Gottesman	Photography,	LLC

1018	Oregon	Ave.

Columbus,	OH	43201

gottesmanphotography@gmail.com

September	3,	2015

US	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington	DC	20590

Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	and Part	11	

of	the	Federal	Aviation	Regulations	from:	14	CFR	Part	21	Subpart	H, 14	CFR

61.113(a)	and	(b),	14	CFR	91.103,	14	CFR	91.109,	14	CFR	91.119,	14	CFR	

91.121,14	CFR	91.151,	14	CFR	91.405,	14	CFR	407,	14	CFR	409,	14	CFR	417

To	Whom	It	May	Concern:

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

“Reform	Act”)	and	14	C.F.R.	Part	11,	Gottesman	Photography,	LLC,	an	operator	of

Unmanned	Aircraft	Systems	(“UASs”)	for	aerial	photography and	video	for	the	real	

estate,	advertising,	agriculture,	and	surveys,	hereby	applies	for	an	exemption	from	

the	Federal	Aviation Regulations	(“FARs”)	to	allow	commercial	operation	of	its	

UASs.

Gottesman	Photography,	LLC’s	requested	exemption	would	permit	the	operation	of	

small,	unmanned	UAS	under	55	pounds	to	conduct	aerial	video	and	photography	

under	the Operational	Control	of	an individual	with	UAS	experience;	under	direct	

control	of	a	Pilot	in	Command	(PIC);	within	Visual	Line	of	Sight	(VLOS);	while	

utilizing	a	second	person	for	the	purpose	of	a	Safety	Observer.	As	established	by	the	

exemptions	already	granted	by	the	FAA,	approval	of	Gottesman	Photography

exemption	would	enhance	safety	and	fulfill	the	Secretary	of	Transportation’s	(the	

FAA	Administrator’s)	responsibilities	to	“...establish	requirements	for	the	safe	

operation	of	such	aircraft	systems	in	the	national	airspace	system.”	Section	333(c)	of	

the	Reform	Act.

The	name	and	address	of	the	applicant	is:

Gottesman	Photography,	LLC

Attn:	Andrew	Gottesman

PH:	614-906-1472

Email:	gottesmanphotography@gmail.com

Address:	1018	Oregon	Ave.	Columbus,	OH	43201

Regulations	from	which	the	exemption	is	requested: 14	CFR	Part	21	Subpart	H,	14	

CFR	61.113(a)	and	(b), 14	CFR	91.103,	14	CFR	91.109,	14	CFR	91.119,	14	CFR	

91.121, 14	CFR	91.151,	14	CFR	91.405,	14	CFR	407,	14	CFR	409,	14	CFR	417
UASs	operated	by	Gottesman	Photography,	LLC	weigh	less	than	55	pounds,	

including	the	payload	(i.e.	camera,	lens,	and	gimbal).	They	operate	at	speeds	of	no	

more	than	50	knots,	can	hover,	and	can	simultaneously	move	vertically	and	

horizontally.	Gottesman	Photography,	LLC	will	only	operate	its	UASs	in	line	of sight	

below	400	feet	AGL.

Such	operations	will	insure	that	the	UAS	will	“not	create	a	hazard	to	users	of	the	

national	airspace	system	or	the	public.”

Given	the	small	size	of	Gottesman	Photography,	LLC’s	UASs	and	the	safety	

considerations	proposed	in	this	petition,	Gottesman	Photography,	LLC’s	UAS	

operations	adhere	to	the	Reform	Act’s	safety	requirements.	Additionally,	due	to	the	

size	of	the	UASs	and	the	proposed	use	in	which	they	will	operate,	approval	of	this	

application	presents	no	national	security	issues.	

Aircraft	And	Equivalent	Level	Of	Safety

The	operating	limitations	proposed	by	Gottesman	Photography provide	for	at	least	

an	equivalent	or	higher	level	of	safety	because	operations	further	enhance	safety	of	

real	estate,	advertising	or	marketing	filming	using	conventional	aircraft.

Gottesman	Photography Proposed	limitations	and	conditions	include:

•	The	UASs	will	weigh	less	than	55	pounds.

