### Al**aska Ae** **rial 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

### Al**aska Ae** **rial 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 motorvehicle trafficforcommunity videos andwithin 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 ofTransportation’s (FAAAdministrator’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 videosfor 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.

### Al**aska Ae** **rial 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 Will**iam 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, WilliamJ. 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 lightweight 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 estateand tourism related

### Al**aska Ae** **rial 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,whetherthe UASwill be operated by line ofsight. 112 P.L. 95 § 333 (a). Each ofthese items reflects infavor of an exemption for me, William J. Sadler. My UAS utilizes four (4) counter

rotating propellers for balance, control and stability. My UAS is equipped with GPS and auto return safety technology. Additionally, my UAS weighs lessthanfive (5) pounds (far belowthe 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 descendtothe point of take off. I do not operate my UAS near airports, hospitals nor heliports, and do not operate near areaswhere general public iswithinfifty 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. Iwill call into localAirTraffic Controlto 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.

### Al**aska Ae** **rial 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 ofcontrol or hazard. Reserve batteries are at handwith 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 cautiouswhen 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.

### Al**aska Ae** **rial Productions, Kenai, AK** 

**- Section 333 Exemption** 

**Petition**



### IV. How**William J. Sadler Request Will Benefit the Public A s**  **A Whole:**  Aerial videographyfor 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 affordableto 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 contactwith local police andfire agencies, andthey 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

### Al**aska Ae** **rial Productions, Kenai, AK** 

**- Section 333 Exemption** 

**Petition**

growth. Granting my exemption request substantiallyfurthersthe 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 Ad** **ve rsely** **A**

**ffect Safety or How** **The Exemption Will Prov ide**  **a Le vel of Safety** **A t Least Equal To Existing Rule:** 

My, William J. Sadler’s exemptionwill not adversely affect safety. Quitethe 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.

### Al**aska Ae** **rial Productions, Kenai, AK** 

**- Section 333 Exemption** 

**P etition** 

 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, sur veys, 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.

### Al**aska Ae** **rial 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 theAct (49 U.S.C. § 44701 (f)) and Section 333 of the ReformAct. Both pieces of legislation permit the FAAto 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 ofan aircraftwithout 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) providesforthe 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.

### Al**aska Ae** **rial 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 non

commercial 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 licensewill 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 of400 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 ofsafetywill 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 otherthings, aircraft owners and operatorsto “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 andThe 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

### Al**aska Ae** **rial Productions, Kenai, AK** 

**- Sectio** **n 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 theAct (49 U.S.C. § 44701 (f)) and Section 333 of the ReformAct. Both pieces of legislation permit the FAAto 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) prohibitsthe operation ofan aircraftwithout 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 ofsafetywill 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 summar**y, William J. Sadler seeks an exemption from the**  **follow ing 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 touristoperations, and to develop economic platforms for real estate to enhance the experience of those seeking to

### Al**aska A erial 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 speedswithin limited areas will provide an equivalent level ofsafety asthat 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