January 8, 2016 

Attn:

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590

RE: RAZZE DESIGN LLC REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF UASs 

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Alexander Razze

Owner/Principle 

RAZZE DESIGN LLC

116 Mountain Laurel Drive

Milton, DE 19968

302-329-9055 mobile 302-362-6392

arazze@gmail.com

SHELL DOCKET #: FAA-2007-0001 

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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS: 3 

SUMMARY: 4 

INTRODUCTION AND INTERESTS OF PETITIONER: 4 

BACKGROUND: 4 

BASIS FOR PETITION: 5 

NAME AND ADDRESS OF PETITIONER: 6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH RAZZE DESIGN SEEKS 

EXEMPTION: 7 

THE EXTENT OF RELIEF RAZZE DESIGN SEEKS AND THE REASON RAZZE DESIGN 

SEEKS THE RELIEF: 10 

THE REASONS WHY GRANTING RAZZE DESIGN’S REQUEST WOULD BE IN THE 

PUBLIC INTEREST: 12 

THE REASONS WHY GRANTING THE EXEMPTION TO RAZZE DESIGN WOULD NOT 

ADVERSELY AFFECT SAFETY: 14 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER: 25 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT RAZZE DESIGN’S REQUEST: 25 

CONCLUSION: 25 

APPENDICES: 26

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GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) 

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

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SUMMARY 

Razze Desgin LLC, hereafter referred to as RAZZE DESIGN seeks exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)

(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (UASs)

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This 

exemption will permit RAZZE DESIGN to operate Unmanned Aircraft Systems (UAS) for the 

commercial purpose of conducting aerial video and photography, residential and commercial real 

estate, civil landscapes and events over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

RAZZE DESIGN has been providing clients with multimedia services for the past 4 years. Prior 

to the formation of RAZZE DESIGN, the owner/principal include working with aviation 

companies to produce product marketing and training materials for general aviation markets. The 

objective of RAZZE DESIGN and our UAS [3D Robotics Solo, DJi Phantom 3 (approved grant 

#13052)], [DJi Inspire 1 (approved grant #13055)] aerial operations is to provide a more 

affordable, high-quality production system for a variety of governmental, commercial, public, 

and residential uses, specifically targeting:

• Marketing productions that include aerial and other photography and video 

• Construction sites before and after

• Real-estate marketings 

• Property surveillance, inspection and mapping

• Special event coverage

The owner/principle of RAZZE DESIGN has safely flown small RC electric quadcopters 

recreationally for approximately 2 years without incident. 

BACKGROUND

RAZZE DESIGN seeks an exemption to operate UAS for compensation or hire within the NAS. 

The UASs is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground 

Control Station (GCS) utilizing electronic tablet or smart phone systems. The UASs, each 

weighing less than 10 Lbs. and utilizing flight controllers known and familiar to the FAA – and 

having the required safety features; GPS, loss of signal RTL, GEO fence, low battery RTL, realtime telemetry, OSD, etc. 

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 The sUASs will be equipped with cameras or imagers, stabilizing gimbals and OSD (on screen 

displays) providing the PIC with GPS strength, altitude, airspeed, battery life and direction. Our 

UAS flight controllers utilize GEO fence to limit the altitude above the ground and limit the 

radius of the distance it flies from the PIC. Our UASs have GPS guided failsafe functions 

allowing the autopilot system to fly back to the launch site autonomously. If the transmitter is 

disconnected the system will automatically trigger return to home and will land safely. 

The UAS that will be operated by RAZZE DESIGN will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and 

marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, RAZZE DESIGN, pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, 

Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to 

commercially operate the UASs, UAS in the National Airspace System (NAS), and for an 

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, RAZZE DESIGN operation of UAS meets the conditions of 

FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H. 

Accordingly, RAZZE DESIGN requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)

(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that 

only apply to aircraft with an airworthiness certificate. 

