration number is displayed on limited, restricted, or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to 

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.”

Even though the Petitioner’s UAS will have no airworthiness certificate, an exemption may be 

necessary as the UAS will have no entrance to the cabin, cockpit, or pilot station on which the word 

“experimental,” etc., can be placed. Also, given the size of Petitioner’s UAS, two-inch lettering will be 

impossible. Petitioner understands the need for markings and will mark its UAS in the largest possible 

lettering on the UAS fuselage so that anyone observing Petitioner’s UAS will be able to see the markings.

14 CFR § 61.113(a) & (b): Private Pilot Privileges and Limitations: Pilot in Command (PIC) and

14 CFR § 61.315(a) & (c): Sport Pilot Privileges and Limitations

These sections limit private pilots and sport pilots to non-commercial operations. Because 

Petitioner’s UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent 

level of safety of current operations by requiring the PIC operating Petitioner’s UAS to have a private 

pilot’s or sport pilot’s license rather than a commercial pilot’s license to operate Petitioner’s small UAS. 

Unlike a conventional aircraft that carries the pilot and passengers, Petitioner’s UAS are remotely 

controlled with no persons onboard. The area of operation will be controlled and restricted, and all 

flights will be planned and coordinated in advance. The risks associated with the operation of 

Petitioner’s UAS are so diminished from the level of risk associated with commercial operations 

contemplated by 14 CFR Part 61 when drafted, that allowing operations of Petitioner’s UAS as requested 

with a private pilot or sport pilot as the PIC exceeds the present level of safety achieved by 14 CFR §§ 

61.113(a) & (b) and 61.315(a) & (c).

14 CFR § 91.7(a): Civil Aircraft Airworthiness 

This section prohibits any person from operating a civil aircraft unless it is in an airworthy 

condition. As there will be no airworthiness certificate issued for Petitioner’s UAS, 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 UAS manufacturer’s manuals and use of safety checklists 

prior to each flight, an equivalent level of safety will be provided. In accordance with the pertinent part 

of 14 CFR § 91.7(b), the PIC for all of Petitioner’s UAS operations shall be responsible for determining 

whether the aircraft is in a safe condition for flight, including the use of pre-flight safety checklists.
14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual, Marking, and Placard Requirements

This sections provides in pertinent part that “[n]o person may operate a U.S.-registered civil 

aircraft ... For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.” Petitioner’s UAS, given 

their size and configuration, have no ability to carry a physical flight manual on the aircraft. The 

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

where the PIC operating Petitioner’s UAS will have immediate access to it.

14 CFR § 91.103(b)(1): Preflight Action

This regulation requires each PIC to take certain actions before flight to insure the safety of each 

flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft, an exemption will 

be needed. Petitioner will comply with the other applicable procedures and requirements stated in § 

91.103(a) & (b). Specifically, the PIC will take all action including reviewing weather, flight battery 

requirements, aircraft performance data, and landing and takeoff distances before initiating a flight. The 

PIC will also account for all relevant site-specific conditions in their preflight procedures.7 Risks 

presented by sun glare will be mitigated by the PIC’s and VO’s ability to see other air traffic and initiate a 

return-to-home sequence if needed.

14 CFR § 91.109(a): Flight Instruction

This section provides in pertinent part that “[n]o 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.” UAS, by their design, do not have functional dual controls. Flight control is accomplished 

through the use of a control box that communicates with the aircraft via radio communications. Given 

the size and speed of Petitioner’s UAS, an equivalent level of safe training can be achieved without dual 

controls because no pilot or passengers are aboard the UAS and all persons will be a safe distance away 

in the event that the UAS experiences any difficulties during flight instruction. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of aircraft and for flight 

instruction in experimental aircraft. See Exemptions Nos. 5778K and 9862A.

14 CFR § 91.119: Minimum Safe Altitudes

This section establishes minimum safe altitudes for operation of civil aircraft. § 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. Similarly, § 

91.119(c) provides that, over other than congested areas, no person may operate an aircraft below an 

altitude of 500 AGL, except over open water or sparely populated areas. As this exemption is for a UAS 

that closely mimics the flight characteristics of a helicopter, and the exemption requests authority to 

operate at altitudes no higher than 400 feet AGL, an exemption may be needed to allow such 

operations.

As set forth herein, Petitioner’s UAS will never operate at higher than 400 feet AGL, nor beyond 

visual line of sight (“VLOS”) of the PIC and VO, whichever is closer. It will, however, be operated in a 

restricted area with individuals tasked with ensuring public safety, and where buildings and people will 

not be exposed to operations without their pre-obtained consent and training. 
The equivalent level of safety will be achieved given the size, weight, and speed of Petitioner’s 

UAS as well as the restricted environments within which they will be operated. No flight will be taken 

without the permission of the property owner. Because of the advance notice to the property owner 

and the participants in the UAS operation, all affected individuals will be aware of the planned flight 

operations. Compared to flight operation with manned aircraft or rotorcraft weighing far more than 

Petitioner’s UAS and the lack of flammable fuels onboard, any risk associated with Petitioner’s 

operations is far less than that presently presented by conventional aircraft operating at or below 500 

feet AGL. In addition, the lowaltitude operations of Petitioner’s UAS will ensure separation between 

Petitioner’s UAS operations and the operations of conventional aircraft that must comply with § 91.119. 

