May 12, 2015

U. S. Department of Transportation

Attn: Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation

Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b);

91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a);

91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

This petition is to inform that individual Ryan Summerfield, seeks exemption pursuant to 

the FAA Modernization and Reform Act of 2012 and the procedures contained within 14

C.F.R. 11, from the Federal Aviation Regulations (“FARs”) listed below so that

Ryan Summerfield, may operate a small ultra-light weight unmanned aircraft system

(“UAS”) commercially in airspace regulated by the Federal Aviation Administration

(“FAA”).

This petition is, in most regards, similar to granted exemption No. 11138 both in

operational approach (closer than 250’) and equipment being utilized (DJI Phantom 2).

As described herein Ryan Summerfield, professional cinematographer and 

photographer with over ten years of hands-on experience in the film and production 

industry formally requests an exemption. In the early stages of building UAS systems for 

testing and research purposes, Ryan Summerfield has since demonstrated the ethical 

and economical use of UAS systems for the use of: Geographical Studies, Coastal

Mapping, and Real Estate Commerce. This is only available following an exemption and 

approval by the FAA.

Ryan Summerfield’s exemption request would permit operation of an ultra-light weight,

unmanned (piloted by remote control) and comparatively inexpensive UAS in tightly

controlled and limited airspace. Predetermined in areas away from general public,

airports, heliports and vehicular traffic for community videos, and within property

boundaries for individual land-owners on which the concurrent film and photo would 

take place. Ryan Summerfield has instilled safety protocols and controls to avoid and 

prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to 

further safety protocols exclusive to lightweight UAS's specific to commercial video and 

photography usage as Ryan Summerfield records flight data and other information 
gained through permitted flight operations to share with the FAA through any required 

FAA reports to assist with future protocol and safety regulation.

Granting Ryan Summerfield’s request comports with the Secretary of Transportation’s 

(FAA Administrator’s) responsibilities 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's] in the national airspace system” under Section 333(c) of the 

Reform Act specific to the use of UAS's for research in commercial, and photography 

uses. Further, Ryan Summerfield will conduct his operations in compliance with the 

protocols described herein or as otherwise established by the FAA. For the reasons 

stated below Ryan Summerfield respectfully requests the grant of an exemption 

allowing operation of ultra-light weight, remote controlled UAS’s for community 

awareness to benefit/stimulate attraction to the Coastal North Carolina region, and to 

enhance tourism projects, research and development, and to establish a safety protocol 

for users alike. Both of which will promote local economic growth through increased 

employment and increased tourism interest. With public safety at the top of the list, 

Ryan Summerfield aims to use this exemption as a standard for safe protocol and 

reliable UAS systems management. 

I. Contact Information:

Ryan Summerfield

Cinematographer

210 Little Kinston Road

Surf City, NC 28445

Mobile: (910)803-4214

Email: ripod704@aol.com

II. The Specific sections of Title 14 of the Code of Federal Regulations from

which Ryan Summerfield requests exemption:

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 relief Ryan Summerfield seeks and the reason they seek such

relief:

Ryan Summerfield 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

Commercial, Tourism, Mapping, 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. Ryan Summerfield’s, ultra-light weight UAS meets the definition of “small unmanned 

aircraft” as defined in Section 331 and therefore the integration of the ultra-light weight 
UAS is expressly contemplated by the Reform Act. Ryan Summerfield would like to 

operate his ultra-light weight 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 UAS's that may operate safely in our national 

airspace system. Considerations include: The weight, size, speed and overall 

capabilities of the UAS's; whether the UAS will be operated near airports or heavily 

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

333 (a). Each of these items are in favor of an exemption for Ryan Summerfield. His

UAS utilizes four (4) counter-rotating propellers for balance, control and stability. His 

UAS is equipped with GPS and auto return safety technology, and weighs less than ten 

(10) pounds (far below the maximum 55 pound limit); including camera and full payload. 

