Zephyr Aerial Productions, LLC

Attn: Christopher Norton, CEO

PO Box 130387

The Woodlands, TX 77393

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 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 

91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 

91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) 

and (2); 14 CFR 91.417(a) and (b) 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

CFR Part 11, Zephyr Aerial Productions, LLC operator of an Unmanned Aircraft System (UAS), hereby 

applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its UAS, so long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA.

As detailed in this document and the attached Appendix of UAS, the requested exemption

would permit the operation of UAS platforms previously approved by the FAA for commercial operations 

in the United States. Approval of this exemption would thereby enhance safety and fulfill the Secretary of

Transportation’s responsibilities to “...establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” Section 333(c) Reform Act.

The name and address of the applicant is: 

Zephyr Aerial Productions, LLC

Attn: Christopher Norton, CEO

Phone: 281-723-4488

Email: Zephyr.Aerial.Productions.llc@gmail.com

Address: PO Box 130387, The Woodlands, TX 77393-0387

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109
14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This

statutory authority includes exempting civil aircraft, as the term is defined under §40101

of the Act, including UAS, from the requirement that all civil aircraft must have a current

airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed

under subsection (a) or (b) of this section or any sections §44702-44716 of this title if the

Administrator finds the exemption in the public interest. 49 USC §44701(f). See also 49

USC §44711(a); 49 USC §44704; 14 CFR 91.203(a)(1).

Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may

operate in the national airspace system without creating a hazard to the user, the public,

or a threat to national security. In making this determination, the Secretary must consider:

• The UAS’ size, weight, speed and operational capability;

• Whether the UAS operates within the visual line of sight of the operator;

• Whether the UAS operates outside of highly populated areas and away from close

proximity to airports.

Reform Act 333(a). If the Secretary determines that a UAS “may operate safely in the

national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft 

in the national airspace system.” Id. 333 (c).

UAS AND OPERATIONAL DESCRIPTION

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.

As the operator of these aircraft, Zephyr Aerial Productions is committed to the following conditions and 

limitations on its operations. Zephyr Aerial Productions understands that failure to comply will be 

grounds for the immediate suspension or rescission of any exemption granted.

1. Operations are limited to the UAS listed in the Appendix when weighing less than

55 pounds including payload.

2. Operations for the purpose of closed-set motion picture and television filming are

not contemplated.

3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per
hour). In no case will the aircraft be operated at airspeeds greater than the

maximum aircraft operating airspeed recommended by the aircraft manufacturer.

4. The aircraft will be operated at an altitude of no more than 400 feet above ground

level (AGL). Altitude must be reported in feet AGL.

5. The aircraft will be operated within visual line of sight (VLOS) of the Pilot in

Command (PIC) at all times. This requires the PIC to be able to use human vision

unaided by any device other than corrective lenses, as specified on the PIC’s U.S.

driver’s license.

6. All operations will utilize a visual observer (VO). The aircraft will be operated

within the visual line of sight (VLOS) of the PIC and VO at all times.

7. All operating documents needed to operate the UAS and will be accessible during

UAS operations and made available to the Administrator upon request. The

operator will also present updated and revised documents if it petitions for

extension or amendment.

8. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical component,

will undergo a functional test flight prior to conducting further operations.

9. Zephyr Aerial Productions is responsible for maintaining and inspecting the UAS to ensure that it 

is in a condition for safe operation.

10. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the

UAS is in a condition for safe flight.

11. Zephyr Aerial Productions will follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft components.

 

12. Each UAS operated under this exemption will comply with all manufacturer

safety bulletins.

13. The PIC will hold a UAS flight training certificate, in some cases training directly

from the aircraft manufacturer, and a valid U.S. driver’s license issued by a state,

the District of Columbia, Puerto Rico, a territory, a possession, or the Federal

government.

