08/20/2015 3:28 AM FAX 

September 10, 2015 

Daniel Zatz 

ZatzWorks Inc. 

178 E. Bunnell Avenue Suite A 

Homer, AK 99603 

907-299-1885 (cell) 

Daniel@~-~-t.zwoxks.&QID (email) 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Room W12-140, West Building Ground Floor 

Washington DC 20590 

202-493-2251 (Fax) 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 

of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 

CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 9l.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 

14 CFR 91.119(c): 14 CFR 91.121; 14 CFR 91.151(b); 14 CFR 91.203 (a) and (b); 14 

CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 

91.417(a) and (b). 

To whom it may concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the 

"Reform Act") and 14 CFR Part 11, Zat'.lWorks, operator of Small Unmanned aircraft 

Systems ('"sUA"), hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its sUA, so long as such 

operations arc conducted within and under the conditions outlined herein or as my 

be established by the FAA as required by Section 333. 

Commercial operation sUA, as described herein, which are equipped with cameras 

and sensors, would operate in the following manner: 

1. Aerial photography andfor video for public andfor private usc including real 

estate, architecture, land surveying, engineering and other relatE~d professional 

activities. 

2. Aerial video and/or photography for public andfor private us~~ including 

television, public events, cinematography and news gathering. 

3. Aerial inspection/photography of residential/commercial ~.-tructures under 

contract with the owners or local government authority. 

4. Aerial video/photography or providing live video feed to assist with search and 

rescue operations in cases of an emergency or natural disaster only when the local 

authorities or government has requested it by contract or donation. 

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5. The ability to offer training to persons individually or belonging to both private 

and/or public organizations that have interests in the use and application of sUA for 

the purpose of the safe operation of sUA to enhance the safety of the National · 

Airspace System (NAS) as well as for the protection of the persons and property. 

As described fully below, the requested exemption would permit the operation of 

sUA under controlled conditions in the NAS that would be a) limited b) controlled c) 

predetermined and d) will provide safety enhancements to the already safe 

operations in the industry presently using conventional aircraft. Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA Administrator's) responsibilities to " .... est."lblish 

requirements for the safe operation of such aircraft systems in the national airspace 

system." 

The name and address of the applicant is: 

Attn: Daniel Zatz 

ZatzWorks 

178 E. Bunnell Avenue 

Homer, AK 99603 

907M299-1885 (cell) 

JlML~@z.atzworks.co_.r:n, (email) 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

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14 CFR 45.23 (b) 

14 CFR 61.113 (a) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CPR 91.103 

14 C.fo'R 91.109 

14 CFR 91.119 (c) 

14 CPR 91.121 

14 CFR 91.151 (b) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CPR 91.409 (a) (2) 

14 CPR 91.417 (a) & (b) 

My DJI Inspire 1 sUA is a multi-rotorcraft weighing 7.5 lbs. including payload. Under 

normal conditions it operates at a maximum speed of 4 7 knots and has the ability 

hover and move along a vertical and horizontal plane simultaneously.lt will operate 

only during daylight and in line of sight and will operate within a closed off and 

predetermined area owned andjoperated by the property representative. 

1 am in the process of registering my DJI Inspire 1 as N19ZW. 
08/20/2015 3:28 AM FAX 

Given the small sb;e of the sUA and the controlled environment provided the 

proposed operations will adhere to the Reform Act's safety requirements. The 

approval of this application presents no national security issues. Regarding the level 

of safety surrounding the proposed operations and the public benefit. reduction in 

environmental impacts, including but not limited to reduced emissions and noise, 

the grant of the requested exemption is in the public interest. Accordingly the 

applicant requests that the FAA grant the requested exemption with minimum 

delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety 

because operations will further enhance the safety of the persons and/or property 

using conventional aircraft. 

These limitations and conditions to which the applicant agrees to adhere to when 

conducting commercial operations under the FAA issued exemption as set forth in 

the User' include: 

1. The sUA will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum flight time for each operational flight will be 20 minutes. Flights will be 

terminated at 25o/o battery power reserve or 20 minut.es of flight time whichever 

occurs first. 

4. Flights will be operated at an altitude of no more than 400 feet above ground level 

(AGL) and not more than 200 feet above an elevated platform from which filming is 

planned. 

S. Minimum crew for each operation will consist of the sUA Pilot, the Visual 

Observer (VO) and may include but not limited to a Camera Operator. 

6. The sUA pilot will be a designated Pilot in Command (PIC) and hold a current 

Third or higher Class Medical Certificate, along with a valid state driver's license. If 

the PIC feels another operator to be qualified with the necessary skills to be PIC & 

possess a Third or higher Class Medical and a valid state driver'~ license, that person 

may be designated PIC provided they have a minimum of20 hours of flight time 

with the sUA. 

