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July 10, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform

Act and Part 11 of the Federal Aviation Regulations from: 14 CFR

61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a);

91.407(a)(1); 91.409 (a)(1) and (2); 91.417(a) and (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

(the “Reform Act”) and 14 C.F.R. Part 11, Ron Greenberg Videography & Photography, an

operator of Small Unmanned Aircraft Systems (“sUASs”) for aerial image

acquisition including but not limited to, the following industries: motion

picture and television, real estate, short range inspection, mapping &

survey, agriculture, search & rescue, hereby applies for an exemption from

the Federal Aviation Regulations (“FARs”) to allow commercial operation of

its sUASs. Ron Greenberg Videography & Photography's requested exemption would permit the

operation of sUAS under controlled and secure conditions that is: (i) limited,

(ii) predetermined, (iii) subject to controlled access, and (iv) provide greater

safety in connection with aircraft operations. As established by the

exemptions already granted by the FAA, approval of Ron Greenberg Videography & Photography’s,

exemption would enhance safety and fulfill the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities to “...establish

requirements for the safe operation of such aircraft systems in the national
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airspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant is:

Ron Greenberg Videography & Photography

Ronald Greenberg

Phone: 607 226 1362

Email: videoserv2@aol.com

Address: 27 Park Drive, Northville, NY 12134

Private Pilot certificate 2209382 

Regulations from which the exemption is requested:

14 CFR 61.113(a) and (b)

14 C.F.R. 91.103

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151(a)

14 CFR 91.405(a)

14 CFR 407(a)(1)

14 CFR 409(a)(2)

14 CFR 417(a) and (b)

sUASsOperated by Ron Greenberg Videography & Photography weigh less than 55 pounds,

including the payload (i.e. camera, lens, and gimbal). They operate at

speeds of no more than 50 knots, can hover, and can simultaneously move

vertically and horizontally. Ron Greenberg Videography & Photography will only operate its

sUASs in line of sight and will operate only within the secure area described

in the FOPM. Such operations will insure that the sUAS will “not create a hazard to users of the national 

airspace system or the public.” Given the small size of Ron Greenberg Videography & Photography's 
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sUASs and the restricted secure environment within which they will operate, Ron Greenberg

Videography & Photography's sUAS operations adhere to the Reform Act’s safety

requirements. Additionally, due to the size of the sUASs, permission from

relevant property owners or other applicable parties, and the limited areas

in which they will operate, approval of this application presents no national

security issues. Based on the substantial level of safety surrounding the

proposed operations, and the significant public benefit (enhanced safety),

reduction in environmental impacts (reduced emissions and noise), the

grant of the requested exemption is in the public interest. Accordingly,

Ron Greenberg Videography & Photography respectfully requests that the FAA grant the

requested exemption. 

Aircraft And Equivalent Level Of Safety

The operating limitations proposed by Ron Greenberg Videography & Photography provide for

at least an equivalent or higher level of safety because operations further

enhance safety of aerial image collection using conventional aircraft.

The limitations and conditions include:

• The sUASs will weigh less than 55 pounds. Frequently far less.

• Flights will be operated within line of sight of a pilot and/or observer.

• Maximum flight time for each operational flight will be no more than 15

minutes. Flights will be terminated at no less than 25% battery power

reserve should that occur prior to the 15 minute limit.

• Flights will be operated at an altitude below 400 feet AGL, and not

more than 200 feet above an elevated platform from which filming is

planned.

• Minimum crew for each operation will consist of the sUAS Pilot, camera operator, and a
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Visual Observer. 

• A sUAS pilot will be an FAA licensed airman with at least a sport pilot’s

certificate, and third class medical or valid US or Canadian drivers

license.

• A sUAS pilot will be Pilot in Command (PIC).

• The sUAS will only operate within a confined secure area as defined

in the FOPM.

• A briefing will be conducted for planned sUAS operations prior to each

day’s flight. All personnel performing duties within the boundaries of

the safety perimeter are required to attend.