14. Zephyr Aerial Productions will not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be operated to 

acquire aerial data, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and structures. PIC qualification flight hours and 

currency will be logged in a manner consistent with 14 CFR § 61.51(b). Zephyr Aerial 

Productions will operate flights for the purposes of training Zephyr Aerial Production’s PICs and 

VOs (training, proficiency, and experience building) and determining the PIC’s ability to safely 

operate the UAS.

15. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1.

All operations will be conducted under visual meteorological conditions (VMC).
16. The aircraft will not operate within 5 nautical miles of an airport reference point

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for

airports not denoted with an ARP, the center of the airport symbol as denoted on

the current FAA-published aeronautical chart, unless a letter of agreement with

that airport’s management is obtained or otherwise permitted by a COA.

17. The aircraft will not be operated less than 500 feet below or less than 2,000 feet horizontally from 

a cloud or when visibility is less than 3 statute miles from the

PIC.

18. If the UAS loses communications or loses its GPS signal, the aircraft will return

to a pre-determined location.

19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC will be prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is enough available power or fuel for the

aircraft to conduct the intended operation and to operate after that for at least five

minutes or with the reserve power or fuel recommended by the manufacturer if

greater.

21. All operations shall be conducted in accordance with an ATO-issued COA if the

blanket COA does not cover the intended operation.

22. All aircraft operated will be identified by serial number, registered in accordance

with 14 CFR part 47, and have identification (N−Number) markings in

accordance with 14 CFR part 45, Subpart C. Markings will be as large as

practicable.

23. Documents used by Zephyr Aerial Productions to ensure the safe operation and flight of the UAS 

and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. 

24. The aircraft will remain clear and give way to all manned aviation operations and

activities at all times.

25. The UAS may be operated by the PIC from a moving device or vehicle; however,

specific requests will be made via subsequent COA.

26. All flight operations will be conducted at least 500 feet from all nonparticipating

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the aircraft or debris in the event of an accident; or

b. The owner/controller/operator of any vessels, vehicles or structures has granted

permission for operating closer to those objects and the PIC has made an

 assessment of the risk of operating closer to those objects and determined that it

 does not present an undue hazard.

27. The PIC, VO, operator trainees or essential persons will not be considered
nonparticipating persons under this exemption.

28. All operations conducted over private or controlled-access property will be

conducted with the permission from the property owner/controller or authorized

representative. Permission from property owner/controller or authorized

representative will be obtained for each flight to be conducted.

29. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA will be

reported to the FAA's UAS Integration Office (AFS−80) within 24 hours.

Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

DESCRIPTION OF SPECIFIC REGULATIONS

C.F.R. Part 21, Subpart H: 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 certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. 

In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at least as safe, or

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. The UAS to be operated here under is less than 55 lbs. 

fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid 

fuels, and operates exclusively 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. 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 21, Subpart H. 

Lastly, application of these same criteria demonstrates that there is no credible threat to national security 

posed by the UAS, 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 

This regulation requires that certain limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft must be marked with 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 UAS will have no airworthiness certificate, an exemption may be needed as 

the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” 

can be placed. Given the size of the UAS, two-inch lettering will be impossible. Zephyr Aerial 

Productions will mark the UAS as practical.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command
Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the

UAS will not carry a pilot or passengers, the proposed operations can achieve the

equivalent level of safety of current operations by requiring the pilot operating the

aircraft to have completed a UAS flight-training course. Unlike a conventional aircraft

that carries the pilot and passengers, the UAS is remotely controlled. 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 UAS are so diminished from the

level of risk associated with commercial operations contemplated by Part 61 when

drafted, that allowing operations of the UAS as requested exceeds the present level of safety achieved by 

14 CFR 61.113(a) and (b).

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 checklists prior to each flight an 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 §21.5 of this chapter, unless there is available in 

the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, 

and placards, or any combination thereof. The UAS, 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 UAS will 

have immediate access to it. 

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command take certain actions before flight to

ensure the safety of flight. An exemption is needed from this requirement, as the pilot

will take separate preflight actions, including checking for weather conditions, checking

flight battery or fuel requirements, checking takeoff and landing distances, and all other

actions in the Operating Manual and safety checklists. These actions will provide an equivalent level of 

safety.