Ryan Summerfield considers safety as a foremost component for each flight. A checklist 

of all solder points, screws, and connectors is provided before each flight. Orange 

cones are used to designate a controlled lift-off, and landing area. His small unmanned 

aircraft is designed to hover in place via GPS and operate in less than a fifteen (15 

mph) wind. For safety, stability and overall preservation of safety, he will not operate in 

winds exceeding ten (10 mph). Built in safety systems include a GPS mode that allows 

the UAS to hover in place when radio controls are released, as well as a radio switch to 

disengage GPS and manually control the UAS when needed. In the event that pilot 

radio communication is lost the UAS is designed to slowly descend to the point of 

takeoff, as well as incorporating a designated “Fail-safe” toggle switch to initiate the 

UAS to slowly land at the home point of takeoff. Ryan Summerfield will not operate his

UAS near Airports, Hospitals nor Police Heliports, and will not operate near areas where 

general public is within fifty to one hundred (50-100) yards depending on location, 

conditions and most of all, permission. Specializing in low-altitude imagery, Ryan 

Summerfield will not exceed altitudes of (250) feet AGL on any given project. Ryan 

Summerfield will be prepared to land/abort immediately to the nearest and safest 

ground station should a manned aircraft approach his location or should he suspect 

manned aircraft may approach near the flying location. Ryan Summerfield will utilize an 

operator and visual spotter with an appropriate certification who has the ability to 

monitor air and ground communications on all flights. Two-way radio is used for 

immediate communication, if needed, however the operator and spotter remain together 

in close proximity at all times. The UAS is capable of vertical and horizontal operations, 

and will only be flown within line of sight of the operator. Utilizing battery power rather 

than combustible fuels, flights generally last between ten (10) to twelve (12) minutes, 

with an altitude under (250) feet AGL programmed in the UAS firmware settings. Ryan 

Summerfield will utilize a properly stored and fully charged battery with each flight as a 

safety precaution; full flight time limit for each battery is twenty-five (25) minutes. 

However, Ryan Summerfield limits each flight to twelve (12) minutes maximum, leaving 

a safety threshold of approximately fifty percent (50%) remaining battery power upon 

grounding the UAS. Ryan Summerfield will not operate the UAS at or below 

manufacturers recommend minimum charge levels for operation; preferring to remain 

well within a safe operating range to insure adequate communication between radio 

control and UAS to eliminate potential for hazard. Reserve batteries will be at hand with 

each exercise to insure replacement for sufficient safe level of operation. Ryan 

Summerfield will exercise extreme caution when operating his UAS/ultra-light weight 
unmanned aircraft and 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 their UAS it falls 

well within Congress’s contemplated safety zone when it promulgated the Reform Act 

and the corresponding directive to integrate UAS's into the national airspace system. 

Ryan Summerfield’s UAS, used in hobby flight, has a demonstrable safety record and 

does not pose any threat to the general public or national security.

IV. How Ryan Summerfield’s request will benefit the public as a whole:

Aerial videography for geographical awareness as well as tourism and real-estate 

cinema has been utilized for years through the use of manned, fixed wing aircraft and 

helicopters. Congress has 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 Ryan Summerfield’s exemption request furthers the public interest 

through visual awareness of the geographical benefits in the coastal North Carolina 

region. His ultra- light weight UAS is battery powered and creates no environment 

impacting emissions or fumes. The consequence of the ultra- light weight UAS 

malfunctioning is far less than a full size helicopter or fixed wing aircraft; which both

contain combustible fuel and can cause catastrophic devastation in the unfortunate 

event of malfunction. The public’s interest is furthered by minimizing ecological and 

crash threat by permitting aerial video/photo capture through the battery operated ultralight weight UAS. Permitting Ryan Summerfield to immediately fly within controlled and

low-altitude air space furthers economic growth and development catering to the UAS 

sector of coastal North Carolina. Granting his exemption request substantially furthers 

the economic impact for the Surf City, NC community for companies looking to relocate 

or build in the area as well as individuals and companies seeking geographical 

information such as: coastal surveying, shoreline erosion mapping, and property 

development. 

V. Reasons why Ryan Summerfield’s exemption will not adversely affect safety or

how the exemption will provide a level of safety at least equal to existing rule:

Ryan Summerfield’s exemption will not adversely affect safety. The following represents 

enhancements to current aerial videography and photography protocol. 

The UAS weighs less than 10 pounds complete with payload. This is a DJI Phantom 2 

UAS with GoPro Hero 4 Camera. 

