November 16, 2015

Robert Hannau

813 NE 97th Street

Miami Shores, FL 33138

Mobile #: 305-609-4974

Email: Bob.Hannau@gmail.com

U.S. Department of Transportation

Docket Management System

West Building Ground Floor, Room W12-140

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Request for Exemption under Section 333 of the FAA Modernization and Reform 

Act and Part 11 of the Federal Aviation Regulations.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

“Reform Act”) and Title 14 CFR Part 11, I, Robert Hannau, seek exemption from Federal 

Aviation Regulations (“FARs”) listed below to allow the commercial operation of Small 

Unmanned Aircraft Systems (“sUAS”) also list below for the purpose of aerial video and 

still photography, marine and real estate photography and site inspections, videography 

and still photography of social events, such as weddings, with the sUAS to remain at least 

500 feet from all nonparticipating persons as noted in the reference exemptions listed 

below.

Operators Contact Information:

Name: Robert Hannau

Address: 813 NE 97th Street, Miami Shores, FL 33138

Mobile: 305-609-4974

Email: Bob.Hannau@gmail.com

List of FARs requesting exemption:

Title 14: Aeronotics and Space

! §61.23(a)

! §61.113(a)

! §91.119(c)

! §91.121

! §91.151(a)

! §91.405(a)

! §91.407(a)(1)

! §91.409(a)(1) & (a)(2)

! §91.417(a) & (b)
List of sUAS

! DJI Phantom 3 Professional

! DJI Inspire 1 Pro / Raw

! 3D Robotics Solo

! 3D Robotics X8+

References:

1) FAA Exemption No. 13574, Regulatory Docket No. FAA-2015-3701, petition by 

Mr. Mark Griggs, GDI, LLC

2) FAA Exemption No. 13567, Regulatory Docket No. FAA-2015-3174, petition by 

Mr. Jonathan Rupprecht, Esq., Counsel for Aerialpixels, LLC

3) FAA Exemption No. 13565, Regulatory Docket No. FAA-2015-3569, petition by

Mr. Patrick Belanger, The 111th Group, Inc.

4) FAA Exemption No. 13507, Regulatory Docket No. FAA-2015-3644, petition by 

Mr. Nicholas Bolland, Panoptic Works, Inc.

5) FAA Exemption No. 13506, Regulatory Docket No. FAA-2015-3645, petition by 

Mr. Shaun Nathan Capps, Top Flight Digital Media LLC

The operator, Robert Hannau, will maintain an equivalent level of safety or no adverse 

impact on safety by following the safe operational parameters of the sUAS manuals, FAA 

rules and FAA Conditions and Limitations noted in the exemptions in the References list 

above. The sUAS, powered by batteries, is smaller, lighter and more maneuverable than 

larger aircraft running on combustible fuel. Operations will be performed safely and more 

cost effectively with the use of sUAS at low altitude within the U.S. national airspace 

system as compared to a manned aircraft. Operations will be performed only at the 

request of and with the authorization and permission of clients and their authorized 

agents in order to facilitate commerce and raise awareness of the beneficial uses of small 

unmanned air systems. So long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 

333. The conditions identified and proposed by, Robert Hannau, are drawn from 

references 1) to 5) above.

The FARs

I, Robert Hannau, request exemption from the above mentioned FARs for the

following reasons:

§61.23(a) Medical Certificates: Exemption Nos. 13574, 13567, 13565, 13507 and 

13506 and others show that a U.S. driver’s license could be used in lieu of the medical 

certificate and provides and equivalent level of safety. I am likewise seeking the same set 

of previously granted restrictions.

§61.113(a) Private Pilot Privileges and Limitations: Sub-section §61.113(a) limits 

private pilots to non-commercial operations. Because the sUAS will not carry a pilot or 

passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have a sport pilot license or 

greater rather than a commercial pilot’s license to operate the sUAS. A visual observer 

(“VO”) will be used at all times while under this requested exemption as noted in 

exemption nos. 13574, 13567, 13565, 13507 and 13506.
§91.119(c) Minimum Safe Altitudes: As discussed in Exemption No. 13506, the 

regulation states that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be 

operating at a maximum of 400 feet AGL, operations will be conducted at least 500 feet 

from all nonparticipating persons, vessels, vehicles and structures unless specific 

permission is granted by the owner/controller of said people and property and the PIC has 

made a safety assessment of the risk of operating closer to those objects and determined 

that is does not present an undue hazard.

