United States Department of Transportation Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 Washington, DC 20590 

Re: Exemption Request Pursuant to Section 333 of the 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 of Small Unmanned 

Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations 

(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 under the conditions outlined herein or as may be established by 

the FAA as required by section 333. 

The Name and address of the applicant is: 

Jonathan A. Steiner, Chief Pilot (FAA Licensed) 

6317 -C Gray cliff Drive 

Boca Raton, Florida 33496 561-644-2023 Jashighspeed@gmail.com 

As described below, the requested exemption would pel1Ilit the operation of lightweight 

(less than 55 lbs. total take off gross weight) UASs under controlled conditions for 

commercial use by professional certificated pilots thereby enhancing 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. 

Jonathan A. Steiner respectfully requests the grant of an exemption to the following 

specific sections of the Title 14 Code of federal 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 relief from any currently applicable FAR's operating to prevent 

future commercial use of small UASs to operate in the national airspace system as 

described below. The Reform Act Section 332 provides for such integration of civil 

unmanned aircraft systems into our national airspace system as it is in the 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 of Jonathan A. Steiner' s 
lightweight UASs are expressly contemplated by the Reform Act. Jonathan A. Steiner 

would like to operate its lightweight U ASs prior to the time period by which the Reform 

Act requires the FAA to promulgate rules governing such aircraft. 

The Reform Act 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 ofUASs 

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 UAS's size, weight, speed and operational capability 

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

• Operation ofthe UAS within visual line of sight of the operator Reform Act 333 (a) 

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." 

Jonathan A. Steiner's UAS's are rotorcraft weighing less than 55 pounds including 

payload. They operate at a speed of less than 50 knots and have the capability to hover 

and move in the vertical and horizontal plane simultaneously. The UAS will operate only 

within the line of sight of the pilot within a protected flight area as described below. Such 

operations will insure that the UASs will not create a hazard to the users of the national 

airspace system or the public. 

The small nature of the UASs utilized by Jonathan A. Steiner combined with the safety 

protocols outlined below will allow for a greater than equivalent level of safety in which 

Congress envisioned that the FAA must, by exemption allow commercial operations of 

UASs to commence immediately. Also due to the size of the UASs and the areas and 

altitudes they will operate, approval of the exemption presents no national security issue 

and absolutely minimal safety concerns which have been mitigated through a rigorous 

risk management process. Given the clear direction given 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, the significant public 

benefit, including enhanced safety, reduced emissions utilizing UASs verse traditional 

aircraft as well as the economic impact of greatly reducing the cost of aerial 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 in the line-of-sight by a ground-based pilot 

2. Flights will only occur in the daytime and clear of clouds 

3. The UASs will weigh less than 55lbs at take off and during flight 

4. Flights will be terminated with 25% of battery life remaining 

5. Flights will be operated at an altitude at or below 400' AGL 

6. Pilots, camera operators 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/Instrument rated pilot or higher 

rating with a current FAA medical. A camera operator and or observer may be added as 

required to further reduce the possibility of task saturation by the pilot depending on the 

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 of Responsibility 

(AOR). This AOR is the actual area for UAS operations for a particular day. Each survey 

will include the assessment of potential 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. If deemed necessary, the crew will 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 thorough briefmg will be conducted, prior to the first flight of the day in an AOR, 

utilizing the briefing guide in the SOPs. All persons who will be in the AOR while UAS 

flights are conducted will be present for this briefing. 
12. Jonathan A. Steiner will obtain consent (verbal or written) for any persons who need 

to be within 100 feet ofUAS flight operations. 

13. Written and or verbal permission from the relevant property owners will be obtained 

prior to flight. 

14. All required permissions and permits would be obtained from territorial, state, county 

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

agencies. 

