August 5, 2015

Kristopher D. Riley

10067 Homestead Rd.

Beulah, MI 49617

C: (231) 383-4129

krisriley73@gmail.com

U. S. Department of Transportation

Docket Operations

1200 New Jersey Ave., SE

Washington, DC 20590

Subj: Kristopher Riley SECTION 333 SUBMISSION TO FAA FOR APPLICATIONS/ 

 PETITIONS/EXEMPTIONS AND ANY OTHER ITEMS FOR WHICH A 

DOCKET DOES NOT EXIST.

Ref: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation 

 Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21;14 CFR 61.113 (a) & (b); 

91.7 (a); 91.9 (b) (2); 

 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 

91.407(a) (1); 91.409 (a) 

 (2);91.417 (a) & (b).

Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform

Act) and 14 C.F.R. Part 11, Kristopher Riley, an operator of Small Unmanned Aircraft 

Systems (“sUAS”) equipped to offer on-demand commercial sUAS operations for a 

host of industries and applications. These include:

-Wedding photography and video

-Music video and photography

-Filmmaking, cinematography, and videography

-Aerial surveying and mappings

-UAS consulting

-Creation of commercial messages for Television

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Kristopher Riley hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its sUASs, so long as such 

operations are conducted within and under the conditions outlined herein or as may 

be established by the FAA as required by Section 333. To include, FAA Certificate of 

Waiver or Authorization (COA) that are issued to Kristopher Riley.

As described below, the requested exemption would permit the operation of green 

minded sUASs relatively inexpensively under controlled conditions in the National 

Airspace System (NAS) that is 1) limited, 2) predetermined, 3) controlled sUAS access 

and operation, and 4) would provide safety enhancements to the already safe 

operations using conventional aircraft. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities to “...establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant is:

Kristopher Riley

10067 Homestead Rd.

Beulah, MI 49617

Ph: (231) 383-4129

Email: krisriley73@gmail.com

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.20345 (a)& (b)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate 

safely in the national airspace system (NAS) before completion of the rulemaking 

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required under Section 332 of the Reform Act. In making this determination, the 

Secretary is required to determine which types of UASs do not create a hazard to users 

of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability

• Operation of the UAS in close proximity to airports and populated areas

• Operation of the UAS within visual line of sight of the operator

Reform Act Section 333 (a). Lastly, if the Secretary determines that such vehicles “may 

operate safely in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft in the national airspace system.” Id. 

Section 333(c) (emphasis added)

Applicant interprets this provision to place the duty on the Administrator to not only 

process applications for exemptions under Section 333, but for the Administrator to craft

conditions for the safe operation of the UAS, if it should be determined that the 

conditions set forth herein do not fulfill the statutory requirements for approval. The 

Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined 

under §40101 of the Act that includes SUASs, from the requirement that all civil aircraft 

must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of 

this title if the Administrator finds the exemption in the public interest. 49 U.S.C. 

§44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

Kristopher Riley request that an exemption be granted to any requirement for SUAS

operators to hold either an airline transport, commercial, private, recreational, or sport 

pilot certificate. This request is in concert with the FAA 14 CFR Parts 21, 43, 45 

Operation and Certification of Small Unmanned Aircraft Systems: Proposed Rule dated 

23 Feb 2015. To add, model aircraft operators operate unmanned aircraft that are 

comparable in size, weight, and speed, but the operator is not required to hold a 

manned pilot certificate. If this exemption is granted, the requestor shall ensure that 

operators pass an aeronautical knowledge test and recertify annually as proposed by 

the FAA Rule Making Committee. The aeronautical knowledge test shall be similar to 

current military knowledge standards until the FAA establishes the FAA aeronautical 

knowledge test for sUAS operators. All operators shall be a minimum age of 17 years 

old and be a U.S. citizen with a valid FAA Class II Medical Certificate and state issued 

driver’s license. 

