1

CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

CAMA Ventures LLC 

DBA Andrew Ciesler Photography 

7768 Westcroft Dr. 

Sylvania, OH 43560 

(419) 318-9318 

aaron@cieslerphotography.com

May 13, 2015

U.S. Department of Transportation Docket Management System

1200 New Jersey Avenue SE 

Washington, DC 20590

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

14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 13 C.F.R. 61.133(a); 91.7 (a);91.9 (b) (2);91.103(b); 

91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b). 

Dear Sir(s)/Madam(s):

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part 11, 

CAMA Ventures LLC, an Ohio limited liability company, DBA Andrew Ciesler Photography (ACP), the operator of a DJI 

Inspire 1 ("UA"), seeks an exemption from the Federal Aviation Regulations ("FARs") as listed and discussed below.

ACP’s team has flown its UAs, for recreational purposes, for hundreds of hours without incident. ACP’s UAs are 

equipped to take aerial videography and photography to enhance awareness for those individuals and companies 

unfamiliar with the geographical layout of certain areas and augment real estate listings and promote the use of 

certain real estate properties which provides an enhancement to academic research being performed in certain 

geographical areas. ACP’s UAs also serve to capture specific moments via videography or photography as seen fit by a 

client to capture (ie: aerial photography for group photos, weddings, reunions and other such client-sanctioned events) 

("purpose").

ACP’s exemption request will permit the operation of comparatively inexpensive UAs in tightly controlled, predetermined 

and limited airspace. This airspace will include areas away from general public, airports, heliports and vehicular traffic for

community videos, and within property boundaries for real estate listing videos and photos and for other videography and 

photography purposes as a client may see fit. Currently, similar lightweight, remote controlled UAs are legally operated by 

unmonitored and untrained amateur hobbyists with no safety plan or controls in place to prevent catastrophic events. ACP 

has safety protocols and controls in place to avoid and prevent public hazards as well as preventing the interference with 

manned aircraft which could cause a hazard or catastrophe. This acts to enhance safety protocols unique to ACP’s 

lightweight UAs being utilized specifically for real estate and personal videography and photography as contracted by a 

client. ACP is able to record flight data and other information gained through permitted flight operations which may be 

shared with the FAA through any required FAA reports to assist with the development of future FAA protocols and safety 

regulations.

The use of ACP's UAs for these purposes reduces the need to operate conventional aircraft, typically needed to perform 

these types of operations, provides an economic benefit to the business consumer as the ACP UAs provides higher 

quality imagery at a fraction of the cost of aerial videography and photography using conventional aircraft. These savings 

result in not only enhanced efficiency and productivity for the affected activities but added environmental and safety 

benefits to the public at large.
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CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

As described more fully below, ACP's requested exemption would authorize commercial operations of aerial videography 

and photography, using ACP's UAs, which will be operated under controlled conditions at an altitude of no greater than 

three hundred (300) feet AGL in airspace that is limited in scope and will have automated control features. As outlined 

below, the airspace in which ACP's UAs will operate within will be disclosed to the FAA in advance to flight operation. 

Finally, ACP's UAs will be used in lieu of comparatively hazardous operations now conducted with fixed wing and rotary 

conventional aircraft which should reassure the FAA that these operations will achieve at least an equivalent level or 

greater level of safety. 

In the interest of economic efficiency and public safety, ACP hereby respectfully applies for an exemption from the listed 

FARs to allow commercial operations of ACP's 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. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation's ("Administrator") 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." 

As discussed above and more fully described below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive UAs under controlled conditions in airspace that is limited and predetermined. 

Approval of this exemption would thereby enhance safety and fulfill the Administrator responsibilities to "...establish 

requirements for the safe operation of such aircraft systems in the national airspace system." Please see Section 333(c) 

of the Reform Act. 

Additionally, the FAA has already granted a previous exemption which is essentially identical to the exemption being 

sought by ACP. Please see FAA Exemption No. 11138 and FAA Exemption No. 11464.