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

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

terminated	at	25%	battery	power	reserve	should	that	occur	prior	to	the	30	minute	

limit.

•	Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL,	and	not	more	

than	200	feet	above	an	elevated	platform	from	which	filming	is	planned.

•	Minimum	crew	for	each	operation	will	consist	of	the	UAS	Pilot,	and	a	visual	

observer.

•	The	UAS	will	be	operated	within	a	confined	area	pre	programmed into	the	

software,	avoiding	inadvertent	fly-away	or	flight	beyond	set	parameters.

•	The	operator	will	obtain	consent	of	all	persons	involved	in	the	filming	and ensure	

that	only	consenting	persons	will	be	allowed	within	50	feet	of	the flight	operation.

•	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.
•	If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	have the	

capability	to	return	to	a	pre-determined	location	and	land.	The	location	will	be clear	

of	all	persons	or	property	during	the	duration	of	the	flight.

•	The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles	

or emergencies.

•	The	UASs	will	operate	on	the	following	frequencies,	which	are	all	FCC	compliant

and	do	not	require	specific	licenses	when	transmit	power	is	limited	to	1	watt:

902	to	928	MHz,	2.400	to	2.4835	GHz,	and	5.725	to	5.875	GHz.

•	The	UASs	will	not	operate	in	the	proximity	of	airports.

14	C.F.R.	Part	21, Subpart	H:	Airworthiness	Certificates

Given	the	size	and	limited	operating	area	associated	with	the	UASs	to	be	utilized by	

Gottesman	Photography,	this	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	the	UASs	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	UASs.	In	all	cases,	an	analysis	of these	

criteria	demonstrates	that	a	UAS	operated	without	an	airworthiness certificate,	in	a	

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.

14	C.F.R.	§	61.113(a)	and	(b):	Private	Pilot	Privileges	and	Limitation

Pilot	in	Command	Sections	61.113	(a)	and	(b)	limit	private	pilots	to	noncommercial

operations.	Because	the	UAS	will	not	carry	a	pilot	or	passengers,	the proposed	

operations	can	achieve	an	equivalent	level	of	safety	of	current	operations by	

requiring	all	operations completed	by	a	trained	UAS	operator.	Unlike	conventional	

manned	aircraft,	a ground-based	operator	remotely	controls	a UAS.	The	operational	

area	is	limited, and	all	flights	are	planned	and	coordinated	in	advance.	The	level	of	

safety	exceeds that	provided	by	a	single	individual	holding	a	commercial	pilot’s	

certificate	operating a	conventional	aircraft.	The	risks	associated with	the	use	of	a	

UAS	are	far	lower from	those	associated	with	commercial	operations	contemplated	

by	Part	61.

Allowing	operational	control	of	a	UAS	by	a	private	pilot	exceeds	the	present	level	of

safety	sought	by	14	C.F.R.	§61.113	(a)	and	(b).

14	C.F.R.	§	91.103:	Preflight	Action

Section	91.103	requires	each	pilot	to	preflight	an	aircraft	before	flight	to	insure the	

safety	of	flight.	As	FAA	approved	rotorcraft	flight	manuals	will	not	be	used, an	

exemption	is	requested.	However,	an	equivalent	level	of	safety	will	be	provided.
The	PIC	will	take	all	actions,	including	reviewing	weather,	airspace,	NOTAMS,

TFRs	flight	battery	requirements,	landing	and	takeoff	distances,	and	performance

data	before	commencement	of	flight.	Additionally	all	UAS	will	be	checked	for

security	of	attached	components	prior	to	every	flight.

14	C.F.R.	§	91.109:	Flight	Instruction

Section	91.109	states,	“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.”	The	proposed	UASs	will	be	operated	utilizing	an	

autopilot to	maintain	controlled	flight,	and	all	UASs	are	programmed	to	return	to	a	

level attitude	and	hover	when	the	controls	are	returned	to	a	neutral	position.	

Because	of these	built	in	safety	features,	dual	control	is	not	necessary	in	order	to	

maintain	an equivalent	level	of	safety	proposed	by	section	91.109	during	training.	

