FROM:

Plt. William Clary PPL#3791891

P.O. Box 1854

1252 Alpinview Dr.

Big Bear City, CA 92314

Tel: (970) 531-2062

Email – wclary@gotaerial.com Regulatory Docket No. ___________

TO:

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:

Below is the requested information via the “Public	Guidance	for	Petitions	for	Exemption	Filed	under	

Section	333”.	William	A.	Clarys	requested exemption would permit the operation of Unmanned Aerial 

Systems (UAS) under a controlled and safe environment. The granting of an exemption would greatly 

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 airspace system.”

Section 333(c) of the Reform Act.

1. As pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”)

and 14 C.F.R. Part 11, William A. Clary an owner and operator of unmanned aerial systems (UAS) . 

for the aerial video and photography for the motion picture and television industry along with inspections

hereby applies for an exemption from the Federal Aviation Regulations (“FARs”) to allow for me to conduct 

commercial UAS operations with my DJI S1000 and Aeronavics Skyjib 8.

William A. Clarys has been designing, building and operating various forms of UAS including fixed wing, 

single rotor, and mutlirotor aerial platforms for the previous 15+years. I started my UAS carrier in 1997 

during my enlistment in the U.S. Army (Honorably Discharged) and have been providing professional aerial 

imagery since 2001. I currently adhere to all the current FAA safety requirements in addition to others which 

have allowed me to have perfect safety record (btgoG).

William A. Clary contacted the FAA in 2001 as to my actions and intentions and was advised to pass the 

private pilot written exam, which he did. William A. Clary also has his single engine private pilot license

(PPL#3791891) and is current as of Jan2015. My Class III Medical is also current as of Dec2014.

Given William A. Clarys body of work and safety record he has been admitted into the International 

Cinematographers Guild (local 600) as a Drone Aerial Service Provider. William A. Clary also have taken a 

UAS flight test from an FAA 333 exempt company (Pictorvision) and passed. 

William A. Clary has safely provided UAS services for 14years, 1000’s of clients, has 4,500+ UAS operating 

hours, trained many pilots, conducted news interviews, and my works can be seen on the History Channel, 

Weather Channel, Discovery Channel, commercials and feature films, documentaries, Colorado Department 

of Transportation, Denver Police, and on Getty Images as a contributor, to mention a few.

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
Also, William A. Clary has or have been a consultant, test pilot, developer and or contributor for many UAS 

industry manufactures and developers such as DJI Innovations, Aeronavics, Dragonlink, AXI Motors, 

Hoverfly, and Honeywell.

The equipment William A. Clary operates are multi-rotorcraft equipped with an on board GPS and Return to 

Home Feature, weighting 55 lbs or less including camera and or payload. I will operate them under normal

VFR conditions, at speeds of no more than 50 KIAS and will have the capability to hover and move in the 

vertical and horizontal and will only be operate line of sight 

William A. Clarys operations will insure that the UAS will not create a hazard to the public or National Air 

Space described in the FMRA 333, and I will insure to get a COA when necessary. 

Given William A. Clarys experience and body of work, the small size of the UAS, the limited environment in 

which, they operate and safety record, William A. Clarys request falls within that zone of safety 

in which Congress envisioned that the FAA must, by exemption, allow commercial operation. 

As the Pilot in Command (PIC), William A. Clary agrees to fly my UAS within line of sight, less then 400feet 

above the ground, slower then 55kts, and 5miles from any airport, heliport, seaplane base, spaceport, 

restricted airspace, or any other location with aviation activities, unless the nearest air traffic authority has 

been notified and operations have been cleared. 

All of William A. Clarys UAS’s have proven capability for controlled and safe flight, in addition the DJI 

S1000 and Aeronavics Skyjib 8. UAS’s have been approved in previous 333 exempt companies. 

2. Preflight inspections, maintenance and repair schedule and logs have been provided in the attached 

documents.

3. William A. Clarys will only utilize radio frequencies that comply with all Federal Communications 

Commission regulations (FCC). 

4. As the PIC, William A. Clary agrees to maintain a current single engine private pilot license and adhere to 

any and all current and future FAA UAS regulations. 

5. As the PIC, William A. Clarys agrees to maintain a current III Class Medical. 

6. William A. Clarys safety procedures include using a Visual Safety Officer qualified with at least a “passed”

single engine private pilot written exam. 

