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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 Licensed Private 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 system (“UAS”) 

commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein I, Robert M. Serino, FAA Licensed Pilot #33442220 for Airplane Single 

Engine Land am experienced in flying hobby helicopters for recreational purposes and for 

US Government purposes. I have added commercial grade DJI Phantom 2 quad-copters to 

my inventory that weigh approximately 3 pounds and are equipped with either a GoPro

Hero3+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 only for daytime Aerial 

Photography and Research and Development. As outlined below, our intent is enhancement 

of community awareness for those individuals, not-for-profit organizations, and companies 

having either aerial photography or Research and Development needs in Maryland and 

Virginia as performed under an FAA-approved exemption:

 Application examples of Aerial Photography include efforts in support of real estate, 

construction, specialized facilities and events. 

 Application examples of Research and Development include fast, remote sensing of 
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toxic and dangerous materials and conditions with compact, advanced technology

sensors, system integration, and technical trials under simulated, relevant conditions. 

 We would also make our services available on a volunteer/no-cost basis to local Notfor-Profit / Search and Rescue / HAZMAT / Fire Fighting organizations.

Figure 1. DJI Phantom 2 quad-copters with Radio Controllers and either a GoPro Hero3+Black camera 

or a FLIR Tau 2 camera. A tripod-mounted 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 recently approved by the FAA under Section 333 

Exemption No. 11138 for Douglas Trudeau on 5 January 2015. The following nine 

Appendices 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 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
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Appendix F - 5.8G VideoLink User Manual

Appendix G - Cloverleaf Antenna User Manual

Appendix H - Robert M. Serino #33442220 Safety Protocols and System Controls

Appendix I - Robert M. Serino #33442220 Safety of Flight Manual and Record

In terms of piloting experience under an exemption, I, Robert M. Serino, FAA Licensed Pilot

#33442220, have been approved by the FAA to fly airplanes for over twenty-six (26) years 

since 6 April 1988, and have been flying RC electric helicopters for 1 (one) year; all without 

incident of any kind. The following Appendix J is an extract of my Pilot Logbook regarding 

take-offs/landings and flying hours of Phantom 2 UAS as Pilot-In-Command (PIC):

Appendix J - RM Serino_UAS PIC Pilot Logbook Extract

We are committed to safety with each flight, and an exemption would permit operation of 

ultra lightweight, unmanned (piloted by remote control) and comparatively inexpensive UAS

in tightly controlled and limited airspace. We would fly in predetermined 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). 

Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored 

amateur hobbyists 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 hazards 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 photography usage as I, Robert M. Serino, record flight data and other 

information gained through permitted flight operations to share with the FAA through any 

required FAA reports to assist with future protocol and safety regulation.

Granting my, 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 system, and 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 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.
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For the reasons stated below, I, Robert M. Serino, respectfully request the grant of an

exemption allowing me to operate ultra lightweight, remote controlled UAS’s for daytime 

Aerial Photography and Research and Development. Our intent is enhancement of

community awareness for those individuals, not-for-profit organizations, and companies 

having either Aerial Photography 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 by greatly enhancing commercial property listings for those 

who cannot afford expensive manned aircraft for the same purpose; thereby, promoting 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 enhanced 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 many 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 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.
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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, seeking relief from any currently applicable FARs operating to prevent me, 

Robert M. Serino, contemplated commercial cinematic, charitable, voluntary, 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. My, Robert M. Serino’s, 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 lightweight UAS prior to the time period by which the Reform 

Act requires the FAA to promulgate rules governing such craft. Allowing such will provide

direct experience and valuable information for formal regulation that can be administered 

uniformly to other UAS-related activities for aerial video and photography. 

The Reform Act guides the Secretary in determining the types of UAS's that may operate 

safely in our national airspace system. Considerations include: 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 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 each and every

flight. My small-unmanned aircraft is designed to hover in place via GPS and operate in less 
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than a 24 knots (15mph) wind. For safety, stability and fear of financial loss, I will not fly in 

winds exceeding 16 kph (10 mph). Built-in safety systems 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 Aerial Photography and Research and Development. 

