1 16 February

2015 U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12
- 140 1200 New Jersey

Avenue, SE Washington, DC 20590 Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from Part 21; and §§ 45.23(b); 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) & (b); 91.405(a); 91.407(a)(1); 91.409 (a)(2); and 91.417(a) & (b) of Title 14, Code of Federal Regulations . Precedence for this exemption request is FAA Exemption 11138 as petitioned and approved for Douglas Trudeau on 5 January 2015. Dear Sir or Madam, I, Robert M. Serino , FAA L icensed P rivate Pilot #33442220 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 I, Robert M. Serino , an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I , Robert M. Serino , may operate small ultra light weight unmanned aircraft s ys tem (“UAS”) commerciall y in airspace regulated b y the Federal Aviation Administration (“FAA”). As described herein I, Robert M. Serino, FAA L icensed Pilot #33442220 for Airplane Single Engine Land am experienced in fl yi ng hobby helicopters for recreational purposes and for US Government purposes . Ihave added commercial grade DJ I Phantom 2 quad
- copters to my inventory that we igh approximately 3 pounds and are equipped with either a GoPro Hero 3+Black camera or a FLIR Tau 2 camera (Figure 1). The cameras are used for recording imagery

captured during flight as well as for providing real
- time, remote First Person View (FPV) of the aircraft’s flight path as well as local situational awareness and understanding for improved flight safety. During flights, we would conduct two
- person pilot plus observer activities at a low
- altitude of under 150 feet, within a line
- of
- sight of under 750 feet, and onl y for daytime Aerial Photograph y and Research and Development. As outlined below, our intent i s enhance ment of community

awareness for those individuals , not - for
- profit organizations, and companies having either aerial photograph y or Research and Development needs in Maryland and Virginia as performed under an FAA
- approved exemption :
 Application examples of Aerial Photograph y include efforts in support of real estate, construction, specialized facilities and events.

 Application examples of Research and Development include fast, remote sensing of2 toxic and dangerous materials and conditions with compact, advanced technology sensors, sy stem integration, and technical trials under simulated, relevant conditions.

 We would also make our services available on a volunteer/no
- cost basis to local Not
for
- Profit / Search and Rescue / HAZMAT / Fire Fighting organizations.

**Figure 1. DJI Phantom 2 quad**  **- copters with**  **Radio Controllers and either a**  **GoPro Hero3+Black cam**  **era or a**  **FLIR Tau 2 cam era.**  **A tripod -**  **mo unted Ground Control Station with separate higher**  **- resolution**  **viewing screen is also shown.** Based upon a prior successful review of a Section 333 exemption application by the FAA, we intend to use Phantom 2 aircraft as recentl y approved by the FAA under Section 333 Exemption No. 11138 for Douglas Trudeau on 5 January 2015. The following nine App endices A
- I provide current, detailed information on safety, built
- in safeguards, reliability and ease
- of

- operability

for the commercial Phantom 2 aircraft we possess, and that would use under an approved exemption: Appendix A - Phantom 2 Quick Start Guid e Appendix B
- Phantom 2 User Manual Appendix C
- NAZA - M Quick Start Guide Appendix D
- Smart Flight Battery Safety Guidelines Appendix E
- 2.4G Bluetooth Datalink & iPad Ground Control Station User Guide3

Appendix F
- 5.8G VideoL ink User Manual Appendix G
- Cloverleaf Antenna User Manual Appendix H
- Robert M. Serino #33442220 Safety Protocols and Sy stem Controls Appendix I
- Robert M. Serino #33442220 Safety of Flight Manual and Record In terms of piloting experience under an exemption, I , Robe rt M. Serino, FAA L icensed Pilot #33442220, have been approved b y the FAA to fl y airplanes for over twenty- six (26) years since 6 April 1988, and have been fl yi ng RC electric helicopters for 1 (one) year ; all without incident of an y kind
. The following Appendix J is an extract of my Pilot Logbook regarding take
- offs/landings and flyinghours of Phantom 2 UAS as Pilot
- In - Command (PI C): Appendix J
- RM Serino_UAS PI C Pilot L o gbook Extract We are c ommitted to safety with each flight , and an exemption woul d permit operation of ultra lightweight, unmanned (piloted by remote control) and comparatively inexpensive UAS in tightly c ontrolled and limited airspace. We would fly in p redetermined in areas for community

