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Aerial Productions and Imaging, LLC 

118 N. Main St. Cascade ld 83611 

FAA Rulemaking 

Section 333 

Of The 

FAA Reform Act and Part 11 

Prepared by 

Tobie K Olson 

February 6, 2015 

Tobie Olson: (208)634-9229 

Managing Member/Operator/Pilot 

Daniel T. Dunn: (208)634-6896 ;: -I ( 

Managing Member /Professional land SlJ'rveyor (Idaho PI.S14217) 

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February 6, 2015 

Attention: United States Secretary of Transportation 

Mr. Anthony R Foxx 

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 form 14 CFR 45.23{b); 14 CFR Part 21; 14 CFR61.113 (a) and (b); 91.7 (a); 91.9 (b) (2); 91.103 

(b); 91.119; 91.121; 91.151 (a); 91.203 (a) and {b); 91.409 (a) (2); 91.417 (a) and (b) 

Dear Mr. Secretary, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (The Reform Act) and 14 CFR 

Part 11, Aerial Productions and Imaging, LLC. Is the operator of Small Unmanned Aircraft Systems 

(SL!AS) equipped to conduct aerial photography for industrial, construction, private, survey and 

photography, hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to 

allow commercial operation of its SUAS 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 in more detail below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive SUAS under controlled conditions in airspace that is 1) limited 2) 

predetermined 3) would provide safety enhancements to the already safe operations in the industrial, 

construction, private and survey industries presently using conventional and unmanned aircraft. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation'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 . 

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The name and address of the applicant is: 

Aerial Productions and Imaging, LLC. 

Phone: 208-382-5469 

Address: 118 N Main ST. Cascade 10 83611 PO Box 884 

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 {a) 

14 CFR 91.9 (b) (2) 

14 CFR 103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 

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This exemption application is expressly submitted to fulfill congress' goal in passing section 333 (a) 

through (c) of the Reform Act. This 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 SUAS 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 SUAS size, weight, speed, and operational capability 

Operation of the SUAS in close proximity too airports and populated areas 

Operation of the SUAS within Visual line of Sight (VLOS) of the pilot and observers. 

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." ld. §333 (c) 

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

authority by its terms includes exempted civil aircraft, as the term is defined under §40101 of the Act, 

that includes SUAS, 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. §44704; 14 CFR §91.203 (a) (1) 

Applicants interpretation of this provision is the duty of said provision is placed on the Administrator to 

not only process applications for exemptions under section 333, but to also craft conditions herein for 

the safe operation of the SUAS, if it should be determined that the conditions set forth herein do not 

fulfill the statutory requirements for approval. 

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Aerial Productions ~nd Imaging, LLC. SUAS are rotorcraft and fixed-wing aircraft, weighing 55 or fewer 

lbs. including payload. Operations of rotorcraft do not exceed more than 50 knots and are capable of 

hover and movement in vertical and horizontal movements simultaneously. Operations of the fixedwing do not exceed more than 50 knots and have very similar flight characteristics of traditional 

airplanes. Both types of SUAS will be operated only under visual line of sight (VLOS) and will operate 

only within the predetermined area and under predetermined altitudes as described in the Flight 

Operation Manual (FOM) attached as Exhibit (a). Adherence to the FOM will insure that the SUAS will 

"not create a hazard to the national airspace system or the public." 

The small size and weight of the SUAS involved and the predetermined area and altitude that operations 

are conducted will place the applicant within a level of safety congruent with Congress vision that the 

FAA must, by exemption, allow commercial operations of SUAS to commence immediately. Compliance 

of the applicants FOM given size and flight parameters of the SUAS will pose no reason that approval of 

the application presents no national security issue. 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 significant public benefit, including enhanced safety, 

reduction in environmental impacts, including reduced emissions associated with allowing SUAS for 

industrial, construction, private, survey and photography operations, the grant of the requested 

exemptions is in the public's interest. Accordingly, the applicant respectfully requests that the FAA grant 

the requested exemption without delay. 