The name and address of the applicant is: 

CAMA Ventures LLC 

DBA Andrew Ciesler Photography 

7768 Westcroft Dr. 

Sylvania, OH 43560 

(419) 318-9318 

REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a) & (b)

13 C.F.R. 61.133(a)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b)(2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b) 

14 C.F.R. 91.405(a)

14 C.F.R. 91.407(a)(1)

14 C.F.R. 91.409(a)(2)

14 C.F.R. 91.417(a) & (b) 
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CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the 

Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may 

operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of 

the Reform Act. In making this determination, the Secretary is required to determine which types of UAs do not create a 

hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UA's size, weight, speed, and operational capability;

• Operation of the UAs in close proximity to airports and populated areas; and 

• Operation of the UAs within visual line of sight ("VLOS") of the operator.

Reform Act§ 333 (a).

Lastly, if the Secretary determines that such vehicles "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) (emphasis 

added). ACP interprets this provision to place the duty on the Administrator to not only process applications for 

exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UA, if it should 

be determined that the conditions set forth herein do not fulfill the statutory requirements for approval. 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms 

includes exempting civil aircraft, as the term is defined under §40101 of the Act; that includes 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 

U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). 

ACP's UAs are rotorcraft weighing less than seven (7) pounds including energy source(s), equipment and any payload. 

They operate, under normal conditions at a ground speed of no more than thirty (30) knots and have the capability to 

hover, and move in the vertical and horizontal plane simultaneously. The UAs will operate only in line of sight and within 

safe operating parameters as outline in the owner’s manual. Such operations will insure that the UA will "not create a 

hazard to users of the national airspace system or the public" (Reform Act Section 333 (b)). 

 

Given the small size of the UAs involved and the restricted environment within which they will operate, ACP falls squarely 

within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, 

allow commercial operations of UAs to commence immediately. Also due to the size of the UAs and the restricted 

areas in which the relevant UAs will operate, approval of the application presents no national security issue. Given the 

clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the 

strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including 

enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UAs for 

aerial videography and photography operations, the grant of the requested exemptions is in the public interest. 

Additionally, there is economic efficiency created with the use of ACP's UAs as the typical cost to perform aerial 

videography and photography with helicopters and airplanes heavily multiplies the cost to business consumers 

and government agencies, including law enforcement, for the services which are to be provided by ACP. 

THE EXTENT AND BASIS OF THE RELIEF SOUGHT BY ANDREW CIESLER PHOTOGRAPHY 

Andrew Ciesler Photography (ACP) submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, 

seeking relief from any currently applicable FARs operating that presently prevents ACP from contemplated commercial 

video-graphic, photographic and other flight operations within the national airspace system. The Reform Act in Section 

332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the 
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CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

public's interest to do so. ACP's UAs meet the definition of "small unmanned aircraft" as defined in Section 331 and 

therefore the integration of ACP's ultralight weight UAs is expressly contemplated by the Reform Act. ACP would like to 

operate its ultralight weight UAs prior to the time period by which the Reform Act requires the FAA to promulgate rules 

governing such craft. This exemption allows ACP to provide direct experience and valuable information for formal 

regulation that can be administered uniformly to all commercial UA aerial videography and photography. The Reform Act 

guides the Administrator in determining the types of UAs that may operate safely in our national airspace system. These 

considerations include: weight, size, speed and overall capabilities of the UAs; whether the UAs will be operated near 

airports or heavily populated areas and; whether the UAs will be operated by line of sight (112 P.L. 95 § 333 (a)). Each 

of these items is favorable to the granting of an exemption to ACP. ACP's UAs utilize four (4) counter-rotating propellers 

for balance, control and stability along a built in camera and sonar system for added stability and safety. ACP's UAs are 

equipped with GPS and auto return safety technology. ACP's UAs weigh less than seven (7) pounds including camera 

and gimbal assembly. ACP puts safety first when considering any UA flight. ACP’s small UAs are designed to hover in 