RAZZE DESIGN submits that the requested relief is proper since an equivalent level of safety 

will be ensured. RAZZE DESIGN will use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, 

and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and UASs 

Instruction Manual). Furthermore, RAZZE DESIGN will document and maintain all 

maintenance records for the UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by RAZZE DESIGN to the extent necessary to 

allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an 

airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and 

currency requirements, that the PIC is able to safely operate the UAS in a manner consistent with 

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this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

RAZZE DESIGN seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because 

the UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart 

H. As such, RAZZE DESIGN submits that they will ensure that the UAS is in an airworthy 

condition, prior to every flight, by determining that the UAS are in compliance with the 

operating documents (i.e., Monthly Maintenance Log, and UASs Instruction Manual), and that 

the aircraft are in a condition for safe flight. 

RAZZE DESIGN also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the UAS will not have a typical barometric altimeter onboard. However, 

altitude information of the UAS will be provided to the PIC via Global Positioning System 

(GPS) equipment and radio communications telemetry data link, which downlinks from the UAV 

to the GCS for active monitoring of the flight path. This altitude information, combined with 

RAZZE DESIGN’s operation of the UAS within visual line of sight, at or below 400 feet AGL, 

will ensure a level of safety equivalent to Section 91.121. 

Additionally, RAZZE DESIGN seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. RAZZE DESIGN submits that safety 

will not be affected by operation of the UAS during daylight hours in visual meteorological 

conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total 

duration of approximately 23 minutes. Battery power indicators are also able to show exactly 

how much battery power is left, as well as how much time is needed to return safely back to 

point of take off. 

In accordance with 14 C.F.R. § 11.81, RAZZE DESIGN provides the following information in 

support of its petition for exemption:

A. Name And Address Of The Petitioner. 

The name and address of the Petitioner and point of contact is: 

Alexander Razze

Owner/Principle 

RAZZE DESIGN

116 Mountain Laurel Drive

Milton, DE 19968

302-329-9055 mobile 302-362-6392

arazze@gmail.com

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B. The Specific Sections Of 14 C.F.R. From Which RAZZE DESIGN Seeks Exemption. 

1. RAZZE DESIGN Seeks Exemption From The Requirements Of Section 61.113(a) And 

(b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or hire; 

nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if— 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. RAZZE DESIGN Seeks Exemption From The Requirements Of Section 91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. RAZZE DESIGN Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level 

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating-- 

(1) Below 18,000 feet MSL, to-- 

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate available 

station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 

4. RAZZE DESIGN Seeks Exemption From The Requirements Of Section 91.151(b). 

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Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection 

 (b), states the following: 

(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. 

5. RAZZE DESIGN Seeks Exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft— 

(a) 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[.] 

6. RAZZE DESIGN Seeks Exemption From The Requirements Of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless-- 

(1) It has been approved for return to service by a person authorized under § 43.7 

of this chapter[.] 

7. RAZZE DESIGN Seeks Exemption From The Requirements Of Sections 91.409(a)(1) 

And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had -- 

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. RAZZE DESIGN Seeks Exemption From The Requirements Of Sections 91.417(a) And 

91.417(b). 

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Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods specified 

in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include-- 

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft 

for return to service. 

 (2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. 

(iii)The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis. 

(iv)The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the aircraft 

and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, 

and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

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(1) The records specified in paragraph (a)(1) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief RAZZE DESIGN Seeks And The Reason RAZZE DESIGN Seeks 

The Relief. 

1. Extent Of Relief RAZZE DESIGN Seeks And The Reason RAZZE DESIGN Seeks Relief 

From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher 

level certificate, as well as a current and valid airman medical certificate, and who has met 

certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for 

compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a 

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if: (1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

As set forth more fully below, RAZZE DESIGN submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the UAS unless that PIC has met 

certain flight-hour and currency requirements, demonstrating that the PIC is able to safely 

operate either the UAS in a manner consistent with the operations specifications as described in 

this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Further, RAZZE DESIGN submits that all flights of the UAS, conducted by the PIC pursuant to 

the grant of this Petition: (1) will be incidental to RAZZE DESIGN’s business; and (2) will not 

carry passengers or property for compensation or hire. 