15. If the U AS loses communications or loses its GPS signal, the U AS 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 in relation to FAR 91.203(a)(1) The size, weight and 

defined area of operations for Jonathan A. Steiner's UAS flights permits exemption from 

Part 21 because Jonathan A. Steiner meets an equivalent level of safety pursuant to 

Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the ACT (49 U.S. C. 44701(t)) and 

Section 333 of the Reform Act. Both pieces oflegislation permit the FAA to exempt 

UASs from the airworthiness certificate requirement in consideration of weight, size, 

speed, maneuverability and proximity to areas such as airports and dense populations. 

Jonathan A. Steiner meets or exceeds each of these elements. 

14 C.F .R. 91.203 (a &b) provides for carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons stated above. The equivalent 

level of safety 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 of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

F ARs, this regulation is inapplicable. 

14 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual in the Aircraft 

14 C.F.R. 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are no 

pilots of passengers, and given the size of the UASs, this regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining an operators manual at the 

flight operations center. The FAA has previously issued exemptions to this regulation in 
. ' 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 

10700 and 32827. 

14 C.F .R. 91.1 03(b) Preflight actions 

14 C.F .R. 91.103 Each pilot in command shall, before beginning a flight, become 

familiar with all available information concerning that flight. This information must 

include: (b) For any flight, runway lengths at airports of intended use, and the following 

takeoff and landing distance information. This subparagraph is not applicable due to our 

off airfield 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 of a civil manned 

aircraft in conjunction with training and flight tests. The U AS to be employed by 

Jonathan A. Steiner are not designated in this category. 

14 C.F.R. 91.121 Altimeter Settings 

14 C.F .R. 91.121 regarding altimeter settings is inapplicable because Jonathan A. 

Steiner's UASs 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 of intended landing, and assuming normal cruising 

speed. 

The battery powering the UAS provides approximately 15 minutes of powered flight, 

which is less than the reserve requirement alone by F ARs for day. Given the limitations 

on the 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 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 planned landing 

zone in the 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 
. . 

Applicable Codes of Federal regulations require aircraft to be marked according to 

certain specifications. Jonathan A. SteinersUASs are unmanned; do not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, two-inch 

lettering is impractical to place on such small aircraft. Jonathan A. Steiner. will, however, 

place the word "EXPERIMENTAL" on its fuselage as required by 14 C.F.R. 45.29 (f) so 

that the pilot, camera operator, observer and any other persons operating in the AOR can 

see the markings on the 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 of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. Jonathan A. Steiner 

will only operate its UASs at or below 400 AGL. Jonathan A. Steiner will operate its 

UASs in a defmed AOR that has been carefully reviewed for hazards and minimizes the 

presence of any persons not essential for operations. Flights will only be conducted over 

private property with consent of the property owner. 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. Compared to flight operations with traditional aircraft or rotorcraft 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 of this part and shall between required inspections, 

except as prescribed 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. 

These regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to Jonathan A. Steiner's UASs should its requested exemption be 

granted. As an equivalent level of safety Jonathan A. Steiner requires its pilots to conduct 

a preflight, through flight and post flight inspection of the UAS to ensure its flight 

worthiness prior to launch. Each UAS is flown in compliance with the applicable 

manufactures manual to include all software update cycles as well as flight checklists. In 

the event of a malfunction the UAS can land immediately. 

Privacy 

All flights will occur over private or controlled access property with the 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 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)(l), 91.409(a)(2), 

91.417(a)&(b)· .. and Closed Set Photography and Video. 

Approval of the above exemptions allowing commercial operations of small UASs in the 

service of aerial and closed set photography, inspections of all 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 of pounds and carrying hundreds of pound of fuel presenting a significant risk 

to life and property. With Jonathan A. Steiner's use of small UASs weighing less than 55 

lbs., powered by batteries and operating at or below 400 AGL they virtually eliminate all 

of the 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. Steiner the above exemptions will allow for the expansion ofUAS 

systems into the future, in a professional, safety conscious culture steep in the tradition of 

Aviation. The safety culture established by Jonathan A. Steiner is based on our 20+ years 

of business 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, Chief Pilot 

6317-C GraycliffDrive 

Boca Raton, FL. 33496 Jashighspeed@gmail.com 561-644-2023.