October 31st, 2015

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation 

Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(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 Reform 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 the Federal Aviation 

Regulations (“FARs”) listed below so that I, Isaac Luther, may operate my small ultralight weight unmanned aircraft system (“UAS”) commercially in airspace regulated by 

the Federal Aviation Administration (“FAA”). As described herein I, Isaac Luther, am an 

aerial photographer within the State of Ohio; experienced in flying hobby multirotors. 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 exemption and approval 

by the FAA. I have flown small multirotors 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 diligence 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 and photography usage as I, 

Isaac Luther, record flight data and other information gained 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 systems [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 otherwise 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 community. 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 overhead 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 heavier 
manned 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)-303-3434

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);

14 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 

definition 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 

Reform 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 Reform 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 heavily 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 unmanned 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 will 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. With 
three 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-five to fifty (25-50) yards depending on location, 

conditions and weather. I am constantly on alert for any manned aircraft

(Police/Medical helicopters, etc.) Preparing to land/abort immediately to the nearest and 

safest ground point should a manned aircraft 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, and 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 look 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 generally last between seven (7) to twelve (12) minutes, with 

an altitude under two hundred (200) feet. I, Isaac Luther, utilize a fresh fully charged 

battery with each flight as a safety precaution; full flight time limit for each battery is 

fifteen (15) to 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 

operation. 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 characteristics 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 and does 

not pose any threat to the general 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. Only large companies and high end realtors or 
luxury homeowners can afford such an expense. Depriving the non-luxury 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 back 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 ultralight 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; which are heavy, large, contain combustible 

fuel, and can cause catastrophic 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-light 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 resort 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

How 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 contribute to the innovation 

and implementation of new and novel, as of yet undiscovered safety protocols for 

realtors 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 200 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 only 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 safety 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 

carries 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 incidents involving loss of life as well as 

extensive property damage; it is far safer to operate a battery powered ultra-light

weight UAS.

 The 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.

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

greatly diminished.

 The small size and extreme maneuverability of my UAS allow me to remotely 

pilot away from and avoid hazards quickly and safely.

 Given 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 editing 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: Airworthiness Certificates, Manuals and the Like.

14 C.F.R. 21, 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 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 from the airworthiness certificate requirement under both the Act (49 U.S.C. § 

44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA 

to exempt UAS's from the airworthiness certificate requirement in consideration of the 

weight, size, speed, maneuverability and proximity to areas such as airports and dense 

populations. My, Isaac Luther’s, current 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 

airworthiness certificate. As no such certificate 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 aircraft. As there are no on board pilots or 

passengers, and given the size of the UAS's, this Regulation is inapplicable. An 
equivalent level of safety will be achieved by maintaining a safety/flight manual 

delineating areas of where safety can be defined.10 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. § 91.121 regarding altimeter 

settings is inapplicable insofar as my UAS utilizes electronic global positioning systems 

with a barometric sensor.14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil 

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

described above. The equivalent level of safety will be achieved by maintaining any 

such required certifications 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 station 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 largest possible 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 previously issued exemptions to this regulation through Exemptions Nos. 8738, 

10167, 10167A and 10700. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: 

PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial 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, 

allowing me, Isaac Luther, to operate my UAS meet and exceed current safety levels in 

relation 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 at lower altitudes in certain conditions. My UAS will never 

operate at an altitude greater than 350 AGL; safely below the standard of 400 AGL. I, 

Isaac Luther, will however operate my UAS in safe areas away from public and traffic, 

providing a level of safety 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 Regulations 

require, amongst other things, aircraft 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 paragraph (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 UAS 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 Certificates, 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 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 certificate 
requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform 

Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness 

certificate requirement in consideration 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. 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 FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) 

requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, 

and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of 

safety will be achieved by maintaining a manual. The FAA has previously issued 

exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, maintenance program that involves regular software updates and 

curative measures for any damaged hardware. 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) and (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 community 

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

estate to enhance the experience of those seeking to relocate to the area. Currently, 

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

use 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 enhance 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 time. Further, I operate at lower altitudes and 

in controlled airspace eliminating potential public risk flying to and from established air 

fields. I, Isaac Luther, have been informally analyzing flight information and 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 

collection of information shared with the FAA will enhance the FAA's internal efforts to 

establish protocols for complying with the FAA Modernization and 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