Information Classification: Limited Access

July 1, 2015

Ryan Henneberry

Imperial Drones LLC

475 48th 3103

Long Island City, NY 11109

Cell: 631.645.2491

Email: ryanhenneberry73@yahoo.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 2059

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments: 1) Phantom 3 Professional User Manual V1.0 2015.04

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014- 

0481 in the matter of the petition of DOUGLAS TRUDEAU 

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–

0508 in the matter of the petition of ADVANCED AVIATION 

SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-

0355 in the matter of the petition of FLYING CAM INC

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption 

under section 333 of the FAA Modernization and Reform Act of 2012, I Ryan 

Henneberry, representing Imperial Drones LLC, referred to hereafter as the 

petitioner, request exemption from the following sections of Title 14,

Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 

91.409 (a)(1); 91.409(a)(2); 91.417(a) & (b);

In order to operate small unmanned aircraft systems (UAS) commercially in 

airspace regulated by the Federal Aviation Administration (FAA) for the purposes 

of aerial photography, cinematography, videography, mapping, crop surveying, 

inspections and other flight operations that could be performed safely and more 

cost effectively with the use of small UAS at low altitude within the U.S. national 

airspace system as compared to a manned aircraft. Operations will be performed 

only at the request of and with the authorization and permission of clients or their 
Information Classification: Limited Access

authorized agents in order to facilitate commerce and raise awareness of the 

beneficial uses of small unmanned air systems. So 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 petitioner are drawn from references 1-3.

The FARs

The petitioner seeks exemption from the above mentioned FARs for the following

reasons;

61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization 

of pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating 

under this exemption would be required to comply with any conditions as set 

forth and in a similar fashion to the previously granted exemptions.

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations

conducted closer than 500 feet to the ground may require that the UA be 

operated closer than 500 feet to essential persons, or objects that would not be 

possible without additional relief. The petitioner requests modification, waiver or 

exemption and clarification concerning the terms “congested areas” and “densely 

populated”. The petitioner requests waiver for this condition to allow reasonable 

and responsible operations in areas of subdivisions and neighborhoods if 

required.

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable 

since the UAS does not have an altimeter and instead utilizes electronic GPS 

with a barometric sensor for altitude information.

91.151(a) As discussed in Exemption 11136 prior relief has been granted for 

manned aircraft to operate at less than the prescribed minimums, including 

Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief 

has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR 

conditions. The UAS provides battery power remaining as percentage to the PIC. 

The UA batteries provide approximately 25 minutes of powered flight. Information 

provided in the operating documents discusses procedures regarding remaining 

battery power management. Those documents contain a condition in which the 

PIC will initiate a landing procedure when battery remaining reaches a specified

level. Given the limitations on proposed operations and the location of those 

proposed

operations, The FAA found that a reduced minimum power reserve for flight in 

daytime VFR conditions was reasonable.
Information Classification: Limited Access

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in 

Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect 

and ensure that the UAS is in a condition for safe flight in accordance with the 

operating documents. The FAA found that adherence to the petitioner’s operating 

documents and the conditions and limitations specified, describing the 

requirements for maintenance, inspection, and recordkeeping, were sufficient to 

ensure that safety would not be adversely affected.

The UAS’s

The Phantom 3 Advance are highly successful consumer grade small rotorcrafts

in the quadcopter configuration with an advertised weight of less than 44 Ounces 

(1242g)

designed primarily to carry aloft a high definition camera. They have an 

advertised maximum speed of less than 35 knots (15m/s) and a maximum climb 

rate of less than 1200 feet per minute (6 m/s). They are powered by four electric 

motors with a distance between motors of less than 14 inches (350mm). They 

utilize an internal inertial measuring unit (IMU) with integrated barometric sensor 

augmented with global positioning system (GPS & GLONASS) to maintain its 

geospatial orientation and position. They are controlled primarily through an FCC

certified radio control (RC) unit. Real time video and telemetry information is 

transmitted back to a ground control station allowing the operator and/or PIC to 

monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, 

camera imagery, and control camera angle. It has failsafe modes of operation for 

either loss of RC or GPS signal. Altitude can be limited by the onboard flight 

controller and maximum altitude can be preprogrammed by the PIC. Battery life 

limits flight times to approximately 25 minutes or less. The onboard flight 

controller will warn the pilot via telemetry and external lighting cues before 

reaching a low battery state. An automatic termination of flight and

landing will be initiated when the battery reaches a predetermined low state. It is

anticipated that flights will usually last less than 10 minutes. More information is

available in attachment 1 or http://www.dji.com/product/phantom-2-vision-plus

and http://www.dji.com/product/phantom-3-professional.

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and 

Limitations section and believes that the procedures specified therein are 

reasonable and will be utilized in order to manage and mitigate risk and ensure 

public safety. A preflight checklist will be developed and employed to ensure that 

the UA airworthiness will be verified before launch. Airworthiness will be 

maintained by performance of routine inspections before each flight, maintaining 

flight and maintenance logs to record time on failure-prone components.
Information Classification: Limited Access

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the

environmental impact as compared to similar operations conducted with manned 

aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, 

use of the UAS in order to facilitate commerce are anticipated to lead to 

economic growth. Operations for this petition will enable service for property 

owners or their designees seeking an enhanced perspective for characteristics, 

amenities, and benefits of their desired photographic

subjects that cannot be displayed through ground level 

videography/photography. Aerial photography is a valuable marketing tool that 

can lead to increased commerce and enhance personal photography. Crop 

surveying applications could lead to decreased use of pesticides and fertilizer 

and conservation of water as well as increased crop yields and decreased costs. 

Aerial surveying and inspections can increase work site efficiency, improve 

volumetric estimations and reduce risks. The petitioner will provide clients with 

photographic data for these purposes on a ‘for hire’ basis acting as an

independent contractor. A visual observer will be utilized. Liability insurance will 

be obtained commensurate with the granting of this request for exemption. Flight 

data including UA flight time, Control Unit operation time, incident, accident, and 

details concerning any deviations from normal operations will be available to FAA 

for use in collecting data regarding the use of UAS as part of this application. 

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial 

photography, cinematography, videography, mapping, crop surveying, 

inspections and other flight operations”. The petitioner's business model is based 

on the idea of offering ad hoc small UAS services to individuals or companies 

who wish to employ these services as a safe, effective, and legal option to 

enhance their business or hobby. The petitioner’s own market research

shows pent up demand for these services currently exists in the real estate 

market and other markets are just beginning to emerge. The petitioner has

refrained from engaging in commercial use of the UAS. The primary purpose of 

seeking this exemption is to obtain the capability to offer those services while 

remaining in compliance. 

Respectfully submitted,

Ryan Henneberry

President

Imperial Drones LLC