place via GPS and operate in less than a 24 knot (27 mph) wind. In order to increase safety plus stability and limit harm 

and financial loss of property, ACP will not fly its UAs in winds exceeding 20 knots (23 mph). ACP's established safety 

systems include a GPS mode that allows its UAs to hover in place when radio controls are released. ACP's UAs have 

three modes to choose from, ACP utilizes the Intelligent Orientation Control (IOC) Flight (with GPS & compass module)

for aerial videography and photography. Intelligent Orientation Control (IOC) Flight (with GPS & compass module) 

includes safe circle for operation, position hold, self-leveling, altitude command, GPS, return home feature, and safety 

control to return home or land in the event of communication interruption between RC transmitter and UA. This mode is 

the safest, most reliable and stable mode to prevent accidents and being a hazard to others. When pilot communication is 

lost, ACP's UAs are designed to return then slowly descend to the point of takeoff. ACP does not operate its UAs near 

airports, hospitals, police heliports or news channel heliports. ACP does not operate its UAs in areas where general public 

is within fifty (50) to one hundred (100) yards depending on location, conditions and weather. ACP's pilots and observers 

are constantly on alert for any manned aircraft and prepared to immediately abort and land the UA at the nearest and 

safest ground point in the event a manned aircraft approaches or the ACP pilot or observer suspects a manned aircraft 

may approach the operating area of a ACP UA. ACP's UAs are capable of vertical and horizontal operations, and are 

flown only within line of sight of the pilot. ACP's UA flights generally last eighteen to twenty-two (18-22) minutes with an 

altitude under three hundred (300) feet and utilize battery power rather than combustible fuels. ACP does not operate its 

UAs below the manufacturer's recommended minimum charge levels for operation preferring to remain well within a safe 

operating range to insure adequate communication between radio control and the UAs to eliminate potential for crashes, 

loss of control or hazard. ACP’s UAs have a feature to automatically return to takeoff point when battery capacity is at the 

minimally required point to safely return. Fully charged reserve batteries are on hand to insure replacement for a 

sufficiently safe level of operation. ACP operates very conservatively and will not take risks that may cause a crash or that 

could create hazard to the public, property and manned aircraft. ACP has logged numerous practice flights in order to 

simulate flights for future commercial use to gain familiarization with the characteristics of this specific UA's performance 

under different temperature and weather conditions. 

ACP is extremely cautious when operating of its UAs and will not "create a hazard to users of the national airspace 

system or the public" (112 P.L. 95 § 333 (b)). Given the small size and weight of ACP's UAs, they fall well within 

Congress's contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate 

UAs into the national airspace system. ACP's UAs, utilized in hobby flight, have a demonstrable safety record and do not 

pose any threat to the general public or national security. 

ANDREW CIESLER PHOTOGRAPHY’S REQUEST WILL BENEFIT THE PUBLIC AT LARGE 

Aerial videography and photography for geographical awareness and for real estate marketing and promotion has been 

around for a long time through the use of manned fixed wing aircraft and helicopters. The challenge for smaller real estate 

companies and average landowners is that the expense related to manned videography and photography is cost 

prohibitive. Typically, only large businesses, large high end real estate companies and high net worth landowners are able 

to absorb such an enormous expense. This deprives non-luxury landowners and small revenue real estate companies 

from the enjoying the benefit of this valuable marketing and promotional tool. Manned aircraft pose a clear threat to the 

general public through potential catastrophic crashes that may occur. There are many documented events where a 

manned aircraft has crashed into populated areas with the size and combustibility of these manned aircraft causing large 

property damage, human injuries and loss of life. ACP's UAs pose no such threat since size and lack of combustible fuel 

alleviates any of these potential threats to the public. 
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CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

With the passage of the Reform Act, Congress has already proclaimed that it is in the public's interest to integrate 

commercially flown UAs into the national airspace system. The grant of the exemption request by ACP furthers the public 

interest through academic and visual awareness of the geographical benefits of certain areas and by making this cost 

effective alternative available to small real estate companies and the average landowner. ACP's ultralight UAs are battery 

powered and create no emissions that may harm the environment. In the unlikely event of an ACP UA crash, the 

consequence is far less than a full size helicopter or fixed wing aircraft, which are heavy and contain combustible fuel, 

crashing and causing catastrophic devastation to the public. 

