5.7.15

Icarus Aerial Media Inc. 

34 Frostfield Place 

Melville, NY 11747

Tel. 516-315-0234

United States Department of Transportation

Docket Management System

1200 New Jersey Ave , SE 

West Building Ground floor Room W12-140

Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 

To Whom it may concern:

Pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained in 14 C.F.R. 11, to 

request that Icarus Aerial Media Inc., an owner and operator of small unmanned aircraft, be exempted from the 

Federal Aviation Regulations ("FARs") listed below so that Icarus Aerial Media Inc. may operate its small 

lightweight unmanned aircraft systems ("UAS") commercially in airspace regulated by the Federal Aviation 

Administration ("FAA"); as long as such operations are conducted within and under the conditions outlined herein 

or as may be established by the FAA as required by Section 333. The conditions identified and proposed by the 

applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8-Issue a Certificate of Waiver Aerial 

Photography and Video. 

As identified and described herein, Gerald Svoronos, and his company Icarus Aerial Media Inc., is an experienced 

and avid RC model flyer for over twenty (20) years. Mr. Svoronos is a degreed Architect and is experienced with 

Construction progress photography. Icarus Aerial Media Inc. has fully equipped its small unmanned aircraft for 

aerial photography and cinematography, primarily for use in Real Estate Advertisement, Construction progress 

photography and Construction Inspections. Though given their stability and maneuverability, they may be used for 

other cinematography, by law enforcement personnel, search and rescue and by other first responders. 

To date, Icarus Aerial Media Inc. has not performed any commercial services in Aerial photography on locations 

within the United States to ensure it is in compliance with any applicable FARs. It, like other applicants, has done 

so despite Judge Patrick G. Geraghty's decision in the Raphael Pirker matter and his reasoning that 

no FARs prohibit the use of small unmanned aircraft or lightweight UASs like those flown by other peer companies. 

Icarus Aerial Media Inc. exemption request would permit its operation of lightweight, unmanned “in line of sight”

UASs (DJI Phantom 3 or Similar ) in tightly controlled and limited airspace. Predetermined, specifically marked 

areas of operation, cordoned off locations and corresponding enhancements to current safety controls will allow 

Icarus Aerial Media Inc. to operate within current safety parameters and new ones being implemented. As 

identified, similar lightweight, remote controlled UASs are legally operated by amateurs with no flight experience, 

safety plan or controls in place to prevent catastrophe. Icarus Aerial Media Inc. Utilizes a pre-flight safety and flight 

plan system. 
 

Icarus Aerial Media Inc. respectfully requests the grant of an exemption allowing it to 

operate lightweight, remote controlled UAS's. The Specific Sections of Title 14 of the Code of 

Federal Regulations.

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). 

Exemption Request Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) 

(2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 

91.409 (a) (2);91.417 (a) & (b). 

The Extent of Relief Icarus Aerial Media Inc. Seeks and the Reason It Seeks Such Relief: 

Icarus Aerial Media Inc. submits this application in accordance with the Reform Act, 112 

P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent 

Icarus Aerial Media Inc. contemplated commercial 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. Icarus Aerial Media Inc. lightweight UASs (DJI Phantom 3 or 

similar) meet the definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of 

Icarus Aerial Media Inc. lightweight UASs are expressly contemplated by the Reform Act. Icarus Aerial Media Inc. 

would like to operate its lightweight UASs prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such craft.

The Reform Act guides the Secretary in determining the types of UASs that may operate safely in our national 

airspace system. Considerations include: The weight, size, speed and overall capabilities of the UAS; Whether the 

UAS will be operated near airports or populated areas; and, Whether the UAS will be operated by line of 

sight. 112 P.L. 95 § 333 (a). Each of these items militates in favor of an exemption for Icarus Aerial Media Inc. 

Icarus Aerial Media Inc. UASs utilizes four counter-rotating propellers for extreme balance, control and stability. 

They each weigh less than 55 pounds, including cinematic or other equipment. 

Each of Icarus Aerial Media Inc. small unmanned aircraft (DJI Phantom 3 or similar) are designed to primarily hover 

in place and operate at less than a 50 knot maximum speed. They are capable of vertical and horizontal operations 

but operate only within the line of sight of the remote control pilot. Utilizing battery power and not combustible 

fuels, flights generally last between five and twenty minutes. Icarus Aerial Media Inc. does not operate its UASs 

with less than twenty five percent battery capacity. Safety systems in place include a GPS mode that allows Icarus 

Aerial Media Inc. UASs to hover in place if communication with the radio control pilot is lost and then slowly 

descend the UAS at twenty five percent battery capacity. Further, Icarus Aerial Media Inc. fleet is programmed, in 

some instances, to slowly follow a predetermined set of waypoints to return to a safety point if communications 

are lost. Icarus Aerial Media Inc. does not operate its UASs near airports and generally does not operate them near 

populated areas. The UAS operating software and GPS navigation systems do not allow any of the Icarus Aerial 

Media Inc. UAS vehicles to operate near airports or restricted fly zones. The failsafe software will disable the UAS 

vehicles from taking off and also limit the UAS systems from operating within specific GPS preset no-fly zones. 

