Chad Schlosser Aerial Optics LLC 14467151stAve Osakis, MN 56360

8/24/2015

U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140

1200 New JerseyAve., SE Washington, DC 20590

Re: Exemption Request Section 333 ofthe FAA Reform Act ofthe 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 ofAerial Optics LLC, am writing pursuantto the FAA Modernization and Reform Act of2012 and the procedures contained within 14 C.F.R. 11, to request that Aerial Optics LLC an operator ofsmall unmanned aircraft, be exempted from the Federal Aviation Regulations ("FARs')listed below so thatAerial Optics LLC, mayoperate mysmall ultra lightweight unmanned aircraft system ("UAS") commercially in airspace regulated bythe Federal Aviation Administration ("FAA").

As described herein Aerial Optics LLC has experienced UAS pilots and intend to use our DJI Inspire 1for photographylvideography/cinematography. Mysmall lightweight UAS is acost effective and potentiallysafer option than utilizing the industrystandard single engine plane or rotorcraft for aerial photography. Ifgiven the exemptions required to commerciallyfly a UAS, Iwill operate my UAS in asafe and effective mannerwhile observing all guidelines setforth bythe exemption.
Granting Aerial Optics LLC request comports with the SecretaryofTransportation's (FAA Administrator's) responsibilities and authorityto not only integrate UAS's into the national airspace system, butto "

...establish requirements forthe safe operation ofsuch aircraft systems [UAS's] in the national airspace system" under Section 333(c) ofthe Reform Act specificto the use of UAS's for commercial photography. FurtherAerial Optics LLC will conduct myoperations in compliance with the protocols described herein or as otherwise established bythe FAA.

Forthe reasons stated belowAerial Optics LLC, respectfully request the grant ofan exemption allowing me to operate ultra lightweight, remote controlled UAS'sfor commercial aerial photographylvideography/cinematography.I. Contact Information: Chad Schlosser Aerial Optics LLC 14467151stAve Osakis, MN 56360
aerialopticsmn@gmail.com

II. The Specific Sections ofTitle 14 ofthe Code ofFederal 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 reliefAerial Optics LLC seeks and the Reason We SeekSuch Relief:

Aerial Optics LLC, submitthis application in accordance with the Reform Act, 112 P.L. 95 

### §§ 331- 334, seeking relieffrom any currently applicable FARs operating to preventAerial Optics LLC, contemplated commercial cinematic, academic and otherflight operations within the national airspace system. The Reform Act in Section 332 provides for such integration ofcivil unmanned aircraft systems into our national airspace system as it is in the public's interestto 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 bythe Reform Act. Iwould like to operate my ultra lightweight UAS priorto the time period by which the Reform Act requires the FAAto promulgate rules governing such craft. The Reform Act guides the Secretary in determining the types ofUAS's that may operate safely in our national airspace system. Considerations indude: The weight, size, speed and overall capabilities ofthe UAS's; Whetherthe UAS will be operated near airports or heavily populated areas; and, Whether the UASwill be operated by line ofsight. 112 P.L. 95 

### § 333 (a). Each ofthese items reflect infavor ofan exemption forAerial 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 safetytechnology and telemetryto displayaltitude and distance from the PIC

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

Aerial Optics LLC considersafety as foremostwith each flight. The DJI Inspire UAS is designed to hover in place via GPS and operate in less than a20 knotwind. Forsafety, stability and fear of financial loss Iwill notfly in winds exceeding 15 KPH. Built in safetysystems include aGPS 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 oftake off. Ido not operate my UAS near airports, Hospitals nor Police heliports, and do not operate nearareas where general public is within fifty to one hundred (50-100) yards depending on location, conditions and weather. Utilizing battery power ratherthan combustible fuels, flights generally last between three (3) to fifteen (12) minutes, with an altitude underone hundred fifty (300) feetAGL. Aerial Optics LLC will operate 

### my UAS with afully charged battery and will ensure there is enough powerto return to the original starting destination with 2 minutes reserve on a batteryas tested lasting 18 minutes.

IV. HowAerial Optics LLC Request Will Benefitthe PublicAs AWhole:

Aerial videography is traditionally achieved using small single engine aircraft equipped with large
cameras. In orderto achieve adear picture, the pilot is tasked with performing ground reference
maneuvers at around 1 OOOftAGL. By utilizing a UAS forthis function, pilots reduce the risk of damages to persons or property in the event ofan in flight emergency. Congress has already proclaimed that it is in the public's interestto integrate commerciallyflown UAS's into the national airspace system, hence the passing ofthe Reform Act.

