October 6, 2015

Stephen Reynolds

8107 Rasper Ct 

North Chesterfield, VA 23235

804-920-4486

stephenreedreynolds@gmail.com

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. §§ Part 21; 45.23(b); 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 91.119; 91.151(a); 

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

Dear Sir or Madam: 

I, Stephen Reynolds, 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, Stephen Reynolds, an owner and 

operator of small unmanned aircrafts, be exempted from the Federal Aviation Regulations 

(“FARs”) listed below so that I, Stephen Reynolds may operate my small lightweight unmanned 

aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration 

(“FAA”). 

I, Stephen Reynolds, have over twenty five of digital photography experience as well as over fifteen

years of experience in the field of Remote Controlled Aircraft. Using either the Blade 350QX3 or DJI 

Phantom 3

1

, I, Stephen Reynolds, intend to provide aerial video and photography services in the areas 

of building inspections, real estate, site surveys, aerial mapping, and special events to include but not 

limited to weddings, private or public parties/events, environmental studies, and other outdoor 

recreational facilities and landscapes. 

1 

Attachment – DJI Phantom 3 Advanced Specifications, Blade 350QX3

Specifications

Stephen Reynolds’ Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

Page 1 
I, Stephen Reynolds, am committed to safety with each flight. My exemption request would permit 

operation of a UAS(s) in areas away from the general public, airports, heliports and vehicular traffic for 

community videos, and within property boundaries for individual homeowner real estate listing 

videos/photos or videos/photos of other similar events. 

I. Contact Information: 

Stephen Reynolds

8107 Rasper Ct.

North Chesterfield, VA 23235

804-920-4486

stephenreedreynolds@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Stephen 

Reynolds Requests Exemption are: 

14 CFR Part 21; 14 C.F.R. 45.23(b); 14 CFR 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. 91.203(a) & (b); 14 C.F.R. 91.151(a); 14 C.F.R. 91.405(a); 14 CFR 

407(a) (1); 14 CFR 409(a) (1) & (a) (2); 14 CFR 417(a) & (b) 

III. The Extent of Relief Stephen Reynolds Seeks and the Reason He Seeks Such Relief: 

I, Stephen Reynolds, 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, Stephen Reynolds, an owner and operator 

of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below 

so that I may operate my small light weight unmanned aircraft system (“UAS”) commercially in 

airspace regulated by the Federal Aviation Administration (“FAA”). 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, Stephen Reynolds’, light-weight UAS meets the definition of 

“small unmanned aircraft” as defined in Section 331 and therefore the (next page)

Stephen Reynolds’ Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

Page 2 
integration of my lightweight UAS is expressly contemplated by the Reform Act. 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, Stephen Reynolds. My UAS utilizes four (4) counter-rotating propellers for balance, control and 

stability and is equipped with a GPS and auto return safety technology. Weighing less than five (5) 

pounds (far below the maximum 55 pound limit); including camera with gimbal. 

I, Stephen Reynolds, will operate the Blade QX3/Phantom 3 in a safe manner, using the following 

checklists as well as operating procedures to determine that the aircraft is physically and 

electronically ready for safe flight and that permission from the property owner/representative is 

received when applicable.

Pre-flight Checklist: 

 Survey the property for hazards, such as trees, utility poles/lines and other elements that might 

compromise safe flight including dense vehicular traffic or crowds. If the location is not deemed 

safe, the flight will be aborted immediately.

 Check the weather for wind speed, cloud cover, and any forecast changes that might adversely 

affect flight safety and performance. 

 Closely examine the aircraft, - verifying connections and searching for cracks and loose parts. 

 Verify the electronic elements are performing correctly (receiving 6 or more GPS signals along 

with calibration of the magnetic compass). 

o Determine that the barometric altimeter reflects approximately 0 feet AGL. (Phantom 3 

only)

o Following takeoff, hover at an altitude of approximately 10 feet to assure that the Home 

Point is correctly located. Then exercise all controls to confirm their functionality, if any 

of the controls is not functioning, the flight will be terminated immediately.

 During Flight, the pilot will always:

 Give right-of-way to any manned aircraft

 Stay clear of FAA controlled airspace at airports (generally a five nautical mile 

radius) as well as restricted and prohibited zones. 

 Fly no higher than 400' and no further than 1000' from the Home Point, recognizing that the 

primary responsibility is to safely keep the aircraft safely within VLOS. 

 Stay clear of clouds and fog (500' vertically and 2,000' horizontally).

Post-flight Checklist: 

 Inspect the UAS to determine its physical and electronic condition. Examine the 

aircraft-looking at connections and searching for cracks and loose parts. 