The public's interest is furthered as ACP minimizes ecological and crash threat by permitting aerial videography and 

photography captured through ACP's battery operated ultralight UAs. Permitting ACP to immediately fly within national air 

space furthers not only public safety but economic growth. Granting ACP's exemption request substantially furthers the 

economic impact for any community and for companies looking to relocate or build in a certain community as well as 

individuals looking to relocate to a community for career advancement through academic and geographical awareness 

provided by ACP. In the end, the granting of this exemption to ACP will serve as a benefit and stimulus to any community. 

ACP’S EXEMPTION WILL NOT ADVERSELY AFFECT SAFETY AND WILL PROVIDE 

A LEVEL OF SAFETY AT LEAST EQUAL TO EXISTING FAA STANDARDS 

ACP's exemption will not adversely affect safety, as it will in fact enhance safety. ACP's ability to log significant, controlled 

and monitored flight time in FAA controlled airspace will allow ACP to contribute to the innovation and implementation of 

new, novel and undiscovered safety protocols for realtors that may be embraced by the National Association of Realtors, 

(NAR, http://www.realtor.org/) through consistent and ongoing cooperation with the FAA. Additionally, the FAA may 

utilize the new safety protocols for the use of UAs in FAA controlled airspace for all industries.

ACP submits the following representations of enhancements to current aerial videography and photography:

• ACP's UAs weigh less than 7 pounds complete with the camera and gimbal assembly;

• ACP will only operate its UAs below three hundred (300) feet which is well within the four hundred (400) feet 

ceiling having been established by the Reform Act of2012;

• ACP's UAs only operate for eighteen – twenty-two (18-22) minutes per flight;

• ACP lands its UAs prior to manufacturer's recommended minimum level of battery power;

• ACP's pilots operate the UAs through Visual Line of Sight only; 

• ACP's UAs have a GPS flight safety feature whereby the UA hovers and then slowly lands if communication 

with the pilot is lost;

• ACP actively analyzes its flight data and other sources of information to constantly update and enhance its 

safety protocols; 

• ACP only operates in reasonably safe environments which are strictly controlled and away from power lines, 

elevated lights, airports and actively populated areas; 

• ACP conducts extensive pre-flight inspections and protocol to ensure safety remains the primary concern;

• ACP always obtains all necessary permissions from the FAA and landowners prior to the operating its UAs 

and;

• ACP has established safety procedures in place to abort flights in the event of safety breaches or any 

potential danger. 

ACP's safety protocols provide a level of safety equal to or exceeding existing FAA rules. It is important to note that 

absent the integration of commercial UAs into our national airspace system, manned fixed wing airplanes and helicopters 

are the primary means of aerial videography and photography for community awareness and real estate uses. While the 

safety record of such helicopters is outstanding, there have been incidents involving loss of life as well as extensive 

property damage due to crashes of these manned aircraft and it is far safer and less expensive to operate a battery 

powered ultralight UA to accomplish the same task. The potential for loss of life is great diminished with a UA as ACP's 

UAs carry no people or fuel on board and the UAs are also very small and versatile which allows ACP to avoid hazards 

quickly and safely. 
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CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

Accordingly, ACP respectfully requests that the FAA grant the requested exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

ACP proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate 

with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to 

operations under the current regulatory structure because the proposed operations represent a safety enhancement to the 

operations conducted with conventional aircraft. The FAA has noted in past exemptions that "Conventional aerial video 

operations, using jet or piston-powered aircraft present risks associated with aircraft that weigh in the neighborhood of 

5,000 to 7,000 pounds or more, carry large quantities of fuel, passengers, and, in some cases, cargo. Such aircraft must 

fly to and from the survey location. Please see FAA Exemption 11110.