V. Reasons WhyAerial Optics LLC Exemption Will NotAdverselyAffect SafetyOr How The Exemption Will Provide a Level ofSafetyAt Least Equal To Existing Rule:

Aerial Optics LLC, believes that by allowing this exemption, itwill 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, itwill legitimizethe industry and create aclear path for safer aviation. Additionally, our UAS is equipped with fail safe programming that allows itto fly and return safely ifthe pilotwere to become incapacitated, orthe connection was lost.

VI. A SummaryThe 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 ofnecessary 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 Part21 because 

### my UAS meets (and exceeds) an equivalent level ofsafety pursuantto Section 333 of the Reform Act. The FAA is authorized to exempt aircraftfrom the airworthiness certificate requirement under both the Act (49 U.S.C. 

### § 44701 (f)) and Section 333 ofthe Reform Act. Both pieces of legislation permitthe FAAto exempt UAS's from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximityto areas such as airports and dense populations. Aerial Optics LLC current and projected UAS's meet or exceed each ofthe elements.

14 C.F.R. 91.7(a) prohibits the operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be applicable in the form contemplated bythe FARs, this Regulation is inapplicable.

14 C.F.R. 

### § 91.9 (b) (2) requires an aircraftflight manual in the aircraft. As there are no on board pilots or passengers, and given the size ofthe UAS's, this Regulation is inapplicable. An equivalent level ofsafetywill 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 mayoperate acivil 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 fullyfunctional dual controls. Flight control is accomplished through the use ofacontrol boxthat communicates with the aircraftvia radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. Additionally, in the absence ofprevious training requirements, Aerial Optics LLC has trained UAS pilots on staffand is developing pilottraining and validation techniques to use as internal qualityand 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 forthe carrying ofcivil aircraft certifications and registrations. They are inapplicable forthe same reasons described above. The equivalent level of safetywill be achieved by maintaining anysuch required certifications and registrations byAerial Optics LLC.

14 C.F.R. § 45.23: Marking ofTheAircraft. Applicable Codes of Federal Regulation require aircraftto be marked according to certain specifications. My UAS are, by definition, unmanned. Theytherefore do not have a cabin, cockpit or pilot station on which to markcertain words or phrases. Further, two-inch lettering is difficultto place on such small aircraftwith dimensionssmallerthat minimal lettering requirement. Regardless, Iwill 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 Ithe pilot, or anyone assisting me as aspotterwith the UAVwill see the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167Aand 10700.

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

Pursuantto 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. Section 61.133(a) requires an individual with acommercial pilot's license to be pilot in command of
an aircraftfor compensation or hire. Aerial Optics LLC can achieve an equivalent level ofsafety 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 forthe operation ofcivil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greaterthan 300 AGL; safely belowthe standard of400 AGL. Aerial Optics LLC will however operate my UAS in safe areas awayfrom public and traffic, providing a level ofsafety at least equivalentto or belowthose in relation to minimum safe altitudes. Given the size, weight, maneuverabilityand speed ofmy UAS, an equivalent or higher level ofsafetywill 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 underVFR conditions unless (considering wind and forecastweather conditions) there is enough fuel to flyto 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 afterthat for at least45 minutes." Aerial Optics LLC will be operating a UAS utilizing battery power ratherthan combustible fuels, flights generally last between three (3) to fifteen (15) minutes, with an altitude underone hundred frfly (300) feet AGL. Aerial Optics LLC will operate my UASwith afully charged battery and will ensure there is enough powerto 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 otherthings, aircraft owners and operators to "have [the] aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except asprovided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 of this chapter

...." These Regulations only applyto aircraft with an airworthiness certificate. Theywill not, therefore, applyto 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 ofmy UAS permits exemption from Part 21 because Aerial Optics LLC's UAS meets an equivalent level ofsafety pursuantto Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraftfrom the airworthiness certificate requirement under both the Act (49 U.S.C. §44701 (f)) and Section 333 ofthe Reform Act. Both pieces of legislation permit the FAAto exempt UAS's from the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverabilityand proximityto areas such as airports and dense populations. My UAS meets or exceeds each ofthe elements. 14 C.F.R. 91.7(a) prohibits the operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be applicable in the form contemplated bythe FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraftflight manual in the aircraft. As there are no pilots or passengers, and given the size ofthe UAS's, this Regulation is inapplicable. An equivalent level ofsafetywill 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 ofsafetywill 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)

Thankyou for yourtime and consideration in this matter.
Regards, Chad Schlosser