Ronald Lee Castle

802 Hannibal Street. Apt. 1 lower

Fulton NY, 13069

315-297-4622

ronald_castle@yahoo.com

June 20, 2015

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590

Re: Request for exemption under Section 333 from 14 CFR Part 21, Subpart H; 14 CFR 

61.113 (a) And (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 CFR 

91.405 (a); 14 

CFR 91.407 (a) (1); 14 CFR 91.409 (a) (1); 14 CFR 91.409 (a) (2); 14 CFR 91.417 (a) 

and (b)

Dear Sir or Madam:

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act) and 14 CFR Part 11, Ronald Lee Castle – iREEL Productions

Hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to 

allow commercial use of its Small Unmanned Aircraft Systems (SUASs), so long as 

such operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333.

Ronald Lee Castle – iREEL Productions is requesting this exemption because - (1) 

existing regulations will severely hinder and burden iREEL Productions (hereafter to be 

referred to as iREEL Productions) (2) iREEL Productions can provide and execute a 

level of PIC competence and safety that is, at the very least, equal to (or greater than in 

many cases) to those provided by existing guidelines, and (3) the request is in the 

public interest and local benefit. The FAA’s authority to issue exemptions from operating 

rules, and the Secretary’s authority granted by Section 333 of P.L. 112-95, Special 

Rules for Certain Unmanned Aircraft Systems, provide an opportunity to authorize 

certain SUAS operations in the National Airspace System (NAS) prior to implementation 
of the SUAS rule. This incremental step will allow iREEL Productions / Ronald Lee 

Castle to safely and legally enter into the NAS.

The requested exemption will permit iREEL Productions/Ronald Lee Castle to operate 

its SUAS under closely monitored conditions in airspace that is confined/limited (<300 

meters in any direction and <100 meters altitude), predetermined and agreed upon, 

controlled to access and would provide safety enhancements to the already safe 

operations of those aircraft of similar size, weight, speed, and operating capability that 

have been granted entry into the NAS via the rules in Academy of Model Aeronautics 

(AMA) National Aircraft Safety Code. Approval of this exemption would thereby greatly 

enhance safety and fulfill the Secretary of Transportation’s (the Secretary) 

responsibilities to “... establish requirements for the safe operation of such aircraft 

systems in the national airspace system” per Section 333 (c) of the Reform Act. 

Ronald Lee Castle /iREEL Productions is requesting exemption from the following 

regulations: 

14 CFR Part 21, Subpart H 

14 CFR 61.23 (a) 

14 CFR 61.113 (a) and (b) 

14 CFR 91.109 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) and (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333 (a) through (c) of the Reform Act. This law directs the Secretary to consider 

whether certain unmanned aircraft systems may operate safely in the NAS before 

completion of the rule-making required under Section 332 of the Reform Act. In making 

this determination, the Secretary is required to determine which types of UASs do not 

create a hazard to users of the NAS, to the public, or pose a threat to national security.

Section 333 of the Reform Act grants the Secretary authority to determine (1) if an 

unmanned aircraft system, as a result of its size, weight, speed, operational capability, 

proximity to airports and populated areas, and operation within visual line of sight 

(VLOS) does not create a hazard to users of the NAS or the public or pose a threat to 

national security, and (2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under 49 USC 44704 is required for the operation of civil 

(non-governmental) UASs. Therefore, if the Secretary determines that such vehicles 
“may operate safely in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft in the national airspace system”.

iREEL Productions Overview

iREEL Productions uses small UAS (quad-copters) weighing less than 6 lbs fully loaded 

(camera and battery). Quad-copters are small, agile UASs with the ability to hover and 

move in the vertical and horizontal planes simultaneously. iREEL Productions will 

operate only in visual line of sight (VLOS), and only in tightly controlled and limited 

airspace. The UASs are capable of operating at speeds of up to 29 knots, but are 

routinely operated at much lower speeds, usually at a standstill for imaging. They are 

most frequently operated below 200 feet above ground level (AGL), and never over 400 

feet AGL. iREEL Productions exemption request would permit a commercial operation 

of SUAS for aerial photography and videography in tightly controlled and limited 

airspace. Aerial photography and videography services will be offered to homeowners, 

realtors, home builders, ranchers and farmers and/or home inspectors for use in, but not 

limited to, real estate marketing and safer inspections of home exteriors. All operations 

will be conducted on private property and with the written and/or oral permission of the 

property owner(s), and always with privacy in mind. Operations will always be 

conducted in areas that are clear of all people, except the pilot in command (PIC) and 

the PIC’s helper(s). Such operations will ensure that the SUAS will “not create a hazard 

to users of the national airspace system or the public”.

