Chad Schlosser 

Aerial Optics LLC 

14467151stAve 

Osakis, MN 56360 

8/24/2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 ofthe FAA Reform Act of the Federal Aviation Regulations 

from 14 C.F.R. Parts 21; 45.23(b); 61.113 (a) & (b); 61.133 (a); 91.7 (a); 91.9 (b)(2); 91.109(a); 

91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.319 (a)(1); 91.405 (a); 91.407 (a)(1); 91.409 

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

Dear Sir or Madam, 

I, Chad Schlosser Co owner of Aerial Optics LLC, am writing pursuant to the FAA Modernization 

and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that Aerial 

Optics LLC an operator of small unmanned aircraft, be exempted from the Federal Aviation 

Regulations ("FARs')listed below so that Aerial Optics LLC, may operate my small ultra 

lightweight unmanned aircraft system ("UAS") commercially in airspace regulated by the Federal 

Aviation Administration ("FAA"). 

As described herein Aerial Optics LLC has experienced UAS pilots and intend to use our DJI 

Inspire 1 for photographylvideography/cinematography. My small lightweight UAS is a cost 

effective and potentially safer option than utilizing the industry standard single engine plane or 

rotorcraft for aerial photography. If given the exemptions required to commercially fly a UAS, I will 

operate my UAS in a safe and effective manner while observing all guidelines set forth by the 

exemption. 

Granting Aerial Optics LLC request comports with the Secretary of Transportation's (FAA 

Administrator's) responsibilities and authority to not only integrate UAS's into the national airspace 

system, but to " ... establish requirements for the safe operation of such aircraft systems [UAS's] in 

the national airspace system" under Section 333(c) of the Reform Act specific to the use of UAS's 

for commercial photography. Further Aerial Optics LLC will conduct my operations in compliance 

with the protocols described herein or as otherwise established by the FAA. 

For the reasons stated below Aerial Optics LLC, respectfully request the grant of an exemption 

allowing me to operate ultra lightweight, remote controlled UAS's for commercial aerial 

photographylvideography/cinematography. 
I. Contact Information: 

Chad Schlosser 

Aerial Optics LLC 

14467151stAve 

Osakis, MN 56360 

aerialopticsmn@gmail.com 

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Aerial Optics 

LLC Requests Exemption are: 

14 C.F.R. 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113 (a) & (b) 

14 C.F.R. 61.133 (a) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b)(2) 

14 C.F.R. 91.109(a) 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) and (b) 

14 C.F.R. 91.319 (a)(1) 

14 C.F.R. 91.405 (a) 

14 C.F.R. 91.407 (a)(1) 

14 C.F.R. 91.409 (a)(2) 

14 C.F.R. 91.417 (a) & (b) Ill. 

The Extent of relief Aerial Optics LLC seeks and the Reason We Seek Such Relief: 

Aerial Optics LLC, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-

334, seeking relief from any currently applicable FARs operating to prevent Aerial Optics LLC, 

contemplated commercial cinematic, academic and other flight operations within the national 

airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned 

aircraft systems into our national airspace system as it is in the public's interest to do so. Aerial 

Optics LLC, ultra lightweight UAS meets the definition of "small unmanned aircraft" as defined in 

Section 331 and therefore the integration of my ultra lightweight UAS is expressly contemplated 

by the Reform Act. I would like to operate my ultra light weight UAS prior to the time period by 

which the Reform Act requires the FAA to promulgate rules governing such craft. The Reform Act 

guides the Secretary in determining the types of UAS's that may operate safely in our national 

airspace system. Considerations indude: The weight, size, speed and overall capabilities of the 

UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, Whether 

the UAS will be operated by line of sight. 112 P .L. 95 § 333 (a). Each of these items reflect in 
favor of an exemption for Aerial Optics LLC. The DJI Inspire 1 UAS utilizes four (4) 

counter-rotating propellers for balance, control and stability. My UAS is equipped with GPS, auto 

return safety technology and telemetry to display altitude and distance from the PIC . Weighing 

less than Six (6) pounds (far below the maximum 55 pound limit); including camera with gimbal. 

Aerial Optics LLC consider safety as foremost with each flight. The DJI Inspire UAS is designed to 

hover in place via GPS and operate in less than a 20 knot wind. For safety, stability and fear of 

financial loss I will not fly in winds exceeding 15 KPH. Built in safety systems include a GPS mode 

that allows my UAS to hover in place when radio controls are released .. When pilot 

communication is lost UAS is designed slowly descend to point of take off. I do not operate my 

UAS near airports, Hospitals nor Police heliports, and do not operate near areas where general 

public is within fifty to one hundred (50-100) yards depending on location, conditions and weather. 

Utilizing battery power rather than combustible fuels, flights generally last between three (3) to 

fifteen (12) minutes, with an altitude under one hundred fifty (300) feet AGL. Aerial Optics LLC will 

operate my UAS with a fully charged battery and will ensure there is enough power to return to 

the original starting destination with 2 minutes reserve on a battery as tested lasting 18 minutes. 

