425 Aerials, LLC 

Erik Petersen 

2333 122nd Place Southeast 

Everett, WA 98208

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act. 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act, 425 Aerials, LLC, 

operator of an Unmanned Aircraft Systems (UAS), hereby applies for an exemption from the 

listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS, 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.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) 

and sensors, would operate in the following manner: 

• Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities. 

• Aerial video and/or photography for public and/or private use including television, 

public events, cinematography and news gathering. 

• Aerial inspection/photography of residential/commercial structures under contract 

with the owners or local government authority. 

• Aerial inspection/photography of residential/commercial utility infrastructure including 

but not limited to electrical power lines, wind turbines and cell towers. 

• Aerial video/photography or providing live video feed to assist with search and 

rescue operations in cases of an emergency or natural disaster only when the local 

authorities or government has requested it by contract or donation. 

• The ability to offer training to persons individually or belonging to both private and/or 

public organizations that have interests in the use and application of a UAS for the 

purpose of the safe operation of a UAS to enhance the safety of the National 

Airspace System (NAS) as well as for the protection of the persons and property. 

As described fully below, the requested exemption would permit the operation of a UAS 

under controlled conditions in the NAS that would be a) limited b) controlled c) 

predetermined and d) will provide safety enhancements to the already safe operations in 

the 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.” 
The name and address of the applicant is: 

425 Aerials, LLC 

Erik Petersen, Owner/Member 

Ph: 425-420-7715 

Email: erik@425aerials.com

Address: 2333 122nd Place Southeast, Everett, WA 98208

UAS:

DJI Inspire 1: SN 0410039050

DJI Inspire 1: SN 0410049973

An authorized pilot will operate each of the two DJI Inspire 1’s, Model T600, with a total 

weight of 2935g or 6.47lbs. The dimensions are 438mm x 451mm x 301mm or 17.24inch x 

17.75inch x 11.85inch. Under still air the maximum speed is no more than 22m/s or 49mph 

with a cruising speed of 11m/s or 25mph. The DJI Inspire 1 has the ability to hover and 

move along a vertical and horizontal plane simultaneously. The DJI Inspire 1 has four 

motors, Motor Model DJI 3510, powered by a 6-cell 4500mAh or 5700mAh Lithium Polymer 

battery. There are four propellers, Propeller Model DJI 1345, in use. The DJI Inspire 1 will 

be controlled with the C1 remote controller with an operating frequency of 2.400GHz –

2.483GHz. The live video feed will have an operating frequency of 5.728GHz –5.850GHz. 

The applicant will operate the UAS in line of sight within a closed off and predetermined 

area owned and/operated by the property representative. Given the small size of the UAS 

and the controlled environment provided the proposed operations will adhere to the Reform 

Act’s safety requirements. The approval of this application presents no national security 

issues. Regarding the level of safety surrounding the proposed operations and the public 

benefit, reduction in environmental impacts, including but not limited to reduced emissions 

and noise, the grant of the requested exemption is in the public interest. Accordingly the 

applicant requests that the FAA grant the requested exemption with minimum delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because 

operations will further enhance the safety of the persons and/or property using conventional 

aircraft. These limitations and conditions to which the applicant agrees to adhere to when 

conducting commercial operations under the FAA issued exemption as set forth in the Flight 

Operations Manual (FOM) include: 

• The UAS will weigh less than 55 lbs.

• The UAS will have a maximum operating speed of no more than 50mph. 

• Flights will be operated within line of sight of the Pilot in Command (PIC) and/or 

Visual Observer (VO).

• Maximum flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve or 30 minutes of flight time whichever 

occurs first.

• Flights will be operated at an altitude of no more than 400 feet Above Ground Level 

(AGL) and not more than 200 feet above an elevated platform from which filming is 

planned.
• Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer 

(VO) and may include but not limited to a Camera Operator.

• The UAS pilot will be a designated Pilot in Command (PIC) and hold a Private, 

Recreational or Sport Pilot’s License along with a Third or higher Class Medical 

Certificate, or state issued driver’s license if the PIC holds a Sport Pilot License. If 

the PIC feels another operator to be qualified with the necessary skills to be PIC & 

possess a Private, Recreational or Private Pilot’s License along with a Third or 

higher Class Medical Certificate, or state issued driver’s license if holding a Sport 

Pilot License, that person may be designated PIC provided they have a minimum of 

20 hours of flight time with the UAS. 

• A briefing will be performed regarding the planned UAS operations prior to each 

day’s flight consisting of all the days’ production activities.

• All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 

• The flights will occur no closer than a 5 mile radius of the geographic center/Airport 

Reference Point (ARP) of a tower controlled or uncontrolled airport without a written 

agreement of the airport manager. The letter of agreement with the airport 

management must be made available to the Administrator or any law enforcement 

official upon request.

• The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate local Flight Standards District Office 

(FSDO) no more than 72 hours but no less than 48 hours from planned operation 

• The operator will obtain verbal/written consent of all persons involved with the 

planned operation and ensure that only consenting persons will be allowed within 

100 feet of the flight operation, and the radius may be reduced to 30 feet based upon 

an equivalent level of safety determination, as required under the FOM. With the 

advanced permission of the FSDO, operations at closer range may be approved. 

• The PIC and VO will have been trained in operation of UAS and receive up-to-date 

information for the particular UAS to be operated.

• The PIC and VO will be able to communicate by voice, radio, and/or text at all times. 

• Written and/or verbal permission and permits will be obtained from territorial, state, 

county or city jurisdictions, including law enforcement, fire or other appropriate 

governmental agencies. 

• If the UAS loses communications with the remote controller or loses GPS signal, the 

UAS will have the capability to return to a pre-determined location within a 

designated location and land autonomously. 

• The UAS will have the capability to abort a flight in case of unpredicted obstacles, 

weather, or emergencies. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for 

the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size 

and limited operating area associated with the aircraft to be utilized by the Applicant, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety 

under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 

U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the 

particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS 
operated without an airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing 

or rotorcraft) operating with an airworthiness certificate without the restrictions and 

conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured and designated area. Unlike other civil aircraft, operations 

under this exemption will be tightly controlled and monitored by both the operator and under 

the requirements and in compliance with local public safety requirements. The FAA will 

have advance notice of all operations. These safety enhancements 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. 

Maintenance will be accomplished by the operator pursuant to the flight manual and 

operating handbook. An equivalent level of safety will be achieved because the UAS is very 

limited in size and will carry a small payload and operate only in restricted areas for a 

limited period of time. If mechanical issues arise the UAS can land immediately and will be 

operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with the aircraft 

and best suited to maintain the aircraft in an airworthy condition to provide the equivalent 

level of safety. 

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the UAS Manufacturer's User Manual. 

As provided in the FOM, the operator will ensure that the UAS is in working order prior to 

initiating flight and perform required maintenance needed. 

About 425 Aerials:

Owner/operator Erik Petersen has built and flown RC model aircraft for over 30 years and is 

currently engaged in obtaining a Private Pilot’s License and is operating under a Class 3 

Medical and Student certificate.

Satisfaction of criteria provided in Section 333 of the Reform Act provide more than 

adequate justification for the grant of the requested exemptions allowing the commercial 

operation of the applicant’s UAS. 

Sincerely, 

Erik James Petersen

425 Aerials, LLC