U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 1 of 17

Brian R. Maziarz

88 Emerson Rd. 

Longmeadow, MA 01106 

August 22, 2015 

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 C.F.R. 21 subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a); 14 C.F.R. 91.7(a); 14 

C.F.R. 91.9(b)(2); 14 C.F.R. 91.103; 14 C.F.R. 91.103; 14 C.F.R. 91.119(c); 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)(1) 

and (2); 14 C.F.R. 91.417(a) and (B)

Dear Sir or Madam: 

Pursuant of Section 333 of the FAA Modernization and Reform Act of 2012 (The Reform Act) and 14 

C.F.R. Part 11, Brian Maziarz, Operator of Small Unmanned Aircraft Systems ("sUASs"), hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its 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.

Commercial operation sUASs, as described herein, which are equipped with cameras and sensors, would operate in 

the following manner:

1. Aerial Photography and/or video for public and/or private use including real estate, architecture, land surveying, 

engineering and other related professional activities. Aerial video and/or photography for public and/or private 

use including television, closed-set motion picture, public events, cinematography and news gathering.

2. Aerial Inspection/photography of residential/commercial structures under contract with the owners or local 

authority.

3. Aerial video/photography or providing live video feed to assist with search and rescue operations In cases of an 

emergency or natural disaster only when the local authorities or government has requested It by contract or 

donation.

4. The ability to offer training to persons individually or belonging to both private and/or public organizations that 

have interests in the use and application of sUASs for the purpose of the safe operation of sUASs to enhance the 

safety of the National Airspace System ("NAS") as well as for the protection of the persons or property.
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 2 of 17

As Described fully below the requested exemption would permit the operation of sUASs under controlled conditions 

in the NAS that would be a) Limited b) Controlled c) Predetermined and d) Will provide safety enhancements to the 

already safe operations in the industry presently using conventional aircraft. Approval of this exemption would 

thereby enhance safety and fulfill the Secretary of Transportation's (The FAA Administrators) responsibilities to 

"establish requirements for the safe operations of such aircraft systems in the national airspace system.'' 

The Name and address of the applicant is: 

Attn: Brian R. Maziarz 

Ph: 303-641-1105 

Email: bmaziarz@gmail.com

Address: 88 Emerson Rd. Longmeadow, MA 01106

Regulations from which the exemption is requested:

14 C.F.R. part 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 

14 C.F.R. 91.109

14 C.F.R. 91.119 (c) 

14 C.F.R. 91.121 

14 (.F_R_ 91-151 (a) 

14 C.F.R. 91.203 (a) & (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. 91.417 (a) & (b) 

The Applicants sUASs are multi-rotor craft weighing less than 55lbs. including payload. Under normal conditions 

they operate at speeds of no more than 5Okts and have the ability to hover and move along a vertical and horizontal 

plane simultaneously. They will operate in the line of sight and will operate within a closed off and predetermined 

area owned and/ operated by the property representative. 

Given the small size of the sUASs and the controlled environment provided the proposed operations will adhere to 

the Reform Act's Safety Requirements. The Approval of this Application presents no National Security issues. 

Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental 

impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the 

public Interest. Accordingly the applicant requests that the FAA grant the requested exemption with minimum delay. 
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 3 of 17

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will further 

enhance the safety of the persons and/or property using conventional aircraft. 

These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations 

under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1. The sUASs will weigh less than 55 lbs.

2. Flights will be operated within line of sight of the pilot and/or observer.

3. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery 

power reserve or 30 minutes of flight whichever occurs first.

4. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 

200 feet above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the sUASs Pilot, the Visual Observer (VO) and may include 

but not limited to a Camera Operator/ Technician.

6. The sUASs pilot will be a designated Pilot In Command (PIC) and hold a current Third or Higher Class 

Medical Certificate, along with a valid state driver's license. If the PIC feels another operator to be qualified 

with the necessary skills to be PIC & possess a Third or higher Class Medical and a valid state driver's license, 

that person may be designated PIC provided they have a minimum of 20 hours of flight time with the sUASs.

7. A briefing will be performed regarding the planned sUASs operations prior to each day's flight consisting of 

all the days' production activities.