7. William A. Clarys will operate my UAS no higher then 400feet, no faster then 50kts, visual line of sight, 

weigh less then 50lbs, and during standard VFR conditions. 

8. William A. Clarys planed use of purpose is for motion picture filming or similar

operations, flight demonstration, area inspections or similar and can expect to safety hazzrds such as 

telephone wires, buildings, birds, people, blowing objects, wind, rain and snow. 

9. When operating within 5miles from any airport, heliport, seaplane base, spaceport, restricted airspace, or 

any other location with aviation activities, aerial operations will not happen unless the nearest air traffic 

authority has been notified and aerial operations have been approved.

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
10. William A. Clarys agrees to operate all my UAS’s within visual line of site and will conduct extensive 

preflight site inspection ensuring a constant line of sight. 

11. Preflight procedures have been include in Appendix and exhibit a desire for the highest level of safety. 

12. William A. Clary agrees to notify the Flight Standards District Offices (FSDOs) prior to operations, such as 

motion picture and television filming, or pipeline and power line patrol.

13. William A. Clary agrees to obtain a COA when applicable and do so before conducting any aerial 

operations. 

14. In conclusion, William A. Clary believes that being granted an exemption will greatly increase the safety 

and cinematic quality of the UAS industry. 

Additional	and	supporting	information	can	be	found	below	or	attached to	this	document	

o UAS Flight Operations and Procedures Manual (FOPM)......Attachment 1

o UAS Aircraft Flight Maintenance Records...................... Attachment 2

o UAS Flight Authorization Sheet ..................................Attachment 3

o UAS Pilot Flight Log ...............................................Attachment 2

o UAS Inspection and Maintenance Manual (POH)...............Attachment 4, 4-1

o UAS Maintenance and Repair Log Book........................ Attachment 2

o UAS Manufacturer Manuals .......................................Attachment 5, 5-1

o UAS Training Manual..............................................Attachment 1

o UAS Preflight, Takeoff and Landing Checklist ................Attachment 6, 6-1

o UAS Risk Assessment Tool ...................................... Attachment 7

o UAS Crew Data sheet .............................................Attachment 2

o UAS Preflight Safety Assessment ................................Attachment 8

UASs operated by William A. Clary will 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. William A. Clary will only operate its UASs in line of sight

and will operate only within the sterile area described in the FOPM. Such operations will insure that

the UAS will “not create a hazard to users of the national airspace system or the public.”

Given the small size of William Clarys UASs and the restricted sterile environment within which

they will operate, William Clarys UAS operations adhere to the Reform Act’s safety requirements.

Additionally, due to the size of the UASs 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, William Clary respectfully requests that the

FAA grant the requested exemption without delay.

Aircraft And Equivalent Level Of Safety

The operating limitations proposed by William A. Clary provide for at least an equivalent or higher

level of safety because operations further enhance safety of movie and television filming using

conventional aircraft.

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
As set forth in the FOPM, the limitations and conditions include:

• The UASs will weigh less than 55 pounds

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

Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery 

power reserve should that occur prior to the 30

minute limit.

• Flights will be operated at an altitude of no more than 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 UAS Pilot, the Visual Observer,

and the Camera Operator.

• A UAS pilot will be an FAA licensed airman with at least a private pilot’s certificate

and third class medical.

• A UAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the UAS Pilot, who 

possesses the necessary PIC qualifications, is also present on set (i.e. the Aerial Coordinator), that person can 

also be designated as PIC.

• The UAS will only operate within a confined “Sterile Area” as defined in the FOPM.

• The FOPM requires the establishment of a “Security Perimeter” for the flight operations area.

• A briefing will be conducted for planned UAS 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 file a FAA Form 7711-1, or its equivalent, as modified in light of

the requested exemption, with the appropriate Flight Standards District Office (”FSDO”).

• The operator will obtain consent of all persons involved in the filming and ensure that only consenting 

persons will be allowed within 100 feet of the flight operation. This radius may be reduced to 30 feet based 

upon an equivalent level of safety determination, as required under the FOPM. With the advanced permission 

of the FSDO, operations at closer range can be approved.

• The operator will submit a written Plan of Activities to the FSDO three days before the proposed shoot as 

required in the FOPM.

• The Pilot and observer must be trained in UAS operations and have received current information on the 

particular UAS to be operated as required by the FOPM.

• The Observer and pilot will at all times be able to communicate by voice and/or text.

