Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

March 26, 2015

U. S. Department of Transportation 

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

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

Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 

61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 

91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

I, Ryan Marlow, 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, Ryan Marlow, an owner and operator 

of small unmanned aircraft (N99887), be exempted from the 

Federal Aviation Regulations (“FARs”) listed below so that I, Ryan 

Marlow, may operate my small ultra light weight unmanned 

aircraft system (N99887) or (“UAS”) commercially in airspace 

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

As described herein I, Ryan Marlow, have added a professional 

grade quad-copter UAS (N99887) to my inventory equipped with 

a DJI Zenmuse H3 camera with intent for aerial 

videography/cinematography to enhance academic community 

awareness for those individuals and companies unfamiliar with 

the geographical layout of the Anchorage area, and pursue

implementation of emergency use UAS systems with public 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

entities; following exemption and approval by the FAA. This will 

allow for enhancement of the academic research experience for 

the Anchorage area. I plan to add a second quad-copter with a 

FLIR camera to my inventory in the future with comparable safety 

capabilities.

I have flown small RC multi rotors for over eight (8) years without 

incident. As well as working with local FSDO on flight safety, I 

am committed to safety with each flight. My, Ryan Marlow's, 

exemption request would permit operation of ultra light weight, 

unmanned (piloted by remote control) and comparatively 

inexpensive UAS(s) in tightly controlled and limited 

airspace. Predetermined in areas away from general public, 

airports, heliports and vehicular traffic for community videos, and 

within property boundaries for individual homeowner real estate 

listing videos/photos. 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, Ryan Marlow, have personally instilled 

safety protocols, sterile cockpit rule and checklists prior to 

operation. This will act to further safety protocols exclusive to 

lightweight UAS's specific to real estate video and photography 

usage as I, Ryan Marlow, 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, Ryan Marlow's, request comports with the Secretary 

of Transportation’s (FAA Administrator’s) responsibilities and 

authority to not only integrate UAS's into the national airspace 

system, but to “...establish requirements for the safe operation of 

such aircraft systems [UAS's] in the national airspace system” 

under Section 333(c) of the Reform Act specific to the use of 

UAS's for Aerial Surveying and Search and Rescue Systems. 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

Further I, Ryan Marlow, will conduct my operations in compliance 

with the protocols described herein or as otherwise established by 

the FAA.

For the reasons stated below I, Ryan Marlow, respectfully request 

the grant of an exemption allowing me to operate ultra light 

weight, remote controlled UAS’s for academic community 

awareness to benefit/stimulate attraction to the Anchorage area 

and to enhance real estate listing videos for homeowners who 

cannot afford expensive manned aircraft for the same purpose. 

Both of which will promote local economic growth through 

increased employment and increased tax base. Both with public 

safety in mind by keeping heavier manned aircraft containing 

combustible fuel that that poses potential public hazard.

I. Contact Information:

Ryan Marlow, Alaska Aerial Media, LLC

7960 Upper O'Malley Road Anchorage, AK 99507

Office: (907)-349-1628

Mobile: (907)-717-9794

Email: apexlivesound@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal 

Regulations From Which Ryan Marlow Requests Exemption 

are:

14 CFR 21;

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 Ryan Marlow seeks and the Reason He 

Seeks Such Relief:

I, Ryan Marlow, submit this application in accordance with the 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any 

currently applicable FARs operating to prevent me, Ryan Marlow, 

from commercial cinematic, academic and other flight operations 

within the national airspace system. The Reform Act in Section 

332 provides for such integration of civil unmanned aircraft 

systems into our national airspace system as it is in the public’s 

interest to do so. My, Ryan Marlow’s, ultra light weight UAS meets 

the definition of “small unmanned aircraft” as defined in Section 

331 and therefore the integration of my ultra light weight UAS is 

expressly contemplated by the Reform Act. I would like to operate 

my ultra light weight UAS prior to the time period by which the 

Reform Act requires the FAA to promulgate rules governing such 

craft. Thereby, providing direct experience and valuable 

information for formal regulation that can be administered 

uniformly to all real estate related UAS 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 reflect in favor of an exemption for me, Ryan 

Marlow. My UAS utilizes four (4) counter-rotating propellers for 

balance, control and stability. My UAS is equipped with GPS and 

auto return safety technology. Additionally, my UAS weighs less 

than five (5) pounds (far below the maximum 55 pound limit); 

including camera with gimbal.

