My name is Salvatore C Gibilisco and I am the founder of Air 2 Ground Imaging 

located in Delran, New Jersey. We are a small design, photography and video 

production business that began in 2014. I 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 Salvatore C Gibilisco of Air 2 Ground Imaging owner of 

a unmanned aircraft system (UAS) be granted exemption from the Federal 

Aviation Regulations (FARS) listed within so that I may operate my UAS 

commercially in airspace regulated by the Federal Aviation Administration. This 

exemption would allow operation of my UAS for the purpose of aerial 

photography, aerial videography to augment real estate listing video and or real 

estate property developers and or golf course design.

Air 2 Ground is equipped with a DJI Phantom 3 Professional (4) blade quad 

copter weighing 6 lbs. 7.5 ounces. The UAS has a maximum airspeed of 30 

knots. Using remote controller operating on frequency 5.728-5.850GHZ /2.400-

2.483GHZ. The Phantom 3 Professional is equipped with built in ground support 

technology that allows it to fly utilizing GPS for stability, tracking, safe flight mode 

and return to home feature in the event of loss of remote control signal or critical 

low battery. All flights start with a pre-flight safety check and all flight data are 

recorded. The Phantom 3 Professional is equipped with a fixed position camera 

that sends a live video signal to the controller allowing the (PIC) person in control 

to monitor real time video. 

Flight data, speed height, distance, battery level and general aircraft conditions 

are also displayed during operation. Phantom 3 Professional battery has a flight 

time of 12 minutes and is therefore always returned to original take off point and 

always flown utilizing VLOS. I have invested a considerable amount of money 

and have logged over 10 hours with this particular UAS and trained 15 hours with 

other UAS operators equipment and find that this model to be far superior in 

flight, safety and reliability. My request for exemption would allow me to offer 

services to my clients at a considerable discount compared to using Helicopters 

and fixed wing planes that pose severe safety risk to accomplish the type of 

aerial coverage needed in the real estate market. 

UAS Safety Operating Parameters

We will abide by the following additional operating conditions under this 

exemption, which ensures a level of safety during UAS flight. 

Operate UAS below 400 feet and within a radius of 1000 feet from PIC always 

maintaining VLOS.

Obtain permission from the owner/controller of any vessels, vehicles and 

Structures when operations may be conducted closer than 500 feet to any such 

vessels, vehicles or structures; we will conduct a safety assessment of the risk of 

operating closer to those objects and determine that it does not present an undue 

hazard. 
Operate the UAS for 8-12 minutes per flight.

Land UAS prior to the manufacturer's recommended minimum level of battery 

power.

Operate UAS during daylight hours only within visual line of sight (VLOS)

Utilize the UAS' global positioning system (GPS) flight safety feature whereby it 

hovers and then slowly lands if communication with the remote control pilot is lost 

or battery becomes critically low

Contact respective airports if operations will be within 5 miles to advise them of h 

estimated flight time, flight duration, elevation of flight and other pertinent 

information.

Always obtain all necessary permissions prior to operation

Have procedures in place to abort flights in the event of safety breaches or 

potential danger.

Review weather reports prior to flight and never operate UAS in unsafe 

conditions, high wind, low clouds or conditions that hinder visibility.

Only operate in safe environments that are strictly controlled, are away from 

power lines, elevated lights, airports and densely populated areas (defined by 

areas depicted in "yellow" on VFR charts and through obtaining information 

regarding congested areas from the local Flight Standards District Office (FSDO); 

Also conduct extensive preflight inspections and protocols, during which safety 

carries primary importance

The PIC will also have a minimum of 5 hours logged on this craft and 10 hours 

minimum flying UAS quad copters under varying conditions and environments 

and will follow all safety protocol of Air 2 Ground Imaging as well as guidelines of 

14 C.F.R 61.51 (b) having the ability to safely operate the UAS in a manner 

consistent with the operating documents, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles 

and structures as outlined. Specific Exemptions Requested Given the size, 

weight, speed, and limited operating area associated with the UA, we feel an 

exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and§

91.203(a) and (b) (Certifications required), subject to certain conditions and 

limitations, is warranted and meets the requirements for an equivalent level of 

safety under 14 CFR part 11 and Section 333 of P.L. 112-95 (Section 333). 