• The operator will obtain consent of all persons involved in the filming

and ensure that only consenting persons will be allowed within 500

feet of the flight operation.

• The Pilot and observer must be trained in sUAS operations and have

received current information on the particular sUAS to be operated as

required by the FOPM.

• The Observer and pilot will be able to communicate by voice and/or

text at all times.

• Written and/or oral permission from the relevant property holders will

be obtained prior to flight operations.

• All appropriate permissions and permits will be obtained from

territorial, state, county, or city jurisdictions, including local law

enforcement, fire, or other appropriate governmental agencies.

• If the sUAS loses communications or loses its GPS signal, the sUAS

will have the capability to return to a pre-determined location within the
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secure perimeter and land.

• The sUAS will have the capability to abort a flight in case of

unpredicted obstacles or emergencies.

14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations:

Pilot in Command

Sections 61.113 (a) and (b) limit private pilots to non-commercial

operations. Because the sUAS will not carry a pilot or passengers, the

proposed operations can achieve the equivalent level of safety of

current operations by requiring the PIC operating the aircraft to have a

private pilot’s license rather than a commercial pilot’s license to

operate a sUAS. Unlike a conventional manned aircraft, a sUAS is

remotely controlled by a ground-based operator. The operational area

is controlled and restricted, and all flights are planned and coordinated

in advance. The level of safety exceeds that provided by a single

individual holding a commercial pilot’s certificate operating a

conventional aircraft. The risks associated with the use of a sUAS are

so diminished from the level of risk associated with commercial

operations contemplated by Part 61 allowing sUAS use by a sport pilot

as the PIC exceeds the present level of safety sought by 14 C.F.R.

§61.113 (a) and (b).

14 C.F.R. § 91.103:

Preflight Action

Section 91.103 requires each pilot to preflight an aircraft before flight

to insure the safety of flight. As FAA approved rotorcraft flight manuals

will not be used, an exemption is requested. However, an equivalent
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level of safety will be provided. The PIC will take all actions, including

reviewing weather, flight battery requirements, landing and takeoff

distances, and aircraft performance data before commencement of

flight.

14 C.F.R. §91.119(c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft.

Section 91.119 provides, in pertinent part, that: “except when necessary for

takeoff or landing, no person may operate an aircraft below the following

altitudes: .....

(c) Over other than congested areas. An altitude of 500 feet above the

surface, except over open water or sparsely populated areas. In those

cases, the aircraft may not be operated closer than 500 feet to any person,

vessel, vehicle, or structure.”

Because Ron Greenberg Videography & Photography requests authority to operate at

altitudes no higher than 400 AGL, and not more than 200 above an

elevated platform from which filming is planned, an exemption is needed to

allow such operations. Except for the limited conditions stated in the FOPM,

the sUAS will never operate higher than 400 AGL. It will, however, be

operated in a restricted area within a security perimeter, where buildings

and people will not be exposed to operations without their pre-obtained

consent.

The equivalent level of safety will be achieved given the size, weight, and

speed of the sUAS as well as the location where it is operated. No flight will

be taken without the permission of property owners or local officials.

Because of the advance notice to the property owners and participants in
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the filming activity, all affected individuals will be informed of the planned

flight operations. Compared to flight operations for manned aircraft and the

lack of flammable fuel, any risk associated with the proposed sUAS

operations is far less than conventional aircraft operating at or below 500

AGL. In addition, the low-altitude operations of the sUAS will ensure

separation between a sUAS and conventional aircraft.

14 C.F.R. §91.121: Altimeter Settings

Section 91.121 requires each person operating an aircraft to maintain

cruising altitude by reference to an altimeter that is set “...to the elevation of

the departure airport or an appropriate altimeter setting available before

departure.” As a sUAS may not have a barometric altimeter, but instead a

GPS altitude data, an exemption is needed. An equivalent level of safety

will be achieved by the operator, pursuant to the FOPM and Safety Check

list, confirming the altitude of the launch site shown on the GPS altitude

indicator before flight.

