July 9th, 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 nearest 
and 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 furthers 
the 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 have 
procedures 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 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 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 Street
Suite 2401

Chicago, Illinois 60601

Attached:

UAS/UAV Aircraft Specifications 

UAS/UAV Operations Manuals and Safety Guidelines

UAS/UAV Aircraft Pre-Flight Check List