January 11, 2016 

Adam Deets 

1311 E 16th Cir 

La Center, Washington 98629 

630-640-4424 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

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

the Federal Aviation Regulations from: 14 CFR 61.113(a) & (b); 91.7(a); 91.103; 

91 .119(c); 91 .121; 91.151(a); 91.405{a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) & 

(b). 

Dear Sir of Madam, 

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

"Reform Act") and 14 C.F.R. Part 11 , Adam Deets, licensed airplane and rotorcraft pilot 

of 18 years and an operator of Unmanned Aircraft Systems ("UAS") equipped to 

conduct aerial photography and videography, real estate photography, aerial surveying 

and mapping, windmill inspections, cell tower inspections, powerline and pipeline 

inspection and patrolling, wildlife and forestry monitoring, search operations, 

construction inspection, general infrastructure, and precision agriculture, hereby applies 

for an exemption from the Federal Aviation Regulations ("FARs") to allow commercial 

operation of its UASs, 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. 

As described below, the requested exemption would permit the operation of 

small, unmanned and relatively inexpensive UASs under controlled conditions. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's {the FAA Administrator's) responsibilities to " ... establish requirements 

for the safe operation of such aircraft systems in the national airspace system." Section 

333(c) of the Reform Act. 
The name and address of the applicant is: 

Name: 

Email: 

Address: 

Phone: 

Adam Deets 

adeetsUAS@gmail.com 

1311 E 16th Cir. 

La Center, WA 98629 

630-640-4424 

Regulations from which the exemption is requested: 

• 61.113(a)&{b) 

• 91 .7(a) 

• 91.103 

• 91.119(c) 

• 91.121 

• 91.151(a) 

• 91.203(a) & (b) 

• 91 .405(a) 

• 91.407(a)(1) 

• 91.409(a)(1) & (2) 

• 91.417(a)&(b) 

This exemption application is expressly submitted to fulfill Congress' goal in 

passing Section 333(a) through (c) of the Reform Act This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate 

safely in the national airspace system (NAS) before completion of the rulemaking 

required under Section 332 of the Reform Act In making this determination, the 

Secretary is required to determine which types of UAS do not create a hazard to users 

of the NAS of the public or pose a threat to national security in light of the following: 

• The UAS's size, weight, and operational capability 

• Operation of the UAS in close proximity to airports and populated areas 

• Operation of the UAS within visual line of sight of the operator 
Reform Act§ 333(a). Lastly, 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." ld. §333(c). 

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority by its terms includes exempting civil aircraft, as the 

term defined under §401 01 of the Act, that includes UASs, from the requirement that all 

civil aircraft must have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of 

this title if the Administrator finds the exemption in the public interest. 49 USC §44701 (f) 

See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1). 

Such operations will insure that the UAS will not create a hazard to users of the 

national airspace system or the public. Given the small size of UASs and the 

environment within which they will operate, UAS operations performed by Adam Deets 

will adhere to the Reform Act's safety requirements. Additionally, approval of this 

application presents no national security issues. Based on the substantial level of 

safety surrounding the proposed operations, and the significant public benefit 

(enhanced safety), reduction in environmental impact (reduced emissions and noise), 

the grant of the requested exemption is in the public interest. Accordingly, Adam Deets 

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

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

UASs to be operated: 

• DJI Phantom 3 

• OJ I Phantom 2 

• DJI Inspire 1 

• DJI S1000 

• 3DR Solo 

Listed above are highly successful consumer grade UASs designed to carry a 

high definition (HD) camera powered by four or more electric motors. They utilize an 

internal inertial measuring unit (IMU) with integrated barometric sensor augmented with 

a global positioning system (GPS) to maintain its geospatial orientation and position. It 
is controlled primarily through an FCC certified radio control (RC) unit. Real time video 

and telemetry information is transmitted back to a ground control station allowing the 

operator and/or pilot in command (PIC) to monitor battery level, GPS signal strength, 

altitude (AGL}, distance from PIC, camera imagery, and control camera angle. All are 

equipped with a failsafe mode operation for either loss of RC or GPS signal. Altitude 

can be limited by the onboard flight control system and maximum altitude can be 

preprogrammed by the PIC. The flight controllerliPad will warn the pilot via telemetry 

and external lighting cues before reaching a low battery state. An automatic termination 

of flight and landing will be initiated when the battery reaches a predetermined low 

state. 