These limitations and conditions to which ACP agrees to be bound when conducting all operations under an FAA issued 

exemption include:

1. The UAs will weigh less than seven (7) pounds.

2. Maximum total flight time for each operational flight will be twenty-two (22) minutes. 

3. Flights will be terminated at fifteen percent (15%) battery power reserve should that occur prior to the twenty-two 

(22) minute limit. 

4. Flights will be operated at an altitude of no more than three hundred (300) feet AGL. 

5. Minimum crew for each operation will consist of the UA Pilot and a Visual Observer ("VO").

6. The UAs will only operate within a safe area. 

7. A briefing will be conducted with regard to the planned UA operations prior to flight operations. It will be 

mandatory that all personnel who will be performing duties with regard to the flight operations be present for this 

briefing. 

8. The Pilot and VO will have been trained in operation of UAs generally and received up-to-date information on the 

particular UA to be operated and the UA will be operated in conformity with ACP's protocols.

9. The PILOT and VO will at all times be able to communicate via voice communication. 

10. Written and/or oral permission from the relevant property holder(s), or their authorized representative(s), will 

be obtained. 

11. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including 

local law enforcement, fire, or other appropriate governmental agencies. 

12. If the UA loses communications or loses its GPS signal, the UA will return to the launch site of the UA, or another 

more appropriate site, and land. 

13. The UA will have the capability to abort a flight in case of unpredicted obstacles 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 ACP, 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 UA. In all cases, an analysis of these criteria demonstrates that the UA 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 hereunder is less than seven (7) pounds fully loaded, carries neither a pilot nor passenger, carries 

no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Unlike other civil aircraft, 
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CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

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, to provide security for the area of operation as is now done with 

conventional aerial videography and photography. 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

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 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 "limited," "restricted," "light-sport," "experimental," or 

"provisional," may be placed. Given the size of the UAs, two-inch lettering will be impossible. The word "experimental," or 

any other term as is so required, will be placed on the fuselage of the UAs in compliance with §45.29 (t).

The equivalent level of safety will be provided by having the UAs marked on its fuselage as required by §45.29 (t) where 

the pilot, observer and others working with the UAs will see the identification of the UAs as "Experimental." The FAA has 

issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

14 C.F.R. § 61.113(A) & (B); 61.133(A): PRIVATE PILOT PRIVILEGES ANDLIMITATIONS; PILOT IN COMMAND; 

COMMERCIAL PILOT PRIVILEGES AND LIMITATIONS: PILOT IN COMMAND

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, 

passengers, and cargo, the UA in this case is remotely controlled with no passengers or property of others on board. 

Section 61.133(a) requires an individual with a commercial pilot's license to be pilot in command of an aircraft 

for compensation or hire. ACP respectfully proposes that operator requirements should take into account the 

characteristics of the particular UA. ACP's UAs have various built-in technical capabilities that strictly limit the potential for 

operation outside of the operating conditions set forth in the exemption application including a fly back to launch point to 

terminate the flight. Since hobbyists are not required to have a pilot license, ACP requests exemption for the need of the 

pilot to be licensed as a pilot by the FAA.

ACP UAs contain the following safety features: 

• Detection of lost GPS or of insufficient satellites initiates an immediate return to launch location.

• Low power on the aircraft triggers escalating alarms at 30% and 15% levels.

• The aircraft weighs less than seven (7) pounds, fully loaded.

Given these safety features, ACP proposes that operators of the UAs should note be required to hold a commercial pilot's 

license.