7. A briefing will be performed regarding the planned sUA operations prior to each 

day's flight consisting of all the days' production activities. 

8. The operator will file FAA Form 7711·1, or its equivalent, as modified in light of 

the requested exemption, with the appropriate local Flight Standards District Office 

(FSDO) no more than 72 hours but no less than 48 hours from planned operation. 

9. The operator will obtain verbal/written consent of all persons involved with the 

planned operation and ensure that only consenting persons will be allowed within 

100 feet of the flight operation, and the radius may be reduced to 30 feet based upon 

an equivalent level of safety determination, as required in the User's Manual. With . 

the advanced permission of the FSDO, operations at closer range may be approved. 

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10. The PIC and VO will have been trained in operation of sUA and receive up-todate information for the particular sUA to be operated. 

11. The PIC and VO will be able to communicate by voice, radio, and/or text at all. 

times. 

12. Written and/or verbal permission and permits will be obtained from territorial, 

state, county or city jurisdictions, including law enforcement, fire or other 

appropriate governmental agencies. 

13. If the sUA loses communications or loses GPS signal, the sUA will have the 

capability to return to a pre-determined location within a design<lted location and 

land autonomously. 

14. The sUA will have the capability to abort a flight in case of unpredictcd obstacles, 

weather, or emergencies. 

15. The Safety Guidelines manual for the Inspire 1 will be followed by the operator. 

14 C.F.R. Part 21, Subpart H: Ail"Worthiness Certificates 14 C .. F.R. §91.203 (a) 

(1) 

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 si1.e and limited operating area associated with the 

aircraft to be utilized by the Applicant, 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 sUA. In all cases. an analysis of these criteria demonstrates that the sUA 

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 rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

The sUA to be operated hereunder is less than 55 lbs. fully loaded. carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured and designated area. Unlike other civil 

aircraft, operations under this exemption will be tightly controlled and monitored 

by both the operator and under the requirements and in c:omplio.:mce with local 

public safely requirements. The FAA will have advance notice of all operations. 

These safety enhancements provide a greater degree of safety to the public and 

property owners than convenlional operations conducted with ~irworthiness 

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 sUA, due to its size, speed of operation, location of operation, lack of 

explosive materials or flammable liquid fuels, and inability to carry a substantial 

external load. 

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

The regulation requires: 

When 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 sUA will have no airworthiness certificate, an exemption may be 

needed as the sUA will have no entrance to the cabin, cockpit or pilot station on 

which the word "Experimental" can be placed. Given t:he size of the sUA, two-inch 

lettering will be impossible. The word "Experimental" will be placed on the fuselage 

in compliance with §45.29 (t). 

The equivalent level of safety will be provided by having the sUA marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working 

with the sUA will sec::: the identification of the sUA as HExperirnental.H 

14 C.F.R. § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in 

Command. 

Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may 

. act as a pilot in command of an aircraft that is carrying passengers or property for 

compensation or hire. Our sUA does not carry any pilots or passengers nor property 

therefore I am seeking an exemption to 14 CFR 61.113(a). Although helpful, a pilot's 

license will not ensure remote control piloting skills. The risks attendant to the 

operation of sUA is far less than the risk levels inherent in the commercial activities 

outlined in 14 CFR 61. I feel the operation and limitations set forth in the User 

Manual will equate to the safe operation of the sUA. 

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 for maintenance and use of 

safety check lists prior to each flight an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft 

... (2) 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 

Rotofcraft Flight Manual, approved manual material, markings. and placards. or any 

combination thereof. The sUA, 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 

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

ground control point where the pilot flying the sUA will have immediate access to it. 

14 C.F.R. § 91.103: Preflight Action. 

This regulation requires each pilot in command to take certain actions before flight 

to ensure the safety of flight As FAA approved rotorcr;;~ft flight manuals will not be 

provided for the aircraft an exemption will be needed. The PIC wHl take all actions 

including reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight. 

14 C.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. sUA and remotely piloted aircraft, by their design do 

not have fully functional dual controls. Flight control is accomplished through the 

usc of a control box that communicates with the aircraft via radio communications. 

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. 