The applicant request that the members of the sUAS aircrew shall not be required to 

hold a pilot’s license or certificate beyond the FAA Class II Flight Medical Certificate or 

commercial driver’s license. Due to the lack of identified UAS Pilot in Command (PIC) 

FAA Certificate requirement that are not outlined in Section 336 of Public Law 112-95 

(theFAA Modernization and Reform Act of 2012), Section 334 “PUBLIC UNMANNED 

AIRCRAFT SYSTEMS”, or Section 336 “SPECIAL RULE FOR MODEL AIRCRAFT”. 

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Therefore, the applicant is requesting an exemption from Pilot In Command (PIC), also 

identified as the Vehicle Operator (VO) throughout this document, not to be required to 

hold “...an airline transport, commercial, private, recreational, or sport pilot certificate” 

as annotated in previous Section 333 Exceptions authorized. Each vehicle operator 

shall be certified on each sUAS type before designation as a vehicle operator (VO) for 

each sUAS type. Before Kristopher Riley sUAS assets are authorized for autonomous 

aircrew operational flights; currency and designations shall be maintained and 

authorized by Kristopher Riley. All records for personnel and sUAS shall be made 

available upon request by an FAA Administrator or law enforcement agency or 

representative. Preflight and post flight inspections shall be conducted as Standard 

Operating Procedure (SOP) within Kristopher Riley. Incidents/mishaps that involve 

injury or damage shall be reported to the FAA within 10 business days of the 

incident/mishap. A safety mind frame of each operator is critical to the success of 

Kristopher Riley and shall be grounds for termination when Safety of Flight (SOF) and 

overall ground safety is not applied. 

Kristopher Riley sUASs are vertical take-off and landing (VTOL) rotary-winged air 

vehicles (AV) and fixed-wing AV, weighting 55 lbs or less including payload. They 

operate, under normal conditions at a speed of no more than 87 knots (100 MPH), 

operation not to exceed manufacturer recommended airspeed, and have the capability 

to hover and move in the vertical and horizontal plane simultaneously. The sUAS assets

will operate only in line of sight and will operate only within a sterile area. Such 

operations will insure that the sUAS will “not create a hazard to users of the national 

airspace system or the public.”

Reform Act Section 333 (b). Given the small size of the sUASs involved and the 

restricted sterile environment within which they will operate, the applicant falls squarely 

within the zone of safety (an equivalent level of safety) in which Congress envisioned 

that the FAA must, by exemption, allow commercial operations of UASs to commence 

immediately. Also, due to the size of the UASs and the restricted areas in which the 

relevant sUASs will operate, approval of the application presents no national security 

issue. Given the clear direction in Section 333 of the Reform Act, the authority 

contained in the Federal Aviation Act, as amended; the strong equivalent level of safety 

surrounding the proposed operations, and the significant public benefit, including 

enhanced safety, reduction in environmental impacts, including reduced emissions 

associated with allowing UASs, the grant of the requested exemptions is in the public 

interest. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant will operate the following aircraft:

1. DJI Phantom 3 2. DJI Phantom 4

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The applicant proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure because the proposed operations represent a 

safety enhancement to the already safe operations conducted with conventional 

aircraft. These limitations and conditions to which Kristopher Riley agrees to be bound 

when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a vehicle operator (VO) and/or

observer.

3. Maximum total flight time for each operational flight will not exceed the capabilities

and limitations of the sUAS type operated per manufacture specifications and

recommendations. Flights will be terminated at no less than 15% battery power reserve

during any flight to ensure Safety of Flight (SOF).

4. Day flights will be operated at an altitude of no more than 400 feet AGL.

5. Range of operation and altitude shall be decreased when operating in close vicinity

of airfields that are not controlled by air traffic control (ATC) in Class G airspace. Where

airfields are controlled by ATC or other forms, coordination and permissive operations

shall be coordinated with the appropriate airspace control authority (ACA), i.e. Class B,

Class C, Class, D, and Class E airspace. Class A airspace shall be avoided. Operation

under Class E airspace and imposing a self-imposed safety buffer below the Class E

airspace shall only be conducted after proper coordination with the Class E airspace

ACA. Safety buffers shall be reasonable and flights shall be cancelled if Safety of Flight

(SOF) is ever a concern by the ACA or of the sUAS VO.

