AerialWorks Imaging

August 19, 2015 Page 1 of 10

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Re: Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the 

Federal Aviation Regulations, Seeking Exemption from:

14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

14 C.F.R. Part 27 - Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. § 91.7(a) – Civil Aircraft Airworthiness

14 CFR 91.203(a) & (b) – Civil Aircraft: Certifications required.

14 C.F.R. § 91.9(c), 45.23(b), 45.27(a) – Aircraft Marking and Identification Requirements.

14 C.F.R. §§ 61.113(a) and (b) – Private Pilot Privileges and Limitations

14 C.F.R. § 91.9 – Civil Aircraft Flight Manual, Marking, and Placard Requirements.

14 C.F.R. § 91.109(a) – Flight Instruction

14 C.F.R. § 91.119 – Minimum Safe Altitudes

14 C.F.R. § 91.121 – Altimeter Settings

14 C.F.R. § 91.151(a) – Fuel Requirements for Flight in VFR Conditions.

14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 

91.417(a) and (b) – Maintenance, Preventive Maintenance, and Alterations

AERIALWORKS IMAGING specifically proposes to conduct survey and aerial 

data collection for real estate and various industries (not to include closed-set 

motion picture filming) with UASs including the DJI Phantom and Inspire 

series rotorcraft.

Dear Sir or Madam:

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

AerialWorks Imaging (the operator), Elliot Rivera (the applicant), planned operator of Small 

Unmanned Aircraft Systems (sUAS) equipped to conduct survey and aerial data collection for 

real estate and various industries (not to include closed set movie filming), hereby applies for an 

exemption from Federal Aviation Regulations (FARs) to allow commercial operation of their 

UASs, 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.

This requested exemption follows the language of exemptions Pursuant to Section 333 that have 

previously been approved by the FAA.

As described more fully below, the requested exemption would permit the operation of UASs by 

the applicant for commercial use that would provide the following benefits:

1. Operations would be performed in an area of operation (designated prior to flight) limited in 

size suitable to the specific use.

2. The flight would be planned in advance to minimize hazards to persons and property in the 

air and on the ground.

3. The operator would reasonably limit or control access to provide safety to those not involved 

in the operation.
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August 19, 2015 Page 2 of 10

4. Operation of a sUAS would provide significant safety, environmental and other 

enhancements not possible by larger sized aircraft.

5. An FAA licensed airman with a Private grade or higher pilot certificate would operate the 

sUAS or an FAA licensed airman with a Commercial grade or higher pilot certificate would 

directly supervise the operation (as per Exemption No. 11157).

6. Provide a beneficial and currently unavailable service to government organizations and the 

general public that would serve the public interest.

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.

It is possible to operate UASs so to not create a hazard to users of the National Airspace System 

(NAS), the public or pose a threat to national security if done so safely and responsibly. The 

applicant has demonstrated their willingness to act safely and responsibly by not engaging in 

commercial sUAS operations. The applicant currently holds an FAA Rotorcraft Helicopter 

Commercial Pilot Certificate (Cert. # 3072198) and a current FAA Rotorcraft Helicopter Flight 

Instructor Certificate with Instrument Rating. This demonstrates that the applicant has a high 

regard to safe operations, as well as a necessary high-level understanding of the NAS and FARs. 

The experience these FAA certificates represent, serves to add significantly to the level of safety 

in any operation performed by the applicant or the applicant’s employees.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics of sUAS and that operate with the limitations listed herein. These limitations 

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

regulatory structure as the proposed operations represent a safety enhancement to the already 

safe aerial commercial photography and survey operations conducted with conventional aircraft.

The UASs planned to be operated are rotorcraft, each weighing 55 or fewer pounds including 

payload. They would operate, under normal conditions, at a speed of no more than 87 knots. 

Operations will be performed by a qualified sUAS PIC, as outlined below, to insure that the 

sUAS will “not create a hazard to users of the national airspace system or the public.” Given the 

small size of the UASs involved and the pre-planned environment within which they will 

operate, the applicant believes that these operations fall squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UASs to commence immediately. Also, operation in a researched (to 

include applicable NOTAMs), pre-defined area will prevent the possibility of a national security 

issue. The operation of UASs by knowledgeable professionals with experience in the NAS will 

serve to enhance safety, add to the public benefit and reduce environmental impacts related to 

current methods of aerial photography and survey.

Listed below are the limitations and conditions to which the operator, or its employees, acting as

sUAS PIC agrees to be bound when conducting commercial operations under an FAA

issued exemption:
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August 19, 2015 Page 3 of 10

1. Safety will be the first and foremost consideration in any sUAS operation.

2. The sUAS pilot will be an FAA licensed airman with at least a Private Pilot

certificate or the sUAS pilot will be directly supervised by an FAA licensed airman

with at least a Commercial Pilot certificate (as per Exemption No. 11157).

3. The sUAS FAA licensed airman will be considered Pilot in Command (PIC),

whether flying or supervising, and will be responsible for safe operation of the

flight.

4. Flights will be operated within visual line of sight (VLOS) of the PIC and visual 

observer (VO).

5. The sUAS will weigh less than 55 lbs total.

6. Flights will be operated in Class G airspace whenever possible. If operation in

other airspace is required, the relevant controlling agency will be notified at least

24 hours prior to the operation and, if required, any necessary permission

obtained.

7. Flights will be operated under visibility and cloud clearance requirements

equivalent to Visual Flight Rules (VFR).

8. The sUAS will at all times give way to any aircraft carrying persons.

9. Minimum crew for each operation will consist of the sUAS PIC and visual observer 

(VO). The observer and PIC will at all times be able to communicate by voice.

