United States Department ofTransportation Docket Management System 1200 NewJersey Ave., SE West Building Ground Floor Room W12-140 Washington, DC 20590 Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act of2012 August 28, 2015 Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and C.F.R. Part 11, Jonathan A. Steiner, Owner and operator ofSmall Unmanned Aircraft Systems (UASs), request to be exempted from the Federal AviationRegulations (FARs) listed below so Jonathan A. Steiner may operate UASs commercially in airspace regulated by the Federal Aviation Administration; as long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by section 333. The Name and address ofthe applicant is: Jonathan A. Steiner, ChiefPilot (FAA Licensed) 6317-C GraycliffDrive BocaRaton, Florida 33496 561-644-2023 Jashighspeed@gmail.com As described below, the requested exemption would pel1Ilit the operation oflightweight (less than 55 lbs. total take offgross weight) UASs under controlled conditions for commercial use by professional certificated pilots thereby enhancing safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to"

.... establish requirements for the safe operation ofsuch aircraft systems inthe national airspace system." Section 333(c) ofthe Reform Act. Jonathan A. Steiner respectfully requests the grant ofan exemptionto the following specific sections ofthe Title 14 Code offederal Regulations allowing it to operate lightweight UAS's for commercial use: 14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 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) & Closed Set Photography & Video. Jonathan A. Steiner submits this application 

### in accordance with the Reform Act, 112 P.L. 95 331-334, seeking relieffrom any currently applicable FAR's operating to prevent future commercial use ofsmall UASs to operate in the national airspace system as described below. The Reform Act Section 332 provides for such integration ofcivil unmanned aircraft systems into our national airspace system as it is inthe public's interest to do so. Jonathan A. Steiner's lightweight UASs meet the definition of "small unmanned aircraft" as defined in section 331 and therefore the integration ofJonathan A. Steiner' slightweight UASs are expressly contemplated by the Reform Act. Jonathan A. Steiner would like to operate its lightweight UASs priorto the time period by whichthe Reform Actrequires the FAAto promulgate rules governing such aircraft. The Reform Act directs the Secretary ofTransportationto considerwhether certain unmanned aircraft systems may operate safely inthe national airspace system (NAS) before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine whichtypes ofUASs do not create a hazard to users ofthe NAS or the public or pose a threatto national security in light ofthe following:

• The UAS's size, weight, speed and operational capability • Operation ofthe UAS inclose proximity to airports andpopulated areas • Operation oftheUAS within visual line ofsight ofthe operatorReform Act 333 (a) Ifthe secretary determines that such vehicles "may operate safely inthe National Airspace System, the Secretary shall establish requirements for the safe operation ofsuch aircraft in the National Airspace System."

Jonathan A. Steiner's UAS's are rotorcraft weighing less than 55 pounds including payload. They operate at a speed ofless than 50 knots and have the capability to hover and move inthe vertical and horizontal plane simultaneously. The UAS will operate only withinthe line ofsight ofthe pilotwithin a protected flight area as described below. Such operations will insure thatthe UASs will not create a hazard to the users ofthe national airspace system orthe public. The small nature ofthe UASs utilized by Jonathan A. Steiner combined withthe safety protocols outlined belowwill allow for a greater than equivalent level ofsafety in which Congress envisioned that the FAAmust, by exemption allow commercial operations of UASs to commence immediately. Also due to the size ofthe UASs and the areas and altitudes they will operate, approval ofthe exemptionpresents no national security issue and absolutely minimal safety concerns which have been mitigated through a rigorous risk managementprocess. Giventhe clear direction given in Section 333 ofthe Reform Act, the authority contained inthe Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations, the significantpublic benefit, including enhanced safety, reduced emissions utilizing UASs verse traditional aircraft as well as the economic impact ofgreatly reducing the cost ofaerial photography thereby benefiting the greater public's interest. Accordingly, the applicant requests that the FAA grant the requested exemption without delay.The following limitations are considered to be binding for the operation ofUASs for commercial purposes by Jonathan A. Steiner: 1. Flights will be operated inthe line-of-sightby a ground-based pilot 2. Flights will only occur inthe daytime and clear ofclouds 3. The UASs will weigh less than 55lbs at take offand during flight 4. Flights will be terminated with 25% ofbattery life remaining 5. Flights will be operated at an altitude at orbelow 400' AGL

6. Pilots, cameraoperators and observers will be trained as to the applicable portion of the UAS's manual as well as the SOPs.

