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May 2 4 , 2015
U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 CF R part 21, subpart H; 14 C.F.R. 45.23(b); 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA M odernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Kenneth A Stephens , hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its Small Unmanned Aircraft Systems (“sUA S’”) for aerial photography and videography, inspections of brid g es , utilities, construction industries and real estate properties and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitud e within the U.S. National Airspace System as compared to manned aircraft. Operations would be performed only at the request of and with the authorization and permission of clients or their authorized agents in order to facilitate commerce and raise awaren ess of the beneficial uses of sUAS’s 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.
**The FAA has granted Exemption No. 11158 & 11694 that uses the sam e UAS as Kenneth A.**  **Stephens The DJI S1000 is a stable lightweight battery operated octocopter**

T he requested exemption would permit the operation of sUAS under controlled conditions in airspace that is a.) limited b.) predetermined c.) controlled to acces s and d.) would provide safety enhancements to the already regulated safety practices presently followed by manned aircraft as governed by the FAA. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the F AA Administrator’s) responsibility to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act. Applicant Contact Information:
Kenneth A Stephens 224 4 th st Juneau Alaska 99801 PH: 907

- 723

- 6399 Email: stephens@gci.net

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I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. I would look forward to working with your office. Please contact me at 907

- 723

- 6399 or via email stephe ns@gci.net at any time if you require additional information or clarification.


### BASI S FOR PETITION

**I**

. **UAS**
The S1000 has alread y been approved b y the FAA to be used in aerial photograph y in exemption No. 11158 & 11694

. Kenneth A Stephens intends to use DJ I S1000 in a similar
manner . The S1000 is an octocopter with retractable landing gear. The aircraft is designed to be stable even with the loss of a rotor. The S1000 has a maximum thrust of 2.5kg. It weighs approximately

9.7 pounds and has a maximum takeoff weight is approximately 24 lbs. The S1000 uses a 6S L iPo battery that allows flight times in excess of 25 minutes. The S1000 has a maximum speed of 45 mph. It can hover and simultaneously move vertically

and horizontally . The S1000 can operate in temperatures between

- 10 C to plus 40 C. The propeller is made out of high strength performance engineered plastics and is approximately 15 X5.2 inches. The S1000 is not water

- proof and is prohibited from flying in the rain and
snow. Further, the S1000 is programmed to return to its launch site in the event of either communications failure, loss of the Global Positioning Sy stem (GPS), or low battery

. **II. Operations** Kenneth A. Stephens has a Flight Operations Manual (“FOM”) which is intended to provide an equival ent or higher level of safet y for flight operations for the FAR’s. Kenneth A Stephens will provide a hard or electronic copy to each Pilot and Observer. The Pilot in Command (“PI C”) will ensure that each flight is in compliance with the FOM, DJ I S1000 Oper ations Manual (“Operations Manual”, which is electronicall y available at http://www.dji.com/product/spreading

- wings

- s1000

- plus/download), applicable FAR’s and any conditions or limitations specified in grant of Exemption. As set forth in the FOM, some requirements, limitations and conditions include: 1.) Minimum crew for each operation will consist of a PI C and the Observer. The PI C may deem other crew essential to the safe operation of the aircraft to include: a camera operator, instructor, trainee, or o ther persons necessary for the safe operation of the flight. 2 .) The PI C and Observer will be able to communicate verbally at all tim es. 3.) Flights will only

be conducted during daylight hours. 4 .) Visibility

will be adequate to ensure that the PIC and/or Observer can maintain visual contact with the aircraft at all times and ensure that the aircraft will remain clear of obstruct ions and people. 5 .) The aircraft will remain clear of clouds at all times. 6 .) Flights will be operated within the line of sight of the PI C and/or Observer. 7 .) Flights will not go beyond 3 ⁄4 statute miles from point of intended landing. 8 .) Flights will be terminated at or before 30 % battery power reserve.

### 3 9 .) Flights will not be conducted at speeds greater than 25 mph. 10 .) Flights will operate at an altitude of no more than 400 feet AGL. 11 .) Flights will remain in Class G airspace. 12 .) Flights will not operate within 5 nautical miles of an airport or heliport unless a letter of agreement with airport management is obtained 13 .) Flights that fly

over private or controlled

- access propert y will be conducted with landowner’s/controller’s permission. 14 .) Flights will not be operated over densely populated areas. 15 .) The PI C will ensure that an adequate preflight inspection of the aircraft has been completed in accordance with the Operations Manual and the FOM. 16 .) The PI C will conduct a briefing before each flight with the Observer and any other essential crew as to the plan for the flight including: flight area, weather, potential obstacles and hazards, flight time, battery time and any other information affecting the safety

of flight.

