US Department Of Transportation

Federal Aviation Administration 800 Independence Ave SW Washington DC 20591

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the reform act) and CFR Part 11; I , **Michael A. Nosewi cz**  ., owner and operator of Small Unmanned Aircraft Sy stems (UASs), request to be exempted from the Federal Aviation Regulations (FAR) listed below so that I, **Michael A. Nosewicz** may operate UASs commercially in airspace regulated by the FAA., as long as su ch operations are conducted within and under the conditions outlined herein or as may

be established by

the FAA as required by

Section 333.
I, **Michael A. Nosewicz** . I am requesting exemption from regulations listed below to perform aerial photograph y and vi deograph y of Real Estate and Landscape. All operations will be performed with the public's safet y and right to privacy safe guarded at all times.

**Michael A. Nosewicz** . UASs is a rotorcraft weighing less than 55 pounds including pay load (The DJ I Phantom 3 V ision Quad Copter). It operates at a speed less than 50 knots and has the capability to hover and move in the vertical and horizontal plane simultaneously . It has an auto return to launch point when battery power is under 25%.The UAS will operate within th e line of sight with in a protected flight area as described below and at 200 feet AGL or less with an observer located close at hand as to make voice communication possible. These operations will not create a hazard to users of the nation airspace, public nor the environment.
I, **Michael A. Nosewicz** ., respectfull y request the grant of an exception to the following specific sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for commercial use, 14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 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)&(b).
I, **Michael A. Nosewicz** . submit this application in accordance with the Reform Act ,112 P.L .95 331

- 334, see king relief from any currently applicable FAR'S operating to prevent **Michael A. Nosewicz**  . future commercial use of small UASs to operate in the national airspace sy stem as described below. The reform Act section 332 provides for such integration of civil unmanned aircraft into our national airspace sy stem as it is in the public's interest to do so. **Michael A. Nosewicz** . UASs meet the definition of "small unmanned aircraft" as defined in Section 331 and therefor the integration of these UASs are expressl y co ntemplated by the Reform Act.
I, **Michael A. Nosewicz** ., would like to operate its light weight UASs prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft. The Reform Act directs the Secretary of Tran sportation to consider whether certain unmanned aircraft s ys tems may

operate safel y in national airspace before completion of the rule making required under Section 332 of the reform Act. In making this determination, the Secretary ofTransportation is req uired to determine which UASs do create a hazard to users of the national airspace sy stem or the public or pose a threat to national security in light of the following: The UASs size, speed, weight and operational capability Operation of the UASs in clos e proximity to airports and populated areas Operation of the UASs within visual line of sight of the operator Reform Act 333(a). If the secretary determines that such vehicles "may operate safel y in National Airspace Sy stem, the secretary shall establish requirements for the safe operation in national airspace.

DJIPhantom 3s are rotorcraft weighing less than 55 lbs. and they operate at speeds less than 50 knots and have the capability to operate in the vertical and horizontal plane simultaneously . The U ASs will operate onl y within the line of sight of the operator within a protected flight area and at 200 feet AGL or less. These will not present a hazard to the national airspace nor the public. The very small nature of these UASs combined with the safe guards presented below, will allow for the safe operation greater than that envisioned by Congress for the FAA to establish and by exemption allow commercial operations of UASs to commence immediately. Also due to the size of UASs and the areas and altitud es they will operate approval of this exception presents no national securit y issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management process.
Given the clear direction, in Section 333 of the Reform Ac t, the authorit y contained in the Federal Aviation Act as amended along with the strong level of enhanced safety , reduced emissions, utilizing UASs verses traditional aircraft. As well as the economic impact of greatly reducing the cost of aerial photograp hy is thereby

benefiting the greater public's interest. Accordingl y, the applicant requests that the FAA grant the requested exemption without delay

. The following will be considered as the binding limitation on operations of **Michael A. Nosewicz** :
1. Fli ghts will only

occur in the day

time hours, 2. Flights will be operated in the line of sight of the operator( PIC) and Observer,(VSO) 3. Flights will be terminated at an y time weather and wind deteriorate to "unsafe for flight" b y manufacturers recommendati ons, 4. The UASs will weigh less that 55 lbs., 5. Flights will be operated at 200 feet AGL or less. 6. Crew will be at a minimum of operator( PIC) and an observer and/or camera operator(VSO), 7. Operator and crew will remain in contact during the flight op eration, 8. The UASs operator will perform a check of the flight area and make certain of the safety of all persons in the area, 9. Consent will be obtained from all persons with in the video capabilities of the units to further reduce the chance of violat ing an yone's privacy

