April 24, 2015

 Exemption No. 11426

 Regulatory Docket No. FAA–2015–0173

Mr. Ryan P. Marlow

Alaska Aerial Media, LLC

7960 Upper O’Malley Road

Anchorage, AK 99507

Dear Mr. Marlow:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

The Basis for Our Decision

By letter posted to the docket on January 26, 2015, and amended on March 26, 2015, you 

petitioned the Federal Aviation Administration (FAA) on behalf of Alaska Aerial Media, LLC

(hereinafter petitioner or operator) for an exemption. The exemption would allow the 

petitioner to operate an unmanned aircraft system (UAS) to conduct aerial

videography and cinematography to enhance academic community awareness for those 

individuals and companies unfamiliar with the geographical layout of the Anchorage area, and 

pursue implementation of emergency use UAS systems with public entities.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.
2

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Alaska Aerial Media, LLC is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 
3

and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Alaska Aerial Media, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC must 

be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 
4

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted this exemption, then the 

operator must petition for an amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS−80) may be contacted if questions arise regarding updates or 

revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g. inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
6

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
7

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on April, 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

March 26, 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, Ryan Marlow, 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, Ryan Marlow, an owner and operator 

of small unmanned aircraft (N99887), be exempted from the 

Federal Aviation Regulations (“FARs”) listed below so that I, Ryan 

Marlow, may operate my small ultra light weight unmanned 

aircraft system (N99887) or (“UAS”) commercially in airspace 

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

As described herein I, Ryan Marlow, have added a professional 

grade quad-copter UAS (N99887) to my inventory equipped with 

a DJI Zenmuse H3 camera with intent for aerial 

videography/cinematography to enhance academic community 

awareness for those individuals and companies unfamiliar with 

the geographical layout of the Anchorage area, and pursue 

implementation of emergency use UAS systems with public 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

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

allow for enhancement of the academic research experience for 

the Anchorage area. I plan to add a second quad-copter with a 

FLIR camera to my inventory in the future with comparable safety 

capabilities.

I have flown small RC multi rotors for over eight (8) years without 

incident. As well as working with local FSDO on flight safety, I 

am committed to safety with each flight. My, Ryan Marlow's,

exemption request would permit operation of ultra light weight, 

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 individual homeowner real 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, Ryan Marlow, have personally instilled 

safety protocols, sterile cockpit rule and checklists prior to 

operation. This will act to further safety protocols exclusive to 

lightweight UAS's specific to real estate video and photography 

usage as I, Ryan Marlow, 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, Ryan Marlow'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 Aerial Surveying and Search and Rescue Systems. 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

Further I, Ryan Marlow, will conduct my operations in compliance 

with the protocols described herein or as otherwise established by 

the FAA.

For the reasons stated below I, Ryan Marlow, 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 Anchorage area 

and to enhance real estate listing videos 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:

Ryan Marlow, Alaska Aerial Media, LLC

7960 Upper O'Malley Road Anchorage, AK 99507

Office: (907)-349-1628

Mobile: (907)-717-9794

Email: apexlivesound@gmail.com

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

Regulations From Which Ryan Marlow 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 Ryan Marlow seeks and the Reason He 

Seeks Such Relief:

I, Ryan Marlow, submit this application in accordance with the 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any 

currently applicable FARs operating to prevent me, Ryan Marlow, 

from 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, Ryan Marlow’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, Ryan 

Marlow. 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 less 

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

including camera with gimbal.

I, Ryan Marlow, 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 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 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

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 slowly 

descend to point of take off. 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 (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. I Do 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 (12) to 

seventeen (17) minutes, with an altitude under one hundred fifty 

(150) feet.

I, Ryan Marlow, utilize a fresh 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 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 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

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, Ryan Marlow, 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. Ryan Marlow’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 Ryan Marlow Request Will Benefit the Public As A 

Whole:

Aerial 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 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. Which 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. Anchorage area is a very busy airspace, which 

is why I am pursuing a 333 Exemption to lead the way 

for other businesses and or enthusiast. My main goal is to prove 

to public that my UAS can be used in Fire, Police or 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

natural disaster relief. My, Ryan Marlow'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 into the national airspace 

system, hence the passing of the Reform Act. Granting my, Ryan 

Marlow’s, exemption request furthers the public interest through 

academic/visual awareness of the geographical benefits in and 

around the Anchorage area. 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, Ryan 

Marlow, to immediately fly within national air space furthers 

economic growth. Granting my exemption request substantially 

furthers the economic impact for the Anchorage community for 

companies looking to relocate or build in the Anchorage area 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 Ryan Marlow's Exemption Will Not 

Adversely Affect Safety Or How The Exemption Will Provide 

a Level of Safety At Least Equal To Existing Rule:

My, Ryan Marlow’s, exemption will not adversely affect safety. 

Quite the contrary, for the reasons stated permitting me, Ryan 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

Marlow, 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, Ryan Marlow, 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.

• 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.

• I have procedures in place to abort flights in the event of 

safety breaches or potential danger.
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

My, Ryan Marlow’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 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.

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, Ryan 

Marlow’s, UAS permits exemption from Part 21 because my 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

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, Ryan Marlow’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, Ryan Marlow.
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage 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, Ryan Marlow, 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, Ryan Marlow, 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, Ryan Marlow, 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. . . .”
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

These Regulations only apply to aircraft with an airworthiness 

certificate. They will not, therefore, apply to my, Ryan Marlow's, UAS. 

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

each flight.

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, Ryan Marlow’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.
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

In summary, Ryan Marlow 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, Ryan Marlow’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 the Anchorage 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, Ryan Marlow’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 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, Ryan Marlow, 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, Ryan Marlow’s, UAS and therefore the 

likelihood of death or serious bodily injury is significantly 

diminished. My, Ryan Marlow’s, operation of my UAS, weighing 
Alaska Aerial Media, Anchorage AK - Section 333 Exemption 

Petition

Alaska Aerial Media, Anchorage AK - Section 333 Exemption Petition

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, Ryan Marlow, 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,

Ryan Marlow, Owner / Manager

Alaska Aerial Media, LLC

7960 Upper O'Malley Road 

Anchorage, AK 99507