FAA 333 UAS EXEMPTION PETITION 

Bradley William Draifinger August 10, 2015 

U.S. Department of Transportation Docket Management System 

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 Draifinger, operator of 

Small Unmanned Aircraft Systems (“sUAS”) equipped to conduct aerial 

videography and photography for the motion picture, television, and 

commercial industry for closed set filming, hereby applies for an exemption 

from the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its sUAS, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as 

required by Section 333. 

I hereby request exemption so that I may operate a Phantom 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 filming 

and photography for real estate, aerial mapping, and aerial photography and 

videography for special events to include but not limited to weddings, 

private or public parties/events, business advertisement(s), promotional 

events, environmental studies, and sports events as well as live feed video 

service for public events.

Prior to each flight, the UAS will be inspected to ensure that it is 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 

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, 

controllers, monitors as well as the area of flight are to be included in the 

preflight inspection. All maintenance and alterations must be properly 
FAA 333 UAS EXEMPTION PETITION 

documented in the aircraft records.

To continue to provide the best and safest service possible 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 said 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 exemption. 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 for 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 exemption would permit the 

operation of small, unmanned and relatively inexpensive sUAS under 

controlled conditions in the NAS that is 1) limited 2) predetermined 3) 

controlled as to access. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “...establish requirements for the safe 

operation of such aircraft systems in the national airspace system.” Section 

333(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 CFR 417 (a) & 

(b) 

This exemption application is expressly submitted to fulfill Congress’ goal 

in passing Section 333(a) through (c) of the Reform Act. This law directs the 

Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. 

In making this determination, the Secretary is required to 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 capability; 

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

• Operation of the sUAS within visual line of sight of the operator. Reform 

Act § 333 (a). Lastly, if the Secretary determines that such vehicles 

“may operate safely in the national airspace system, the Secretary 

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 

exemptions. 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 Administrator 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 USC §44711(a); 49 USC 

§44704; 14 CFR §91.203 (a) (1). Bradley Draifinger owns a DJI 

Inspire 1 & DJI Phantom 3 Professional sUAS rotorcraft, weighing 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 only within a 

predetermined and closed off property area under the permission of 

the property representative. Such operations will insure that the sUAS 

will “not create a hazard to users of the national airspace 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 per 

the Reform Act Section 333 (b). 

Given the small size of the sUAS involved and the restricted sterile 

environment within which they will operate, the applicant falls squarely 

within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations 

of sUAS to commence immediately. Also due to the size of the sUAS and 

the restricted areas in which the relevant sUAS will operate, approval of the 

application presents no national security issue. Given the clear direction in 

Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended; the strong equivalent level of safety surrounding 

the proposed operations, and the significant public benefit, including 

enhanced safety, reduction in environmental impacts, including reduced 

emissions associated with allowing sUAS for movie and commercial 

videography operations, the grant of the requested exemptions is in the 

public interest. Accordingly, the applicant (Bradley Draifinger) respectfully 

requests that the FAA grant the requested exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OFSAFETY 

The applicant proposes that the exemption requested herein apply to civil 

aircraft that have the characteristics and that operate with the limitations 

listed herein. These limitations provide for at least an equivalent or even 

higher level of safety to operations under the current regulatory structure 

because the proposed operations 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 than 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 flight will be 30 minutes. 

Flights will be terminated at 25% battery power reserve should that 

occur prior to the 30 minute 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 deems 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 50 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 radius may be reduced 

to 30 feet based upon an equivalent level of safety determination. 

With the advanced permission of the relevant FSDO, operations 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 flying RC multi-rotor systems 

for 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.If the sUAS loses communications or loses its GPS signal, the sUAS will 

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 certificates as required by 

FAR §91.203 (a) (1). Given the size and limited operating area associated 

with the aircraft to be utilized by the Applicant, an exemption from Part 21 

Subpart H meets the requirements of an equivalent level of safety under Part 

11 and Section 333 of the Reform Act. The Federal Aviation Act (49 

U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the 

FAA to exempt aircraft from the requirement for an airworthiness certificate, 

upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular sUAS. In all 

cases, an analysis of these criteria demonstrates that the sUAS operated 

without an airworthiness certificate, in the restricted environment and under 

the conditions proposed will be at least as safe, or safer, than a conventional 

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

without the restrictions and conditions proposed. 
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 flammable 

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 requirements and in 

compliance with local public safety requirements, to provide security for the 

area of operation as is now done with conventional filming. The FAA 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 airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of 

these same criteria demonstrates that there is no credible threat to national 

security posed by the sUAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and 

inability to carry a substantial external load. 

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

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration 

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

experimental or provisionally certificated aircraft, the operator must also 

display on that aircraft near each entrance to the cabin, cockpit, or pilot 

station, in letters not less than 2 inches nor more than 6 inches high, the 

words "limited," "restricted," "light-sport," "experimental," or "provisional," 

as applicable. 

Even though the sUAS will have no airworthiness certificate, an exemption 

may be needed as the sUAS will have no entrance 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 equivalent 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 others 

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 . 

Because the sUAS will not carry a pilot or passengers, the proposed 

operations can achieve the equivalent level of safety of current operations by 

requiring the PIC operating the aircraft to have no less than 40 hours of 

flight time with the sUAS. Unlike a conventional 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 flights 

are planned and coordinated in advance. 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is 

in airworthy condition. As there will be no airworthiness certificate issued 

for the aircraft, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness. Given the size of the 

aircraft for maintenance and use of safety check lists prior to each flight, as 

set forth in Sections J, L and Q, an equivalent level of safety will be 

provided. 