6. Minimum crew for each operation will consist of the sUAS vehicle operator (VO). If

line-of-sight (LOS) is an issue during sUAS flight operations, an observer shall be

utilized. When operating specific sUAS air vehicles during specific missions, a Payload

Operator (PO) shall be a part of the aircrew.

7. sUAS VO shall be trained and certified in the sUAS type operating and have visual

acuity, correctable by glasses or contacts, of 20/20 and not be color blind.

8. sUAS VO shall perform as the Pilot in Command (PIC) duties and be responsible for

the sUAS SOF. Consideration to obstacles, safe launch/recovery area, LOS, sUAS

capabilities and limitations, sUAS Operational Brief, pre/post flight operations, and

Kristopher Riley imposed airspace control measures and procedures shall be adhered 

to, i.e. mandatory ascending/descending Elevator Points, Emergency Holding Points, 

etc.

9. A sUAS flight path shall never be programmed to fly over another sUAS

launch/recovery site and/or Ground Control Station (GCS).

10. Multiple sUAS launch/recovery sites shall ensure that sUAS VOs coordinate

through positive communication during sUAS operations and shall stagger AV launches

and landings to ensure SOF.

11. The sUAS will only operate within an identified confined “Sterile Area” of the flight

operations area. Area shall be surveyed by the aircrew prior to sUAS operational flight

commencement. sUAS operations within the aforementioned operations area shall not 

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commence unless, if applicable, required ACA coordination has been completed, 

agreed upon, and authorized.

12. A sUAS brief shall be conducted in regard to the day’s planned sUAS operations.

sUAS Brief shall be conducted before sUAS flight operations commence. The sUAS

Brief is mandatory and all participating personnel who will be performing duties within the 

boundaries of the safety perimeter shall be present for this briefing.

13. The operator shall obtain the consent of all persons involved and ensure that only

consenting persons will be allowed within 75 feet (25 meters) radius of the SUAS launch/

recovery site (GCS); the radius may be reduced to 30 feet (10 meters) based upon an 

equivalent level of safety and environment conditions and restrictions determination by 

the sUAS VO (PIC).

14. sUAS VO shall maintain current proficiency in all sUAS type that they are certified

with.

15. During all sUAS operations, where an observer is utilized, positive communication

shall be maintained between the sUAS VO and the observer.

16. Written and/or oral permission from the relevant property holders shall be obtained.

17. All required permissions and permits will be obtained from territorial, state, county or

city jurisdictions, including local law enforcement, fire, or other appropriate governmental

agencies when applicable.

18. If the sUAS is the subject of a Loss of Link (LOL) emergency or a GPS Loss

emergency, the sUAS will have the capability to return to a pre-determined location

within the operating area, i.e. manual control, and/or land safely, i.e. “land immediately”

feature or similar.

19. The sUAS will have the capability to abort a flight in case of emergencies and the

VO shall conduct established Kristopher Riley Emergency Procedures and manufacturer

established emergency procedures.

20. All sUAS incidents that involve death, injury, damage to equipment (other than the

company owned sUAS), and damage to property (other than company owned) shall be

reported appropriately.

21. “Right of way” shall always be given to all other manned and unmanned air vehicles

in every scenario and event without exception. Special consideration shall always be

granted in every event that requires actions that would prevent death of injury of any

person.

22. Kristopher Riley, on the behalf of the sUAS VO, shall submit a written Plan of

Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the

area of proposed sUAS operations. It is understood that the 3-day notification may be

waived with the concurrence of the FSDO. The plan of activities shall include at least the 

following: 

a. Dates and times for all flights.

b. Name and phone number of the vehicle operator (VO) for the sUAS conducting the

sUAS operation under this grant of exemption.

c. Name and phone number of the person responsible for the on-scene operation of the

sUAS.

d. Make, model, and serial or N-Number of sUAS to be used

e. Name and certificate number of sUAS vehicle operator (VO)/pilot in command (PIC)

involved in the sUAS operation.

