June 5, 2015 

U.S. Deparhnent of Transportation Docket Management System 

1200 New Jersey Ave., SE Washington, DC 20590 

Re: 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). 

To Whom It May Concern: 

In pursuant with Section 333 of the FAA Modemization and Reform Act of2012 and 14 C.F.R. Part 11, 

Aerial Experts LLC (Aerial Experts), an operator of a small Unmanned Aircraft System (sUAS) for the 

motion picture and television industry, seeks an exemption from the Federal Aviation Regulations (FARs) 

to allow commercial operations of its sUAS. Regulations ("FARs") to allow commercial operation of its 

sUASs, 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. 

As described more fully below, the requested exemption would permit the operation of small and 

unmanned sUAS under controlled conditions in airspace that is limited, predetermined, controlled as to 

access and would provide safety enhancements to the already safe operations in the film and television 

industry presently using conventional aircraft. Approval of this exemption would thereby enhance safety 

and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to "...establish 

requirements for the safe operation of such aircraft systems in the national airspace system." Section 333(c) 

of the Reform Act. 

Information Supporting this Petition as Specified in 14 C.F.R § 11.81 

(a) Your name and mailing address and, if you wish, other contact information such as a fax number, 

telephone number, or e-mail address; 

Aerial Experts LLC. Derrick Nevot (President) 

7350 SW 21'' 

Miami, FL 33155 

(786) 326 6414 

Email: derricimevot@yahoo.com 

(b) The specific section or sections of 14 C.F.R. from which Aerial Experts seeks an exemption 

• 2 1- Subpart H Certification procedures for products and parts, Airworthiness 

Certificates 

• 45.23 - Display of marks; general 

• 61.113- Private pilot privileges and limitations: Pilot in command 

• 91.103- Preflight Actions 

• 91.105- Flight crewmembers at stations 

• 91.109- Flight instruction; Simulated instrument flight and certain flight tests 
• 91.119- Minimum safe altitudes: General 

• 91.121-Altimetersettings 

• 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions 

• 91.203 -Civil aircraft: certification required 

• 91.405- Maintenance required 

• 91.407- Operation after maintenance, preventative maintenance, rebuilding, and alteration 

• 91.409 -Inspections 

• 91.417 - Maintenance records 

(c) The extent of relief Aerial Experts seeks, and the reason Aerial Experts seeks the relief 

entitles several provisions of 14 C.F.R. Parts 21, 45, 61, and 91 to the extent to operate stnall 

UASs to document aerial video for production purposes. 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 

333(a) through (c) ofthe Reform Act. This law directs the Secretary of Transportation to consider 

whether certain unmanned aircraft systems may operate safely in the national airspace system 

(NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In 

making this determination, the Secretary is required to determine which types of UASs do not 

create a hazard to users of the NAS or the public or pose a threat to national security in light of the 

following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act§ 333 (a). Lastly, if the Secretary determines that such vehicles "may operate 

safely in the national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft in the national airspace system" 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority by its terms includes exempting civil aircraft, as the term is 

defined under §40101 of the Act, which includes UASs, from the requirement that all 

civil aircraft must have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the 

Administrator fmds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 

USC §44711(a); 49 USC §44704; 14CFR§91.203 (a) (1). 

14 C.F.R 21 - Subpart H Certification procedures for products and parts, 

Airworthiness Certificates 

Aerial Experts seeks exemption from 14 C.F.R. 21, Subpart Which states the 

certification procedures for products and parts as well as au -worthiness certificates. The 

UAS to be under 551bs take off weight in its entirety. Not carrying a pilot, passengers, 

explosive materials, flammable liquids, or fuels. Operating exclusively within a secured 

area as set out in the manual. Unlike civil aircraft, operations under this exemption will 

be controlled and monitored by the operator. Operating under the manual's requirements 

and the compliance of local public safety. These safety enhancements, which already 

apply to civil aircraft operations in connection with motion pictures and television 

production provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. 

Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UAS, due to its size, speed of operation, 
location of operation, lack of explosive materials or flammable liquid fuels, and inability 

to carry a substantial external load. Aerial Experts has developed our own training 

procedures and regulations to promote and provide safe flying experiences for our PIC(s), 

which can be viewed in section (e) of this petition. Unlike other civil aircraft, operations 

under this exemption will be controlled and monitored by both the operator, pursuant to 

the manual's requirements, and under the requirements and in compliance with local 

public safety requirements, to provide security for the area of operation. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

Aerial Experts seeks exemption from 14 C.F.R. 45.23, which discusses the display of marks. Specifically, 

section 45:23 states, "(a) each operator of an aircraft must display on that aircraft marks consisting of the 

Roman capital letter "N" (denoting United States registration) followed by the registration number of the 

aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter (b) when marks 

include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or 

light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also 

display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the words "limited," "restricted," "light- sport," "experimental," or 

"provisional," as applicable". 

Aerial Experts will need exemption from this regulation due to the small size of the aircraft and that there is 

no cabin, cockpit, or pilot station for the aircraft. The words "Experimental" has been placed on the 

fuselage in compliance with §45.29 (f) where the pilot, observer and others working with the UAV will see 

the identification of the UAS as "Experimental." The FAA has issued the following exemptions to this 

regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

14 C.F.R. § 61.113 (a) &(b): Private Pilot Privileges and Limitations: Pilot in Command. Aerial 

Experts seeks exemption from 14 C.F.R. 61.113, which discusses private pilot privileges and limitations for 

the Pilot in connnand (PIC). 

Aerial Experts is seeking exemption from this regulation, because Aerial Experts believes that there is 

inconclusive evidence that a person with a private pilot certificate can successfully maneuver a sUAS 

without first hand flight experience with the particular sUAS. In fact, having a private pilot license does not 

automatically ensure competence at flying a sUAS in 3rcc person view as required to properly operate an 

sUAS within the required line of sight. However, we believe that the PIC and our FOVO (Field Operation 

Visual Observer) must be able to understand and correctly interact with the general aviation community. 

Therefore, we believe our own flight training with the sUAS will be more than satisfactory. Our PIC and 

FOVO will be both certified in Ground School training to be able to properly interact with General Aviation 

protocols. They will also actively pursue a private pilot's license as well have the necessary medical 

qualifications. 

14 C.F.R. 91.103- Preflight Actions 

Aerial Experts seeks exemption from 14 C.F.R. 91.103 which states that each pilot in command shall, 

before beginning a flight, become familiar with all available information concerning that flight. This 

information must include: (a) For a flight under IFR or a flight not in the vicinity of an airport, weather 

reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, 

and any known h-affic delays of which the pilot in command has been advised by ATC; actions, including 

reviewing. weather, flight battery requirements, landing and takeoff distances, and aircraft performance data 

before starting a flight. 

Aerial Experts will be operating our sUAS in VFR. Our operations manual already includes preflight 

procedures directly pertaining to our sUAS which includes equipment checklist as well a preplanning details 

regarding weather conditions, review of any possible flight path of general aviation, our mission flight path 

and weather conditions amongst other parameters required to complete the mission. 
14 C.F.R. 91.105 -Flight crewmembers at stations 

Aerial Experts seeks exemption from 14 C.F.R. 91.105, which discusses flight crewmembers at stations. 

Specifically, 91.105 states "(a) During takeoff and landing, and while en route, each required flight 

crewmember shall (1) Be at the crewmember station unless the absence is necessary to perform duties in 

connection with the operation of the aircraft or in connection with physiological needs; and (2) Keep the 

safety belt fastened while at the crewmember station. (b) Each required flight crewmember of a U.S.- 

registered civil aircraft should, during takeoff and landing, keep his or her shoulder harness fastened while 

at his or her assigned duty station. This paragraph does not apply if (1) The seat at the crewmember's 

station is not equipped with a shoulder harness; or (2) The crewmember would be unable to perform 

required duties with the shoulder harness fastened. Aerial Experts will need exemption from this regulation 

due to the fact that the sUAS will not have a flight crew or crew stations other than the PIC and a FOVO. 