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

Section 91.151(a) 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 . . . .”

The typical battery powering the Ron Greenberg Videography & Photography sUASs provides

less than 25 minutes of powered flight. To meet the 30-minute reserve

requirement in 14 CFR §91.151, sUAS flight would not be possible. Given

the limitations on the sUAS’s proposed flight area and its proposed
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operations within a predetermined location, a longer time frame for flight in

daylight VFR conditions is reasonable. Furthermore, operating the sUASs in

a tightly controlled area where only people, property owners, or official

representatives who have signed waivers will be allowed, less than 30

minutes of reserve fuel does not engender the type of risk that §91.151(a)

was intended to address.

Ron Greenberg Videography & Photography believes that safety can be achieved by limiting

flights to 18 minutes or 25% of battery power, whichever occurs first. This

restriction would be more than adequate to return the sUAS to its predetermined

landing zone from anywhere in its limited operating area.

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

Inspections

These regulations require that an aircraft operator or owner shall “have that

aircraft inspected as prescribed in subpart E of this part and shall between

required inspections, except as provided in paragraph (c) of this section,

have discrepancies repaired as prescribed in part 43 of this chapter...,” and

others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an

airworthiness certificate, these sections will not apply to Ron Greenberg

Videography & Photography. Maintenance will be accomplished by the operator.

An equivalent level of safety will be achieved because the sUASs are

limited in size, will carry a small payload and operate only in restricted

areas for limited periods of time. If mechanical issues arise, the sUAS can

land immediately and will be operating from no higher than 400 feet AGL.

As provided in the FOPM, the operator will ensure that the sUAS is in
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working order prior to flight, perform any required maintenance, and keep a

log of any maintenance performed. Moreover, the operator is the person

most familiar with the sUAS and best suited to maintain it in an airworthy

condition.

Summary for Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for

publication in the Federal Register, should it be determined that publication

is needed:

Ron Greenberg Videography & Photography seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a);

91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) to operate

commercially a small unmanned vehicle (55 pounds or less) in commercial

image acquisition operations.

As established by the sUAS exemptions already granted by the FAA,

allowing commercial operations of sUASs in agriculture, real estate,

inspection, S & R, and film industries will enhance safety by reducing risk.

Conventional survey, agricultural, mapping, inspection, and film operations,

using turbine aircraft, operate at low altitudes and present the risks

associated with aircraft that weigh around 4,000 pounds, and which carry

large amounts of Jet A fuel. Such aircraft must also fly to and from the

target location. In contrast, a sUAS weighing fewer than 55 pounds and

powered by batteries eliminates virtually all of that risk given the small size

and lack of combustible fuel. The sUAS is carried, and not flown, to target

site. In this regard, the sUAS carries no passengers or crew and, therefore,

will not expose them to the risks associated with manned flights.
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The operation of sUASs conducted in the strict conditions outlined in the

FOPM will provide an equivalent level of safety supporting the grant of the

exemption requested herein. The sUASs operate at slow speeds, close to

the ground, and in a secure environment. As a result, they are far safer than

conventional operations conducted with turbine helicopters flying near the

ground and people.

Privacy

All flights will occur over private or controlled access areas with the property

owner’s prior consent and knowledge. Recognizable images will only be

recorded of people who have given their consent or otherwise have agreed

to be in the area where active image acquisition will take place.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

(size, weight, speed, operating capabilities, proximity to airports and

populated areas and operation within visual line of sight and national

security) provide more than adequate justification to grant Ron Greenberg Videography & 

Photography’s requested exemption, allowing for Ron Greenberg Videography & Photographys’sUAS 

commercial operations for the listed industries pursuant to the included FOPM.

If you have any questions or need any additional information, please

contact the undersigned by phone at 607 226 1362 or via email at Videoserv2@aol.com.

Sincerely,

Ron Greenberg

Ron Greenberg Videography & Photography