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January 12, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Request for exemption from multiple regulatory provisions to allow the use of small

unmanned aerial systems over land controlled by employees of Unmanned Aerial Solutions (AMS) to 

assist in the safe capture of video, images, and surveying of persons and property for commercial use.

Dear Sir or Madam

Unmanned Aerial Solutions (AMS) pursuant to the FAA Modernization and Reform Act of 2012 

respectfully requests exemption from several provisions of the Federal Aviation Regulations (“FAR”), 

specifically portions of 14 C.F.R. Parts 45, 61, and 91 to allow, commercial operations of its unmanned 

aerial system in remote, rural, and closed production sets, areas of the United States, as further defined 

herein, by a Pilot in Command holding an Airline Transport pilot certificate, and the Unmanned Aerial 

Solutions Flight Operations Manual.

Brian Walk, and his company Unmanned Aerial Solutions, is an experienced FAA Air Transport Pilot. 

Mr. Walk is currently responsible for a single aircraft IS-BAO stage II private flight department. Mr. 

Walk has extensive knowledge and respect for the F.A.R.s that govern and certify manned aircraft. Mr. 

Walk has been an avid R/C model flyer for over twenty years. Brian Walk, Unmanned Aerial Solutions

have been actively involved in the technical development of UAV/UAS service applications to provide 

high definition video, Near Infrared and surveying capability with small unmanned and light weight 

UASs. Unmanned Aerial Solutions exemption request would permit its operation of lightweight, 

unmanned (remotely controlled in line of sight) UASs in tightly controlled and limited airspace. 

Predetermined, specifically marked areas of operation, cordoned off locations and corresponding 

enhancements to current safety controls will allow Unmanned Aerial Solutions to operate within current 

safety parameters and new ones being implemented. As identified, similar lightweight, commercially 

available remote controlled UASs are legally operated by amateurs with no flight experience, or practices 

in place to prevent accidents or incidents from occurring. Unmanned Aerial Solutions will employ fully 

licensed and current pilots that are also experts in the flight characteristics of the UAS/UAV in which 

Unmanned Aerial Solutions operates. 

Granting Unmanned Aerial Solutions requests furthers the Secretary of Transportations responsibility and 

authority to not only integrate UAS’s into the national airspace system, but to “... establish requirements 

for the safe operation of such aircraft systems [UAS] in the nation airspace system” under section 333(c) 

of the Reform Act, specific to the use of UAS’s for high definition video and Near Infrared scientific 

purposes. Unmanned Aerial Solutions will conduct operations in compliance with the protocols 

described herein or as otherwise established by the FAA.
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I. Contact Information

Brian M. Walk

Unmanned Aerial Solutions

2 North Street, Suite 2A

Waldwick, NJ 07463

Mobile: 201-259-2343

Email: Brian@brianwalk.com

II. Specific Section of the Title 14 Code of Federal Regulations from which Unmanned Aerial 

Solutions requests exemption are:

14 CFR 21;

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

14 CFR 61.113 (a) & (b);

14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and,

14 CFR 417 (a) & (b).

III. The extent of the relief Unmanned Aerial Solutions seeks and reasons for relief.

Unmanned Aerial Solutions will operate as safely as possible, taking every precaution to minimize risk to 

the NAS or to persons and property on the ground. Brian Walk, is an experienced FAA Air Transport 

Pilot. Mr. Walk is currently responsible for a single aircraft IS-BAO stage II private flight department. 

Mr. Walk has extensive knowledge and respect for the F.A.R.s that govern and certify manned aircraft. 

Mr. Walk has been an avid R/C model flyer for over twenty years Brian Walk and Unmanned Aerial 

Solutions exemption will not adversely affect safety to persons or property by following the strict 

guidance set forth by its procedures and the operator’s years of experience. By allowing Unmanned 

Aerial Solutions to operate, Unmanned Aerial Solutions pilots will be able to gain valuable real world 

experience that is unattainable any other way. Much like operating a commercial or corporate aircraft. 

Experience is gained through practical and safe real world experience. With this experience Unmanned 

Aerial Solutions will develop existing techniques and protocols, as well as develop new ones. In 

addition, Unmanned Aerial Solutions submits its Flight operations Manual attached to this Exemption 

Request. Included in the Unmanned Aerial Solutions Flight Operations Manual.

