### Jeffrey **L. Craig -**  **Section 333**  **Exemption Petition** 

August 21 , 2015
U.S. Department ofTransportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590
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, Jeffrey L. Craig, amwriting pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Jeffrey L. Craig, an owner and operator of small unmanned aircrafts, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Jeffrey

L. Craig and my co-pilot; Michael Leal, may operate my small ultra-light weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”). As described herein I, Jeffrey L. Craig, am experienced in flying hobby helicopters for recreational purposes. I have added a hobby grade quad-copter UAS to my inventory equipped with a HD Camera with intent for aerial videography / cinematography

/ photography to enhance academic community awareness for those individuals and companies unfamiliar with the geographical South East Region, Alabama, Florida, Georgia, and augment real estate listing photos/ videos; following exemption and approval by the FAA thereby enhancing their academic research experience for the afformentioned Southern states

. I have flown small RC electric helicopters for over ten (10) years without incident. I am also active duty Air Force and am an HH-60G Helicopter Crew Chief. I have been to several courses dedicated to safe maintenance practices and have operated in and around aircraft for 18 y ears. My, Jeffrey

L. Craig’s, exemption request would permit operation of ultralight weight, under 6lbs, unmanned (piloted by remote control with FPV systems) and comparatively inexpensive UAS(s) in tightly controlled and limited airspace. Predetermined in areas awayfrom general public, airports, heliports and vehicular traffic for community videos, and within property boundaries for individual homeowner real

### Jeffrey **L. Craig -**  **Section 333**  **Exemption Petition** 
estate listing videos/photos. Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. I, Jeffrey L. Craig, have personally instilled safety protocols and controls4 to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to further safety protocols exclusive to lightweight UAS's specific to real estate video and photography usage as I, Jeffrey L. Craig, 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. Granting my, Jeffrey

L. Craig’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, Jeffrey L. Craig, will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA. For the reasons stated below I, Jeffrey L. Craig, respectfully request the grant of an exemption allowing me to operate ultra-light weight, remote controlled UAS’s for academic community awareness to benefit/stimulate attraction to the Alababama/ Georgia/ Florida area and to enhance real estate listing videos/photos for homeowners who cannot afford expensive manned aircraft for the same purpose. 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. **I. Contact**  **Information:** Jeffrey L. Craig, 7495 Highway

37 Ray City, GA 31645 Mobile: (229) 563-2758 Email:jeffrey.l.craig@gmail.com **II. The**  **Specific Sections**  **of Title**  **14 of**  **the Code**  **of Federal**  **Regulations From**  **Which Jeffrey**  **L. Craig Requests**  **Exemption are:** 

4Appendix D – Personal Protocols and Controls

### Jeffrey **L. Craig -**  **Section 333**  **Exemption Petition** 
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 Jeffrey L. Craig**  **seeks and**  **the Reason**  **she Seeks**  **Such Relief:**  I, Jeffrey L. Craig, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relieffrom any currently applicable FARs operating to prevent me, Jeffrey L. Craig, 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, Jeffrey L. Craig’s, 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 uniformlyto 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, Jeffrey L. Craig

. 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 five (5) pounds (far below the maximum 55 pound limit); including camera with gimbal. I, Jeffrey L. Craig, considers safety as foremost with each flight. My small unmanned aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 16 kph (10 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 Yuneec/GPS mode for aerial videography /photography

. This is the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication is lost UAS is

.

### Jeffrey **L. Craig -**  **Section 333**  **Exemption Petition**  designed slowly descend to point of takeoff. I do not operate my UAS near airports, Hospitals nor Police heliports, and do not operate near areas where general public is within fifty to one hundred (50-100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft (Airplanes/Police/Medical helicopters, etc.) and prepared 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. 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 three (5) to seven (15) minutes, with an altitude under four hundred (400) feet. I, Jeffrey

L. Craig, utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limit for each battery is nine (15) to twelve (25) minutes as tested. 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 cause a crash that could create hazard to the public/property /manned aircraft, and have no desire to lose an investment. I have clocked 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, Jeffrey L. Craig, am extremely cautious 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. Jeffrey L. Craig’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**  **Jeffrey L. Craig’s Request**  **Will Benefit**  **the Public**  **as A** **Whole:** Aerial photography/videographyfor geographical awareness 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 photography/videography is cost prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to absorb such expense. Depriving non-luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through potential catastrophic crashes. Each resulting in loss of life. Each with combustible fuel that exploded and burned on impact. My, Jeffrey L. Craig’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 commerciallyflown UAS's

