June 20, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Dear Sir or Madam

Attached please find Arkansas Aerials LLC’s (“Arkansas Aerials”) request for an 

exemption from the listed Federal Aviation Regulations to allow commercial operation 

of its Small Unmanned Aircraft Systems, hereby referred to as “UAS”. Arkansas Aerials 

LLC requests to operate an unmanned aircraft system (UAS) to conduct aerial image 

acquisition for Aerial Data, including but not limited to, the following industries: motion 

picture and television, real estate, short range inspection, mapping and survey, 

agriculture, and search and rescue. 

This exemption request is for the use of UAS manufactured by Arkansas Aerials LLC 

(USA), and Foxtech FPV. (CHINA).

Also attached to this letter is Arkansas Aerials Operations Manual (“Manual”), which is 

the product of a collaborated effort with a proprietary copywriter. This flight manual 

outlines the operating requirement, limitations, and technical specifications for 

Arkansas Aerials Systems. Applicant submits this Manual as proprietary information 

pursuant to 14 CFR 11.35 (b). 

The Manual contains operating conditions and procedures that are not available to the 

public and are protected from release under the Freedom of Information Act 5 USC 552 

et. Seq.

Thank you for your time and consideration, and please let me know if you have any 

questions

Sincerely,

Robert L Davis

Owner

Arkansas Aerials LLC
June 20, 2015

U. S. Department 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 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and 14 C.F.R. Part 11, Arkansas Aerials LLC ("Arkansas Aerials"), a video production 

company, hereby applies for an exemption from the listed Federal Aviation Regulations 

("FARs") to allow commercial operation of its Small Unmanned Aircraft Systems ("UAS") 

for aerial imaging for the purpose of aerial photography and videography of real estate, 

personal property, commercial production, agriculture and construction sites, 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 detailed in this document and the attached Flight Manual, the requested exemption 

would permit the operation of UAS under controlled conditions in airspace that is 

1) limited 

2) predetermined 

3) controlled as to access and 

4) would provide safety enhancements to the already best practices safety protocols 

followed by Arkansas Aerials at each one of its filming location sites. 

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.

The name and address of the applicant is:

Arkansas Aerials LLC

Robert L Davis 

PH: 501-607-3893

Email: Robert@arkansasaerials.com

Address: 1814 Calgary Trail, Little Rock, Arkansas 72211
Regulations from which the exemption is requested:

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and

(b), to the extent necessary to allow the petitioner to operate a UAS to perform Aerial 

Data collection and closed set motion picture and filming. 

I. STATUTORY AUTHORITY FOR EXEMPTIONS

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

statutory authority includes exempting civil aircraft, as the term is defined under

§40101 of the Act, including UAS, 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 finds the exemption in the public interest. 49 U.S.C. §44701(f) 

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

Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may 

operate in the National Airspace System (NAS) without creating a hazard to the user, the 

public, or a threat to national security. In making this determination, the Secretary must 

consider:

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

• Whether the UAS operates within the visual line of sight of the operator

• Whether the UAS operates outside of highly populated areas and away from close 

proximity to airports

Reform Act §333(a).

If the Secretary determines that a UAS "may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe 2 operation of 

such aircraft in the national airspace system." 

Id. §333(c). Arkansas Aerials LLC’s UAS are multirotor vehicles, weighing 55 or fewer lbs. 

including pay load. They operate under normal conditions at a speed of no more than 87

knots and have the capability to hover, and move in the vertical and horizontal plane 

simultaneously. The UAS will operate only in the pilot's visual line of sight at all times 

and will operate only within the sterile area. Given the small size of Arkansas Aerials 

LLC's UASs and the restricted secure environment within which they will operate, our 

application falls squarely within the zone of safety (an equivalent level of safety) in 

which Congress envisioned that the FAA must, by exemption, allow commercial 

operations of UAS to commence immediately, Also due to the small size of the UAS and 

the low altitudes and restricted areas in which our UAS will operate, approval of the 

application presents no national security issue. 
Given the clear direction in Section 333 of the Reform Act, the authority contained in 

the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding 

the proposed operations, and the significant public benefit, including enhanced safety, 

the grant of the requested exemptions is in the public interest. Accordingly, Arkansas 

Aerials LLC respectfully requests that the FAA grant the requested exemption without 

delay. 

II. PUBLIC INTEREST

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

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate 

safely in the NAS before completion of the rulemaking required under Section 332 of 

the Reform Act. By granting an exemption the FAA will fulfill Congress's intent of 

allowing UAS to operate with significant safety precautions in low risk environments.

