July 9 th , 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

To whom it may concern,

I, Steven Robert Adams, 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, Steven Robert Adams, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Steven Robert Adams, may operate my small ultra light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein I, Steven Robert Adams, am a small business owner within the State of Illinois; experienced in flying hobby type helicopters for recreational and cinematic purposes. I have added a hobby grade quad-copter UAS ( DJI Phantom 3 Professional) to my inventory equipped with an attached camera with intent for aerial photography/cinematography to provide services for real estate listings, land development, events, promotional videos, closed set motion picture filming; following exemption and approval by the FAA.

My, Steven Robert Adams, exemption request would permit operation of ultra lightweight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly controlled and limited airspace for use in aerial data collection, photography, closed set filming, and other aerial cinematography purposes.

Predetermined in areas away from general public, airports, heliports and vehicular traffic for community videos, and within property boundaries for individual homeowner real estate listing videos/photos, and predetermined closet sets for motion pictures. Currently, unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe legally operate similar lightweight, remote controlled UAS’s in the National Airspace System.

I, Steven Robert Adams, have personally instilled safety protocols and controls to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe.This will act to further safety protocols exclusive to lightweight UAS's specific to

aerial data collection, video, cinematography and photography usage as I, Steven Robert Adams, record flight data and other information gained through permitted flight operations to share with the FAA through any required FAA reports to assist with future protocol and safety regulations.

Granting my, Steven Robert Adams, request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities and authority to not only integrate UAS's into the airspace, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the ” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate, photography and closed set filming purposes. Further I, Steven Robert Adams, will conduct my operations in compliance with the protocols described herein or as otherwise established by the

FAA.

For the reasons stated below I, Steven Robert Adams, respectfully request the grant of an exemption allowing me to operate ultra light weight, remote controlled UAS’s to enhance real estate listings, aerial data collection and closed set motion picture capture for those who cannot afford expensive manned aircraft. This will promote local economic growth through increased employment and increased tax base. This will keep public safety in mind by keeping heavier manned aircraft containing combustible fuel that poses potential public hazard.

I. Contact Information:

Steven Robert Adams

Owner Chicago Aerial Video LLC 340 East Randolph Street

Suite 2401 Chicago, IL 60601 Number: (248)-885-4730

Email: stevead22@gmail.com

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

Which Steven Robert Adams Requests Exemption 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).

III. The Extent of relief Steven Robert Adams seeks and the Reason He Seeks

Such Relief:

I, Steven Robert Adams, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent me, Steven Robert Adams, contemplated commercial cinematic, closed set motion picture production, academic and other flight operations within the National Airspace System. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our National Airspace System as it is in the public’s interest to do so. My, Steven Robert Adams ’ , ultra light weight

UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra light weight UAS prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all aerial data collection related UAS video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our National Airspace System. Considerations include: The weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operated near airports or heavily populated areas; and, whether the UAS will be operated by line of sight. Each of these items reflects in favor of an exemption for me, Steven Robert Adams. My UAS utilizes four (4) counter-rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Weighing less than five (5) pounds (far below the maximum 55-pound limit); including camera with gimbal.

I, Steven Robert Adams, consider safety as foremost with each flight. My small unmanned aircraft is designed to hover in place via GPS and operate in less than a 24-knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place when radio controls are released. With three modes to choose from, I utilize the Smart Mode for aerial videography/photography. This is the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost UAS is designed slowly descend to point of take off. I do not operate my UAS near airports, Hospitals nor Police heliports, and do not operate near areas where general public is within fifty to one hundred (50-100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft and prepared to land/abort immediately to the nearestand safest ground point should a manned aircraft approach my location or I

suspect manned aircraft may approach near my location.

My UAS is capable of vertical and horizontal operations, and are flown only within my line of sight of me, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights generally last between three (3) to fifteen (15) minutes, with an altitude under three hundred (300) feet. I, Steven Robert Adams, utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is up to twenty-five (25) minutes. I do not operate my UAS at or below manufacture recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss

of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash, which could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have clocked numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of this specific UAS's performance under different temperature and weather conditions.

I, Steven Robert Adams, am extremely cautious when operating of my UAS/ultra lightweight unmanned aircraft and will not “create a hazard to users of the National Airspace System or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the National Airspace System. Steven Robert Adams ’ UAS, used in hobby flight, has a demonstrable safety record and does not pose any threat to the general public or national security.

