O ctober 31 st , 2015

Re: Exemption Request Section 333 of the FAA Reform Act of t he Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.11 3(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a) ; 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

I, Isaac Luther am writing pursuant to the FAA Modernization and Ref orm Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Isaac Luther an owner and operator of small unmanned aircraft, be exempted from t he Federal Aviation Regulations (“FARs”) listed below so that I, Isaac Luther , may operate my small ultra

light weight unmanned aircraft system (“UAS”) commercially in airspace re gulated by

the Federal Aviation Administration (“FAA” ). As described herein I, Isaac Luther , am an aerial photographer within the State of O hio ; experienced in f lying hobby m ultirotors. I

have added the DJI Phantom 3 and DJI Inspire 1 UAS to my inventory with intent for aerial videography/cinematography to enhance academic community awareness via
UAS research , and augment real estate listing videos; following exem ption and approval by the FAA. I have flown smal l m ultirotors for over 2 years, I, Isaac Luther , have

installed safety protocols and controls to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. I have also done my due dilige nce to educate the public about how useful UAS platforms can be. This will act to further safety protocols exclusive to lightweight UAS's specific to real estate video an d photography usage as I,

Isaac Luther , record flight data and other information gaine d through permitted flight operations to share with the FAA through any required FAA reports to assist with future protocol and safety regulation. This data is logged by the device on both the Phantom 3 and Inspire 1 platforms

. Granting my, Isaac Luther 's, request comports with the Secretary of Transportation’s (FAA Administrator’ s) responsibilities and authority to not only integrate UAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft syst ems [ UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor purposes. Further I, Isaac Luther , will conduct my operations in compliance with the protocols described herein or as otherw ise established by the FAA. For the reasons stated below I, Isaac Luther , respectfully request the grant of an exemption allowing me to operate ultra

- light weight, remote controlled UAS’s for

academic enrichment to benefit researchers as well as the commun ity. Also to enhance and augment real estate listing videos for realtors and homeowners who cannot afford expensive manned aircraft alternatives. I, Isaac Luther, also intend on augmenting action videos in sporting events and the like by providing an overh ead camera that is much easier to operate than the location installing traditional cable based camera systems. Both of which will promote local economic growth through increased employment and increased tax base. Both with public safety in mind by keeping heaviermanned aircraft containing combustible fuel that that poses potential public hazard , as

well as a smaller system results in much safer maneuverability

.

I. Contact Information:

Isaac Luther

22625 Buck Allen Drive Marysville, Ohio 43040 (937)

- 303

- 34 34

Email: lutherisaac@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From

Which Isaac Luther Requests Exemption are: 14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b);

1 4 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent of relief Isaac Luther seeks and the Reason He Seeks Such Relief: I, Isaac Luther , submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331

- 334, seeking relief from any currently applicable FARs operating to prevent me,

Isaac Luther , contemplated commercial cinematic, academic 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 public’s interest to do so. My, Isaac Luther

, ultra

- light weight UAS meets the

defin ition of “small unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra

- light weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra

- light weight UAS prior to the time period by which the

Ref orm Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all real estate related UAS aerial video and photography. The Refor m Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS's; whether the UAS will be operated near airports or h eavily populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for me, Isaac Luther . My UAS utilizes four (4) counter

- rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Weighing less than ten ( 10 ) pounds (far below the maximum 55 pound limit); including camera with gimbal. I, Isaac Luther , consider safety as foremost with each flight. My small unman ned aircraft is designed to hover in place via GPS and operate in less than a 19 knot ( 22 mph) wind. For safety, stability and fear of financial

loss I wi ll not fly in winds exceeding 13 knots (15 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place when radio controls are released. Withthree modes to choose from, I utilize the Smart Mode for aerial cinematography . This is

the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost UAS is designed slowly descend to point of takeoff . I do not operate my UAS near airports, hospitals or other heliports, and do not operate in areas of high population density within twenty

- f ive to fifty ( 25

- 50 ) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft (Polic e/Medical helicopters, etc.) Preparing to land/abort immediately to the nearest and safest ground point should a manned aircraf t approach my location or I suspect manned aircraft may approach near my location. In more populated areas, or areas that may include hazards to my UAS I fly with a flight crew. The DJI Inspire 1 includes a feature to allow one operator to fly the craft, a nd another to control the camera. I, Isaac Luther, control the operations of the craft, and another team member controls the operations of just the camera, and another team member is constantly focused on the craft, in case one of the operators needs to lo ok down at the controls for any given amount of time. My UAS is capable of vertical and horizontal operations, and are flown only within my line of sight of me, as the remote control pilot. Utilizing battery power rather than combustible fuels, flights gen erally last between seven (7) to twelve (12 ) minutes, with

an altitude under two hundred ( 2 00 ) feet. I, Isaac Luther , utilize a fresh fully charged battery with each flight as a safety precaution; full flight time l imit for each battery is fifteen (15) t o twenty

