,, 

December 31, 2015 

U.S. Department of Transportation 

Docket Operations 

West Bldg Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Zilll ~~:_;,! lll P J l~O 

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

Federal Aviation Regulations 

Dear 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, Wright Bros [unmanned aerial systems], seeks 

an exemption from the Federal Aviation Regulations ("FARs") listed below to allow 

commercial operation of its sUAS' 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. 

The requested exemption would permit commercial operation of Wright Bros 

[unmanned aerial systems, a multi rotor aircraft, weighing less than 55 lbs. 

including cargo. The applications for this sUAS device would consist of still 

photographs and/or video taken by an onboard camera and associated data 

processing functions and used for aerial videography and photography for weddings 

and special events, real estate, filmmaking and aerial inspections on construction 

sites of difficult to reach equipment or structures. Use of the sUAS for these 

purposes reduces the need to operate conventional aircraft or other equipment for 

the same purpose and provides very high quality imagery at a fraction of the cost of 

surveys and inspections using conventional means. Likewise, inspections of 

structures can be safely performed without endangering the inspector or inhibiting 

local industrial or public operations with ladders, lifts or other equipment. These 

savings result in enhanced safety. efficiency and productivity for the affected 

activities, as well as environmental benefits and potential savings in both cost and 

hazards to the public. 

The name and address of the applicant is: 

Steven L. Wright (Ref: A&P Certificate Number 3729542) 

DBA: Wright Bros [Unmanned Aerial Videography] hereinafter called Wright Bros. 

26920 15th Ave NE 

Arlington, WA 98223 

Phone: (424) 231-6908 

Email: stevewright720@gmail.com 
U.S. Department of Transportation 

Docket Operations 

West Bldg Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Page 2 

Regulations from which the exemption is requested: 

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

14 C.F.R. 45.23(b) 14 C.F.R. 409 (a) (2) 

14 C.F.R. 61.113 (a) & (b) 14 C.F.R. 407 (a) (1) 

14 C.F.R. 91.7 (a) 14 C.F.R. 91.405 (a) 

14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.203 (a) & (b) 

14 C.F.R. 91.103 14 C.F.R. 91.151 (a) 

14 C.F.R. 91.109 14 C.F.R. 91.121 

14 C.F.R. 91.119 

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

determination, the Secretary is required to determine which types of sUAS' 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 sUAS' size, weight, speed, and operational capability; 

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

• Operation of the sUAS within visual line of sight of the operator. 

Reform Act 333 (a) 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." 

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 sUAS', from the 

requirement that all civil aircraft must have a current airworthiness certificate. 

Wright Bros. understands this provision to place the duty on the Administrator to 

not only process applications for exemption under section 333, but for the 

Administrator to craft conditions for the safe operation of the sUAS, if it should be 

determined that the condition set forth herein do not fulfill the statutory 

requirements for approval. 
U.S. Department of Transportation 

Docket Operations 

West Bldg Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Page 3 

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). 

Wright Bros. will use a multiblade rotorcraft built by myself (Ref: A&P Certificate 

Number 3729542) weighing less than 55 lbs. including payload. It operates under 

normal conditions at a speed of no more than 30 knots and has the capability to 

hover, and move in the vertical and horizontal plane simultaneously. It will operate 

only in line of sight (LOS) of the pilot and will operate only within the project area. 

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

national airspace system or the public. 

Given the small size of the sUAS involved and the restricted environment withiri 

which it will operate, Wright Bros. falls squarely within that zone of SAFETY (an 

equivalent level of SAFETK) in which Congress envisioned the FAA must, by 

exemption, allow commercial operations of sUAS to commence immediately. Also 

due to the size of the sUAS and the restricted areas in which the relevant sUAS 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 sUAS for event and inspection operations the 

grant of the requested exemptions is in the public interest. Accordingly, Wright 

Bros. respectfully requests that the FAA grant the requested exemption without 

delay. 

Aircraft and equivalent Level of SAFETY 

Wright Bros. proposes 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 photography and surveying 

operations conducted with conventional aircraft. 
U.S. Department of Transportation 

Docket Operations 

West Bldg Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Page4 

These limitations and conditions to which the Wright Bros. agree 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 pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 20 minutes. 

