Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

May 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, William J. Sadler, 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, William J. Sadler holder of both a Commercial Pilots (# 

1781355) and Mechanic (# 2021362) Certificates utilizing my acquired 

skills and knowledge in the proper operation of my UAS’s and the owner 

and operator of small unmanned aircraft (“N” number is being applied for 

and reservation number of N99611 requested), be exempted from the 

Federal Aviation Regulations (“FARs”) listed below so that I, William J. 

Sadler, 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, William J. Sadler, have 

added a professional grade quad-copter UAS Inspire 1 to my inventory 

equipped with a DJI Zenmuse H3 camera with intent for aerial 

videography/cinematography to enhance and promote Alaska Tourism for 

those individuals and companies unfamiliar with the geographical layout of 

Alaska and pursue implementation of emergency use UAS systems with 

public entities; following exemption and approval by the FAA. This will allow 

for enhancement of the tourism experience for the state of Alaska. I have 

flown small quad copter's for over two years without incident. I am 

committed to safety with each and every flight. My, William J Sadler 

exemption request would permit operations of ultralight weight, unmanned 

(piloted by remote 
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

control) and comparatively inexpensive UASs in tightly controlled and 

limited airspace, predetermined in areas away from general public, airports, 

heliports and motor vehicle traffic for community videos and within property 

boundaries for individual home or real estate listing videos/photos. 

Currently, similar lightweight remote-controlled you UAS’s are legally 

operated by unmonitored amateur hobbyist with no safety plan or controls 

in place to prevent safety issues. I William J Sadler, have personally 

installed necessary safety protocols, and checklists prior to operation. This 

will act to further safety protocols exclusive to lightweight UAS’s specific to 

real estate and tourism video and photography used as I, William J Sadler, 

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 regulations. I, William J. Sadler hold 

both a Commercial Pilots (# 1781355) and Mechanic (# 2021362) 

Certificates and will utilize my acquired skills and knowledge in the proper 

operation of my UAS’s. Granting my, William J. Sadler, 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 too “...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 Aerial Surveying and 

Search and Rescue Systems. Further I, William J. Sadler, will conduct my 

operations in compliance with the protocols described herein or as 

otherwise established by the FAA. For the reasons stated below I, William 

J. Sadler, respectfully request the grant of an exemption allowing me to 

operate ultra light weight, remote controlled UAS’s for tourism specifically 

and overall community awareness to benefit and stimulate attraction to 

Alaska and to enhance real estate listing and tourism videos for individuals

and organizations who are unable to 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 significantly heavier manned aircraft containing 

combustible fuel posing potential public hazard.
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

I. Contact Information:

William J. Sadler - Alaska Aerial Promotions

381 Senior Court # 106 Kenai, Alaska 99611

Mobile: (907)-953-0092

Email: Bluesdown@aol.com

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

Regulations From Which William J. Sadler’s Requests 

Exemption

are:

14 CFR 21;

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 William J. Sadler seeks and the 

Reason He Seeks Such Relief:

I, William J. Sadler 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, William J. Sadler, from commercial aerial 

video and still cinematic, 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, William J. Sadler’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 and tourism related 
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

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 reflects in favor 

of an exemption for me, William J. Sadler. My UAS utilizes four (4) counterrotating propellers for balance, control and stability. My UAS is equipped 

with GPS and auto return safety technology. Additionally, my UAS weighs 

less than five (5) pounds (far below the maximum 55 pound limit); including 

camera with gimbal.

I, William J, Sadler, consider safety 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 concern 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 (GPS) Smart 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 designed to slowly descend to the 

point of take off. I do not operate my UAS near airports, hospitals nor 

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 (Police/Medical 

helicopters, general and commercial aviation 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. I will call in to local Air Traffic Control to alert of 

my flight plan and operations as well as calling back when operations are 

complete. My UAS is capable of vertical and horizontal operations, and is 

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 

twelve (10) to seventeen (17) minutes, with an altitude under two hundred 

(200) feet.
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

I, William J. Sadler, utilize a fully charged smart battery with each flight as a 

safety precaution; full flight time limit for each battery is eighteen (18) to 

twenty (20) minutes as tested. I do not operate my UAS at or below 

manufacture recommend minimum charge levels for operation or exceed 

temperature ratings of 0*F as per manufactures request; preferring to 

remain well within a safe operating range to insure adequate 

communication between radio control and 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 made a significant investment 

and have no desire to lose that investment. I have performed 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.