All	training	will be	conducted	in	a	controlled	environment	as	to	not	cause	undue	

harm	or	damage	to persons	or	property.

14	C.F.R.	§91.119:	Minimum	Safe	Altitudes

Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft.	Section

91.119	provides,	in	pertinent	part,	that:	“except	when	necessary	for	takeoff	or

landing,	no	person	may	operate	an	aircraft	below	the	following	altitudes...

(c)	Over	other	than	congested	areas.	An	altitude	of	500	feet	above	the	surface,

except	over	open	water	or	sparsely	populated	areas.	In	those	cases,	the	aircraft may	

not	be	operated	closer	than	500	feet	to	any	person,	vessel,	vehicle,	or structure.”

Because	Gottesman	Photography,	LLC	requests	authority	to	operate	at	altitudes	only	

up	to 400	AGL,	and	not	more	than	200	above	an	elevated	platform	from	which	

filming is	planned,	an	exemption	is	needed	to	allow	such	operations.

The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	and	speed of	

the	UAS	as	well	as	the	location	where	it	is	operated.	All	affected	individuals	will be	

informed	of	the	planned	flight	operations.	Compared	to	flight	operations	for manned	

aircraft	and	the	lack	of	flammable	fuel,	any	risk	associated	with	the proposed	UAS	

operations	is	far	less	than	conventional	aircraft	operating	at	or	below

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

between	a	UAS	and	conventional	aircraft.

14	C.F.R.	§91.121	Altimeter	Settings

Section	91.121	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	a	UAS

may	not	have	a	barometric	altimeter,	but	instead	reference	a	GPS	altitude,	an

exemption	is	needed.	The	operator	will	achieve	an	equivalent	level	of	safety,

confirming	the	altitude	of	the	launch	site	shown	on	the	GPS	altitude	indicator	before

flight.
14	C.F.R.	§91.151:	Fuel	Requirements	for	Flight	in	VFR	Condition

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.	.	.	

.”	The	battery	powering	the	proposed	UASs	provides	approximately

30	minutes	of	powered	flight.	Therefore	the	UAS	cannot	meet	the	30-minute reserve	

requirement	in	14	CFR	§91.151.	In	lieu	of	this	requirement	the	UAS flights	will	be	

terminated	at	approximately	25%	remaining	battery	life	or	better.

Gottesman	Photography,	LLC	believes	that	an	equivalent	level	of	safety	can	be

achieved	by	limiting	flights	to	25%	of	battery	power,	this	restriction	would	be more	

than	adequate	to	return	the	UAS	to	its	pre-determined	landing	zone	from anywhere	

in	its	limited	operating	range.

Gottesman	Photography,	LLC	is	not	seeking	an	exemption	for	night-time	UAS

operations.

14	C.F.R.	§91.405:	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	sections	and	Part	43	apply	only	to	aircraft	with	an	airworthiness

certificate,	these	sections	will	not	apply	to	Gottesman	Photography operations.

Maintenance	will	be	accomplished	by	the	operator	in	accordance	with	the

manufacturers	recommended	procedures.	An	equivalent	level	of	safety will	be	

achieved	because	the	UASs	are	limited	in	size,	will	carry	a	small	payload	and operate	

only	for	limited	periods	of	time.	A	preflight	inspection	will	be	performed	prior to	

every	flight	to	ensure	no	mechanical	issues	are	present.	If	mechanical	issues arise,	

the	UAS	can	land	immediately	and	will	be	operating	from	no	higher	than 400	feet	

AGL.	The	operator	will	ensure	that	the	UAS	is	in	working	order	prior	to flight,	and	

perform	any	required	maintenance.	Moreover,	the	operator	is	the	person most	

familiar	with	the	UAS	and	best	suited	to	maintain	it	in	an	airworthy	condition

14	C.F.R.	§91.407:	Operation	after	Maintenance

Functional	check	flights	will	be	conducted	away	from	people	or property	after	any

maintenance	has	been	accomplished	on	the	UAS.	The	UAS	may	be	returned	to

service	once	it	has	been	determined	safe	for	flight.
14	C.F.R.	§91.409:	Inspections

