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 procedur es 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 light weight 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 350QX 3 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, aer ial 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 Specific ations , Blade 350QX3 Specifications

Stephen Reynolds ’ Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations
Page 1I, 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. Co ntact 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 w eight 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 2integration of my light weight UAS is expressly contemplated by the Reform Act. The Reform Act guides

the Secretary in determining the types of UAS's that ma y 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 lin e 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 techn ology. 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 t hat the aircraft is physically and electronically ready for safe flight and that permission from the property ow ner/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 e xamine the aircraft

, - verifying connections a nd 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 approximate ly 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 3IV. 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

catast rophic 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 intere st 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 compl ete 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 r easonably 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 alwa ys 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 Airwort hiness 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
Refo rm 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 Regulatio ns Page 4speed, 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 m anual 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) th ere 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 registration s. 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 Applica ble 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. F urther, 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 i ts 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: Priva te Pilot Privileges and Limitations: PIC Pursuant to 14 C.F.R. § 61.113 (a) & (b), private pilots are limited to non commercial operations. I, Stephen Reynolds

, can achieve an equivalent level of safety as achieved by current Regulations because my UAS
doe s not carry any

Stephen Reynolds ’ Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations
Page 5pilots or passengers. Further, while helpful, a pilot license will not ensure remote control

p iloting 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 excee ds 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 i n 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 equ ivalent 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 paragra ph (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 becau se 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 m eets 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 prev iously 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 69299, 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. § 91.40 7 (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, cinematog raphy, 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 signifi cantly 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

Attachment s : DJI Phantom 3 Advanced Specifications, Blade QX3 Specifications

Stephen Reynolds ’ Exemption Request Section 333 of the FAA Reform Act of the Fe deral Aviation Regulations
Page 7