I, William J. Sadler, am very 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. I, William J. Sadler’s UAS, used in hobby flight, has a 

demonstrable safety record and does not pose any threat to the general 

public or national security. 
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

IV. How William J. Sadler Request Will Benefit the Public As 

A Whole:

Aerial videography for geographical awareness for real estate, recreational 

and tourism marketing has been around for a long time through manned 

fixed wing aircraft and helicopters. For small budget production companies 

and average homeowners, the expense of such aerial videography is cost 

prohibitive. Only large companies and high end film companies can afford 

to absorb such expense. This is where the option of less expensive 

unmanned systems becomes affordable to anyone. Manned aircraft pose a 

threat to the public through potential catastrophic crashes that Alaska has 

come to expect every year. Kenai, Seward, and Homer areas are very busy 

airspaces, which is why I am pursuing a 333 Exemption to be instrumental 

and lead the way for other businesses and or enthusiast. My additional goal 

is to prove to the public that my UAS can be used effectively in fire, police 

or natural disaster relief as well as instructional training enhancement. I 

have made contact with local police and fire agencies, and they are excited 

about the potential value for their organizations.

My, William J. Sadler’s UAS use, poses no 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, William J. Sadler, exemption 

request furthers the public interest through promotional/visual awareness of 

the geographical benefits primarily in and around the Kenai Peninsula. 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, William J. 

Sadler, to immediately fly within national air space furthers economic 
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

growth. Granting my exemption request substantially furthers the economic 

impact for the Alaska communities for companies looking to relocate or 

build in the Kenai Peninsula area as well as individuals looking to relocate 

for career advancement, recreational, and or retirement through 

geographical awareness, all of which serve as a stimulus to the community.

V. Reasons Why William J. Sadler’s Exemption Will Not

Adversely Affect Safety or How The Exemption Will Provide

a Level of Safety At Least Equal To Existing Rule:

My, William J. Sadler’s exemption will not adversely affect safety. Quite the 

contrary, for the reasons stated permitting me, William J. Sadler 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. I, William J. Sadler, 

submit the following representations of enhancements to current aerial 

videography, photography and aerial surveying aspects:

My UAS weighs less than 5 pounds complete with a small

ultra light weight high quality DJI Zenmuse H3 camera.

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 operates for 12-17 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.
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

I only operate in reasonably safe environment that are

strictly controlled, are away from power lines, towers, 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.

I have procedures in place to abort flights in the event of

safety breaches or potential danger.

My, William J. Sadler’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, surveys, tourism and real estate. While the safety 

record of such helicopters is remarkable; 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.
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

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, weight 

and enclosed operational area of my, William J. Sadler’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, William J. Sadler’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. 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, William J. Sadler.
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

B. 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. I, William J. Sadler, 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 although I do hold a Commercial pilot’s 

license. 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, William J. Sadler, to operate my UAS meet and 

exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

C. 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 200 AGL; safely below the 

standard of 400 AGL. I, William J. Sadler, 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. D. 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, William J. Sadler’s, UAS. 

However, as a safety precaution I inspect my UAS before and after each 

flight and I do hold a Mechanics certificate as well. 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, William J. Sadler’s, UAS meets an 
Alaska Aerial Productions, Kenai, AK - Section 333 Exemption

Petition

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 firmware updates and curative

measures for any damaged hardware. Therefore, an equivalent level of 

safety will be achieved.

In summary, William J. Sadler 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, William J. Sadler, small 

unmanned vehicle/lightweight unmanned aircraft vehicle in community 

awareness and real estate and tourist operations, and to develop economic 

platforms for real estate to enhance the experience of those seeking to 
Alaska Aerial Productions Kenai, AK- Section 333 Exemption

Petition

relocate to the Kenai Peninsula and/or the Alaska 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, William J. Sadler’s, request for exemption 

will reduce current risk levels and thereby enhance safety. My UAS craft 

does not contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional real estate and tourism 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 airfields. I, William J. Sadler, have been informally 

analyzing flight information and will compile safety protocols and the 

implementation of a flight operations manual for 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, William J. Sadler’s, UAS and therefore the likelihood of death or 

serious bodily injury is significantly diminished. My, William J. Sadler’s, 

operation of my UAS, weighing less than 5 pounds and traveling at lower 

speeds within limited areas will provide an equivalent level of safety as that 

achieved under current FARs. Accordingly I, William J. Sadler’s 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,

William J. Sadler, Owner 

Alaska Aerial Productions 

381 Senior Court #106

Kenai, Alaska 99611