*Please note, there was a decision inserted in my docket that doesn’t belong there. This response is 

from:

AirCam Photography

Tippon Chandler Weiss

798 Lighthouse #232

Monterey, Ca 93940

This is a follow up to my petition for exemption posted to the public docket on December 2, 2014, 

Docket No. FAA-2014-1006 in your request for more information to comply with the requirements of 

§11.81 for your consideration.

Specific section or sections of 14 CFR from which I seek relief and the reason I seek relief:

Part 21; and

§§ 45.23(b);

91.7(a); 91.9(b)(2); 91.103(b);

91.119; 91.121, 91.151(a);

91.203(a) & (b); 91.405(a); 91.407(a)(1);

91.409(a)(2); and 91.417(a) & (b) of

Title 14, Code of Federal Regulations

Part 21 91.203(a) & (b)

Given the size, weight, speed, and limited operating area associated with the aircraft to be

utilized by him, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates)

subject to certain conditions and limitations, is warranted and meets the requirements for

an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 (Section

333).

45.23

Marking of the aircraft because UA will not have a cabin, cockpit or pilot station on which to

mark certain words or phrases. Further, two-inch lettering is difficult to place on such a

small aircraft with dimensions smaller than the minimal lettering requirement.

Will mark UAS in the largest possible lettering by placing the word “experimental” on its fuselage as

required by § 45.29(f) so that anyone assisting him as a spotter will see the markings.

91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b)

Maintenance inspections may be required and should be granted since they only apply to

aircraft with an airworthiness certificate. However as a safety precaution user will perform a

preflight inspection of his UAS before each flight as outlined in his operating documents

and follow manufacture maintenance recommendations as stated in UA user manual.

91.7(a) 

prohibits the operation of an aircraft without an airworthiness certificate.

There is currently no certificate applicable to this operation, this regulation is inapplicable.

91.9(b)(2) 

requires an aircraft flight manual in the aircraft, however since there are no pilots

or passengers on board his aircraft and given its size, this regulation is inapplicable. An

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

UAS ground station.

91.103(b)

The PIC will take all actions including reviewing weather, flight battery requirements,

landings, and takeoff distances and aircraft performance data before initiation of flight.
Stricter requirements with regard to visibility and distance from clouds; this is to both keep

the UA from departing the VLOS and to preclude the UA from operating in the NAS. Sun

glare will be taken into account. PIC’s and VO’s ability to still see other air traffic, combined

with the PIC’s ability to initiate a return-to-home sequence, are sufficient mitigations. The

PIC will also account for all relevant site-specific conditions in his or her preflight

procedures.

91.119

Prescribes safe altitudes for the operation of civil aircraft, but that it allows helicopters to be

operated at lower altitudes in certain conditions. UAS will not be operated above the

altitude of 400 feet above ground level (AGL) and will also only operate in safe areas away

from the public and traffic, thus “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 the UAS, an equivalent or higher level of safety will be achieved.

91.121

Altimeter settings is inapplicable since he UAS utilizes electronic GPS with a barometric

sensor. Sensor is calibrated before flight and reads AGL altitudes.

91.151 (a)

Fuel requirements for flight in VFR conditions, prior relief has been granted for manned

aircraft to operate at less than prescribed minimums, including Exemption Nos. 2689, 5745,

and 10650. In addition, similar UAS-specific relief has been granted in Exemption Nos.

8811, 10808, and 10673 for daytime, VFR conditions. The UAS will land prior to the

manufacturer’s recommended minimum level of battery power (30%). The operating

documents indicate that the low battery level failsafe is triggered when the battery is

depleted to a point that may affect the safe return of the aircraft. Users are to return home

or land the aircraft immediately when these warnings are shown. Pilot ground station will

advise user to return the aircraft to the Home Point when low battery warning is triggered.