videos, and within property boundaries for Aerial Photography and Research and Development. We would do so with markings and signage keeping activities 150 feet away from the general public and vehicular traffic, as well as fully comply with FAA directives on Flight Restricted areas such as airports, heliports, and special security zones, as well as NOTices to AirMen (NOTAM’s) about Temporary Flight Restricted (TFR) areas such as sporting events, VIP events, and VIP routes or areas. GPS - based methods insure compliance with designated No
- Flight Areas such as airports using GPS
- based navigation and flight monitoring with and without aid of a Ground Control Station. An example flight
- restricted 5
- mile zone is shown for the Baltimore area on the Ground Control Station flight monitoring map (Figure 2). C urrently , similar lightweight, remote controlled UAS's are legally operated by

unmonitored amateur hobb yi sts with no safety plan or controls in place to prevent catastrophe. I, Robert M. Serino, have personally instilled safety protocols and controls to avoid and prevent public hazard, as well as manned aircraft h azards catastrophe. We use materials and methods including those outlined and detailed in Appendices A
- I. These will further enable strict safety protocols exclusive to lightweight UAS's specific to real estate video and photograph y usage as I, Robert M. Serino, record flight data and other information gained through permitted flight operations to share with the FAA through an y required FAA reports to assist with future protocol and safety regulat ion. Granting m y, Robert M. Serino , request conforms with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to integrate UAS's into the national airspace sy stem, and to “...establish requirements for the safe operation of such aircraft sy stems [UAS's] in the national airspace s ys tem” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor purposes. Further I, Robert M. Serino , will conduct my

operations in full compliance with the protocols described herein or as otherwise established and/or amended by the FAA.4

For the reasons stated below , I, Robert M. Serino , respectfull y request the grant of an exemption allowing me to operate ultra lightweight, remote controlled UAS’s for d ay time Aerial Photograph y and Research and Development. Our intent is enhance ment of community

awareness for those individuals , not - for
- profit organizations, and companies having either Aerial Photograph y or Research and Development needs in Maryland and Virginia as performed under an FAA
- approved exemption . In one example, this approval would serve community needs b y greatly enhancing commercial property l istings for those who cannot afford expensive manne d aircraft for the same purpose; thereby, promoti ng faster economic growth through increased sales, employment and tax base. In a second example, this approval could enable development of advanced useful capabilities for the fast, remote sensing of toxic and dangerous materials and conditions for enhanc ed protection of the public. Further, this approval would hold public safety foremost by keeping away

from the public heavier manned aircraft operated under similar conditions with 500x larger mass and containing man y gallons of combustible fuel.

**Figure 2. GPS -**  **based methods insure compliance with designated No -**  **Flight Areas such as airports using GPS**  **- based navigation and flight m**  **onitoring with and without aid of a Ground Control Station. An example flight**  **- restricted 5**  **- mi**  **le zone is shown for the Bal tim**  **ore area on the Ground Control Station flight m**  **onitoring map .** 5

**I.** Contact	Information: Robert M. Serino, Ph.D FAA Licensed Private Pilot #33442220 8953 Chapel Avenue Ellicott City , MD 21043 (240)461
- 3954 robertmserino@yahoo.com **II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Robert M Serino Requests Exemption are:**  14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b). **III. The Extent of relief Robert M. Serino seeks and the Reason He Seeks Such Relief:** I, Robert M. Serino , submit this application in accordance with the Reform Act, 112 P.L .95 §§ 331 - 334, se eking relief f rom an y currentl y applicable FARs operating to prevent me, Robert M. Serino , contemplated commercial cinematic, charitable, voluntary , and other flight operations within the national airspace s ys tem. The Reform Act in Section 332 provides for such integrat ion of civil unmanned aircraft s ys tems into our national airspace s ys tem as it is in the public’s interest to do so. My , Robert M. Serino’s , ultra lightweight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore th e integration of my