I, Ryan Marlow, consider safety foremost with each flight. My 

small, unmanned aircraft is designed to hover in place via GPS 

and operate in less than a 24 knot (15 mph) 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 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

released. With three modes to choose from, I utilize the (GPS) 

Smart Mode for aerial videography/photography. This is the 

safest, most reliable and stable mode to prevent accident and 

hazard. When pilot communication is lost UAS is designed slowly 

descend to point of take off. I do not operate my UAS near 

airports, Hospitals nor Police heliports, and do not operate near 

areas where general public is within fifty to one hundred (50-100) 

yards depending on location, conditions and weather. I am 

constantly on alert for any manned aircraft (Police/Medical 

helicopters, etc.) 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. I Do call in to local Air Traffic Control to alert of 

my flight plan and operations as well as calling back when 

operations are complete. My UAS is capable of vertical and 

horizontal operations, and is flown only within my line of sight of 

me, as the remote control pilot. Utilizing battery power rather than 

combustible fuels, flights generally last between twelve (12) to 

seventeen (17) minutes, with an altitude under one hundred fifty 

(150) feet.

I, Ryan Marlow, utilize a fresh fully charged smart battery with 

each flight as a safety precaution; full flight time limit for each 

battery is eighteen (18) to twenty (20) minutes as tested. I do not 

operate my UAS at or below manufacture recommend minimum 

charge levels for operation or exceed temperature ratings of 0*F 

as per manufactures request; 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. Reserve batteries are at hand with each 

exercise to insure replacement for sufficient safe level of 

operation. I do not believe in taking risk that may cause a crash 

that could create hazard to the public/property/manned aircraft, 

and have no desire to lose an investment. I have clocked 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

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.

I, Ryan Marlow, am extremely cautious when operating of my 

UAS/ultra light weight 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 contemplated safety zone when it 

promulgated the Reform Act and the corresponding directive to 

integrate UAS's into the national airspace system. Ryan Marlow’s 

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 Ryan Marlow Request Will Benefit the Public As A

Whole:

Aerial videography for geographical awareness and for real estate 

marketing has been around for a long time through manned fixed 

wing aircraft and helicopters. For small budget production 

companies and average homeowners the expense of such aerial 

videography is cost prohibitive. Only large companies and high 

end film companies can afford to absorb such expense. Which is 

where the option of less expensive unmanned systems becomes 

affordable to anyone. Manned aircraft pose a threat to the public 

through potential catastrophic crashes that Alaska has come to 

expect every year. Anchorage area is a very busy airspace, which 

is why I am pursuing a 333 Exemption to lead the way 

for other businesses and or enthusiast. My main goal is to prove 

to public that my UAS can be used in Fire, Police or 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

natural disaster relief. My, Ryan Marlow's, UAS pose no such 

threat since size and lack of combustible fuel alleviates any 

potential threat to the 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, Ryan 

Marlow’s, exemption request furthers the public interest through 

academic/visual awareness of the geographical benefits in and 

around the Anchorage area. My ultra light weight UAS is battery 

powered and creates no emissions that can harm the 

environment. The consequence of my ultra light weight UAS 

crashing is far less than a full size helicopter or fixed wing aircraft; 

which are heavy, contain combustible fuel and can cause 

catastrophic devastation to the public.

The public’s interest is furthered by minimizing ecological and 

crash threat by permitting aerial video/photo capture through my 

battery operated ultra light weight UAS's. Permitting me, Ryan 

Marlow, to immediately fly within national air space furthers 

economic growth. Granting my exemption request substantially 

furthers the economic impact for the Anchorage community for 

companies looking to relocate or build in the Anchorage area as 

well as individuals looking to relocate for career advancement 

through academic and geographical awareness. Both of which 

serve as a stimulus to the community.

V. Reasons Why Ryan Marlow's Exemption Will Not 

Adversely Affect Safety Or How The Exemption Will Provide 

a Level of Safety At Least Equal To Existing Rule:

My, Ryan Marlow’s, exemption will not adversely affect safety. 

Quite the contrary, for the reasons stated permitting me, Ryan 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

Marlow, to log more flight time in FAA controlled airspace, with 

communication with the FAA, will allow me to contribute to the 

innovation and implementation of new and novel, as of yet 

undiscovered safety protocols.

I, Ryan Marlow, submit the following representations of 

enhancements to current aerial videography, photography and 

aerial surveying aspects:

 My UAS weighs less than 5 pounds complete with a small 

ultra light weight high quality DJI Zenmuse H3 camera.