### Jeffrey **L. Craig -**  **Section 333**  **Exemption Petition** 
into the national airspace system, hence the passing of the Reform Act. Granting my, Jeffrey L. Craig’s, exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around Alabama/Georgia/Florida

. My ultra-light weight UAS is battery powered and creates no emissions that can harmthe 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, 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, Jeffrey L. Craig, to immediatelyfly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the Albaman/Georgia/Florida communities for companies looking to relocate or build in Alabama/Florida/Georgia as well as individuals looking to relocate for career advancement through academic and geographical awareness. Both of which serve as a stimulus to the community. **V. Reasons**  **Why Jeffrey L.**  **Craig’s Exemption**  **Will Not**  **Ad versely**  **Af fect**  **Safety Or**  **How the**  **Exemption Will**  **Provide a**  **Level of**  **Safety At**  **Least Equal**  **To Existing**  **Rule:** My, Jeffrey

L. Craig’s, exemption will not adversely affect safety

. Quite the contrary, for the reasons stated permitting me, Jeffrey L. Craig, 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 NAR6, NKAR7 for development in cooperation with the FAA. In addition I, Jeffrey L. Craig, submit the following representations of enhancements to current aerial videography and photographyfor real estate:

 My UAS weighs less than 5 pounds complete with a small ultra-light weight high definition (HD) camera/ GoPro 3+ Black camera;
 I only operate my UAS below 400 feet8 (well within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 2012);
 My UAS only operate for 5-15 minutes per flight; I land my UAS prior to manufacturer recommended minimum level of battery power;
 I pilot my UAS through remote control/FPV only by line of sight;

### Jeffrey **L. Craig -**  **Section 333**  **Exemption Petition** 

 My UAS has GPS a flight safetyfeature 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 awayfrom 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 obtain 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, Jeffrey

L. Craig’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 beenl incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra-light weight UAS.

 First, the potential loss of life is diminished because UAS's carry no people on board and I only operates my UAS in specific areas awayfrom mass populations.
 Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished.
 Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely

.  Lastly, 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. Accordingly, my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels. **VI. A**  **Summary the**  **FA A**  **Ma y**  **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,

### Jeffrey **L. Craig -**  **Section 333**  **Exemption Petition**  weight and enclosed operational area of my, Jeffrey L. Craig’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 proximityto areas such as airports and dense populations. My, Jeffrey L. Craig’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 safetywill be achieved by maintaining a safety /flight manual delineating areas of where safety can be defined.9 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 safetywill be achieved by maintaining any such required certifications and registrations by me, Jeffrey L. Craig

.

B. 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.

. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

### Jeffrey **L. Craig -**  **Section 333**  **Exemption Petition**  C. 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 non-commercial operations. I, Jeffrey L. Craig, can achieve an equivalent level of safety as achieved by current Regulations because my UAS does not carry any pilots or passengers. 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, Jeffrey L. Craig, to operate my UAS meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). D. 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 400 AGL; safely below the standard of 400 AGL. I, Jeffrey L. Craig, will however operate my UAS in safe areas awayfrom 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.
E. 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, Jeffrey

L. Craig’s, UAS. However, as a safety precaution I inspect my UAS before and after each flight.

### Jeffrey **L. Craig -**  **Section 333**  **Exemption Petition** 
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, Jeffrey L. Craig’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 proximityto 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 safetywill be achieved. **In summary,**  **Jeffrey L. Craig 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, Jeffrey

L. Craig’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 Alabama/Georgia/Florida

. 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, Jeffrey L. Craig’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, Jeffrey L. Craig, 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, Jeffrey L. Craig’s, UAS and therefore the likelihood of death or serious bodily injury is significantly diminished. My, Jeffrey L. Craig’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

### Jeffrey **L. Craig -**  **Section 333**  **Exemption Petition**  achieved under current FARs. Accordingly I, Jeffrey L. Craig, 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.
RespectfullySubmitted, 

# Jeffrey L. Craig
Jeffrey L. Craig 7495 Highway

37 Ray City, GA 31645