ACP notes that the FAA has found that safety factors permitted operation of UAs by operators with these qualifications 

in the case of operations pursuant to public COAs where the mandatory operating conditions specified above are 

present. Please see Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) 

Operational Approval, at 20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to 

waive the pilot requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of ACP's UAs 

without a commercial pilot's license, under the conditions set forth herein.
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CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

The risks associated with the operation of ACP's UAs (given its size, speed, operational capabilities, and lack of 

combustible fuel) are so diminished from the level of risk associated with private pilot operations or commercial operations 

contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAs as set 

forth above meets or exceeds the present level of safety provided under 14 C.P.R. § 61.113(a) & (b) and does not rise to 

the level of requiring a commercial pilot to operate the aircraft under §61.133(a). 

Sections 61.113 (a) & (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 not requiring the 

pilot operating the aircraft to have a commercial pilot's license to operate these small UAs. Unlike a conventional aircraft 

that carries the pilot and passengers, the UAs are remotely controlled with no living thing on board. The area of operation 

is controlled and restricted, and all flights are planned and coordinated in advance. The level of safety provided by ACP 

exceeds that provided by a single individual holding a commercial pilot's certificate operating a conventional aircraft. 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 with a private pilot as 

the PILOT exceeds the present level of safety achieved by 14 C.P.R. §61.113 (a) & (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 and the requirements for maintenance and use of safety check 

lists prior to each flight. 

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 their 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. 
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CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

The equivalent level of safety will be maintained by keeping at the ground control point where the pilot flying the UAs will 

have immediate access to it. The FAA has issued the following exemptions to this regulation: Please see FAA Exemption 

Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602,32827, and 10700.

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. An equivalent level of 

safety will be provided. The pilot 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 91.109 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. Please see FAA Exemption Nos. 5778K & 9862A. The equivalent level of safety is provided as 

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 UAs that are a helicopter and the exemption 

requests authority to operate at altitudes up to three hundred (300) feet AGL, an exemption may be needed to allow such 

operations. As set forth herein, except for the limited conditions, the UAs will never operate at higher than three hundred 

(300) feet AGL. It will however be operated in a restricted area with security perimeter, where buildings and people will 

not be exposed to operations without their pre- obtained consent. 

The equivalent level of safety will be achieved given the size, weight, 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 or local officials. Because of the advance 

notice to the property owner(s), or their authorized representative(s), all affected individuals will be aware of the planned 

flight operations. When one compares the flight operations proposed herein with aircraft or rotorcraft weighing far in 

excess of the less than seven (7) pounds and the lack of flammable fuel, any risk associated with these proposed 

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

(500) feet AGL. In addition, the low altitude operations of the UAs will ensure separation between these small 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 UA 

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, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight.
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CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

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."

Michael's Drone Photography believes that an equivalent level of safety can be achieved by limiting flights to 

twenty-two (22) minutes or fifteen percent (15%) of battery power whichever happens first. This restriction would be more 

than adequate to return the UAs to their planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

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 UAs fully loaded weight is no greater than seven (7) pounds 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 UA.

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

flying the UA will have immediate access to them to the extent they are applicable to the UA. The FAA has issued 

numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 

9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

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

ACP. 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 UAs 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 UAs may land immediately 

and will be operating from no higher than three-hundred (300) feet AGL. The operator will ensure that the UAs are 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. 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be 

determined that publication is needed: 

ACP 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) (1); 

91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle weighing less than 

fifty-five (55) pounds (25 Kg) in its operations.
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CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

Approval of exemptions allowing commercial operations of UAs in the purposes outlined above (or similar operations) 

will enhance safety by reducing risk. Conventional aerial videography and photography operations, using jet or piston 

power aircraft, operate at extremely low altitudes just feet from the object being photographed and often in extreme 

proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of four 

thousand (4,000) pounds, carrying large amounts of jet A or other fuel (one hundred and forty (140) gallons for jet 

helicopters). Such aircraft must fly to and from the site's location. In contrast, a UA weighing less than seven (7) pounds 

and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried 

on board. The UA is carried to the site of the purposes outlined above (or similar operations) and not flown to the site. 

The UA will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft 

flights.