We request an exemption from§ 45.23 Marking of the aircraft because the UA 

will not have a cabin, cockpit or pilot station on which to mark certain words or 

phrases. Further, the two-inch lettering is difficult to place on such a small aircraft 

with dimensions smaller than the minimal lettering requirement. Regardless of 

this, we can mark the UAS in the largest possible lettering by placing the word 

"Experimental" on its fuselage as required by § 45.29(f) so that anyone will see 

the markings. 

We request an exemption from § 91.7(a) which prohibits the operation of an 

aircraft without an airworthiness certificate, since there is currently no certificate 

applicable to our operation, this regulation is inapplicable. 
We request an exemption from§§ 91.405(a), 91.407(a)(1 ), 91.409(a)(2) and 

91.417(a) and (b) Maintenance inspections since they only apply to aircraft with 

an airworthiness certificate. However, as a safety precaution we will perform a 

preflight inspection of the UAS before each flight as outlined in the attached 

operating documents. 

We request an exemption from§ 91.9(b)(2) which requires an aircraft flight 

manual in the aircraft, however since there are no pilots or passengers on board 

the aircraft and given its size, this regulation is inapplicable. We believe an 

equivalent level of safety will be achieved by maintaining a safety/flight manual 

with the UAS ground station. 

We request an exemption from § 91.119 which prescribes safe altitudes for the 

operation of civil aircraft, but it allows helicopters to be operated at lower altitudes 

in certain conditions. We will not operate our UAS above the altitude of 400 feet 

above ground level (AGL) and will also only operate in safe areas away from the 

public and traffic, thus "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 the UAS, an equivalent or higher level of safety 

will be achieved. We request an exemption from § 91.121 Altimeter settings as it 

is inapplicable since the UAS utilizes electronic GPS with a barometric sensor. 

We request an exemption from § 91.151 (a) Fuel requirements for flight in VFR 

conditions. The UAV is 100% electric and two low battery alerts are issued - per 

the operating documents, the UAV will be landed at the first alert. Also, our flights 

will last only 8-12 minutes each, and the UAS has an automated function, which 

results in immediate landing when a low battery is detected. The PIC will not 

begin a flight unless (considering wind and forecast weather conditions) there is 

enough power to fly to the first point of intended landing and, assuming normal 

cruising speed, land the UA with 30% battery power remaining. 

Public Interest

Aerial videography for geographical awareness and for real estate marketing has 

been around for a long time through manned fixed wing aircraft and helicopters, 

but for small business owners, its expense has been cost-prohibitive. By granting 

this exemption we would be able to provide this service at a much lower cost. 

Further, our small UAS will pose no threat to the public given its small size and 

lack of combustible fuel when compared to larger manned aircraft. Additionally, 

the operation of our UAS will minimize ecological damage and promote economic 

growth by providing information to companies looking to relocate or build in the 

metro areas we service. 

Summary 

We will comply with all of the following conditions and limitations should this grant 

of exemption be provided:
1) Operations will be limited to the following aircraft described in the operating 

documents which is a quad-rotor aircraft weighing less than 7 pounds: 

DJI Phantom 3 Professional 

Aircraft System.

2) The UAS will not be flown at an indicated airspeed exceeding 30 knots.

3) The UAS will be operated at an altitude of no more than 400 feet above 

ground level (AGL), as indicated by the procedures specified in the operating 

documents. All altitudes reported to ATC must be in feet AGL.

4) The UAS will be operated within visual line of sight (VLOS) of the Pilot In 

Command (PIC) at all times.

5) All operations may utilize a visual observer {VO). The UA will be operated 

within the visual line of sight {VLOS) of the VO at all times. The VO and PIC will 

be able to communicate verbally at all times. The PIC will be designated before 

the flight and will not transfer his or her designation for the duration of the flight. 

The PIC will ensure that the VO can perform the functions prescribed in the 

operating documents.