14 C.F.R. §91.109: Flight instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual controls. UAS 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. The equivalent level of safety provided by the fact that 

neither a pilot nor passengers 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. The UAS will

never operate at altitude higher than 400 AGL and all operations will occur during

daylight hours under Visual Meteorological Conditions (VMC) only.

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

location where it is operated. No flight will be taken without the

permission of the property owner. Because advance notice to the property owner and any

onsite personnel, as well as the precautions outlined below, all affected individuals will

be aware of the planned flight operations.

Flight operations will be conducted at least 500 feet from all non-participating persons

(persons other than the pilot in command (PIC) or visual observer (VO)), vessels,

vehicles and structures, unless operations do not present an undue hazard.

The UAS will remain within visual line of sight of the PIC or VO. Flight operations will

be conducted at least 5 miles from an airport. The PIC or VO will provide notification to

the local Flight Standards District Office and airport controller of all operations within 5

miles of an airport. The FAA will have advance notice of all operations through the filing

of notices-to-airmen.

Compared to flight operations with aircraft or rotorcraft weighing far more than the UAS

proposed herein, any risk associated with our operations is far less than those presently

presented with helicopters and other conventional aircraft operating at or below 500 feet

AGL. In addition, the low-altitude operations of the UAS will ensure separation between

these UAS operations and the operations of conventional aircraft that must comply with

Section 91.119.

14 C.F.R. §91.121 Altimeter settings

This regulation 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 UAS 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, pursuant to 

the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on 

the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel requirements for flight in VFR conditions 

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions.

Relief from Section 91.151(a)(1) is requested to the extent required to allow flights of a

variety of UAS during daylight hours in visual flight rules (VFR) conditions to continue

until 90 percent of remaining battery power or fuel reserves remain. Zephyr Aerial Productions seeks the

requested relief because without an exemption from Section 91.151(a)(1), the flight time

duration of the selected aircraft will be reduced and severely constrain the practicality of

any aerial acquisition of data that Zephyr Aerial Productions proposes to conduct pursuant to this Petition.

The technical specifications of the proposed UAS, their Operations Manuals, and

Zephyr Aerial Production’s proposed operating limitations, ensure that Zephyr Aerial Production will 

safely operate the selected aircraft during daylight hours in VFR conditions until 90 percent of remaining 

battery power or fuel reserves remain.
14 C.F.R. §91.203 (a) and (b): Carrying civil aircraft certification and registration 

The UAS has no cabin, cockpit or pilot station and is operated without an onboard pilot.

Therefore, there is no ability or place to carry certification and registration documents or

to display them on the UAS. An equivalent level of safety will be achieved by keeping

these documents at the ground control point where the pilot flying the UAS will have immediate access to 

them, to the extent they are applicable to the UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 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 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...,” 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

pursuant to the User Guide or Operating Manual. An equivalent level of safety will be

achieved because these UASs are limited in size and will carry a small payload and

operate only in restricted areas for limited periods of time. If mechanical issues arise, the

UAS can land immediately and will be operating from no higher than 400 feet AGL. The

PIC will ensure that the UAS is in working order prior to initiating flight, perform

required maintenance and keep a log of any maintenance performed. Moreover, the PIC

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.

ADDITIONAL INFORMATION

The applicant, Christopher Norton, has been professionally involved in commercial aviation for more 

than 30 years. Also the primary pilot, Christopher Norton currently holds an Airline Transport Pilot 

License with type rating in the B-737. Christopher also performs the duties of Line Check Airman for the 

B737. In addition he hold a B727 Flight Engineers Certificate and a Flight Dispatchers Certificate. 

Christopher Norton has an in-depth understanding of the capabilities and safety concerns involved in 

using this technology as an asset to the community. Satisfaction of criteria provided in Section 333 of the 

Reform Act of 2012 provide more than adequate justification for the grant of the requested exemptions 

allowing the commercial operation of the applicant’s UAS. 