 I only operate my UAS below 200 feet (well within the 400 

foot permissible ceiling set by the FAA Modernization and 

Reform Act of 2012.)

 My UAS only operates for 12-17 minutes per flight.

 I land my UAS prior to manufacturer recommended minimum 

level of battery power.

 I pilot my UAS through remote control only by line of sight.

 My UAS has GPS a flight safety feature whereby it hovers 

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 primary importance.

 I always obtain all necessary permissions prior to operation.

 I have procedures in place to abort flights in the event of 

safety breaches or potential danger.
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

My, Ryan Marlow’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, helicopters are the primary means of aerial 

video and photography for community awareness and real estate. 

While the safety record of such helicopters is remarkable; it is far 

safer to operate a battery powered ultra light weight UAS.

 First, the potential loss of life is diminished because UAS's 

carry no people on board and I only operates 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.

 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, Ryan 

Marlow’s, UAS permits exemption from Part 21 because my 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

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, Ryan Marlow’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 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, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable 

insofar as my UAS utilizes electronic global positioning systems 

with a barometric sensor.

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

aircraft certifications and registrations. They are inapplicable for 

the same reasons described above. The equivalent level of safety 

will be achieved by maintaining any such required certifications 

and registrations by me, Ryan Marlow.
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

B. 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, Ryan Marlow, 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 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 me, Ryan Marlow, to operate my UAS meet and exceed 

current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

C. 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 200 AGL; safely below the standard of 400 

AGL. I, Ryan Marlow, will however operate my UAS in safe 

areas away from public and traffic, providing a level of safety at 

least equivalent to or below those in relation to minimum safe 

altitudes. Given the size, weight, maneuverability and speed of 

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

D. 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. . . .”
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

These Regulations only apply to aircraft with an airworthiness 

certificate. They will not, therefore, apply to my, Ryan Marlow's, UAS. 

However, as a safety precaution I inspect my UAS before and after 

each flight.

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 UAS permits 

exemption from Part 21 because my, Ryan Marlow’s, UAS meets 

an equivalent level of safety pursuant to Section 333 of the 

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

airworthiness certificate requirement under both the Act (49 

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

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

airworthiness certificate requirement in consideration of the 

weight, size, speed, maneuverability and proximity to areas such 

as airports and dense populations. My UAS meets or exceeds 

each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of 

an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) 

requires an aircraft flight manual in the aircraft. As there are no 

pilots or passengers, and given the size of the UAS's, this 

Regulation is inapplicable. An equivalent level of safety will be 

achieved by maintaining a manual. The FAA has previously 

issued exemptions to this regulation in Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 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.
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

In summary, Ryan Marlow 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, Ryan Marlow’s, 

small unmanned vehicle/lightweight unmanned aircraft vehicle in 

community awareness and real estate operations, and to develop 

economic platforms for real estate to enhance the experience of 

those seeking to relocate to the Anchorage area. Currently, area 

awareness and real estate aerial videography/photography relies 

primarily on the use of larger aircraft running on combustible fuel. 

Posing potential risk to the public. Granting my, Ryan Marlow’s, 

request for exemption will reduce current risk levels and thereby 

enhance safety. My UAS craft does not contain potentially

explosive fuel, is smaller, lighter and more maneuverable than 

conventional real estate video and photographic aircraft with 

much less flight time. Further, I operate at lower altitudes and in 

controlled airspace eliminating potential public risk flying to and 

from established airfields. I, Ryan Marlow, have been informally 

analyzing flight information and will compile safety protocols and 

the implementation of a flight operations manual for usage that 

exceeds currently accepted means and methods for safe flight. 

Formal collection of information shared with the FAA will enhance 

the FAA's internal efforts to establish protocols for complying with 

the FAA Modernization and Reform Act of 2012. There are no 

personnel on board my, Ryan Marlow’s, UAS and therefore the 

likelihood of death or serious bodily injury is significantly 

diminished. My, Ryan Marlow’s, operation of my UAS, weighing 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

less than 5 pounds and traveling at lower speeds within limited 

areas will provide an equivalent level of safety as that achieved 

under current FARs. Accordingly I, Ryan Marlow, respectfully 

request that the FAA grant my exemption request and am willing 

to cooperate in sharing information to benefit the FAA, safety of 

manned aircraft, and the general public at large.

Respectfully,

Ryan Marlow, Owner / Manager

Alaska Aerial Media, LLC

7960 Upper O'Malley Road 

Anchorage, AK 99507