April 5, 2014

United States Department of Transportation Docket Management System 1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam: I am writing pursuant to the FAA Modernization and Reform Act of 20121 (the 

“Reform Act”) and the procedures contained in 14 C.F.R. 11, to request that Camera Artistry 

Photography an owner and operator of small unmanned aircraft, be exempted from the Federal 

Aviation Regulations (“FARs”) listed below so that Camera Artistry Photography may operate its small 

unmanned aircraft / lightweight unmanned aircraft systems (“UAS”) commercially in airspace 

regulated by the Federal Aviation Administration (“FAA”). As identified and described herein, Larry L. 

Letzer Sr. and Larry L. Letzer Jr. and their company Camera Artistry Photography, are experienced, 

recognized veterans in the photography graphic design and website development industry. Larry Sr. 

and his company have been providing quality services to their clients since 1974. Mr. Letzer Jr. has 

also been an avid Radio Controlled model builder and operator for over 15 years. Mr. Letzer Sr. holds 

a FAA Commercial certificate and is Instrument qualified. They are looking to add a valuable service to 

his clients through Camera Artistry Photograph through the use of a small, lightweight UAS as several 

of his clients have requested this type of service. Primary uses will be low altitude aerial photography 

for use on client websites and print pieces and video for use on client websites. Larry Jr. has operated 

his current UAS on several occasions non-commercially without incident. The UAS utilizes battery 

power, not combustible fuels. Flight time ranges between 5 and twenty minutes. The UAS has GPS 

functionality to hover in place as well as a return to home function in case of loss of contact with the 

radio. It has an audible and visual warning system and will start to descend slowly if battery power 

reaches 25%. The failsafe software will disable the UAS from taking off and also limit the UAS systems 

from operating within specific GPS preset no-fly zones. Camera Artistry Photography exemption 

request would permit its operation of lightweight, unmanned (piloted by remote control) and 

comparatively inexpensive UASs in tightly controlled and limited airspace. Currently, similar 

lightweight, remote controlled UASs are legally operated by amateurs with no flight experience, 

safety plan or controls in place to prevent catastrophe. It is only logical to allow Larry L. Letzer Jr. , an 

experienced remote control pilot, to operate similar lightweight UASs. This will act to further safety 

protocols specific to lightweight UASs as Camera Artistry Photography researches flight data and 

other information gained through permitted flight operations. Granting this request comports with 

the Secretary of Transportation’s (FAA Administrator’s) responsibilities to not only integrate UASs into 

the national airspace system, but to “...establish requirements for the safe operation of such aircraft 

systems [UASs] in the national airspace system” under Section 333(c) of the Reform Act. Further, 

Camera Artistry Photography will conduct its operations in compliance with the protocols described 

herein or as otherwise established by the FAA. 

For the reasons stated below, Camera Artistry Photography respectfully requests the grant of an 

exemption allowing it to operate lightweight, remote controlled UAS’s. 1. Contact Information: Larry

L. Letzer Jr. and Camera Artistry Photography 2908 Oak Hill Drive Copperas Cove, Texas 76522. email: studio@hot.rr.com 2. The Specific Sections of Title 14 of the Code of Federal Regulations From 

Which We Request 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). U.S. Dep’t of Transp. 3. 
The Extent of Relief Camera Artistry Photography Seeks and the Reason It Seeks Such Relief: Camera 

Artistry Photography submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-

334, seeking relief from any currently applicable FARs operating to prevent Camera Artistry 

Photography contemplated commercial cinematic, research and other flight operations within the 

national airspace system. The Reform Act in Section 332 provides for such integration of civil 

unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. 

Our lightweight UAS meets the definition of “small unmanned aircraft” as defined in Section 331 and 

therefore the integration of our lightweight UAS is expressly contemplated by the Reform Act. We 

would like to operate our lightweight UAS prior to the time period by which the Reform Act requires 

the FAA to promulgate rules governing such craft. The Reform Act guides the Secretary in determining 

the types of UASs that may operate safely in our national airspace system. Considerations include: • 

The weight, size, speed and overall capabilities of the UAS; • Whether the UAS will be operated near 

airports or populated areas; and, • Whether the UAS will be operated by line of sight. 112 P.L. 95 § 

333 (a). Each of these items militates in favor of an exemption for Camera Artistry Photography. Our 

UAS utilizes four counter-rotating propellers for extreme balance, control and stability. It weighs less 

than 5 pounds, including battery and all equipment. This small unmanned aircraft is designed to 

primarily hover in place and operate at less than a 50 knot maximum speed. It is 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, we us a spotter, such that, at minimum, two Camera Artistry

Photography personnel govern the safe flight of the aircraft at all times. 