- two (22 ) minutes as tested , this full flight time is based on the time for the emergency return to home to engage on the UAS . I do not operate my UAS at or below manufacture recommend minimum charge levels for operation; preferring to

remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of

op eration. I do not believe in taking risk that may result in a crash that could create hazard to the public/property/manned aircraft. I have logged numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain

familiarization with the c haracteristics of this specific UAS's performance under different temperature and weather conditions. I also practice computerized simulated flights to maintain adequate skills and response reflex time. All for the sake of safety. I, Isaac

Luther

, exercise extreme caution when operating of my UAS/ ultra

- light weight unmanned aircraft 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 my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system.

Isaac Luther 's UAS, used in hobby flight, has a demonstrable safety record an d does not pose any threat to the gener al public or national security.

IV. How Isaac Luther 's Request Will Benefit the Public As A Whole:

Aerial cinematography for ground camera augmentation and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget real estate companies and average homeowners the expense of such aerial videography is cost prohibitive. Onl y large companie s and high end r ealtors o rluxury homeowners can afford such an expense. Depriving the non

- luxu ry home owning

market from a valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic crash that all too often leads b ack to a manned aircraft getting to close to the ground . Each resulting in an unnecessary loss of life . My, Isaac

Luther 's, UAS pose no such threat since size and lack of combustible fuel alleviates any potential threat to the public. Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act. Granting my, Isaac Luther ’s, exemption request furthers the public interest through academic/visual awareness of life above the Earth. My ultra

light weight UAS is battery powered and creates no emissions that can harm the environment. The consequence of my ultra

- light weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; w hich are heavy , large , contain combustible

fuel

, and can cause catastro phic devastation to the public. The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo capture through my battery operated ultra

- l ight weight UAS's. Permitting me, Isaac

Luther , to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact on the communities in which I might fly for companies looking to relocate or build in the area as well as individuals looking to relocate for career advancement through academic and geographical awareness. For example, recording video footage of skiers going down the mountains at a local ski resort, and then the ski re sort using that footage to promote

their business. All of which serve as a stimulus to the community.

V. Reasons Why Isaac Luther ’s Exemption Will Not Adversely Affect Safety or H ow the Exemption Will Provide a Level of Safety At Least Equal to Existing Rule: My, Isaac Luther ’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Isaac Luther , to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to co ntribute to the innovation and implementation of new and novel, as of yet und iscovered safety protocols for

r ealtors that can be embraced by the National Association of Realtors, and for development in cooperation with the FAA. In addition I, Isaac Luther

, submit the following representations of enhancements to current aerial videography and photography for real estate:

 My UAS weighs less than 10 pounds complete with a small ultra

- light weight high quality

 I only operate my UAS below 2 00 feet (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012);

 My UAS only operate for 7

- 12 minutes per flight; I land my UAS prior to manufacturer recommended minimum level of battery power;

 I pilot my UAS through remote control on ly by line of sight;

 My UAS has GPS a flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost;

 I actively analyze flight data and other sources of information to constantly update and enhance saf ety protocols; I only operate in reasonably safe environment that are strictly controlled, are

away from power lines, elevated lights, airports and actively populated areas;

 I conduct extensive pre

- flight inspections and protocol, during which safety

carri es primary importance;

 I always obtains all necessary permissions prior to operation; and,

 I have procedures in place to abort flights in the event of safety breaches or potential danger. My, Isaac Luther ’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness and real estate. While the safety record of such helicopters is remarkably astounding, there has been isolated incident s involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra

- light weight UAS.

 T he potential loss of life is diminished because UAS's carry no people on board and I only operate my UAS in specific areas away from large populations.

 T here is no fuel on board a UAS and thus the potential for fire or explosions is

gre atly diminished.

 T he small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely.

 G iven its small size and weight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of post ed iting software allowing pan and zoom.

 Rarely do I fly alone. A typical flight involves at least one other person serving as a spotter.

 I only operate at safety levels that I can verify experimentally. When testing new features or methods I prove them in a safe area and determine a safe operating

radius for that feature or method.

