Salvatore Bonaccorso 1241 Salerno Court League City, Texas 77573 (321) 446‐0055

December 14 th , 2015 U.S. Department of Tra n sportation Federal  Aviation Administrat ion 800 Independence Ave.
, SW Washington, DC 20591

Dear Sir or Madam:

Attached please find Salvatore Bonaccorso’s request for  an exemption fro m the listed Federal Aviation Regulations to allow commercial operation of its Small Unmanned Aircraft Systems ("sUASs") for  imaging real‐estate, film productions, and safety matters

, alo n g  with the monitoring of secured and controlled en v i r onments. This exemption request is for  the  use of Da‐Jiang Innov at ion s (DJI) UASs, a China based company.

I am a Student Pilot with over 45 Hours of logged flying experi ence of Private Ai rcraft.  I have a Class III Medical clearance and also am pursuing my Private Pil ot License.  In addition to this request for exemption, I will also adhere to the Drone Registra tion Requirements beginning on December 21 st , 2015.

Also attached to  this letter i s both UAS Flight Manuals  ("Manual"), which outlines the operation  requirements, limitations

, and technical specifications for my DJI systems

. Salvatore Bonaccorso (myself) has reviewed these m anuals and h as fo und it to  be acceptable for sUAS operat i ons on my projects s i ght s and  film sets.

Thank you for your time and consideration. Please contact me if you have any questions.

Regards,

Sal BonaccorsoDecember 14, 2015 U.S. Department of Transportation Federal Aviation Administration 800 Independence Ave.
, SW Washington, DC 20591

Re: Exemption  Request Section 333  of the FAA Reform Act and Part 11of 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;  91.121; 91.151( a ) ; 91.204(a)  & (b); 91.405(a) (1); 91.409(a) (2); 91.417(a) & (b). Dear

Sir or Madam:

Pursuant to Sections 333 of the FAA Modernization  and  Reform Act of2012 (the Reform Act and 14 C.F.R. Part 11, Salvatore Bonaccorso

, an individual

, h ereby  app li es for an exemption from  the listed Federal Aviation Regulations ("FARs") to allow commercial operations of its Small Unmanned Aircraft Systems ("sUAS") for aerial cinematography for film and commer cial productions, aerial imaging for commercial and residential real estate

u se, aerial imaging for safety  and monitoring  of secu r ed and controlled env ironment s, aerial imaging for search and rescue as well as assist ing any law enforcement and rescue crews, so long as s uch ope r a tions are co ndu cted  wi thin and  under t h e conditions outlined herein  or as may established by t h e FAA as  required  by Section 333.

As det a iled in this document and  the attached Flight Manual, the requested

exem ption would  permit the operations sUAS under  controlled conditions in a ir s pace that is 1)  limited 2) predetermined 3 ) controlled as  to access and  4) wou l d provide  safety enhanceme nts to the a lr eady best  practices s a f et y protocol s followed by Salvatore Bonaccorso at each and  eve ry film set  or job l ocation

. Approv a l of this exemptio n would thereby enhance safety and fulfill the Secretary of Transportation's (the  FAA Administrator's) r esponsibili ties to "... establish requirements for th e safe operat i on of such aircraft systems in the  national  airspace  system." Section  333 (c) of the Reform Act.

The name and address of the applicant is :

Salvatore Bonaccorso
PH: 321‐446‐0055 Email: sal.bonaccorso@gmail.com Address: 1241 Salerno Cour t, League City, Texas 77573Regulations from  which  the exemption is requested:

14 C.F.R. Part 21
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 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) & (b)
14 C.F.R. 91.405 ( a )
14 C.F.R. 407  (a) (2)
14 C.F.R. 417 (a) & (b)

1. STATUTORY AUTHORITY FOR EXEMPTIONS

The  Federal Aviation  Act expressly grants the FAA authority to issue exemptions

. This statutory  authority includes exemptions civil aircraft, as the term is defined u n de r §40101 of the Act, including 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 subsections (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 U.S.C. §44711 (a); U.S.C. §44704; 14  C.F.R. §91.203 (a) (1).

