U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 

of the Federal Aviation Regulations 

To Whom it May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of201 2 and 14 C.F.R., 

Part 11, Certified Site Safety of NY LLC, operator of Small Unmanned Aircraft Systems ("sUAS") 

equipped to conduct aerial videography of high-rise residential and commercial structures for 

enforcement of safety standards set forth by the Occupational Safety and Health Administration 

as well as local municipality law for the construction of such structures and for continued 

inspection of those structures to ensure compliance with all relevant laws governing safe structural 

integrity, requests a limited exemption from the below-listed regulations to allow commercial 

operation of its sUASs, provided that the proposed sUAS operations comply with the conditions 

outlined below or as established by the Federal Aviation Administration ("FAA") under Section 

333. 

The name and address of the applicant is: Certified Site Safety of NY LLC ("Certified Site 

Safety"), 99 Lafayette Avenue, White Plains, NY 10603 c/o Penny Gianatasio, 

pgianatasio@certifiedsitesafety.com. Certified Site Safety maintains personnel who possess 

licenses issued by municipal authority to perform inspections of commercial and residential 

building facades to ensure compliance with all relevant federal, state and local safety laws. In 

addition, Certified Site Safety employs a licensed professional engineer and architects that provide 

services to building owners, property managers, developers and general contractors to ensure the 

design and construction of commercial and residential buildings are safe for occupancy and to the 

public. 

Certified Site Safety makes this request under the "summary grant" process that the FAA 

announced in April 2015. This request is similar in all material respects to a number of recent 

grants of exemption, including Exemption No. 12499 to Skanska USA Civil (FAA Docket No. 

FAA- 2015- 1207); Exemption No. 12710 toAerovista, LLC (FAA Docket No. FAA- 2015- 1141); 

Exemption No. 13001 to Dering Harbor LLC (FAA Docket No. FAA- 2015-2810); Exemption 

No. 12991 to Lee M. Woodworth (FAA Docket No. FAA-2015-2794); Exemption No. 12785 to 

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2014-0825).1 

Regulations from which the exemption is requested: 

• 14 C.P.R. part 21 

• 14 C.P.R. § 45.23 (b) 

• 14 C.P.R. §§ 61.113 (a) & (b) 

• 14C.F.R.§91.7(a) 

• 14 C.P.R.§ 91.9 (b) (2) 

• 14 C.P.R.§ 91.103 

• 14 C.P.R. § 91.109 

• 14 C.P.R.§ 91.119 

• 14C.F.R.§91.121 

• 14 C.P.R.§ 91.151 (a) 

• 14 C.P.R.§§ 91.203 (a) & (b) 

• 14 C.P.R.§ 91.405 (a) 

• 14 C.P.R. 407 (a) (1) 

• 14 C.P.R. § 409 (a) (2) • 14 C.P.R.§§ 417 (a) & (b) 

Certified Site Safety proposes that it receive an exemption to use sUAS to gather footage 

in two categories of filming: 1) the sites for construction of residential and commercial properties 

to ensure compliance with federal and local laws for the protection of the workers and the public; 

and 2) the inspection of residential and commercial buildings to ensure compliance with local 

building codes. Certified Site Safety would obtain the consent of the building owners, developers, 

general contractors and property managers within the vicinity in which the sUAS may operate. 

The proposed sUAS operation will be conducted safely to minimize risk to the national 

airspace system ("NAS") or to persons and property on the ground. Certified Site Safety proposes 

that the exemption apply to civil aircraft that operate within the limitations listed below. These 

limitations were established in the FAA's grant of the exemptions listed above: 

1. The sUAS will weigh less than 55 pounds, including payload. Proposed operations of 

any other aircraft will require a new petition or a petition to amend this exemption. 

1 Certified Site Safety incorporates by reference the arguments set forth in the underlying applications for those 

exemptions. 

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compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

3. The UA will be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude will be reported in feet AGL. 

4. The UA will be operated within visual line of sight (VLOS) ofthe Pilot in Charge (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 U.S. driver's license. 

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

VLOS of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains the VLOS capability. The VO and 

PIC will be able to communicate verbally at all times; electronic messaging or texting 

will not be permitted during flight operations. The PIC will be designated before the 

flight and cannot transfer his or her designation for the duration of the flight. The PIC 

will ensure that the VO can perform the duties required of the VO. 

6. This exemption and all documents needed to operate the sUAS and conduct its 

operations in accordance with the conditions and limitations stated in the grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents will be accessible during sUAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

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

the conditions and limitations herein take precedence and will be followed. Otherwise, 

Certified Site Safety will follow the procedures as outlined in its operating documents. 

Certified Site Safety may update or revise its operating documents. It is Certified Site 

Safety's responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. Certified 

Site Safety will also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If Certified Site Safety determines that any 

update or revision would affect the basis upon which the FAA granted this exemption, 

then Certified Site Safety must petition for an amendment to its grant of exemption. 

The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise 

regarding updates or revisions to the operating documents. 

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Functional test flights may only be conducted by a PIC with aVO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property. 

8. Certified Site Safety is responsible for maintaining and inspecting the UAS to ensure 

that it is in a condition for safe operation. 

