September 24, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor Room W12-140

Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:

I am writing pursuant to the FAA Modernization and Reform Act (the "Reform

Act") and the procedures contained in 14 C.F.R. 11, to request that Nicholas Price, an 

owner and operator of small unmanned aircraft, be exempted from the Federal Aviation 

Regulations ("FARs") listed below so that Nicholas Price, may operate his small 

unmanned aircraft/ lightweight unmanned aircraft systems ("UAS") commercially in 

airspace regulated by the Federal Aviation Administration ("FAA"); as long as such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333. 

Mr. Price has been a member of the public safety community for over sixteen years, and 

has held a number of vital roles in the community. Being a first responder, Mr. Price has 

proven how responsible he is and that safety of everyone is a high priority. Mr. Price is 

currently seeking a business license that will allow himself, and only himself to provide 

UAS’s commercially in his community.

Nicholas Price respectfully requests the grant of an exemption allowing him to operate 

lightweight, remote controlled UAS's. The specific sections of Title 14 of the Code of 

Federal Regulations are: 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 

C.F.R. 91, et seq.; 14 CFR 407 (a)(1); 14 CFR 409 (a)(2); and, 14 CFR 417 (a) & (b). 

Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & 

(b); 91.7 (a); 91.9 (b)(2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 

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

Mr. Price’s UAS’s utilizes four counter-rotating propellers for extreme balance, control 

and stability. They each weigh less than 55 pounds, including cinematic or other 

equipment. Each unmanned aircraft are designed to primarily hover in place and operate 

at less than a 50-knot maximum speed. They are capable of vertical and horizontal 

operations but operate only within the line of sight of the remote control pilot. 
Utilizing battery power and not combustible fuels, flights generally last between five and

twenty minutes. Mr. Price does not operate his UAS’s with less than twenty five percent

battery capacity. Safety systems in place include a GPS mode that allows UASs to hover 

in place if communication with the radio control pilot is lost and then slowly descend the 

UAS at twenty five percent battery capacity. Further, the UAS is programmed, in some 

instances, to slowly follow a predetermined set of waypoints to return to a safety point if 

communications are lost.

Mr. Price does not operate his UAS’s near airports and generally does not operate them 

near populated areas. Mr. Price only operates his UAS’s in predetermined areas.

The FAA has the authority to issue the exemption to Nicholas Price, pursuant to the

Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

Below are several reasons Why Mr. Price’s exemption will not adversely affect safety:

• UASs weigh less than 55 pounds complete with high definition quality cameras like the 

DJI 12 megapixel photo camera with an integrated 3-axis stabilization gimbal;

• Only operates UAS’s below 400 feet;

• UAS’s only operate for 5-25 minutes per flight;

• Lands UASs when they reach 25% battery power;

• Remote control piloting UAS’s by line of sight;

• High definition remote control video backup should I somehow lose sight of the UAS;

• UAS’s have GPS flight modes where they land if communication with the remote 

control pilot is lost or battery power is below 25% (auto-return, auto-land);

• Only operates in secured areas that are strictly controlled, are away from airports, 

restricted airspace and populated areas;

• Always obtains all necessary permissions and permits prior to operation and has 

procedures in place to abort flights in the event of safety breaches or potential danger.

UAS’s carry no people on board and Mr. Price usually operates them 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. The small size and extreme 

maneuverability of UAS’s allow the remote control pilots to avoid hazards. 

A summary the FAA may publish in the federal register:

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates.

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)(l). 

The size, weight and enclosed operational area of Mr. Price’s UAS’s permits exemption 

from Part 21 because the UASs meet 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. Mr. 

Price’s 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 

pilots or passengers, and given the size of the UASs, this Regulation is inapplicable. 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 as Mr. Price’s UAS’s 

utilize electronic global positioning systems and internal gyroscopes to provide spatial 

coordination. 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. 

14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation 

require aircraft to be marked according to certain specifications. UASs are, by definition, 

unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark 

certain words or phrases. Further, two-inch lettering is difficult to place on such small 

aircraft. Regardless, Mr. Price will mark its UASs in the largest possible lettering 

required by 14 C.F.R. §45.29 (f) if an exemption is not granted so that the pilot and 

others working near the UAV will see the markings. The FAA has previously issued 

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

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 can achieve an equivalent level of safety as achieved by current regulations 

because UAS’s do not carry any pilots or passengers. 

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. UAS’s will never 

operate at an altitude greater than 400 ft. 

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

These Regulations only apply to aircraft with an airworthiness certificate. They will not,

therefore, apply to Nicholas Price should my requested exemption be granted. Mr. Price

conducts an extensive maintenance program that involves regular software updates and 

constant inspection for assessment of any damaged hardware. Therefore, an equivalent 

level of safety will be achieved.
Summary

Nicholas Price seeks an exemption from the following Regulations: 14 C.F.R.

21, subpart H; 14 C.P.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.P.R. § 91.409 (a)(2); 14 C.P.R. § 91.409 

(a)(2); and, 14 C.P.R. §§ 91.417 (a) & (b) to commercially operate his fleet of small 

unmanned vehicles and lightweight unmanned aircraft.

There are no people on board the UAS’s and therefore the likelihood

of death or serious bodily injury is significantly limited. Nicholas Price’s operation of his

UAS’s, weighting less than 55 pounds and traveling at speeds lower than 50 knots in 

contained areas will provide at least an equivalent level of safety as that achieved under 

current FARs.

Nicholas Price respectfully requests that the FAA grant its exemption request without 

delay. The FAA has the authority to issue the exemption sought by Nicholas Price

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

Sincerely,

Nicholas Price

127 E. 5th Avenue

Escondido, CA 92025

Nprice1127@aol.com