2. Extent Of Relief RAZZE DESIGN Seeks And The Reason RAZZE DESIGN Seeks Relief 

From Section 91.7(a). 

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Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow RAZZE DESIGN to determine that the UAS are in airworthy condition prior to 

every flight by ensuring that the UAS is in compliance with the operating documents (i.e., 

RAZZE DESIGN Aerial Operations Manual, Monthly Maintenance Log, and UASs Instruction 

Manual). 

RAZZE DESIGN seeks the requested relief because the UAS do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, RAZZE DESIGN will 

ensure that the UAS are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and UASs) prior to every flight, and further, 

determine that the aircraft are in condition for safe flight, as stated in the conditions and 

limitations below. 

3. Extent Of Relief RAZZE DESIGN Seeks And The Reason RAZZE DESIGN Seeks Relief 

From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the PIC at 

the ground control station (GCS). Since the FAA requires that any altitude information 

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level 

(AGL), RAZZE DESIGN seeks the requested relief because the UASs UA’s altimeter may be set 

on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before 

each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought 

to the extent necessary to comply with the applicable conditions and limitations stated below. As 

more fully set forth herein, an equivalent level of safety will be maintained since the UAS are 

equipped with a barometric pressure sensor and GPS equipment, which automatically ensures 

that a ground level pressure setting will be established prior to each flight, and provides the PIC 

with altitude information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief RAZZE DESIGN Seeks And The Reason RAZZE DESIGN Seeks Relief 

From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered UAS during daylight 

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total 

duration of 23 minutes. RAZZE DESIGN seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered UAS will 

12
severely constrain the practicality of any aerial video or still photo flight operations that RAZZE 

DESIGN proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the UAS, the UASs operating 

documents, and RAZZE DESIGN’s proposed operating limitations, ensure that RAZZE 

DESIGN will safely operate the battery powered UAS during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to 

fly for a total duration of 23 minutes. 

5. Extent Of Relief RAZZE DESIGN Seeks And The Reason RAZZE DESIGN Seeks Relief 

From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, RAZZE DESIGN requests relief from these Sections 

because the UAS do not require airworthiness certificates. As set forth more fully below, the 

UAS meet the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, RAZZE DESIGN will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the UAS operating documents (i.e., the RAZZE DESIGN Aerial Operations 

Manual, Monthly Maintenance Log, and UASs Instruction Manual). Furthermore, RAZZE 

DESIGN will document and maintain all maintenance records for the UAS. 

D. The Reasons Why Granting RAZZE DESIGN Request Would Be In The Public Interest; 

That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing RAZZE DESIGN to 

safely, efficiently, and economically perform aerial video and photography of construction sites, 

real estate, events and civic landscape over certain areas of the United States. 

Additionally, use of the UAS will decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of RAZZE DESIGN’s proposed 

operation of the UAS will be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The UAS are battery powered and serve as a safe, efficient, and economical alternative to the 

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of 

manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a UAS 

13
would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well 

as increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced. The UAS do not 

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial 

video and photography missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The UAS. 

Conducting aerial acquisitions with the UAS, instead of manned aircraft, will greatly benefit the 

public by drastically reducing the levels of air and noise pollution generated during traditional 

aerial video and still photography flight operations. By using battery power and electric motors, 

the UAS produce no air pollution, and is the most viable environmentally conscious alternative 

to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for 

aerial video and photography, while burning approximately 20-30 gallons per hour of leaded 

aviation fuel. The UAS, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather 

than an internal combustion engine. 

By using the UAS to perform aerial acquisitions, the substantial risk to life and property in the 

air and on the ground, which is usually associated with traditional manned aircraft flight 

operations, will be substantially reduced or completely eliminated. Aside from the lack of flight 

crew members located onboard the aircraft, the UAS (weighing approximately 2.8 pounds at 

their maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on board), 

has less physical potential for collateral damage to life and property on the ground, and in the air, 

compared to the manned aircraft that typically conduct similar operations (weighing 

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a 

fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The UAS Will Benefit The 

Economy. 

