Jeffrey L. Craig - Section 333 Exemption Petition

August 21, 2015

U.S. Department of Transportation

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, 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, 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 years. 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 away from 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 controls4to 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:

4 Appendix 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 relief from 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 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, 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/videography for 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 commercially flown 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 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, 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 immediately fly 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 Adversely Affect 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, NKAR7for

development in cooperation with the FAA. In addition I, Jeffrey L. Craig, submit the following

representations of enhancements to current aerial videography and photography for 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 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 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 away from 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 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,
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 proximity to 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 safety will 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 safety will 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 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.

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 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, 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