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

• All required 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 UAS loses communications or loses its GPS signal, the UAS will have the capability to return to a predetermined location within the Security Perimeter and land.

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
• The UAS will have the capability to abort a flight in case of unpredicted obstacles or

emergencies.

Specific sections of 14 CFR from which William A. Clary is seeking exemptions are:

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).

These limitations and conditions to which I, William A. Clary agrees to be

bound when conducting business/commercial operations under this FAA issued exemption are

consistent with the Administrators grant of Exemption to the MPAA, include:

1. The UAS must weigh less than 55 pounds (25 Kg), including energy source(s) and

equipment. Operations authorized by this grant of exemption are limited to the following

aircraft: DJI S1000 and Aeronavics Skyjib 8.. 

Proposed operations of any other aircraft will

require a new petition or a petition to amend this grant.

2. The UAS may not be flown at a speed exceeding a ground speed of 50 knots.

3. Flights must be operated at an altitude of no more than 400 feet above ground level

(AGL), as indicated by the procedures specified in the operator's manual. All altitudes

reported to ATC must be in feet AGL.

4. The UAS must be operated within visual line of sight (VLOS) of the Operator at all

times. This requires the Operator to be able to use human vision unaided by any device

other than corrective lenses, as specified on the PIC's FAA-issued medical certificate.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the

VLOS requirement, as long as the PIC always maintains VLOS capability. The VO and

PIC must be able to communicate verbally at all times.

6. The operator's checklist is considered acceptable to the FAA, provided the additional

requirements identified in these conditions and limitations are added or amended. The

operator's checklist and this grant of exemption must be maintained and made available

to the Administrator upon request. If a discrepancy exists between the conditions and

limitations in this exemption and the procedures outlined in the checklists the conditions

and limitations herein take precedence and must be followed. Otherwise, the operator

must follow the procedures as outlined in its checklists.

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
The operator may update or revise its operator's checklists. It is the operator's

responsibility to track such revisions and present updated and revised documents to the

Administrator upon request. The operator must also present updated and revised

documents if it petitions for extension or amendment. If the operator determines that

any update or revision would affect the basis for which the FAA granted this exemption,

then the operator must petition for amendment to their exemption. The FAA's UAS

Integration Office (AFS-80) may be contacted if questions arise regarding updates or

revisions to the operator's manual.

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe

flight. If the inspection reveals a condition that affects the safe operation of the UAS,

the aircraft is prohibited from operating until the necessary maintenance has been

performed and the UAS is found to be in a condition for safe flight. The Ground

Control Station, if utilized, must be included in the preflight inspection. All maintenance

and alterations must be properly documented in the aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation

or flight characteristics, e.g. replacement of a flight critical component, must undergo a

functional test flight in accordance with the operator's manual. The PIC who conducts

the functional test flight must make an entry in the UAS aircraft records of the flight. The

requirements and procedures for a functional test flight and aircraft record entry must be

added to the operator's manual.

9. The operator must follow the manufacturer's UAS aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements. When unavailable,

aircraft maintenance/ component/overhaul, replacement, and inspection/maintenance

requirements must be established and identified in the operator's manual. At a

minimum, the following will be included in the operator's manual:

a. Actuators Servos

b. Transmission (single rotor)

c. Power plant (motors)

d. Propellers

e. Electronic speed controller

f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used)

j. Any other components as determined by the operator

10. The Operator In Command (OIC) must possessed A certificate of graduation from a

pilot training course conducted by an FAA-approved pilot school, or a statement of

accomplishment from the school certifying the satisfactory completion of the ground school

portion and at least a current third-class medical certificate.

11. Prior to operations conducted for the purpose of motion picture filming (or similar

operations), the OIC must have accumulated and logged, in a manner consistent with

14 CFR § 61.51 (b), a minimum of 30 hours of total time as a UAS rotorcraft pilot and

at least ten hours logged as a UAS pilot with a similar UAS type (single blade or

multirotor). 

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
Prior documented flight experience that was obtained in compliance with

applicable regulations may satisfy this requirement. Training, proficiency, and

experience-building flights can also be conducted under this grant of exemption to

accomplish the required flight cycles and flight time. 