The Flight Operation Manual is presented as an applicant Confidential document under 14 CFR 11.35 (b) 

as the entire manual contains proprietary methods and information that the applicant has not and will 

not share with others. The manual reflects learned experience, method, operating conditions, and 

procedures that are not available to the public and are protected from release under the Freedom of 

Information Act USC 552 et. seq. Reform Act Section 333 (b) 

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AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

Aerial Productions and Imaging, LLC. Requests exemptions to operate multi-engine quads and plans to 

add a third fixed- wing later in 2015. The applicant proposes that the exemption requested herein apply 

to civil aircraft that have the characteristics and that operate with the limitations listed below. These 

limitations provide for at least an equivalent or even higher level of safety to operations under the 

current FAR's. Furthermore the proposed operations enhance the safety of already safe operations for 

survey and photogrammetry currently conducted in conventional aircraft. 

Current SUAS 

1. DJI Phantom 2 

2. Thrust UAV Freeflight x4 

The Phantom 2 and Freeflight X4 are Quad copters designed to carry a High Definition camera, Infra-Red 

camera, Thermal imager and survey grade Scanners. Powered by four electric motors utilizing an 

internal inertial measuring unit with integrated barometric sensor augmented with GPS to maintain its 

geospatial orientation and position. Primary flight controls are radio controlled (RC) although the usual 

flight mission will be controlled by the ground control station through a PC Laptop. Real time video and 

telemetry information is transmitted back to the ground station allowing the Pilot in Charge 

(PIC)/Observer to monitor battery%, GPS signal strength, altitude, horizontal and vertical distance from 

the ground station and camera imagery. Built in failsafe modes initiate automatically in the event of loss 

of ground to aircraft signal. Altitude limitations will be programmed prior to each mission by the PIC. 

The flight controller/ground station has automatic low battery warnings in the form of automated 

announcements and also vibration warnings in the RC flight controller. The SUAS onboard flight 

controller monitors battery levels and will abort the mission and "return to home" in the event of. low 

battery levels. 

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ALL SUAS operations conducted by Areal Productions and Imaging, LLC will: 

A: Be conducted in accordance with the FOM for Aerial Productions and Imaging, LLC. 

B: SUAS will weigh less than 55 lbs. including the payload SUAS and attachments I.E. camera and 

components 

C: Preflight operations include PIC attaining FAA approved weather briefing, review of current 

sectional chart for the area of operation to preclude operation within 5 miles of an airport with 

surface class E or greater airspace. 

D: Monitor Common Traffic Advisory Frequency (CTAF) or Air Traffic Control (ATC) with the ability 

to communicate with local traffic or ATC with intentions and current locations via handheld 

aviation broadband radio. 

E: Be operated by an FAA certificated airman holding no less than a Private Pilot certificate and no 

less than a 3n:1 class medical. 

F: 

G: 

H: 

1: 

Operate only in visual line of sight (VLOS) of the PIC 

Operate at an altitude of no more than 400 feet above ground level (AGL). 

Operate at speeds of no more than so knots. 

Be operated at a lateral distance of no less than 100 feet from any inhabited structures, 

buildings, vehicles, vessels, or people not associated with the operation or who have not signed 

a waiver in advance of the operation 

J: limit each flight mission to 30 minutes or less. Flights will be terminated at 25% battery power 

reserve or 30 minutes which ever should occur first. 

K: Have the capability to return to the point of departure or a pre-determined .location if the 

SUAS loses RC communications or GPS signal. 

l: Be monitored by the ground station, receiving real time SUAS info (i.e. battery, attitude, 

altitude, coarse heading, GPS location and flight time . 

M: Minimum 2 man crew for each SUAS operation will consist of the PIC and Observer. 

In most cases a third Observer will observe or monitor imaging equipment. 

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• 14 CFR Part 21, subpart H: Airworthiness Certificates 14 CFR §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 Aerial Productions and Imaging, LLC 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 capability, and proximity to airports and 

populated areas of the particular (UAS). In all cases, an analysis of these criteria demonstrates that the 

SUAS 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 operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

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

tightly controlled and monitored by both the PIC and Observers. These safety enhancements, which 

already apply to civil aircraft operated in the industrial, construction, private, survey and photography, 

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

• 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 SUAS 

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 . 

• 14 CFR §45.23 (b): Marking of the Aircraft 

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The regulation requires 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, hi letters not less than 2 inches not more than 6 inches high, the words "limited, 

restricted, light-sport, experimental, or provisional", as applicable. 

