January 11, 2016

U.S. Department of Transportation Federal Aviation Administration 

800 Independence Avenue, SW Washington, DC 20591

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from: 14 CFR 61.113{a) & (b); 91.7 (a); 91.103; 91.119{c); 91.121; 91.151{a); 91.405{a); 91.407(a)(1); 

91.409 (a)(1) and {2}; 91.417{a) &(b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act, I, John Zaner, operator of an Unmanned Aircraft 

System (UAS), hereby apply, on behalf of Zaner Aviation LLC, 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 required by Section 333.

I would like to formally submit for an exemption from part 21, subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)(2),

91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1),

91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). This proposed exemption would 

allow the operation of unmanned aircraft systems (UAS) for the purpose of aerial videography and photography real 

estate purposes and events.
Applicant: John Zaner Owner

Zaner Aviation LLC

10859 SW 89th Ave Ocala, Florida 34481

jzaner9@gmail.com

(352) 897-1004

Commercial operation of an UAS, as described herein, which are equipped with camera and sensors, would operate 

in the following manner:

 Aerial photography and/or video for public and/or private use including real estate and other related 

professional activities.

 Aerial video and/or photography for public and/or private use including public and private events.

As described fully below, the requested exemption would permit the operation of a UAS under controlled

conditions in the NAS that would be a) limited, b) controlled, c) predetermined, and d) will provide safety 

enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of Transportation responsibilities to “establish 

requirements for the safe operation of such aircraft systems in the national airspace system.”
As found in Exemptions recently approved by the FAA, we will operate the SUAS DJI Phantom, The Blade 350 QX, 

and the 3D Robotics Solo. These SUAS are all quad-copters weighing less than 3.3 pounds and are comprised of an 

unmanned aircraft (UA), an attached high definition camera and a transportable ground station.

The described SUAS are equipped with four rotors that are driven by electric motors powered by batteries. They have

a maximum airspeed of 15 m/s. It will be operated over various metropolitan areas, primarily around Ocala, FL, to 

augment real estate listing videos, capture event areal video and photography, and related business operations.

UAS Operating Parameters

We will abide by the following additional operating conditions under this exemption, which ensures a level of safety 

at least equal to existing rules:

 operate UAS below 300 feet and within a radius distance of 1000 feet from the controller to aid in direct line 

of sight visual observation;

 obtain permission from the owner/controller of any vessels, vehicles and structures when operations may be 

conducted closer than 500 feet to any such vessels, vehicles or structures; we will conduct a safety assessment 

of the risk of operating closer to those objects and determine that it does not present an undue hazard;

 operate the UAS for 5--‐10 minutes per flight;

 land UAS prior to the manufacturer’s recommended minimum level of battery power;

 operate UAS during daylight hours only within visual line of sight(VLOS);

 use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if 

communication with the remote control pilot islost;

 conduct all operations under the flight safety protocols (including posting a warning sign reading: “Attention 
Aerial Photography in Progress – Remain Back 150 feet”) contained in the operating documents and will 

actively analyze flight data and other sources of information to constantly update and enhance safety

protocols;

 contact respective airports if operations will be within 5 miles to advise them of his estimated flight time,

flight duration, elevation of flight and other pertinent information;

 always obtain all necessary permissions prior to operation; have procedures in place to abort flights in the 

event of safety breaches or potential danger;

 only operate in safe environments that are strictly controlled, are away from power lines, elevated lights, 

airports and densely populated areas (defined by areas depicted in “yellow” on VFR charts and through 

obtaining information regarding congested areas from the local Flight Standards District Office (FSDO);

 conduct extensive preflight inspections and protocols, during which safety carries primary importance 

Regarding UAS operational training, we have flown numerous practice flights in remote areas as hobbyists 

simulating flights for future commercial use to gain familiarization with the characteristics of the UAS’ performance 

under different temperature and weather conditions.

Any PIC operating our UAS will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours 

of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multirotor UAS. The PIC 

will also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of 

UAS to be used for operations. In addition to the hour requirements, the PIC will accomplish 3 take-‐‐offs and landings 

in the preceding 90 days (for currency purposes) prior to any flight.
Specific Exemptions Requested

Given the size, weight, speed, and limited operating area associated 

with the UA, we feel an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203(a) and 

(b) (Certifications required), subject to certain conditions andlimitations, is warranted and meets the requirements 

for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112--‐95 (Section 333).

We request an exemption from § 45.23 Marking of the aircraft because the UA will not have a cabin, cockpit or pilot 

station on which to mark certain words or phrases. Further, the two-‐‐inch lettering is difficult to place on such a small 

aircraft with dimensions smaller than the minimal lettering requirement. Regardless of this, we can mark the UAS in 

the largest possible lettering by placing the word “Experimental” on its fuselage as required by § 45.29(f) so that 

anyone will see themarkings.

We request an exemption from § 91.7(a) which prohibits the operation of an aircraft without an airworthiness 

certificate, since there is currently no certificate applicable to our operation, this regulation is inapplicable.

We request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance 

inspections since they only apply to aircraft with an airworthiness certificate. However, as a safety precaution we 

will perform a preflight inspection of the UAS before each flight as outlined in the attached operating documents.

We request an exemption from § 91.9(b)(2) which requires an aircraft flight manual in the aircraft, however since 

there are no pilots or passengers on board the aircraft and given its size, this regulation is inapplicable. We believe 
an equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station.

We request an exemption from § 91.119 which prescribes safe altitudes for the operation of civil aircraft, but it 

allows helicopters to be operated at lower altitudes in certain conditions. We will not operate our UAS above the 

altitude of 300 feet above ground level (AGL) and will also only operate in safe areas away from the public and 

traffic, thus “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.