7. Minimum UAS crew will be one certificated Private/Instrumentrated pilot orhigher rating with a current FAAmedical. A camera operator and or observermay be added as required to further reduce the possibility oftask saturation bythe pilot depending onthe mission requirements.

8. Pilot, observer and camera operator will maintain real time communication capability throughout flight operations.

9. The UAS Pilot will conduct a full site survey to determine the Area ofResponsibility (AOR). This AORis the actual areafor UAS operations for a particular day. Each survey will include the assessment ofpotential hazards to include but not limited to airspace classification, NOTAMS, temporary flight restrictions, closest airport proximity, natural and manmade obstacles, and unnecessary persons which may pose a risk to operations or safety. 

### Ifdeemed necessary, the crewwill employ additional personal as safety observers. 10. Jonathan A. Steiner will employ safety observers as well as sign notifications 

### in areas close to public activity.

11. A thoroughbriefmg will be conducted, prior to the first flight ofthe day 

### in an AOR, utilizing the briefing guide 

### inthe SOPs. All persons who will be inthe AORwhile UAS flights are conducted will be present for this briefing.12. Jonathan A. Steiner will obtain consent (verbal orwritten) for any persons who need to be within 100 feet ofUAS flight operations.

13. Written and orverbal permission from the relevant property owners will be obtained priorto flight.

14. All required permissions and permits would be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire or other governmental agencies. 15. Ifthe UAS loses communications or loses its GPS signal, the UAS will have the capability to return to a pre-determined location within the AOR and land autonomously. 16. The UAS will have the ability to abort a flight in case ofunpredicted obstacles or emergencies. 14 C.F.R Part 21 Subpart H: Airworthiness Certificates 14 C.F.R. 91.7(a), 91.203 (a)(1) Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates inrelation to FAR91.203(a)(1) The size, weight and defined area ofoperations for Jonathan A. Steiner'sUAS flights permits exemption from Part 21 because Jonathan A. Steiner meets an equivalent level ofsafety pursuantto Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement underboththe ACT (49 U.S. C. 44701(t)) and Section 333 ofthe Reform Act. Bothpieces oflegislationpermitthe FAA to exempt UASs from the airworthiness certificate requirement in consideration ofweight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Jonathan A. Steiner meets or exceeds each ofthese elements. 14 C.F.R. 91.203 (a &b) provides for carrying ofcivil aircraft certifications and registrations. They are inapplicable for the same reasons stated above. The equivalent level ofsafety will be achieved by maintaining such certifications and registrations at Jonathan 

### A. Steiner's flight operations center. 14 C.F.R. 91.7(a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable inthe form contemplatedby the FARs, this regulation is inapplicable. 14 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual inthe Aircraft 14 C.F.R. 91.9(b)(2) requires an aircraft flight manual inthe aircraft. As there are no pilots ofpassengers, and giventhe size ofthe UASs, this regulation is inapplicable. An equivalent level ofsafety will be achieved by maintaining an operators manual at the flight operations center. The FAAhas previously issued exemptions to this regulation in

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ExemptionNos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. 91.103(b) Preflight actions 14 C.F.R. 91.103 Eachpilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This informationmust include: 

### (b) For any flight, runway lengths at airports ofintendeduse, andthe following takeoffand landing distance information. This subparagraph is not applicable due to our offairfield operations. 14 C.F.R. 91.109 Flight instructions; Simulated instrument flight and certain flight tests. 14 C.F.R. 91.109 and all the subparagraphs address the operation ofa civil manned aircraft in conjunctionwithtraining and flight tests. The UAS to be employed by Jonathan A. Steiner are notdesignated inthis category. 14 C.F.R. 91.121 Altimeter Settings 14 C.F.R. 91.121 regarding altimeter settings is inapplicable because Jonathan A. Steiner'sUASs utilize GPS systems and internal gyroscopes to provide spatial stability and a reference datum. 14 C.F.R. 91.151 Fuel Requirements for Flight in VFR Conditions 14 C.F.R. 91.151 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 ofintended landing, and assuming normal cruising speed. The battery powering the UAS provides approximately 15 minutes ofpowered flight, which is less than the reserve requirement alone by FARs for day. Given the limitations onthe UAS's flight envelope, proposed AOR size, battery life and its ability to land immediately it is reasonable to allow an exception. An equivalent level ofsafety canbe achieved by limiting flights to 25% ofbattery power. This restriction wouldbe more than adequate to returnthe UAS to its planned landing zone inthe AOR. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673 and 10808. 14 C.F.R. 45.23 Marking ofthe Aircraft