PUBLIC INTEREST

Approval of exemptions allowing commercial operations of UASs for aerial acquisition

of data enhances safety while reducing risk. Manned aircraft in certain application such

as pipeline monitoring create a greater risk because the aircraft are much larger and carry

an onboard human pilot. In contrast, a UAS weighing 55 pounds or less will carry no

passengers or crew and, therefore, will not expose them to the risks associated with

manned aircraft flights. In addition, additional streams of aerial data will allow large

commercial entities to make decisions about how to best deploy ground resources and ensure the safety 

and cost-effectiveness of their operations.

EQUIVALENT LEVEL OF SAFETY
Zephyr Aerial Productions proposes that the exemption requested herein apply to civil aircraft that have 

the characteristics and that operate within the limitations listed herein. These limitations provide for at 

least an equivalent or even higher level of safety to operations under the current and proposed regulatory 

structure.

PRIVACY

All flights will occur over private or controlled access property with the property owner’s prior consent 

and knowledge. Images or video taken of individuals will have consented to being filmed or otherwise 

they will be made anonymous.

NATIONAL SECURITY

Given the small size of the UAS involved and the restricted environment within which they will operate, 

our petition presents no national security issue.

ADDITIONAL INFORMATION

Christopher Norton, Founder and CEO

Christopher Norton has been professionally involved in commercial aviation for more than 30 years.

Christopher graduated from Florida Institute of Technology with a Bachelor of Science in Aviation 

Management. As the primary pilot, Christopher Norton currently holds an Airline Transport Pilot License 

with type rating in the B-737. Christopher also performs the duties of Line Check Airman for the B-737. 

In addition he hold a B-727 Flight Engineers Certificate and a Flight Dispatchers Certificate. Christopher 

has been involved in a number of Flight Ops IT initiatives throughout his career. Starting in the late 

1980’s, Christopher was part of a four-man team that worked to bring Internet based communications to a 

major airline pilot group. Later Christopher led the team that selected and implemented and created the 

training programs that created the PBS Scheduling System currently in use by over 10,000 pilots. He also 

worked hand and hand with Steve Abdu in the selection of the initial EFB product that would bring this 

technology to a major airline. The EFB Project involved interfacing with the FAA and numerous other 

airlines working towards a Class 2 solution. During the EFB Project, Christopher was a member of the 

working group responsible for putting together the video and written documentation that resulted in the 

then FAA Administrator, Marion Blakey, approving Own Ship Moving Map for Taxi on a Class 2 device.

Most recently, Christopher was selected by management of a major airline to join the Change 

Management Team and was directly involved in most Flight Ops IT integration projects related to the 

merger. These projects included CCS (Crew Communications System) used by over 10,000 

crewmembers, ACARS 2.0 Inflight Data Uplink Projects, and iPad Based Class 2 EFB initiatives. 

Christopher Norton has an in-depth understanding of the capabilities, technology and safety concerns 

involved in integrating UAV technology in the NAS and using it as an asset to the community. 

Satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provide more than adequate 

justification for the grant of the requested exemptions allowing the commercial operation of the 

applicant’s UAS. 

Steve Abdu, EVP Video Effects

Steve Abdu has more than 42 years of experience as a Captain and First Officer for a major U.S. airline. 

His experience includes global operations utilizing the B727, B737, B757, B767, and B777. During his 

airline tenure, Steve oversaw the implementation of a Preferential Bidding System (PBS), and was 

instrumental in developing the training program to introduce the new system to the pilot group. 

Additionally, Steve was part of a select group of pilots chosen by his airline to determine which variant of 
the Electronic Flight Bag (EFB) would be installed on the B757/767 fleet.

An avid technologist, Steve was naturally interested in Unmanned Aerial Vehicles (UAVs) when the 

evolving technology became available and affordable. Sensing the tremendous potential these vehicles 

possess, he assembled 2 small UAV’s for evaluation and to learn the technology. His fleet has expanded 

to 6 UAV’s, equipped with cameras and First Person Viewing (FPV). 