6) The operating documents will be accessible during UAS operations and made 

available to the Administrator upon request. Any revisions to the operating 

documents will be presented to the Administrator upon request.

7) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition 

for safe flight. If the inspection reveals a condition that affects the safe operation 

of the UAS, the UAS will not be operated until the necessary maintenance has 

been performed and the UAS is found to be in a condition for safe flight. The 

Ground Control Station will be included in the preflight inspection. All 

maintenance and alterations will be properly documented

in the aircraft records.

8) Any UAS maintenance or alterations that affect the UAS operation or flight 

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

functional test flight. The PIC who conducts the functional test flight will make an 

entry in the aircraft records.

9) The pre-flight inspection section in the operating documents will account for all 

discrepancies, i.e. inoperable components, items, or equipment, not already 

covered in the relevant sections of the operating documents.

10) We will follow the UAS manufacturer's aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

11) We will carry out maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance, 

inspection, and alterations will be noted in the aircraft records, including total 

flight hours, description of work accomplished, and the signature of the 

authorized person returning the UAS to service.

12) Each UAS operated will comply with all manufacturer Safety Bulletins.

13) An authorized person will make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections. 
14). The PIC will also meet the flight review requirements specified in 14 CFR 

61.56 in an aircraft in which the PIC is rated on.

15) Prior to operations conducted for the purpose of aerial 

videography/cinematography and augmenting real estate listing videos (or similar 

operations), the PIC will have accumulated and logged, in a manner consistent 

with 14 CFR 61.51 (b),

16) Prior to operations conducted for the purpose of aerial 

videography/cinematography and augmenting real estate listing videos (or similar 

operations), the PIC will have accumulated and logged, in a manner consistent 

with 14 CFR 61.51 (b), a minimum of 5 hours as UAS pilot operating the make 

and model of the UAS to be used in operations. 

17) The PIC will not operate the UAS for the purpose of aerial 

videography/cinematography and augmenting real estate listing videos (or similar 

operations), unless the PIC has demonstrated and logged in a manner consistent 

with 14 CFR 61.51 (b), the ability to safely operate the UAS in a manner 

consistent with the operating documents, including evasive and emergency 

maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

18) UAS operations will not be conducted during night, as defined in 14 CFR 1.1. 

All operations will be conducted under visual meteorological conditions (VMC). 

19) The UA will not operate within 5 nautical miles of an airport reference point 

as denoted on a current FAA-published aeronautical chart.

20) The UA will 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.

21) If a UA loses communications or loses its GPS signal, it will return to a 

predetermined location within the planned operating area and land or be 

recovered in accordance with the operating documents.

22) The PIC will abort a flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents.

23) The PIC will not begin a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 30% battery power remaining.

24) Before conducting operations, the radio frequency spectrum used for 

operation and control of the UA will comply with the Federal Communications 

Commission {FCC) or other appropriate government oversight agency 

requirements.

25) The documents required under 14 CFR 91.9 and 91.203 would be available 

to the PIC at the Ground Control Station of the UAS any time the UAS is 

operating. These documents will be made available to the Administrator or any 

law enforcement official upon request.

26) The UA will remain clear and yield the right of way to all manned aviation 

operations and activities at all times.

27) The UAS will not be operated by the PIC from any moving device or vehicle. 
28) The UA will not be operated over congested or densely populated areas.

29) Flight operations will 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. We will 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 and/or;

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

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, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do 

not present an undue hazard to those persons per § 91.119(a). 

30 ) All operations will be conducted over private or controlled-access property 

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

31) Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA will 

be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. 

Accidents will be reported to

the National Transportation Safety Board (NTSB) per instructions contained on 

the NTSB Web site: www.ntsb.gov. 

On behalf of Air 2 Ground Imaging. I would like to thank you for your 

consideration in granting this exemption. It will be an honor to hold this 

designation and I look forward to adding UAS video I photography offerings to my 

business portfolio. 

Thank you for your consideration 

Salvatore C Gibilisco

Air 2 Ground Imaging

157 Fox Chase Drive, Delran, New Jersey 08075

609-864-0884