Salvatore Bonaccorso 

1241 Salerno Court 

League City, Texas 77573 

(321) 446‐0055 

December 14th, 2015

U.S. Department of Transportation

Federal  Aviation  Administration

800  Independence Ave., SW 

Washington, DC 20591

Dear Sir or  Madam:

Attached please find Salvatore Bonaccorso’s request for  an exemption from 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, 

along  with the monitoring of secured and  controlled environments. This  exemption 

request is for  the  use of Da‐Jiang Innovations (DJI) UASs, a China based  company.

I am a Student Pilot with over 45 Hours of logged flying experience of Private Aircraft.  I have a 

Class III Medical clearance and also am pursuing my Private Pilot License.  In addition to this 

request for exemption, I will also adhere to the Drone Registration Requirements beginning on 

December 21st, 2015. 

Also attached to  this  letter is both  UAS Flight Manuals  ("Manual"),  which  outlines the 

operation  requirements, limitations, and technical specifications for my DJI systems.

Salvatore Bonaccorso (myself) has  reviewed these manuals and has found it to  be 

acceptable for sUAS operations on my  projects sights and  film sets.

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

questions. 

Regards, 

Sal Bonaccorso
December 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, hereby  applies  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 commercial productions, aerial imaging for commercial  and residential real estate  

use, aerial imaging for safety  and  monitoring  of secured and  controlled  environments, 

aerial imaging for search and rescue  as well as assisting any law enforcement and rescue 

crews, so long as such operations are  conducted  within and  under the conditions outlined 

herein  or as may established by the FAA as  required  by Section  333.

As detailed in this document and  the attached Flight Manual, the requested 

exemption  would  permit  the operations sUAS under  controlled  conditions  in airspace that 

is 1)  limited  2) predetermined 3)  controlled as  to access and  4) would provide  safety 

enhancements to the already  best  practices safety protocols  followed by  Salvatore 

Bonaccorso at  each and  every film set  or  job location. 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:

Salvatore Bonaccorso

PH: 321‐446‐0055

Email: sal.bonaccorso@gmail.com

Address: 1241 Salerno Court, League City, Texas 77573
Regulations 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 §40101of 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 airports
Salvatore Bonaccorso’s sUAS is a multi‐rotor vehicle weighing 3‐pounds, including  its 

fixed high‐performance camera  (DJI  Phantom  3 Professional). 

It operates under  normal  conditions at a speed  of no more than 30  knots, with  the capability  to 

hover, move on a vertical  and  horizontal plane simultaneously. The sUAS will operate only in the 

pilots visual line of site  at all times  and will operate only within  the sterile  area  described  in the all 

DJI manuals, attached as Exhibit 1(hereinafter "the  Manuals"). Such Operations will insure  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 restricted and sterile environment 

within  which  it will operate,  my  application falls squarely within the zone of safety  (an 

equivalent  level of safety)  in which Congress envisioned.  Also due to the small size of the sUAS 

and  the low altitudes  and restricted areas  in which my sUAS will operate,  approval  of the 

applications 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, 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 exemption application is expressly  submitted to fulfill Congress' goal in passing Section 

333  (a)  through (c) of the Reform Act.Thislaw directs 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 

will fulfill Congress's  intent  of allowing UAS to operate with significant safety  precautions 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 minutes.

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 all 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  loses 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  21Subpart 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 air

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 sUASoperated 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  exclusively within  a secured area. Like other civil aircraft, operations 

under this  exemption will  be tightly controlled and  monitored 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 apply 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, lack 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 regulation requires certain  experimental, provisionally  certificated aircraft,  or 

light‐sport category  aircraft  to  be marked  with letters between  2 inches and  6 inches 

high "limited," "restricted," "light‐sport,""experimental," or "provisional,"  near  each 

entrance to a cabin  cockpit  or  pilot station.

Even though  the sUAS will have  no airworthiness 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 a sUAS, two  2‐inch letters 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 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 sUAS as "Experimental".  The  FAA has issued  the 

following exemptions to  this regulation: Exemptions  Nos.10700,8738,

10167, and 10167A.

14 C.F.R.61.113 (a) & (b): Private pilot privilegesand 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 achieve the 

equivalent  level of safety  operations 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 level of risk 

associated  with  commercial  operations contemplated by Part 61 when  drafted,  that 

allowing  operations of the sUAS as requested with  a pilot who has  met 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,10602,32827, and 

10700.

14  C.F.R.91.103: Preflight Action

This  regulation  requires each  pilot in command  to take certain  actions  before flight 

to 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  landing 

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 hasfully 

functioning  dual  controls.
By design, sUASs and  remotely  piloted aircrafts do not  have fully functional dual 

controls.  Flight control  is accomplished  through  the  use of a control  box that communicates 

with  the aircraft  via radio communications.The  FAA has previously approved  exemptions 

for aircraft  without  fully functional  dual  controls.  See Exemptions  Nos. 5778K & 9862A. The 

equivalent level 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

Section  91.119  establishes safe altitudes for operation of civil aircraft.  Section

91.119  (b) allows  helicopters to be operated at less 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 security  parameter,

where  buildings and  people  will not  be exposed  to 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. Compared  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 aircrafts  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 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 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  launch 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) 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  10673 (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  less than  30 minutes or  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 sUAS. Additionally, limiting sUAS flight to 10 minutes  would  greatly 

reduce  the  utility for which  the exemption will be granted.

An equivalent level of safety  can be achieved  by limiting  flights to 30 minutes, or 

enough  battery reserve to ensure that  the sUAS lands  at  the grounding  station

with at least  20%  of battery  power  (as determined by the on board  monitoring

system  and the  pilot)., whichever happens  first. This restriction would  be more than 

adequate 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, 9797A,

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 with

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 in
working  order  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 level of safety.

•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••

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, aerial imaging for commercial 

and  residential  real estate  use, aerial  imaging for safty and  monitoring of secured  and 

controlled  environments,aerial imaging for search  and  rescue  ans well as assisting local 

laws enforcement and  rescue  crews.

Approval  of exemptions allowing 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 supporting the grant  of 

the exemptions requested herein,  including  exempting the application  from  the 

requirements 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