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

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

aircraft... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by 

§21.5 of this chapter, unless there is available in the aircraft a current 

approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combinationthereof. 

The sUAS, given its size and configuration has no ability or place to carry 

such a flight manual on the aircraft, not only because there is no pilot on 

board, but because there is no room or capacity to carry such an item on the 

aircraft. 

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

manual at the ground control point where the pilot flying the sUAS will have 

immediate access to it. The FAA has issued the following exemptions to this 
FAA 333 UAS EXEMPTION PETITION 

regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 

10167, 10167A, 10602, 32827, and 10700. 

14 C.F.R. § 91.103: Preflight action 

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

flight to insure the safety of flight. As FAA approved rotorcraft flight 

manuals will not be provided for the aircraft an exemption will be needed. 

The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data 

before initiation of flight. 

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

5 

Section 91.103 provides that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that 

aircraft has fully functioning dual controls. 

sUASs and remotely piloted aircraft, by their design do not have fully 

functional dual controls. Flight control is accomplished through the use of a 

control box that communicates with the aircraft viaradio communications. 

The FAA has approved exemptions for flight training without fully 

functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent 

level of safety provided by the fact that neither a pilot nor passengers will be 

carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. 

Section 91.119 (d) allows helicopters to be operated at less than the 

minimums prescribed, provided the person operating the helicopter complies 

with any route or altitudes prescribed for helicopters by the FAA. As this 

exemption is for a sUAS that is a helicopter and the exemption requests 

authority to operate at altitudes up to 400 AGL, or not more than 200 above 

an elevated platform from which filming is planned, an exemption may be 

needed to allow such operations. As set forth herein, the 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 structure 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 structure. 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 given 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 individuals will be aware of the planned flight 

operations. Compared to flight operations with aircraft or rotorcraft

weighting far more than the maximum 55lbs. proposed herein and the lack 

of flammable fuel, any risk associated with these operations is far less than 

those presently presented with conventional aircraft operating at or below 

500 AGL in the movie industry. In addition, the low-altitude operations of 

the sUAS will ensure separation between these small- UAS operations and 

the operations of conventional aircraft that must comply with Section91.119. 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain 

cruising altitude by reference to an altimeter that is set “...to the elevation of 

the departure airport or an appropriate altimeter setting available before 

departure.” As the sUAS may not have a barometric altimeter, but instead a 

GPS altitude read out, an exemption may be needed. An equivalent level of 

safety will be achieved by the operator, 

pursuant to the safety check list and live flight data monitoring, confirming 

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

flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFRConditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an 

airplane under VFR conditions unless (considering wind and forecast 

weather conditions) there is enough fuel to fly to the first point of intended 

landing, and, assuming normal cruising speed – (1) During the day, to fly 

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

45 minutes.” 

The battery powering the 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 conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within 

the scope of prior exemptions. See Exemption 10673 (allowing Lockheed 

Martin Corporation to operate without compliance with FAR 91.151 (a)). 

Operating the small UAS, in a tightly controlled area where only people and 

property owners or official representatives who have signed waivers will be 

allowed, with less than 30 minutes of reserve fuel, does not engender the 

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

and speed of the small UAS. Additionally, limiting sUAS flights to 10 

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

granted. 

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

limiting flights to 30 minutes or 25% of battery power— whichever happens 

first. This restriction would be more than adequate to return the 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 airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization 

issued under §91.715 is displayed at the cabin or cockpit entrance so that it 

is legible to passengers or crew. 

The sUAS fully loaded weighs no more than 55 lbs and is operated without 

an onboard pilot. As such, there is no ability or place to carry certification 

and registration documents or to display them on the sUAS. 
FAA 333 UAS EXEMPTION PETITION 

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

at the ground control point where the pilot flying the sUAS will have 

immediate access 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, 9789, 

9789A, 9797, 9797A, 9816A, and 10700. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance

Inspections 

These regulations require that an aircraft operator or owner “shall have that 

aircraft inspected as prescribed in subpart E of this part and shall between

required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter...,” and 

others shall inspect or maintain the aircraft in compliance with Part43. 

Given that these section and Part 43 apply only to aircraft with an 

airworthiness certificate, these sections will not apply to the applicant. 

Maintenance will be accomplished by the operator pursuant to the flight 

manual and operating handbook. An equivalent level of safety will be 

achieved because these small UASs are very limited in size and will carry a 

small payload and operate only in restricted areas for limited periods of time. 

If mechanical issues arise the sUAS can land immediately 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 performed. Moreover, the 

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

maintain the aircraft in an airworthy condition to provide the equivalent 

level of safety. 

An equivalent level of safety will be achieved because maintenance and 

inspections will be performed in accordance with the sUAS Manufacturer's

Manual, as referenced in the Aircraft 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 Views & 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 

publication 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; 91.119; 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 motion 

picture, television, and commercial videography operations. 

Approval of exemptions allowing commercial operations of sUASs in the 

film industry will enhance safety by reducing risk. Conventional film 

operations, using jet or piston power aircraft, operate at extremely low 

altitudes just feet from the subject being 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 large 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. The sUAS is carried to 

the film set. The sUAS will carry no passengers or crew and, therefore, will 

not expose them to the risks associated with manned aircraft flights. 

The operation of small UASs, weighting less than 55 lbs., conducted in the 

strict conditions outlined above, will provide an equivalent level of safety 

supporting the grant of the exemptions requested herein, including

exempting the applicant from the requirements of Part 21 and allowing 

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 conducted 

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 filmed 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, please contact the 

undersigned at (215) 584-1917 or at BradleyDraifinger@gmail.com

Sincerely, 

Bradley Draifinger

sUAS Pilot/Operator