ultra lightweight UAS is expressly contemplated b y the Reform Act. I would like to operate m y ultra lightweight UAS prior to the time period by which the Reform Act requires the FAA to promulgat e rules governing such craft. Allowing s uch will provide direct experience and valuable information for formal regulation that can be administered uniformly to other UAS
- related activities for aerial video and photograph y. The Reform Act guides the Secretary in determining the types of UAS's that may operate safel y in our national airspace s ys tem. Considerations include: The weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operated near airports or heavil y populated areas; and, Whether the UAS will be operate d by line of sight. 112 P.L . 95 § 333 (a). Each of these items reflects in favor of an exemption for me, Robert M. Serino . My UAS utilizes four (4) counter
- rotating propellers for balance, control and stability
. My UAS is equipped with GPS and auto return, fail
- safe safety technology , and weighs approximately three (3 ) pounds (far below the maximum 55 pounds limit); including camera with gimbal. I, Robert M. Serino , consider safety to be the most important requirement for ea ch and every flight. M y small
- unmanned aircraft is designed to hover in place via GPS and operate in less6

than a 24 knots (15mph) wind. For safety, stability and fear of financial loss , I will not fl y in winds exceeding 16 kph (10 mph). Built
- in safety sy stems include a GPS mode that allows my UAS to hover in place when radio controls are released. With three modes to choose from, I utilize the GPS mode for both A erial P hotograph y and Research and Development
. This is the safest, most reliable and stab le mode to prevent accident and hazard. When pilot communication is lost , the UAS is designed to go into a Fail
- Safe mode and slowly return - to home; i.e., within 3 meters of the point of take off. In accordance with FAA regulations, I do not operate m y UAS near airports, within temporary flight restricted areas, near hospitals or sporting event areas , near special security areas, and do not operate near areas where general public is an ywhere within 150 feet
. With an observer alway s present, we are const antly

on alert for both people on the ground and manned aircraft in the air, and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach m y location or I suspect manned aircraft may approach near m y locat ion. My UAS is capable of vertical and horizontal operations, and are flown only within my line of sight and not to exceed 150 feet altitude and not to exceed 750 feet distance , as the remote control pilot in command
. These distances are controlled by so ftware
- based, GPS
- enabled input to the NAZA flight control software (Figure 3).

**Figure 3. Maximum allowable height above ground and**  **ma ximu**  **m allowable distance are controlled by**  **software input to the NAZ**  **A flight control software.** Utilizing battery power rather than combustible fuels , flights will last not more than seven (7) to ten (10) minutes
. I, Robert M. Serino , will utilize a fresh full y- charged Smart B attery with7

each the start of each flight as a safety precaution; full flight time for each battery is 15 ( fifteen ) to tw enty ( 20 ) minutes as tested ; thereb y providing not less than a fifty (50) percent Smart Battery

power margin . I do not operate m y UAS at or below manufacture r recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Extra Smart B atterie s are kept at hand and in reserve with each flight event to insure fast rep lacement and an alway s foremost safe level of operation (Figure 4).

**Figure 4 .**  **Sm art Battery employed in Phantom** **2 provides immediate visual awareness and percent battery charge rem**  **aining as well as sim ilar inform**  **ation during flight through Ground Control Station.** I do not believe in taking any risk that may cause any harm or coul d create a hazard to the public, to property and to manned aircraft, and have neither an y desire what
- so - ever to create such nor an y desire to risk loss of an investment. I have recorded numerous practice flights in remote areas as a hobbyist simulating f lights for future commercial use to gain familiarization with the characteristics of this specific UAS's performance under different temperature and weather conditions. I also practice computerized simulated flights to maintain adequate skills and respons e reflex time. All for the sake of safety , I , Robert M. Serino , am extremely

cautious when operating m y UAS/ultra lightweight unmanned aircraft and will not “create a hazard to users of the national airspace s ys tem or the public.” 112 P.L
. 95 § 333 (b). Given the small size and weight of my UAS , it falls well within Congress’s8

contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace sy stem. Robert M. Serino’s Phantom 2 UAS, used in hobby

