## FAA 333 UAS EXEMPTION PETITION

Bradley William Draifinger August 10 , 2015

U.S. Department of Transportation Docket Management Syst em

1200 New Jersey Avenue

SE

, Washington DC 20590

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, Bradley Draifinge r, operator of
Sma ll Unmanned Aircraft Systems (“s UAS”) equipped to conduct aerial videography and photography for the motion picture, television, and commercial industry for closed set filming, hereby applies for an exempt ion from the listed Federal Aviation Regulations (“FARs”) to all ow commercial operation of its s UAS, so long as such operations are conducted within a nd unde r the conditions outlined herein or as may be establis hed by the FAA as required by Section 333.

I hereby request exemption so that I may operate a Phant om 3 that is under 3 pounds and operates on a frequency of 2.400

- 2.483GHz as well as the DJI Inspire 1 that is under 7 pounds and operates on the frequency of 2.400

- 2.483GHz and7.725

- 5.825GHz to provide services for profit, including aerial photography, aerial videography and cinematography, aerial fil ming and photography for real estate, aerial mapping, a nd aerial photography and videography for special events to include but not limited to weddings, private or public parties/events, business advertisement(s), promotiona l events, environmental studies, and sports events as well as live feed video service fo r public events.

Prior to each flight, the UAS will be inspected to ensure that it i s in a condition safe for flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft will be grounded and prohibited from

opera ting until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, controllers, monitors as well as the area of flight are to be included in the preflight inspection. All maintenan ce and alterations must be properly

## FAA 333 UAS EXEMPTION PETITION

documented in the aircraft records.

To continue to provide the best and safest service p ossible I will continue training using flight simulators as well as hands on training with said UAS in a controlled area and areas away from the public. Any other person or persons that may become an operator or (PIC) will train in this same

manner.

I, Bradley Draifinger , will be the initial sole operator of said UAS and will be the (PIC) for the entire duration of operation(s) of s aid UAS. I will not let any other person operate any UAS until they have reached a level of competence to control and operate safely as well as being granted their own
333 ex emption . Flight Operations above one hundred feet (100 ft.) will be avoided or minimized when possible when performed directly above any person(s). Operations will also be done in a (VLOS) manner at all times.

The intent of my request is so that I may start a fo r profit business that provides aerial photography and videography to the general public and to private business. If required I can provide a copy or copies of my valid Drivers License or other documentation if required in order to complete the review and/or approval process of my request.

As described more fully below, the requested exemptio n would permit the operation of small, unmanned and relatively inexpensive s UAS under controlled conditions in the NAS that is 1) limited 2) predet ermined 3) controlled as to access. Approval of this exemption would thereby enh ance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish re quirements for the safe operation of such aircraft systems in the national airspace system .” Section 333(c) of the Reform Act.

___________________________________________________ The name and address of the applicant is:

Bradley William Draifinger

Tel : (215) 584

- 1917

Email: BradleyDraifinger@gmail.com

## FAA 333 UAS EXEMPTION PETITION

Address: 370 Manhattan Avenue Apt. 4K New York, NY 10026

_ __________________________________________________ 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 CF R 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of the Re form Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraf t systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the R eform Act.
In m aking this determination, the Secretary is required t o determine which types of sUAS do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The sUAS size, weight, speed, and operational ca pability;

• Operation of the sUAS in close proximity to airports an d populated areas

• Operation of the sUAS within visual line of sight of th e operator. Reform Act § 333 (a). Lastly, if the Secretary determines th at such vehicles “may operate safely in the national airspace system, the Secretar y shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis added). The Federal Aviation Act expressly grants the FAA the authority to issue exempt ions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, that includes sUAS, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrato r may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 US C §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). Bradley Draifinger owns a DJI Inspire 1 & DJI Phantom 3 Professional sUAS rotorcraft, we igh ing 55 lbs. or less including payload. They operate, under normal conditions

## FAA 333 UAS EXEMPTION PETITION

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 o nly within a predetermined and closed off property area under the permission of the property represent ative. Such operations will insure that the sUAS will “not create a hazard to users of the national a irspace system or the public. Such operations will insure that the sUAS will “not create a hazard to users of the national airspace system or the public” as pe r the Reform Act Section 333 (b).

G iven the small size of the sUAS involved and the restricted sterile environment within which they will operate, the applicant falls sq uarely within that zone of safety (an equivalent level of s afety) in which Congress

env isioned that the FAA must, by exemption, allo w commercial operations of sUAS to commence immediately. Also due to the size of the sUAS and the restricted a reas in which the relevant sUAS will operate, approval of the application presents no national securi ty 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 sUAS for movie and commercial videography operations, the grant of the requested exemptions is in the public interest. Accordingly, the applicant (Bra dley Draifinger) respectfully requests that the FAA grant the requested exemption wi thout delay.

