August 11, 2015

Exemption No. 12418

Regulatory Docket No. FAA–2015–2201

Mr. William J. Sadler

Alaska Aerial Productions

381 Senior Court # 106

Kenai, AK 99611

Dear Mr. Sadler:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated May 21, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Alaska Aerial Productions (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

videography and cinematography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 
2

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Alaska Aerial Productions is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Alaska Aerial Productions is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 
4

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 
5

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 
6

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
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29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

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

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

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

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

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

May 21, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of 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; 119.121; 91.151(a);

91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

I, William J. Sadler, am writing pursuant to the FAA Modernization and 

Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to 

request that I, William J. Sadler holder of both a Commercial Pilots (# 

1781355) and Mechanic (# 2021362) Certificates utilizing my acquired 

skills and knowledge in the proper operation of my UAS’s and the owner 

and operator of small unmanned aircraft (“N” number is being applied for 

and reservation number of N99611 requested), be exempted from the 

Federal Aviation Regulations (“FARs”) listed below so that I, William J. 

Sadler, may operate my small ultra light weight unmanned aircraft system 

(“UAS”) commercially in airspace regulated by the Federal Aviation 

Administration (“FAA”). As described herein I, William J. Sadler, have 

added a professional grade quad-copter UAS Inspire 1 to my inventory 

equipped with a DJI Zenmuse H3 camera with intent for aerial 

videography/cinematography to enhance and promote Alaska Tourism for 

those individuals and companies unfamiliar with the geographical layout of 

Alaska and pursue implementation of emergency use UAS systems with 

public entities; following exemption and approval by the FAA. This will allow 

for enhancement of the tourism experience for the state of Alaska. I have 

flown small quad copter's for over two years without incident. I am 

committed to safety with each and every flight. My, William J Sadler 

exemption request would permit operations of ultralight weight, unmanned 

(piloted by remote 
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

control) and comparatively inexpensive UASs in tightly controlled and 

limited airspace, predetermined in areas away from general public, airports, 

heliports and motor vehicle traffic for community videos and within property 

boundaries for individual home or real estate listing videos/photos. 

Currently, similar lightweight remote-controlled you UAS’s are legally 

operated by unmonitored amateur hobbyist with no safety plan or controls 

in place to prevent safety issues. I William J Sadler, have personally 

installed necessary safety protocols, and checklists prior to operation. This 

will act to further safety protocols exclusive to lightweight UAS’s specific to 

real estate and tourism video and photography used as I, William J Sadler, 

record flight data and other information gained through permitted flight 

operations to share with the FAA through any required FAA reports to 

assist with future protocol and safety regulations. I, William J. Sadler hold 

both a Commercial Pilots (# 1781355) and Mechanic (# 2021362) 

Certificates and will utilize my acquired skills and knowledge in the proper 

operation of my UAS’s. Granting my, William J. Sadler, request comports 

with the Secretary of Transportation’s (FAA Administrator’s) responsibilities 

and authority to not only integrate UAS's into the national airspace system, 

but too “...establish requirements for the safe operation of such aircraft 

systems [UAS's] in the national airspace system” under Section 333(c) of 

the Reform Act specific to the use of UAS's for Aerial Surveying and 

Search and Rescue Systems. Further I, William J. Sadler, will conduct my 

operations in compliance with the protocols described herein or as 

otherwise established by the FAA. For the reasons stated below I, William 

J. Sadler, respectfully request the grant of an exemption allowing me to 

operate ultra light weight, remote controlled UAS’s for tourism specifically 

and overall community awareness to benefit and stimulate attraction to 

Alaska and to enhance real estate listing and tourism videos for individuals

and organizations who are unable to afford expensive manned aircraft for 

the same purpose. Both of which will promote local economic growth

through increased employment and increased tax base both with public 

safety in mind by keeping significantly heavier manned aircraft containing 

combustible fuel posing potential public hazard.
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

I. Contact Information:

William J. Sadler - Alaska Aerial Promotions

381 Senior Court # 106 Kenai, Alaska 99611

Mobile: (907)-953-0092

Email: Bluesdown@aol.com

II. The Specific Sections of Title 14 of the Code of Federal

Regulations From Which William J. Sadler’s Requests 

Exemption

are:

14 CFR 21;

14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent of relief William J. Sadler seeks and the 

Reason He Seeks Such Relief:

