Jeremy L. Lewis, Bridgeport, OH --- Section 333 Exemption Petition 

 November 11, 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, Jeremy L. Lewis, 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, 

Jeremy L. Lewis, an owner and operator of small unmanned aircraft, be 

exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, 

Jeremy L. Lewis, 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, Jeremy L. Lewis, am experienced in flying hobby helicopters for 

recreational purposes and have been doing so for several years. I have added a hobby grade

quad---copter/UAS to my inventory, a DJI Phantom 3, equipped with an

integrated aerial video system with intent for aerial 

videography/cinematography/photography for commercial purposes mostly in the Ohio, 

WV, Pennsylvania area.

I have flown small RC electric airplanes and helicopters for several years without 

incident. Committed to safety with each flight, my, Jeremy L. Lewis'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 aerial videography/cinematography for commercial purposes. 

 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, Jeremy L. Lewis, will continue to strictly comply with safety and maintenance procedures included in all applicable UAS manufacturer’s instructions 

and operating manuals to avoid and prevent public hazard, as well as manned 

aircraft hazards/catastrophe. This will act to further safety protocols exclusive to 

lightweight UAS's specific to video and photography usage as I, Jeremy L. Lewis, 

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, Jeremy L. Lewis’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 real 

estate/Realtor purposes. Further I, Jeremy L. Lewis, will conduct my operations in 

compliance with the protocols described herein or as otherwise established by the 

FAA. 

 

For the reasons stated below I, Jeremy L. Lewis, respectfully request the grant of an 

exemption allowing me to operate ultra light weight, remote controlled UAS’s for 

aerial videography/cinematography/photography for commercial purposes. 

 

I have attached the user manual for the Phantom 3 Professional for your review. 

 

I. Contact Information: 

Jeremy L. Lewis 

71465 Twin Beech Road Bridgeport, OH 43912 

 jllewis5@comcast.net 

 

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Jeremy L. Lewis 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 Jeremy L. Lewis seeks and the Reason He Seeks 

Such Relief: 

 

I, Jeremy L. Lewis, 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, Jeremy L. Lewis, contemplated commercial 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, Jeremy L. Lewis’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 
commercial 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 reflects in favor of an exemption for me, Jeremy L. 

Lewis. 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, Jeremy L. Lewis, consider safety as 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 released. When 

pilot communication is lost the UAS is designed to slowly descend to the 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 am 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. My UAS is capable of vertical and horizontal operations, and are 

flown only within my line of sight of me, as the remote control pilot. Utilizing 

battery power rather than combustible fuels, flights generally last less than 15 minutes, with an altitude under four hundred (400) feet. I, Jeremy L. Lewis, 

 utilize a fresh fully charged battery with each flight as a safety precaution; full 

flight time limit for each battery is fifteen (15) to twenty---five (25) minutes as 

tested. I do not operate my UAS at or below manufacture recommend minimum 

charge levels for operation; 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 on 

hand with each exercise to insure replacement for sufficient safe level of 

operation. I do not believe in taking a risk that may cause a crash that could 

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

lose an investment. I have clocked 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 have done all of this for the 

 sake of safety. 
 

I, Jeremy L. Lewis, 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. Jeremy L. Lewis’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 Jeremy L. Lewis’s Request Will Benefit the Public As A Whole: 

 Aerial videography and photography for geographical awareness for commercial marketing has been around for a long time through manned fixed wing aircraft and 

helicopters. For small budget real estate companies and average homeowners the 

expense of such aerial videography is cost prohibitive. Only large companies and 

high end Realtors or luxury homeowners can afford to absorb such expense. 

Depriving non---luxury homeowners and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat to the public through potential 

catastrophic crash that the community has experienced in the past. Each resulting in 

loss of life. Each with combustible fuel that exploded and burned on impact. Police 

helicopters have made emergency hard landings within city limits. My, Jeremy L. 

Lewis'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 UASs into the national airspace system, hence the passing of 

the Reform Act. Granting my, Jeremy L. Lewis’s, exemption request furthers the 

public interest through academic/visual awareness of the geographical benefits in 

and around the tri-state 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, Jeremy L. Lewis, to immediately fly within national air 

space furthers economic growth. Granting my exemption request substantially 

furthers the economic impact for the Ohio, West Virginia, and Pennsylvania area. 

 V. Reasons Why Jeremy L. Lewis’s Exemption Will Not Adversely Affect 

Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To 

Existing Rule: 

 
My, Jeremy L. Lewis’s, exemption will not adversely affect safety. Quite the 

contrary, for the reasons stated permitting me, Jeremy L. Lewis, 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 commercial operators that can be embraced by 

the NAR6, AAR7, and TAR8 for development in cooperation with the FAA. In 

addition I, Jeremy L. Lewis, submit the following representations of enhancements 

to current aerial videography and photography for commercial purposes: 

 My UAS weighs less than 5 pounds complete with an integrated video system: 

• I only operate my UAS below 400 feet (within the 400 foot permissible 

ceiling set by the FAA Modernization and Reform Act of 2012) 

• My UAS will only operate for up to 15 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. 

My, Jeremy L. Lewis’s, safety protocols provide a level of safety equal to or exceeding 

existing rules. It is important to note that absent of the integration of commercial UAS 

into our national airspace system, helicopters are the primary means of aerial video 

and photography for commercial purposes. While the safety record of such 

helicopters is remarkably astounding, there have been incidents involving loss of life as well as extensive property damage. 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, Jeremy L. 

Lewis’s, UAS permits exemption from Part 21 because my UAS meets (and exceeds) 

an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is 

authorized to exempt aircraft from the airworthiness certificate requirement under 

both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of 

legislation permit the FAA to exempt UAS's from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability and 

proximity to areas such as airports and dense populations. My, Jeremy L. Lewis’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.10 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, Jeremy L. Lewis. 

 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 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 non --- commercial operations. 

I, Jeremy L. Lewis, 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, Jeremy L. 

Lewis, to operate my UAS and 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 400 AGL; safely at orbelow the 

standard of 400 AGL. I, Jeremy L. Lewis, 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. 

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, Jeremy L. Lewis'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, Jeremy L. 

Lewis’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, Jeremy L. Lewis 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, 

Jeremy L. Lewis'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 Ohio/West Virginia/Pennsylvania 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, 

Jeremy L. Lewis’s, request for exemption will reduce current risk levels and 

thereby enhance safety. My UAS craft do 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 air fields. I, Jeremy L. Lewis, have been informally analyzing flight 

information and will compile safety protocols and the implementation of a flight 

operations manual for real estate 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, 

Jeremy L. Lewis’s, UAS and therefore the likelihood of death or serious bodily 

injury is significantly diminished. My, Jeremy L. Lewis’s, operation of my UAS, weighing less than 5 pounds and travelling at lower speeds within limited areas 

will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, Jeremy L. Lewis, 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 submitted, 

 

Jeremy L. Lewis 

71465 Twin Beech Road 

Bridgeport, OH 43912

 Jllewis5@comcast.net