During training, proficiency, and experience-building flights, all persons not essential for flight operations are 

considered non-participants, and the PIC must operate the SUAV with appropriate distance from

non-participants in accordance with 14 CFR § 91.119. Prior to operations conducted for the purpose of motion 

picture filming (or similar operations), the OIC must have accumulated and logged, in a manner consistent 

with 14 CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS to be 

utilized for operations under the exemption and three take-offs and three landings in the preceding

90 days. Training, proficiency, experience-building, and take-off and landing currency

flights can be conducted under this grant of exemption to accomplish the required flight

time and 90 day currency. During training, proficiency, experience-building, and take-off

and landing currency flights all persons not essential for flight operations are considered

non-participants, and the PIC must operate the UAS with appropriate distance from nonparticipants

in accordance with 14 CFR § 91.119.

12. Prior to operations conducted for the purpose of motion picture filming (or similar

operations), a flight demonstration, administered by an operator-approved and -qualified

pilot must be successfully completed and documented. This documentation must be

available for review upon request by the Administrator. Because the knowledge and

airmanship test qualifications have been developed by the operator, and there are no

established practical test standards that support a jurisdictional FAA FSDO evaluation

and approval of company designated examiners, the petitioner will conduct these tests

in accordance with the operator's manual.

13. The UAS may not be operated directly over any person, except authorized and

consenting production personnel, below an altitude that is hazardous to persons or

property on the surface in the event of a UAS failure or emergency.

14. Regarding the distance from participating persons, the operator's manual has safety

mitigations for authorized and consenting production personnel. At all times, those

persons must be essential to the closed-set film operations. Because these procedures

are specific to participating persons, no further FSDO or Aviation Safety Inspector (ASI)

approval is necessary for reductions to the distances specified in the petitioner's

manuals. This is consistent with the manned aircraft procedures described in FAA Order

8900.1, V3, C8, S1 Issue a Certificate of Waiver for Motion Picture and Television

Filming.

15. The UAS may not be operated directly over any person, except authorized and

consenting production personnel, below an altitude that is hazardous to persons or

property on the surface in the event of a UAS failure or emergency.

16. Regarding distance from non-participating persons, the operator must ensure that no

persons are allowed within 500 feet of the area except those consenting to be involved

and necessary for the filming production. This provision may be reduced to no less than

200 feet if it would not adversely affect safety and the Administrator has approved it. For

example, an equivalent level of safety may be determined by an aviation safety

inspector's evaluation of the filming production area to note terrain features,

obstructions, buildings, safety barriers, etc. 

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
Such barriers may protect non-participating

persons (observers, the public, news media, etc.) from debris in the event of an

accident. This is also consistent with the same FAA Order 8900.1, V3, C8, S1.

17 .If the UAS loses communications or loses its GPS signal, the UAS must return to a

pre-determined location within the security perimeter and land or be recovered.

18. The UAS PIC must abort the flight in the event of unpredicted obstacles or

emergencies. The Operator shall carry/use appropriate LIPO battery protective bags

and fire extinguishing equipment.

19. Each UAS operation must be completed within 30 minutes flight time or with 25%

battery power remaining, whichever occurs first.

20.1n addition to the conditions and limitations proposed by the operator, the FAA has

determined that any operations conducted under this grant of exemption must be done

pursuant to the following conditions and limitations:

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver

or Authorization (GOA) prior to conducting any operations under this grant of exemption.

This GOA will also require the operator to request a Notice to Airman (NOTAM) not

more than 72 hours in advance, but not less than 48 hours prior to the operation.

22. All aircraft operated in accordance with this exemption must be identified by serial

number, registered in accordance with 14 CFR part 47, and have identification (N-Number)

markings in accordance with 14 CFR part 45, Subpart C. Markings must be as

large as practicable.

23. The PIC must develop procedures to document and maintain a record of the UAS

maintenance, preventative maintenance, alterations, status of replacement/overhaul

component parts, and the total time in service of the UAS. These procedures must be

added to the operator's manual/checklists.

24. Each UAS operated under this exemption must comply with all manufacturer Safety

Bulletins.

25. The PIC must develop UAS technician qualification criteria. These criteria must be

added to the operator's manual/Checklists.

26. The preflight inspection section in the operator's checklists manual must be amended to

include the following requirement: The preflight inspection must account for all

discrepancies, i.e. inoperable components, items, or equipment, not covered in the

relevant preflight inspection sections of the operator's manual.

27. Before conducting operations, the radio frequency spectrum used for operation and

control of the UAS must comply with the Federal Communications Commission (FCC)

or other appropriate government oversight agency requirements.