Steve also is a principal in a video production company that has produced instructional videos for the past 

20 years and has over 30 productions on the market. He shoots, directs, produces, edits and manufactures 

the DVD media final output from his studios in northern New Hampshire and Vista Mar, San Carlos,

Republic of Panama.

Norm Gustitis, EVP Emergency Management Services

Norm Gustitis is a Captain at a major U.S. airline with over thirty years and approximately

29,000 hours of flight experience. He holds Type Ratings on the EMB-110, DC-9, MD-80, 

B737, B757 and B767.

Norm graduated from Southeastern Oklahoma State University in 1980 with a Bachelor of 

Science Degree in Aerospace Technology and a minor in Business Administration-Management. 

Norm has served in several Flight Operations Management roles, including Assistant Chief Pilot, 

Lead B757/767 Line Check Airman, FAA Aircrew Program Designee (APD), and pilot hiring 

board member. After serving in these positions he was then selected as a Flight Operations Duty

Manager (FODM), a position designed for specially trained and qualified Captains to provide 

24/7 real-time support from his airline’s operations center to flight crews located around the 

world experiencing emergencies, diversions, mechanical problems, dispatch, medical and/or 

technical issues. Additionally, Norm provided technical and operational support for the B-787 

proving runs required of his airline by the FAA for North American operational certification. He 

is currently involved in the training and qualification process for both new hire and transition 

pilots in the B-757/B-767 for domestic and international operations.

John Keown, EVP, Marketing

John Keown has more than 29 years experience in aviation and has been working for a major 

U.S. airline for the past 17 years with 7 years experience as a Captain. He has worked closely 

with the FAA on regulatory issues and brings a wealth of knowledge to the table in navigating 

the bureaucratic processes. His experience extends beyond the cockpit as he also works on 

technology issues both inside and outside the airline in which he is currently employed and has 

successfully acquired, started, run, and sold several small businesses.

Dianna Klein, EVP, Regulatory Compliance

Dianna Klein has been involved in numerous facets of aviation including Part 91 and 141 flight 

instruction, Part 135 charter operations, Part 121 airline operations at the regional and major 

level, and as an officer and pilot in the United States Air Force. She is currently a B-787 pilot for 

a major U.S. airline and holds type ratings in the BE-400 and the B-737.
Dianna holds a Master of Science in Aeronautical Science degree with a dual specialization in 

Aviation Safety and Human Factors from Embry-Riddle Aeronautical University-Daytona 

Beach. Additionally, she is a graduate of the MITRE Corporation’s Aviation Safety Management 

Systems Principals course. Dianna is also the President of Shenandoah Aviation, LLC, an 

aviation safety consulting firm located in Spring, TX.

Dianna has held several Flight Operations positions at her airline, including B-737 

Instructor/Evaluator, Project Manager, and Flight Manager. Prior to flying for a major U.S. 

airline, Dianna flew the EMB-145 for a large U.S. regional airline, and was also a Captain on a 

King Air C90 for a Part 135 operator. Also, she flew the C-5 Galaxy in support of combat 

operations during Operations Iraqi and Enduring Freedom for both the USAFR and Air National 

Guard.

Peter Schnur, EVP, Training and Standards

Peter Schnur is a B-787 First Officer at a major U.S. airline since January of 1999. In addition to the 787, 

he has flown the B-737 as a First Officer and Captain, and the B-757 and B-767 as First Officer. Prior 

aviation experience includes operation of the EMB-120 as a First Officer, the ATR-42 and ATR-72 as 

Captain and Check Airman, and the EMB-145 as Captain and Line Check Airman. He also worked as a 

Certified Flight Instructor (with Instrument and multi-engine ratings) from 1992 until 1996, accruing 

more than 1,500 hours of instructional time in single- and multi-engine General Aviation airplanes.

Peter graduated from Embry-Riddle Aeronautical University, Prescott Campus, in June of 1994, with a 

Bachelor of Science in Aeronautical Science. 