VI. A Summary the FAA May Publish in the Federal Register:
14 C.F.R. 21 and 14 C.F.R. 91: Airworthine ss Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificat es, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §91 .203(a)(1). The size, weight and enclosed operational area of my, Isaac Luther ’s, UAS permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt

aircraft fro m the airworthiness certificate requirem ent under both the Act (49 U.S.C. § 44701 (f)) and Sect ion 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's fro m the airworthiness certificate requirement in consideration of the weight, size, speed, maneuve rability and prox imity to areas such as airports and dense populations. My, Isaac Luther ’s, c urrent and projected UAS's meet or exceed each of

the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an

a irworthiness certificate. As no such certificat e will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the air craft. As there are no on board pilots or passengers, and given the size of the UAS's, this Re gulation is inapplicable. Anequivalent level of safety will be achieved by maintaining a s afety/flight manual

delineating areas of where safety can be defined.10 The FAA has previously issued

e xemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 929 9A, 9565, 9565B, 10167, 10167A,10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplic able insofar as my UAS utilizes electronic global positioning syste ms with a barometric sensor. 14 C.F.R. § 91.203 (a) and (b) pr ovides for the carrying of ci vil

aircraft certifications and registrations. They are inapplicable for the same reasons

descri bed above. The equivalent level of safety will be achieved by maintaining any such required cert ifications and registrations by me, Isaac Luther 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot st ation on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft with

dimensions smaller that minimal lettering requirement. Regardless, when testing experimental system I will mark its UASs in the l argest po ssible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45 .29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see the markings. The FAA has previousl y issued exemptions to this r egulation through Exemptio ns Nos. 8738, 10167, 10167A and 10700. 14 C.F.R. § 61.113: Private Pilot P rivileges and Limitations:
PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilot s are limited to non

commercial operations. Further, while helpful, a pilot license will not ensure remote control piloting skills. The risks attended to the operation of my UAS is far less than the

risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus,

allo wing me, Isaac Luther, to ope rate my UAS meet and exceed current safety levels in

rela tion to 14 C.F.R. §61.113 (a) & (b). 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 a t lower altitudes in certain condition s. My UAS will never operate at an altitude greater than 350 AGL; safely below the standa rd of 400 AGL. I, Isaac Luther, will however operate my UAS in safe areas away from public and traff ic, providing a level of safe ty at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The above

- cited Reg ulations require, amongst other things, a ircraft owners and operators to “ have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in p aragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . . ” These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Isaac Luther 's, UAS. However, as a safety precaution I inspect my UA S before and after each flight. A Summary the FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R.

91: Airworthiness Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H, entitled
Airworthiness Cer tificates, sets forth requirements for procure ment of necessary

airworthiness certificates in relation to FAR § 91.203(a) (1). The size, weight a nd enclosed operational area of my UAS permits exemption from Part 21 because my,

Isaac Luther ’ s, UAS meets an equivalent level of safety pursuant to Section 333 of the

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificaterequirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform

Act. Both pieces of legis lation permit the FAA to exempt UAS's from the airworthiness certificate requirement in considerat ion of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds

each of the elements. 1 4 C.F.R. 91.7(a) prohibits the o peration of an aircraft without an airworthiness certificate. As no such certificate will be applica ble in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft fli ght manual in the aircraft. As the re are no pilots or passengers,

a nd given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety wi ll be achieved by maintaining a manual. The FAA has previously issued exemptions to this reg ulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenanc e program that involves regular software updates and curative measures for any damaged har dware. Therefore, an equivalent level of safety

will be achieved.

In summary, Isaac Luther seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 ( a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 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) a nd (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. §

91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Isaac

Luther ’ s, small unmanned vehicle/lightweight unmanned aircraft vehicle in comm unity

awareness and real estate operations, and to develop economic platforms for real

estate to e nhance the experience of those seeking to relocate to the area. Cur re ntly,

area awareness and real estate aerial videography/photography relies primarily on the

us e of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting my, Isaac Luther ’ s, request for exemption will reduce current risk levels and thereby enha nce safety. My UAS craft do not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional real estate video and photographic aircraft with much less flight ti me. Further, I operate at lower alti tudes and in controlled airspace eliminating potential public risk flying to and from established air

fields. I, Isaac Luther , have been informally analyzing flight information an d will compile safety protocols and the implementation of a flight operations manual for real estate usage that exceeds currently accepted means and methods for safe flight. Formal

c ollection of information shared with the FAA will enhance the FAA's internal efforts to establish p rotocols for complying with the FAA Modernization an d Reform Act of 2012.

There are no personnel on board my, Isaac Luther 's, UAS and therefore the likelihood

of death or serious bodily injury is significantly diminished. My, Isaac Luther ’s, operation of my UAS, weighing less than 5 pounds and travelling at lower speeds within limited areas will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, Isaac Luther , respectfully request that the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,Isaac Luther

22625 Buck Allen Drive Marysville, Ohio 43040