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
28.At least three days before scheduled filming, the PIC of the UAS affected by this

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction

over the area of proposed filming. The 3-day notification may be waived with the

concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights

b. Name and phone number of the operator for the UAS filming production conducted

under this grant of exemption

c. Name and phone number of the person responsible for the on-scene operation of the

UAS

d. Make, model, and serial or N-number of UAS to be used

e. Name and certificate number of UAS PICs involved in the filming production event

f. A statement that the operator has obtained permission from property owners and/or

local officials to conduct the filming production event; the list of those who gave

permission must be made available to the inspector upon request.

g. Signature of exemption-holder or representative

h. A description of the flight activity, including maps or diagrams of any area, city, town,

county, and/or state over which filming will be conducted and the altitudes essential to

accomplish the operation

29. The documents required under 14 CFR § 91.9 and § 91.203 must be available to the

PIC at the ground control station of the UAS any time the aircraft is operating. These

documents must be made available to the Administrator or any law enforcement official

upon request.

30. The UAS must remain clear and yield the right of way to all other manned operations

and activities at all times (including, but not limited to, ultralight vehicles, parachute

activities, parasailing activities, hang gliders, etc.).

31.UASoperations may not be conducted during night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights

under special visual flight rules (SVFR) are not authorized.

32. The UAS cannot be operated by the OIC from any moving device or vehicle.

33. The UAS may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

34.The UAS may not operate in Class B, C, or D airspace without written approval from

the FAA. The UAS may not operate within 5 nautical miles of the geographic center of a

non-towered airport as denoted on a current FAA-published aeronautical chart unless a

letter of agreement with that airport's management is obtained, and the operation is

conducted in accordance with a NOTAM as required by the operator's GOA The letter

of agreement with the airport management must be made available to the Administrator

upon request.

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
35.Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable GOA must be reported

to the Federal Aviation Administration's (FAA) UAS Integration Office (AFS-80) within

24 hours. Accidents must be reported to the National Transportation Safety Board

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight

operations may not be conducted until the incident, accident, or transgression is

reviewed by AFS-80 and authorization to resume operations is provided.

Unless otherwise specified in this grant of exemption, the UAS, and operator must comply

with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

Description of Regulations Which May Apply From Which Petitioner Requests Exception

1. Exception 14 C.F.R. Part 21, Subpart H: 

Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)Subpart H, entitled Airworthiness Certificates, establishes 

the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). 

Given the size and limited operating area associated with the SUAVS to be utilized by the Petitioner, an

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety

under Part 11 and Section 333 of the FMRA. The Federal Aviation Act (49 U.S.C.§44701 (f))

and Section 333 of the FMRA both authorize the FAA to exempt aircraft from the requirement

for an airworthiness certificate, upon consideration of the size, weight, speed, operational

capability, and proximity to airports and populated areas of the particular SUAVS. In all cases,

an analysis of these criteria demonstrates that the UAS operated without an airworthiness

certificate, in the restricted environment and under the conditions proposed will be at least as

safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, is by definition

unmanned and carries neither a pilot nor passenger, carries no explosive materials or

flammable liquid fuels, and operates exclusively within a limited flight area. Unlike other civil

aircraft, operations under this exemption will be tightly controlled and monitored by the

PIC/Operator and will also remain within the requirements of, and in compliance with, local

public safety requirements. These safety enhancements, which already apply to civil aircraft

provide a greater degree of safety to the public and property owners than conventional

operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart

H. Lastly, application of these same criteria demonstrates that there is no credible threat to

national security posed by the UAS due to its size, speed of operation, location of operation,

lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external

load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires; When marks include only the Roman capital letter "N" and the

registration number is displayed on limited, restricted or light-sport category aircraft or

experimental or provisionally certificated aircraft, the operator must also display on that aircraft

near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor

more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or

"provisional," as applicable.

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
Even though the UAS will have no airworthiness certificate, an exemption may be

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the

word "Experimental" can be placed. Given the size of the UAS, two-inch lettering will be

impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29

(f). The equivalent level of safety will be provided by having the UAS marked on its

fuselage as required by §45.29 (f) where the pilot, observer and others working with the

SUAVS will see the identification of the UAS as "Experimental." The FAA has issued the

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A.