Section  333  (b)  or  the Reform Act assists the Secretary in determining whether
sUAS may operate in the  National Airspace System (NAS) without creating a hazard to the use, the  public,  or  a threat to national security. In making this determination, the Secretary must consider:

• The sUAS size, weight, speed, and operational  capability

• Whether the sUAS operates within the visual line of sight  of the operator

• Whether the sUAS operates outside highly populated areas and away from  close proximity to airportsSalvatore Bonaccorso’s sUAS is a multi‐rotor vehicle weighing 3‐pounds, including  its fixed high‐ performance camera (DJI Ph antom  3 Professional). It operates under  normal condition s at a s p eed of no more than 3 0  knots, with the capability  to hover, move on a vertical  and horizont a l plane simultaneously

. The sUAS will operate only in the pilots visua l line of site  at all times  and will operate only within  the ster il e area  described in the a ll D JI manuals, attached as Exhibit 1 (hereinafter "the Manuals"). S u ch Operations will in sure that the sUAS will not create  a hazard to  users or the  national airspace  system or the public." Reform Act Section 333 (b).

Given the small  size of the sUAS involved and  the restri cted and ste rile env ironm ent within  which  it will operate,  my  application falls squa rely within the zone of safety (an equivalent level of safe ty) in which Congress en v i s ioned

. A l so due to the small size of the sUAS and  the low a l titudes and restricted areas in which my sUAS will operate, ap proval of the

ap p lic ations presents no n ational  security issue.

Given the clear  direction  in Section 333 of the Reform Act, the a uthority contained in the  Federal  Aviation Act, as amended ; the strong equiva lent level of safety surrounding the proposed operations, and  the significant public benefit, including  enhanced safety, the grant of the requested exemptions is in the public interest. Accordingly, Salvatore Bonaccorso respectfully requests that  the FAA grant requested exemption without delay.

2. Public Interest

This exempt ion application is express ly submitted to fu l fill Congress' goal in pass in g Section 333 (a)  through (c) of the Reform Act

. T h i s l a w direct s the Secretary of Transportation to consider whether certain unmanned aircraft  systems may operate safely in the NAS before  completion of the  rulemaking  required unde r Section 333 of the  Reform Act. By granting an exemption, the FAA wi ll fulfill Congress's  intent  of a llo wing UAS to operate w ith sig n i ficant safety pr ecautio n s in low risk environments.The use of sUAS to assist in aerial imaging in search  and rescue can significantly reduce  risk to public safety workers as well as civilians. sUAS can inspect, photograph, and collect data  in and around hard  to get or hazardous areas that otherwise would  require personal to  put themselves in danger to gather the information.

In addition, having a knowledgeable and experienced crew  and personnel working with  the sUAS on film productions sets  as well as capturing images  for real estate  will decrease the amount of inexperienced pilots  by giving the clients a safer option to go with.

Additionally, sUAS could replace  the  use of helicopters and small aircraft to monitor sites  and capture cinematography. The sUAS I propose to fly in these applications range from  payloads  reaching  as much as .5‐pounds, with total payload and  carry  no combustible material  on  board, as opposed to the much larger conventionally powered small  aircraft. Shifting to sUAS from helicopters presents a marked  safety increased fo r film crews  and  the public.

Lastly, sUAS reduce  the environmental impact by dramatically decreasing the energy  used for aerial  imaging, data  collection, and  aerial cinematography for film productions. My sUAS uses a rechargeable lithium ion  batteries, as opposed to fossil fuels burned in operation of small aircraft that are many hundreds of times heavier.

3. EQUIVALENT  LEVEL OF SAFETY

Salvatore Bonaccorso proposes that the exemption requested herein  apply to civil aircraft that have the characteristics and that operate with the limitations listed  herein. These limitations provided 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 protocols followed on film production sites
, imaging areas , and  surveying operations conducted with helicopters and  other conventional aircraft.Salvatore Bonaccorso  will be bound  by the  following limitations when conduction  its sUAS operations under a FAA issued exemption:

1.   The sUAS will never exceed  5 pounds at any given time. 2. Flights will be operated within  visual  line of sight  of the pilot. 3. Maximum total  flight time  for each operation flight will be 30 minute s

