Ryan Tyson

2203 Gardenmoss Drive

Green Cove Springs, FL 32043

(904) 608-2580

July 10th, 2015

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); 

 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)

To whom it may concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Ryan 

Tyson, operator of micro Unmanned Aerial Systems (mUAS), hereby applies for an exemption from the 

listed Federal Aviation Regulations to allow commercial operation of a micro UAS, so long as such 

operations are conducted within and under the conditions outlined herein or as my be established by 

the FAA as required by Section 333.

As described more fully below, the requested exemption would authorize the Applicant to perform 

commercial operations with sUAS that will provide the following benefits:

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities.

2. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

3. Aerial video/photography for agriculture activities.

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s 

(the FAA Administrator's) responsibilities under Section 333(c) of the Reform Act to "establish 

requirements for the safe operation of such aircraft systems in the national airspace system."

The name, phone, email and address of the applicant: 

Name: Ryan Tyson

Phone: (904) 608-2580

Email: ryan.tyson@yahoo.com

Address: 2203 Gardenmoss Drive, Green Cove Springs, FL 32043
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The regulations from which the exemption is requested are as follows:

 14 CFR 21 subpart H; 

 14 CFR 45.23(b); 

 14 CFR 61.113(a); 

 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)

The sUAS operated are rotorcraft and fixed wing aircraft, typically weighing 10 lbs. or less, but never 

exceeding 55 lbs. including payload. They would operate, under normal conditions, at a speed of no 

more than 87 knots. The principal construction material of the sUAS aircraft would typically be foam 

and/or plastic. Given the small size of the micro UAS and the controlled environment provided the 

proposed operations will adhere to the Reform Act’s safety requirements. The approval of this 

application presents no national security issues. Regarding the level of safety surrounding the proposed 

operations and the public benefit, reduction in environmental impacts, including but not limited to 

reduced emissions and noise, the grant of the requested exemption is in the public interest.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

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. These limitations 

and conditions to which the applicant agrees to adhere to when conducting commercial operations 

under the FAA issued exemption include:

1. The micro UAS will weigh less than 4.4 lbs.

2. Operations will only take place within Class G airspace.

3. Flights will be operated within visual line of sight of a pilot and/or observer.

4. Maximum flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) 

and not more than 200 feet above an elevated platform from which filming is planned.

6. Minimum crew for each operation will consist of the UAS Pilot in Command (PIC), a Visual 

Observer (VO) when needed, and may include but not limited to a Camera Operator.

7. The UAS pilot will be Ryan Tyson ONLY not allowing any other person to operate the UAS in 

a commercial capacity.

8. A briefing will be performed regarding the planned UAS operations prior to each day’s flight 

consisting of all the days’ production activities.

9. The PIC will obtain verbal/written consent of all persons involved with the planned 

operation and ensure that only consenting persons will be allowed within 100 feet of the 

flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of 

safety determination, as required under the FOM. With the advanced permission or 

direction of the FSDO, operations at closer range may be approved.

10. The PIC and VO will have been trained in operation of UAS and receive up-to-date 

information for the particular UAS to be operated and will be able to show upon request 

their competent ability to operate the UAS and/or Camera.

11. The PIC and VO will be able to communicate by voice and/or radio at all times.
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12. Written and/or verbal permission and permits will be obtained from territorial, state, county 

or city jurisdictions, including law enforcement, fire or other appropriate governmental 

agencies when needed.

13. No operations of the UAS will occur within 5 nautical miles of an airport without prior 

authorization from the airport operators and the control tower.

14. If the UAS loses communications or loses GPS signal, the UAS will have the capability to 

return to a pre-determined location within a designated location and land autonomously.

15. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, 

or emergencies.

14 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 

small UAS. In all cases, an analysis of these criteria demonstrates that the small 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 micro UAS to be operated hereunder is less than 4.4 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 micro 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

The regulation requires: When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to 

the cabin, cockpit, or pilot station, in 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 micro 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 words can be placed. Given 

the size of the micro UAS, two-inch lettering will be impossible. 
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14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot in 

command of an aircraft that is carrying passengers or property for compensation or hire. 