Furthermore, the manufacturer of Petitioner’s UAS, DJI, has implemented Firmware updates that limit 

UAS flights around airports, along with distance and elevation limits.

14 CFR § 91.121: Altimeter Settings 

In pertinent part, this section 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 Petitioner’s UAS may not have a 

barometric altimeter, but instead a GPS altitude readout, an exemption may be needed. An equivalent 

level of safety will be achieved by the PIC confirming the altitude of the launch site shown on the GPS 

altitude indicator, and prior to each flight, a zero altitude initiation point will be established and 

confirmed for accuracy by the PIC. The PIC will also ensure effective pairing with multiple GPS sources to 

guarantee accurate detection of altitude.

14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This section prohibits a person from beginning “a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed—(1) during the day, to fly after that for at least 

30 minutes; or (2) at night, to fly after that for at least 45 minutes.”

The battery powering Petitioner’s UAS provide approximately 12-15 minutes of powered flight 

in hover mode without payload. Thus, Petitioner’s UAS will not be able to meet the 30 minute reserve 

requirement contained in 14 CFR § 91.151(a). Operating Petitioner’s UAS in a tightly controlled area 

where only people or property owners or official representatives who have signed waivers will be 

allowed, with less than 30 minutes of reserve power, does not engender the type of dangers that § 

91.151(a) was intended to alleviate given the size and speed of Petitioner’s UAS. Petitioner believes that 

an equivalent level of safety can be achieved by prohibiting Petitioner’s PIC from beginning any flights 

unless, considering the wind and forecast weather conditions, there is enough available power for 

Petitioner’s UAS to conduct the intended operation and to operate after that for at least five minutes or 

with the reserve power recommended by the manufacturer, whichever is greater. This restriction would 

be more than adequate to return the Petitioner’s UAS to its planned landing zone from anywhere in its 

limited operating area. FAA has granted similar exemptions; see e.g. Exemption Nos. 2689F, 5745, 

10673, and 10808.
14 CFR § 91.203(a) & (b): Civil Aircraft: Certifications Required

This regulation provides in pertinent part that “(a)...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 

... is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.”

Petitioner’s UAS fully loaded weighs less than 55 pounds and is operated without a pilot, 

passengers, or crew onboard. As such, there is no is ability or place to carry certification and registration 

documents or to display them on Petitioner’s UAS. An equivalent level of safety will be achieved by 

keeping these documents at the ground control station where the PIC will have immediate access to 

them, to the extent they are applicable to Petitioner’s UAS. FAA has issued numerous exemptions to this 

section; see e.g. Exemption Nos. 9565, 9665, 9789, 9789A, 9797, and 10700.

14 CFR §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(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 sections and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to Petitioner. Petitioner will strictly adhere to the safety and maintenance 

procedures included in all applicable UAS manufacturer’s instructions and operating manuals.8 To the 

extent such information is not included in the guidelines as developed by the manufacturers, Petitioner 

will undertake to develop and document maintenance, overhaul, replacement, and inspection 

requirements, and procedures to document and maintain maintenance records with regards to 

Petitioner’s UAS.9 An equivalent level of safety will be achieved because Petitioner’s UAS are very 

limited in size and will carry small payloads and operate only in restricted areas for limited periods of 

time. If mechanical issues arise, Petitioner’s UAS can land immediately and will be operating from no 

higher than 400 AGL. The Petitioner will ensure that its UAS are in working order prior to initiating each 

flight, perform regular maintenance, and keep a log of any maintenance performed. Moreover, 

Petitioner is the person most familiar with the aircraft and is best suited to maintain the aircraft in an 

airworthy condition in order to ensure safe operations.

EQUIVALENT LEVEL OF SAFETY 

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

characteristics and that operate within the limitations listed herein. Petitioner’s requested exemptions 

will not adversely affect safety, and Petitioner’s proposed operational limits will provide for at least an 

equivalent or even greater degree of safety than for similar operations conducted using conventional, 

manned aircraft, due to the size, speed, and limited operating area of Petitioner’s UAS.

The UAS Petitioner plans to operate are small, multi-rotor rotorcraft, each weighing much less 

than 55 pounds including their payload. They will operate, under normal conditions, at a speed of no 

more than 50 knots. Operations will be performed by a fully qualified and trained UAS PIC, as outlined 

below, to ensure that Petitioner’s UAS will “not create a hazard to users of the national airspace system 
or the public.” Given the small size of Petitioner’s UAS and the pre-planned, controlled-access 

environment within which they will operate, Petitioner believes that these operations fall squarely 

within that zone of safety in which Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UAS to commence immediately. Also, operation in a secured, pre-defined area 

will prevent the possibility of a national 8 See Appendix A, Appendix B, and Appendix C 9 See Appendix 

E, Appendix F, and Appendix G security issue. The operation of Petitioner’s UAS by knowledgeable 

aviation professionals with experience in the national airspace system (“NAS”) will serve to enhance 

safety, add to the public benefit, and reduce environmental impacts related to current methods of aerial 

operations of the kind proposed by Petitioner.

