November 13, 2015

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

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Home Course Aerials, an operator of Unmanned Aircraft Systems (“UAS”) for producing high-definition aerials videos/cinematography for 

golf courses, golf clubs and private country clubs, hereby applies for an exemption 

from the Federal Aviation Regulations (“FARs”) to allow commercial operation of its 

UAS platforms. 

Home Course Aerials(HCA) requested exemption would permit the operation of 

small, unmanned UAS under controlled conditions in airspace that is: (1) limited, (2) 

predetermined, (3) subject to controlled access, and (4) provide greater safety in 

connection with aircraft operations in the outdoor film and television industry. As established by the exemptions already granted by the FAA, approval of Home Course 

Aerials exemption would enhance safety and fulfill the Secretary of 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 © of the Reform act. 

HOME COURSE AERIALS

215-221-4340 padzeke@me.com 2003 Grace Lane Flourtown, PA 19031
Benefits of UAS

HCA is owned by Paul Pizzica, and is the operator and current owner of a Phantom Vision2 Plus, Phantom 3, and DJI Inspire 1. I have been flying at least one of 

these UASs for 24 months now without incident as a hobbyist, and have kept detailed 

flight logs for each flight. The services provided by HCA would mainly serve golf clubs 

in the golf association of Philadelphia and surrounding area, and would provide an 

economical benefit to its members and member clubs. As this area is rich in golf history, HCA services of high-definition overhead aerials videos through the use of a 

sUAS would provide each golf course and their owners with videos for golf course 

historical preservation use, as well as for marketing use for their current and prospective members. Aerial footage of golf course holes can provide competitive golfers an 

awareness of or knowledge of the course before playing, as well as giving respective 

greenskeepers visuals of their home golf courses for maintenance purposes. 

 HCA services are a safe, low cost, and effective solutions to obtaining these 

aerials videos without the use of a helicopter or manned aircraft with fuel and persons 

on board. Further safety is ensured as all flights will be conducted over privately held 

property, with very few or no structures and nonparticipating persons around during 

flights. The desired shots or video captured for these purposes is envisioned with no 

persons visible in the camera frame.

This application is submitted by: 

Home Course Aerials 

Owner: Paul Pizzica 

215-221-4340 

padzeke@me.com

2003 Grace Lane, Flourtown, PA 19031 
Regulations from which the exemption is requested: 

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a)

14 CFR 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 CFR 91.151 (a)

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b) 

HCA UASs are rotorcraft, 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. They will operate only in line of sight and will operate only after all safety protocols and preflight 

checks have been completed. 

Given the small size of the UASs involved and the restricted controlled environment 

within which they will operate, the applicant falls squarely within that zone of safety 

(an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due 

to the size of the UASs and the restricted areas in which the relevant UASs 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, reduction in environmental impacts, including reduced emissions associated with allowing UASs for movie and television operations, the grant of the requested exemptions 

is in the public interest. Accordingly, the applicant respectfully requests that the FAA 

grant the requested exemption. 

The substance of this request is essentially the same as granted to Mile Sky Productions LLC, Regulatory Docket No. FAA-2015-0612, and Thomas Goodall, Regulatory 

Docket No. FAA-2015-1333. 
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant 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 filming operations conducted with conventional aircraft. 

These limitations and conditions to which HCA agrees to be bound when conducting 

commercial operations under an FAA issued exemption include: 

1. The UAS will weigh less than 55 lbs including payload(camera, etc) - UASs for this 

exemption include DJI Phantom2 Vision Plus (2.74l bs), Phantom 3(2.82 lbs) and 

DJI Inspire 1 (6.47 lbs).

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

3. Flights will be operated at an altitude of no more than 400 feet AGL.

4. The UASs will not exceed speeds of 15m/s(30 knots).

5. Minimum crew for each operation will consist of the UAS Pilot, and a Visual Observer.

6. Observer and pilot will at all times be able to communicate by voice.

7. UAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the 

UAS Pilot, who possess the necessary PIC qualifications, is also present, that person can also be designated as PIC.

8. UAS flights will not be conducted at night.

9. The UAS will not operate within 5 miles of an any airport, unless a letter of 

agreement is obtained from that airport’s management, or an additional COA is 

issued. The letter of agreement or additional COA will carried by PIC during all 

operations and flights.

10. If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to a pre-determined location within the Security Perimeter and land.

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

or emergencies.
12. Any flights will be prohibited from beginning if there is insufficient power available for the UAS to operate for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

13. All flights will be conducted on private property with written or oral permission 

granted by the relevant property owners

14.All flights will be conducted at least 500 feet from all nonparticipating persons, 

vehicles or structures, unless said owners of any of those vehicles or structures has 

granted permission to fly closer to them.