I, William J. Sadler submit this application in accordance with the Reform 

Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently applicable 

FARs operating to prevent me, William J. Sadler, from commercial aerial 

video and still cinematic, and other flight operations within the national 

airspace system. The Reform Act in Section 332 provides for such 

integration of civil unmanned aircraft systems into our national airspace 

system as it is in the public’s interest to do so. My, William J. Sadler’s, ultra 

light weight UAS meets the definition of “small unmanned aircraft” as 

defined in Section 331 and therefore the integration of my ultra light weight 

UAS is expressly contemplated by the Reform Act. I would like to operate 

my ultra light weight UAS prior to the time period by which the Reform Act 

requires the FAA to promulgate rules governing such craft. Thereby, 

providing direct experience and valuable information for formal regulation 

that can be administered uniformly to all real estate and tourism related 
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

UAS aerial video and photography. The Reform Act guides the Secretary in 

determining the types of UAS's that may operate safely in our national 

airspace system. Considerations include: The weight, size, speed and 

overall capabilities of the UAS's; whether the UAS will be operated near 

airports or heavily populated areas; and, whether the UAS will be operated 

by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflects in favor 

of an exemption for me, William J. Sadler. My UAS utilizes four (4) counterrotating propellers for balance, control and stability. My UAS is equipped 

with GPS and auto return safety technology. Additionally, my UAS weighs 

less than five (5) pounds (far below the maximum 55 pound limit); including 

camera with gimbal.

I, William J, Sadler, consider safety foremost with each flight. My small, 

unmanned aircraft is designed to hover in place via GPS and operate in 

less than a 24 knot (15 mph) wind. For safety, stability and concern of 

financial loss, I will not fly in winds exceeding 16 kph (10 mph). Built-in 

safety systems include a GPS mode that allows my UAS to hover in place 

when radio controls are released. With three modes to choose from, I 

utilize the (GPS) Smart Mode for aerial videography/photography. This is 

the safest, most reliable and stable mode to prevent accident and hazard. 

When pilot communication is lost UAS is designed to slowly descend to the 

point of take off. I do not operate my UAS near airports, hospitals nor 

heliports, and do not operate near areas where general public is within fifty 

to one hundred (50-100) yards depending on location, conditions and 

weather. I am constantly on alert for any manned aircraft (Police/Medical 

helicopters, general and commercial aviation etc.) and prepared to 

land/abort immediately to the nearest and safest ground point should a 

manned aircraft approach my location or I suspect manned aircraft may 

approach near my location. I will call in to local Air Traffic Control to alert of 

my flight plan and operations as well as calling back when operations are 

complete. My UAS is capable of vertical and horizontal operations, and is 

flown only within my line of sight of me, as the remote control pilot utilizing 

battery power rather than combustible fuels, flights generally last between 

twelve (10) to seventeen (17) minutes, with an altitude under two hundred 

(200) feet.
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

I, William J. Sadler, utilize a fully charged smart battery with each flight as a 

safety precaution; full flight time limit for each battery is eighteen (18) to 

twenty (20) minutes as tested. I do not operate my UAS at or below 

manufacture recommend minimum charge levels for operation or exceed 

temperature ratings of 0*F as per manufactures request; preferring to 

remain well within a safe operating range to insure adequate 

communication between radio control and to eliminate potential for crash, 

loss of control or hazard. Reserve batteries are at hand with each exercise 

to insure replacement for sufficient safe level of operation. I do not believe 

in taking risk that may cause a crash that could create hazard to the 

public/property/manned aircraft, and have made a significant investment 

and have no desire to lose that investment. I have performed numerous 

practice flights in remote areas as a hobbyist simulating flights for future 

commercial use to gain familiarization with the characteristics of this 

specific UAS's performance under different temperature and weather 

conditions. I also practice computerized simulated flights to maintain 

adequate skills and response reflex time.

I, William J. Sadler, am very cautious when operating of my UAS/ultra light 

weight unmanned aircraft and will not “create a hazard to users of the 

national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the 

small size and weight of my UAS it falls well within Congress’s 

contemplated safety zone when it promulgated the Reform Act and the 

corresponding directive to integrate UAS's into the national airspace 

system. I, William J. Sadler’s UAS, used in hobby flight, has a 

demonstrable safety record and does not pose any threat to the general 

public or national security. 
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

IV. How William J. Sadler Request Will Benefit the Public As 

A Whole:

Aerial videography for geographical awareness for real estate, recreational 

and tourism marketing has been around for a long time through manned 

fixed wing aircraft and helicopters. For small budget production companies 

and average homeowners, the expense of such aerial videography is cost 

prohibitive. Only large companies and high end film companies can afford 

to absorb such expense. This is where the option of less expensive 

unmanned systems becomes affordable to anyone. Manned aircraft pose a 

threat to the public through potential catastrophic crashes that Alaska has 

come to expect every year. Kenai, Seward, and Homer areas are very busy 

airspaces, which is why I am pursuing a 333 Exemption to be instrumental 

and lead the way for other businesses and or enthusiast. My additional goal 

is to prove to the public that my UAS can be used effectively in fire, police 

or natural disaster relief as well as instructional training enhancement. I 

have made contact with local police and fire agencies, and they are excited 

about the potential value for their organizations.