- Pilot in Command Qualifications and duties

- Second in Command Qualifications and duties

- Spotter qualifications and duties

- FAA Medical Requirements

- Pilot currency requirements

- Crew Resource Management objectives 

- Safety Management System

Unmanned Aerial Solutions strives to provide a level of safety that exceeds the existing regulations. 

Unmanned Aerial Solutions strives to operate its UAS/UAV as closely and within practicality to the 

already proven safe F.A.R.s. It is significantly safer to operate a battery powered lightweight UAS 

piloted by FAA licensed pilots than the current helicopter based aerial cinematography systems. First, and 

foremost the potential loss of life is zero because UASs do not carry an on board crew and Unmanned 

Aerial Solutions only operates them in specific areas away from dense populations. UAS are battery 

powered, carrying no flammable liquids, thus the potential for fire or explosions is greatly diminished. 

Third, the small size and extreme maneuverability of Aerial Media Systms UASs allow our remote 

control pilots to avoid hazards. Given their small size and weight, they pose less of an environmental and 
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noise impact than conventional manned helicopter based systems available today. Unmanned Aerial 

Solutions UAS systems produce less noise than ground power units used to power small corporate 

aircraft. Thus reducing the acoustic footprint.

• Unmanned Aerial Solutions UASs weigh less than 55 pounds Max Tax off Weight

• Unmanned Aerial Solutions only operates its UASs below 400 feet;

• Unmanned Aerial Solutions UASs only operate for 5-25 minutes per flight;

• Unmanned Aerial Solutions lands its UASs when they reach 30% battery power;

• Unmanned Aerial Solutions remote control pilots operate Unmanned Aerial Solutions UASs

by line of sight;

• Unmanned Aerial Solutions remote control pilots have video backup should they somehow

lose sight of the UAS;

• Unmanned Aerial Solutions staffs each flight with a remote control pilot, technician and

spotter with communication systems enabling real time communication between them;

• Unmanned Aerial Solutions UASs have GPS flight modes whereby they hover and then

slowly land if communication with the remote control pilot is lost or battery power is

below 30%;

• Unmanned Aerial Solutions actively analyses electronic flight data and other sources of

information to constantly update and enhance safety protocols;

• Unmanned Aerial Solutions only operates in secured areas that are strictly controlled, are

away from airports and populated areas;

• Unmanned Aerial Solutions conducts extensive briefing prior to flight, emphasizing safety.

Unmanned Aerial Solutions recognizes there is always a potential hazard to those on the ground. These 

people will be protected by the fact that the no one will be allowed entry into the operations area without 

prior permission. Security will be established for the operations area as part of the pre-flight inspections. 

Each person within the operations area will be briefed about the UAS system’s flight and give consent to 

be in the operations area.

Unmanned Aerial Solutions UASs utilizes four or eight counter-rotating propellers for balance, control 

and stability in all segments of flight. Each craft weighs less than 55 pounds, including cinematic or other 

research equipment. Each of Unmanned Aerial Solutions small unmanned aircraft are designed to 

primarily hover in place and operate at less than a 50 knot maximum speed. They are capable of vertical 

and horizontal operations but operate only within the line of sight of the remote control pilot. In addition 

to the remote control pilot, Unmanned Aerial Solutions uses a spotter/ Second in Command and a 

technician, such that, at minimum, three Aerial Medial Systems personnel govern the safe flight of an 

Unmanned Aerial Solutions aircraft at all times. Utilizing battery power and not combustible fuels, flights 

generally last between five and twenty minutes. Unmanned Aerial Solutions does not operate its UASs 

with less than 30 percent battery capacity. Safety systems in place include a GPS mode that allows 

Unmanned Aerial Solutions UASs to hover in place if communication with the radio control pilot is lost 
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and then slowly descend the UAS at 30 percent battery capacity. Unmanned Aerial Solutions aircraft are 

programmed, in some instances, to slowly follow a predetermined set of waypoints to return to a safety 

point predetermined by the Pilot-In-Command if communications are lost.

Unmanned Aerial Solutions will not operate its UASs within 5 miles of airports and will not

operate them over uncontrolled populated areas. The UAS operating software and GPS navigation 

systems do not allow any of the Unmanned Aerial Solutions UAS vehicles to operate near airports or 

FAA mandated no-fly zones. In the event an operation needs to be conducted closer to an airport, 

Unmanned Aerial Solutions will inform the airport operator and airport air traffic control tower of the 

contemplated operation and will comply with any directions issued by air traffic control at that airport 

Unmanned Aerial Solutions only operates its UASs in predetermined areas and only in compliance with 

safety protocols such as those contained within the its own Flight Operations Manual. Unmanned Aerial 

Solutions Flight Operations Manual is tailored to UAS flight, and as closely as practical follows 

guidelines set forth for the operation of the multi-crew manned aircraft.