In addition to being safe and efficient, the UAS are also an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such, operation of the UAS will allow 

United States based companies, like RAZZE DESIGN, to remain competitive and contribute to 

growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, 

U.S. owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered UAS is one such technology that not only 

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allows companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft. 

By operating the UAS, companies such as RAZZE DESIGN, can remain competitive and 

profitable, and therefore, provide greater job stability to employees and contractors, which will 

ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of the UAS, provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows companies to 

invest in research and development in order to remain competitive both in the United States and 

abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

RAZZE DESIGN’s proposed operation of the UAS will not implicate any privacy issues. 

Specifically, the UAS will be operated only in compliance with operating documents (i.e., 

RAZZE DESIGN Aerial Operations Manual, Monthly Maintenance Log, and UASs Instruction 

Manual) which requires property owner involvement as well as local law enforcement 

notification, and in accordance with the Federal Aviation Regulations, including the minimum 

altitude requirements of 14 C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How 

The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The 

Rule From Which RAZZE DESIGN Seeks Exemption. 

1. Reasons Why The UAS Meet The Conditions Of The FAA Modernization and Reform 

Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, RAZZE DESIGN’s operation of the UAS meet the 

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets 

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the 

following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the 

15
national airspace system before completion of the plan and rulemaking required by 

section 332 of this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum-- 

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to users 

of the national airspace system or the public or pose a threat to national 

security; and 

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems identified 

under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this section 

that certain unmanned aircraft systems may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such 

aircraft systems in the national airspace system. 

In seeking this exemption, RAZZE DESIGN submits that the UAS can operate safely in the NAS 

pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the UAS; (b) the 

pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The UAS Demonstrate Its Safe Characteristics. 

The UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to 

national security considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The UAS. 

The technical specifications of the UAS are set forth by the UASs User Manual, attached hereto 

as Appendix A. 

ii. The UAS Global Positioning Modes Enable The UAS To Remain Within A Defined 

Operational Area. 

The UAS may be operated in both manual and global positioning flight modes. A complete 

description of the flight and navigational modes of the UAS is provided at pages 11 of the UASs 

User Manual attached hereto as Appendix A. 

iii. The UAS Are Designed For Automatic Return To Home Point Or Hover In The Event 

Of Loss Of The Control Link Or Navigation. 

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When the Control Link is lost, the UAS will remain stationary, in flight, for 3 seconds or more. 

If, after 3 seconds, the UAS does not reacquire control link data from the GCS, the UAS will 

assume that the Control Link is lost and the will return to the home position (i.e., failsafe mode) 

via GPS, and will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the UAS are set forth at pages 12 through 14 

of the UASs User Manual, attached hereto as Appendix A. 

iv. The UASs GCS And Its Operation. 

A complete description of the operation and specifications of the UASs GCS and flight control 

software is provided at pages 23 through 29 of the UASs User Manual. UASs User Manual is 

attached hereto as Appendix A. 

b. Flight Operations Of UAS Is Limited To The Line Of Sight Of A Certificated Pilot in 

Command With A Safety Observer. 

RAZZE DESIGN video production staff will be the only persons to act as a pilot in command 

(PIC) of the UAS. Additionally, a safety observer will assist him at all times during flight time. 

c. Flights Of UAS Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, RAZZE DESIGN proposes to commercially operate UAS for the 

special purpose of conducting aerial video and photography over certain areas of United States, 

pursuant to the following specific operating limitations. 

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UAS weighing less than 55 

pounds maximum gross weight: UASs Unmanned Aircraft Systems. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

grant. 

2. UAS operations under this exemption will be limited to conducting operations for 

the purpose of aerial video and photography. 