We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the UAS utilizes 

electronic GPS with a barometric sensor.

We request an exemption from § 91.151(a) Fuel requirements for flight in VFRconditions. The UAV is 100% 

electric and two low battery alerts are issued -‐‐ per the operating documents, the UAV will be landed at the first 

alert. Also, our flights will last only 5-‐‐10 minutes each, and the UAS has an automated function, which results in 

immediate landing when a low battery is detected. The PIC will not begin a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly to the first point of intended landing and, assuming 

normal cruising speed, land the UA with 30% battery power remaining.

Public Interest

Aerial photography and videography for real estate and events are proven strategies to enhance marketing efforts 

and increase business success. The industry is not new. However, until recently it was conducted through the use of 

costly manned aircraft, a prohibitive business activity for small companies. By granting this exemption I would be 
able to provide affordable services.

Further, the small UAS will pose no threat to the public given its small size and lack of combustible fuel when 

compared to larger manned aircraft. Additionally, the operation of our UAS will minimize harm to the environment 

economic growth by providing information to companies and the public looking to relocate or build in the 

metropolitan areas we service. Public and private events serviced by our business enhance vibrancy and add culture 

to the community and its citizens.

Summary

We will comply with all of the following conditions and limitations should this exemption be provided:

1) Operations will be limited to the following aircraft described in the operating documents, which is a quadrotor 

aircraft weighing 2.8 pounds: 

2) The UA will not be flown at an indicated airspeed exceeding 50 knots.

3) The UA will be operated at an altitude of no more than 400 feet above ground level (AGL), All altitudes reported to 

ATC must be in feet AGL.

4) The UA will be operated within visual line of sight (VLOS) of the Pilot in Command (PIC) at all times.

5) All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight (VLOS) of 

the VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be designated 

before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that 

the VO can perform the functions prescribed in the operating documents.

6) The operating documents will be accessible during UAS operations and made available to the Administrator 

upon request. Any revisions to the operating documents will be presented to the Administrator upon request.
7) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspection 

reveals a condition that affects the safe operation of the UAS,the UAS will not be operated until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe flight. All maintenance and 

alterations will be properly documented in the aircraft records.

8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a 

flight critical component, will undergo a functional testflight. The PIC who conducts the functional test flight will 

make an entry in the aircraftrecords.

9) The pre--‐flight inspection section in the operating documents will account for all discrepancies, i.e. inoperable 

components, items, or equipment, not already covered in the relevant sections of the operating documents.

10) We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul; replacement, inspection, and 

life limitrequirements.

11) We will carry out maintenance, inspections, and record keeping requirements, in accordance with the operating 

documents. Maintenance, inspection, and alterations will be noted in the aircraft records, including total flight 

hours, description of work accomplished, and the signature of the authorized person returning the UAS to service.

12) Each UAS operated will comply with all manufacturer Safety Bulletins.

13) An authorized person will make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections.

14) UAS operations will be conducted by a PIC possessing at least a private pilot certificate and at least a current 

third-‐‐class medical certificate. The PIC will also meet the flight review requirements specified in 14 CFR 61.56 in an 

aircraft in which the PIC is rated on his or her pilot certificate.

15) Prior to operations conducted for the purpose of aerial videography/photography and for real estate listing 

videos and public and private events and similar operations, 
16) the PIC will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multirotor UAS.

17) Prior to operations conducted for the purpose of aerial videography/photography and for real estate listing 

videos and public and private events and similar operations, the PIC will have accumulated and logged, in a manner 

consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the make and model of the UAS to be 

used in operations. The PIC will accomplish 3 take-‐offs and landings in the preceding 90 days.

18) The PIC will not operate the UAS for the purpose of aerial videography/photography and for real estate listing 

videos and public and private events and similar operations, unless the PIC has demonstrated and logged in a 

manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent with the 

operating documents, including evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and structures.

19) 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).

20) The UA will not operate within 5 nautical miles of an airport reference point as denoted on a current FAA 

published aeronautical chart.

21) The UA 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.

22) If a UA loses communications or loses its GPS signal, it will return to a predetermined location within the 

planned operating area and land or be recovered in accordance with the operating documents.

23) The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance with the 

operating documents.
24) The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to 

fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining.

25) We will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to 

conducting any operations, and also request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not 

less than 48 hours prior to the operation.

26) Before conducting operations, the radio frequency spectrum used for operation and control of the UA will 

comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency

requirements.

27) The 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 UAS is operating. These documents will be made available to the Administrator or any law 

enforcement official upon request.

28) The UA will remain clear and yield the right of way to all manned aviation operations and activities at all

times.

29) The UAS will not be operated by the PIC from any moving device or vehicle.

30) The UA will not be operated over congested or densely populated areas.

31) 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 UA and/or 

debris in the event of an accident. We will 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 UA, 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).

32) All operations will 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.

33) 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 will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov.

If you have questions or need additional information, please contact me at jzaner9@gmail.com

or (352) 897-1004.

Thank you,

John Zaner,

Owner

Zaner Aviation LLC
Supporting Documentation

The applicant, John A Zaner, owner and operator of Zaner Aviation LLC has the following

Certificates and Experience:

Private Pilot (Single Engine Land) Rating acquired 1969 with 1260 PIC hours logged

Airframe and Powerplant Mechanic rating acquired 1985

FCC Amateur Radio Technician License issued 1994

Member Academy of Model Aeronautics since 1964 Contest Director and International Miniature Aerobatics 

Club Judge.

Radio Control Model Fixed and Rotor wing Pilot with 5270 PIC Flights Totaling 540 hours logged with at least 

35 hours Multi-Rotor PIC logged including Tri-Copter, Quad-Copter, Hexa-Copter, and Octo-Copter.