All UAS operations conducted by Adam Deets will: 

• Weigh less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). 

• Operate at speeds of no more than 50kts, can hover, and can simultaneously move 

vertically and horizontally. 

• Flights will be operated within line of sight of a pilot(PIC}. 

• Limit each operational flight to 30 min or less. Flights will be terminated at 25% 

battery power reserve should that occur prior to the 30 minute limit. 

• Operated at an altitude of no more than 400 feet AGL. 

• Be operated by a FAA licensed airman with at least a private pilot's certificate and 

third class medical. 

• Be operated at a lateral distance of at least 100 feet from any inhabited structures, 

buildings, vehicles, vessels, or people not associated with the operation or who have 

not signed a waiver in advance of the operation. 

• Require operators (PIC) to check for any Temporary Flight Restrictions (TFR) by 

calling 1800 WX Brief and a current sectional chart for the area of operation to make 

sure they will not violate National Airspace System (NAS). 

• Have the capability to return to a pre-determined location if the UAS loses 

communications or loss of GPS signal. 

• Have the ability to communicate if needed by radio or phone. Operators (PIC) during 

all UAS operation have the local Flight Standards District Offices (FSDO) and the 

closest airport control towers phone number and frequency. 
• Be entered into a flight log. This allows tracking of UAS maintenance and component 

intervals as well as proficiency of PIC, thereby enhancing the safety of the program. 

DISCUSSION OF EXCEPTIONS REQUESTED 

14 C.F.R. § 61.113(a) & (b): Private Pilot Privileges and limitations: Pilot in 

Command 

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. 

Because the UAS will not carry a pilot or passengers, the proposed operations 

can achieve the equivalent level of safety of current operations by requiring the 

pic operating the aircraft to have a private pilot's license rather than a commercial 

pilot's license to operate a small UAS. 

Unlike a conventional manned aircraft, a UAS is remotely controlled by a ground-based 

operator. The operational area is controlled and restricted, and all flights are planned 

and coordinated in advance. The level of safety exceeds that provided by a single 

individual holding a commercial pilot's certificate operating a conventional aircraft. The 

risks associated with the use of a UAS are so diminished from the level of risk 

associated with commercial operations contemplated by Part 61 allowing UAS use by a 

private pilots as the PIC exceeds the present level of safety sought by 14 CFR 

§61.113(a) and (b). 

14 C.F.R. § 91.7(a) Civil aircraft airworthiness 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

Since no FAA regulatory standard exists for determining airworthiness of the UAS, the 

regulation will need an exemption. Compliance with operating documents/operating 

manuals will be sufficient means for determining an airworthy condition. 

14 C.F.R. § 91.103: Preflight Action 

Section 91.103 requires each pilot to preflight an aircraft before flight to insure 

the safety of flight. 
As FAA approved rotorcraft flight manuals will not be used, an exemption is requested. 

However, an equivalent level of safety will be provided. The PIC will take all actions, 

including reviewing weather, flight battery requirements, Notices to Airmen (NOT AM), 

landing and takeoff distances, and aircraft performance data before commencement of 

flight. 

14 C.F.R. § 91.119(c): Minimum Safe Altitudes 

Section 91 .119 establishes safe altitudes for operation of civil aircraft. Section 91. 119 

provides/ in pertinent partl that: 

" ... except when necessary for takeoff or landing/ no person may operate an 

aircraft below the following altitudes: ... 

(b) Over other than congested areas. An altitude of 500 feet above the 

surface/ except over open water or sparsely populated areas. In those 

cases/ the aircraft may not be operated closer than 500 feet to any 

person I vessel/ vehicle/ or structure. II 

Because applicant requests authority to operate at altitudes only up to 400 AGL, an 

exemption is needed to allow such operations. 