Our Aircraft

iREEL Productions operates and uses the YUNEEC Typhoon Q500+.

AirCraft specs

o Flight Time

Up to 25 Minutes

o Dimension

16.5x16.5x9.5in (420x420x240mm)

o Diagonal Length Without Rotor Blades 

22.2in (565mm) 

o Propeller/Main Rotor Diameter

13.0in (330mm) 

o Weight Without Battery and Payload

40.0oz (1130g) 

o Battery

5400mAh 3S 11.1V LiPo (included) 

o Charger

3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included)

o Transmitter

10-channel 2.4GHz with 5.8GHz video downlink (included) 

o 3 Flight Modes

Smart, Angle and Home Modes 

o Maximum Flying Height

Default 122m (400ft) Above Ground Level (Adjustable via the Q500 GUI) 
o Maximum Rotation Rate

65°/s 

o Maximum Roll Angle

35° 

o Operating Temperature Range

-5°C to 80°C

Our Aircraft (continued)

The Yuneec Typhoon Q500+ Quadcopter has multiple safety features programmed in to 

its APM flight control system. These features serve to minimize any risk posed by loss 

of control, loss of transmission signal or loss of orientation. These features include, but 

are not limited to:

• GPS controlled positioning allows the UAS to "know" its location, attitude and altitude.

• RTH (return to home) when triggered, will bring the Typhoon back and land it 

autonomously in the event the PIC is unable to do so.

• FAILSAFE will return the UAS and land it autonomously should the control 

transmission get cut off for any reason. 

• GEOFENCE allows the PIC to set a virtual "fence", or boundaries that the Typhoon

cannot cross. By default, it is 300 meters lineal and 125 meters vertical. Crossing this 

boundary will automatically trigger the RTH feature.

These highly advanced capabilities will ensure that the SUASs can be safely operated 

and “not create a hazard to users of the national airspace system or the public.”

Equivalent Level of Safety

In an effort to join the FAA in its mission to provide the safest, most efficient aerospace 

system in the world and to minimize the risk to the NAS or to persons and property on 

the ground, iREEL Productions agrees to be bound by the following limitations and 

conditions when conducting commercial operations under a FAA issued exemption:

A. For the purposes of ensuring SUASs will be operated within the standards that the 

FAA has allowed in the AMA National Model Aircraft Safety Code: 

1. SUASs will not be flown: 

a. In a careless or reckless manner. 

b. At a location where SUAS activities are prohibited. 
2. SUAS pilots will: 

a. Yield the right of way to all human-carrying aircraft. 

b. See and avoid all aircraft and a spotter must be used when appropriate

(Continued on next page)

c. Not fly higher than 400 feet above ground level or within three (3) miles 

of an airport without notifying the airport operator. 

d. Not interfere with operations and traffic patterns at any airport, heliport 

or seaplane base except where there is a mixed use agreement. 

e. Not exceed a takeoff weight of 55 pounds (including payload).

f. Ensure the aircraft is identified by affixing the owner’s contact 

information to the outside of the SUAS. 

g. Not operate SUASs while under the influence of alcohol or while using 

any drug that could adversely affect the PIC’s ability to safely control the 

model. 

h. Not operate SUASs carrying pyrotechnic devices that explode or burn, or 

any device which propels a projectile or drops any object that creates a 

hazard to persons or property. 

3. SUASs will not be flown unless: 

a. The aircraft, control system and pilot skills have successfully 

demonstrated all maneuvers intended or anticipated prior to the specific 

event. 

b. An inexperienced pilot is assisted by an experienced pilot. 

4. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or 

structures and shall avoid endangerment of life and property of others. 

5. A successful radio equipment ground-range check in accordance with 

manufacturer’s recommendations will be completed before the first flight of a new 

or repaired model aircraft. 
6. SUASs must use the radio-control frequencies currently allowed by the Federal 

Communications Commission (FCC). 

7. SUASs will not knowingly operate within three (3) miles of any pre-existing flying 

site without a frequency-management agreement.

 

8. Excluding takeoff and landing, no SUASs may be flown outdoors closer than 25 

feet to any individual, except for the PIC and the PIC's helper(s) located at the 

takeoff site.

9. Under no circumstances may a pilot or other person touch a SUAS in flight while 

it is still under power, except to divert it from striking an individual. 

10. The PIC of the SUAS shall: 

a. Maintain control during the entire flight, maintaining visual contact 

without enhancement other than by corrective lenses prescribed for the 

pilot. 

b. Fly using the assistance of a camera or First-Person View (FPV) only in 

accordance with the procedures outlined in AMA Document #550. 

c. Fly using the assistance of autopilot or stabilization system only in 

accordance with the procedures outlined in AMA Document #560. 

11. The flying area must be clear of all utility wires or poles and an SUAV will not be 

flown closer than 50 feet to any above-ground electric utility lines. 

12. The flying area must be clear before the engine is started, except for PIC and the 

spotter.

In addition to the above rules outlined by the AMA National Model Aircraft Safety 

Code and in an effort to enhance the safety offered by the already safe operations 

mentioned above, iREEL Productions also agrees to be bound by the following 

limitations and conditions: 

1. Flights will be operated within VLOS of the PIC. 

2. Maximum total flight time for each operational flight will be 18 minutes. Flights 

will be terminated at 25% battery power reserve should that occur prior to the 18 

minute limit. 

3. The SUAS will only operate in tightly controlled and limited airspace.
4. A briefing will be conducted in regard to the planned SUAS operations prior to 

each flight. It will be mandatory that all personnel who will be performing duties 

within the boundaries of the safety perimeter be present for this briefing. 

5. The PIC and the PIC’s helper(s) will have been trained in operation of SUAS and 

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

6. The pilot and the PIC's helper(s) will at all times be able to communicate by voice. 

(Continued from page 6)

7. If the SUAS loses communications or loses its GPS signal, the SUAS will have 

capability to return to a pre-determined location within the security perimeter and 

safely land. 

8. The SUAS will have the capability to abort a flight in case of unpredicted obstacles 

or emergencies. 

9. All flights will be conducted on private property and with the written and/or oral 

permission of the property owner(s). 

10. Flights will always be conducted in areas that are clear of all people, except for 

the PIC and the PIC's helper(s). 

11. All flights will be conducted outdoors in visual meteorological conditions (VMC) 

and never during severe weather conditions. 

12. Flights will not occur in weather conditions that prevent the PIC from operating 

within visual line-of-sight (VLOS) at all times or in weather conditions that 

dramatically affect the UAS’s flight (e.g. high winds). 

13. If an operation occurs in an area where people could inadvertently enter the 

area, an operational border will be established with traffic cones. If it’s not 

Feasible to use traffic cones due to interference with the photography/videography, the 

PIC's helper(s) will be responsible for keeping a safe perimeter around the operation. 

The operation will cease immediately and be rescheduled if it’s impossible to establish a 

safe perimeter around the operation.

14. The PIC will be responsible for logging all flights to ensure the comprehensive 

preventative maintenance plan can be followed, as described in the “Preventative 

Maintenance” section below. 
15. The SUAS will not be routinely operated in the proximity of any airports. In any 

cases where the SUAS must be operated within three (3) miles of an airport, the airport 

operator will be notified before the operation commences. The operation of SUASs, 

weighing less than 6 lbs., conducted in the strict conditions as outlined above, will 

provide an equivalent level of safety supporting the grant of exemptions requested 

herein, including exempting the applicant from the requirements of Part 21 and 

allowing commercial operations. These lightweight aircraft operate at slow speeds, 

close to the ground, and in a tightly controlled environment. As a result, they offer a 

much safer way to capture aerial photography and videography. Furthermore, the 

proposed operations represent a safety enhancement to the already safe operations 

that have been granted by the FAA for the establishment of the AMA National Model 

Aircraft Safety Code. 