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

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the

UASis unmanned and 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 FAA ground school rather than a commercial pilot's license to operate this

small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the SUAVS

is remotely controlled with no living thing on board. The area of operation is controlled and

restricted, and all flights are planned and coordinated in advance. The level of safety provided

by the requirements included herein exceed that provided by a single individual holding a

commercial pilot's certificate operating a conventional aircraft. The risks associated with the

operation of the UAS are so diminished from the level of risk associated with commercial

operations contemplated by Part 61 when drafted, that allowing operations of the UAS as

requested with a private pilot as the PIC exceeds the present level of safety achieved by 14

C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should

this exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the aircraft and the requirements contained herein for the use of safety check

lists prior to each flight, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this

chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight

Manual, approved manual material, markings, and placards, or any combination thereof.

The UAS, given its size and configuration has no ability or place to carry such a flight

manual on the aircraft, not only because there is no pilot on board, but because there is no

room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the UAS operation

manual and appropriate checklists at the ground control point where the pilot flying the UAS

will have immediate access to it. The FAA has issued the following exemptions to this

regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A,

10602, 32827, and 10700.

14 C.F.R. § 91.103: Pre-flight action

This regulation requires each pilot in command to take certain actions before flight to

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for

the aircraft an exemption will be needed. An equivalent level of safety will be provided as set

forth hereinabove. The PIC will take all actions including reviewing weather, flight battery

requirements, landing and takeoff distances and aircraft performance data before initiation of

flight using appropriate checklists.

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
14 C.F.R. §91.109: Flight instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned

free balloon) that is being used for flight instruction unless that aircraft has fully functioning

dual controls.

UAS and remotely piloted aircraft, by their design do not have fully functional dual

controls. Flight control is accomplished through the use of a radio transmitter that

communicates with the aircraft via a receiver in the UAS. The FAA has approved

exemptions for flight training without fully functional dual controls for a number of aircraft and

for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The

equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried

in the aircraft and by the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119

(d) allows helicopters to be operated at less than the minimums prescribed, provided the

person operating the helicopter complies with any route or altitudes prescribed for helicopters

by the FAA. This exemption is for a UAS and the exemption requests authority to operate at

altitudes up to 400 AGL underneath navigable airspace and in class E and G airspace

maintaining safe separation from actual aircraft, an exemption may be needed to allow such

operations.

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

as well as the location where it is operated. No flight will be taken without the permission of

the property owner or local officials. Because of the advance notice to the property owner and

participants in the filming activity, attempts will be made to contact all affected individuals

regarding the planned flight operations. Compared to flight operations with aircraft or rotorcraft

weighting far more than the maximum 551bs. proposed herein, and the lack of flammable fuel,

any risk associated with these operations is far less than those presently presented with

conventional aircraft. In addition, the low-altitude operations of the SUAVS will ensure

separation between these UAS operations and the operations of conventional aircraft that

must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation 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 the UAS may not have a

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An

equivalent level of safety will be achieved by the operator, pursuant to the Manual 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; or (2) At night, to fly after that for at least 45

minutes." The battery powering the UAS provides approximately between 10-60 minutes of

powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, SUAVS flights

would be limited to approximately 10 minutes in length.

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
Given the limitations on the SUAVS proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

Petitioner believes that an exemption from 14 CFR §91.151 (a) falls within the scope of

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate

without compliance with FAR 91.151 (a)). Operating the SUAVS in controlled area where only

people and property owners or official representatives who have signed waivers will be

allowed, with less than 30 minutes of flight operation time, does not give rise to the type of

risks that Section 91.151 (a) was intended to alleviate particularly given the size and speed of

the UAS. Additionally, limiting UAS flights to 20 minutes would greatly reduce the utility

for which the exemption will be granted.

Petitioner believes that an equivalent level of safety can be achieved by limiting flights

to 60 minutes or no less than 20% of battery power, whichever happens first. This restriction

would be more than adequate to return the UAS to its planned landing zone from anywhere

within its limited operating area.Similar exemptions have been granted to other operations, including 

Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has

within it the following:

(1) An appropriate and current airworthiness certificate ....

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed

at the cabin or cockpit entrance so that it is legible to passengers or crew.

The SUAVS fully loaded weighs no more than 55 lbs and typically less than 20 lbs. And

is operated without an onboard pilot. As such, there is no ability or place to carry certification

and registration documents or to display them on the SUAVS.

An equivalent level of safety will be achieved by keeping these documents at the ground

control point where the pilot flying the SUAVS will have immediate access to them, to the

extent they are applicable to the SUAVS. The FAA has issued numerous exemptions to this

regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665,

9789, 9789A, 9797, 9797A, 9816A, and 10700.