The PIC will also not have to be restrained into a seat via shoulder harness or safety belt at the time of the 

flight. 

14 C.F.R 91.109- Flight instruction; Simulated instrument flight and certain flight tests 

Aerial Experts seeks exemption from 14 C.F.R. 91.109, which discusses flight instruction, simulated 

instrument flight, and certain flight tests. Specifically, 91.109 states, "(a) No person may operate a 

civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has 

fully functioning dual controls. However, instrument flight instruction may be given in an airplane that is 

equipped with a single, functioning throw over control wheel that controls the elevator and ailerons, in 

place of fixed, dual controls, when (1) The instructor has determined that the flight can be conducted 

safely; and (2) The person manipulating the controls has at least a private pilot certificate with appropriate 

category and class ratings. (b) An airplane equipped with a single, functioning throw over control wheel 

that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight instruction to 

conduct a flight review required by §61.56 of this chapter, or to obtain recent flight experience or an 

instrument proficiency check required by §61.57 when (1) The airplane is equipped with operable rudder 

pedals at both pilot stations; (2) The pilot manipulating the controls is qualified to serve and serves as pilot 

in command during the entire flight; (3) The instructor is current and qualified to serve as pilot in command 

of the airplane, meets the requirements of §61.195(b), and has logged at least 25 hours of pilot-in-command 

flight time in the make and model of airplane; and (4) The pilot in command and the instructor have 

determined the flight can be conducted safely. (c) No person may operate a civil aircraft in simulated 

instrument flight unless (1) The other control seat is occupied by a safety pilot who possesses at least a 

private pilot certificate with category and class ratings appropriate to the aircraft being flown. (2) The 

safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the 

aircraft adequately supplements the vision of the safety pilot; and (3) Except in the case of lighter- than-air 

aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight 

may be conducted in a single-engine airplane, equipped with a single, functioning, throw over control 

wheel, in place of fixed, dual controls of the elevator and ailerons, when (i) The safety pilot has determined 

that the flight can be conducted safely; and (ii) The person manipulating the controls has at least a private 

pilot certificate with appropriate category and class ratings. (d) No person may operate a civil aircraft that 

is being used for a flight test for an airline transport pilot certificate or a class or type rating on that 

certificate, or for a part 121 proficiency flight test, unless the pilot seated at the controls, other than the 

pilot being checked, is fully qualified to act as pilot in command of the aircraft". Again, Except when 

necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) 

Anywhere. Never exceeding an altitude where an emergency landing without any hazard to persons or 

property on the surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or 

over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 50Q feet 

above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not 

be operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered 

parachutes, and weight-shi8-control aircra8. If the operation is conducted without hazard to persons or 

property on the surface- (1) A helicopter may be operated at less than the minimums prescribed 
In paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any 

routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A powered parachute or 

weight-shift-control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this 

section (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating-(1) Below 18,000 feet 

MSL, to-(i) The current reported altimeter setting of a station along the route and within 100 nautical miles 

of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the 

current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not 

equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available 

before depam re; or (2) At or above 18,000 feet MSL, to 29.92" Hg. (b) The lowest usable flight level is 

determined by the atmospheric pressure in the area of operation as shown in the following table: 

Aerial Experts believes that there is inconclusive evidence that a person with a private pilot certificate or 

license can successfully maneuver or train someone to use an sUAS without first hand flight experience 

with the particular sUAS. Flying in ard person orientation requires built-up experience in that form of flying 

for many years. Therefore, we believe our own flight training, pilot protocols and first hand experiences 

with the sUAS as laid out in our Flight Operations Manual meets and exceeds the requirements necessary 

to safely operate our sUAS for the tasks we purpose. Also, the sUAS will be operated by a remote control, 

which will only require a single person operator and dual controls will not be necessary. 