• The operator will only operate the UAS below 250 feet (within the 400 foot

permissible ceiling set by the FAA Modernization and Reform Act of 2012);

• The operator only operates the UAS for 10-15 minutes per flight;

• The operator will land the UAS prior to manufacturer recommended minimum level of 

battery power;

• The operator will command the UAS through 2.4ghz remote only by line of sight;

• Ryan Summerfield will utilize and adhere guidance from a pilot with experience in 

manned and radio controlled aircraft operation;

• The UAS has GPS, a flight safety feature whereby it hovers and then slowly descends 

to the landing point if communication with the remote control pilot is lost;

• The operator will actively analyze flight data and other sources of information

to constantly update and enhance safety protocols;
• The operator will only operate in reasonably safe environments, away from power

lines, elevated lights, airports and actively populated areas;

• The operator will conduct extensive pre-flight inspections and protocol, during

which safety carries primary importance;

• The operator will obtain all necessary permissions prior to operation; and,

• He will have procedures in place to abort flights in the event of safety

breaches or potential danger. Ryan Summerfield’s safety protocols provide a level of 

safety equal to or exceeding existing rules. The potential loss of life is diminished 

because the UAS carries no passengers, and only operates in specific areas away from 

mass populations. There is No fuel on board a UAS and thus the potential for fire or 

explosions is greatly diminished. The small size and extreme maneuverability of the 

UAS allows for it to be remotely piloted away from and avoid hazards quickly and safely.

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.

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 and weight of Ryan Summerfield’s UAS permits exemption

from Part 21 because the 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.

Ryan Summerfield’s, 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

on board 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

safety/flight manual delineating areas of where safety can be defined.3 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 as the 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 the FAA for Ryan Summerfield.

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. UAS are, by definition, unmanned. They therefore do 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 with dimensions smaller that

minimal lettering requirement. Regardless, Ryan Summerfield will mark his 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, or anyone assisting the pilot 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. Ryan Summerfield, can achieve an equivalent level of safety as achieved by 

current Regulations because the UAS does not carry any pilots or passengers.

Further, Ryan Summerfield will adhere a private pilot with experience in manned and

radio controlled aircraft. The risks attended to the operation of the UAS are far less

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

seq. Thus, allowing the operation of the UAS to 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.

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. Their UAS will

never operate at an altitude greater than 250 AGL; in accordance with the standard of

400 AGL. Ryan Summerfield will operate his 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 the 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.

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 Ryan Summerfield’s, UAS. However, as a safety precaution Ryan 

Summerfield will inspect the UAS before and after each flight. Applying proper 

techniques to review and ensure a safe and reliable flight system. 

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 and weight of

Ryan Summerfield’s UAS permits exemption from Part 21 because Ryan Summerfield’s

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. Ryan Summerfield’s UAS meets or 

exceeds each of these elements. 12 C.F.R. 91.7(a) prohibits the operation of an aircraft 

without the airworthiness certificate. As no such certification 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, this regulation is inapplicable. An equivalent level of 

safety will be achieved by maintaining a ground manual. The FAA has previously issued 

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

9565B, 10167. A precautionary maintenance program will be utilized that involves 

regular software updates and curative measures for any damaged hardware. Therefore, 

an equivalent level of safety will be achieved. 

In summary, Ryan Summerfield 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 a small, 

unmanned vehicle/ultra-lightweight unmanned aircraft for coastal tourism awareness, 

business relocation development, and real estate cinema and photography to help 

attract new businesses, and economic growth in the coastal Carolina region. Currently, 

tourism and awareness projects rely primarily on the use of larger aircraft with 

combustible fuel, posing potential threat risk to the public. Granting Ryan Summerfield’s 

request for an exemption will reduce current risk levels as well as enhancing safety 

protocols for the usage of the UAS system with developing and implementing features 

to enhance the reliability and safety of each flight. Ryan Summerfield’s UAS will be 

operated at lower altitudes than the (400ft AGL) ceiling, rather, staying below the 250 

feet operating range. Ryan Summerfield’s UAS weighting less than 10 pounds and 

traveling at lower speeds within limited areas will provide an equivalent level of safety 

as that achieved under current FARs. Ryan Summerfield’s level of safety and 

awareness will prove to become a necessity as he assesses and treats every flight 

operation with care, integrity, privacy, and overall respect for FAA Modernization and 

Reform Act or 2012. Accordingly, Ryan Summerfield respectfully and formally requests 

that the FAA grant his exemption request.

Respectfully submitted,

Ryan Summerfield

Cinematographer

210 Little Kinston Rd

Surf City, NC 28445