Unmanned Aerial Solutions operation of its small unmanned aircraft will not "create a

hazard to users of the national airspace system or the public." 112 P.L. 95 § 3 3 3 (b). Given the

small size and weight of Unmanned Aerial Solutions UASs, combined with their operation in cordoned 

off and well-controlled areas, Unmanned Aerial Solutions flight operations fall within Congress's 

contemplated safety zone when it disseminated the Reform Act and the corresponding directive to 

integrate UASs into the national airspace system. Unmanned Aerial Solutions UASs have a demonstrable 

safety record and do not pose any threat to the general public or national security.

IV. How Unmanned Aerial Solutions request will Benefit the public as a whole:

Granting Unmanned Aerial Solutions exemption request furthers the public interest in many ways.

Congress has pronounced that it is in the public's interest to integrate commercially flown UASs into the 

national airspace system. Unmanned Aerial Solutions will conduct research into safe UAS operations 

every time it flies one of its UASs. Flight data, visual inspections, recorded observations and flight 

analyses are compiled to further enhance current safety procedures. Unmanned Aerial Solutions intends 

on using their Near Infrared technology to work with golf courses to reduce and more efficiently use 

pesticides and water resources. This furthers the public interest by reducing the amount of chemicals put 

into the ground as well as precious fresh water supplies. Allowing Unmanned Aerial Solutions to provide 

high definition video of real estate for sale, will bring a non-invasive and non-dramatic use of UAS into 

the public’s everyday life. Unmanned Aerial Solutions believes that by seeing a UAS used in small 

applications will promote a positive view towards UASs, instead of historically known military 

applications. Unmanned Aerial Solutions also believes that UAS used for real estate will be beneficial to 

its local economy by offering a different and unique view to properties that would otherwise go 

unnoticed. 

Allowing Unmanned Aerial Solutions to fly commercially, will allow real world experience to help 

develop better and more robust safety procedures. The public has an interest in reducing the danger and 

emission associated with current aerial cinematic capture methods, namely, full size helicopters. 

Unmanned Aerial Solutions UASs are battery powered and create no emissions. If an Unmanned Aerial 

Solutions UAS crashes, there is no fuel to ignite and cause significant damage or injury. The impact of 

Unmanned Aerial Solutions lightweight UASs is far less than a full size helicopter or current aerial 

platforms. Although, the noteworthy safety record of full size helicopters used in the motion picture 

industry currently is impeccable. The public's interest is furthered, by minimizing ecological and crash 

impacts, by permitting motion picture capture through Unmanned Aerial Solutions lightweight UASs. 

Aerial Medial Systems has been analyzing flight data and other information into novel safety protocols. 

These procedures and lessons will be implemented into flight operations manual that exceeds currently 
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accepted means and methods of safe flight. Unmanned Aerial Solutions and Brian Walk through years of 

command experience on large cabin corporate aircraft, have based their Flight operations manual off of an

IBAO stage II manual for a manned aircraft, of which Brian Walk is the author of. Congress mandated the 

integration of UASs into our national airspace system, in part, to achieve progression in this field. 

Permitting Unmanned Aerial Solutions to immediately fly within the United States furthers these goals. 

Whether it is the scientific discoveries applicable to feature film making to advancements in publicly 

usable technologies, or advancements in equipment available to law enforcement personnel I first 

responders that does not cost millions of dollars.

V. Reasons Why Unmanned Aerial Solutions Exemption Will Not Adversely Affect Safety 

Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing 

Rule:

Unmanned Aerial Solutions strives to provide a level of safety that exceeds the existing regulations. 

Unmanned Aerial Solutions strives to operate its UAS/UAV as closely and within practicality to the 

already proven safe F.A.R.s. It is significantly safer to operate a battery powered lightweight UAS 

piloted by FAA licensed pilots than the current helicopter based aerial cinematography systems. First, and 

foremost the potential loss of life is zero because UASs do not carry any crew and Unmanned Aerial 

Solutions only operates them in specific areas away from dense populations. UAS are battery powered, 

carrying no flammable liquids, thus the potential for fire or explosions is greatly diminished. Third, the 

small size and extreme maneuverability of Aerial Media Systms UASs allow our remote control pilots to 

avoid hazards. Given their small size and weight, they pose less of an environmental and noise impact 

than conventional manned helicopter based systems available today. Unmanned Aerial Solutions UAS 

systems produce less noise than ground power units used to power small corporate aircraft. Thus reducing 

the acoustic footprint.

