July 9, 2015

Jonathon E. Doss, Owner

Sublime Media Group, LLC

1225 Shawnee Way

Bowling Green, KY 42104

Cell (270) 543-4501

Email: jon@sublimemediagroup.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

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, Jonathon E. Doss, 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, Jonathon E. Doss, an owner and operator of small 

unmanned aircraft, be exempted from the Federal Aviation Regulations 

(“FARs”) listed below so that I, Jonathon E. Doss, may operate my small 

ultra lightweight unmanned aircraft system (“UAS”) commercially in 

airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein I, Jonathon E. Doss, am a small business owner 

within the Commonwealth of Kentucky; experienced in flying hobby type 

helicopters for recreational purposes. I have added a hobby grade quadcopter UAS (DJI Phantom 2) to my inventory, equipped with a GoPro 

camera with intent for aerial videography/cinematography to augment 

television commercials, corporate videos, wedding and event filming, 

promotional videos; following exemption and approval by the FAA.

My exemption request would permit operation of ultra lightweight, 

unmanned (piloted by remote control) 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 private business 

and property videos/photos. Currently, unmonitored amateur hobbyists 
July 9, 2015

with no safety plan or controls in place to prevent catastrophe legally 

operate similar lightweight, remote controlled UAS’s in the National 

Airspace System.

I, Jonathon E. Doss, have personally established safety protocols to avoid 

public hazard. Granting my request conforms with the Secretary of 

Transportation’s (FAA Administrator’s) responsibilities and authority to not 

only integrate UAS's, but to “...establish requirements for the safe 

operation of such aircraft systems [UAS's] in the ” under Section 333(c) of 

the Reform Act specific to the use of UAS's for commercial photography 

and videography purposes. Further I, Jonathon E. Doss, will conduct my 

operations in compliance with the protocols described herein or as 

otherwise established by the FAA.

For the reasons stated below I, Jonathon E. Doss, respectfully request the 

grant of an exemption allowing me to operate ultra lightweight, remote 

controlled UAS’s to enhance television commercials, corporate videos, 

wedding and event filming, and promotional videos for clients who cannot 

afford expensive manned aircraft. This will promote local economic growth 

through increased employment and increased tax base. This will keep 

public safety in mind by keeping heavier manned aircraft containing 

combustible fuel that poses potential public hazard.

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

From Which Jonathon E. Doss Requests Exemption are:

14 CFR 21;

14 C.F.R. 45.23(b);

14 CFR 61.113 (a) & (b);

14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and,

14 CFR 417 (a) & (b).

III. The Extent of relief Jonathon E. Doss seeks and the Reason He 

Seeks Such Relief: 

I, Jonathon E. Doss, 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, Jonathon E. Doss, contemplated 

commercial cinematic, academic and other flight operations within the 
July 9, 2015

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 ultra 

lightweight 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 lightweight 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 commercially 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. Each of these items reflects in favor of an exemption for 

me, Jonathon E. Doss. 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, Jonathon E. Doss, consider safety foremost with each flight. My smallunmanned 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 

Smart Mode for aerial videography/photography. This is the safest, most 

reliable and stable mode to prevent accident and hazard. When 

communication is lost, the UAS is designed to slowly descend to point of 

take off.

I, Jonathon E. Doss, 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 

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.
July 9, 2015

My UAS is capable of vertical/horizontal operations, and are flown only 

within my line of sight (LOS) of me, as the remote control pilot. Utilizing 

battery power rather than combustible fuels, flights generally last between 

three (5) to seven (10) minutes, with an altitude under one hundred fifty 

(150) feet. I, Jonathon E. Doss, utilize a fresh fully charged battery with 

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

to twenty-five (25) minutes. I do not operate my UAS at or below 

manufacture recommend minimum charge levels for operation. I prefer 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, which could create 

hazard to the public/property/manned aircraft, and have no desire to lose 

an investment. I have practiced extensively with 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, Jonathon E. Doss, am extremely cautious when operating of my UAS/

ultra lightweight 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. Jonathon E. Doss’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 Jonathon E Doss’s Request Will Benefit the Public As A 

Whole: 

Aerial videography for television commercials and otherwise has been 

around for a long time through manned fixed-wing aircraft and helicopters. 

For small budget production companies and wedding/event 

videographers, the expense of such aerial videography is cost prohibitive. 

