Norman Card, photographer, Selbyville Delaware - Section 333 Exemption Petition 

16Feb2016 

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U.S. Department of Transportation Docket 

Management System 

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1200 New Jersey Ave, SE Washington, 

DC 20590 

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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, Norman Card, 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, Norman Card, an 

owner and operator of small unmanned aircraft, be exempted from the Federal Aviation 

Regulations ("FARs") listed below so that I, Norman Card, 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, Norman Card, am a Photographer within the State of Delaware ; 

experienced in flying hobby helicopters for recreational purposes. I have added a hobby 

grade quad-copter, Phantom 3 Professional UAS to my inventory equipped with a Soney 

Exmor camera with intent for aerial videography/cinematography to enhance academic 

community awareness for those individuals and companies unfamiliar with the 

geographical layout of the suburban Delaware area, and augment real estate listing 

videos; following exemption and approval by the FAA. Thereby enhancing their academic 

research experience for the area. I plan to add a second quad-copter to my inventory in the 

future with comparable safety capabilities. 

I have flown small RC electric helicopters for over six (6) years without incident. Committed 

to safety with each flight and held a fixed-wing student pilot license My, Norman Card's , 

exemption request would permit operation of ultra light weight, unmanned (piloted by remote 

control) and comparatively inexpensive UAS(s) in tightly controlled and limited airspace. 

Predetermined in areas away from general public, airports, heliports and vehicular traffic 

catastrophe for community videos, and within property boundaries for individual 

homeowner real estate listing videos/photos. Currently, similar lightweight, remote 

controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan 

or controls in place to prevent . I, Norman Card, have personally instilled safety 

Norman Card, Photographer Selbyville Delaware - Section 333 Exemption Petition 

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protocols and controls to avoid and prevent public hazard, as well as manned aircraft 

hazards/catastrophe. This will act to further safety protocols exclusive to lightweight UAS's 

specific to real estate video and photography usage as I, Norman Card~ 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 regulation. 

Granting my, Norman Card, 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 to " ... 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 real estate/photography purposes. Further I, Norman 

Card, will conduct my operations in compliance with the protocols described herein or as 

otherwise established by the FAA. 

For the reasons stated below I, Norman Card, respectfully request the grant of an 

exemption allowing me to operate ultra light weight, remote controlled UAS's for academic 

community awareness to benefit/stimulate attraction to the 

Appendix~A-User manual 

Appendix-B-Quick start guide 

Appendix-C-Safety Guidelines 

Appendix-0-Prop guards 

Appendix-E-Smile radius Ocean City, Maryland 

Appendix-F-Fiight check list 

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DelaiNare area and to enhance real estate listing videos for homeowners who cannot 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 heavier manned aircraft containing combustible fuel that that 

poses potential public hazard. 

Norman Card, Photographer 

37 406 Shady Way 

Selbyville, Delaware, 19975 

Mobile: (443) 523-9762 

Email Buzzman1946@gmail.com 

I. The Specific Sections of Title 14 of the Code of Federal Regulations From Which 

Norman Card Requests Exemption are: 

14 CFR21; 

14 C.F.R. 45.23(b); 

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). 

Norman Card, Photographer Selbyville Delaware -Section 333 Exemption 

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II. The Extent of relief Norman Card seeks and the Reason He Seeks Such Relief: 

I, Norman Card, 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, 

Norman Card, contemplated commercial cinematic, academic 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. I, Norman Card, 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 related 

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 reflect in favor of an 

exemption for me, Norman Card. My UAS utilizes four (4) counter-rotating propellers for 

balance, control and stability. My UAS is equipped with GPS and auto return safety 

technology. Weighing less than five (5) pounds (far below the maximum 55 pound limit); 

including camera with gimbal. 

I, Norman Card, considers safety as 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 fear 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 Smart 

Mode5 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 slowly 

descend to point of take off. I do not operate my UAS near airports, Hospitals nor Police 

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, 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. My UAS is capable 

of vertical and horizontal operations, and are 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 three 15-20 minutes with an altitude under one hundred fifty (150) feet 

5 Smart Mode includes safe circle for operation, position hold, self-leveling, altitude command, GPS, retum home feature, and safety 

control to return home or land in the event of communication interruption between RC transmitter and UAS. See Appendix A -

Operator Manual. 

Norman Card, Photographer Selbyville Delaware - Section 333 Exemption 

I, Norman Card, utilize a fresh fully charged battery with each flight as a safety precaution; full 

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flight time limit for each battery is nine 15 to 20 minutes as tested. I do not operate my UAS at 

or below manufacture recommend minimum charge levels for operation; preferring to remain 

well within a safe operating range to insure adequate communication between radio control 

and UAS 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 no desire to lose an 

investment. I have clocked 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. All for the sake of safety. 

I, Norman Card, am extremely 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. Norman 

Card's UAS, used in hobby flight, has a demonstrable safety record and does not pose any 

threat to the general public or national security. 