• Unmanned Aerial Solutions UASs weigh less than 55 pounds Max Tax off Weight

• Unmanned Aerial Solutions only operates its UASs below 400 feet;

• Unmanned Aerial Solutions UASs only operate for 5-25 minutes per flight;

• Unmanned Aerial Solutions lands its UASs when they reach 30% battery power;

• Unmanned Aerial Solutions remote control pilots operate Unmanned Aerial Solutions UASs

by line of sight;

• Unmanned Aerial Solutions remote control pilots have video backup should they somehow

lose sight of the UAS;

• Unmanned Aerial Solutions staffs each flight with a remote control pilot, technician and

spotter with communication systems enabling real time communication between them;

• Unmanned Aerial Solutions UASs have GPS flight modes whereby they hover and then

slowly land if communication with the remote control pilot is lost or battery power is

below 30%;

• Unmanned Aerial Solutions actively analyses electronic flight data and other sources of

information to constantly update and enhance safety protocols;
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• Unmanned Aerial Solutions only operates in secured areas that are strictly controlled, are

away from airports and populated areas;

• Unmanned Aerial Solutions conducts extensive briefing prior to flight, emphasizing safety.

Unmanned Aerial Solutions recognizes there is always a potential hazard to those on the ground. These 

people will be protected by the fact that the no one will be allowed entry into the operations area without 

prior permission. Security will be established for the operations area as part of the pre-flight inspections. 

Each person within the operations area will be briefed about the UAS system’s flight and give consent to 

be in the operations area.

Unmanned Aerial Solutions UASs utilizes four or eight counter-rotating propellers for balance, control 

and stability in all segments of flight. Each craft weighs less than 55 pounds, including cinematic or other 

research equipment. Each of Unmanned Aerial Solutions small unmanned aircraft are designed to 

primarily hover in place and operate at less than a 50 knot maximum speed. They are capable of vertical 

and horizontal operations but operate only within the line of sight of the remote control pilot. In addition 

to the remote control pilot, Unmanned Aerial Solutions uses a spotter/ Second in Command and a 

technician, such that, at minimum, three Aerial Medial Systems personnel govern the safe flight of an 

Unmanned Aerial Solutions aircraft at all times. Utilizing battery power and not combustible fuels, flights 

generally last between five and twenty minutes. Unmanned Aerial Solutions does not operate its UASs 

with less than 30 percent battery capacity. Safety systems in place include a GPS mode that allows 

Unmanned Aerial Solutions UASs to hover in place if communication with the radio control pilot is lost 

and then slowly descend the UAS at 30 percent battery capacity. Unmanned Aerial Solutions aircraft are 

programmed, in some instances, to slowly follow a predetermined set of waypoints to return to a safety 

point predetermined by the Pilot-In-Command if communications are lost.

Unmanned Aerial Solutions will not operate its UASs within 5 miles of airports and does not

operate them over uncontrolled populated areas. The UAS operating software and GPS navigation 

systems do not allow any of the Unmanned Aerial Solutions UAS vehicles to operate near airports or 

FAA mandated no-fly zones. In the event an operation needs to be conducted closer to an airport, 

Unmanned Aerial Solutions will inform the airport operator and airport air traffic control tower of the 

contemplated operation and will comply with any directions issued by air traffic control at that airport

Unmanned Aerial Solutions only operates its UASs in predetermined areas and only in compliance with 

safety protocols such as those contained within its own Flight Operations Manual. Unmanned Aerial 

Solutions Flight Operations Manual is tailored to UAS flight, and as closely as practical follows 

guidelines set forth for the operation of the multi-crew manned aircraft.

Aerial Medial Systems operation of its small unmanned aircraft will not "create a

hazard to users of the national airspace system or the public." 112 P.L. 95 § 3 3 3 (b). Given the

small size and weight of Unmanned Aerial Solutions UASs, combined with their operation in cordoned 

off and well-controlled areas, Unmanned Aerial Solutions flight operations fall within Congress's 

contemplated safety zone when it disseminated the Reform Act and the corresponding directive to 

integrate UASs into the national airspace system. Unmanned Aerial Solutions UASs have a demonstrable 

safety record and do not pose any threat to the general public or national security.

