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Gregory	Dirk	Sichel

FAA Document # FAA-2015-0398-0001

FAA Exemption Rulemaking 

Section 333 of the FAA Reform Act 

and Part 11 

FAA Document # FAA-2015-0398-0001

This is amended to reflect the addition of additional 

aircraft being the DJI Phantom 2, DJI Phantom 3,

DJI S-900, DJI S-1000, 3D Robotics Iris, Solo, X8, Aero-M

and SenseFly eBee.

Prepared by 

Gregory Dirk Sichel Private Pilot

Filed February 18, 2015 and amended April 23, 2015.

3900 County Line Road

Suite 4A

Tequesta, Florida 33469

512-430-2227/ dirksichel@gmail.com
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Gregory	Dirk	Sichel

FAA Document # FAA-2015-0398-0001

Attention: United States Secretary of Transportation Mr. 

Anthony R. Foxx1200 New Jersey Ave., SEWashington, 

DC 20590 

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

Federal Aviation Regulations from 14 CFR 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); 91.409 (a) (2); 91.417 (a) & (b) 

Dear Mr. Secretary, 

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

Reform Act) and 14 CFR Part 11, Gregory Dirk Sichel, private pilot, and operator 

of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial 

photography for the education of real estate professionals and real estate 

marketing purposes, general aerial photography and videography, 3d mapping 

and surveying, agricultural surveying, inspections, training and data gathering

and 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.

These operations as requested do not include closed cinematography, 

television production or lift and delivery systems.

As described more fully below, the requested exemption would permit the 

operation of small, unmanned and relatively inexpensive sUAS under controlled 

conditions in airspace that is 1) limited 2) predetermined and 3) controlled as to 

access. Approval of this exemption would thereby fulfill the Secretary of 

Transportation’s (the responsibilities to “...establish requirements for the safe 

operation of such aircraft systems in the national airspace system.” Section 333 

(c) of the Reform Act.

Sincerely;

Gregory Dirk Sichel

Gregory Dirk Sichel

3900 County Line Road, Suite 4A

Tequesta, Florida 33469
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Gregory	Dirk	Sichel

FAA Document # FAA-2015-0398-0001

The name and address of the applicant is: 

Gregory Dirk Sichel

3900 County Line Road, Suite 4A

Tequesta, Florida 33469

Private Pilot FAA 3575382

512-430-2227

dirksichel@gmail.com

Regulations from which the exemption is requested: 

14 CFR Part 21

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a)

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 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 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; 

and 

Operation of the UAS within Visual Line of Sight (VLOS) of the Pilot and 

Observers. Reform Act §333 (a). Lastly, if the Secretary determines that 
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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. §333 (c) (emphasis added). 

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. §44704; 14 CFR §91.203 

(a) (1). 

Gregory Dirk Sichel’s UAS(s) are small rotorcraft aircraft, weighing less than10

lbs. including sensor payload. They operate their rotorcraft, under normal 

conditions at a speed of no more than 20 knots, usually 3-5 knots, and have the 

capability to hover, and move in the vertical and horizontal plane simultaneously. 

They will manually operate only in Visual Line of Sight.

Aircraft included: DJI Inspire 1, DJI Phantom 2, DJI Phantom 3, DJI S-900, 

DJI S-1000, 3D Robotics X8, Iris, Solo, and Aero-M SenseFly eBee.

Adherence to the Operating Manual will insure that the sUAS will “not create a 

hazard to the national airspace system or the public.”

Given the small size and weight of the sUAS involved and the restricted sterile 

environment within which they will operate, the applicant falls squarely within that 

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 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 significant 

public benefit, including enhanced safety, reduction in environmental impact, 

including reduced emissions associated with allowing UASs for educational and 

marketing operations, (as opposed to full scale aircraft), the granting of the 

requested exemptions is in the public interest. Accordingly, the applicant 

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

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

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 possibly higher level of 
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safety to operations under the current regulator structure because the proposed 

operations represent a safety enhancement to the already safe filming operations 

conducted with conventional aircraft. These limitations and condition to which 

Gregory Dirk Sichel agrees to be bound when conducting commercial operations 

under an FAA issued exemption include: 

1. The sUAS will weigh less than 10 lbs. 

2. Flights will be operated manually within visual line of sight (VLOS) of the Pilot and aircrew 

(Spotter / 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, though most 

operations will be conducted within 50 feet of the ground

5. Minimum two (2) man crew for each sUAS operation will consist of the Pilot and Spotter / 

Observer. In most cases the third aircrew member will serve as the Safety Officer. 

6. The sUAS Pilot will be an FAA licensed airman with at least a private pilot’s certificate 

and third class medical and valid driver’s license.

7. The sUAS Pilot will serve as Pilot in Command (PIC). If a pilot certificate holder, other 

than the sUAS Pilot, possesses the necessary PIC qualifications and is also present, that 

person can also be designated as PIC.