Ill. How Norman Card's Request Will Benefit the Public As A Whole: 

Aerial videography for geographical awareness and for Photography marketing has been 

around for a long time through manned fixed wing aircraft and helicopters. For small 

budget companies and average homeowners the expense of such aerial videography is 

cost prohibitive. Only large companies and high end Photography can afford to absorb 

such expense. Depriving non-luxury homeowners and lower budget. Manned aircraft pose 

a threat to the public through potential catastrophic crash that the Selbyville community has 

experienced in the past with military aircraft crashes within the city of Selbyville. Each 

resulting in loss aircraft. Each with combustible fuel that exploded and burned on impact. 

Police helicopters have made emergency hard landings within city limits. My, Norman 

Card, UAS pose no such 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, Norman Card's, exemption request furthers the public interest through 

academic/visual awareness of the geographical benefits in and around the Selbyville 

Delaware area. 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 

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less than a full size helicopter or fixed wing aircraft; which are heavy, contain 

combustible fuel and can cause catastrophic devastation to the public. 

Norman Card, Photographer Selbyville Delaware -Section 333 Exemption 

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, Norman Card, to immediately fly within national air space furthers economic growth. 

Granting my exemption request substantially furthers the economic impact for the Selbyville, 

Delaware community for companies looking to relocate or build in the Selbyville area as well 

as individuals looking to relocate for career advancement through academic and 

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

IV. Reasons Why Norman Card Exemption Will Not Adversely Affect Safety Or How 

The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

My, Norman Card, exemption will not adversely affect safety. Quite the contrary, for the 

reasons stated permitting me, Norman Card, 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 for 

Realtors that can be embraced by the Photographer for development in cooperation with 

the FAA. In addition I, Norman Card, submit the following representations of enhancements 

to current aerial videography and photography for real estate/photography. 

MyUAS weighs less than 5 pounds complete with a small ultra light weight high 

quality GoPro 3+ Black camera; 

I eonly operate my UAS below 200 feet9 (well within the 400 foot permissible 

ceiling set by the FAA Modernization and Reform Act of2012); 

flltY UAS only operate for 15-20 minutes per flight; 

I ~nd my UAS prior to manufacturer recommended minimum level of battery power; 

l.,ilot 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 ectively analyze flight data and other sources of information to constantly update 

and enhance safety protocols; 

14>nly operate in reasonably safe environment that are strictly controlled, are away 

from power lines, elevated lights, airports and actively populated areas; 

l.x>nduct extensive pre-flight inspections and protocol, during which safety carries 

primary importance; 

I elways obtains all necessary permissions prior to operation; and, 

1 ehave procedures in place to abort flights in the event of safety breaches or 

potential danger. 

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Norman Card, Photographer Selbyville Delaware - Section 333 Exemption 

Norman Card, 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 and real estate. While the safety record of such helicopters is 

remarkably astounding, there has been local incident involving loss of life as well as 

extensive property damage; it is far safer to operate a battery powered ultra light weight 

UAS. 

F4rst, 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, 

tAE3re is no fuel on board a UAS and thus the potential for fire or explosions is greatly 

diminished. 

T~ird, the small size and extreme maneuverability of my UAS allow me to remotely 

pilot away from and avoid hazards quickly and safely. 

Lt~stly, 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. 

V. 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, Norman Card'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, Norman Card, 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 equiyalent level of safety will be achieved by maintaining a 

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' . 

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial 

operations. I, Norman Card, 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. 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, Norman Card, to operate my UAS 

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

B. 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, 

Norman Card, 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. 

C. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

Norman Card, Photographer Selbyville Delaware - Section 333 Exemption 

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, Norman Caret, UAS. However, as a safety precaution I inspect my UAS before and after 

each flight. 

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, Norman 

Card's, UAS meets 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 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 

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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, 95658, 10167, maintenance program that involves regular software updates and 

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

be achieved. 

In summary, Norman Card 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, Norman 

Card's, small unmanned vehicle/lightweight unmanned aircraft vehicle in community 

awareness and, and to develop economic platforms for photography to enhance the 

experience of those seeking to relocate to the Selbyville, Delaware 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, 

Norman Card, request for exemption will reduce current risk levels and thereby enhance 

safety. My UAS craft do not contain potentially. 

Norman Card, Photographer Selbyville Delaware - Section 333 Exemption 

explosive fuel, is smaller, lighter and more maneuverable than conventional real estate 

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 air fields. I, Norman Card, have been informally analyzing flight information 

and will compile safety protocols and the implementation of a flight operations manual 

for real estate 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, Norman Card's, UAS and 

therefore the likelihood of death or serious bodily injury is significantly diminished. My, 

Norman Card's, operation of my UAS, weighing less than 5 pounds and travelling at 

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

achieved under current FARs. Accordingly I, Norman Card, 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 submitted, 

Norman Card 

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