. 10. All required FAA clearances, will be obtained and distances from airports strictly observed. 11. All UASs will have the capability to return automatically

to the operator in a safe manner with the auto return function checked and working.12. When operated in conjunction with fishing vessels in the gulf, a chase boat will be assigned

to operate the UASs at a safe distance from the main fishing boat. 13. Flights will only

operate in VFR conditions. 14. UASs have a function on the co ntrol to tell operator the distance away from the operator and its battery power remaining. 15. Flight team will communicate b y voice and the use of two

- way radio if the area is too big to hear voice from all team members. 16. UASs will be used to video pr ivate outings and functions, boating, jet skiing, kay aking, fishing trips in the gulf area and sporting events from a safe distance. 17. When operating over or near water the UASs will be equipped with flotation device so that recovery can be made as to pr event lithium battery exposure to the water table. 14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1) Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in relati on to FAR 91.203(a)(1). The size, weight and defined area of operations for **Michael A. Nosewicz's** UASs flights permits exception from Part 21 because they meet an equivalent level of safet y pursuant to Section 333 of the Reform Act. The FAA is authorized t o exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in consideration of weight, size , speed, maneuverability

and proximity

to areas such as airports and dense populations. **Michael A. Nosewicz's** USAs meets or exceeds each of these elements As of March 23, 2015 the FAA has stated that it will automatically grant a "blanket" COA for flights at or under 200 AGLto an y UASs operator with a section 333 exemption. 14 CFR 61.113 (a) & (b): Private Pilot Privileges and L imitations: Pilot in Command. Because the UAS’s in unmanned and will not carry a pilot or passengers, the proposed operations can achieve a high level of safet y of operation without the required pilot license. 14 CFR 91.203 (a&b) provides for carrying of civil aircraft certifications and registrations. These are inapplicable for the same reasons stated above. 14CFR91.7 (a) proh ibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by FAR's this regulation is inapplicable. 14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft 14 CFR 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 UASs this regulation is inapplicable. An equivalent level of safet y will be achieved b y m aintaining such certifications and registratio ns at ME Drone Video LLC operations center. The FAA has previously

issued exemptions to this regulation in Exemptions No's 8607,8737,8738,9299,9299A, 9565,9565B, 10167,10167A, 10602,10700 and 32827.14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It

allows helicopters to be operated at lower altitudes in certain conditions. ME Drone Video LLC will only operate its UASs at or below 200AGL. They will be operated on a will defined AOR that has been carefully reviewed for hazards and minimizes the presence of any persons not essential for these operations. Flights will only be over private propert y that the owner has consented and all persons within this video area also give consent for this filming. Compared to flight operations of conventional and traditional aircraft or rotorcraft weighing far more than 50 lbs., operating below 500 AGL with flammable fuel UASs operations present a far smaller risk to the public. Approval of these 333 Exemptions allowing commercial operations of small UASs in the service of aerial photograph y will greatly enhance safet y by reducing the overall risk associated with traditional aircraft. Traditional aerial photograph y requires large aircraft with flammable fuel to fly in close proximity

of populated areas and people in general. With the use of small UASs of 55 lbs. or less, battery

operated and fling below 200 feet AGL the risk of injury of people on the ground or the crew has been reduced or almost erased. The granting of the u se of these small UASs by **Michael A. Nosewicz** will give potential sellers of Real Estate a competitive edge in the market place. Granting **Michael A. Nosewicz** the above exemption will allow for the expansion of UAS sy stems into the future for the safe con duct of free enterprise and the enjoyment of the masses.
I, **Michael A. Nosewicz** respectfull y requests the FAA grant its exception without delay . The FAA has the authorit y to issue the exemption sought by **Michael A. Nosewicz,** pursuant to the Federal Aviati on Act, 85 P.L . 726 (1958) as amended (the ACT).