A **. STATUTORY AUTHORITY FOR EXEMPTIONS**
The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the ter m is defined under § 40101 of the Act, including sUASs, 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; CFR §91.203(a)(1).
Section 333(b) of the Reform Act assists the Secretary in determining whether sUASs may operate in the National Airspace System without creating a hazard to the user, the public, or a threat to national security. In making this determination, the Secretary must consider : a.) The sUAS’s size, weight, speed and operational capability b.) Whether the sUAS operates within the visual line of sight of the o perator c.) Whether the sUAS operates outside of highly populated areas and away from close proximity to airports
Reform Act §333(a). If the Secretary determines that a sUAS “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).

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Kenn eth A Stephens will be using a octoco pter manufactured by DJI. The model being used is the S1000 The S1000 weighs less than 25 pounds, including payload. The S1000 , operating under normal conditions, (no wind) travels at a maximum speed of 45 MPH and has the capability to hover and move in the vertical and horizontal plane simultaneously. The S1000 will operate only in the pilot’s visual line of sight at all times and will operate only within the limits of the area required to be videoed or photog raphed. Such operations will insure that the S1000 will “not to create a hazard to users of the national airspace system or the public.” Reform Act Section 333(b).

Given the small size of the S1000 and the restricted and predetermined environment within w hich it will operate, this application falls squarely within the 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 smal l size of the S1000 and the low altitudes and restricted areas in which it 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 Av iation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, grant of the requested exemptions is in the public interest. Accordingly, Kenneth A Stephens r espectfully requests that the FAA grant the requested exemption without delay.

**B. PUBLIC INTEREST**
This exemption application is expressly submitted to fulfill Congress’s goal in passing Section 333(a) through (c) of the Reform Act. This law directs the S ecretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the National Airspace System before completion of the rulemaking required under Section 332 of the Reform Act. By granting an exemption the FAA will fulf ill Congress’s intent of allowing UAS to operate with significant safety precautions in low risk environments.
The use of sUAS for videoing or photographing drainage ways, bridges and survey mapping can reduce the risk of injuries to workers attempting to walk in very dangerous/difficult terrain found in waterways, detention ponds and surveying areas as well as reduce environmental impacts to wetland areas that are very sensitive for wildlife. Use of sUASs on construction sites can significantly reduce the risk to workers of falls while inspecting, surveying or monitoring site progress. sUASs can inspect, photograph and collect data on hard to get to areas that otherwise would require worker inspection. Falls are the leading source of workplace could save w orkers lives. Aerial videography for real estate marketing has been around for years through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videography is cost prohibitiv e. Only large companies and high end realtors or luxury homeowners can afford to absorb such expense, depriving non

- luxury homeowners and lower budget realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through potential ca tastrophic crashes resulting in loss of life due to the potential combustible fuel that can explode and burn on impact. sUASs pose no such threat since size and lack of combustible fuel alleviates any potential threat to the public.

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Finally, sUASs reduce the environmental impact by dramatically decreasing the energy used for aerial imaging. The S1000 uses rechargeable lithium ion batteries, as opposed to fossil fuels burned in operation of small aircraft and helicopters that are hundreds or thousand s of times heavier.
**C. EQUUIVALENT LEVEL OF SAFETY**
Kenneth A Stephens proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe operations conducted with helicopters and other conventional aircraft.
Kenneth A Stephens will be bound by the following limitations when conducting its sUAS operations under an FAA issued exemption:
1.) The sUAS will be less than 25 pounds. 2.) Flights will be operated within visual line of sight of the pilot. 3.) Maximum total flight time for each operational flight will be 1 5 minute s. The S1000 calculates battery reserve in real time, and will return to its ground station with at least 30 % battery reserve should that occur prior to the 1 5 minute limit. 4.) Flights will be operated normally at approximately 150 feet AGL, never exceeding 400 feet AGL. 5.) Horizontal flight speed will not exceed 45 MPH

