August 11, 2015

Exemption No. 12418 Regulatory Docket No. FAA

– 20 15

– 2201

Mr. William J. Sadler Alaska Aerial Pro duc tions 381 Senior Court # 106 Kenai, A K 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 a n exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial videography and cinematography

.
See Appendix A for the petition submitted to the FAA des cribing 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, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic 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 the2

aircraft and its operation, the Secr etary 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

, C ertification 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 collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 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 Lab s , 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 requesti ng 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 limi tations 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 (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.3

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 u se 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 (VL OS) 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 ;

e lectronic messaging or texting is not permitte d 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 documen ts 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 oper ations 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 u pdate 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 FA A’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 condu cting 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 co ndition 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 prohibite d 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flig ht revi ew 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 be5

operated under this exemption, including evasive and emergency maneuvers and maintaining approp riate 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 (traini ng, proficie ncy, 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 traini ng, 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 (S VFR) 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 symbo l 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 avail able 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 c ommunications or loses its GPS sign al, the UA must return to a
pre

- determined location within the pr ivate 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 beginn ing 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 manufacture r if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operation s 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 identification6

(N− Number) markings in accor dance 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 t he 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 nonpartici pating 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 r emain 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 control led

- access property with permission from the property owner/controller or aut horized 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 opera tional area as defined by the applicable COA must be reported to the FA A'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.7

29. The operator must have a mot ion 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 a rea 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 phon e number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e 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 th e 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 t o 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

### Al **aska Ae**  **rial 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:** Ex emption 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, Wil liam 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 Regulat ions (“FARs”) listed below so that I, William J. Sadler, may operate my s mall ultra light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”). As described herein I, William J. Sadler, h ave 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 g eographical 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 ev ery flight. My, William J Sadler exemption request would permit operations of ultr alight weight, unmanned (piloted by remote

### Al **aska Ae**  **rial 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, air ports, 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 protoc ol 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 c omports 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 herei n or as otherwise established by the FAA. For the reasons stated below I, Wi lliam 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 aw areness 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 empl oyment and increased tax base b oth with public safety in mind by keeping significantly heavier manned aircraft containing combustible fuel posing potential public hazard.

### Al **aska Ae**  **rial 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 Will **iam J. Sadler seeks and the Reason He Seeks Such Relief:** 

I, Wi lliam 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 s till 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 u ltra 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

### Al **aska Ae**  **rial 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, w hether 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) counter

rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety te chnology. 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 plac e 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 c ontrols 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 c onstantly 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 ai rcraft may approach near my location. I will call in to local Air Traffic Control to alert of my f light plan and operations as well as calling back wh en operations are complete. My UAS is capable of vertical and horizontal operations, and is flown only wit hin my line of sight of me , as the remote control pilot u tilizing battery power rather than combustible fuels, flights g enerally last between twelve (10 ) to sev enteen (17) minutes, with an altitude under two hundred (200) feet.

### Al **aska Ae**  **rial 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 ex ercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash that coul d create hazard to the public/property/manned aircraft, and have made a signific ant 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. Sad ler, am very cautious when operating of my U AS/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 po se any threat to the general public or national security.

### Al **aska Ae**  **rial Productions, Kenai, AK** 

**- Section 333 Exemption** 

**Petition**



### IV. How **William J. Sadler Request Will Benefit the Public A s**  **A Whole:**  Aerial videograph y 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 c ompanies and average homeowners, the expense of such aerial vi deography is cost prohibitiv e. 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 cras hes that Alaska has come to expect every year. Kenai, Seward, and Homer areas are very busy airspaces, which is wh y 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 organ izations.

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 int o 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 Peninsul a. 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 wi ng aircraft; which

are heavy, contain combustib le 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 b attery operated ultra light weight UAS's. Permitting me, William J. Sadler, to immediately fly within national air space furthers economic

### Al **aska Ae**  **rial Productions, Kenai, AK** 

**- Section 333 Exemption** 

**Petition**

growth. Granting my ex emption request substantially furthers the economic impact for the Alaska communiti es 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 Ad**  **ve rsely** **A**

**ffect Safety or How**  **The Exemption Will Prov ide**  **a Le vel of Safety** **A t Least Equal To Existing Rule:** 

My , Wil liam 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 w eighs less than 5 pounds complete with a small ultra light weight high quality DJI Zenmuse H3 camera.

 I only operate my UAS below 20 0 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012.)

 My UAS only o perates 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.

### Al **aska Ae**  **rial Productions, Kenai, AK** 

**- Section 333 Exemption** 

**P etition** 

 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 ex isting 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 communi ty aw areness, sur veys, 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 o nly 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 pos t editing software allowing pan and zoom. Accordingly, my UAS h as been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels.

### Al **aska Ae**  **rial 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 U AS meets (and exceeds) an equivalent level of safety pursua nt 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 U AS'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 a ircraft 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 m aintaining a safety/flight manual delineating areas o f 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 abo ve. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, William J. Sadler.

### Al **aska Ae**  **rial 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 non

commercial operations. I, William J. Sadler, can achieve an equivalent level of safety as achieved by current Regulations because my U AS does not carry any pilots or passengers. Further, while helpful, a pilot license will not

ensure re mote 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 20 0 AGL; safely b elow 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, man euverability 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 , W illiam J. Sadler’s, UAS. However, as a safety precaution I inspect my UAS before and after each flight and I do hold a Mechanics certifica te 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 U AS permits exemption from Part 21 because my, William J. Sadler’s, UAS meets an

### Al **aska Ae**  **rial Productions, Kenai, AK** 

**- Sectio**  **n 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 Refor m 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 exce eds 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 is sued 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 summar**y, William J. Sadler seeks an exemption from the**  **follow ing 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 commerci ally 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

### Al **aska A erial 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 U AS craft d oes 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 eli minating 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

c urrently 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 personne l 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 o f manned aircraft, and the general public at large.

Respectfully,

William J. Sadler, Owner

Alaska Aerial Productions 381 Senior Court #106 Kenai, Alaska 99611