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

sUAS is in a condition for safe flight. The pre-flight inspection will account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the sUAS, the aircraft 

will be prohibited form operating until the necessary maintenance has been performed 

and the sUAS is found to be in a condition for safe flight. 

10. Certified Site Safety will follow the sUAS manufacturer's maintenance, overhaul, 

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

components. 

11. Each sUAS operated under this exemption will comply with all manufacturer safety 

bulletins. 

12. Under this grant of exemption, a PIC will hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC will also hold a current FAA 

airman medical certificate or 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. The 

PIC also will 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. 

13. Certified Site Safety wiil not permit any PIC to operate unless the PIC demonstrates 

the ability to safely operate the sUAS in a manner consistent with how the sUAS will 

be operated under this exemption, 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). Flights for the purposes of training the operator's PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC's ability to 

safely operate the sUAS in a manner consistent with how the sUAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

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14. UAS operations will not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations will be conducted under visual meteorological conditions (VMC). Certified 

Site Safety will not operate flights under special visual flight rules (SVFR). 

15. The UA will not operate within the no-flight zones designated by federal and local 

government. 

16. 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. 

17. If the sUAS loses communications or loses its GPS signal, the UA will return to a predetermined location within the private or controlled-access property. 

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

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

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

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater. Air Traffic Organization (ATO) 

Certificate of Waiver or Authorization (COA). All operations will be conducted in 

accordance with an A TO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the 

terms of the attached COA. 

20. All aircraft operated in accordance with this exemption will be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as 

large as practicable. 

21. Documents used by Certified Site Safety to ensure the safe operation and tlight of the 

sUAS 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 sUAS any time the aircraft is operating. 

These documents will be made available to the Administrator or any law enforcement official upon request. 

22. The UA will remain clear and give way to all manned aviation operations and activities 

at all times. 

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a. Gain consent of property owner/property manager. 

b. Notify property managers of surrounding adjacent buildings; 

c. Have markers on street notifying use of UA in progress; 

d. Notify the precinct commander of the local police precinct of use. 

e. Notify any other federal, state, local authorities as needed. 

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

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. 

26. 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. 

Unless otherwise specified, the sUAS operations will comply with all applicable parts of 14 CFR 

including, but not limited to, parts 45, 47, 61 , and 91. 

Federal Register Notice 

As stated above, publication in the Federal Register is unnecessary because this application 

meets the FAA's crite1ia for summary approval. To the extent that the FAA determines that 

publication is necessary, the following summary is provided: 

Applicant seeks an exemption from the following rules: 14 C.F.R. § 21, subpart H; 14 

C.F.R 45.23 (b); 14 C.F.R. § 61.113 (a) & (b); 91.7 (a); 91.9 (b)(2); 91.103 (b); 91.109; 91.119; 

91.121; 91.151(a); 91.203 (a) and (b); 91.405 (a); 91.407 (a)(l); 91.409 (a)(2); 91.409 (a)(2) and 

91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in videography 

operations. 

The Exemption is in the Public Interest 

As demonstrated above, the proposed sUAS operations would minimize the risk of harm 

to individual safety or damage to the NAS, the public and property. The operations proposed by 

Certified Site Safety would provide tremendous public benefits by providing a new mechanism to 

bolster the safety to the men and women who construct commercial and residential properties in 

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The conditions outlined in this petition clearly satisfy Section 333 's exemption criteria 

regarding "size, weight, speed, operational capability, proximity to airpotis and populated areas, 

and operation within visual line of sight," and therefore the proposed operations would not "create 

a hazard to users ofthe national airspace system or the public or pose a threat to national security." 

As discussed above, Certified Site Safety agrees to use limitations that are substantially identical 

to those contained in the FAA's grants of exemption for Exemption No. 12499 to Skanska USA 

Civil (FAA Docket No. FAA-2015-1207); Exemption No. 12710 to Aerovista, LLC (FAA Docket 

No. FAA-2015-1141); Exemption No. 13001 to Dering Harbor LLC (FAA Docket No. 

FAA-2015-2810); Exemption No. 12991 to Lee M. Woodworth (FAA Docket No. 

FAA-2015-2794); Exemption No. 12785 to Statstellar LLC (FAA Docket No. FAA-2015-1259); 

Exemption No. 12963 to Michael Linneman (FAA Docket No. FAA-2015-2731 ); Exemption No. 

13012 to RoofCorp of CA, Inc. (FAA Docket No. FAA- 2015-2260); Exemption No. 12703 to 

NMotion VAS LLC (FAA Docket No. FAA-2015-1239); Exemption No. 11676 to DPR 

Construction (FAA Docket No. F AA-20 15-D568); Exemption No. 11275 to Danis Building 

Construction Company (FAA Docket No. FAA-2014-D825). Accordingly, the proposed UAS 

operations of Certified Site Safety should not raise safety or national security concerns, and should 

receive summary approval. 

Please do not hesitate to contact the undersigned if you need additional information. 

Very truly, 

CERTIFIED SITE SAFETY OF NY, LLC. U2 r-1~-

PennyGia::Q--

President 

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