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Applicable Codes ofFederal regulations require aircraft to be marked according to certain specifications. Jonathan 

### A. SteinersUASs are unmanned; do not have a cabin, cockpit orpilot station on whichto mark certain words orphrases. Further, two-inch lettering is impractical to place on such small aircraft. Jonathan A. Steiner. will, however, place the word "EXPERIMENTAL" onits fuselage as required by 14 C.F.R. 45.29 

### (f) so that the pilot, camera operator, observer and any other persons operating 

### inthe AORcan see the markings onthe UAS. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167 A, and 10700. 14 C.F.R. 91.119 Minimum Safe Altitudes 14 C.F.R. 91.119 prescribes safe altitudes for the operation ofcivil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. Jonathan 

### A. Steiner will only operate its UASs at orbelow 400 AGL. Jonathan A. Steiner will operate its UASs in a defmed AORthat has been carefully reviewed for hazards and minimizes the presence ofany persons notessential for operations. Flights will only be conducted over private property with consent ofthe property owner. The equivalent level ofsafety will be achieved giventhe size, weight and speed ofthe UAS as well asthe locationwhere it is operated. Comparedto flight operations withtraditional aircraft orrotorcraft weighing far more than 55lbs, operating below 500 AGL with flammable fuel UAS operations present a far smaller risk. 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 the aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as prescribed inparagraph (c) ofthis section, have discrepancies repaired as prescribed inpart 43 ofthis chapter, and others shall inspect or maintain the aircraft in compliance with Part43. These regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to Jonathan A. Steiner'sUASs should its requested exemption be granted. As an equivalent level ofsafety Jonathan A. Steiner requires its pilots to conduct a preflight, through flight and post flight inspection ofthe UAS to ensure its flight worthiness priorto launch. Each UAS is flown in compliance withthe applicable manufactures manual to include all software update cycles as well as flight checklists. In the event ofa malfunctionthe UAS canland immediately. Privacy All flights will occur overprivate orcontrolled access property withthe property owner's prior consent and knowledge.l • . l •

Summary Jonathan A. Steiner is seeking exemption from the following rules: 14 CFR 21, subpart H, 14 CFR45.23(b), 14 CFR 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)(l), 91.409(a)(2), 91.417(a)&(b)·

..and Closed Set Photography and Video. Approval ofthe above exemptions allowing commercial operations ofsmall UASs in the service ofaerial and closed set photography, inspections ofall kinds, real estate surveys,etc. will greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraft weighing thousands ofpounds and carrying hundreds ofpound offuel presenting a significant risk to life and property. With Jonathan A. Steiner's use ofsmall UASs weighing less than 55 lbs., powered by batteries and operating at orbelow400 AGL they virtually eliminate all ofthe risk associated with traditional aerial & closed set photography. The UASs will carry no people thereby eliminating the exposure to the risks associated with flying while accomplishing the same task in a much safer manner. Granting Jonathan A. Steinerthe above exemptions will allow for the expansion ofUAS systems into the future, in a professional, safety conscious culture steep inthe tradition of Aviation. The safety culture established by Jonathan A. Steiner is based on our 20+ years ofbusiness experience···.and over10 years as a pilot. Jonathan A. Steiner respectfully requests that the FAA grant its exception without delay. The FAA has the authority to issue the exemption sought by Jonathan A. Steiner pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

ona an A. Steiner, ChiefPilot 6317-C GraycliffDrive BocaRaton, FL. 33496 Jashighspeed@gmail.com 561-644-2023.