. The sUASs calculates battery reserve in real  time and will return to its home within  20%  battery power  reserve,  should  that  occur  prior to the  30 minute limit

4. Flights will be operated at an altitude of 200 feet AGL, never exceeding  the  400  feet AGL. 5.   Crew for the operations will consist  of the sUAS pilot who will keep the sUAS within his/her visual sight at a ll times. 6.   The sUAS pilot will be trained  in flight, operations
, and safety procedures as detailed  in the  Flight Manuals and  Salvatore Bonaccorso's requirements. 7.   The sUAS will operate within a confined "Sterile Area" and will always have an established "Security Parameter" for  the  flight operations area. 8

. A briefing will be conducted in regards to the  planned  sUAS operations prior to each day's productions activities. 9. The pilot will have been  trained  in operations of sUAS generally and receive up‐ to‐date information  on particular sUAS planned  to be operated.
10. All required permissions and permits will be obtained for territorial, state, county and/or city jurisdictions, to include  local law enforcement, fire or other appropriate  governmental agencies.
11. If the sUAS loses communications or lo ses its GPS signal, it will have the capability  to  return   to a pre‐determined "home" point within the security perimeter and land. 12. The sUAS will have  the capability  to abort a flight in case unpredicted obstacles or emergencies.4. DESCRIPTION  OF SPECIFIC REGULATIONS

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

Subpart H, entitled  Airworthiness  Certificates, established 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 Salvatore Bonaccorso, an exemption from Part 21 Subpart H meets the requirements of an equivalent level  of safety under Part 21and 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 ai r worthiness certificate, upon consideration of the  size, weight, speed, operation capability, and proximity to airports and populated areas or the particular sUAS. All our
sUASs will  be operated at low speed in a controlled environment, at least five miles  from

an airport and more  than three miles from  any densely populated area. 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  safe  (or safer) than  a conventional fixed and/or rotary winged aircrafts operating with an airworthiness certificate without the restrictions and conditions proposed.

The  sUAS is to  be operated hereunder are less  than 48‐pounds fully loaded, carries neither a pilot  nor passenger, carries no explosive material or flammable liquid fuels, and operates exclus iv ely within  a secured area. Like other civil aircraft, operations under this exemption will  be tightly controlled and mon ito red by the operator, pursuant to  the Manual's requirements, to provide cinematography and photography for  are  of operations as is currently done  on active  film production sets and more.  The local law enforcement as well  as the FAA will  have advance notice of all operations.

These  safety enhancements, which already ap p l y to civil aircraft operated in connection with film productions, provide 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. Lastly, applications of these same criteria demonstrates that there is no credible threat to  nation security posed by the sUASs, due to  their  size, speed of operation, location of operation, l ack of explosive materials or flammable liquids fuels, and  ability  to carry  and external load no greater than 20‐pounds.14 C.F.R

. 45.23 (b): Marking of Aircraft

This regulat ion requires certain experimental, provisionally certificated aircraft,  or light‐spor t category  aircraft  to  be marked  with letters between  2 inches and 6 inches high "li mit e d," "restricted," "light‐sport, " "exper imental ," or "provisional,"  near each

entrance to a cabin  cockpit  or pilo t station.

Even though the sUAS will have  no airworthiness cert ificat e, an exempti o n may be needed,  as the s UAS will have no en trance to the cabin, cockpit, or pilot station on which  the word "Ex p er im enta l" can be placed. Given the size of a sUAS, two  2‐inch l etter s will be impossibl e. The word "Experimenta l " will be placed  on the f u s e la g e in compliance  with §45.29 (f).

The equivalent l eve l of safety will be provided by having the sUAS marked on its fuselage  as  required by §45.29 (f) where  the  pilot, observer and  others working with  the sUAS will see  the  identification of the s UAS as "Experimental".  The FAA has issued  the following exemptions to  this regulation: Exemptions Nos. 10700, 8738, 10167, and 10167 A.