Additionally, Peter has worked for the pilot’s union associated with his airline on the Scheduling 

Committee from 2006 to 2013. His committee duties included implementation of a preferential bidding 

system (PBS), including initial development and deployment of a training system and syllabus. The 

documents, training classes and support systems he developed continue to be utilized by the airline today. 

Other areas of expertise derived from his committee involvement include pilot staffing and allocation, trip 

construction, and the negotiation and implementation of pilot contracts.

FEDERAL REGISTER SUMMARY

Docket No.: No. FAA-2015-____

Petitioner: Zephyr Aerial Productions, LLC

Part 21 and §§ 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119,

91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b) of

Title 14, Code of the Federal Regulations (14 CFR).

Description of Relief Sought: Zephyr Aerial Productions is seeking an exemption to conduct commercial

acquisition of aerial data using unmanned aircraft systems.

Sincerely,

////Signed////
Christopher Norton

CEO & Founder

Zephyr Aerial Productions, LLC

PO Box 130387

The Woodlands, TX 77393
Appendix

1. 2AgEagle

2. 3D Robotics Aero-M

3. 3D Robotics Iris

4. 3D Robotics Iris+

5. 3D Robotics X8

6. 3DRobotics Fixed Wing

7. 3DRobotics Multirotor

8. 3DRobotics Quadrotor

9. 3DR Solo

10. 3DR Spektre

11. 3DRobotics Spektre Industrial Multi-Rotor Aerial Vehicle

12. 3D Robotics Solo

13. 3DRobotics X8+

14. 3D Robotics X8-M

15. 3D Robotics Y6

16. Aerial Mob Heavy Lifter

17. Aerial Mob Light Lifter

18. Aerial Remote Mineral Detection System (ARMDS)

19. Aerialtronics Zenith with intergrated Airware system

20. Aerialtronics Altura Zenith ATX8

21. Aerigon

22. Aerobo

23. AeroCine Kopterworx Hammer X12

24. Aeromao AeroMapper 300

25. Aeromao Talon

26. Aeromao Aeromapper 300

27. Aeromao Aeromapper EV-2

28. AeroVironment Shrike

29. AeroVironment Puma

30. Aeronavics X4 Titanium

31. Aeryon Sky Ranger

32. Aervonics Sky Jib frame with a DJI A2 flight system

33. Aero-M

34. Aeryon Scout

35. Aeryon SkyRanger

36. AgEagle

37. AgEagle Robotic

38. AgScout

39. AgScout Mini

40. Agribotix Hornet Drone

41. Agribotix Enduro Quad

42. AgriView VK Ranger EX
43. Aibot

44. Aibotix X-6

45. Air Rover AR-3000

46. AirCover QR-425s

47. AirRobot AR 180

48. AirRobot AR 100

49. AirRobot AR200

50. Air-X

51. Align M690

52. Altavian Nova

53. Altavian Nova F6500

54. Altavian Nova R8400

55. Altus X-4

56. Altus X-8

57. American Drones, LLC Eagle

58. Apprentice

59. Arch Aerial OCTO multi-rotor UAS

60. Arris hexacoper

61. AR-960 Hex Rotor

62. AR-540 Quad Rotor

63. ARF-MikroKopter OktoXL

64. ARF-MikroKopter OktoXL +

65. ArrowLite

66. AscTec Falcon

67. AscTec Falcon 8

68. Astraeus Aerial Cinema System V.3CS

69. Atlantic RC Aircraft LC04

70. Auburn Trimble UX5

71. Auburn War Eagle

72. Auburn EasyStar

73. Auburn

74. AV44

75. Bixler 3DR Plane

76. Blade 350QX

77. Bixler 2