The limitations and conditions to which Petitioner agrees to be bound when conducting 

commercial operations under this petition include but are not limited to the following, at a minimum:

1. Safety will be the first and foremost consideration for all of Petitioner’s UAS operations.

2. Petitioner will conduct operations using only the DJI Phantom 3 UAS, of which weighs less 

than 55 pounds fully loaded.

3. Petitioner’s UAS PIC will be required to be an FAA licensed airman and hold at least an FAA 

Third Class Medical certificate or valid driver’s license.

4. Petitioner’s UAS PIC will be responsible at all times for the safe operation of each flight 

conducted pursuant to the requested exemptions.

5. All flights will be operated within VLOS of the PIC at all times.

6. All operations will utilize a visual observer (“VO”). The VO will be used to maintain VLOS with 

the UAS so long as the PIC also always maintains VLOS capability, and the PIC and VO will at all 

times remain close enough to be able to communicate verbally during flight operations. The PIC 

will be responsible for ensuring that the VO can perform the duties required by the VO.

7. The UAS will operate at no more than 50 knots, and in no case will UAS be operated at 

airspeeds greater than the maximum operating airspeed recommended by the UAS 

manufacturer.

8. This exemption, if granted, and all other documents needed to operate Petitioner’s UAS and 

conduct operations in accordance with the limitations and conditions as set forth herein and as 

established by the FAA will at all times be kept with the PIC at the ground control station and 

will be immediately available upon request.

9. Petitioner’s UAS will utilize GPS navigation, failsafe, return-to-home (“RTH”), and/or flight 

abort safety features.

10. The PIC will be prohibited from beginning a flight unless, considering the wind and forecast 

weather conditions, there is enough available power for Petitioner’s UAS to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer, whichever is greater.

11. Flights will be operated at an altitude at or below 200 feet above ground level (“AGL”) under 

normal conditions, and will never exceed 400 feet AGL.

12. Petitioner will not allow its PIC to operate unless the PIC demonstrates the ability to safely 

operate Petitioner’s UAS in a manner consistent with how the UAS will be operated as proposed 

herein, including evasive and emergency maneuvers and maintaining appropriate distances 

from persons and property, and including familiarization with applicable airspace restrictions 

and the UAS operations manuals.
13. Operations will never be conducted at night. Daytime operations will only be conducted 

under Visual Flight Rules (“VFR”) conditions.

14. Petitioner’s UAS will only be operated within a pre-planned, controlled-access flight 

perimeter sized so as to allow the PIC and VO to maintain VLOS with the UAS at all times during 

flight operations.

15. A briefing will be conducted in regard to each planned UAS operation, and the safety 

thereof, prior to operation at each new location.

16. All persons not directly involved with UAS flight operations will be prohibited from entering 

the flight perimeter unless there exists therein barriers or structures sufficiently robust to 

protect nonparticipating persons from the UAS and/or debris in the event of an accident. 17. All 

UAS operations will be conducted over private or controlled-access property with permission 

from the property owner or property controller or their respective authorized representative. 

Permission from the property owner or controller or their authorized representative will be 

obtained prior to each operation.

18. If the UAS loses communications or loses its GPS signal, it will have the capability to return to 

a pre-determined location within the flight perimeter.

19. The PIC will have the power, and the duty, to abort all flight operations in the event of 

unpredicted obstacles or emergencies.

The Requested Exemptions Promote the Public Interest

The enhanced safety achieved by replacing significantly larger manned aircraft carrying 

crew, passengers, and flammable fuel with small UAS carrying no passengers, crew, or 

flammable fuel under the specific guidelines and procedures proposed by Petitioner gives 

FAA good cause to find that the UAS operations enabled by this petition are in the public 

interest. Moreover, by replacing the manned aircraft traditionally used for the kinds of 

operations proposed by Petitioner with small UAS, Petitioner will be able to provide aerial 

operations services at a greatly reduced cost, making these kinds of services available to a 

greater range of businesses and consumers, thereby enhancing the utility of aerial 

operations and benefitting the economy as a whole. Similarly, the small, electric, batterypowered UAS utilized by Petitioner will benefit the public as a whole by greatly reducing the 

pollution and ecological impact associated with traditional aircraft and rotorcraft 

operations.

Congress and the FAA, through passage of the Reform Act and in numerous Exemptions 

(see e.g. Exemption No. 11 062), have already recognized that UAS provide a greater degree 

of flexibility and safety than traditional manned aircraft when used within certain 

operational limits and for the kinds of operations proposed herein by Petitioner. Granting 

Petitioner exemption to operate its UAS commercially furthers economic growth and public 

safety while limiting the ecological impacts of aerial operations. Thus, FAA has good cause to 

grant this petition. 
Conclusion 

For the forgoing reasons, the exemptions requested by Petitioner herein should be 

granted and Petitioner should be permitted to conduct commercial UAS operations in 

accordance with the limitations and conditions proposed herein and as established by the 

FAA. 

Respectfully submitted, 

Jason Lauzer