Preflight Action Plan

The PIC will follow a comprehensive pre-flight checklist to ensure that the SUAS is in a 

condition for safe flight. This plan will be improved as needed in order to ensure all 

known safety precautions and/or safety precautions suggested by the manufacturer are 

being accounted for. 

A. Pre-flight Inspection 

1. Check that the remote control, Yuneec Typhoon 1 battery(s), ST-10+ 5.5" Android 

touch screen personal ground station, Bluetooth GCS and smartphone are all fully 

charged. 

2. Visually inspect the LIPO batteries for signs of wear or damage. Check both 

battery switches for proper operation.

3. Turn the motor shafts with your fingers and verify they are smooth without 

excessive play or binding. 

4. Verify that the rotation diagram on the propellers matches the rotation diagram on 

the Typhoon arms.

5. Inspect the propeller edges for nicks or cuts.

6. Flex both side of the propellers’ blades to check for hairline cracks where the 

blades connect in the center of the propeller. 

7. Verify that the landing gear is secure (not cracked/broken/loose). 

8. Verify that the retractable landing gear is functioning smoothly.
9. Verify that the Micro-SD card has been inserted and formatted. 

10. Verify that the damping absorbers are not broken and/or worn. 

11. Arm/Disarm motors three separate times to allow GPS to lock on the launch site.

12. Inspect the gimbal and camera for smooth operation.

13. Verify all trims and switches set at "0".

14. Verify video connection between the Typhoon and the ST-10+ 5.5" Android touch 

screen personal ground station.

15. Perform final area check for obstructions.

Preventative Maintenance

A comprehensive preventative maintenance plan will be followed in order to ensure the 

SUAS’s software is up-to-date, the batteries are in good health, and the aircraft itself is 

always ready for safe flight.

Pilot in Command (PIC) Qualifications

The PIC does not hold an airman certificate or medical certification. Since the SUAS is 

similar in size, weight, speed and operating capability as those currently allowed to be 

flown for hobby/recreation, holding the PIC to those same set of standards will allow for 

an equivalent level of safety. 

The PIC has over 20 years’ experience in piloting RC/UAS craft, and has been an 

instructor to many students, a few of which were pilots. Because the PIC is not actually 

in the aircraft, quick reflexes, manual dexterity and computer knowledge is more 

important to safely piloting the UAS than an airman certificate.

It cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed 

wing aircraft, has the skill or ability to safely operate an unmanned aerial vehicle,

operating at 400 feet AGL or lower, within strictly controlled pre-approved airspace. 
Since there are no standards for either private or commercial SUAS pilot certificates, 

knowledge of airspace regulations and dexterity in the control and operation of the 

SUAS acquired from actual operation of the aircraft will be the most important factors in 

establishing an equivalent level of safety. With that in mind, iREEL Productions 

proposes that its PIC be required to do the following prior to the first commercial 

operation (NoteThese are mostly the same requirements proposed by Singer's 

Creations in their successful request for exemption. iREEL Productions believes 

that these requirements are an excellent start to ensure the PIC is qualified to 

operate safely ):

1. Perform 20 flights or log 20 hours of flight time (the greater of the two) with the 

Typhoon.

 

2. Successfully learn and demonstrate all flight maneuvers in the Typhoon manual.

3. Study and be familiar with all sections of the “Typhoon’s user manual”.

4. Study and be familiar with all sections of the “ST-10+ 5.5" Android touch screen 

personal ground station manual".

5. Study, be familiar with, and demonstrate (where possible) the “Always be 

Prepared for the Worst” scenarios.