My, William J. Sadler’s UAS use, poses no threat since size and lack of 

combustible fuel alleviates any potential threat to the public. Congress has 

already proclaimed that it is in the public’s interest to integrate 

commercially flown UAS's into the national airspace system, hence the 

passing of the Reform Act. Granting my, William J. Sadler, exemption 

request furthers the public interest through promotional/visual awareness of 

the geographical benefits primarily in and around the Kenai Peninsula. My 

ultra light weight UAS is battery powered and creates no emissions that 

can harm the environment. The consequence of my ultra light weight UAS 

crashing is far less than a full size helicopter or fixed wing aircraft; which 

are heavy, contain combustible fuel and can cause catastrophic 

devastation to the public. The public’s interest is furthered by minimizing 

ecological and crash threat by permitting aerial video/photo capture through 

my battery operated ultra light weight UAS's. Permitting me, William J. 

Sadler, to immediately fly within national air space furthers economic 
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

growth. Granting my exemption request substantially furthers the economic 

impact for the Alaska communities for companies looking to relocate or 

build in the Kenai Peninsula area as well as individuals looking to relocate 

for career advancement, recreational, and or retirement through 

geographical awareness, all of which serve as a stimulus to the community.

V. Reasons Why William J. Sadler’s Exemption Will Not

Adversely Affect Safety or How The Exemption Will Provide

a Level of Safety At Least Equal To Existing Rule:

My, William J. Sadler’s exemption will not adversely affect safety. Quite the 

contrary, for the reasons stated permitting me, William J. Sadler to log 

more flight time in FAA controlled airspace, with communication with the 

FAA, will allow me to contribute to the innovation and implementation of 

new and novel, as of yet undiscovered safety protocols. I, William J. Sadler, 

submit the following representations of enhancements to current aerial 

videography, photography and aerial surveying aspects:

My UAS weighs less than 5 pounds complete with a small

ultra light weight high quality DJI Zenmuse H3 camera.

I only operate my UAS below 200 feet (well within the 400

foot permissible ceiling set by the FAA Modernization and

Reform Act of 2012.)

My UAS only operates for 12-17 minutes per flight.

I land my UAS prior to manufacturer recommended minimum

level of battery power.

I pilot my UAS through remote control only by line of sight.

My UAS has GPS a flight safety feature whereby it hovers

and then slowly lands if communication with the remote

control pilot is lost.

I actively analyze flight data and other sources of information

to constantly update and enhance safety protocols.
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

I only operate in reasonably safe environment that are

strictly controlled, are away from power lines, towers, elevated lights,

airports and actively populated areas.

I conduct extensive pre-flight inspections and protocol,

during which safety carries primary importance.

I always obtain all necessary permissions prior to operation.

I have procedures in place to abort flights in the event of

safety breaches or potential danger.

My, William J. Sadler’s , safety protocols provide a level of safety equal to 

or exceeding existing rules. It is important to note that absent the 

integration of commercial UAS into our national airspace system, 

helicopters are the primary means of aerial video and photography for 

community awareness, surveys, tourism and real estate. While the safety 

record of such helicopters is remarkable; it is far safer to operate a battery 

powered ultra light weight UAS.

First, the potential loss of life is diminished because UAS's

carry no people on board and I only operates my UAS in

specific areas away from mass populations.

Second, there is no fuel on board a UAS and thus the

potential for fire or explosions is greatly diminished.

Third, the small size and extreme maneuverability of my

UAS allow me to remotely pilot away from and avoid hazards

quickly and safely.

Lastly, given its small size and weight, even when close

enough to capture amazing images, my UAS need not be so

close to the objects they are focused on through the

technology and use of post editing software allowing pan

and zoom.

Accordingly, my UAS has been experimentally operated for 

familiarization/competency and will continue to operate at and above 

current safety levels.
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates,

Manuals and the Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness 

Certificates, sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight 

and enclosed operational area of my, William J. Sadler’s, UAS permits 

exemption from Part 21 because my UAS meets (and exceeds) an 

equivalent level of safety pursuant to Section 333 of the Reform Act. The 

FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of 

the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's 

from the airworthiness certificate requirement in consideration of the 

weight, size, speed, maneuverability and proximity to areas such as 

airports and dense populations. My, William J. Sadler’s, current and 

projected UAS's meet or exceed each of the elements. 14 C.F.R. 91.7(a) 

prohibits the operation of an aircraft without an airworthiness certificate. As 

no such certificate will be applicable in the form contemplated by the FARs, 

this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft 

flight manual in the aircraft. As there are no on board pilots or passengers, 

and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a safety/flight 

manual delineating areas of where safety can be defined. The FAA has 

previously issued exemptions to this regulation in Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 