AIRCRAFT AND EQUIVALENT LEVEL OFSAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and t hat 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 structur e because the proposed operations are conducted on closed off property under the permission of the property owner or property representative.

These limitations and conditions to which Bradley Draifinger agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less tha n 55 lbs.

## FAA 333 UAS EXEMPTION PETITION

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

3. Maximum total flight time for each operational fligh t will be 30 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minu te limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated platform from which filming is planned.

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

6. sUAS Pilot will be Pilot in Command (PIC). If the PIC deem s another operator to be qualified with the necessary skills to be PIC, that person can also be designated as PIC provided they have a minimum of 40 hours of flight time with the sUAS.

7. Flights will be operated at a lateral distance of at least 5 0 feet from any inhabited structures, buildings, vehicles, vessels, or people not associated with the operation or who have not signed a waiver in advance of the operation.

8. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s production activities. It will be mandatory that all personnel involved with the operational duties of the flight within the boundaries of the safety perimeter be present for this briefing.

9

. The operator will obtain the consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and this ra dius may be reduced to 30 feet based upon an equivalent level of s afety determination. With the advanced permission of the relevant FSDO, o perations at closer range can be approved

10 . The operator will file an FAA Form 7711

- 1, or its equivalent, as modified in light of the requested exemption, with the Flight Standards District Office ("FSDO").

11 .Pilot and observer will have been trained in operation of sUAS generally and received up

- to

- date information on the particular sUAS to be

## FAA 333 UAS EXEMPTION PETITION

operated.

12 . The pilot

, Bradley Draifinger, has been fly ing RC multi

- rotor systems fo r 4 years and is considered to have advanced expertise on piloting, maintenance and safety concerns.

13 .Observer and pilot will at all times be able to communicate by voice, radio, and/or text.

14 .Written and/or oral permission from the relevant property holders or property representatives will be obtained.

15 .All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement

, fire, or other appropriate governmental agencies.

16 .I f the sUAS loses communications or loses its GPS signal, the sUAS wil l have the capability to return to a pre

- determined location within the Security Perimeter and land autonomously.

17 .The sUAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.

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 certifi cates as required by FAR §91.203 (a) (1). Given the size and limited operating area associa ted 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 bo th 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 sUAS. In al l cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restrict ed 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 airworthin ess certificate without the restrictions and conditions proposed.

## FAA 333 UAS EXEMPTION PETITION

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or fl ammable liquid fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the require ments and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional filming. The FA A will have advance notice of all operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworth iness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, app lication of these same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, speed of operation, locati on of operation, lack of explosive materials or flammable liquid fuels, a nd 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 numbe r 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 t han 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable.

Even though the sUAS will have no airworthiness certi ficate, an exemption may be needed as the sUAS will have no e ntrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAV, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29(f ).

The equi valent level of safety will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and othe rs working with the sUAS will see the identification of the sUAS as “Experimental.” The FAA has issued the following

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

## FAA 333 UAS EXEMPTION PETITION

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 .
Be cause the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operat ions by requiring the PIC operating the aircraft to have no less than 40 hours of flight time with the sUAS. Unlike a c onventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all f lights are planned and coordinated in advance.

14 C.F.R. §91.7(a): Civi l 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 regulat ory

s tandard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists prior to each flight, as set forth in Sections J, L and Q, an equivalent level of safety will b e provided.

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

Section 91.9 (b) (2) pr ovides: No person may operate a U.S.

- registered civil aircraft...

(2) For which an Airplane or Rotorcraft Flight Manual is n ot required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Ma nual, approved manual material, markings, and placards, or any combinationthereof.

The sUAS, given its size and configuration has no abi lity or place to carry such a flight manual on the aircraft, not only because there is no pil ot 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 fl ying the sUAS will have immediate access to it. The FAA has iss ued the following exemptions to this

## FAA 333 UAS EXEMPTION PETITION

regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9 299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to ta ke certain action s before flight to insure the safety of flight. As FAA approved rotorcraft fl ight manuals will not be provided for the aircraft an exemp tion will be needed. The PIC will take all actions including reviewing weat her, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction:

5

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight i nstr uction unless that aircraft has fully functioning dual controls.