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.
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14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements

for procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The 

size, weight and enclosed operational area of Unmanned Aerial Solutions, UAS permits 

exemption from Part 21 because our UAS meets (and exceeds) an equivalent level of safety 

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 

of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability 

and proximity to areas such as airports and dense populations. Unmanned Aerial Solutions, 

current and projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board 

pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. 

10 The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 

8737,8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 

91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global 

positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and

registrations. They are inapplicable for the same reasons described above. The equivalent level of 

safety will be achieved by maintaining any such required certifications and registrations by 

Unmanned Aerial Solutions.

B. 4 C.F.R. § 45.23: Marking of the Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. Unmanned Aerial Solutions sUAS are, by definition, unmanned. They therefore do 

not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, twoinch lettering is difficult to place on such small aircraft with dimensions smaller that minimal 

lettering requirement. Regardless, I will mark its UASs in the largest possible lettering by placing 

the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 (f) so that I the 

pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has 

previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A 

and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations:

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

operations Unmanned Aerial Solutions, can achieve an equivalent level of safety as achieved by

current Regulations because my UAS does not carry any pilots or passengers. Further, while 

helpful, a pilot license will not ensure remote control piloting skills. The risks

attended to the operation of my UAS is far less than the risk levels inherent in the commercial 

activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing, Unmanned Aerial Solutions, to 

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

D. 14 C.F.R. 91.119: Minimum Safe Altitudes.
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14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows

helicopters to be operated at lower altitudes in certain conditions. My UAS will never

operate at an altitude greater than 200 AGL; safely below the standard of 400 AGL. Unmanned 

Aerial Solutions, will however operate its UAS in safe areas away from public and

traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe 

altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of 

safety will be achieved.

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

10 Appendix E - Safety/Flight Manual

The above-cited Regulations require, amongst other things, aircraft owners and

operators to “have [the] aircraft inspected as prescribed in subpart E of this part and Shall between 

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

prescribed in part 43 of this chapter. . . .” These Regulations only apply to aircraft with an airworthiness 

certificate. They will not, therefore, apply Unmanned Aerial Solutions UAS. However, as a safety 

precaution Unmanned Aerial Solutions will inspect its

UAS before and after each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14

C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H,

entitled Airworthiness Certificates, sets forth requirements for procurement of necessary

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and

enclosed operational area of Unmanned Aerial Solutions UAS permits exemption from Part 21 because 

Unmanned Aerial Solutions, UAS meets an equivalent level of safety pursuant to Section 333 of the 

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of

the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the

airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and 

proximity to areas such as airports and dense populations. Unmanned Aerial Solutions UAS meets or 

exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation

of an aircraft without an airworthiness certificate. As no such certificate will be

applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no

pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An

equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued 

exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

maintenance program that involves regular software updates and curative measures for any damaged 

hardware. Therefore, an equivalent level of safety will be achieved.

In summary Unmanned Aerial Solutions seeks an exemption from the following

Regulations:

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

C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 

14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 

14 C.F.R. § 91.409 (a)(2); 14 C.F.R. §91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially 

operate Unmanned Aerial Solutions’, small unmanned vehicle/lightweight unmanned aircraft vehicle in 
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favorable, safe community awareness projects, Near Infrared spectrographic analysis, real estate 

operations, and small event photography. Currently Near Infrared spectrograph/videography/photography 

relies primarily on the use of larger aircraft running on combustible fuel flying low. Posing potential risk 

to the public. Granting Unmanned Aerial Solutions, request for exemption will reduce current risk levels 

and thereby enhance safety. Unmanned Aerial Solutions UAS craft do not contain potentially explosive 

fuel, is smaller, lighter and more maneuverable than conventional video and photographic aircraft with 

much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential 

public risk flying to and from established air fields. Unmanned Aerial Solutions has written and will work 

on refining current safety protocols, and flight manuals that exceed currently accepted means and 

methods for safe flight. Formal collection of information shared with the FAA will enhance the FAA's 

internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 

2012. There are no personnel on board Unmanned Aerial Solutions UAS and therefore the likelihood of 

death or serious bodily injury is significantly diminished. Unmanned Aerial Solutions’, operation of my 

UAS, weighing less than 55 pounds and travelling at lower speeds within limited areas will provide an 

equivalent level of safety as that achieved under current FARs. Unmanned Aerial Solutions respectfully 

request that the FAA grant it’s exemption.

Sincerely,

Brian M. Walk