Stephen Reynolds’ Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

Page 3 
IV. How Stephen Reynolds’ Request Will Benefit the Public as A Whole: 

Aerial videography and photography has been around for a long time through manned fixed wing 

aircraft and helicopters. For small budget companies and individuals, the expense of such aerial 

videography and photography is cost prohibitive. Only large companies and high-income individuals 

can afford to absorb such expense. Manned aircraft pose a threat to the public through potential 

catastrophic crashes resulting in a potential loss of life. My, Stephen Reynolds’, UAS poses 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’ into the 

national airspace system, hence the passing of the Reform Act. My, Stephen Reynolds, light-weight 

UAS is battery powered and creates no emissions that can harm the environment. 

V. Reasons Why Stephen Reynolds’ Exemption Will Not Adversely Affect Safety Or How the 

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

My, Stephen Reynolds’, exemption will not adversely affect safety for the following reasons:

 My UAS weighs less than 5 pounds complete with a small light-weight high definition (HD) 

camera. I only operate my UAS below 400 feet (well within the 400 foot permissible ceiling 

set by the FAA Modernization and Reform Act of 2012).

 I land my UAS prior to manufacturer recommended minimum level of battery power.

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

 My UAS has GPS with a flight safety feature whereby it hovers and then slowly lands if 

communication with the remote control pilot is lost.

 I only operate in reasonably safe environments 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. 

VI. A Summary the FAA May Publish in the Federal Register: 

A. 14 C.F.R. § 21, 14 C.F.R. § 91 and 91.151: 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, Stephen Reynolds’, UAS permits exemption 

from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to 

Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the 

Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness 

certificate requirement in consideration of the weight, size, 

Stephen Reynolds’ Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

Page 4 
speed, maneuverability and proximity to areas such as airports and dense populations. My, 

Stephen Reynolds’, current and projected UAS’ 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, 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. § 91.151(a) with the condition that the PIC does not begin a flight unless (considering 

wind and forecast weather conditions) there is enough power to fly to the first point of intended 

landing and, assuming normal cruising speed, land the UA with 30% battery power remaining. 

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, Stephen Reynolds. 

B. 14 C.F.R. § 45.23: Marking of the Aircraft Applicable Codes of Federal Regulation require 

aircraft to be marked according to certain specifications. My, Stephen Reynolds, UAS is, by 

definition, unmanned. Therefore does not have a cabin, cockpit or pilot station on which to mark 

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

dimensions smaller that minimal lettering requirement. Regardless, I, Stephen Reynolds, will mark 

the UAS in the largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as 

required by 14 C.F.R. § 45.29 (f) so that I, Stephen Reynolds, the pilot, will see the markings. The 

FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 

10167A and 10700. 

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC Pursuant to 14 C.F.R. § 

61.113 (a) & (b), private pilots are limited to noncommercial operations. I, Stephen Reynolds, 

can achieve an equivalent level of safety as achieved by current Regulations because my UAS 

does not carry any 

Stephen Reynolds’ Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

Page 5 
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, 

Stephen Reynolds, to operate my UAS in a manner that meets and exceeds current safety 

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

D. 14 C.F.R. § 91.119: Minimum Safe Altitudes 14 C.F.R. § 91.119 prescribes safe altitudes for the 

operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. 

My UAS will never operate at an altitude greater than 400 AGL; safely below the standard of 400 

AGL. I, Stephen Reynolds, 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. 

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

above-cited Regulations require, amongst other things, aircraft owners and operators to have the 

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

except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in 

part 43 of this chapter. 

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

therefore, apply to my, Stephen Reynolds’, UAS. However, as a safety precaution, I, 

Stephen Reynolds, 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 

. 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 permit exemption from Part 21 because my, Stephen Reynolds’, 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’ 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 

. § 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’, 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, 

Stephen Reynolds’ Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

Page 6 
9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and 

curative measures for any damaged hardware. Therefore, an equivalent level of safety will be 

achieved. 

In summary, Stephen Reynolds 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. § 91.119; 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) (1); and, 14 C.F.R. § 91.417 (a) & (b) 

I, Stephen Reynolds, am requesting this exemption for the purposes of aerial photography, 

cinematography, videography, inspections and other flight operations. The reason for such a general 

and broad based request is that I, Stephen Reynolds, wish to utilize a business strategy that 

capitalizes on opportunities as they may arise in the future. My, Stephen Reynolds’, business model is 

based on the idea of offering ad hoc small UAS services to individuals or companies who wish to 

employ these services as a safe, effective, and legal option to enhance their business. 

Granting my, Stephen Reynolds’, 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 video and photographic aircraft. Further, I operate at lower altitudes 

and in controlled airspace eliminating potential public risk flying to and from established air fields. 

There are no personnel on board my, Stephen Reynolds’, UAS and therefore the likelihood of death or 

serious bodily injury is significantly diminished. My, Stephen Reynolds’, operation of my UAS, 

weighing less than 5 pounds and travelling at lower speeds within limited areas will provide an 

equivalent level of safety as that achieved under current FARs. Accordingly I, Stephen Reynolds,

respectfully request that the FAA grant my exemption. 

Respectfully submitted, 

Stephen Reynolds

Attachments: DJI Phantom 3 Advanced

Specifications, Blade QX3 Specifications

Stephen Reynolds’ Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

Page 7