. 6.) Crew for each operation will consist of the sUAS Pil ot who will keep the sUAS within his/her visual line of sight at all times and a Visual Observer who will also keep the aircraft within line of sight as well as watch for other aircraft or personnel that might enter the operation area. 7.) Pilot and Visual Observer will keep in constant v erbal contact throughout the duration of each flight. If conventional aircraft or unauthorized personnel enter the flight operations
are a unexpectantly the flight will be terminated immediately. 8.) The sUAS pilot will be trained in flight, operations , chec klists and safety procedures with 25 hours of flight time and 100 landings and take off with the S1000 9.) The sUAS will only operate in a confined predetermined area around which a security perimeter will be established for flight operations. 10.) Warning signs will be pos ted in the flight operations area indicating to remain clear of the area. 11.) A briefing will be conducted in regard to the planned sUAS operations prior to each flight. It will be mandatory that all personnel who will be present wi thin the boundaries of the safety perimeter be present for this briefing. 12. ) All personnel will consent to the UAS flyover on site by waiver, and the operator will obtain additional verbal or written consent of all persons who will be allowed within 100 feet of the flight operation

. 13.)Written and/or oral permission from the relevant property holders will be obtained 14.)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 when required. 15.)The pilot will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 16.) The observer will be required to complete training as outlined in the FOM

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17.)The pilot will have a Pilot’s lice nse and a Class III medical. 18.)The pilot will perform a minimum of 3 takeoffs and landings within the preceding 5 days with the S1000 sUAS. 19.)If the S1000 loses communications or loses its GPS signal, it will automatically return to a pre

determined l ocation within the security perimeter and land. 20.)The pilot will abort a flight (return to home) in case of unpredicted obstacles or emergencies with the push of a button.. 21.)Single family residential and commercial properties to be videoed will be l imited to a minimum of one acre parcels, in size, which would allow the sUAS to be maneuvered around the perimeter of the structure without over flying the structure being videoed as well as any structures on adjacent properties thus allowing an emergency landing, if a power failure occurs, without any undue hazard to persons or property on the surface. 22.)sUAS will not be flown within 5 miles of airports as shown on current FAA

- published aeronautical charts unless authorization has been granted by the controlling ATC facility governing that airport. 23.)Pilot will preflight/inspect sUAS for airworthine ss prior to each flight including the Ground Control station. 24.)Pilot will maintain the S1000 and properly document all maintenance and alterations in the S1000 records. 25.)Pilot will conduct a functional test flight after all maintenance prior to the next operational flight and record this flight in the S1000 records/ flight log. 26.)All flights will be flown only during daylight hours under visual meteorological conditions (VMC). **D. DESCRIPTION OF SPECIFIC REGULATIONS REQUESTING EXEMPTION FROM:**

**1 4 CFR 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 Kenneth A. Stephens 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 V.S.C.§44701 (t) and Section 333 of the Reform Act both auth orize 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. Our small UAS will be opera ted at low speed in a controlled environment, at least five miles from an airport and more than three miles from any densely populated area. An analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the rest ricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or helicopter) operating with an airworthiness certificate without the restrictions and conditions proposed.

The DJI S1000 to be operated hereunder is less than 25 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within

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a secured area. Like other civil aircraft, operations under this ex emption will be tightly controlled and monitored by the operator and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation.
These safety enhancements provide a greater degree of safet y 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 secur ity posed by the sUAS , due to its size, speed of operation, location of operation, lack of explosive mate rials or flammable liquid fuels.
**14 C.F.R. 45.23(b): Marking of the Aircraft**
This regulation requires certain experimental, provisionally certificated aircraft, or lightsport category aircraft to be marked with letters between 2 inches and 6 inches high “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” near each entrance to a cabin, cockpit, or pilot station.
Even though the sUA S will have no airworthiness certificate, an exemption would 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 sUAS , two

- inch lettering would be impossib le. The FAA has issued an exemption to this regulation: Exemption No. 11109. **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 pilot operating the sUAS to have completed sUAS flight training by reviewing each of the three DJI Inspire 1 manuals (at tached to this document), The pilot would also perform a minimum of 200 flight cycles, 25 hours of total time as a sUAS rotocraft pilot and a minimum of 10 0 landing and take off before performing the first “operational flight” under this exem ption. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance . The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a pilot who has met the minimu m requirements stated above exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).
**14 C.F.R. 91.7(a): Civil aircraft airworthiness**

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the requirements contained in the DJI S1000 Manuals, FOM and the use of a preflight checklist prior to each flight an equivalent level of safety will be provided.
**14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements**