The equivalent level of safety provided by the fact that neither a pilot nor 

passengers will be carried in the aircraft 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 air,craft. 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. As this exemption is for a sUA that is a 

helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, or not more than 200 above an elevated platform from which filming is 

planned. an exemption may be needed to allow such operations. As set forth herein, 

the sUA will never operate at higher than 400 AGL with the exception that in 

circumstances where the sUA is used to survey or photograph a structure whose 

height exceeds 400 feet AGL. the sUA will not be operated more than 100' above the 

highest point on the structure. ll will however be operated in a restricted area with 

security perimeter, where buildings and people will not be exposed to operations 

without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the 

sUA as well as the location where it is operated. No flight will be taken without the 

permission of the property owner or local officials. Because of the advance notice to 

the property owner and participants in the filming activity, 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 SSlbs. proposed herein 

and the lack of flammable fuel, any risk associated with these operations is far less 

than those presently presented with conventional aircraft operarjng at or below 500 

AGL. In addition, the low-altitude operations of the sUA will ensure separation 

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between these small- UAS operations and the operations of conventic>nal 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 sUA 

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 safety check list and live flight data monitoring, 

confirming the altitude of the launch site shown on the GPS altitude indicator before 

flight 

14 C.F.R. § 91.151(b): Fuel Requirements for Flight in VFR C<l,nditions 

Section 91.151 (b) prohibits an individual from beginning "(b) No person may begin 

a flight in a rotorcraft 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, to fly after that for at least 20 minutes." 

The battery powering the sUA provides approximately 20 minutes of powered fllght. 

To meet the 20-minutc reserve requirement in 14 CFR §91.151, sUA flights would 

be limited to approximately 0 minutes in length. Given the limitations on the sUA's 

proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight or twilight VFR 

conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(b) fa:tls within the scope 

of prior exemptions. Operating the small UAS, in a tightly controlled area where only 

people and property owners or official representatives who have signed waivers 

will be allowed, with less than 20 minutes of reserve fuel, does not constitute the 

type of risks that Section 91.151(b) was intended to alleviate given the size and 

speed of the small UAS. Applicant believes that an equivalent lev•el of safety can be 

achieved by limiting flights to 20 minutes or 25% of battery power- whichever 

happens first. This restriction would be more than adequate to r·~turn the sUA to its 

planned landing zone from anywhere in its limited operating area. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and 

Registration 

The regulation provides in pertinent 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. Each U.S. airworthiness 

certificate used to comply with this subparagraph (except a special flight permit, a 

copy of the applicable operations specifications issued under §21.197( c) of this 

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chapter, appropriate sections ofthc air carrier manual required by parts 121 and 

135 of this chapter containing that portion of the operations specifications issued 

under §21.197(c). or an authorization under §91.611) must have on it the 

registration number assigned to the aircraft under part 4 7 of this chapter. However, 

the airworthiness certificate need not have on it an assigned special identification 

number before 10 days after that number is first affixed to the aircraft A revised 

airworthiness certificate having on it an assigned special identification number, that 

has been affixed to an aircraft, may only be obtained upon application to an FAA 

Flight Standards district office. 

(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 sUA fully loaded weighs no more than 55 lbs. and is operated without an 

on board pilot As such, there is no ability or place to carry certification and 

registration documents or to display them on the sUA. 

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

ground control point where the pilot flying the sUA will have immediate access to 

them, to the extent they are applicable to the sUA. 

14 C.F.R. §91.405 (a); 407 (a) (1); 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 betwe·en 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 the applicant. Maintenance will be 

accomplished by the operator in accordance with the flight mam.1al and operating 

handbook. An equivalent level of safety will be achieved because these small sUAs 

are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods oftime. If mechanical issues arise the sUA can land 

immediately and will be operating from no higher than 400 feet AGL. The operator 

will ensure that the sUA is in working order prior to initiating flight. perform 

required maintenance, and keep a log of any maintenance perfo~rmed. Moreover, the 

operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condilion to provide the equivalent level of safety. 

An equivalent level of safety will be achieved because maintenance and inspections 

will be performed in accordance with the sUA Maintenance Manual. The operator 

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will ensure that the sUA is in working order as per the User Manual, prior to 

initiating flight and perform required maintenance needed. 

Additional Information 

Daniel Zatz, the owner of ZatzWorks, is a 25 year Alaskan with roots in the Southern 

California broadcast market working in LA and San Diego. He has four Ernmy 

Awards and clients include BBC Natural History, an array of Discovery and National 

Geographic series, The History Channel, NHK, CBC, German television, and 

commercial clients like Smuggler, Aero Film, etc. He's filmed in every corner of 

Alaska and has more than 3000 hours of aerial Cineflex® filming in the state- more 

than any other operator in the world. Jn addition to operating the Cineflex, Zatz 

founded and led an Alaska-based robotics company and he provides regular 

technical support to Cineflex owners throughout the world. He is also an FAA 

licensed fixed wing and helicopter Private Pilot (#3282151)- giving him a good 

understanding of the challenges operating sUAs could present to other types of 

aircraft if not responsibly operated within the boundaries of FAA regulation. He 

holds a third class medical certificate and a current Alaska Driver's License 

(#6501521). 

Satisfaction of criteria provided in Section 333 of the Reform Act of2012 provide 

more than adequate justification for the grant of the requested exemptions allowing 

the commercial operation of the applicant's sUA. 

141 0009/0009