 3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents unless a 

special request is made and approved by ATC. All altitudes reported to ATC must be in 

feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any device 

17
other than corrective lenses, as specified on the PIC’s FAA-issued airman medical 

certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. The SO 

and PIC must be able to communicate verbally at all times. Electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. The 

PIC must ensure that the SO can perform the functions prescribed in the operating 

documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant of 

exemption and the procedures outlined in the operating documents, the conditions and 

limitations contained in the grant of exemption take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator upon request. The operator must also present updated 

and revised documents if it petitions for extension or amendment to the grant of 

exemption. If the operator determines that any update or revision would affect the 

basis upon which the FAA granted the exemption, then the operator must petition for 

amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) 

may be contacted if questions arise regarding updates or revisions to the operating 

documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition 

for safe flight. If the inspection reveals a condition that affects the safe operation of the 

UAS, the aircraft is prohibited from operating until the necessary maintenance has 

been performed and the UAS is found to be in a condition for safe flight. The Ground 

Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, must 

18
undergo a functional test flight. The PIC who conducts the functional test flight must 

make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the UAS 

in a manner consistent with how the UAS will be operated under the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours must be 

logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of 

training the operator’s PICs are permitted under the terms of the exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. 

All operations must be conducted under visual meteorological conditions (VMC). If 

flight at night is required, a special request will be made at the FAA office closest to 

proposed area of operations. Flights under special visual flight rules (SVFR) are not 

authorized. 

19
20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of 

agreement with the airport management must be made available to the Administrator 

upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies 

in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising speed to 

the intended landing point and land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. All operations shall be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be 

as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the Federal Communications Commission (FCC) 

or other appropriate government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to 

the PIC at the Ground Control Station of the UAS any time the UAS is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request. 

20
29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/

controller of such vessels, vehicles or structures has granted permission and the 

PIC has made a safety assessment of the risk of operating closer to those 

objects and determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do 

not present an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will be obtained for each 

flight to be conducted. 

 33. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) 

Would Not Adversely Affect Safety. 

RAZZE DESIGN submits that the equivalent level of safety established by Section 61.113(a) 

and (b) will be maintained because no PIC will be allowed to operate the UAS unless that PIC 

has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is 

able to safely operate the UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. 

21
Considering RAZZE DESIGN’s proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of 

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary 

to safely operate the UAS, RAZZE DESIGN submits that the additional manned airmanship 

experience of a commercially certificated pilot would not correlate to the airmanship skills 

necessary for RAZZE DESIGN’s specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11158, 11159, 11160, 11161). 

RAZZE DESIGN will not allow any PIC to operate the UAS unless that PIC has demonstrated, 

by meeting minimum flight-hour requirements or the UAS training and currency requirements, 

that the PIC is able to safely operate the UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those 

hours as a UAS pilot operating the same make and model of UAS to be used for operations under 

the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety 

during RAZZE DESIGN’s proposed operations. The Administrator has held that prior 

documented flight experience that was obtained in compliance with applicable regulations would 

ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a 

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor 

UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make 

and model of UAS to be used for operations under the exemption. For clarification, the 

FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 

5 hours make and model time may be included in the 10 hours of multi-rotor time and the 

10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the 

hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

days (for currency purposes). The FAA finds that at a minimum, the flight-hour 

22
requirements in Exemption No. 11062 are appropriate to practice and build proficiency in 

the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also 

finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experience-building 

flights the PIC is required to operate the UA with appropriate distances in accordance 

with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, RAZZE DESIGN will ensure safe operations by not allowing any PIC to operate 

the UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, RAZZE DESIGN will ensure that the UAS is in an airworthy condition based upon 

the UAS’s compliance with its operating documents and as stated in the conditions and 

limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained because the 

altitude information of the UAS will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of the flight path and altitude. This altitude information, combined with RAZZE 

DESIGN’s operation of the UAS within visual line of sight, at or below 500 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. The altitude information will be generated 

23
by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation 

point is automatically established by the UAS at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) as a result of (1) the technical specifications of the UAS; (2) the limitations on 

the proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, RAZZE DESIGN will ensure that it will safely operate the battery powered UAS 

during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 

23 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the UAS; the limitations on the 

proposed flight operations; and the location of the proposed operations, will ensure an equivalent 

level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as 

the UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences 

low battery voltage, the first warning occurring at approximately 33% remaining battery power, 

and again at approximately 10% remaining battery power. At the critically low battery level, the 

UAS will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. Relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely 

Affect Safety. 