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f. A statement that the VO has obtained permission from property owners and/or, if

applicable, local officials to conduct the filming production event; the list of those who

gave permission must be made available to the inspector upon request.

g. Signature of exemption holder or representative.

h. A description of the flight activity, including maps or diagrams of any area, city, town,

county, and/or state over which filming will be conducted and the altitudes essential to

accomplish the operation.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given 

the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal

Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular UAS. In all cases, an analysis of these criteria 

demonstrates that the sUAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft (fixed-wing or rotary-wing) operating with an 

airworthiness certificate without the restrictions and conditions proposed. The sUAS to 

be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a safe area as set out in the Manual. Unlike other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by both the 

operator, pursuant to the Manual’s requirements, and under the requirements and in 

compliance with local public safety requirements, to provide security for the area of 

operation as is now done with conventional filming during filming services. In regard to 

motion picture and television production, security of the filming location adds to and 

provides a greater degree of safety to the public and property owners than conventional 

operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, 

Subpart H. This type of local operations area security is also found within the industrial 

and manufacturing areas, specific national, state, local, and privately controlled areas, 

and during local emergencies that are supported. Lastly, application of these same 

criteria demonstrates that there is no credible threat to national security posed by the 

sUAS, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. §45.23 (b). Marking of the Aircraft. The regulation requires: When marks 

include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 

inches high, the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable. Even though the SUAS will have no airworthiness 

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certificate, an exemption may be needed as the sUAS will have no entrance to the 

cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given 

the size of the sUAV, two-inch lettering will be impossible. The word “Experimental” will 

be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety 

will be provided by having the SUAV marked on its fuselage as required by §45.29 (f) 

where the sUAS air vehicle (AV) vehicle operator (VO), AV visual observer, and others 

working with the sUAS will see the identification of the sUAS as marked appropriately 

with registered aircraft markings. Each Crossview Concepts Corporations, Inc. sUAS 

air vehicle shall be registered with the FAA and the FAA aircraft registration number 

shall be placed on the air vehicle in the largest practicable manner. The FAA has 

issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 

10167 and 10167A.

14 C.F.R. §1.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command. Section 61.113 (a) & (b) limit private pilots to non-commercial operations. 

Because the UAS will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety of current operations by requiring the PIC 

operating the aircraft to have a private pilot’s license rather than a commercial pilot’s 

license to operate this sUAS. Unlike a conventional aircraft that carries the pilot and 

passengers, the sUAS is remotely controlled with no living thing on board. The area of 

operation is controlled and restricted, and all flights are planned and coordinated in 

advance. The level of safety provided by the requirements included in the Manual 

exceeds that provided by a single individual holding a commercial pilot’s certificate 

operating a conventional aircraft. The risks associated with the operation of the sUAS 

are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 when drafted, that allowing operations of the sUAS as 

requested with a private pilot as the PIC exceeds the present level of safety achieved by

14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no 

person may operate a civil aircraft unless it is in airworthy condition. As there will be no 

airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the 

aircraft and the requirements contained in the Manual for maintenance and use of 

safety check lists prior to each flight, as set forth in Sections (j), (l) and (q), an 

equivalent level of safety will be provided.

14 C.F.R. §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) 

(2) provides:

“No person may operate a U.S.-registered civil aircraft...” (2) For which an Airplane or

Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless it is available in

the aircraft, a current approved airplane or Rotorcraft Flight Manual, approved manual

material, markings, and placards, or any combination thereof. The sUAS, given its size

and configuration, has no ability or place to carry such a flight manual on the aircraft,

not only because there is no pilot on board, but because there is no room or capacity to

carry such an item on the aircraft. The equivalent level of safety will be maintained by

Page 8 of 12
keeping the flight manual at the GCS within the reach of the sUAS vehicle operator for 

immediate access. The FAA has issued the following exemptions to this regulation: 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 

32827, and 10700.

14 C.F.R. §91.103: Preflight action. This regulation requires each pilot in command to

take certain actions before flight to insure the safety of flight. As FAA approved 

rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed.