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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 i ssued the following exemptions to this regulation: Exemption Nos. 11062 , 11109 , 11112 , 11213 , 11694 , 11158 , **14 C.F.R. 91.103(b): Preflight Action**
This regulation requires each pilot in command take certain actions before flight to ensure the safety of fl ight. An exemption is needed from this requirement as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions in the Pref light Checklist in the DJI S1000 Manuals. These actions will provide an equivalent level of safety.
**14 C.F.R. 91.109: Flight Instruction**
Section 91.109 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. By design, sUASs and remotely piloted aircraft do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates w ith the aircraft via radio communications. The FAA has previously approved exemptions for aircraft without fully functional dual controls. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passeng ers will be carried in the aircraft, the ability to control the sUAS via radio signals from the controller, 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 o peration 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. This exemption i s for a multirotor craft that flies similarly to a helicopter, with vertical takeoff and vertical landing, which will typically operate at altitudes of 150 AGL, so an exemption may be needed to allow such operations. The sUAS will never operate at altitude higher than 400 AGL and will be in a restricted area with security p erimeter, 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 o f 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 any onsite personnel all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 25 lbs. proposed herein and carrying flammable fuel, any risk associated with our operations is far less than those present ly

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presented with helicopters and other conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude operations of the sUAS will ensure separation between these sUAS operations and the operations of conventional aircraft that must com ply with Section 91.119.
**14 C.F.R. 91.151(a): Fuel requirements for flight in VFR conditions**
Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. The S1000 is limited to operations in predetermined and controlled environments, and has a limited range and flight time which require an exemption from 14 CFR 91.151(a).
The battery powering the S1000 provides approximately 1 5 minutes of powered flight. To meet t he 30 minute reserve requirement in 14 CFR §91.151, DJI S1000 flights would not be possible. Given the limitations on the DJI S1000 proposed flight area and the location of its proposed operations within a predetermined area, a time frame of 1 5 minutes for flight in daylight VFR conditions is reasonable.
Kenneth A. Stephens 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 wit h FAR 91.151 (a)). Operating the DJI S1000 , 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 ris ks that Section 91.151(a) was intended to alleviate given the size and speed of the S1000

. Additionally, limiting S1000 flights to less than 1 5 minutes would greatly reduce the utility for which the exemption will be granted.

An equivalent level of safety can be achieved by limiting flights to 1 5 minutes, or enough battery reserve to ensure that the S1000 lands at the ground station with at least 3 0% of battery power (as determined by the onboard monitoring system and the pilot), whichever happens first. This restriction would be more than adequate to return the S1000 to its planned la nding zone from anywhere in its limited operating area.
Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

**14 CFR 91.203 (a) & (b):**  **Carrying civil aircraft certification and registration**
The regulation provides in 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 o r crew.

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The DJI S1000 fully loaded weighs no more than 25 lbs. and is operated without an onboard pilot. Therefore there is no ability or place to carry certification and registration documents or to display them on the DJI S1000

. An equivalent level o f safety will be achieved by keeping these documents at the ground flight 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 regula tion. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.
**14 C.F.R. 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections**
These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter

... ,” and others shall inspect or maintain the aircraft in compliance with Part 43.
Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Kenneth A, Stephens . Maintenance will be accomplished by the operator. An equivalent level of safety will be achieved because the DJI S1000 is 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 DJI S 1000 can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the DJI S1000 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 condit ion to provide the equivalent level of safety.
Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determi ned 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; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle ( 25 lbs. or less) in aerial photography and videography for mapping, inspections of dr ainage ways, , utilities, construction industries , bridges and real estate properties and other flight operations that could be performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. National Airspace System as compared to manned aircraft.
Approval of exemptions allowing commercial operations of sUASs enhances safety while reducing risk. Manned aircraft create a greater risk because the craft are much larger, have combustible fuel, and carry an onboard human pi lot. In contrast, a sUAS weighing fewer than 25 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel

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carried on board. The sUAS will carry no passengers or crew and, therefore, will not exp ose them to the risks associated with manned aircraft flights.
The operation of small UASs, weighing less than 25 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions re quested 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, and in a sterile environment and, as a result, are far safer than conventional 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 owner's prior consent and knowledge. Images tak en will be of individuals who have also consented to being filmed or otherwise have agreed to be in the area where aerial photography will take place.
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 adeq uate justification for the grant of the requested exemptions allowing commercial operation of Kenneth A. Stephens sUAS in above referenced services pursuant to the DJI Manuals
Thank you for considering this exemption request.
Sincerely,

Kenneth A. Stephens