Flights will be terminated at 25% battery power reserve should that occur 

prior to the 20 minute limit. 

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

5. Minimum crew for each operation will consist of the sUAS Pilot and a Visual 

Observer. 

6. sUAS Pilot will be a skilled sUAS operator experienced in the type of UAS 

flown. 

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other 

than the sUAS Pilot, who possess the necessary PIC qualifications, is also 

present that person can also be designated as PIC. 

8. The sUAS will only operate within a confined Project Area. 

9. A briefing will be conducted in regard to the planned sUAS operations prior 

to aerial activities. All personnel who will be performing duties within the 

boundaries of the SAFETY perimeter will be made aware of the sUAS 

flight(s). 

10. The operator will obtain the consent of all persons involved in the project 

and ensure that only consenting persons will be allowed within 100 feet of 

the flight operation. 

11. Pilot and observer will have been trained in operation of sUAS generally and 

received up-to-date information on the particular sUAS to be operated. 

12. Observer and pilot will at all times be able to communicate by voice andjor 

visuals. 

13. Written and/or oral permission from the relevant property holders will be 

obtained. 

14. All required permissions and permits to be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies. 

15. If the sUAS loses communications or loses its GPS signal, the sUAS will have 

capability to return to a pre-determined location within the Security 

Perimeter and land. 

16. The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies 
U.S. Department of Transportation 

Docket Operations 

West Bldg Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Page 5 

Description of Specific Regulations: 

14 CFR 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 Wright Bros., 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 (0) 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 SUAS. 

Our small sUAS will be operated at low speed in a controlled environment at least 

five miles from an airport. 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 helicopter) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

The sUAS to be operated hereunder is less that 55 lbs. fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials 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, and under the requirements and in 

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

of operation as is currently done on active construction sites. The FAA will have 

advance notice of all operations. 

These SAFETY enhancements, which already apply to civil aircraft operated in 

connection with construction sites, 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, 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 ability to carry an external load 

no greater than two lbs. 
U.S. Department of Transportation 

Docket Operations 

West Bldg Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Page 6 

14 C.F.R. 45.23(b): Marking ofthe 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 the sUAS, two-inch 

lettering will be impossible. The word "Experimental" will be placed on the fuselage 

in compliance with 45.29 (t). The equivalent level of SAFETY will be provided by 

having the sUAS marked on its fuselage as required by 45.29 (t) 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. 107, 8738, 10167 and 10167 A. 

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in 

Command 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 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 and restricted, and all flights are planned and coordinated in advance. 

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 is an 

experienced sUAS operator 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 checklists performed 

by myself an A&P licensed mechanic, Ref: Certificate Number 3729542 prior to each 

flight, an equivalent level of SAFETY will be provided. 
U.S. Department of Transportation 

Docket Operations 

West Bldg Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Page 7 

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

requirements 

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 keeping the flight manual at the 

ground control point where the pilot flying the sUAS will have immediate access to 

it. 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 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 in the Preflight Checklist, in the sUAS 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 instruction unless that aircraft has 

fully functioning dual controls. By design, sUAS and remotely piloted aircraft 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 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, the ability to control the sUAS via radio signals from the controller, and by 

the size and speed of the aircraft. 
U.S. Department of Transportation 

Docket Operations 

West Bldg Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Page 8 

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. This exemption is for a multirotor craft that 

flies similarly to a helicopter, with vertical take off and vertical landing, which will 

typically operate at altitudes of 200 AGL an exemption may be needed to allow such 

operations. The sUAS will never operate at an altitude higher than 400 AGL and will 

be in a restricted area, 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 and speed of the sUAS as well as the location where 

it is operated. No flight will be taken without the permission of the property owner 

and any onsite personnel all affected individuals will be aware of the planned flight 

operations. Compared to flight operations with aircraft or rotorcraft weighing far 

more than the maximum 55 lbs. proposed herein and carrying flammable fuel, any 

risk associated with our operations is far less than those presently presented with 

helicopters and other conventional aircraft operation at or below 500 AGL in the 

industry. In addition, the low-altitude operations of the sUAS will ensure separation 

between these small sUAS operations and the 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 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 

operator, pursuant to the sUAS Manual and SAFETY Checklist, 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 sUAS is limited to operations in sterile and controlled environments 

and has a limited range and flight time which require an exemption from 14 CFR 

91.151(a). 
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U.S. Department of Transportation 

Docket Operations 

West Bldg Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Page 9 

The battery powering the sUAS provides approximately 20 minutes of powered 

flight. This does not meet the 30 minute reserve requirement in 14 CFR 91.151. 