The FAA has the authority to issue the exemption to Icarus Aerial Media Inc. pursuant to the 

Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). Commercial and Public Benefits Granting Icarus 

Aerial Media Inc. exemption request furthers the public interest. First, Congress has already pronounced that it is 

in the public's interest to integrate commercially flown UASs into the national airspace system, hence the passing 
 

of the Reform Act. Second, Icarus Aerial Media Inc. conducts research into safe UAS operations every time it flies 

one of its UASs. Flight data, visual inspections, recorded observations and flight analyses are compiled to 

further enhance current safety protocols. Allowing Icarus Aerial Media Inc.to log more flight 

time directly relates to its research and its ability to further enhance current safety measures. 

The public has an interest in reducing the danger and emission associated with current 

aerial cinematic capture methods, namely, full size helicopters. Icarus Aerial Media Inc. UASs 

are battery powered and create no emissions. If an Icarus Aerial Media Inc. UAS crashes there is 

no fuel to ignite and explode. The impact of Icarus Aerial Media Inc. lightweight UASs is far 

less than a full size helicopter, notwithstanding the statistically noteworthy safety record of 

full size helicopters used in motion picture capture. The public's interest is furthered by minimizing 

ecological and crash impacts by permitting motion picture capture through Icarus Aerial Media Inc.

Services lightweight UASs. 

Progression of the arts and sciences has been fundamental to our society since its inclusion 

in the United States Constitution. Indeed, Congress mandated the integration of 

UASs into our national airspace system, in part, to achieve progression in this noteworthy, and inevitable, field. 

Permitting Icarus Aerial Media Inc.to immediately fly within the United States furthers these 

goals. Whether it is the advancements in publicly usable technologies or advancements in equipment available to 

law enforcement personnel I first responders that does not cost millions of dollars, granting Icarus Aerial Media 

Inc. exemption request substantially furthers the public's interest in ways known and currently unknown. 

Reasons Why Icarus Aerial Media Inc. Exemption Will Not Adversely Affect Safety Or How 

The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

Icarus Aerial Media Inc. exemption will not adversely affect safety. Quite the contrary, for 

the reasons stated, supra, permitting Icarus Aerial Media Inc.to log more flight time in FAA 

controlled airspace will allow Icarus Aerial Media Inc.to innovate and implement new and as of 

yet undiscovered safety protocols. In addition, Icarus Aerial Media Inc. submits the following 

enhanced safety protocols to current aerial photography capture techniques: 

Safety protocols:

• Icarus Aerial Media Inc. UASs weigh less than 55 pounds complete with 4k Resolution Motion picture quality 

Camera.

• Icarus Aerial Media Inc. only operates its UASs below 200 feet; 

• Icarus Aerial Media Inc. UASs only operate for 5-25 minutes per flight; 

• Icarus Aerial Media Inc. lands its UASs when they reach 25% battery power; 

• Icarus Aerial Media Inc. remote control pilots operate UASs by Visual Line of Sight (VLOS) and will operate under 

daytime VFR conditions;

• Icarus Aerial Media Inc. remote control pilots have video backup should they somehow 

 lose sight of the UAS; 

• Icarus Aerial Media Inc. UASs have GPS flight modes whereby they hover and then 

 slowly land if communication with the remote control pilot is lost or battery power is below25%; 

• Icarus Aerial Media Inc. actively analyses electronic flight data and other sources of 

 information to constantly update and enhance safety protocols; 

• Icarus Aerial Media Inc. only operates in secured areas that are strictly controlled, are away from airports and 

highly populated areas; 

• Icarus Aerial Media Inc. conducts extensive inspections of equipment prior to flight, during which safety 

 carries primary importance; maneuverability and speed of Icarus Aerial Media Inc. UASs, an equivalent level of 

 safety will be achieved. 
 

Icarus Aerial Media Inc. will not operate within 5NM of an airport having an operational control tower or:

 3 NM from an airport with a published instrument flight procedure, but not an operational tower

 2 NM from an airport without a published instrument flight procedure or an operational tower

 2 NM from a heliport with a published instrument flight procedure

Summary 

Icarus Aerial Media Inc. seeks an exemption from the following Regulations: 14 C.F.R. 

21, subpart H; 14 C.P.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.P.R. § 91.409 (a)(2); 14 C.P.R. § 91.409 (a)(2); and, 14 C.P.R. §§ 91.417 (a) 

& (b) to commercially operate its fleet of small unmanned vehicles and lightweight unmanned 

aircraft vehicles in Construction progress video/ photography and Real Estate video/photography, to conduct its 

own research and to develop economic platforms for law enforcement and or search and rescue operations. 

Granting Icarus Aerial Media Inc. request for exemption will reduce current risk levels and 

thereby enhance safety. Currently, Aerial Construction and Real Estate photography’s use of 

larger aircraft running on combustible fuel. Icarus Aerial Media Inc. craft do not contain 

potentially explosive fuel, are smaller, lighter and more maneuverable than conventional motion 

picture aircraft. Further, Icarus Aerial Media Inc. operates at lower altitudes and in controlled 

airspace. 

Icarus Aerial Media Inc . will be analyzing flight data and other information in 

compiling safety protocols and the implementation of a flight operations manual that 

exceeds currently accepted means and methods of safe flight. 

There are no people on board Icarus Aerial Media Inc. UASs and therefore the likelihood 

of death or serious bodily injury is significantly limited. Icarus Aerial Media Inc. operation of 

its UASs, weighting less than 55 pounds and traveling at speeds lower than 50 knots in cordoned off 

areas will provide at least an equivalent level of safety as that achieved under current FARs. 

I thank you for your attention to this matter. If you should have any questions, please do not hesitate to contact 

me.

Sincerely,

Gerry Svoronos

Gerald Svoronos