Utilizing battery power and not combustible fuels, flights generally last between five and twenty 

minutes. We do not operate the UAS with less than twenty five percent battery capacity. Safety 

systems in place include a GPS mode that allows the UAS to hover in place or return to takeoff 

location if communication with the radio control pilot is lost and then slowly descend the UAS at 

twenty five percent battery capacity. We generally do not operate the UAS near airports or near 

populated areas. To date, we have only operated the UAS in a noncommercial manner. Our operation 

of this small unmanned aircraft will not “create a hazard to users of the national airspace system or 

the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of the UAS, combined with its 

operation in cordoned off and well-controlled areas, this falls within Congress’s contemplated safety 

zone when it promulgated the Reform Act and the corresponding directive to integrate UASs into the 

national airspace system. Indeed, our UAS will not pose any threat to the general public or national 

security. The FAA has the authority to issue the exemption sought by Camera Artistry Photography

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the “Act”). 4. How this Request 

Will Benefit the Public as A Whole: Granting this exemption request furthers the public interest. First, 

Congress has already pronounced that it is in the public’s interest to integrate commercially flown 

UASs into the national airspace system, hence the passing of the Reform Act. Second, Camera Artistry 

Photography conducts research into safe UAS operations every time it flies its UAS. Flight data, visual 

inspections, recorded observations and flight analyses are compiled to further enhance current safety 

protocols. Allowing us to log more flight time directly relates to our research and our ability to further 

enhance current safety measures. Third, the public has an interest in reducing the danger and 

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

UAS is battery powered and creates no emissions. If our UAS crashes there is no fuel to ignite and 

explode. The impact of our lightweight UAS is negligible when compared to a full size helicopter, 

notwithstanding the statistically noteworthy safety record of full size helicopters used in motion 
picture capture. The public’s interest is furthered by minimizing ecological and crash impacts by 

permitting photo and motion picture capture through our lightweight UAS. Progression of the arts and 

sciences has been fundamental to our society since its inclusion in the United States Constitution. 

Indeed, Congress mandated the integration of UASs into our national airspace system, in part, to 

achieve progression in this noteworthy, and inevitable, field. Permitting Camera Artistry Photography

to immediately fly within the United States furthers these goals. Whether it is the amalgam of 

scientific discoveries applicable to feature film making (including those drawing upon architecture, 

physics, engineering and cultural inclusiveness) to advancements in publicly usable technologies or 

advancements in equipment available to law enforcement personnel / first responders that does not 

cost millions of dollars, granting this exemption request substantially furthers the public’s interest in 

ways known and currently unknown. Granting this request will also allow small business owners and 

home owners to be able to afford high quality aerial images and video that they would otherwise 

have no access to due to several factors, cost being the biggest.

5. Reasons Why Camera Artistry Photography Exemption Will Not Adversely Affect Safety Or How The 

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: This exemption will not 

adversely affect safety. Quite the contrary, for the reasons stated, supra, permitting Camera Artistry 

Photography to log more flight time in FAA controlled airspace will allow us to innovate and 

implement new and novel, as of yet undiscovered safety protocols. In addition, we submit the 

following representations of enhancements to current aerial photo and motion picture capture 

techniques: • Our UAS weighs less than 5 pounds complete with all mounted equipment and battery; 

• We only operate our UAS below 400 feet; • Our UAS only operates for 5-20 minutes per flight; • We 

land our UAS when it reaches 25% battery power; • Our remote control pilot operates the UAS by line 

of sight; • Our remote control pilot has video backup should he somehow lose sight of the UAS; • We 

staff each flight with a remote control pilot and spotter with communication systems enabling real 

time communication between them; • Our UAS has GPS flight modes whereby it hovers, returns to 

takeoff position and then slowly lands if communication with the remote control pilot is lost or 

battery power is below 25%; • We actively analyze electronic flight data and other sources of 

information to constantly update and enhance safety protocols; • We conduct extensive briefings 

prior to flight, during which safety carries primary importance, and; • We have procedures in place to 

abort flights in the event of safety breaches or potential danger. Our safety protocols provide a level 

of safety at least equal to existing rules, and in nearly every instance, greater than existing rules. It is 

important to note that absent the integration of commercial UASs into our national airspace system, 

helicopters are the primary means of aerial motion picture capture. While the safety record of such 

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

First, the potential loss of life is diminished because UASs carry no people on board and Camera 

Artistry Photography only operates them 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 our UAS allows our remote control pilot to avoid hazards. 