32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable 

insofar as my UAS utilizes electronic global positioning systems with a 

barometric sensor. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying 

of civil aircraft certifications and registrations. They are inapplicable for the 

same reasons described above. The equivalent level of safety will be 

achieved by maintaining any such required certifications and registrations 

by me, William J. Sadler.
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

B. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. I, William J. Sadler, can achieve an equivalent level 

of safety as achieved by current Regulations because my UAS does not 

carry any pilots or passengers. Further, while helpful, a pilot license will not 

ensure remote control piloting skills although I do hold a Commercial pilot’s 

license. The risks attended to the operation of my UAS is far less than the 

risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, 

et seq. Thus, allowing me, William J. Sadler, to operate my UAS meet and 

exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

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

prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. My UAS 

will never operate at an altitude greater than 200 AGL; safely below the 

standard of 400 AGL. I, William J. Sadler, will however operate my UAS in 

safe areas away from public and traffic, providing a level of safety at least 

equivalent to or below those in relation to minimum safe altitudes. Given 

the size, weight, maneuverability and speed of my UAS, an equivalent or 

higher level of safety will be achieved. D. 14 C.F.R. 91.405 (a); 407 (a) (1); 

409 (a) (2); 417(a) & (b): Maintenance Inspections. The above-cited 

Regulations require, amongst other things, aircraft owners and operators to 

“have [the] 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. . .” These Regulations only apply to aircraft with an airworthiness 

certificate. They will not, therefore, apply to my, William J. Sadler’s, UAS. 

However, as a safety precaution I inspect my UAS before and after each 

flight and I do hold a Mechanics certificate as well. A Summary The FAA 

May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: 

Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, 

entitled Airworthiness Certificates, sets forth requirements for procurement 

of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). 

The size, weight and enclosed operational area of my UAS permits 

exemption from Part 21 because my, William J. Sadler’s, UAS meets an 
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

equivalent level of safety pursuant to Section 333 of the Reform Act. The 

FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of 

the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's 

from the airworthiness certificate requirement in consideration of the 

weight, size, speed, maneuverability and proximity to areas such as 

airports and dense populations. My UAS meets or exceeds each of the 

elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an 

airworthiness certificate. As no such certificate will be applicable in the form 

contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 

(b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots 

or passengers, and given the size of the UAS's, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a 

manual. The FAA has previously issued exemptions to this regulation in 

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

maintenance program that involves regular firmware updates and curative

measures for any damaged hardware. Therefore, an equivalent level of 

safety will be achieved.

In summary, William J. Sadler seeks an exemption from the

following Regulations:

14 C.F.R. 21, subpart H; 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(b); 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) and (b); 14

C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. §

91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§

91.417 (a) & (b) to commercially operate my, William J. Sadler, small 

unmanned vehicle/lightweight unmanned aircraft vehicle in community 

awareness and real estate and tourist operations, and to develop economic 

platforms for real estate to enhance the experience of those seeking to 
Alaska Aerial Productions Kenai, AK- Section 333 Exemption

Petition

relocate to the Kenai Peninsula and/or the Alaska area. Currently, area 

awareness and real estate aerial videography/photography relies primarily 

on the use of larger aircraft running on combustible fuel, posing potential 

risk to the public. Granting my, William J. Sadler’s, request for exemption 

will reduce current risk levels and thereby enhance safety. My UAS craft 

does not contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional real estate and tourism video and 

photographic aircraft with much less flight time. Further, I operate at lower 

altitudes and in controlled airspace eliminating potential public risk flying to 

and from established airfields. I, William J. Sadler, have been informally 

analyzing flight information and will compile safety protocols and the 

implementation of a flight operations manual for usage that exceeds 

currently accepted means and methods for safe flight.

Formal collection of information shared with the FAA will enhance the 

FAA's internal efforts to establish protocols for complying with the FAA 

Modernization and Reform Act of 2012. There are no personnel on board 

my, William J. Sadler’s, UAS and therefore the likelihood of death or 

serious bodily injury is significantly diminished. My, William J. Sadler’s, 

operation of my UAS, weighing less than 5 pounds and traveling at lower 

speeds within limited areas will provide an equivalent level of safety as that 

achieved under current FARs. Accordingly I, William J. Sadler’s respectfully 

request that the FAA grant my exemption request and am willing to 

cooperate in sharing information to benefit the FAA, safety of manned 

aircraft, and the general public at large.

Respectfully,

William J. Sadler, Owner 

Alaska Aerial Productions 

381 Senior Court #106

Kenai, Alaska 99611