78. Boomerang Carbon Fiber Frame (The Identified System)

79. Bormatec Maja UAV

80. BOSH Technologies Super Swiper

81. Bumblebee-S

82. C-Astral Bramor gEO

83. CarbonCore Octocopter 1000

84. Carbon Core Cortex Quadcopter

85. CCO w/Wkm M

86. Chameleon Pro
12

87. CinesStar

88. Cinestar6

89. Cinestar X8

90. Cinestar8

91. Cinestar 8 HL

92. Cinestar 8 Okto XL

93. Coaxial Quad Multirotor VAO1-V1

94. Coaxial Quad Multirotor VAO2-V2

95. CopelandRED LLC Delta Wing Aircraft

96. CyberQuad Maxi

97. DJI Flame Wheel F450

98. DJI Flame Wheel F550

99. DAx8

100. DJI Inspire

101. DJI Inspire1

102. DJI Inspire2

103. DJI M P330z

104. DJI Phantom

105. DJI Phantom1

106. DJI Phantom2

107. DJI Phantom 2+

108. DJI Phantom 2 Vision

109. DJI Phantom 2 Vision+

110. DJI Phantom Vision+

111. DJI Phantom3

112. DJI Phantom FC40

113. DJI Spreading Wings S900

114. DJI Spreading Wings S1000

115. DJI Spreading Wings S1000+

116. DJI S800

117. DJI S800 EVO

118. DJI T600

119. Draganflyer Guardian

120. Draganflyer X4ES

121. Draganflyer X4P

122. Draganflyer X6

123. DT-18

124. DYS D800-X8

125. Eagle VTOL

126. Eagle V2

127.E-Flite Apprentice

128. Event 38 E384 

129. F-450

130. Falcon VTOL
13

131. Fire Fly6

132. First Aerial Responder UAV

133. Flame Wheel G4 7.8 Skycrane

134. Flying-Cam 3.0 SARAH

135. Foxtech Kraken 130 V2

136. FreeFly Systems ALTA RTF

137. FreeFly Systems Octocopter Airframe (Legacy)

138. G4

139. G4 models

140. GeoStar

141. GerMAP G220

142. GerMAP G180

143. goFarm GF-1

144. Gryphon Dynamics X8

145. GT80X

146. Harris 18 HL

147. HEFF

148. Helicopters West DJI Inspire

149. Helicopters West SkyJib8

150. Helios 960

151. Hawkeye Mk-III

152. HexaCrafter HC-1100 85.

153. HexaCrafter HO-1250

154. HH Blade 350QX2 AP

155. Hobbyking “Bixler” Fixed Wing Trainer

156. HoneyComb AgDrone

157. Horizon Hobby Blade 350 Qx2 quadcopter

158. Hoverfly LiveSky, BigSky 60 andH-Frame

159. Hubsan X4 micro drone

160. HVP 14301 Multi Rotor

161. Identified System

162. IMT Global xFold Cinema

163. Indago

164. InovalDrone:Inova One

165. InstantEye Mk-2

166. InstantEye Mk-2 Gen2

167. Intuitive Aerial Aeragon

168. K130 Octocopter

169. KongCopter X8

170. Kopterworx Hammer X12

171. Latitude HQ-4 Hybrid Multirotor

172. LB700

173. Leading Edge Precision Vision 10

174. Leptron Avenger
14

175. Lewis Realty Associates Hexacopter 650

176. Liberty1

177. Lockheed Martin Desert Hawk III

178. Lockheed Martin Indago

179. Matrix quad copter

180. MaxFlight 

181. MD4-200 

182. MD4-1000

183. Mikrokopter 2.5

184. MLB Company Super Bat

185. MU-1H

186. Multirotor G4 7.8 Skycrane

187. Nighthawk

188. Nighthawk VTOL

189. OktoXL 6S12

190. PAG X4

191. Parksone Radian RTF

192. Parrot Bebop drone

193. Parrot PF 725100 Bebop Drone 14MP

194. Parrot Skycontroller

195. Patriot X4

196. Patriot X8

197. Finwing Penguin V2

198. Birdseyeview FireFly6

199. Phoenix

200. Phoenix VTOL

201. Phoenix 60

202. Phoenix 60LE

203. Pixhawk