flight, has a demonstrable safety record and does not pose an y threat to the general public or national security. **IV. How Robert M. Serino’s Request Will Benefit the Public As A Whole:** Aerial Photograph y for geographical awareness and commercial sales has been conducted for ye ars through manned fixed
- wing and rotary
- wing aircraft. For small budget businesses and homeowners , the expense of such A erial Photography is cost
- prohibitive in the hundreds to thousands of dollars
. Only larger companies and luxury home owners can a fford to absorb such expense; d epriving non
- luxury home owners and small businesses f rom a valuable imaging tool. Small UAS will allow businesses to leverage airspace faster and at a greatl y lower cost than a manned s ys tem. Research and Development for fast, remote sensing of toxic and dangerous materials, and the supporting sy stem integration of sensor packages is focused on maximizing the value of unmanned s ys tems for employ ment into very

hazardous conditions and fo r which the operational value is potentially very high. Key

technologies are coming available fast to protect people better, and this field of endeavor becomes all
- the
- more - important with an increasing number and diversity of threats. M anned aircraft can pose a threat to the general public through a potential ly catastrophic crash , and communities have experienced such in the past through both the mass of the aircraft and the on
- board combustible fuel that can burn persons and property quite violentl y upo n impact. My

UAS pose s no such impact threat to the general public since size / weight / power is approximately

1/500th of a manned aircraft and the lack of combustible fuel alleviates any potential burning threat to the general public
. Congress has already proclaimed that it is in the public’s interest to integrate commerciall y flown UAS's into the national airspace s ys tem, hence the passing of the Reform Act. Granting m y, Robert M. Serino’s , exemption request furthers the public interest through vi sual awareness and Research and Development in the Maryland and Virginia area. In furtherance of the public’s interest, we would also make our services available on a volunteer/no
- cost basis to local Not
- for
- Profit / Search and Rescue / Fire Fighting organizations. My ultra lightweight UAS is battery powered and creates no emissions that can harm the environment. The consequence of m y ultra lightweight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy , contain a pilot, many gallons of combustible fuel and can cause catastrophic devastation to the public
. The Smart Battery employed in Phantom 2 provides immediate visual awareness and percent battery charge remaining as well as similar information during flight through Ground Control Station
. The public’s interest is further supported b y minimizing the potential for ecological damage and crash threat s by

permitting my

battery operated ultra lightweight UAS's. Permitting me,9

Robert M. Serino , to immediately fly wi thin national air space furthers economic growth. Granting m y exemption request substantially furthers the economic impact for the Maryland and Virginia area for companies , families and (ultimately) Government agencies, as well as Not - for
- Profit / Search and Rescue / HAZMAT / Fire Fighting needing enhanced local and situational awareness, all of which serve to strengthen, protect, and stimulate the community
. **V. Reasons Why Robert M. Serino’s Exemption Will Not Adversely Affect Safety Or How The Exemptio**  **n Will Provide a Level of Safety At Least Equal To Existing Rule:** My , Robert M. Serino ’s, exemption will not adversely affect safety
. I have been fl yi ng for 26 years with zero incidents and quite to the contrary for the reasons stated , permitting me, Rob ert M. Serino , to log more flight time in FAA controlled airspace. Further, this exemption would enable communication with the FAA and allow me to contribute to the innov ation and implementation of new, innovative , and as of yet undiscovered safety protoc ols for Aerial Photography / Research and Development / Not
- for
- Profit support / Search and Rescue / HAZMAT support / Fire Fighting support in cooperation with the FAA. In addition I , Robert M. Serino , submit the following representati ons on enhancements to current approaches to Aerial P hotograph y and Research and Development :
 My UAS weighs approximately 3 pounds complete with a small ultra lightweight high quality GoPro Hero3+ Black camera or FLIR Tau 2 camera;  I onl y operate m y UAS at less than 150 feet altitude. Altitude limits are software
- defined and GPS
- enabled, and well within the 400 foot permissible ceiling set b y the FAA Modernization and Reform Act of 2012;  I pilot my

UAS through remote manual and GPS
- stabilized control only by line
- of
- sight not beyond 750 feet. Distance limits are software
- defined and GPS
- enabled.  I pilot my

UAS with the aid of a Ground Control Station with real
- time monitoring of Smart Battery

status, GPS signals, Geo
- Lo cation, and embedded emergency modes for Auto - Land and Return
- to - Home (Figure 5);  I pilot my