The operation of small UAs, weighing less than seven (7) pounds, conducted in the strict conditions outlined above, will 

provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting ACP

from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, 

close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted 

with turbine helicopters operating in close proximity to the ground and people.

PRIVACY

All flights will occur over private, controlled or approved property with the property owner's, or their authorized 

representative, prior consent and knowledge. The aerial videography and photography will be of structures and property 

whose owner, or authorized representative, has consented to the aerial videography and photography or otherwise have 

agreed to be in the area where aerial videography and photography will take place. The grant of this exemption request 

will provide improved safety in all operations.

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012- size, weight, speed, operating capabilities, 

proximity to airports and populated areas and operation within visual line of sight and national security-provide more 

than adequate justification for the granting of the requested exemptions allowing commercial operation of ACP's UAs.

SUMMARY OF ACP'S REQUEST FOR AN FAA EXEMPTION

1. ACP’s UAs must weigh less than seven (7), including energy source(s) and equipment. Operations 

authorized by the grant of an exemption are limited to the following aircraft: Michael's Drone 

Photography's UA aircraft variant, bearing serial #CC26195937365C onward as additional UAs are utilized 

by ACP provided the additional UAs are of the same or similar specifications as the UA bearing serial 

#CC26195937365C. Any proposed operations of any other aircraft will require a new petition or a petition to 

amend this grant.

2. ACP's UAs may not be flown at a ground speed exceeding thirty (30) knots.

3. ACP's flights must be operated at an altitude of no more than three hundred (300) feet above ground level 

(AGL), as indicated by the procedures. All altitudes reported to ATC must be in feet AGL.

4. ACP's UAs must be operated within the VLOS of the pilot at all times. This requires the pilot to be able to use 

human vision unaided by any device other than corrective lenses.

5. All ACP operations must utilize a VO. The VO may be used to satisfy the VLOS requirement as long as the 

pilot always maintains VLOS capability. The VO and pilot must be able to communicate verbally at all times.

6. Prior to each flight the pilot must inspect the UA to ensure it is in a condition for safe flight. If the inspection 

reveals a condition that affects the safe operation of the UA, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UA is found to be in a condition for safe flight. A Ground 

Control Station, if utilized, must be included in the preflight inspection. All maintenance and alterations must 
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CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

be properly documented in the aircraft records.

7. Any UA that has undergone maintenance or alterations that affect the UA's operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The pilot 

who conducts the functional test flight must make an entry in the UA's aircraft records of the flight.

8. ACP must follow the manufacturer's UA aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, 

replacement, and inspection/maintenance requirements must be established and identified. At a minimum, 

requirements for the following may be included in protocols and controls to be established by ACP:

a. Actuators/Servos;

b. Transmission (single rotor);

c. Power plant (motors);

d. Propellers;

e. Electronic speed controller;

f. Batteries;

g. Mechanical dynamic components (single rotor);

h. Remote command and control;

1. Ground control station (if used); and

J. Any other components as determined by ACP.

9. Prior to operations conducted for the purposes outlined above (or similar operations), the pilot must have 

accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of twenty-five (25) hours 

of total time as a UA rotorcraft pilot (single blade or multi-rotor) and at least ten (10) hours logged as a UA 

pilot with multi-rotor UA which is similar to the UA to be utilized pursuant to this exemption. Prior documented 

flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. 

Training, proficiency, and experience-building flights must be conducted under an exemption to accomplish 

the required flight cycles and flight time. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered nonparticipants, and the PILOT must operate the 

UA with appropriate distance from nonparticipants in accordance with 14 CFR §91.119.

10. Prior to operations conducted for the purposes outlined above (or similar operations), the PILOT must 

have accumulated and logged, in a manner consistent with 14 CFR §61.51(b), a minimum of five (5) hours as 

a UA pilot operating the make and model of UAs to be utilized for operations under the exemption and three 

(3) take-offs and three (3) landings in the preceding ninety (90) days. Training proficiency, experience-building, 

and take-off and landing currency flights can be conducted under the grant of exemption to accomplish the 

required flight time and ninety (90) day currency. During training, proficiency, experience-building, and take-off 

and landing currency flights all persons not essential for flight operations are considered 

nonparticipants, and the pilot must operate the UA with appropriate distance from nonparticipants in 

accordance with 14 CFR § 91.119. 