The sUAS vehicle operator will take all actions including reviewing weather, flight 

battery requirements, launch paths and landing approaches, and aircraft pre-flight check

parameters and data before committing to a AV Launch.

14 C.F.R. §91.109: Flight instruction. Section 91.103 provides that no person may 

operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls. sUASs and remotely 

piloted aircraft, by their design do not have fully functional dual controls. Flight control is

accomplished through the use of the GCS Hand Controller Unit (HCU) that 

communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of aircraft

and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. 

The equivalent level of safety provided by the fact that neither a pilot nor passengers 

will be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes. Section 91.119 establishes safe altitudes

for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less

than the minimums prescribed, provided the person operating the helicopter complies 

with any route or altitudes prescribed for helicopters by the FAA. As this exemption is 

for a sUAS that is for not only sUAS fixed-wing AVs, but also SUAS rotary-winged 

(helicopter) and the exemption requests authority to operate at altitudes up to400 AGL, 

an exemption may be needed to allow such operations. As set forth herein, except for 

the limited conditions stated in the Manual, the sUAS will never operate at higher than 

400 AGL unless authorized by a COA or the published FAA rules for sUAS scheduled to

be published in 2015. The equivalent level of safety will be achieved given the size, 

weight, and speed of the UAS as well as the location where it is operated. No flight will 

be taken without the required ACA coordination, permission of the property owner or 

local officials, and other unforeseen requirements that may arise. Due to the advance 

notice to the property owner and participants in the aerial activity, all affected individuals

will be aware of the planned sUAS flight operations. Compared to flight operations with 

aircraft or rotorcraft, weighting far more than the maximum 55lbs. proposed herein and 

the lack of flammable fuel, any risk associated with these operations is far less than 

those presently presented with conventional aircraft operating at or below 400 AGL 

other industries. In addition, the low-altitude operations of the SUAS will ensure 

separation between these sUAS operations and the operations of conventional aircraft 

that must comply with Section 91.119.

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14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating 

an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the 

elevation of the departure airport or an appropriate altimeter setting available before 

departure.” As the sUAS may not have a barometric altimeter, but instead a GPS 

altitude read out, an exemption may be needed. An equivalent level of safety will be 

achieved by the sUAS vehicle operator, pursuant to the Manual and Safety Check list, 

confirming the altitude of the launch/recovery site shown on the GPS altitude indicator 

before flight.

14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions. Section 

91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough 

fuel to fly to the first point of intended landing, and, assuming normal cruising speed – 

(1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that

for at least 45 minutes.” The battery powering the sUAS provides set flight endurances

for each sUAS type. To meet the 30-minute reserve requirement in 14 CFR §91.151,

sUAS flights would be extremely limited or not be able to fly at all. Given the limitations

on the sUAS’s proposed flight area and the location of its proposed operations within a

predetermined area, a longer time frame for flight in daylight VFR conditions is

reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within

the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin

Corporation to operate without compliance with FAR 91.151 (a)). Operating the sUAS,

in a tightly controlled area where only people and property owners or official

representatives who have signed waivers will be allowed, with less than 30 minutes of

reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to

alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights

to extreme minimum flight time would greatly reduce the utility for which the exemption

will be granted. Applicant believes that an equivalent level of safety can be achieved by

limiting flights to the manufacture’s flight endurance specifications and self-imposing

minimum reserve battery life to force a controlled landing safely without exceeding the

manufacturer’s maximum flight endurance specifications. This restriction would be

more than adequate to return the sUAS to its planned launch/recovery site from

anywhere within its limited operating area. Similar exemptions have been granted to

other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration.

The regulation provides in pertinent part: (a) Except as provided in Section 91.715, no 

person may operate a civil aircraft unless it has within it the following: (1) An appropriate

and current airworthiness certificate. . . . (b) No person may operate a civil aircraft 

unless the airworthiness certificate required by paragraph (a) of this section or a special 

flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance 

so that it is legible to passengers or crew. The sUAS, fully loaded, weighs no more than

55 lbs and is operated without an onboard pilot. As such, there is no ability or place to 

carry certification and registration documents or to display them on the SUAS. An 

equivalent level of safety will be achieved by keeping these documents at the GCS 

where the sUAS vehicle operator operating the AV will have immediate access to them, 

Page 10 of 12
to the extent they are applicable to the sUAS. The FAA has issued numerous 

exemptions to this regulation. A representative sample of other exceptions includes 

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

Inspections. 