14 C.F.R. § 91.121 Altimeter Settings 

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

by reference to an altimeter that is set: 

" ... to the elevation of the departure airport or an appropriate altimeter setting 

available before departure. I I 

As the UAS may not have a barometric altimeter, but instead a G PS altitude read out, 

an exemption is needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the safety checklist and live flight data monitoring, confirming the altitude of 

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

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning: 
"a flight in an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruise 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 UAS provides approximately 30 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be 

limiting factor. Given the limitations on the UAS an exemption may be needed. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless 

it has within the following: (1) an appropriate and current airworthiness certificate. 

(b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization issued 

under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew. 

The UAS fully loaded weight is no more than 55 pounds and is operated without an 

onboard pilot. As such, there is no ability or place to carry certification and registration 

documents or to display them on the UASs. An equivalent level of safety will be 

achieved by keeping these documents at the ground control point where the controller 

(PIC) of the UAS will have immediate access to them, to the extent they are applicable 

to the UAS. 

14 C.F.R. §91,405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner: 

"shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 
have discrepancies repaired as prescribed in part 43 of this chapter .. . ," and 

others shall inspect or maintain the aircraft in compliance with par 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

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

accomplished by the operator pursuant to the flight manual and operating handbook. 

An equivalent level of safety will be achieved because these UAS are very limited in 

size and will carry a small payload. If mechanical issues arise, the UAS can land 

immediately and will be operating from no higher than 400 feet AGL. The operator will 

ensure that the UAS is in working order prior to initiating flight, perform maintenance, 

and keep a log book of any maintenance performed as well as track all flight hours. The 

operators 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. An equivalent 

level of safety will be achieved because maintenance and inspection will be performed 

in accordance with the UAS Manufacturer's Manual, as referenced in the Aircraft 

Operations Manual. As provided in the Operations Manual, the operator will ensure that 

the UAS is in working order prior to initiation flight and perform required maintenance 

needed. 

SUMMARY FOR PUBLICATION 

Applicant seeks an exemption from the following rules: 

14 CFR 61 .113(a) & (b); 91.7(a); 91.1 03; 91.119(c); 91.121; 91.151 (a); 91.405(a); 

91.407(a)(1 ); 91.409(a)(1) and (2); 91.417(a) &(b). To operate commercially 

small unmanned vehicle (551bs or less) in aerial photography and videography, real 

estate photography, aerial surveying and mapping, windmill inspections, cell tower 

inspections, powerline and pipeline inspection and patrolling, wildlife and forestry 

monitoring, search operations, construction inspection, general infrastructure, and 

precision agriculture. 

Approval of exemptions allowing UASs commercial operations in the areas listed 

above will enhance safety by reducing risk. A UAS weighing fewer than 55 lbs. and 

powered by batteries eliminates virtually all of that risk given the reduced mass and lack 

of combustible fuel carried onboard traditional aircraft performing the same function. 

The UAS will carry no passengers or crew and, therefore, will not expose them to the 

risks associated with manned aircraft flights. The operation of small UAS conducted in 

the strict conditions outlined above, will provide an equivalent level of safety supporting 

the grant of the exemptions requested herein, including exempting the applicant from 
the requirements of Part 21 and allowing commercial operations. These UASs operate 

at very low speeds, close to the ground, as a result, are far safer than conventional 

operations conducted with turbine helicopters operating in close proximity to the ground 

and people. 

PRIVACY 

All flights will occur over private controlled areas with the property owner's prior 

consent and knowledge. Filming will be only of people who have given their consent or 

otherwise have agreed to be in the area where filming will take place. Satisfaction of 

the criteria provided in Section 333 of the Reform Act of 2012 (size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security) provide more than adequate justification to 

grant Adam Deets requested exemption. 

If you have any questions or need any additional information, please contact me at 

630-640-4424 or adeetsUAS@gmail.com 

Sincerely, 

Adam Deets