Due	to	the	small	size	of	the	UASs	that	will	be	operated	by	Gottesman	Photography,	

LLC and	limited	components,	I request	that	the	UASs	be	exempt	from	regularly	

scheduled	inspections.	To	meet	an	equivalent	level	of	safety	sought	by	14CFR

91.409,	all	UASs	will	be	thoroughly	inspected	prior	to	flight.	Since	the	UASs	will have	

limited components,	a	thorough	inspection	can	be	accomplished	before	each flight,	

eliminating	the	need	for	periodic,	time	based,	or	flight-hour	based	inspection cycles.

14	C.F.R.	§91.417:	Maintenance	Records

As	previously	described,	the	UASs	proposed	size	and	use	significantly	limits	the

amount	of	maintenance	required.	The	UASs	that	will	be	operated	by	Limitless

Drones,	LLC	are	designed	by	the	manufacturer	for	the	average	hobbyist	to purchase	

and	fly	with	minimal	assembly,	regular	preventative	maintenance	is	limited to	

security	of	attached	components	and	proper	storage	of,	and	charging	of	batteries.

As	such,	Gottesman	Photography,	LLC	requests	an	exemption	from	maintaining

maintenance	records	as	prescribed	by	14CFR	91.417.	However,	in	order	to	operate

as	safely	as	possible,	Gottesman	Photography,	LLC	will	keep	a	running	log	of	all

maintenance	performed	on	each	UAS,	and	any	anomalies	noted	during	operation	in

order	to	diagnose	and	prevent	problems	with	the	UAS.

Summary	for	Publication

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:

Gottesman	Photography,	LLC	seeks	an	exemption	from	the	following	rules:

14	CFR	Part	21	Subpart	H,	14	CFR	61.113(a)	and	(b),	14	CFR	91.103,

14	CFR	91.109,	14	CFR	91.119,	14	CFR	91.121,14	CFR	91.151,	14	CFR	91.405,

14	CFR	407,	14	CFR	409,	14	CFR	417	to	operate	commercially	small	unmanned

vehicles	(55	pounds	or	less)	for	aerial	photography	and	video	for	the	real	estate,

advertising,	agriculture,	and	surveys.

As	established	by	the	UAS	exemptions	already	granted	by	the	FAA,	allowing

commercial	operations	of	UASs	in	the	real	estate	and	film	industry	will	enhance

safety	by	reducing	risk.	Conventional	film	operations,	using	turbine	aircraft,	operate

at	low	altitudes	and	present	the	risks	associated	with	aircraft	that	weigh	thousands	

of pounds,	and	carry	large	amounts	of	fuel.	Such	aircraft	must	also	fly	to	and	from	

the	film location.	In	contrast,	a	UAS	weighing	fewer	than	55	pounds	and powered	by	

batteries virtually	eliminates	all	of	that	risk	given	the	small	size	and	lack	of	

combustible	fuel.	The UAS	is	carried,	and	not	flown,	to	a	film	location.	In	this	regard,	

the	UAS	carries	no passengers	or	crew,	therefore	will	not	expose	anyone	to the	risks	

associated	with manned	flights.	The	operation	of	UASs	conducted	in	accordance	

with	this	request	will provide	an	equivalent	level	of	safety	supporting	the	grant	of	

the	exemption	requested herein.	The	UASs	operate	at	slow	speeds,	close	to	the	

ground,	and	within	a	limited range.	As	a	result,	they	are	far	safer	than	conventional	
operations	conducted	with turbine	helicopters	carrying	fuel	and	flying	near	the	

ground	and	people.

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	of	2012

(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	to	grant	Gottesman	Photography,	LLCs	requested	

exemption, allowing	for	Gottesman	Photography,	LLC’s	UAS	for	marketing	of	Real	

Estate,	advertising,	agriculture,	and	surveys.

Sincerely,

Andrew	Gottesman,	Owner

Gottesman	Photography,	LLC