8. Additionally, the sUAS will only operate under 400ft AGL, and outside a 5 statute mile 

radius of any airport. The sUAS will never enter any MOA or Restricted Airspace, nor 

shall it violate any TFR as outlined by the FAA.

9. A pre-flight briefing will be conducted in regard to the planned sUAS operation prior to 

each day’s flying / recording activities. It will be mandatory that all personnel who will be 

performing duties as “flight crew” be present for this briefing. 

10. The Operator will obtain the consent of all persons involved in the filming and ensure that 

only consenting persons will be allowed within 100 feet of the flight operation, and this 

radius may be reduced to 30 feet based upon an equivalent level of safety determination. 

11. Pilot and Spotter (Observer) will have been trained in operation of sUAS generally and 

received up-to-date information on the particular sUAS to be operated as required. 
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12. Spotter (Observer) and Pilot will at all times be able to communicate by voice or radio.

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

14. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to 

return to a pre-determined location and land. 

15. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

A. The sUAS Pilot in Command (PIC) shall possess at a minimum, a private pilot certificate 

and current third-class medical certificate. 

i. The PIC shall also meet the flight review requirements specified in 14 CFR §61.56 

in an aircraft in which the PIC is rated on their pilot certificate. 

ii. The PIC shall be trained in the operation of the specific make and model of the 

sUAS being piloted and successfully completed all training required. 

iii. The PIC shall have accumulated and logged, in a manner consistent with 14 CFR 

§61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a sUAS rotorcraft 

pilot and at least five hours logged as a sUAS pilot with a similar sUAS type (multirotor or 

helicopter). Prior documented flight experience that was obtained in compliance with 

applicable regulations may satisfy this requirement. 

iv. The PIC shall have accumulated and logged, in a manner consistent with 14 CFR 

§61.51 (b), a minimum of five hours as sUAS pilot operating the make and model of sUAS to 

be utilized for operations under the exemption and three take-offs and three landings in the 

preceding 90 days. 

v. Training, proficiency, and experience-building flights can also be conducted under 

this grant of exemption to accomplish the required flight cycles and flight time. 

1. During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered non-participants, and the PIC 

must operate the sUAS with appropriate distance from non-participants in 

accordance with 14 CFR §91.119. 

B. The sUAS Safety Observer (SO) shall meet all training requirements and be responsible 

for all of his/her duties as set forth by sUAS Operating Manual. 

C. The PIC and SO will be designated before each flight 

i. Minimum crew for each flight operation will consist of the sUAS PIC and SO. 
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D. The PIC and SO shall always be within visual line of sight (VLOS) of each other and in 

direct verbal communication at all times. 

E. Safety Briefings shall be conducted before each day’s activities to include, but not limited 

to: 

i. Designated roles of PIC and SO 

ii. Risk Management and Mitigation 

F. Liability Insurance

General Liability Insurance shall be maintained.

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §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 capability, and proximity to airports and populated areas of 

the particular UAS. In all cases, an analysis of these criteria demonstrates that 

the UAS 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 rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

The sUAS to be operated hereunder is less than 10 lbs. fully loaded, carries 

neither a pilot nor passenger, carries no explosive materials nor flammable liquid 

fuels, and operates exclusively within a limited radius area as set out in the pre 

flight briefing / VLOS operations. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the Operator, pursuant 

to safety 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 aircraft. These safety enhancements, which already apply 

to civil aircraft operated in connection with video production, 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 UAS, due to its size, speed of 

operation, location of operation, lack of explosive materials or flammable liquid 
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fuels, and inability to carry a substantial external load. 

14 CFR §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 UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS 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, twoinch 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 Pilot, Spotter (Observer) and others 

working with the sUAV will see the identification of the UAS as “Experimental.” 

The FAA has issued the following exemptions to this regulation to Exemptions 

Nos. 10700, 8738, 10167 and 10167A. 

14 CFR §61.113 (a) & (b): Private Pilot Privileges and Limitations - Pilot in Command 

(PIC) 

Sections 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 small UAS. 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 as set forth in the

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

the Operating Manual meets that provided by single individual holding a 

commercial pilot’s certificate operating a conventional aircraft. The risks 

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 CFR §61.113 (a) & (b). 

14 CFR §91.7 (a): Civil Aircraft Airworthiness 

The regulation requires that no person may operate a civil aircraft unless it is in 
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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 Operating Manual for maintenance and use of safety checks 

prior to each flight, as set forth in the Operating Manual, an equivalent level of 

safety will be provided. 

14 CFR §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 there 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 keeping the Operating 

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 CFR §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. An equivalent level 

of safety will be provided as set forth in the Operating Manual. The PIC will take 

all actions including reviewing weather, flight battery requirements, landing and 

takeoff distances and aircraft performance data before initiation of flight. 

14 CFR §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 a control box 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 
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experimental aircraft. See Exemptions Nos. 5778K & 9862A. The equivalent level 

of safety provided by the fact that aircraft will be piloted by a certified private pilot 

who has previously trained in remote flight areas before attempting flight within 

filming distance of structures.