The SUAS will have no airworthiness certificate, and exemption may be needed as the SUAS will have no 

entrance to the cabin, cockpit or pilot station on which the word "Experimentar' can be placed. Given 

the size of the SUAS, two-inch lettering will be impossible. The Word "Experimental" will be placed on 

the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the SUAS marked on its fuselage as required by 

§ 45.29 (f} where the pilot, Spotter (Observer) and others working with the SUAS will see the 

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

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

14 CFR §61.113 (a) & {b): Private Pilot Privileges and limitations- PIC 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Given the SUAS will not 

carry a pilot or passenger, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have a private pilot's license rather than a 

commercial pilot's license to operate this SUAS. Unlike a conventional aircraft that carries the pilot and 

passengers, the SUAS is remotely controlled with no living thing on board. The area of operation is 

controlled and all flights are planned and coordinated in advance as set forth in the FOM. The level of 

safety provided by the requirements included in the FOM exceeds that of a single individual holding a 

c~mmercial pilot's certificate operating a conventional aircraft. The risks associated with commercial 

operations contemplated by Part 61 when drafted, that allowing operations of the SUAS as requested 

with a private pilot as the PIC exceeds the present level of safety achieved by 14 CFR 

§61.113 (a) & (b) . 

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• 14 CFR §91.7 (a): Civil Aircraft Airworthiness 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA FAR will exist for detennining airworthiness. Given the size of the aircraft and the requirements 

contained in the Manual for maintenance and the use of safety check lists prior to each flight, an 

equivalent level of safety will be provided. 

14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft 

Section 91.9 (b) (2): 

No person may operate a U.S.-registered civil aircraft. ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. 

• Given the size and configuration of the SUAS they are incapable of carrying a flight manual, there is no 

room, capacity or pilot on board the aircraft. 

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The equivalent level of safety will be maintained by keeping the FOM at the ground station for the, PIC 

or the Observer to access immediately. The FAA has issued the following exemptions to this regulation: 

Exemption Nos.8607, 8737,8738,9299, 9299A, 9565,95658, 10167A, 10602, 32827, and 10700 

14 CFR §91.103: Preflight Action 

This regulation required each pilot in command to take certain actions before flight to insure the safety 

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption 

will be needed. An equivalent level of safety will be provided as required in Aerial Productions and 

Imaging, LLC FOM. The PIC will take all actions including reviewing weather, battery requirements, 

landing and takeoff perfonnance before initiating flight missions . 

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14 CFR §91.109: flight Instruction 

Section 91.103 states that no person may operate a civil aircraft (except a manned free balloon) that is 

used for flight instruction unless that aircraft has fully functioning dual controls. SUAS is flown through 

the use of a control box that communicates with the aircraft via RC, by design these aircraft do not have 

fully functional duel controls. The FAA has approved exemptions for flight training for aircraft without 

fully functional dual controls, (experimental) such as Nos. 5778K and 9862A. Furthermore Aerial 

Productions and Imaging, l~C has a training program in the FOM provided. This will provide at minimum 

the equivalent level of safety. 

14 CFR §91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation Qf civil aircraft. Section (b)" .... Except when 

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

(b) Over other than congested areas. An altitude of 500 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) Allows helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by to FAA. 

Due to the Applicants request to operate at altitudes up to but not exceeding 400 AGL, an exemption is 

needed. Furthermore Aerial Production and Imaging, llC FOM addresses the SUAS will never operate 

higher than 400 feet AGL It will however be operated in areas where buildings and people will be 

exposed to operations only after consent is signed and owners permissions are obtained. 

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

location. No flight will be taken without the permission of the property owner or local officials. 

Compared to conventic~mal aircraft weight, flammable fuel load, and speed, the SUAS prove to be as safe 

or safer. In addition the low-altitude operations of the SUAS will ensure separation between these 

operations and those of conventional aircraft that must comply with Section 91.119 . 

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14 CFR §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 SUAS may not have a barometric altimeter, it utilizes GPS altitude 

readout, an exemption may be needed. An equivalent level of safety will be achieved by the PIC as the 

FOM states. Confirming the altitude of the launch site shown on the GPS altitude indicator before each 

flight will be an essential part of every mission. 

14 CFR §91.151 (a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "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. 