14 C.F.R

. 61.113 (a) & (b): Private pilot privilege s and limitations : Pilot in Command

Sections  61.113  (a) limit private  pilots to non‐commercial operations. Because the sUAS will not carry  a pilot or passengers, the proposed operations can ac hiev e the

eq uiv a lent  l evel of safety operation s by requiring the  pilot operating the aircraft  to have completed  a sUAS flight‐training course of 100hours before flying a sUAS as recommended by the  Manual. Unlike a conventional aircraft  that  carries the pilot and passengers, the sUAS is remotely  controlled  with  no living thing or cargo on  board. The area  of operation is controlled, restricted environment. All flights are planned  and coordinated in advanced. The risks associated  with  the operation of the sUAS are  so diminished  from  the lev el of risk associated  with  commercial operations contemplated by Par t 61 when  drafted, that allowing operation s of the sUAS as requested with  a pilot who has  me t the minimum requirements  recommended in the manual  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 the airworthy condition. As there will be no airworthiness certificates 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 checklists prior  to each  flight, as set  forth in Section Band  Section G and equivalent level of safety will be provided.

14 C.F.R.91.9  (b) (2):Civil aircraft flight manual, marking, and placard requirements

The sUAS, given its size and configurations 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 keeping the  flight manual at  the ground control  point where  the  pilot flying the sUAS will have immediate access. The FAA has issued  the  following exemptions to the regulations: Exemption Nos.8607,8737,8738,9299,9299A, 9565,9565B,10167,10167A,10602,328 27, and 10700.

14  C.F.R.91.103: Preflight Action

This  regulation requires each pilot in command to take certain act ion s before flight

to ensure the safety  of flight. An exemption is needed  from  this requirement, as  the pilot will take separate preflight actions, including  checking  for weather conditions, checking  flight battery requirements, checking  takeoff and l anding distances, and all other actions that are required in the  Pre‐flight Checklist in the Manual. These actions  will provide an equivalent level of safety.

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 instructions unless that aircraft ha s fully functioning  dual controls.By design, sUASs and  remotely  piloted aircrafts do not  have fully functional dual controls.  Flight control  is acco mplished  through  the  use of a control  box that communicates with  the aircraft via radio communication s

. The FAA has previously approved exemptions for aircraft  without  fully functional  dual  controls. See Exemptions  Nos. 5778K & 9862A. The equivalent l evel of safety  provided  by the fact that neither  a  pilot nor passengers will be carried in the aircraft,  the ability to control  the sUAS via radio  signals  from the controller

, and by the size and speed of the aircraft.

14 C.F.R. 91.119: Minimum Safe Altitudes

Sect ion 91.119 establishes safe altitudes for operation of civil aircraft. Sectio n 91.119  (b) allows helicopters to be operated at les s than  minimums prescribed

, provided the  person operating the helicopter complies  with any route  or altitudes of 200‐feet AGL,

so an exemption  may be needed to allow such operations. The sUAS will never operate at altitude higher  than  400‐feet AGL and  will be in restricted area with secur ity parameter , where  buildings and  people  will not  be exposed t o operations without their pre‐obtained

consent.

The equivalent level of safety will be achieved  given  the size, weight, speed of the sUASs, as well as the location  where it is operated. C ompared  to flight operations with aircraft  or rotorcraft weighting  far more  than  the maximum 5 pounds  proposed  herein and  carrying  flammable  fuel, any  risk associated  with my operations is far less than  those presently presented with helicopters and other conventional a ir crafts operating at  or below 500‐feet AGL in the  film industry. In addition, the low altitude operations of the sUAS will ensure separation between these sUAS operations along with operations of conventional aircraft  that must comply with  Section 91.119.

14 C.F.R. 91.121:  Altimeter Settings

This regulation requires eac h person operating an aircraft  to maintain cruisin g

a ltitude 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 sUASs 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 operator, pursuant to the Manual and  Safety Check list, confirming  the altitude  of the l aunc h s it e  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) outlines  fuel requirements for beginning a flight in VFR conditions

. Our sUASs are limited to operations in sterile  and controlled environments and has a limited range  and flight time, which  required and exemption  from 14 C.F.R. 91.151 ( a ).