14 C.F.R. 91.119- Minimum safe altitudes: General 

Aerial Experts seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe altitudes. As this 

exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up 

to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption 

may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the 

Manual, the UAS will never operate at higher than 400 AGL. It will however be operated in a restricted area 

with security perimeter, where buildings and people will not be exposed to operations without their preobtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the 

location where it is operated. No flight will be taken without the permission of the property owner or local 

officials. Because of the advance notice to the property owner and participants in the filming activity, all 

affected individuals will be aware of the planned flight operations as set forth in the Manual. Compared to 

flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs. proposed herein 

and the lack of flammable fuel, any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or below 500 AGL in the movie industry. In addition, the 

low-altitude operations of the sUAS will ensure separation between these small- UAS operations and the 

operations of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions 

Aerial Experts seeks exemption from 14 C.F.R. 91.151, which discusses fuel requirements for flight in 

VFR conditions. Specifically, 91.151 states "(a) No person may begin a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first 

point of intended landing and, assuming normal cruising speed- (1) During the day, to fly after that for at 

least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. (b) No person may begin a flight in 

a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after 

that for at least 20 minutes". 

Aerial Experts sUAS has a typical mission time of less than 15 minutes with maximum flight time of 25 

minutes. Since this amount less than the 30-minute reserve minimum, this reserve minimum would not 

even make sense in allowing the sUAS a chance to fly. According to Aerial Experts aircraft flight manual, 
the PIC is instructed to maintain flight until battery power reaches 25%, or lst level warning. At this level, 

landing procedures will be initiated. Once the sUAS reads 20%, 2nd level warning, the flight control system 

automatically`take over and initiates safe landing sequence at the logged in takeoff point. Aerial Experts 

policy outlined in our Flight Operations Manual achieves satisfactory safety standards. 

Aerial Experts believes that an appropriate and current airworthiness certificate would not be necessary to 

fly a sUAS given the size of the aircraft and the necessary level of skill needed to operate the aircraft. 

Before putting in to service, each of our sUAS goes through our own airworthiness procedures of minimum 

test flight and reliability checks. Also, our sUAS are recalibrated each at the site location before each flight 

to ensure that all systems functions as designed. Aerial Experts seeks exemption from this regulation 

because we believe this rule was not meant for a sUAS and operators. 

14 C.F.R. 91.405, 91.407, 91.409, and 91.417 

Aerial Experts seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 91.417, which discusses 

required aircraft maintenance, operation after maintenance, preventive maintenance, rebuilding, or 

alteration, inspections, and maintenance records. In Aerial Experts aircraft flight manual, maintenance and 

inspection procedures have been established for the aircraft. Aerial Experts believes these regulations are 

meant for manned operated aircrafts and not unmanned systems, therefore making them unnecessary. 

Nevertheless, we seek an exemption from any such specific provisions to the extent FAA finds it necessary 

to grant this request. 

(d) The reasons why granting Aerial Experts request would be in the public interest; that is, how it would 

benefit the public as a whole. 

Aerial Experts is classified as an engineering company by the U.S. Deparhnent of Transportation and 

provides services to aerial support for commercial interest. Aerial Experts use of a sUAS can assist in 

making task safer and minimize human exposure to being at dangerous elevations. Aerial Experts sUAS 

usage in the aerial photography and cinematography will also reduce the time required to capture the 

needed scenes as compared to convention helicopters or airplanes. Ultimately, the result is quick 

completion of task a reduction of dangerous elevation perspective needs. 

(e) The reasons why granting the exemption would not adversely affect safety, or how the exemption would 

provide a level of safety at least equal to that provided by the rule from which Aerial Experts seeks 

exemption Our Engineering deparhnent will provide a level of safety that exceeds the level of safety 

required by the FAA for its use on sUAS. The following are Aerial Experts safety procedures, features, 

regulations, and operating specifications for our sUAS: 

• Our Squadron Leader/Chief Pilot in Charge is an engineer who has 10 years of RC Model building 

and flight experience with over 1000 flight hours in Fixed-wing, Helicopter and Multi-Rotor 3rd 

person flight. He has been involved with flight design, experimentation and system optimization 

for model industry since 2008 though SAPAC, Inc. models. 