8. The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the requested exemption, 

with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 

hours from planned operation.

9. The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure 

that only consenting persons will be allowed within the 100 feet of the flight operation, and the radius may be 

reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. With 

the advanced permission of the FSDO, operations at closer range may be approved.

10. The PIC and VO will have been trained in operation of sUASs and receive up-to-date information for the 

particular sUASs to be operated.

11. The PIC and VO will be able to communicate by voice; radio, and/or text at all times.

12. Written and/or verbal permission and permits will be obtained from territorial, state, county, or city 

jurisdictions, including law enforcement, fire or other appropriate governmental agencies.

13. If the sUASs loses communication or loses GPS signal, the sUASs will have the capability to return to a PreDetermined location within a designated location and land autonomously.

14. The sUASs will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 4 of 17

14 C.F.R. Part 21, Subpart l-t: Airworthiness Certificates 14 C.F.R. § 91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, 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 the Applicant, 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 

U.S.C§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificat@1 upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas of the particular sUASs. In all cases, an analysis of these criteria 

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

the conditions proposed will be at least safe, or safer, that a conventional aircraft (fixed wing or rotorcraft) operating 

with an airworthiness certificate without the restrictions and conditions proposed. 

The sUASs to be operated hereunder Is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no 

explosive material or flammable liquid fuels, and operates exdus1vely within a secured and designated area. Unlike 

other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator 

and under the requirements and in compliance with local public safety requirements. The FAA will have advanced 

notice of all operations. These safety enhancements provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 C,F,R, Part 211 

Subpart H. Lastly, application of these same criteria demonstrates that there Is no credible threat to national security 

posed by the sUASs1 due to its size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and Inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capitol letter "N" and the registration number is displayed on limited, 

restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also 

display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more than 6 inches high, the words "limited”, "restricted”, "light· sport”, “experimental”, or Provisional”, as 

applicable. 

Even though the sUASs will have no airworthiness certificate, an exemption may be needed as the sUASs will have 

no entrance to the cabin, cockpit or pilot station on which the word "Experimental" will be placed on the fuselage in 

compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUASs marked on its fuselage as required by §45.29 

(f) where the pilot, observer and others working with the sUASs will see the identification of the sUASs as 

''Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738

10167, and l0167A.
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 5 of 17

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

Pursuant to 14 C.F.R, 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in command 

of an aircraft that is carrying passengers or property for compensation or hire. Our sUASs do not carry any pilots or 

passengers nor property therefore I am seeking an exemption to 14 C.F.R. 61.113 (a) & (b). Although helpful, a 

pilot's license will not ensure remote control piloting skills. Unlike conventional aircraft that carries a pilot and 

passengers, the sUASs is remotely controlled with no persons onboard. The area of operation is controlled and 

restricted; and all flights are planned and coordinated in advance. The risks associated with the operation of the 

sUASs are so diminished from the level of risk associated with commercial operations contemplated by Part 61 

when drafted, that allowing operations as requested with a skilled PIC in the ground crew exceeds the present level 

of safety achieved by 14 C.F.R. §31.113 (a) & (b). The applicant has also been found to be properly qualified to 

exercise the privileges of Commercial Pilot with Rotorcraft-Helicopter and Instrument Helicopter Rating.

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

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be 

no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard 

will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists 

prior to each flight and equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S. registered civil aircraft ... (2) For which an Airplane or 

Rotorcraft Flight Manual is not required by §21.S of this chapter, unless there is available in the aircraft a current 

and approved airplane or rotorcraft flight manual, approved manual material, markings, and placards, or any 

combination thereof. The sUASs, given its size and configuration has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board; but because there is no room or capacity to carry 

such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the 

ground control point where the pilot flying the sUASs will have immediate access to it. The FAA has issued the 

following exemptions to this regulation: Exemption Nos. 8807, 8737, 8738, 9299, 9299A, 9565; 95658, 10167, 