Only large companies can afford to absorb such expense, depriving nonsmaller production companies from a valuable marketing tool. My UAS 

poses no threat, since size and lack of combustible fuel alleviates any 

potential threat to the public.
July 9, 2015

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, Jonathon E. Doss’s, 

exemption request furthers the public interest through academic/visual 

awareness of the geographical benefits in and around Kentucky. My ultra 

lightweight UAS is battery powered and creates no emissions that can 

harm the environment. The consequence of my ultra lightweight 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 

lightweight UAS's. Permitting me, Jonathon E. Doss, to immediately fly 

within national air space furthers economic growth. Granting my 

exemption request substantially furthers the economic impact for the local 

community for companies looking to relocate or build in the 

Commonwealth of Kentucky, 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 Jonathon E. Doss’s Exemption Will Not Adversely 

Affect Safety Or How The Exemption Will Provide a Level of Safety At 

Least Equal To Existing Rule:

My, Jonathon E. Doss’s, exemption will not adversely affect safety. Quite 

the contrary, for the reasons stated permitting me, Jonathon E. Doss, 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 other 

individuals and development in cooperation with the FAA. In addition I, 

Jonathon E. Doss, submit the following representations of enhancements 

to current aerial videography and photography for commercials, events 

and other opportunities, which may present itself:

My UAS weighs less than 5 pounds complete with a small ultra lightweight 

high quality built-in 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 operate for 5-10 minutes per flight; I will 

land my UAS prior to manufacturer recommended minimum level of 
July 9, 2015

battery power; I pilot my UAS through remote control only by visual line of 

sight (VLOS); 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, Jonathon E. Doss’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 small business, helicopters are the 

primary means of commercial aerial video and photography.

The potential loss of life is diminished because UAS's carry no people on 

board, and I only operate my UAS in specific areas away from mass 

populations. There is no fuel on board a UAS and thus the potential for fire 

or explosions is greatly diminished. The small size and extreme 

maneuverability of my UAS allow me to remotely pilot away from and 

avoid hazards quickly and safely. Given its small size and weight, even 

when close enough to capture amazing images, my UAS need not be so 

close to the objects they are focused on through the technology and use 

of post editing software allowing pan and zoom.

Accordingly, my UAS has been operated for familiarization and 

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, weight and enclosed operational 

area of my, Jonathon E. Doss’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.
July 9, 2015

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, Jonathon E. Doss’s, current 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 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 previously issued exemptions to this regulation in Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 

10700, 32827 and many others.

14 C.F.R. § 91.121 regarding altimeter settings are inapplicable, as my 

UAS uses 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, 

Jonathon E. Doss.

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. 

Regardless, I will mark its UASs in the largest possible lettering by placing 

the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R. §45.29 

(f) so that I the pilot, or anyone assisting me as a spotter with the UAV will 
July 9, 2015

see the markings. The FAA has previously issued exemptions to this 

regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

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 noncommercial operations. I, Jonathon E. Doss, 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, 

Jonathon E. Doss, 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 200 AGL, safely below the 

standard of 400 AGL.

I, Jonathon E. Doss, will 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, Jonathon E. Doss’s, UAS. However, 

as a safety precaution, I inspect my UAS before and after each flight.
July 9, 2015

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, Jonathon E. Doss’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, Jonathon E. Doss, 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, Jonathon E. Doss’s, small 

unmanned vehicle/lightweight unmanned aircraft vehicle in community 

awareness, at commercial shoots, wedding and events and other 

opportunities which may present itself. Currently, commercial and event 
July 9, 2015

aerial videography/photography relies primarily on the use of larger aircraft 

running on combustible fuel. Posing potential risk to the public.

Granting my, Jonathon E. Doss’s, request for exemption will reduce 

current risk levels and thereby enhance safety. My UAS aircraft does not 

contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional commercial 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, Jonathon E. Doss, have been informally analyzing flight information and 

will compile safety protocols and the implementation of flight operation for 

commercial and event filming usage that exceeds currently accepted 

means and methods for safe flight. 

There are no personnel on board my, Jonathon E. Doss’s, UAS and 

therefore the likelihood of death or serious bodily injury is significantly 

diminished. My, Jonathon E. Doss’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. 

I, Jonathon E. Doss, respectfully request that the FAA grant my exemption 

request, and I am more than willing to cooperate in sharing information to 

benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully,

Jonathon E. Doss, Owner

Sublime Media Group, LLC

d.b.a Sublime Wedding Films

1225 Shawnee Way

Bowling Green, KY 42104