IV. How Aerial Optics LLC Request Will Benefit the Public As A Whole: 

Aerial videography is traditionally achieved using small single engine aircraft equipped with large 

cameras. In order to achieve a dear picture, the pilot is tasked with performing ground reference 

maneuvers at around 1 OOOft AGL. By utilizing a UAS for this function, pilots reduce the risk of 

damages to persons or property in the event of an in flight emergency. Congress has already 

proclaimed that it is in the public's interest to integrate commercially flown UAS's into the national 

airspace system, hence the passing of the Reform Act. 

V. Reasons Why Aerial Optics LLC Exemption Will Not Adversely Affect Safety Or How The 

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

Aerial Optics LLC, believes that by allowing this exemption, it will create the beginning framework 

for other UAS enthusiasts to operate their aircraft in a much more regulated and safer 

environment. By creating laws and regulations for commercial UAS use, it will legitimize the 

industry and create a clear path for safer aviation. Additionally, our UAS is equipped with fail safe 

programming that allows it to fly and return safely if the pilot were to become incapacitated, or the 

connection was lost. 

VI. A Summary The FAA May Publish in the Federal Register: 

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR§ 91.203(a)(1). The size, 

weight and enclosed operational area of my, Aerial Optics LLC, UAS permits exemption from Part 
21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of 

the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both 

pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability and proximity to areas 

such as airports and dense populations. Aerial Optics LLC current and projected UAS's meet or 

exceed each of the elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board 

pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining safety/flight manual delineating areas of 

where safety can be defined. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 

and 32827. 

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction 

These regulations provide 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. UAS's are remotely piloted aircraft and by design and do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications. The FAA has approved exemptions for flight training without 

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

aircraft. See Exemption Nos. 5778K & 9862A. Additionally, in the absence of previous training 

requirements, Aerial Optics LLC has trained UAS pilots on staff and is developing pilot training 

and validation techniques to use as internal quality and safety controls. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level of 

safety will be achieved by maintaining any such required certifications and registrations by Aerial 

Optics LLC. 

14 C.F.R. § 45.23: Marking ofThe Aircraft. Applicable Codes of Federal Regulation require 

aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. 

They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or 

phrases. Further, two-inch lettering is difficult to place on such small aircraft with dimensions 
smaller that minimal lettering requirement. Regardless, I will mark its UASs in the largest possible 

lettering by placing the word "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. §45.29 

(f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The 

FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 

10167A and 10700. 

14 C.F.R. § 61.113; 14 C.F.R. § 61.133: Private Pilot Privileges and Limitations; PIC; Commercial 

Pilot Privileges and Limitations: 

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. 

Section 61.133(a) requires an individual with a commercial pilot's license to be pilot in command of 

an aircraft for compensation or hire. Aerial Optics LLC can achieve an equivalent level of safety as 

achieved by current regulations because my UAS does not carry any pilots or passengers. The 

risks attended to the operation of my UAS is far less than the risk levels inherent in the 

commercial activities outlined in 14 C.F .R. § 61, et seq. Thus, allowing Aerial Optics LLC to 

operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b) 

and 14 C.F.R §61.133 (a). 

14 C.F.R. 91.119: Minimum Safe Altitudes. 

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters 

to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude 

greater than 300 AGL; safely below the standard of 400 AGL. Aerial Optics LLC will however 

operate my UAS in safe areas away from public and traffic, providing a level of safety at least 

equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved. 

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

This regulation 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." Aerial Optics 

LLC will be operating a UAS utilizing battery power rather than combustible fuels, flights generally 

last between three (3) to fifteen (15) minutes, with an altitude under one hundred frfly (300) feet 

AGL. Aerial Optics LLC will operate my UAS with a fully charged battery and will ensure there is 

enough power to return to the original starting destination with 2 minutes reserve on a battery as 

tested lasting 18 minutes. 

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

Regulations require, amongst other things, aircraft owners and operators to "have [the] 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 .... " 

These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, 

apply to Aerial Optics LLC, UAS. 

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth for procurement of 

necessary airworthiness certificates in relation to FAR§ 91.203(a)(1). The size, weight and 

endosed operational area of my UAS permits exemption from Part 21 because Aerial Optics 

LLC's UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The 

FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the 

Act (49 U .S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit 

the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the 

weight, size, speed, maneuverability and proximity to areas such as airports and dense 

populations. My UAS meets or exceeds each of the elements. 14 C.F .R. 91.7(a) prohibits the 

operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable 

in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) 

requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given 

the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved 

by maintaining a manual. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, maintenance program that 

involves regular software updates and curative measures for any damaged hardware. Therefore, 

an equivalent level of safety will be achieved. 

In summary, Aerial Optics LLC seeks an exemption from the following Regulations: 

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §§ 61.133 

(a); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.109(a); 14 C.F.R. § 91.119; 14 

C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.319 

(a)(1); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2) and, 14 

C.F.R. §§ 91.417 (a) & (b) 

Thank you for your time and consideration in this matter. 

Regards, 

Chad Schlosser