§91.121 Altimiter Settings: As noted in Exemption No. 13507, the sUAS will not have a 

typical barometric altimeter onboard. However, altitude information of the DJI or 3D 

Robotics sUAS will be provided to the PIC via Global Positioning System (GPS) 

equipment and radio communications telemetry data link, which downlinks from the 

sUAS to the controller for active monitoring of the flight path. This altitude information, 

combined with the visual observer will ensure an equivalent level of safety equivalent.

§91.151(a) Fuel Requirements for Flight in VFR Conditions: The regulation provides 

that no person may begin a flight in an airplane under day-VFR conditions unless there is 

enough fuel to fly to the first point of intended landing and to fly after that for at least 30 

minutes. The sUAS is battery operated and the maximum duration of flight from a single 

battery charge is approximately 20 minutes with a reserve. To provide an equivalent level 

of safety, as noted in exemption nos. 13574, 13567, 13565, 13507 and 13506 (and 

others), flight will not begin unless (considering wind and forecast weather conditions) 

there is enough available power for the sUAS to conduct the intended operation and to 

operate after that for at least 5 minutes or with the reserve power recommended by the 

manufacturer if greater.

§91.405(a). 91.407(a)(1). 91.409 (a)(1) & (2). 91.417(a) & (b) Maintenance, 

Preventive Maintenance and Alterations: The regulation provides that the operator is 

primarily responsible for maintaining the aircraft in an airworthy condition, including 

compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be 

“approved for return to service by a person authorized under 43.7” after maintenance and 

inspection.

It is my intention that the PIC perform maintenance and inspection of the aircraft and “be 

authorized to approve the aircraft for return to service.” A Pre-Flight Checklist to be 

performed by the PIC before every flight will ensure that the aircraft is in an airworthy 

condition prior to every flight. In addition conduct detailed inspections after every two 

hours of flight. Maintenance performed by the PIC is limited to replacing a propeller, 

checking electrical connections and updating software and firmware for the on-board 

computer. All other maintenance will be performed by the manufacturer or their 

designated repair facility. The PIC will document work performed in accordance with 

§91.417. I feel that due to the size, construction, and simplicity of the aircraft, the PIC 

can ensure an equivalent level of safety.
Public Interest

The use of sUAS on aerial photography operations can significantly reduce the risk to 

photographers and participants. sUAS can inspect, photograph, and collect data on hard 

to get to areas that otherwise would require direct access or manned aircraft with much 

larger and expensive photographic equipment. The sUAS I propose to fly in this 

application are less than 55 pounds and carry no combustible material on board, as 

opposed to the much larger conventionally powered small aircraft. The sUAS compared 

to manned aircraft presents a marked safety increase for the participants and reduces the 

environmental impact by dramatically decreasing the energy used for aerial imaging and 

data collection.

I, Robert Hannau, will also make the sUAS and myself available to local first responder 

organizations (for no charge) such as fire departments, local law enforcement, etc., to 

perform search and rescue operations, or other similar events as directed by authorities.

In addition, the use of the sUAS in order to facilitate commerce could lead to economic 

growth. Operations for this petition will enable service for property owners or their 

designees seeking an enhanced perspective for characteristics, amenities, and benefits of 

their desired photographic subjects that cannot be displayed through ground level 

photography. Aerial photography is a valuable marketing tool that can lead to increased 

commerce for my clients.

A visual observer will be utilized at all times the sUAS is performing duties for

compensation and the PIC will hold the proper documents. Liability insurance will be 

obtained commensurate with the granting of this request for exemption. Flight data 

including sUAS flight time, Control Unit operation time, incident, and details will be 

recorded for each flight and made available to the FAA upon request. Any deviations 

from normal operations will also be recorded and made available to the FAA.

Proposed Operations

Proposed operations are for the purpose of aerial video and still photography, marine and 

real estate photography and site inspections, videography and still photography of social 

events, such as weddings, with the sUAS to remain at least 500 feet from all 

nonparticipating persons as noted previously.