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 section and Part 43 apply only to aircraft with an airworthiness

certificate, and the requirements of pre-flight inspection required herein, these sections will not

apply to the applicant. Routine and pre-flight maintenance will be accomplished by the

operator. An equivalent level of safety will be achieved because these UAS are very limited

in size and will carry a very small payload and operate only in restricted areas for limited

periods of time. If mechanical issues arise the UAS can land immediately and given its

small size poses very little risk to persona or property. The operator will ensure that the

UAS is in working order prior to initiating flight, perform required maintenance, and keep a

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

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the

equivalent level of safety.

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
2. Publication Summary:

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:

Petitioner seeks an exemption from the following rules:

14 CFR Part 21, 14 C.F.R. 91.109, 14 CFR 91.405 (a), 14 C.F.R. 45.23(b), 14 C.F. R. 91.119, 14 CFR 407 (a) 

(1), 14 CFR 61.113 (a) & (b), 14 C.F.R. 91.121, 14 CFR 409 (a) (2), 14 C.F.R. 91.7 (a), 14 CFR 91.151 (a), 

14 CFR 417 (a) & (b), 14 CFR 91.9 (b) (2) 14 CFR 91.203 (a) & (b), 14 C.F.R. 91.103

to operate commercially a UAS vehicle (551bs or less) for Aerial Photography Operations.

Approval of exemptions allowing commercial operations of UASs for aerial

photography/Inspection for the following; Business Operations: over land, water-ways, and

oceans; operation over/in non restricted National Parks, National Forests, flight in nonnavigable

airspace, using non-intrusive recording devices, operation in otherwise unrestricted

US States/Territories will enhance safety by reducing risk. Conventional film operations, using

jet or piston power aircraft, operate at extremely low altitudes, just feet from the subject being

filmed, and in extreme proximity to people and structures; and present the risks associated

with vehicles that weigh in the neighborhood of 4,0001bs, carrying large amounts of jet A or

other fuel. In addition such actual certificated aircraft must fly to and from the film location. In

contrast, a UAS weighing fewer than 55 lbs., and powered by batteries rather than fuel,

eliminates virtually all of that risk. The UAS is driven/carried to the film set, not flown. The

UAS will carry no passengers or crew and, therefore, will not expose any crew to the risks

associated with manned aircraft flights.

The operation of UAS, weighing less than 55 lbs., conducted in the strict conditions

outlined above, will provide at least an equivalent level of safety supporting the grant of the

exemptions requested herein, including exempting the Petitioner from the requirements of Part

21 and allowing commercial operations. These lightweight aircraft operate at slow speeds,

close to the ground, and in a line of sight, relatively sterile environment and are, as a result, far

safer than conventional operations conducted with actual aircraft/helicopters operating in close

proximity to the ground and people.

3. Privacy

All business/commercial flights which occur over private or controlled access property

will be with the property owner's prior consent and knowledge. Filming will be of people who

have also consented to being filmed or otherwise have agreed to be in the area where filming

will take place. Petitioner will not infringe on any individual or landowner privacy rights.

Limited nighttime operations may be conducted. Nighttime as defined FAR's in Section

is as follows 1.1. "Night means the time between the end of evening civil twilight and the

beginning of morning civil twilight, as published in the American Air Almanac, converted to

local time." Night operations may be conducted by the SUAVS following the guidelines above

and provided such operations have sufficient lighting so that Petitioner/Operator maintains

visual line of sight. Allowing SUAVS this exemption will provide a far safer nighttime filming

alternative to the current full size aircraft operations.

4. Commercial Activities: That, within the conditions described in this Request and any

others the US DOT-FAA understands must be included, authorization be granted to us to

use UASs, as described herein, which are equipped with cameras and sensors, in order to

engage in the following professional and commercial activities:

(a) Video filming and photography by air for public and private purposes, including:

television, cinematography, advertising and promotions, only with the written

authorization of the owners or producers.

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
(b) Video filming and photography by air to support professional operations in

engineering, land surveying, architecture, real estate and other related professional

activities, only with the written authorization of the owners.

(c) Video filming and inspections by air of agricultural areas only under contract with the

owners or with a government entity.

(d) Video filming and inspections by air of infrastructure such as bridges, highways,

electrical installations, dams, aqueducts, photovoltaic power stations, pipelines and

wind farms, only under contract with the owners or with a government entity.