sUASs and remotely piloted aircraft, by their design do not have fu lly functional dual controls. Flight control is accomplished through the use of a control box that communicates with the ai rcraft viaradio communications. The FAA has approved exemptions for flight training w ithout fully functional dual controls for a number of aircraft and for flight inst ruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equiv alent level o f 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 aircr a ft. 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 helicopte rs by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption request s authority to operate at altitudes up to 400 AGL, or not mor e 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 sUAS will never operate at higher than 400 AGL with the exception that in circumstances where the sUAS is used to survey or photograph a struc ture whose height exceeds 400 feet AGL, the sUAS will not be operated more than 100' above

## FAA 333 UAS EXEMPTION PETITION

the highest point on the structur e. It 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 give n the size, weight, speed of the sUAS 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 indiv iduals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed here in and the lack of flammable fuel, any risk associated with these operations is f ar les s 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 sUAS will ensure separation between these small - UAS operations and the operations of conventio nal aircraft that must comply with Section91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an ai rcraft 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 sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An e quivalent level of safety will be achieved by the operator,

pur suant to the safety check list and live flight data monitoring, confi rming 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 VFRConditions

Section 91.151 (a) prohibit s 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 t he 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 sUAS provides approximately 30 minutes of powered flight. Tomeet the30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in

## FAA 333 UAS EXEMPTION PETITION

length. Given the limitations on the sUAS’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 co nditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.1 51(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance wit h FAR 91.151 (a)). Operating the sma ll UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers wi ll be allowed, with less than 30 minutes of reserve fuel, does not engender t he type of risks that Section 91.151(a) was intend ed to alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flight s to 10 minutes would greatly reduce the utility for which the exemption will be granted.

Applicant believes that an equivalent level of safet y 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 sUAS 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 airw orthiness 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 sUAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no a bility or place to carry certification and registration documents or to display them on the sUAS.

## FAA 333 UAS EXEMPTION PETITION

An equivalent level of safety will be achieved by kee ping these documents at the ground control point where the pilot flying the sUAS will have immediate acc ess to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 97 89, 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, exc ept 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 Part43.

Given that these section and Part 43 apply only to a ir craft with an airworthiness certificate, these sections will not apply to the applicant

. Maintenance will be accomplished by the operator pur suant to the flight manual and operating handbook. An equivalent level of safety will be achieved because these sma ll 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 sUAS can land immediat ely and will be operating from no higher than 400 feet AGL. The operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance perfor med. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircra ft in an airworthy condition to provide the equivalent level of safety.

An equivalent level of safety will be achieved becaus e maintenance and inspections will be performed in accordance with the sUAS Manufacturer's Manual, as referenced in the Aircra ft OperationsManual. As provided in the Operations Manual, the operator will ensure that the sUAS is in working order prior to initiating flight and perform required maintenance needed.

## FAA 333 UAS EXEMPTION PETITION

Additional V iews & Information :

I have been directly involved in piloting RC vehicles for 4 years and have been a camera operator for the film /TV industry for 2 of those years. I’ve been working my way through the ranks of the TV industry in NYC and am seriously devoted and passionate about my craft. Safety is always my main concern as it’s always a priority when on set or location. I work in a highly professional manner and conduct my piloting skills with the utmost focus.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publ ication in the Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7(a); 91.9 (b) (2);91.103(b);91.109; 9 1.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in mot ion picture, television, and commercial videography operation s.

Approval of exemptions allowing commercial operations of sUASs in the film industry will enhance safety by reducing risk. Conventional fi lm operations, using jet or piston power aircraft, operate at extremel y low altitudes just feet from the subject be ing filmed and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of 4,000lbs., carrying lar ge amounts of jet A or other fuel (140 gallons for jet helicopters.) Such aircraft must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. T he sUAS is carried to the film set. The s UAS will carry no passengers or crew and, therefore, wil l not expose them to the risks associated with manned aircraft flights

. The operation of small UASs, weighting less than 55 l bs., conducted in the strict conditions outlined above, will provide an eq uivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowi ng commercial operations. These lightweight aircraft operate at slow speeds, close to the ground but under 400 feet AGL, and in a sterile environment

## FAA 333 UAS EXEMPTION PETITION

and, as a result, are far safer than conventional flight operations conduct ed with turbine helicopters operating in close proximity to the ground and people.

Privacy :

All flights will occur over private or controlled access property with the property representative or owner’s prior consent and knowledge. Filming will be of people who have also consented to being fi lmed or otherwise have agreed to be in the area where filming will take place.

All flights will occur in accordance with any state or local laws regarding privacy.

Satisfaction of the criteria provided in Section 333 of the Reform Act of
2012

-- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security
– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s sUAS in the motion picture, television, and commercial videography industry.

Any questions or requests for additional information, pl ease contact the undersigned at (215) 584

- 1917 or at BradleyDraifinger@gmail.com

Sincerely,

Bradley Draifinger

sUAS Pilot/Operator