Public Interest

Granting this exemption would benefit the public as a whole. SUASs offer a strong 

equivalent level of safety, a reduction in environmental impacts, and are free from the 

harmful emissions associated with the manned aircraft that are currently used for aerial 

photography and videography. Due to the size of the SUAS and the tightly controlled 

and limited airspace in which the SUAS will operate, approval of this application 

presents no risk to the public. Furthermore, the public will be able to legally acquire 

aerial photography and videography to help in, but not limited to, advertising homes for 

sale, advertising uninhabited home lots, use of photos and video as an aid when 

researching homes for sale on the market, or safely accessing high and/or awkward 

areas of a home’s exterior to assess damage that needs to be repaired.
Privacy

Since the areas being photographed or filmed will be on private property, accessed only 

after given written and/or oral consent by the property owner(s), and clear of all people, 

except for the PIC and the PIC's helper(s), approval of this application presents no risk 

to the public privacy. In addition, iREEL Productions will honor all requests for "no-fly 

zone".

National Security

Due to the size of the SUAS and the tightly controlled and limited airspace in which the 

SUAS will operate, approval of this application presents no risk to national security. 

Requested Exemptions

Ronald Lee Castle /iREEL Productions requests exemption from the following 

regulations since it’s not possible to fully comply with them, and attempting to follow 

them for the purposes of operating a SUAS would be a burden: 

(Continued on next page)

Airworthiness Certificates 14 CFR Part 21, Subpart H

Subpart H establishes the procedural requirements for the issuance of airworthiness 

certificates as required by FAR 91.203 (a) (1). Given the size and limited operating 

area associated with the aircraft to be utilized by Singer’s Creations, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under 

Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 USC 44701 

(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from 

the requirement for an airworthiness certificate, upon consideration of the size, weight, 

speed, operational capability, and proximity to airports and populated areas of the 

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

operated without an airworthiness certificate, in the restricted environment and under 

the conditions proposed, will be at least as safe, or safer, than a conventional aircraft 

operating with an airworthiness certificate without the restrictions and conditions 

proposed.

Medical certificates 14 CFR 61.23 (a) 

This regulation requires pilots of manned aircraft to hold a medical certificate. Since 

risks associated with the operation of the proposed SUAS are so diminished from the 

level of risk associated with any manned aircraft; the SUAS is of a size, weight, 

speed, and operational capabilities which makes it much safer than any manned 
aircraft; since operations will occur in tightly controlled and limited airspace; and 

considering that all operations will be on private property that is clear of all people, 

obtaining and maintaining a medical certificate would not improve the safety of the 

operation. In the very rare case of a mishap, the SUAS being flown will pose 

significantly less of a threat than manned helicopters and fixed wing aircraft because 

the SUASs are a fraction of the size, a fraction of the weight, will be flown at a fraction 

of the speed, carry no flammable fuel, and carry no crew or passengers. 

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

(b)

These regulations limit private pilots to non-commercial operations. Because the 

SUAS will not carry a pilot or passengers; due to the SUAS’s size, weight, speed, and 

operational capabilities; and since operations will occur in tightly controlled and 

limited airspace, the proposed operations can achieve the equivalent level of safety of 

current operations that currently require a commercial pilot’s license. 

Furthermore, since there are no standards for either private or commercial SUAS 

pilot certificates, knowledge of airspace regulations and dexterity in the control and 

operation of the SUAS acquired from actual operation of the aircraft will be the most 

important factors in establishing an equivalent level of safety. It cannot be assumed 

that a commercial pilot, approved to operate a manned helicopter or fixed wing 

aircraft, has the skill or ability to safely operate an unmanned aerial vehicle, operating 

at 400 feet AGL or lower, within strictly controlled pre-approved airspace.

Flight instruction 14 CFR 91.109

This regulation provides that no person may operate a civil aircraft (except a manned 

free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. SUASs and remotely piloted aircraft, by their design do not 

have fully functional dual controls. Flight control is accomplished through the use of a 

control box that communicates with the aircraft via radio communications. The FAA has 

approved exemptions for flight training without fully functional dual controls for a number 

of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety 

provided by the fact that neither a pilot nor passengers will be carried in the aircraft and 

by the size and speed of the aircraft.