UAS with the aid of a R adio Controller, and a dditional emergency modes are embedded withi n the R adio Controller for Fail
- Safe, Home
- Lo ck, and Command Shut
Off ;  The Ground Control Station Iuse is on an iPad platform and has an embedded Weather App for real
- time monitoring of local weather reports, warnings and doppler weather radar.  My UAS onl y operate s for less than 10 minutes per flight with an unused 50% Smart Battery power margin ;  I land m y UAS prior to manufacturer recommended minimum level of battery power;  My UAS has a GPS - based flight safety feature whereby

it returns - to - home and then slowly lands if communication with the remote control pilot is lost;  I activel y analyze flight data and other sources of information to constantly update and enhance safety

protocols;  I onl y operate in reasonably safe environment that are strictl y controlled, are away from power lines, elevated lights, airports and activel y populated areas;  I conduct extensive pre
- flight inspections and protocol, during which safety carries the10

p re - eminent importance;  I alway s obtain all necessary permissions prior to operation; and,  I have procedures in place to abort flights in the event of safety breaches or potential danger. My , Robe rt M. Serino’s , safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace s ys tem, 1,500+ pounds rotary
- wing and fixed
- wing aircraft are the primary means of Aerial Photography and airborne sensing . While the safety record of such aircraft is remarkable, there have been local incident s involving loss of life as well as extensive property damage; thus, it is far safer to operate a 3 - pound, battery powered ultra lightweight UAS.

**Figure 5. Ground Control Station with real -**  **tim e monitoring of Sm**  **art Battery status, GPS signals, Geo**   ** Location, and em****bedded emergency m odes for Auto**  **- Land and Return**  **- to**  **- Hom**  **e. Additional em ergency**  **modes for Fail -**  **Safe, Hom e**  **- Lock, and Command Shut**  **- Off are em** **b edded on the Radio Controller.**  **Weather App for real**  **- tim**  **e local weather reports, warnings and doppler**  **weather radar is also embedded**  **within iPad platform . Screenshot taken during photo for Figure 1. Geo**  **- location and orientation**  **indicated on map by red arr owhead and GPS**  **- recorded hom**  **e point indicated by “H” icon.**

 First, the potential loss of life is diminished because UAS's carry no people onboard and I only operate m y UAS in specific areas away from mass populations.  Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatl y diminished.11

 Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickl y and safel y.  Lastl y, given its small size and weight, even wh en close enough to capture amazing images, m y UAS need not be so close to the objects they are focused on through the technology

and use of post editing software allowing pan and zoom. Accordingl y, my UAS has been experimentally operated for familiarizati on/competency and will continue to operate at and above current safety levels. **VI. A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R.91: Airworthiness Certificates, Manuals and The Like.**  **14 C.F.R. 21, Subpart H, enti tled 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 , Robert M. Serino’s , UAS permits exemption from Part 21 because m y 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 33 3 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 , Robert M. Serino’s , 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 th e 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 o f safety will be achieved by

maintaining a safety/ flight manual with the PI C during UAS flight operations . The FAA has previously issued exemptions to thi s regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 107 00 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes the global positioning s ystem to report altitude in real
- time through the Ground Control Station plus maximum allowable altitudes and distances are p re - set through the NAZA flight control software. 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 b y maintaining any such required certifications and registrations by

me, Robert M. Serino on site during UAS flight operations.12

**B. 14 C.F.R. § 45.23: Marking of t**  **he Aircraft.** Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. M y UAS are, b y 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 than the minimal lettering requirement. Regardless, I will mark the UASs in the largest possible lettering b y 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 a spotter with the UA S will see the markings. The FAA has previousl y issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. **C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.** Pur suant to 14 C.F.R.§§ 61.113 (a) & (b), private pilots are limited to non
- commercial operations. I, Robert M. Serino , can achieve an equivalent level of safety as achieved b y current Regulations because my UAS does not carry

any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risk associated to the operation of m y UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Robert M. Serino, Princ ipal and FAA Licensed Private Pilot #33442220, to operate m y UAS will meet and exceed current safety levels in relation to 14C.F.R. §61.113 (a) & (b). **D. 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 150 feet AGL; safel y below the standard of 400 AGL. I, Ro bert M. Serino , will operate m y UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my