Wright Bros. 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 

small sUAS, in a tightly controlled area where only people and property owners or 

official representatives who have signed waivers will be allowed, with less that 30 

minutes of reserve fuel, does not engender the type of risks that Section 91.252 (a) 

was intended to alleviate given the size and speed of the small sUAS. An equivalent 

level of SAFETY can be achieved by limiting flight to 15 minutes, or enough battery 

reserve to ensure that the sUAS lands at the ground station with at least 20% of 

battery power (as determined by the onboard 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 operation 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 weighs no more than 55 lbs and is operated without an 

onboard 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 flying 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 other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797 A, 9816A 

and 10700. 
;J ' \ • 

U.S. Department of Transportation 

Docket Operations 

West Bldg Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Page 10 

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 these sections and Part 43 

apply only to aircraft with an airworthiness certificate these sections will not apply 

to Wright Bros. Maintenance will be accomplished by the operator pursuant to the 

flight manual and operating handbook. An equivalent level of SAFETY will be 

achieved because these small sUAS' are very limited in size and will carry a small 

payload and operate only in restricted areas for limited periods. If mechanical 

issues arise the sUAS can land immediately and will be in operation no higher than 

400 feet AGL. 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, (Ref: A&P Certificate Number 3729542). 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, [rule making] the following summary is provided for 

publication in the Federal Register, should it be determined that publication is 

needed: 

Wright Bros. seeks an exemption from the following rules: 14 C.F.R. 21, subpart H; 

[airworthiness certificates] 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)(1); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small 

unmanned vehicle (55 lbs or less) in construction, inspection and events. 

Approval of exemptions allowing commercial operations of sUAS in the 

construction, surveying, special event or inspection industry enhances SAFETY 

while reducing risk. Manned aircraft monitoring and surveying creates a greater 

risk because the craft are much larger, have combustible fuel and carry an onboard 

pilot. In contrast, a sUAS will carry no passengers, crew or combustible fuel and; 

therefore, will not expose them to the risks associated with manned aircraft flights. 
U.S. Department of Transportation 

Docket Operations 

West Bldg Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Page 11 

The operation of small sUAS, weighting less than 55 lbs, conducted in the strict 

conditions outlined above, will provide an equivalent level of SAFETY supporting 

the grant of the exemptions requested herein, including exempting Wright Bros. 

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 and as a result, are far safer than conventional operations conducted 

with helicopters operating in close proximity to the ground and people. 

Privacy 

All flights will occur over private or controlled access property with the property 

owner's prior consent and knowledge. Images taken will be of individuals who have 

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

aerial photography will take place. 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 Wright Bros. sUAS' in 

special event, construction and inspection industry pursuant to the sUAS Manual. 

Specific Examples of Potential sUAS use by Wright Bros: 

Wright Bros. [Unmanned Aeral Videography} is currently in the process of building 

a custom commercial airframe using OPEN source electronics including Alt Hold and 

GPS functions to deploy if/when permission is granted. Construction of a similar yet 

more advanced model to be introduced at a later date. Use of this tool would allow 

Wright Bros. to: 

• Inspect existing inaccessible or difficult to access structures such as wind 

turbine towers, sides of bridges, industrial rooftops, and smoke stacks. This 

would save time and money and public inconveniences by negating the need 

to mobilize large lift equipment or close roads during bridge or public 

building inspections. 

• Enhanced public awareness. Wright Bros. use of aerial videography and still 

photography for special events and the real estate market will enable the 

client and those in attendance to better understand the proper and safe use 

ofthe sUAS venue as proposed by the FAA. 

Sincerely Steven L. Wright 

A&P Certificate Number 3729542 

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