Aircraft will automatically return to home point if no action is taken after 10 second

countdown. User can cancel the return to home any time. The thresholds for these

warnings are automatically determined based on the current aircraft altitude and its

distance from home point.

Aircraft will land automatically if the current battery level can only support the aircraft to

land to the ground from the current altitude. User can use ground station to control the

aircraft during landing process.

How my request will benefit the public as a whole:

I would gladly offer my services upon request and with proper coordination and appropriateness to any 

official search and rescue or emergency services organization to benefit the public. Agricultural and 

crop inspection could substantially decrease water usage and increase efficiency in the industry by 

identifying troubled areas and waste. This would greatly benefit the public as we have been in a water 

drought on the West Coast for the last three years. Aerial videography for geographical awareness, 

agricultural applications, and marketing has been around for a long time through manned fixed wing 

aircraft and helicopters. Although they have been operated in an extremely safe manner, my UASs pose 

much less risk since the small size and lack of combustible fuel greatly reduces the 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 AirCam 

Photography’s exemption request furthers the public interest through academic/visual awareness of the 

geographical benefits in and around the Monterey Bay area. My light weight UAS is battery powered 

and creates no emissions that can harm the environment. The consequence of my light weight UAS 
crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible 

fuel and can cause catastrophic devastation to the public. 

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial 

video/photo capture through my battery operated light weight UAS's.

The reasons why the exemption would not adversely affect safety or how the exemption would 

provide a level of safety at least equal to existing rule:

My, Tippon Chandler Weiss’s, exemption will not adversely affect safety. Quite the contrary, for the 

reasons stated permitting me, Tippon Chandler Weiss, to log more flight time in FAA controlled airspace 

will allow me to contribute to the innovation and implementation of new and novel, as of yet 

undiscovered safety protocols for UAS operators.

 I generally operate my UAS below 200 feet AGL (well within the 400 foot permissible ceiling set 

by the FAA Modernization and Reform Act of 2012)

 I don’t operate within 5 miles of an airport unless prior contact to Air Traffic Control or the 

airport manager has been made. I determine this distance with GPS using a pilot’s app called 

Foreflight on the Apple Ipad or Iphone.

 I land my UAS prior to manufacturer recommended minimum level of battery power

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

 My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position

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

 I only operate in reasonably safe environment that are strictly controlled, are away from power 

lines, 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; and,

 I have procedures in place to abort flights in the event of safety breaches or potential danger. 

My, Tippon Chandler Weiss’s, safety protocols (see attached) 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, inspections, crop management, and real estate. While the safety record of such 

helicopters is remarkably astounding, it is far safer to operate a battery powered UAS. First, the 

potential loss of life is diminished because UAS's carry no people on board and I only operate 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. Accordingly, my 

UAS has been experimentally operated for familiarization/competency and will continue to operate at 

and above current safety levels.

Additional Information:
The bulk of our aerial operations will be using the DJI Phantom 2 with Gimbal (3 pounds) and the DJI 

Inspire 1 (6.5 pounds)

Using the same safety protocols as outlined and found in our Safety Protocol Manual (Separate 

document) for the DJI Phantom 2 and DJI Inspire 1 and an additional camera operator/observer, we 

would like to have the option of employing the DJI S900, a six (6) rotor multirotor UAS with GH4 Gimbal 

or similar variants(16.5 pounds). We feel we can operate all 3 UAS platforms with utmost safety without 

putting the general public or manned aircraft at risk. As noted in exemption 11138 for Douglas Trudeau, 

Realtor, the minimum separation between the public and his operations is 150 feet for his 3 pound DJI 

Phantom 2. We feel this is a safe minimum distance but if it is deemed that it needs to be larger, we 

would like to at least have the option of operating our DJI Phantom 2 at 150 feet or greater and the 

larger separation distance to apply to our DJI Inspire and/or DJI S900.

10 Additional documents submitted as proprietary information.

Sincerely, 

Tippon Chandler Weiss

AirCam Photography