Our micro UAS does not carry any pilots or passengers nor property therefore I am seeking an 

exemption to 14 CFR 61.113(a). Although helpful, a pilot’s license will not ensure remote control piloting 

skills. The risks attendant to the operation of micro UAS is far less than the risk levels inherent in the 

commercial activities outlined in 14 CFR 61. I feel the operation and limitations set forth in the FOM will 

equate to the safe operation of the micro UAS.

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 micro 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 micro UAS will have immediate access to 

it.

14 C.F.R. § 91.103: Preflight Action.

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

of flight. 

As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing 

and takeoff distances and aircraft performance data before initiation of flight.

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. 
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Micro 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. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. 

As this exemption is for a micro UAS that is a helicopter and the exemption requests authority to 

operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming 

is planned, an exemption may be needed to allow such operations. As set forth herein, the micro UAS 

will never operate at higher than 400 AGL. The equivalent level of safety will be achieved given the size, 

weight, speed of the micro UAS as well as the location where it is operated. No flight will be taken 

without the permission of the property owner or local officials. Because of the advance notice to the 

property owner and participants in the filming activity, all affected individuals will be aware of the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more 

than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with conventional aircraft operating at or below 

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

micro 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 micro 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) prohibits an individual from beginning “a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at least 

30 minutes; or (2) At night, to fly after that for at least 45 minutes.” 

The battery powering the micro UAS provides approximately 23 minutes of powered flight. To meet the 

30 minute reserve requirement in 14 CFR §91.151, small UAS flights would be limited to approximately 

18 minutes in length. Given the limitations on the micro UAS’s proposed flight area and the location of 
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its proposed operations within a predetermined area, a longer time frame for flight in daylight or 

twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls 

within the scope of prior exemptions. 

Operating the micro UAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does 

not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed 

of the micro UAS. Additionally, limiting micro UAS flights to 18 minutes would greatly reduce the utility 

for which the exemption will be granted. Applicant believes that an equivalent level of safety can be 

achieved by limiting flights to 30 minutes or 25% of battery power— whichever happens first. This 

restriction would be more than adequate to return the micro UAS to its planned landing zone from 

anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

a. Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following: (1) An appropriate and current airworthiness certificate. . . .

b. No person may operate a civil aircraft unless the airworthiness certificate required by paragraph 

(a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin 

or cockpit entrance so that it is legible to passengers or crew.

The micro UAS fully loaded weighs no more than 4.4 lbs. and is operated without an onboard pilot. As 

such, there is no ability or place to carry certification and registration documents or to display them on 

the micro UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point

where the pilot flying the micro UAS will have immediate access to them; to the extent they are 

applicable to the micro 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 by the operator pursuant to the flight manual and 

operating handbook. An equivalent level of safety will be achieved because these small UASs are very 

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 small UAS can land immediately and will be operating from no higher 

than 400 feet AGL. The operator will ensure that the small UAS is in working order prior to initiating 

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

operator 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.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the micro UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual 
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(AOM). As provided in the FOM, the operator will ensure that the micro UAS is in working order prior to 

initiating flight and perform required maintenance needed.
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SUMMARY OF SECTION 333 EXEMPTION REQUEST

Ryan Tyson, a freelance photographer/videographer hereby provides pursuant to Part 11 a summary of

its exemption application to perform commercial operations with sUAS that will provide the following 

benefits all of which are critical to the well-being of the general public:

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities.

2. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

3. Aerial video/photography for agriculture activities.

All of which are critical to the well-being of the general public. 

An exemption is requested from the following regulations:

 14 CFR 21 subpart H; 

 14 CFR 45.23(b); 

 14 CFR 61.113(a); 

 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)

Please do not hesitate to contact me if you have any questions or concerns. I thank you for reviewing 

my application and eagerly await your response.

Sincerely,

Ryan Tyson
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