14 CFR §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, Gregory Dirk Sichel requests authority to operate at altitudes up to 400 ft. 

AGL; an exemption may be needed to allow such operations. As set forth herein, 

the UAS will never operate at higher than 400 ft. AGL. It will however be 

operated in a controlled 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, speed of 

the UAS as well as location where it is operated. No flight will be taken without 

the permission of the property owner. Because of the advance notice to the 

property owner and participants in the photographic activity, all affected 

individuals will be aware of the planned flight operations as set forth in the 

Operating Manual. Compared to flight operations with aircraft or rotorcraft 

weighing far more than the maximum 10 lbs. 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 500 ft. AGL. 

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

between these small UAS operations and the operations of conventional aircraft 

that must comply with Section 91.119. 

14 CFR §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 will 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 Operating Manual and Safety Check list, confirming 

the altitude of the launch site shown on the GPS altitude indicator before flight. 

14 CFR §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 
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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 approximately 20 minutes of powered

flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS 

flights would be impossible. Given the limitations on the UAS’s proposed flight 

area and the location of its proposed operations within a predetermined area, a 

longer time frame for flight in daylight or night 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 

small UAS, 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 reserved 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 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 20 minutes or 25% of battery power whichever happens first. This 

restriction would be more than adequate 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 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent 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 (b) 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 UAS fully loaded weighs no more than 10 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 
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ground control point where the Pilot flying the sUAS will have immediate access 

to them, to the extent they are applicable to the sUAS, and should they be 

issued. 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 CFR §91.405 (a); 407 (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 section and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the applicant. Maintenance will be 

accomplished by the operator; pursuant to the Operating manual. An equivalent 

level of safety will be achieved because these small UASs are very limited in size 

and will carry a small payload and operate only in restricted areas for limited 

periods of time. If mechanical issues arise the UAS can land immediately and will 

be operating from no higher than 400 ft. AGL. As provided in the Operating 

Manual, the PIC (operator) will ensure that the UAS is in working order prior to 

initiating flight, and perform required maintenance. 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 CFR 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 CFR § 21, subpart H; 

14 CFR § 45.23 (b); 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) and 91.417 (a) & (b) to operate commercially a small unmanned 

vehicle (5lbs or less) in Educational and Marketing operations. 

Privacy 

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

owner’s prior consent and knowledge, or over remote public land. Image capture 

of people will rarely take place, but in the event they are, they will have 

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

data collection will take place. 

Airborne Image Capture
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With regard to airborne filming, Gregory Dirk Sichel adheres to all FAA 

regulations. Further Gregory Dirk Sichel airborne teams operate under the 

principals of: Safety First, Quality Assurance, Accountability, Reporting, and 

Training. When approved by the FAA it is Gregory Dirk Sichel’s mandate to treat 

all sUAS operations the exact same level of professionalism and seriousness as 

that of conventional aircraft. 

Approval of exemptions allowing commercial operations of sUASs will enhance 

safety by reducing risk. Conventional filming operations, using turbine or piston 

powered aircraft present the risks associated with vehicles that weigh in the 

neighborhood of 2,000lbs.+, carrying large amounts of Jet A or 100LL (90 gallons 

for the aircraft primarily used by Gregory Dirk Sichel). Such aircraft must fly to 

and from photographing location. In contrast, a sUAS weighing fewer than 10lbs 

and powered by batteries eliminates virtually all of the risk given the substantial 

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

typically transported to the location via auto or cargo van in a medium sized case 

and is never flown to set. The sUAS will carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned aircraft 

The operation of small UASs, weighting less than 10lbs., 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 applicant 

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 ground than conventional 

operations conducted with piston helicopters or fixed wing aircraft operating in 

relatively close proximity to the ground and people. 

The primary market of interest for Gregory Dirk Sichel utilizing sUASs is the 

marketing of real property, general aerial photography and videography, 

agricultural surveying, 3D mapping, inspections, training and data gathering.

These operations as requested do not include cinematography, television 

production or lift and delivery systems.

It is anticipated that the airborne image capture process will be accomplished 

exclusively in day time VFR environments. To capture the highest quality of 

resolution the majority of airborne data collections will take place during the 

07:00am – 07:00pm (19:00) window.

Public Safety and Reason to grant exemption

Many un-authorized commercial UAV operations are taking place. My goal is to 

operate safely and legally to provide these services to the public and adhere to 

FAA regulations.
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Summary

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 sUAS. Gregory Dirk Sichel is 

eagerly standing by to support the FAA and sUAS community in its quest to 

establish proper regulations and protocols for the safe introduction of unmanned 

aircraft into the national airspace. 

Sincerely, 

Gregory Dirk Sichel

Gregory Dirk Sichel

3900 County Line Road

Suite 4A

Tequesta, Florida 33469

512-430-2227