November 15 , 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 Quin Servantez, (herein known as Steven Servantez ), 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,
am an owner and operator of small unmanned aircraft, and that I be
e xempted from the Federal Aviation Regulations (“FARs”) listed below so that I may operate my small ultralight weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein I , Steven Servantez, am a small business owner within the State of Wisconsin; experienced in flying hobby type UAS (small UAS) 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/nature photography and to provide services for real estate listings, land development, events, promotional videos, closed set motion picture filming; following exemption and approval by the FAA. This exemption request would permit operation of ultra lightweight, unmanned (piloted by remote control) and comparatively inexpensiveUAS(s) in tightly controlled and limited airspace for use in aerial data collection,

photogr aphy, 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 controll ed UAS’s in the National Airspace System.
With respect to operating my UAS for non

- commercial use I have already implemented safety protocols and controls to avoid and prevent any public hazard, as well as maintain at all times a distance from manned aircraft to systematically avoid hazards/catastrophe.
Granting my 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 hereby certify that I will conduct my operation s in compliance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below I, Steven Servantez, respectfully request the grant of an exemption allowing me to operate ultralight weight, remote controlled U AS’s to enhance real estate listings, aerial data collection and closed set motion picture capture and nature photography for those who cannot afford expensive manned aircraft. This will promote local economic growth through increased employment and incre ased 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 Quin Servantez 447 East Manogue Rd. Milton, WI 53563 Number: (608) 29 5

-8986 Email: dogdoc89@gmail.com
II. The Specific Sections of Title 14 of the Code of Federal Regulations From: Which Steven Servantez 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 : I, Steven Servantez, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs op erating to prevent me and or my assigns/agents , contemplate d 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 integratio n of civil unmanned aircraft systems into our National Airspace System as it is in the public’s interest to do so. My, DJI Phantom 3 Professional UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and therefore the int egratio n 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 timeperiod by which the Reform Act requires the FAA to promulgate rules governing

such craft. Thereby, providing di rect 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 Q
. Servantez. 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 consider safety as foremost with each flight. My small unmanned aircraft is designed to hover in plac e via GPS and operate in less than a 24

- knot (15 mph) wind. For safety, stability and fear of financial loss

. My safety protocol prevents flights when winds exceed 20 mph. Built in safety systems include a GPS mode that allows my UAS to hover in place wh en 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 desig ned slowly return to the point of take
o ff at a pre
- determined altitude with vertical decent to landing as to minimize risks associated with loss of direct control . I do not operate my UAS within 3 miles of airports, h ospital s nor p olice heliports, and do not operate near areas where general public could pose a danger risk . I am constantly on alert for any manned aircraft and prepared to land/abort immediately to the nearest and safest ground point should a manned airc raft approach my location or I suspect manned aircraft may approach near my location.
My UAS is capable of vertical and horizontal operati ons, and are flown within sight of the operator at all times. Utilizing battery power rather than combustible fuels, flights are restricted to 20 m inute intervals to minimize the possibility of reduced battery function during flight.My 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. It is my intent to operate in as safe a manner as possible using every safety measure possible . I have clocked numerous practice flights in r emote 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 personally have also logged over 100 hours of flight simulation time in quadcoptor scenarios

. I 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 Nati onal Airspace System. Steven Servantez s’ 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 Granting of this Request Will Benefit the Public: Aerial videography for geographical awareness, real estate marketing, nature photography 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 aer ial 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 valuablemarketing tool. My UAS pose s a minimal t hreat to the general public since size and lack

of combustible fuel alleviates any significant dangers related to legacy methods for obtaining cinematic footage

.
Congress has already proclaimed that it is in the public’s interest to integrate commercia lly flown UAS's into the National Airspace System, hence the passing of the Reform Act. Granting my exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around Chicago, Illinois, a city of be auty and industry. My ultralight 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, c ontain 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 ultralight weight UAS's. P ermitting me, Steven Servantez, to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the Rock County community for companies looking to relocate or build in the mid

-west 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 this Exemption Will Not Adversely Affect Safety o r How The E xemption Will Provide a Level of Safety At Least Equal To Existing Rule: My exemption will not adve rsely affect safety. I believe for the reasons stated permitting me to log more flight time in FAA controlled airspace, with communication with the FAA, w ill 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 Servantez, submit the followingrepresent ations of enhancements to current aerial videography and photography

for real estate, aerial data collection, closed set motion pictures and other opport unities, 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 cont rol 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 have procedures in place to abort flights in the event of safety breaches or potential danger.
My 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 pote ntial 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 i s 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 whenclose 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 a t 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 Servantez s',UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equ ivalent 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 legis lation 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 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 Regulati on 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's, this Regulation is inapplicable. An equivalent level of safety will be achi eved 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 civ il 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, Rudolph A. McCormick

.

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 w hich 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 Servant ez, 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 op eration 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 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 the standard of 400 ft AGL. My UAS operations fly between 75

- 200 ft AGL 99% of the time. I, Steven Servantez, 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 relat ion 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

- ci ted 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 disc repancies 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 UAS. However, as part of my pre

-flight checklist I inspect my UAS and as part of my after landing checklist I inspect 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 21because my 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 p ieces 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 o f 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) req uires 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 issue d 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 Quin Servantez 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
c ommercially operate my 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 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 air craft 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.
There are no personnel on board my UAS and therefore the likeliho od of death or serious bodily injury is significantly diminished. My 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. Accordi ngly I hereby 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 Quin Servantez 447 East Manogue Rd. Milton, WI 53563 Number: (608) 295

-8986 Email: dogdoc89@gmail.com

Attached:
UAS/UAV Operators Manual for DJI Phantom UAS/UAV UAS Phantom Pre Flight Checklist UAS/UAV UAS Phantom Professional Specs