(e) Video filming and inspection by air of land and residential, commercial and industrial

structures, only under contract with the owners or with any government authority.

(f) Inspections by air to detect sources of pollution, gas emissions and leaks, under

contract with the owners of the properties involved or with a government entity.

(g) Provide support to search and rescue operations and reconnaissance in cases of

need, law enforcement operations, emergency or natural disasters and only when

government authorities have requested it by contract or donation.

(h) Offer consultancy, demonstrations, and training to private and public entities, which

are interested in the DOT-FAA authorization for the use of UASs like ours. 

5. Conclusion: General Request of Exemption: That, taking into consideration that:

a) all of our operations will be subject to FAA supervision and regulations, and will

never interfere with air traffic and/or any other government activity;

b) we are committed to comply rigorously with the FAA’s safety measures, the

protection of third party rights, and the procedures that are part of this Request

including the manuals and risk mitigation procedures;

c) aforementioned security measures as well as our comprehensive manuals are

equivalent to conventional aircraft regulations, and therefore mitigate proportional

and reasonable air and ground safety in what pertains to these small devices;

d) our flights would only take place under 400 feet (AGL), during daytime, far away from

airports and congested or populated areas, following strict security measures, within

the PIC visual line of sight (VLOS), with written authorization from the owners of the

property in which the activity is taking place and/or written authorization from a

government agency. Due to the nature of the services we will offer, most of our

flights will take place between 100 and 200 feet (AGL);

e) our services benefit the public interest as a whole;

f) we have FAA certified pilots and trained specialists with expertise in the maintenance

of UASs, and we have a workshop specialized in the repair, maintenance, and

programming of UAS-Model Aircrafts and other R/C devices;

g) in order to address the NAS and national security concerns, all our staff has with

necessary credentials and experience to perform their respective tasks;

h) we are hereby providing all the specifications for each and every one of our devices

that are already acceptable in the national market as Model Aircrafts; and

i) we will offer commercial and professional services in a safer, more cost-effective,

and accessible way than other conventional methods, which are used for these

services...

...the DOT-FAA grants us authorization to offer professional and commercial services

using the UASs specified herein, subject to what is included in this Request and any

other conditions which the US DOT-FAA understands must be amended or included.

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
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:

William A. Clary seeks an exemption from the following rules:

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).

to operate commercially a small unmanned vehicle (55 pounds or less) in motion picture and television 

operations. As established by the UAS exemptions already granted by the FAA, allowing commercial

operations of UASs in the film industry will enhance safety by reducing risk. Conventional 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 film location. In contrast, a UAS 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 UAS is carried, and not flown, to a film set. In this regard, the UAS carries

no passengers or crew and, therefore, will not expose them to the risks associated with manned

flights.

The operation of UASs 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 UASs

operate at slow speeds, close to the ground, and in a sterile 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. Filming will be only of people who have given their consent or

otherwise have agreed to be in the area where filming 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

William A. Clarys requested exemption, allowing William A. Clary UAS commercial operations for the

motion picture/television industry and inspections pursuant to the FOPM included herewith.

I Request that the administrator please keep private the following attachments 

o UAS Flight Operations and Procedures Manual (FOPM)......Attachment 1

o UAS Aircraft Flight Maintenance Records...................... Attachment 2

o UAS Flight Authorization Sheet ..................................Attachment 3

o UAS Pilot Flight Log ...............................................Attachment 2

o UAS Inspection and Maintenance Manual (POH)...............Attachment 4, 4-1

o UAS Maintenance and Repair Log Book........................ Attachment 2

o UAS Manufacturer Manuals .......................................Attachment 5, 5-1

o UAS Training Manual..............................................Attachment 1

o UAS Preflight, Takeoff and Landing Checklist ................Attachment 6, 6-1

o UAS Risk Assessment Tool ...................................... Attachment 7

o UAS Crew Data sheet .............................................Attachment 2

o UAS Preflight Safety Assessment ................................Attachment 8

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -
If you have any questions or need any additional information, please feel free to contact me at 

(970) 531-2062, wclary@gotaerial.com

Sincerely yours,

William A. Clary

Owner/Operator 

Got Aerial llc. 

(970) 531-2062

wclary@gotaerial.com

- William A. Clary – P.O. Box 1854 1252 Alpinview Dr. Big Bear City, CA 92314 (970) 531-2062 – wclary@gotaerial.com www.gotaerial.com -