This is the safest, most reliable and stable 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-tohome; i.e., within 3 meters of the point of take off. In accordance with FAA regulations, I

do not operate my 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 anywhere within 150 feet. With an observer always present, we are

constantly 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 my location or I suspect manned aircraft may approach near my location. 

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 software-based, GPS-enabled 

input to the NAZA flight control software (Figure 3).

Figure 3. Maximum allowable height above ground and maximum allowable distance are controlled by 

software input to the NAZA 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 fully-charged Smart Battery with 
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each the start of each flight as a safety precaution; full flight time for each battery is 15

(fifteen) to twenty (20) minutes as tested; thereby providing not less than a fifty (50) percent 

Smart Battery power margin. I do not operate my UAS at or below manufacturerrecommend 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 Batteries are kept at hand 

and in reserve with each flight event to insure fast replacement and an always foremost safe 

level of operation (Figure 4).

Figure 4. 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. 

I do not believe in taking any risk that may cause any harm or could create a hazard to the 

public, to property and to manned aircraft, and have neither any desire what-so-ever to create 

such nor any desire to risk loss of an investment. I have recorded numerous practice flights 

in remote areas as a hobbyist simulating flights 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 response reflex time. All for the sake of safety, I, Robert M. 

Serino, am extremely cautious when operating my UAS/ultra lightweight unmanned aircraft 

and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 

95 § 333 (b). Given the small size and weight of my UAS, it falls well within Congress’s 
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contemplated safety zone when it promulgated the Reform Act and the corresponding 

directive to integrate UAS's into the national airspace system. Robert M. Serino’s Phantom 2 

UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to 

the general public or national security.

IV. How Robert M. Serino’s Request Will Benefit the Public As A Whole:

Aerial Photography for geographical awareness and commercial sales has been conducted for 

years through manned fixed-wing and rotary-wing aircraft. For small budget businesses and 

homeowners, the expense of such Aerial Photography is cost-prohibitive in the hundreds to 

thousands of dollars. Only larger companies and luxury home owners can afford to absorb 

such expense; depriving non-luxury home owners and small businesses from a valuable 

imaging tool. Small UAS will allow businesses to leverage airspace faster and at a greatly 

lower cost than a manned system.

Research and Development for fast, remote sensing of toxic and dangerous materials, and the 

supporting system integration of sensor packages is focused on maximizing the value of 

unmanned systems for employment into very hazardous conditions and for 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.

Manned aircraft can pose a threat to the general public through a potentially 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 violently 

upon impact. My UAS poses 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 commercially 

flown UAS's into the national airspace system, hence the passing of the Reform Act. 

Granting my, Robert M. Serino’s, exemption request furthers the public interest through 

visual 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 my 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 by minimizing the potential for ecological damage 

and crash threats by permitting my battery operated ultra lightweight UAS's. Permitting me, 
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Robert M. Serino, to immediately fly within national air space furthers economic growth. 

Granting my 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 Exemption 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 flying for 

26 years with zero incidents and quite to the contrary for the reasons stated, permitting me, 

Robert 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

innovation and implementation of new, innovative, and as of yet undiscovered safety

protocols 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 representations on enhancements to 

current approaches to Aerial Photography 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 only operate my UAS at less than 150 feet altitude. Altitude limits are software-defined 

and GPS-enabled, and well within the 400 foot permissible ceiling set by 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-Location, and embedded emergency modes for 

Auto-Land and Return-to-Home (Figure 5); 

 I pilot my UAS with the aid of a Radio Controller, and additional emergency modes are 

embedded within the Radio Controller for Fail-Safe, Home-Lock, and Command ShutOff;

 The Ground Control Station I use 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 only operates for less than 10 minutes per flight with an unused 50% Smart 

Battery power margin;