15.All flight accidents will be reported to the FAA’s UAS Integration Office with 24 

hours.

16. Additionally, for our operations, we have a Standard Operations Procedure before 

each flight. This SOP will provide for the level of safety as required for this exemption request, as well as a pre-flight checklist that is listed in each of the manuals for 

the Phantom2 Vision Plus, Phantom 3 and Inspire 1. This SOP will be communicated between PIC and VOS before each flight operation.

• determine if area of flight is in a non-flight zone specified by local laws 

and regulations

• first observe the flight area for any mobile phone base stations, radio 

transmission towers, power lines or any other electromagnetic interference that could disrupt flight

• check weather conditions, not flying in winds speeds in excess of 10m/s, 

snow or rain

• check the UA and battery performance are subject to safe air density and 

temperature

• check that remote controller, wifi transmission range extender, aircraft 

batteries and mobile devices are fully charged

• place aircraft on open, flat ground with battery indicator facing toward 

pilot

• propellers are mounted correctly and firmly, as is camera and gimbal

• power on the remote controller, wifi transmission range extender and 

mobile device, followed by the Intelligent Flight Battery
• check that the DJI camera app(either Vision and Pilot) can connect to aircraft and video transmission is being sent and received, and the proper 

camera settings for each particular flight are set

• mobile phones(primary and backup) have cell service to access maps 

apps for GPS waypoint plotting and auto-piloting, or by previously 

caching maps

• camera and gimbal are are operational

• wait until aircraft indicator turns green, recording a Home Point via GPS

• calibrate the compass flight location(according to manuals), maintaining 

a good distance from all electromagnetic sources of interference in doing so

• start motors, checking that they are fully functional

• set waypoints with DJI camera app with desired height(never above 400” 

AGL) and speed(never over 15m/s)

• begin takeoff and flight, shooting video and still photos using the DJI 

camera app

• initiate a return to home through the DJI camera app, or toggle remote 

switch to gain control of aircraft if in waypoint plotting auto-pilot

• land over a level flat surface by gently pulling down on the throttle slowly 

to descend, as per training, and then holding throttle at its lowest position for 3 seconds or until motors stop

• turn off the Intelligent Flight Battery, followed by the remote controller 

and/or range extender

14 C.F.R. Part 21, Subpart H: Airworthiness 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 size 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 UAS. In all cases, 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 rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. 

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 inability to carry a substantial external load. 

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 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 UAV, 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 UAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the 

UAV will see the identification of the UAS as “Experimental.” The FAA has issued the 

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 

10167A. 
14 C.F.R. 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 PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, 

the UAS is remotely controlled with no living thing on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance as 

set forth in the Manual. The level of safety provided by the requirements and limitations by the manufacturer of this UAS exceeds that provided by a single individual 

holding a commercial pilot’s certificate operating a conventional aircraft. 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 with a private pilot as the PIC 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 for maintenance 

and use of safety check lists prior to each flight as recommended by the manufacturer, 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 Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. 

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 exemptions to this regulation: Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 

10700. 

14 C.F.R. 91.103: Preflight action 

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

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will 

be provided as set forth in the Manual. The PIC will 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. 

UASs and remotely piloted aircraft, by their design 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 approved exemptions 

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

flight instruction in experimental aircraft. 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 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. As this exemption is for a UAS 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, except for the limited conditions 

stated in the Manual, the UAS will never operate at higher than 400 AGL. It will how-
ever 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 

UAS 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 as set forth in Section K of the Manual. 

Compared to flight operations with aircraft or rotorcraft weighting far more than the 

maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated 

with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL in the movie industry. In addition, the low-altitude 

operations of the UAS will ensure separation between these small- 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 Manual and Safety Check list, confirming the altitude of the launch site shown on 

the GPS altitude indicator before flight. 

14 C.F.R. 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual 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 the UAS provides approximately 40 minutes of powered flight. 

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

limited to approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined 

area, a longer time frame for flight in daylight or night VFR conditions is reasonable. 
Applicant believes that an exemption from 14 CFR §91.151(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 only people and property owners or official representatives 

who have signed waivers will be allowed, 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 10 

minutes would greatly reduce the utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting 

flights to 30 minutes or 25% of battery power 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. 

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. . . . 

(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. As such, 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 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 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 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 the applicant. Maintenance will be accomplished 

by the operator pursuant to the flight manual and operating handbook as referenced 

in the 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 restricted 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 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. 

********* 

Sincerely, 

Paul Pizzica 

Home Course Aerials