10602, 32827; and 10700 

14 C.F.R. § 91.103: Preflight Action. 

This regulation requires each PIC to take certain actions before flight to insure the safety of flight. As FAA 

approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will

take all actions including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft 

performance data before initiation of flight. Further, we have proprietary manuals created with the help of sUASs 

experts, the manufactures, and the regional sUAS vendor, and continue to work with these organizations to ensure 

best safe practices are adhered to.
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 6 of 17

14 C.F.R. § 91.109: Flight Instruction.

Section 91.103 provides that no person may operate a civil aircraft (except 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. See Exemption Nos. 5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot 

nor passenger will be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. § 91.119: Minimum safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be 

operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route 

or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUASs that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform 

from which filming Is planned, an exemption may be needed to allow such operations. As set forth herein, the 

sUASs is used to survey or photograph a structure whose height exceeds 400 feet AGL, the sUASs will not be 

operated more than 100 feet above the highest point of the structure. It will however be operated in a restricted area 

with a security perimeter; where buildings and people will not be exposed to operations without their pre-obtained

consent.

The equivalent level of safety will be achieved given the size, weight, speed of the sUASs as well as the location 

where it is to be operated. No flight will be taken without the permission of the property owner or local officials. 

Because of the advance notice to the property owner and participants in the filming activity, all affected Individuals 

will be aware of the planned flight operations, Compared to flight operations with aircraft or rotorcraft weighing far 

more than the maximum 55 lbs. proposed herein and the lack of flammable fuel; any risk associated with these 

operations Is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In 

addition, the low-altitude operation of the sUASs will ensure separation between these small sUASs operations and 

the operations of conventional aircraft that must corn ply with Section 91.119.

14 C.F.R. § 91.121: Altimeter Settings.

Section 91.121 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 sUASs 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, confirming the altitude of the launch site 

shown on the GPS altitude indicator before flight. The PIC and technician will also ensure effective pairing with 

multiple GPS sources to guarantee accurate detection of height.
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 7 of 17

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 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 sUASs provides approximately 30 minutes of powered flight in hover mode without 

payload. The applicant’s sUASs will not be able to meet the 30-minute reserve requirement in 14 C.F.R §91.151. 

Given the limitations on the sUASs proposed flight area and the location of its proposed operations within a

predetermined area, a longer flight time frame for flight in daylight or twilight VFR conditions is reasonable. 

Operating the sUASs, in a tightly controlled area where only people and property owners or official representatives 

who have signed waivers will be allowed, with less than 30 minute of reserve power, does not engender the type of 

risks that Section 91.151 (a) was intended to alleviate given the size and speed of the sUASs. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of 

battery power whichever comes first. This restriction would be more than adequate to return the sUASs to its 

planned landing zone from anywhere in its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 2689f, 5745, 10673, and 10808.

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 it 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 to a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance

so that it is legible to passengers and crew.

The sUASs fully loaded weighs no more than 55 lbs 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 sUASs.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the 

pilot flying the sUASs will have immediate access to them; to the extent they are applicable to the sUASs. The FAA 

has issued numerous exemptions to this regulation. A representative sample of other exemptions includes Exemption 

Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 8 of 17

14 C.F.R. § 91.405 (a); 407 (a)(t); 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 chapter 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 section 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, operating 

handbook and maintenance handbook. An equivalent level of safety will be achieved because these sUASs are very 

limited in size and will carry a small payload and operated only in restricted areas for limited periods of time. If 

mechanical issues arise the sUASs can land immediately and will be operating from no higher than 400 feet AGL. 

The operator will ensure that the sUASs is in working order prior to initiating fllght, perform required maintenance, 

and keep a log of any maintenance performed. 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.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance 

with the sUASs Manufacturer's Manual1 as referenced in the Aircraft Operations Manual (AOM). As provided in 

the FOM, the operator will ensure that the sUASs is in working order prior to initiating flight and perform required 

maintenance needed.

*******

Pursuant to 14 C.F.R. Part 11, the following summary is provided for the publication in the Federal

Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.9(b)(2);

91.103(b); 91.109; 91.121; 91.15l(a); 91.203(a) & (b); 91.40S(a); 91.407(a)(1); 91.409(a) (2); and

91.417(a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) in motion picture and television 

operations, as well as in the public and private sector.