Lastly, given their small size and weight, even when close enough to capture amazing images, our UAS 

needs not be so close to the objects it is focused on. Accordingly, our UAS has operated and will 

continue to operate at and above current safety levels.

6. 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 Camera Artistry 

Photography UAS permits exemption from Part 21 because Camera Artistry Photography 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 UASs from 

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

and proximity to areas such as airports and dense populations. Camera Artistry Photography 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 UASs, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a manual at the flight 

operations center. 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 Camera Artistry Photography’s UAS 

utilizes electronic global positioning systems and internal gyroscopes to provide spatial coordination. 

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 such certifications and registrations at Camera Artistry Photography flight

operations center. B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal 

Regulation require aircraft to be marked according to certain specifications. Camera Artistry 

Photography UAS is, by definition, unmanned. It therefore does 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 small aircraft. Regardless, Camera Artistry Photography will mark its UAS 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 the pilot, technician, spotter and others working 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. Camera Artistry Photography can 

achieve an equivalent level of safety as achieved by current Regulations because Camera Artistry 

Photography UAS does not carry any pilots or passengers. Further, while helpful, a pilot license for 

Larry L. Letzer Jr. will not ensure remote control piloting skills. As stated, Larry L. Letzer Sr. is an FAA 

certified aviator. Further, the risks attendant to the operation of Camera Artistry Photography UAS is 

far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. 

Thus, allowing Camera Artistry Photography to operate its UAS with a private pilot as the pilot in 

control will 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. 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. Camera Artistry 

Photography UAS will never operate at an altitude greater than 400 AGL. Camera Artistry 

Photography will, however, operate its UAS in cordoned off areas with security perimeters, providing 

a level of safety at least equivalent to those in relation to minimum safe altitudes. Given the size, 

weight, maneuverability and speed of Camera Artistry Photograpy UAS, an equivalent 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. 

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 to Camera Artistry should its requested exemption be granted. Camera 

Artistry Photography conducts an extensive maintenance program that involves regular software 

updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety 

will be achieved. F. Summary Camera Artistry Photography 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 its lightweight unmanned aircraft vehicle in motion picture or photography 

operations and to conduct its own research. Granting Camera Artistry Photography request for 

exemption will reduce current risk levels and thereby enhance safety. Currently, motion picture image 

capture relies primarily on the use of larger aircraft running on combustible fuel. Camera Artistry 

Photography craft does not contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional motion picture aircraft. Further, Camera Artistry Photography

operates at lower altitudes and in controlled airspace. Camera Artistry Photography has been 

analyzing flight data and other information in compiling novel safety protocols and the 

implementation of a flight operations manual that exceeds currently accepted means and methods of 

safe flight. There are no people on board Camera Artistry Photography UAS and therefore the 

likelihood of death or serious bodily injury is significantly limited. Camera Artistry Photography

operation of its UAS, weighting less than 5 pounds and travelling at speeds lower than 50 knots in 

cordoned off areas will provide at least an equivalent level of safety as that achieved under current 

FARs. 

Accordingly, Camera Artistry Photography respectfully requests that the FAA grant its exemption 

request without delay. The FAA has the authority to issue the exemption sought by Camera Artistry 

Photography pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the “Act”). In 

closing, I would like to state that it would be very easy to ignore the FAA and operate a UAS 

commercially without applying for any consideration from them. I have seen and spoken with several 

people who are already doing so. I hope the simple fact that someone such as myself who operates a 

very small business and will be operating a UAS on a very small scale is applying for this exemption 

shows how serious I am about safety and doing things properly. Thank you very much for your time 

and consideration.

Respectfully submitted,

Larry L. Letzer Jr. Partner, Camera Artistry Photography 2908 Oak Hill Drive Copperas Cove, Texas 

76522