Altimeter settings 14 CFR 91.121

This regulation requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set “...to the elevation of the departure airport or 

an appropriate altimeter setting available before departure.” As the SUAS may not 

have a barometric altimeter, but instead a GPS altitude read out, an exemption may 

be needed. An equivalent level of safety will be achieved by the operator by 
confirming the altitude of the launch site shown on the GPS altitude indicator before 

flight.

Fuel Requirements for Flight in VFR Conditions 14 CFR 91.151 (a) 

This regulation prohibits an individual from beginning “a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and, assuming normal cruising 

speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to 

fly after that for at least 45 minutes.” 

The battery powering the SUAS provides approximately <25 minutes of powered flight. 

That would make it impossible to meet the 30 minute reserve requirement. Given the 

limitations on the SUAS’s proposed flight area and the location of its proposed 

operations within a predetermined area, a longer time frame for flight in daylight or 

night VFR conditions is reasonable. An equivalent level of safety can be achieved by 

limiting flights to <25 minutes or 25% of battery power (whichever occurs first). This 

restriction would be more than adequate to return the SUAS to its planned landing 

zone from anywhere in its limited operating area.

Maintenance Inspections 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 

(a) (1); 14 CFR 91.409 (a) (2); 14 CFR 91.417 (a) and (b) 

These regulations require that an aircraft operator or owner “shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft 

in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft 

with an airworthiness certificate, these sections will not apply. Maintenance will be 

accomplished by the operator pursuant to the aforementioned Scout 4X user manual 

and guide. An equivalent level of safety will be achieved because these small SUASs 

are very limited in size, will carry a small payload, and operate only in restricted areas 

for limited periods of time. If mechanical issues arise, the SUAS can land immediately 

and will be operating from no higher than 400 feet AGL. As outlined in the 

aforementioned Pre-flight Action Plan, the operator will ensure that the SUAS is in 

working order prior to initiating flight and perform maintenance as required. Moreover, 

the operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety.

In accordance with 14 CFR Part 11, the following summary is provided for 

publication in the Federal Register: 
The applicant seeks an exemption from the following rules: 14 CFR Part 21, 

Subpart H; 14 CFR 61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 

91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(1); 14 CFR 91.409 (a)(1); 14 CFR 

91.409 (a)(2); 14 CFR 91.417 (a) and (b) to commercially operate small unmanned 

aircraft systems (55 lbs. or less) in order to safely and legally capture aerial 

photography and videography for use by homeowners, realtors, home builders, 

home contractors, and/or home inspectors.

The operation of SUASs conducted in the strict conditions outlined above, will provide 

an equivalent and/or greater level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 

and allowing commercial operations. These lightweight aircraft operate at slow speeds, 

close to the ground, and in a sterile environment, and as a result, are far safer than 

existing operations conducted with helicopters operating in close proximity to the 

ground, people, or other buildings in the vicinity. Given the small size of the SUASs 

involved, the slow speed at which they must be operated in order to capture photos and 

videos, and the restricted environment within which they will operate, the Scout 4X 

demonstrates that it can be operated within an equivalent level of safety in which 

Congress envisioned that the FAA must, by exemption, allow commercial 

Operations of SUASs to commence immediately. Also, due to the size of the SUASs 

and the restricted areas in which the relevant SUASs will operate, approval of this 

application presents no threat to national security. Given the clear direction in Section 

333 of the Reform Act, the authority contained in the Federal Aviation Act, the strong 

equivalent level of safety surrounding the proposed operations, the significant public 

benefit – including enhanced safety, reduction in environmental impacts, no emissions, 

ability to legally obtain aerial photography and videography services – the grant of the 

requested exemptions is in 

The public interest. Accordingly, iREEL Productions respectfully requests that the 

FAA grant the requested exemption without delay. Satisfaction of the criteria provided 

in Section 333 of the Reform Act – size, weight, speed, operating capability, proximity 

to airports and populated areas, operation within the visual line of sight, public safety, 

and national security – provide more than adequate justification to grant iREEL 

Productions the requested exemption, allowing for commercial operations as 

described herewith. Sincerely, 

Founder: Ronald Lee Castle / iREEL Productions