11. ACP shall not permit the pilot to operate the UAs for the purpose of aerial videography or photography (or 

similar operations), unless the pilot 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 how the UA will be operated under 

this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

12. The UA may not be operated directly over any person, except authorized and consenting personnel and 

persons, below an altitude that is hazardous to persons or property on the surface in the event of a UA's 

failure or an emergency. 

13. At all times, those persons must be essential to the purposes outlined above (or similar operations). Because 

these procedures are specific to participating persons, no further FSDO or aviation safety inspector approval 

is necessary for reductions to the distances specified in ACP's manuals. 

14. ACP's flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, 
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CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

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 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 pilot 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 PILOT, VO, operator trainees or essential persons do not present an undue 

hazard to those persons per§ 91.119(a).

15. If the UAs lose communications or loses its GPS signal, the UAs must return to a pre-determined location 

within the security perimeter and land or be recovered.

16. The UAs must abort the flight in the event of unpredicted obstacles or emergencies. 

17. Each UA operation must be completed within twenty-two (22) minutes flight time or with fifteen (15%) battery 

power remaining, whichever occurs first.

18. ACP must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to 

conducting any operations under this grant of exemption. This COA will also require ACP to request a Notice 

to Airman (NOTAM) not more than seventy-two (72) hours in advance, but not less than forty- eight (48) hours 

prior to the operation.

19. All aircraft operated in accordance with this exemption must 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 must be as large as practicable. 

20. ACP has developed procedures to document and maintain a record of the UA's maintenance, preventative 

maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the 

UAs.

21. Each UA operated under this exemption must comply with all manufacturer Safety Bulletins. 

22. The preflight inspection section in ACP's Confidential Protocols and Controls Exhibit includes the following 

requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or 

equipment, not covered in the relevant preflight inspection.

23. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must 

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

agency requirements. 

24. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the pilot at the Ground 

Control Station, if utilized, of the UA at any time the UA is operating. These documents must be made 

available to the Administrator or any law enforcement official upon request.

25. ACP's UAs must remain clear and yield the right of way to all other manned operations and activities at all 

times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, 

etc.).

26. ACP's UA operations may not be conducted during night, as defined in 14 CFR §1.1. All operations must be 

conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are 

not authorized.

27. ACP's UAs may not be operated by the pilot from any moving device or vehicle.

28. ACP's UAs may not be operated less than five-hundred (500) feet below or less than two-thousand (2,000) 

feet horizontally from a cloud or when visibility is less than three (3) statute miles from the pilot.

29. ACP's UA may not operate in Class B, C, or D airspace without written approval from the FAA. The UA may 

not operate within five (5) nautical miles of the geographic center of a non-towered airport as denoted on a 

current FAA-published 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 ACP's COA. The 

letter of agreement with the airport management must be made available to the Administrator upon request.

30. 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 UA Integration Office (AFS-80) within 
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CAMA Ventures LLC, 7768 Westcroft Dr., Sylvania, OH 43560 

Phone: (419) 318-9318 

twenty-four (24) hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per 

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

31. ACP's UAs, the UA's pilot, and the UA's operations must comply with all applicable parts of 14 CFR 

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

As mentioned above, the FAA has already granted a previous exemption which is essentially identical to the 

exemption being sought by Andrew Ciesler Photography in this petition for an exemption. Please see FAA Exemption 

No. 11138 and 11464. 

Therefore, ACP respectfully requests the FAA grant an exemption pursuant to its application as outlined above.

Sincerely,

Aaron M. Miller

Manager

CAMA Ventures LLC 

DBA Andrew Ciesler Photography