The battery powering the sUAS provides approximately 35 minutes of powered flight. To meet  the 30‐minute reserve requirement in 14 C.F.R

. §91.151, sUAS flights would  be limited to approximately 5 minutes  in length. Given the limitations on the sUASs proposed flight area  and location of its proposed operations within a predetermined area , a longer time  frame  for flight in daylight or night VFR conditions  is reasonable.

Salvatore Bonaccorso believes  that  an exemption  from 14 C.F.R

. §91.151 (a)  falls within the scope of prior exemptions

. See Exemption 1067 3 (allowing  Lockheed Martin Corporation  to operate without  compliance  with FAR 91.151(a)). Operation the sUAS in a tightly  controlled  area  where  only people and property owners or official representatives who  have signed waivers  will be allowed,  with les s than  30 minutes or  reserve  fuel, does

not engender the  type of ri sks that Section 91.151 (a) was intended to alleviate,  given  the size and  speed  of the sUAS. Additionally, limiting sUAS flight to 10 minutes  would great ly reduce th e utility for which  the exemption will be grante d.

An equivalent level of safety  can be ac hieved  by limiting  flights to 30 minutes, or enough battery reserve to ensure th a t  the s UAS lands  at  the grounding station with at least 20%  of battery power  (as determined by the on board monitorin g system a nd the  pilot)., whichever happens  first. This re s triction would  be more than

a dequate to  return  the sUAS to its planned  landing zone  from anywhere in 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) & (b): Carrying civil aircraft certification and registration

The regulation  provides  in part:

(a)  Except as provided in §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  will never surpass 45 pounds  and  is operated without an on board  pilot. Therefore 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 ground  flight control  point  where  the  pilot operating the sUAS will have immediate access to them,  to  the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation

. A representative sample of these exemptions includes Exemption Nos. 9565,9665,9789, 9789A, 9797, 9797 A, 9816A, and 10700.

14 C.F.R. 91.405 (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  other  shall  inspect or maintain  the aircraft in compliance  with  Part 43.

Given that  these sections and  Part  43 applies  only to aircrafts with an airworthiness certificate,  these sections will not apply to Salvatore Bonaccorso. Maintenance  will be accomplished  by the operator pursuant to the  flight manual  and operating handbook as  referenced  in the Manual. An equivalent level of safety will be achieved because  these sUASs are  very limited  in size and  will carry  a small  payload along wit h operate only in restricted areas  of limited  period of time. If mechanical issues arise,  the sUAS can land immediately and  will be operating from  no higher  than 400‐ feet AGL. As provided  in the  Manual, the operator will insure  that  the sUAS is inworking or d er prior  to initiating  flight, perform  required maintenance, and  keep  a log of

any maintenance performed. Moreover, the operator is the  person most familiar  with the aircraft  and  best suited to maintain the aircraft in an airworthy condition to provide the equivalent lev e l of safet y

.

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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) &  (b); 91.405  (a); 91.407 (a) (1) ; 91.409  (a)  (1); 91.409  (a)  (2); and 91.417  (a) & (b) to operate commercially  a small unmanned vehicle  (55  pounds  or less) in operations pertaining to (but  not limited to) professional cinematography and  commercial productions, aeria l imaging for commercial and  residential real estate use, aerial imaging for safty and monitoring of secured  and

contro ll ed environments
, aeria l imaging for search  and  rescue ans well as assisting local laws enforcement and rescue crews.

Approval of exemptions a llowin g commercial operations for sUASs in or industry enhances safety while  reducing risk. Manned aircraft filming and surveying creates  a greater risk  because the crafts are much larger,  have combustible fuel, and carry  and on board  human  pilot. In contrast, a sUAS weighing fewer  than 45 pounds and powered  by batteries eliminates virtually all of that  risk given. The sUAS will carry no passengers or crew and, therefore, will not expose  them to the risks associated with manned aircrafts flights.

The operation of sUAS, weighting  less  than  5  pounds,  conducted  in the strict conditions  outlined above, will provide an equivalent level of safety supportin g the grant  of the exemptions requested herein,  including exempting the application from  the

requ irements of Part 21 and allowing  commercial operations. These  lightweight  aircraft operate at slow  speeds, close to  the ground,  and  in a sterile environment. As a result,  they

are far safer  than conventional operations conducted with turbine helicopters operating