• Our staff includes an FAA-rated commercial flight instructor (ret) who coordinates our FOVO 

team in integration with general aviation. 

• The Pilot In Command (PIC) and Field Operations Visual Observer (FOVO) will be required to 

wear hard hats, safety vests, and safety glasses to protect the head and eyes from potential mishaps 

during given operational flights including training or testing of sUAS. 

• The flight area of the sUAS will be observed for best take off and landing locations. Desired 

conditions include: flat and level surfaces clear of debris, at least 15ft from power lines and 

structures, and a minimum distance of 12ft from the PIC and observers. 

• The sUAS will also be in the Visual Line of Sight (VLOS) to both the PIC and FOVO during all 

flights. 

• Flights must take place during good weather conditions with no rain, low laying clouds, or heavy 

winds. All flights will take place during daylight hours with no evening or late night flights. 
• The PIC(s) of the sUAS will at least have 12 training hours or 24 flights accrued before being 

designated working flights. 

• All batteries must be charged completely before each flight and each flight must end when the 

battery has a 30% power level remaining. 

• A visual safety inspection will occur before each flight, testing propeller tightness, security mount 

of camera/detection equipment, remote range test, and proper safety equipment is adomed to PIC 

and FOVO. 

• The sUAS will be flown under a height of 500 ft. AGL. 

• No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity during a critical 

phase of flight so as to ensure that the sUAS is in a condition for safe flight operation and in a 

configuration appropriate for the purpose of the intended flight. 

• If there is more than just an operator at a site during a flight, the PIC operator and observer or 

FOVO will maintain two-way communication with each other during all operations; if unable to 

maintain two-way communications, or if any condition occurs that may otherwise cause the 

operation to be unsafe, the operator will immediately conclude the operation. 

• If the communication link is lost, the sUAS will go into fail-safe mode and safely descend to its 

designated home-point location. If the communication link is reconnected during fail-safe mode, 

control of the sUAS can be regained before landing occurs at the home-point location. 

• There is no fuel or payload to the sUAS, therefore there will be no potential explosives or risk of 

explosion if a crash occurs with the sUAS. 

• The sUAS will feature a built in compass that will be recalibrated at every site to maintain 

accurate directional readings. The compass will also help in keeping the sUAS stable during 

flights. 

• The sUAS will record GPS location data once Ready to fly status has been obtained. A minimum 

of 6 satellites will activate the Ready to fly status. 

• The weight ofthe sUAS is less than 20 ]bs. 

• The aircrafts vertical and horizontal aspect concerning hovering accuracy is less than 0.5m and 

1.5m respectfully. With a maximum wind resistance of 18mph. 

• The typical aircraft wheelbase will be less than 1 OOOmm in length. 

• The aircraft runs off a Li-Po battery. 

(fl A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The rule from which 

you seek the exemption; and (2) A brief description of the nature of the exemption you seek 

Petitioner: Aerial Experts, LLC. 

Sections of 14 C.F.R. Affected: 21 Subpart H; 45:23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 

91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. 21 

Subpart H; 45 .23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 

91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 to Cinematographic filming subject to 

operating procedures that meet or exceed those that FAA requires. 

(g) Any additional infotmation, views or arguments available to support your request Please see 

the introduction to this exemption request. 

(h) If you want to exercise the privileges of your exemption outside of the United States, the 

reason why you need to do so 

The Operations described in this exemption request will be conducted wholly within the United 

States. 
Please do not hesitate to contact me via email at derricknevot@yahoo.com if you have any 

questions. 

Sincerely 

Derrick M. Nevot, President 

Aerial Experts, LLC 

7350 S.W. 21't Street 

Miami, FL. 33155 

786.326.6414