Approval of exemptions allowing commercial operations of sUASs lh the film industry will enhance safety by 

reducing risk. Conventional film operations, using jet or piston powered aircraft operate at extremely low altitudes 

just feet from the subject being filmed and in extreme proximity to people and structures; and present the risks 

associated With vehicles that weigh in the neighborhood of 4JOOO lbs., carrying large amounts of Jet A or other 

fuel. (140 gallons for the jet helicopter shown below.) Such aircraft must fly to and from the film location. In 

contrast, a sUASs 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. The sUASs is carried to the film set and not flown. The 

sUASs will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned 

aircraft flights.
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 9 of 17

Privacy

All flights will occur over private or controlled access property with the property owner's or official representative's 

prior consent and knowledge. Filming will be of the people who have also consented to being filmed or otherwise

have agreed to be In the area where filming will take place.

Commercial and Public Benefits

The applicant believes that granting this exemption request furthers the public interest by providing safe (by the way 

of unmanned system) and efficient means to meet technical problems solvable by elevated data collection 

instruments. The applicants client base are typically small to medium sized business' and realtors looking to increase 

their awareness of structures or landscape on their respective properties through data collection by photographic, 

video graphic or LIDAR based surveying. By moving these subjects onto sUASs based aircraft) the potential for 

loss of life or property is diminished due to the greater control in a smaller and safer aircraft that holds no pilot, 

crew, or passengers. Second, there are no reactive or combustible materials on board the sUASs and thus the 

potential for fire or explosion is greatly diminished. Third, the small size and extreme maneuverability of the 

applicant's sUASs allow the PIC to avoid hazards. Lastly due to the nature of the remote sensing instrumentation 

onboard, the sUASs can maintain quite a safe distance between the aircraft and the object(s) undergoing scrutiny.

Accordingly, the Applicants sUASs have operated and will continue to operate at and above current safety levels.

The effect of an exemption for the applicant on the quality of the natural and social environments

Utilizing sUASs minimizes the requirement for conventional aircraft. This eliminates the need for an onboard pilot. 

Time consuming adherence to regulations surrounding bookkeeping and submission of flight paths to local civil or 

military airports, and detrimental effects to the environment caused by operating a combustible fuel_ large scale 

aircraft, with restrictions on the proximity to the target for remote sensing, photography or videography.

Flight Capabilities and Characteristics of the Applicants sUASs

Pursuant to 112 P.L. 95 §333 (a), concerns for public safety are mitigated by the overall capabilities and 

characteristics of the sUASs. *

The Applicant's sUASs utilizes four (4) counter-rotating propellers paired oppositely to each other for balance, 

control and stability. The total span of the sUASs is = 599mm to 589mm including propellers, allowing for stable 

flight or landing even with the sudden onset of detrimental environmental conditions. The sUASs maximum weight 

(including battery, propellers) is 2.9 Kg. The applicant's sUASs is designed to hover in place to capture 

photographic data and then operate at less than 50 knot maximum speed to the next point of Interest. They are 

capable of vertical and horizontal operations but, in practice, is operated only within unaided VLOS of the PIC. In 

addition to the PIC; the Applicant employs a spotter (VOS role) and a technician (secondary VOS and on-site 

personnel liaison), which are within verbal communication range. These personnel are supplemented by safety 

officials provided by the client who are instructed to cordon off and otherwise minimize pedestrian access in the 

flight zone of the client’s grounds. In the event of loss of visual of the sUASs, the PIC can change the flight controls 

from Cartesian (X, Y,Z.) based controls to radial (r,x,h) based control, which allows the PIC to utilize one controller 

axis to recall the sUASs to the PIC's position without concern to the current heading of the sUASs. The sUASs also 

have a Return-to-Home feature that allows the sUASs to return to the PIC's location in the case of the sUASs losing 

signal to the PIC, or if the PIC initiates the Return-to-Home procedure. In the event of loss of sight of the sUASs 

into an area containing hazards or possible hazards, the spotter has a heads-up-display containing a live video feed 

which can be used to locate the sUASs while it maintains its position hover mode. The sUASs has demonstrated its 

ability to maintain its position by GPS, SONAR, and Optical flow camera with an accuracy of 0.5m vertical and 

2.5m horizontal.
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 10 of 17

All of the applicant's sUASs utilize liPo (lithium polymer) battery based power sources, decreasing safety risks from 

more easily combustible, fuel based, power sources. Flight times generally last between eight (8) to ten (10)

minutes, allowing the staff to work with small areas per phase. The maximum flight time with payload is 

approximately 18 minutes; however the applicant further restricts flight time by not operating the sUASs with less 

than twenty five percent (25%) battery capacity.