24
In seeking this exemption, RAZZE DESIGN submits that the equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because RAZZE 

DESIGN will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the 

operating documents (i.e., RAZZE DESIGN Aerial Operations Manual, Monthly Maintenance 

Log, and UASs Instruction Manual). Furthermore, RAZZE DESIGN will document and maintain 

all maintenance records for the UAS. 

Since the UAS will be inspected as prescribed by the operating documents, RAZZE DESIGN 

will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 

91.409(a)(2). A copy of the UASs User Manuals are attached hereto as Appendix A and B; a 

copy of the UAS Maintenance LOG is attached hereto as Appendix C. 

Likewise, the exemption sought will not adversely affect safety because RAZZE DESIGN will 

use trained technicians to perform maintenance, alterations or preventive maintenance on the 

UAS using the methods, techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety established by 

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the UAS will be 

performed by trained technicians. Maintenance will be documented and maintained utilizing the 

monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)

(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected 

when the technical characteristics and operating limitations of the UAS are considered. 

In consideration of RAZZE DESIGN’s proposed operating limitations, the operating documents, 

and the technical aspects of the UAS, RAZZE DESIGN submits that safety will not be adversely 

affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 

91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 

14 C.F.R. § 21.16 entitled Special Conditions, RAZZE DESIGN requests that the FAA prescribe 

special conditions for the intended operation of the UAS, which contain such safety standards 

that the Administrator finds necessary to establish a level of safety equivalent to that established 

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will 

25
permit safe operation of the UAS for the limited purpose of conducting aerial video and 

photography over certain areas of the United States for compensation or hire. FMRA Section 333 

sets forth the requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification in accordance with any 

requirements that must be established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not 

contain adequate or appropriate safety standards, due to the novel or unusual design features of 

the aircraft. Section 21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations. 

See 14 C.F.R. § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe 

special conditions for Leading Edge’s intended operation of the UAS, which contain such safety 

standards that the Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

 • A Summary That Can Be Published In The Federal Register, stating: The 

Rules From Which RAZZE DESIGN Seeks Exemption: 

RAZZE DESIGN seeks exemption from the requirements of 14 C.F.R Sections 

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)

(2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption RAZZE DESIGN Seeks: 

This exemption will permit RAZZE DESIGN to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video and photography over 

certain areas of the United States. 

 • Any Additional Information, Views, Or Arguments Available To Support 

RAZZE DESIGN’s Request. 

26
This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS 

may operate safely in the NAS. As such, RAZZE DESIGN’s request for exemption may be 

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, RAZZE DESIGN will operate the UAS safely in the NAS, without 

creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national 

security. 

CONCLUSION 

As set forth herein, RAZZE DESIGN seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the UAS commercially, without an airworthiness certificate, for the limited purpose 

of conducting aerial video and photography over certain areas of the United States. By granting 

this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public, by 

allowing RAZZE DESIGN to safely, efficiently, and economically operate the UAS 

commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, RAZZE DESIGN respectfully requests that 

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R 

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)

(2), and 91.417(a) & (b), and permit Leading Edge to operate the UAS commercially for the 

purpose of conducting aerial video and photography over certain areas of the United States.

Respectfully submitted, 

Alexander Razze

Owner/Principle 

RAZZE DESIGN

116 Mountain Laurel Drive

Milton, DE 19968

302-329-9055 mobile 302-362-6392

arazze@gmail.com

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Appendices: 

A – Links to UAS Manuals:

https://3drobotics.com/wp-content/uploads/2015/11/v8_11_20_15.pdf

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual__V1.6.pdf

https://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_en_v2.0_1218.pdf

28