 I land my 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 actively analyze flight data and other sources of information to constantly update and 

enhance safety protocols;

 I only operate in reasonably safe environment that are strictly controlled, are away from 

power lines, elevated lights, airports and actively populated areas;

 I conduct extensive pre-flight inspections and protocol, during which safety carries the 
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pre-eminent importance;

 I always 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, Robert 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 system, 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 incidents 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-time monitoring of Smart Battery status, GPS signals, GeoLocation, and embedded emergency modes for Auto-Land and Return-to-Home. Additional emergency 

modes for Fail-Safe, Home-Lock, and Command Shut-Off are embedded on the Radio Controller. 

Weather App for real-time 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 arrowhead and GPS-recorded home point indicated by “H” icon.

 First, the potential loss of life is diminished because UAS's carry no people onboard and I 

only operate my 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 

greatly diminished.
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 Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot 

away from and avoid hazards quickly and safely.

 Lastly, given its small size and weight, even when close enough to capture amazing 

images, my 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. Accordingly, my 

UAS has been experimentally operated for familiarization/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, 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, Robert M. Serino’s, 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. 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 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 a safety/flight manual with the 

PIC during UAS flight operations. The FAA has previously issued exemptions to this 

regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 

10602, 10700 and 32827.

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

the global positioning system to report altitude in real-time through the Ground Control 

Station plus maximum allowable altitudes and distances are pre-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 by maintaining any such required certifications and

registrations by me, Robert M. Serino on site during UAS flight operations.
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B. 14 C.F.R. § 45.23: Marking of the 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 than the minimal 

lettering requirement. Regardless, I will mark the 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 UAS will see the markings. The 

FAA has previously 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.

Pursuant 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 by 

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 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 me, Robert M. Serino, Principal and FAA 

Licensed Private Pilot #33442220, to operate my 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; safely below the standard of 400 AGL. I,

Robert M. Serino, will operate my 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 higher 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 apply to 

aircraft with an airworthiness certificate. They will not, therefore, apply to my, Robert M. 

Serino’s UAS. Nevertheless, as a safety precaution, I inspect my UAS before and after each 

flight. As an added measure, my aircraft have been routinely checked by the local OEM 

dealer, Intelligent UAS www.1uas.com to insure all elements and the total system are 

functioning to specification. Further, only OEM replacement parts are used in my Phantom 2 
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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 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 operational 

area of my UAS permit exemption from Part 21 because my, Robert M. Serino’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 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 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. 14C.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 onsite 

during UAS flight operations. The FAA has previously issued exemptions to this regulation 

in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 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, 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.§91.409 (a ) (2); and, 14 

C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Robert M. Serino’s, small, 

lightweight unmanned aircraft for benefit of the community and the local economy through 

Aerial Photography and Research and Development operations in Maryland and Virginia. 

Aerial Photography and Research and Development operations currently rely primarily on 

the use of larger aircraft running on combustible fuel and posing an impact and flammables 

risk to the public. Granting my, Robert M. Serino, request for exemption will reduce current

risk levels and thereby enhance safety. My UAS aircraft does 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 altitudes and in controlled airspace; thereby, eliminating 

potential public risk by flying to and from established airfields. 

I, Robert M. Serino, have been informally analyzing 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 methods for safe flight. Formal collection of 

information will be shared with the FAA, and will enhance the FAA's internal efforts to 
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establish protocols for complying with the FAA Modernization and Reform Act of 2012. 

There are no personnel on board my, Robert M. Serino’s, UAS and therefore the likelihood 

of death or serious bodily injury is significantly diminished. My, Robert M. Serino’s, 

operation of my 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 Colonel, 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 Start 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 VideoLink User Manual

Appendix G - Cloverleaf Antenna User Manual

Appendix H - Robert M. Serino #33442220 Safety Protocols and System Controls

Appendix I - Robert M. Serino #33442220 Safety of Flight Manual and Record

Appendix J - RM Serino_UAS PIC Pilot Logbook Extract