204. Precision Drone Pacesetter

205. PrecisionHawk

206. PrecisionHawk Hawkeye Mk-III

207. PrecisionHawk Lancaster

208. Precision Lancaster MK3

209. Prioria Hex

210. Prioria’s Maveric

211. Pulse Aerospace, PA 01 Vapor

212. Pulse Aerospace Pulse Vapor 35

213. Pulse Vapor

214. Puma AE DDL

215. PV 14817 Multi Rotor

216. PV HL1

217. PV HL2

218. Q1
15

219. Quadcopter LLC MikroKopter

220. Quiet UAV

221. Qube

222. R/C Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & Octo Heavy Lift Prof. 

 Multi-Loader 

223. Frame Ronin Edition Microdrones:MD4-1000

224. RCTimer Hexacopter

225. RDASS

226. REHawk 500

227. REHawk 680

228. RF-70

229. Riegl RiCopter

230. RITEWING Z3 Spade 47”

231. Ritewing Drake 60”

232. RITEWING Z3 Spade 70”

233. RITEWING Z4 Spade 52”

234. RMAX

235. Roboflight

236. Rotomotion SR-15

237. RV Jet

238. Scout X4

239. SD02

240. Seahawk 1.2

241. SelectTech Geospacial’s EH-4

242. SenseFly eBee

243. SenseFly eBee RTK

244. SenseFly eXom

245. Sensurion Magpie MP-1

246. Service-Drone Recon One

247. Service-Drone Blackbird

248. SH900

249. ShadowHawk

250. Shrike

251. Sirius

252. SkyCatch

253. SkyJib 8 v.2 Heavy Lifter

254. SkyPhilly MI

255. Skywalker Aero

256. Skywalker Flying Wing X8

257. SnapRoll Media SUAS

258. Solutions Phoenix 30

259. SteadiDrone

260. Steadidrone Quad

261. Steadydrone QU4D
16

262. Steadidrone Mavik

263. SuperX/P2 Multirotor

264. Swift Radioplanes Lynx

265. Tali 500

266. Talon 120LE

267. Tarot FY690S Hexacopter

268. Tarot quadcopter

269. Tarot 680pro

270. Tarot 690

271. Tarot 900

272. Tarot 960

273. TarotT-15

274. Tarot T15 C/F Folding Octocopter

275. Tarot T18 UAV

276. Tarot T690

277. Tarot T810

278. Tarot T960

279. Tarsier Systems MoAC

280. Tayzu Robotics Titan X8

281. TBS Discovery Pro

282. Team Black Sheep Discovery Pro Tarot T15

283.T-Rex 700E F3C

284. TREX 800E DFC PRO

285. Trimble UX5

286. Trimble UX5 hp

287. Trimble ZX5

288. Turningy Talon 500

289. TUPX8-800

290. Turbo Ace CINEWING6

291. TurboAce Matrix-G quadcopter

292. Turbo Ace matrix-E

293. Turbo Ace MATRIX-1

294. UAV Solutions Phoenix 60

295. Universeye Penguin

296. Unmanned Flying Rolling Orb “UFRO”

297. US2 GreenHawk

298. UtiliCopter ITX8

299. VA03-v1

300. VA04-v1

301. VA07-v1

302. Viking UAS Multicopter (VTOL)

303. Viking UAS FF-X4/X8

304. VK-Patriot X4/X8

305. Viking UAS Patriot X4/X8 Multirotor
20

17

306. Viking UAS X6 Model 800

307. Viking UAS Viking ONE

308. VK-450

309. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX

310. Viking VK-FF-X4

311. VK- Ranger EX- SAR Fixed Wing UAS

312. Volantex Raptor Tarot T-18

313. Volt Aerial Robotics Octane

314. Vulcan frame controlled by a DJI A2 flight controller

315. Vulcan Mantis

316. Vulcan Octocopter

317. Vulcan Raven

318. Vulcan UAV

319. Walkera TALI H500

320. Walkera Scout X4

321. Wookong DJI 5800

322. xCel Drones XD550CDR

323. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter, 

and x12 Copter 

324. X8-M