Mr. John S. Duncan Director, Flight Standards Service 800 Independence Ave., SW Washington, DC 20591

Mr. Duncan,

Re: Public Law 112

- 95

- FAA Modernization and Reform Act of 2012, H.R. 658

- 65 Section 333 Exemption No. 12236 (granted July 30, 2015) Regulatory Docket No. FAA

-2015

- 1928

The FAA granted OConnor Aerial Videos & Editing LLC exemptions from Section 333 Special Rules for Certain Unmanned Aircraft Systems, July 30, 2015, signed by you. I also received a Certificate of Waiver or Authorization (COA) as well. Thank you.Mr. Duncan, I am a one

- man company operating out of a small room in my house, it would be prohibitively expensive and impractical for me to obtain a pilot’s license. My two UAS, a DJI Phantom 2 and DJI Phantom 3, both are 16 inc hes wide, 8 inches high, they weigh 4 pounds and 2 pounds respectively, and are restricted to flying 200 feet AGL, please see the attached photo

.

But I am confused about what the FAA requires of me in order that I may run my business commercially within the framework set forth in your granting me my request for Section 333 exemption.

Attached you will find a list of my suggested changes to the Con ditionsand Limitations listed in my Section 333 exemption notice. Below is an extensive explanation as to why I feel these changes should be made.

In the FAA notification letter dated July 30, 2015, granting me Section 333 exemptions, Line 13 under Condi tions and Limitations, it’s stated that the “...Pilot In Charge (PIC) must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. That the PIC must also meet flight review requirements specified in 14 CFR § 61.53 in an aircraft in which the PIC is rated on his or her pilot certificate.”

14 CFR § 61.53 is directed at manned aircraft, not the Unmanned Aircraft Systems I fly. Per the FARs, all I need isa minimum of a Sport Pilot license to fly my UAS commercially, yet these same FARs state Sport Pilots, Private Pilots, Recreational Pilots cannot fly aircraft commercially. So how is it that if I have one of these three type of pilot’s licenses I can fly my UAS for commercial purposes but if I fly manned aircraft with eit her of these three licenses, I’m forbidden from flying aircraft for commercial purposes?

I find this confusing and contradictory to

me.

Line 13 also talks about flight review requirements for flying my UAS, there are there are no flight review requiremen ts listed anywhere in the FARs regarding UAS, FARs only refer to manned aircraft. There are no FARsregarding UAS pilot testing or flight review procedures.

I’m asking you for an exemption from the licensed pilot requirement and the flight review requirem ent in Line 13 of the Conditions and Limitations section in my Section 333 exemption notification.

The other issue I have is under Line 2 of the Conditions and Limitations section of my Section 333 grant of exemption document, which states “ Operations for the purpose of closed

- set motion picture and television filming are not permitted.” I have worked in the film/video business for well over 30 years now and I know what a closed set is but I need clarification from you about this. “Closed

-set” means outsiders are not allowed to see what is being filmed andusually pertains to scenes shot in an enclosed building where outsiders cannot gain access to nor view what is being filmed. If that is what the FAA means by “Closed

- Set”, then I’m fine with that, but it needs clarification.

But if the FAA means I cannot use my UAS on ANY film or TV production that is shot outside in the open air, then I would like you to indicate that in Line 2 of the Conditions and Limitations section of my Section 333 not ification that I am exempted from that clause.

Line 6 of the Conditions and Limitations, “All operations must utilize a Visual Observer or VO.” My aerial mapping UAS is a true drone, it flies a pre

- programmed flight route autonomously via computer progra m Iupload to it and as the operator of that drone, all I have to do is watch my UAS perform its mission while I easily act as my own VO but I have instant access to control the UAS if needed. Since both of my UAS will fly below 200 feet AGL and within 1,5 00 feet horizontally of me, well within Class G airspace, I would like an exemption from Line 6 of the Conditions and Limitations requiring a VO during operations.

Line 22 of Conditions and Limitations requires that I register my UAS and have identificati on N

- Number affixed to them. Part of that process requires that I prove these UAS were never registered in a foreign country. My UAS were manufactured in China by DJI, shipped to DJI North America who ships them to their US distributors who then re

- shipth em to hobby shops all over the United States. Along with my submission of Form 8050

- 1 and 8050

- 88 there is the requirement that I prove that my small UAS were not registered in a foreign country. I was told by the FAA Aircraft Registration Branch that incl uding purchase receipts from US hobby shops is not enough proof that they were never registered in a foreign country, as per Jamie Powers, Legal Instruments Examiner, of your Oklahoma City Aircraft Registration Branch. If there is a way you can notify this branch of the FAA that a sales receipt of a new UAS bought from a U.S. hobby shop is enough proof, I’d appreciate it.

I am attempting to be responsible and I have put myself on the FAA’s “radar” by applying and now receiving my Section333 exemption, but I’m faced with overwhelming competition from corporations that have deep pockets and can hire licensed pilots to fly their UAS and I’m faced with severe competition from companies and individuals who don’t bother with Section 333 exemptions. My small busi ness is effectively dead in the water because of the licensed pilot requirement.

I hope you take my suggested changes/additions into consideration and grant me these changes/additions to the listed Conditions and Limitations in my Section 333 exemption do cument.

Albert S. OConnor, Manager OConnor Aerial Videos & Editing LLC 1010 Black Willow DriveOviedo, FL. 32765 407

- 761

-4595 idronecom@aol.com

Mr. Duncan, here are the changes I have suggested:

**Conditions and Limitations** In this grant of exemption, OConnor Aerial Videos & Editing LLC dab iDRONE is hereafter referred to as the operator.

2. Operations for the purpose of closed

- set motion picture and television filming are not permitted. Change to: Operations for the purposeof filming indoors in a building or studio, so as to limit the public’s access to what is being filmed, or what is called “closed

-set” filming, of motion picture and television productions, is not permitted.

6. All op erations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. ThePIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight.The PIC must ensure that the VO can perform the duties required of the VO. Change to Add: Operations under 200 feet AGL within Visual Line Of Sight or VLOS, a VO is recommended but not required.

13. Under this grant of exemption, a PIC must hold either an airlin e transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified by 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. Change to: Under this grant ofexemption and with COA, operations under 2 00 feet AGL require no pilot’s license as this would be expensive and impractical. Furthermore, Medical certification can be provided by showing proof of FAA airman medical certificate or valid U.S. driver’s license issued by a state, the District of Colum bia, Puerto Rico, a territory, a possession, or the Federal Government.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) marki ngs in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. Change to Add: If UAS was purchased new from a U.S. distributor or U.S. retailstore, a sales receipt is the only proof necessary to prove the origin of purchase to file for an Aircraft N

- Number.

This last change would require notifying the Aircraft Registration Branch in Oklahoma City, Oklahoma, that the requirement that UAS operators who have purchased, new, their UAS through a U.S. distributor or retail store, wi ll only require a copy of the sales receipt to prove non

-foreign registration of a UAS.