Reasons Why an Exemption to the Applicant Will Not Adversely Affect Safety Standards

The Applicant contends that operation of its sUASs will not "create a hazard to users of the national airspace system 

or the public." As stated in 112 P.L. 95 § 333(b). Given the diminutive size and weight of the sUASs, combined with 

their operation in cordoned off and well-controlled areas. The applicant's sUASs falls within congress's 

contemplated safety zone. The applicant's sUASs have an established safety record bolstered by multi-point 

preflight checklists, awareness of their surroundings and intimate knowledge and behavior of the sUASs platform in 

many weather conditions. This safety record and implemented operational practices demonstrates an awareness of

public safety. 

The applicant has also been found to be properly qualified to exercise the privileges of 

II COMMERCIAL PILOT

III CERTIFICTE NUMBER (provided upon request)

X DATE OF ISSUE 14 OCT 2006 (original), 2 DEC 2014 (reissued/copy)

XII RATINGS

ROTORCRAFT-HELICOPTER; INSTRUMENT HELICOPTER

XIII LIMITATIONS

NONE

The applicant is extremely familiar with airspace regulations, flight safety, planning, navigation and other topics that 

will ensure safe operations of a sUAS.

The applicant routinely provides a level of safety at least equal to existing rules, and in nearly every instance, 

exceeds existing rules while operating the sUAS. The applicant's sUASs does not and cannot operate on or near 

airports and generally has only operated its fleet on private grounds with cordoned off areas or areas under the 

control of the property owner/ client with assistance by safety officials employed by the business. The applicant 

determines the areas needed to fulfill the clients goals and only operates its sUASs in these flight zones and only in 

compliance with well-regarded safety protocols set forth initially by the RC sUASs trade and hobby groups and 

recently codified by relevant FAR's.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-sl2e, weight, speed, operating 

capabilities, proximity to airports and populated area and operation within visual line of site and national securityprovide more than adequate justification for the grant of the requested exemptions allowing commercial operation of 

the applicant's sUASs in the real estate, architecture, land survey/ engineering, motion picture and television 

industry pursuant to the manuals appended hereto.

Sincerely,

Brian Maziarz

Encl: Supplement A: Physical Characteristics./ Specifications of sUASa (3 pages)

Encl: Supplement B: Flight operations and procedures Manual (FOPM) related to operation (3 pages)

Encl; Supplement C: Inspire 1 Safety Guidelines v1.0

Supplemental A: Physical Characteristics/ Specifications of sUASs Page 1
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 11 of 17

Supplemental A: Physical Characteristics/ Specifications of sUASs Page 2
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 12 of 17

Supplemental A: Physical Characteristics/ Specifications of sUASs Page 3
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 13 of 17

Supplemental A: Physical Characteristics/ Specifications of sUASs Page 3
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 14 of 17
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 15 of 17

Supplemental B: Summary Sections of Flight Operations and Procedure Manual (FOPM) Page 1

I. Introduction

This manual describes the notable roles, tasks, and operations performed by the applicant Brian Maziarz. 

II. Roles and Responsibilities

Pilot in Command (PIC)

 Piloting the sUASs. This will Include:

o Takeoff

o Normal flight

o Flight during emergency procedures

o Landing

 Assembling the sUASs

 Performs pre-flight checks of the firmware

 Performs pre-flight checks of the hardware

 Performs preflight checks of the software

Spotter

 Relays notable flight parameters such as flight time battery strength, and telemetry from the sUASs.