IV. How Steven Robert Adams' Request Will Benefit the Public:

Aerial videography for geographical awareness, real estate marketing, and closed set motion pictures has been around for a long time through manned fixed-wing aircraft and helicopters. For small budget companies and average homeowners, the expense of aerial videography is cost prohibitive. Only large companies and high-end Realtors or luxury homeowners can afford to absorb such an expense. Depriving non-luxury homeowners and lower budget Realtors from a valuable marketing tool. My, Steven Robert Adams', UAS pose no threat since size and lack of combustible fuel alleviates any potential threat to the public.

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the National Airspace System, hence the passing of the Reform Act. Granting my, Steven Robert Adams', exemption request furthersthe public interest through academic/visual awareness of the geographical benefits

in and around Chicago, Illinois, a city of beauty and industry. My ultra light weight UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public.

The public’s interest is furthered by, minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra light weight UAS's. Permitting me, Steven Robert Adams, to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the Chicagoland community for companies looking to relocate or build in the midwest area as well as individuals looking to relocate for career advancement through academic and geographical awareness. Both of which serve as a stimulus to the community.

V. Reasons Why Steven Robert Adams' Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

My, Steven Robert Adams' , exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Steven Robert Adams, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for other individuals and development in cooperation with the FAA. In addition I, Steven Robert Adams, submit the following representations of enhancements to current aerial videography and photography for real estate, aerial data collection, closed set motion pictures and other opportunities, which may present them selves.

My UAS weighs less than 5 pounds complete with a small ultra light weight high quality built-in camera; I only operate my UAS below 300 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012); my UAS only operate for 3-15 minutes per flight; I will land my UAS prior to manufacturer recommended minimum level of battery power; I pilot my UAS through remote control only by visual line of sight (VLOS); My UAS has GPS a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost; I actively analyze flight data and other sources of information to constantly update and enhance safety protocols; I only operate in reasonably safe 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; and, I haveprocedures in place to abort flights in the event of safety breaches or potential

danger.

My, Steven Robert Adams', safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our community, helicopters are the primary means of aerial video and photography for community awareness, real estate, aerial inspection and closed set film production.

First, the potential loss of life is diminished because UAS's carry no people on board and I only operate my UAS in specific permitted areas away from mass populations. Second, there is no combustible fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom.

Accordingly, my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety

levels.

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

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a) (1). The size, weight and enclosed operational area of my, Steven Robert Adams',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, speed, maneuverability and proximity to areas such as airports and dense populations.

My, Steven Robert Adams ’ , current and projected UAS's meet or exceed each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there areno on board pilots or passengers, and given the size of the UAS's, this Regulation

is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined.

The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700, 32827, 11279, 11062 and many others.

14 C.F.R. § 91.121 regarding altimeter settings are inapplicable in so far as my UAS utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, Steven Robert Adams.

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 UAS 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 with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs 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 the pilot, or anyone assisting me as a spotter with the UAV 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 non-commercial operations. I, Steven Robert Adams, can achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Steven Robert Adams, to operate my UAS meet and exceed 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 300 ft AGL,safely below the standard of 400 ft AGL.I, Steven Robert Adams, 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) (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, Steven Robert Adams', UAS. However, as a safety precaution I inspect my UAS before and after each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my, Steven Robert Adams', UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

In summary, Steven Robert Adams, seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) &(b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. §

91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Steven Robert Adams', small unmanned vehicle/lightweight unmanned aircraft vehicle in community aware ness, aerial photography, aerial data collection, closed set motion picture filming and other opportunities which may present itself. Currently, area awareness and real estate, motion picture and aerial data photography collection relies primarily on the use of larger aircraft running on combustible fuel. Posing potential risk to the public.

Granting my, Steven Robert Adams', request for exemption will reduce current risk levels and thereby enhance safety. My UAS air craft does not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional ariel data video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled consensual airspace eliminating potential public risk flying to and from established airfields.

I, Steven Robert Adams, have been informally analyzing flight information and will compile safety protocols and the implementation of a flight operations manual for aerial data photography usage that exceeds currently accepted means and methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA

Modernization and Reform Act of 2012.

There are no personnel on board my, Steven Robert Adams', UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Steven Robert Adams', operation of my UAS, weighing less than 5 pounds and traveling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, Steven Robert Adams, respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,

Steven Robert Adams

Owner Chicago Aerial Video, LLC 340 East Randolph StreetSuite 2401

Chicago, Illinois 60601

Attached:

UAS/UAV Aircraft Specifications UAS/UAV Operations Manuals and Safety Guidelines UAS/UAV Aircraft Pre-Flight Check List