The battery powering the SUAS provide approximately 30-40 minutes of flight. To meet the 30 minute 

reserve requirement in 14 CFR §91.151, SUAS flights would be limited to at most 10 minutes. Given the 

limitations on the SUAS 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. 

Aerial Productions and Imaging, LLC. Believes that an exemption from 14 CFR §91.151 (a) falls within the 

scope of prior exemptions. Exemption 10673 allowing lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a). Operating the SUAS in a small controlled area where only people and 

property owners or official representatives who have signed waivers will be allowed, with 30 minute or 

less flight reserve, does not engender the type of risks that section 91.151 (a) was intended to alleviate 

given the size and speed of the SUAS. Furthermore limiting flights to 10 minutes would greatly reduce 

the utility for which the exemption will be granted. 

The Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes 

or 25% of battery power whichever happens first. This restriction would be more than adequate for 

return of the SUAS to its predetermined landing zone. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 

and 10808. 

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14 CFR §91.203 (a} & (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent 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 

(b) 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 SUAS fully loaded weighs no more than 55 lbs. and is operated without an onboard Pilot. There is no 

ability or place to carry certification· of registration documents or to display them on the SUAS. 

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

where the PIC will have immediate access to them, to the extent they are applicable to the SUAS. The 

FAA has issued numerous exemptions to this regulation including Nos. 9565, 9665, 9789, 9789A, 9797, 

9797 A, 9816A and 10700. 

14 CFR §91.405 (a); 407 (a) & (b): Maintenance Inspections 

Regulations require that an aircraft operator or owne.r "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 ..... n 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 the applicant. Maintenance will be accomplished by the operator pursuant to 

the FOM. An equivalent level of safety will be achieved because these SUAS art: limited in size and will 

carry a small payload and operate only in predetermine areas for not more than 30 minutes. If 

mechanical issues arise the SUAS can land immediately. Additionally the Preflight x4 is equipped with 

the SUAS equivalent to the ballistic para-chute; it automatically deploys with any electrical failure or can 

be deployed via RC controller by the PIC at any time. SUAS will be operated from no higher than 400 feet 

AGL. The PIC as stated in the FOM will conduct visual and control checks in the preflight operations to 

ensure the SUAS is in working order prior to all missions to confirm whether any maintenance is needed 

and furthermore will document and log any and all maintenance done as well as all flight hours. In 

addition the {PIC) is the most familiar person with the aircraft and best suited to maintain the aircraft in 

an airworthy condition to provide the equivalent level of safety: 

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Pursuant to 14 CFR Part 11, the following summary is provided to publication in the Federal Register, 

should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14 CFR §21, subpart H; 14 CFR § 45.23 (b); 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) and 91.417 

(a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or tess) in industrial, construction, 

private, survey and photography operations. 

Privacy 

All flights will occur over private or controlled areas with the property owner's prior consent and 

knowledge. Image capture of people will rarely take place; in the event they are, they will have 

consented prior to being filmed or otherwise have agreed to be in the area where data collection will 

take place. 

API's primary focus is to utilize SUAS in assisting the survey community for the purpose of aerial 

photogrammetry, topographic survey, volumetric survey, 30 modeling and general aerial photography. 

Given the high cost, environmental impact, dose proximity to people, structures, and vessels, the weight 

(average 4000 lbs.) of conventional aircraft that are currently safely preforming these same types of 

missions the applicant believes with the grant of requested exemptions API can offer a more cost 

effective (to the consumer), more environmentally friendly (with no combustible fuel), controlled 

predetermine area, and weighing 55lbs or less (compared to several thousand lbs.) an equally and likely 

a safer option that is in the public's best interests and benefits . 

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Summary: 

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 Aerial Production and Imaging, LLC SUAS in the industrial, 

construction, private, survey and photography industry's pursuant to the FOM attached hereto. Aerial 

Productions and Imaging, llC is eagerly standing by to support the FAA and SUAS community in its quest 

to establish proper regul~tions and protocols for the safe introduction of unmanned aircraft into the 

national airspace. 

Sincerely, 

• Tobie K. Olson 

Managing member 

Aerial Productions and Imaging, LLC. 

J • D-----------

Daniel T. Dunn 

Managing member 

Aerial Productions and Imaging, LLC. 

Page 14 February 18, 2015