These regulations require that an aircraft operator or owner “shall have that 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...,” and others shall inspect or maintain the aircraft 

in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft 

with an airworthiness certificate, these sections will not apply to the applicant. The 

operator pursuant to the flight manual and operating handbook will accomplish 

maintenance. An equivalent level of safety will be achieved due to the nature of these 

sUASs based on their sized and will carry a small payload and operate only in observed

controlled areas for limited periods of time. If mechanical issues arise, the SUAS can 

land immediately and will be operating from no higher than 400 feet AGL unless 

otherwise authorized through a FAA COA. The operator will ensure that the sUAS is in 

working order prior to initiating flight and perform required operator maintenance. Major

maintenance events beyond basic operator maintenance shall be recorded in the sUAS 

equipment record jacket maintained by the applicant. Moreover, the vehicle operator is 

the person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety.

Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: Applicant seeks 

an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 

C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121;

91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2)

and 91.417 (a) & (b) to operate commercially a small unmanned aircraft vehicle (SUAS)

(55 lbs. or less). Approval of exemptions allowing commercial operations of sUASs, will

enhance safety by reducing risk while operating within the NAS. Conventional

operations, using jet or piston power aircraft, operate at extremely low altitudes just feet

from the subjects being filmed or equipment being inspected and in extreme proximity to

people and structures and present the risks associated with vehicles that weigh in the

neighborhood of 4,000lbs, carrying large amounts of Jet A, JP-8 or other fuel. Such

aircraft must fly to and from the operational location. In contrast, a sUAS weighing

fewer than 55lbs. and powered by batteries eliminates virtually all of that risk given the

reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the

operation site and not flown. The SUAS will carry no passengers or crew and, therefore,

will not expose them to the risks associated with manned aircraft flights. The operation

of sUASs, weighting less than 55 lbs., conducted in the strict conditions

aforementioned, will provide an equivalent level of safety supporting the grant of the

exemptions requested herein, including exempting the applicant from the requirements

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of Part 21 and allowing commercial operations. These lightweight aircraft operate at 

slow speeds, close to the ground, and in a sterile environment; resulting in a far safer air

vehicle flight than conventional aircraft operations utilizing combustible fuels and 

rotating blades operating within close proximity to the ground, personnel, and 

equipment during filming and inspections. Kristopher Riley has every intention to 

adhere to and comply with established policies, rules, guidelines, and established laws.

Privacy

Privacy of personnel and property shall be adhered to. No person shall be surveilled 

unless proper authorization is provided by the appropriate authorizing agency or 

organization in accordance with established intelligence oversight practices and in 

compliance with all applicable regulations, orders, publications, and/or policies. All 

flights will occur over private or controlled access property with the property owner’s 

prior consent and knowledge, unless the area is deemed a public area. Navigational 

imagery may be used to support incident/mishap reporting as applicable. Only imagery 

supporting the purpose of the sUAS operational flight shall be utilized for the 

appropriate purpose. Commercial Film and TV filming events will be of people who 

have also consented to being filmed or otherwise have agreed to be in the area where 

filming will take place. All sUAS operations shall be conducted in consideration to the 

direction to government entities set forth in the Presidential Memorandum, Promoting 

Economic Competitiveness While Safeguarding Privacy, Civil Rights, and Civil Liberties

in Domestic Use of Unmanned Aircraft Systems (February 15, 2015). The grant of this 

exemption request will provide improved safety in both day and low-light operations. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of 

applicant’s commercial and private sUAS.

Respectfully,

Kristopher Riley

Videographer

krisriley73@gmail.com

Small Unmanned Aircraft Systems (SUAS) Service Provider

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