In seeking this exemption, operations will be conducted per the manufacturer of the 

sUAS, conditions and limitations of the FAA and local government. Following are the 

proposed operations:

1. The sUAS may not be flown at an indicated airspeed exceeding 55 knots.

2. The sUAS must be operated at an altitude of no more than 400 feet above ground 

level (AGL), as indicated by the procedures specified in the operating documents 

unless a special request is made and approved by ATC. All altitudes reported to 

ATC must be in feet AGL.
3. The UAs must be operated within visual line of sight (VLOS) of the 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 FAA-issued airman medical 

certificate or valid U.S. driver’s license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possession, or the Federal government.

4. All operations must utilize a Visual Observer (VO). The VO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times. 

Electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for 

the duration of the flight. The PIC must ensure that the VO can perform the 

functions prescribed in the operating documents.

5. The VO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and is 

not permitted to operate the camera or other instruments.

6. The operating documents and the grant of exemption must be accessible during 

sUAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions and 

present updated and revised documents to the Administrator upon request. The 

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

extension or amendment to the grant of exemption. If the operator determines that 

any update or revision would affect the basis upon which the FAA granted the 

exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS80) may be contacted if 

questions arise regarding updates or revisions to the operating documents.

7. Prior to each flight the PIC must inspect the sUAS to ensure that it is in a 

condition for safe flight. If the inspection reveals a condition that affects the safe 

operation of the sUAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the sUAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

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

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

must undergo a functional test flight. The PIC who conducts the functional test 

flight must make an entry in the aircraft records.

9. The preflight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents.

10. The operator must follow the sUAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements.
11. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts must

be noted in the aircraft records, including total time in service, description of 

work accomplished, and the signature of the authorized person returning the 

sUAS to service.

12. Each sUAS operated under this exemption must comply with all manufacturer 

Safety Bulletins.

13. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered between inspections.

14. The PIC must possess at least a sport pilot certificate 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.

15. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the 

sUAS in a manner consistent with how the sUAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Training operations may only be conducted during dedicated training 

sessions. During training, proficiency, and experiencebuilding flights, all persons 

not essential for flight operations are considered nonparticipants, and the PIC 

must operate the sUAS with appropriate distance from nonparticipants in 

accordance with 14 C.F.R. §91.119.

16. sUAS operations may not be conducted during night, as defined in 14 C.F.R. § 

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). If flight at night is required, a special request will be made at the FAA 

office closest to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized.

17. The sUAS may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAApublished aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of 

agreement with the airport management must be made available to the 

Administrator upon request.

18. The sUAS may 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.

19. If the sUAS loses communications or loses its GPS signal, it must return to a

predetermined location within the planned operating area and land or be 

recovered in accordance with the operating documents.

20. The PIC must abort the flight in the event of unpredicted obstacles or emergencies 

in accordance with the operating documents.
21. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power for the sUAS to 

conduct the intended operation and to operate after that for at least 5 minutes or 

with the reserve power recommended by the manufacturer if greater.

22. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. This COA will also require the operator to request a Notice to 

Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours 

prior to the operation. All operations shall be conducted in accordance with 

airspace requirements in the ATO issued COA including class of airspace, altitude 

level and potential transponder requirements.

23. The sUAS must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

24. Flight operations must be conducted at least 500 feet from all nonparticipating

persons (persons other than the PIC, VO, operator trainees or essential persons),

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the sUAS, flight operations must 

cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present an 

undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do 

not present an undue hazard to those persons per § 91.119(a).

25. All operations shall be conducted over private or controlled access property with

permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

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

reported to the FAA’s UAS Integration Office (AFS80) 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.

Make and Model of the Aircraft for Proposed Operations:

Make Model

DJI Phantom 3 Professional

DJI Inspire 1 Pro / Raw

3D Robotics Solo

3D Robotics X8+
Conclusion:

The operation of Robert Hannau using a sUAS, weighing less than 55 lbs., conducted 

under the proposed restrictions outlined above, will provide an equivalent level of safety 

supporting the exemptions requested herein. If I can be of any assistance to further 

expedite this petition, please do not hesitate to contact me at (305) 609-4974 or via email 

bob.hannau@gmail.com

Sincerely,

Robert Hannau

813 NE 97th Street

Miami Shores, FL 33138

m: 305-609-4974

e: bob.hannau@gmail.com