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 

exempted 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 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. 

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 operations 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 

UAS’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 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 Quin Servantez

447 East Manogue Rd.

Milton, WI 53563

Number: (608) 295-8986

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 operating 

to prevent me and or my assigns/agents, 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, DJI Phantom 3 Professional UAS meets the definition of “small 

unmanned aircraft” as defined in Section 331 

and therefore the integration of my ultralight weight UAS is expressly contemplated 

by the Reform Act. I would like to operate my ultralight 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 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 place 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 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 return to the point of take 

off 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, hospitals nor police 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 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 within sight of the operator at all 

times. Utilizing battery power rather than combustible fuels, flights are restricted to 20 minute 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 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 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 National Airspace System. Steven Servantezs’

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 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 UAS poses a minimal threat 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 

commercially 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 beauty and industry. My 

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

The consequence of my ultralight 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 ultralight weight 

UAS's. Permitting 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 or How The Exemption Will Provide a Level of Safety At Least Equal 

To Existing Rule: 

My exemption will not adversely affect safety. I believe for the reasons stated permitting me 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 Servantez, 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 themselves. 

My UAS weighs less than 5 pounds complete with a small ultralight 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 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 Servantezs',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 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, 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 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 Servantez, 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 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 

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 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 21 
because 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 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 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 

commercially 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 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. 

There are no personnel on board my UAS and therefore 

the likelihood 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. Accordingly 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