 Primary communication between pilot and on-site safety personnel

 Will hold physical documents related to current flight

 Performs pre-flight checks of the data collection equipment

 Monitors ground and above-ground environment for safety concerns

Technician

 Assembling the sUASs

 Preforms pre-flight checks of the hardware

 Preforms pre-flight checks of the software

 Secondary communication link between pilot and onfts1te safety personnel

 Relays to the spotter and records notable flight data telemetry from the sUASs

 Monitors ground and above-ground environment for safety concerns

III. Pre-Flight Check List

A. Before power is applied

 Check for physical damage and any missing hardware

 Check all electronics present end connected/ check cord connections are tight

 Confirm all batteries are charged

 Check all rotors and moving parts for debris that would prevent proper operation

 Check weather patterns the night beforehand.

 Check all data collection equipment for proper Installation/operation

 Check all data collection equipment for issues that would impact safe operations of flight package.
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 16 of 17

Supplemental B: Summary Sections of Flight Operations and Procedure Manual (FOPM) Page 2

B. After power source is applied

 Confirm proper power reading of battery

 Run hardware based systems check

 Run software based systems check

 Check flight LED array

 Confirm proper radio link to flight controller

 Confirm proper radio link to data collection device controller

 Confirm secondary controller connection to sUASs onboard flight controller

 Confirm desired behavior of emergency fail safes

 Check with on-site safety personnel for any changes in plan

IV. Run-Up Checklist

 Check with on-site personnel for safe flight area for first flight

 Record relevant metrics in flight log

 Check for ground hazards at home base

 Confirm GPS lock

 Confirm initial state of controllers

 Initialize rotors and check for proper operation

 Check landing gear flight mode (up) operation

 Perform controlled multi-axis roll procedure to check for proper orchestrated rotor operation

 Hover check

 Return sUASs to normal orientation

 Perform controlled flight to hover mode one (1) meter above the ground

 Check landing gear landing mode (down) operation

 Land the sUASs and check for proper de-initialization of rotors

 Perform controlled flight to hover mode approximately five (5) meters above the ground

 Check landing gear flight mode (up) operation

 Return sUASs to normal orientation

 Remove power to the flight package

 Remove power to the data collection package

 Remove power to controllers

 Complete flight log

V. Standing Procedures

 The Pilot, Spotter, and Technician will be the only members in the forward flight area. On-site personnel 

will be within verbal range behind the PIC, Spotter, and Technician

 The maximum power used to control the device is soft limited to 75% in order to maintain power in reserve 

for unforeseen conditions

 Flight time is limited to reserving 25% battery power

 Flight height is soft limited to visible and unaided line of sight (VLOS), and hard limited to 400ft. AGL

 Flight time is limited to operation in safe environmental conditions

 Flight staff will maintain proximity so as to be in dear verbal range

 The PIC will announce all movements to staff and on-site staff so that non-PIC staff members can identify 

possible safety concerns before operation of the sUASs to the next waypoint or position

 All regular and irregular operations are noted with timestamps, relevant sUASs metrics and corrective 

action procedures (CAP) that are performed

o Note: All irregular behavior have root cause analysis performed before sUASs operation is 

resumed
U.S.	Department	of	Transportation

August	22,	2015

Brian	Maziarz

88	Emerson	Rd.	Longmeadow	MA,	01106

bmaziarz@gmail.com 303-641-1105

Page 17 of 17

Supplemental B: Summary Sections of Flight Operations and Procedure Manual (FOPM) Page 3

VI. Emergency procedures

 Loss of Remote Signal

o The flight package features an optional enhanced fail-safe which returns the sUASs to the home 

base way point or the operator controller by climbing to an altitude above the highest obstacle but 

not to exceed airspace limitations and will then return to home direct line of site. 

o The sUASs will then perform a hover over the home point or controller and perform a controlled 

landing

o This failsafe mode can be overridden by the PIC if the signal returns

 Loss of GPS signal

o The system will operate in GPS mode with three (3) satellites

o At loss of three (3) GPS satellites, manual mode can be activated and the flight package can be 

programmed to perform a controlled landing to the home point.

o Ground based height ranging is performed by separate system and so loss of GPS will not impact 

controlled landing in a safe manner

 Loss of Ground Control Software

o This will not affect operation of the flight. The unit will be piloted to a safe landing area so that 

examination of the link can be made.