UAS, an equivalent or h igher level of safety will be achieved. **E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.** The above
- cited 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 appl y to aircraft with an airworthiness certificate. They will not, therefore, apply to my , Robert M. Serino’s UAS. Nevertheless , as a safety precaution, Iinspect my UAS before and after each flight. As an added measure, my aircraft have been routinely checked by

the loc al OEM dealer, Intelligent UAS www.1uas.com to insure all elements and the total sy stem are functioning to specification. Further, onl y OEM replacement parts are used in my Phantom 213

aircraft in order to insure the peak level of reliability and performance. **A Summary The FAA May Publish in the Federal Register:** A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certi ficates, Manuals and The L ike. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth req uirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and operational area of m y UAS permit exemption from Part 21 because m y, Robert M. Serino’s UAS meets an equivalent level of safety pursu ant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the air worthiness 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 ea ch of the elements. 14 C.F.R. 91.7(a) prohib its 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. 14C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the airc raft. 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 b y m aintaining a manual onsite during UAS flight operations . The FAA has previously issued exemp tions to thi s regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative meas ures for any damaged hardware. Therefore, an equivalent level of safety will be achie ved. In summary , Robert M. Serino 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. §91.7 (a); 14 C.F.R.§ 91.9 (b)(2); 14 C.F.R.§ 91.103(b); 14 C.F.R.§ 91.109; 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. § 91.405 (a); 14 C.F.R.§ 91.407 (a)(1); 14 C.F.R.§ 91.409 (a)(2); 14 C.F.R.§9 1.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commerciall y operate my, Robert M. Serino’s, small, lightweight unmanned aircraft for benefit of the community and the local economy

through Aerial Photograph y and Research and Development operations in Maryland and Virginia. Aerial P hotograph y and Research and Development operations currently rely primaril y on the use of larger aircraft running on combustible fuel and p osing an impact and flammables risk to the public. Granting m y, Robert M. Serino , request for exemption will reduce current risk levels and thereb y enhance safety. M y UAS aircraft do es not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional manned photographic and R&D aircraft , and requires much less flight time to complete a flight mission . Further, I operate at lower altitud es and in controlled airspace ; thereby , eliminating potential public risk by flyingto and from established airfields. I, Robert M. Serino , have been informall y anal yz ing flight information and will compile safety protocols and the implementation of a flight operations manual for real estate usage that exceeds currently

accepted means and m ethods for safe flight. Formal collection of information will be shared with the FAA , and will enhance the FAA's internal efforts to14

establish protocols for complyin g with the FAA M odernization and Reform Act of 2012. There are no personnel on board m y, Robert M. Serino’s , UAS and therefore the likelihood of death or serious bodily injury is significantl y diminished. My, Robert M. Serino ’s, operation of m y UAS, weighing approximately 3 pounds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly

I , Robert M. Serino , respectfully request that the FAA grant my exemption request. I , Robert M. Serino, am willing to cooperate in sharing information to benefit the FAA, safety of manned /unmanned aircraft, and the general public at large. Respectfully

submitted,

Robert M. Serino, Ph.D Lieutenant Colone l, US Army Retired FAA Licensed Private Pilot #33442220 8953 Chapel Avenue Ellicott City , MD 21043 (240)461
- 3954 robertmserino@yahoo.com Appendices: Appendix A - Phantom 2 Quick St art Guide Appendix B
- Phantom 2 User Manual Appendix C
- NAZA - M Quick Start Guide Appendix D
- Smart Flight Battery Safety Guidelines Appendix E
- 2.4G Bluetooth Datalink & iPad Ground Control Station User Guide Appendix F
- 5.8G VideoL ink User Manual Appendix G
- Cloverleaf Antenna User Manual Appendix H
- Robert M. Serino #33442220 Safety Protocols and Sy stem Controls Appendix I
- Robert M. Serino #33442220 Safety of Flight Manual and Record Appendix J
- RM Serino_UAS PI C Pilot L ogbook Extract