Due to the size of the UASs, permission from relevant property owners or other 

applicable parties, and the limited areas in which they will operate, provides a

substantial level of safety surrounding the proposed operations. UAS operation is of 

significant public benefit (enhanced safety), reduction in environmental impacts 

(reduced emissions and noise), and the grant of the requested exemption is in the public 

interest. Additionally, UAS could replace the use of helicopters and small aircraft to 

collect Aerial Data. The UASs we propose to fly in this application are less than 55

pounds, and carry no combustible material on board, as opposed to the much larger 

conventionally powered small aircraft. Shifting to UAS from helicopters presents a 

marked safety increase for our workers and the public.

UAS reduce the environmental impact by dramatically decreasing the energy used for 

Aerial Data over a site. Because of the advance notice to the property owner and any 

onsite personnel as outlined in the Manual, all affected individuals will be aware of the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the maximum 55 lbs. proposed herein and carrying flammable 

fuel, any risk associated with our operations is far less than those presently presented 

with helicopters and other conventional aircraft operating at or below 500 AGL.

In addition, the low-altitude operations of the UAS 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. 91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set "...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the UAS may not have a
barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the Manual 

and Safety Check list, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight.

14 CFR 91.151 

(a): Fuel requirements for flight in VFR conditions

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. 

Our UAS is limited to operations in sterile and controlled environments as outlined in 

the Manual, and has a limited range and flight time which require an exemption from 14 

CFR §91.151.

CFR 91.151(a).

The battery(s) powering the UAS provides approximately 18 minutes of powered flight. 

To meet the 18-minute reserve requirement in 14 CFR §91.151, UAS flights would be 

limited to approximately 5 minutes in length. Given the limitations on the UAS's 

proposed flight area and the location of its proposed operations within a predetermined 

area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

Arkansas Aerials LLC believes that an exemption from 14 CFR §91.151(a) falls within the 

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin 

Corporation to operate without compliance with FAR 91.151 (a)). Operating the small 

UAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of 

reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the small UAS. Additionally, limiting UAS flights to 

5 minutes would greatly reduce the utility for which the exemption will be granted.

An equivalent level of safety can be achieved by limiting flights to 30 minutes, or enough 

battery reserve to ensure that the UAS lands at the ground station with at least 20% of 

battery power (as determined by the onboard monitoring system and the pilot), 

whichever happens first. This restriction would be more than adequate to return the 

UAS to its planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745,10673, and 10808.14 

CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration

The regulation provides in part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following:

(1) An appropriate and current airworthiness certificate. ...

(b) No person may operate a civil aircraft unless the airworthiness certificate required 

by paragraph (a) of this section or a special flight authorization 
issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew. The UAS’s fully loaded weigh no more than 55 lbs and operate

without an onboard pilot. 

Therefore there is no ability or place to carry certification and registration documents or 

to display them on the UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground 

flight control point where the pilot flying the UAS will have immediate access to them, 

to the extent they are applicable to the UAS. The FAA has issued numerous exemptions 

to this regulation. A representative sample of other exceptions includes Exemption Nos. 

9565,9665,9789,9789A, 9797,9797A, 9816A, and 10700.

14 CFR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections

These regulations require that an aircraft operator or owner "shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter...," and others shall inspect or maintain the aircraft 

in compliance with Part 43. Given that these section and Part 43 apply only to aircraft 

with an airworthiness certificate, these sections will not apply to Arkansas Aerials LLC. 

Maintenance will be accomplished by the operator pursuant to the flight manual. An 

equivalent level of safety will be achieved because these small UAS’s are very limited in 

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

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

operating from no higher than 400 feet AGL. As provided in the Manual, 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.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules: 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and

(b), to the extent necessary to allow the petitioner to operate a UAS to perform Aerial 

Data collection and closed set motion picture and filming. 
Approval of exemptions allowing commercial operations of UAS enhances safety while 

reducing risk. Manned aircraft collecting Aerial Data creates a greater risk because the 

craft are much larger, have combustible fuel, and carry an onboard human pilot. In 

contrast, a UAS weighing fewer than 55 lbs. and powered by lithium batteries eliminates 

virtually all of that risk given the reduced mass and lack of combustible fuel carried on 

board. The UAS will carry no passengers or crew and, therefore, will not expose them to 

the risks associated with manned aircraft flights.

The operation of small UASs, weighting less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight aircraft 

operate at slow speeds, close to the ground, and in a sterile environment and, as a 

result, are far safer than conventional operations conducted with turbine helicopters 

operating in close proximity to the ground and people.

Privacy

Flights will occur over private or controlled access property, with the property owner's 

prior consent and knowledge. Flights may be conducted over public property by utilizing 

the FAA “B4UFLY” App (see: https://www.faa.gov/uas/b4ufly/). Public images taken will 

be of individuals who have also consented to being filmed or otherwise have agreed to 

be in the area where aerial photography will take place.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012—size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation 

of applicant's UAS’s pursuant to the Manual appended hereto.

Sincerely,

Robert L Davis

Owner

Arkansas Aerials LLC