10. Prior to a sUAS flight, an area of operation will be established. This area of

operation will include a defined lateral and vertical area, where the sUAS will

operate. Safety procedures will be established for persons, property and

applicable airspace within the area of operation.

11. Flight planning will include flight completion with at least 20% battery power 

remaining as measured by the sUAS or appropriate timing.

12. The sUAS aircraft used will utilize GPS navigation, failsafe, return-to-home (RTH) 

and/or flight abort safety features.

13. A briefing will be conducted in regard to the planned sUAS operations prior to 

operation at each new location. All personnel who will be performing duties within the 

boundaries of the area of operation will be present for this briefing.

14. All required permissions and permits will be obtained from appropriate state, county 

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

governmental agencies.

15. Written (to include electronic, and/or oral) permission from the relevant property 

owners will be obtained prior to an operation.

16. The sUAS pilot will be trained in advance for the safe operation of the sUAS to be 

operated. This training will include a minimum of 100 takeoff/landing cycles, 25 hours of 

total time as a UAS rotorcraft pilot and at least 10 hours logged as a sUAS pilot with a 

similar sUAS type. Prior to operations the PIC will have accumulated and logged a 

minimum of 5 hours as sUAS pilot operating the make and model of sUAS as well as 3 

takeoffs and landings in the proceeding 90 days. Specific training will include normal and 

emergency modes of operation and will include familiarization with the operation manual 

published by the sUAS manufacturer. Training will also include types of maneuvers to be 

performed during operations including safe operation in relation to persons, property and 

applicable airspace.
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17.The sUAS PIC will establish a working relationship with a representative at the local 

FSDO with which to annually review safety procedures and other operations to further 

enhance safety.

18. Prior to each flight, the PIC will inspect the sUAS to ensure it is in a condition for 

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

sUAS, the sUAS will not be operated until the necessary maintenance has been 

performed and the sUAS 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.

19. Any sUAS that has undergone maintenance or alterations that affect the sUAS 

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.

20. The pre-flight inspection section in the operating documents will account for all 

potential discrepancies, e.g. inoperable components, items, or equipment, not already 

covered in the relevant sections of the operating documents.

21. The operator will follow the sUAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements.

22. The operator will carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts will be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the sUAS to service.

23. Each sUAS operated under this exemption will comply with all manufacturer Safety 

Bulletins.

24. The authorized person will make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections.

It is the applicant’s belief that the size, speed, operating environment, limitations and

level of applicant’s experience in the NAS outlined provides an “equivalent level of

safety” or better when operating a sUAS for the public interest as outlined in Section 333

in the FAA Modernization and Reform Act of 2012. It is requested that the FAA issue an

exemption to permit safe, legal, commercial sUAS operation by the applicant as soon as

possible.

Sincerely,

Elliot Rivera, Owner/CEO

Commercial & CFII

Rotorcraft Helicopter, Instrument

AerialWorks Imaging

P.O. BOX 175

Riverdale, NE 68870

308-293-3260
AerialWorks Imaging

August 19, 2015 Page 5 of 10

Appendix A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

AerialWorks Imaging, requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of UASs:

14 CFR Part 21, Subpart H: Airworthiness Certificates

The FAA has stated that no exemption is needed from this section if a finding is made under the 

Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met, and therefore no 

exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA- 2014-0352 

at 13-14, 22. If, however, the FAA determines that there are some characteristics of the chosen 

UAS that fail to meet the requirements of the Reform Act, an exemption is requested. The 

AerialWorks Imaging' use of sUAS is safe when taking into account its size, weight, speed, and 

operational capability. Operations conducted under this exemption will be closely controlled and 

monitored by the operator and will be conducted in compliance with local public safety 

requirements, to provide security for the area of operation. AerialWorks Imaging will also 

provide the FAA with advance notice of all operations via NOTAMs and coordination with the 

local FSDO, as necessary. In all cases, operation of the sUAS under the proposed conditions will 

be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness 

certificate. Further, the UAS does not need a means to communicate with other aircraft or ATC, 

because those capabilities will be possessed by the PIC and Observer, who are not onboard the 

UAS. See Grant of Exemption, Docket FAA-2014-0352 at 13. In addition, no sense-and-avoid 

technology is necessary for the UAS because it will be operated at all times in VFR conditions 

and within VLOS of the PIC and Operator.

14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of 

normal category rotorcraft. To the extent that AerialWorks Imaging's small UASs would 

otherwise require certification under Part 27, this petitioner seeks an exemption from Part 27's 

airworthiness standards for the same reasons identified in the request for exemption from 14 

C.F.R. Part 21, Subpart H.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Inasmuch as there will be no airworthiness certificate issued for the UAS, AerialWorks Imaging

seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy 

condition to be operated. The FAA has stated that no exemption is required for 14 C.F.R. § 

91.7(a) to the extent that the requirements of Part 21 are waived or found inapplicable. See Grant 

of Exemption to Astraeus Aerial, Docket No. FAA-2014-0352 at 13-14, 22. Accordingly, 

Petitioner requests that the requirements for § 91.7(a) be treated in accordance 14 CFR Part 21, 

Subpart H.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned to 

the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph 
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(b) provides that the airworthiness certificate be “displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew.” A sUAS is too small to carry documentation, does not 

have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level 

of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this 

aircraft by the FAA will be co-located with the crew at the ground control station and available 

for inspection upon request. In order to identify the aircraft, we propose the use of the sUAS’ 

unique manufacturers serial number, and a contact telephone number be mounted on the sUAS 

on a placard of reasonable size in relation to the sUAS. In the event that a unique manufacturers 

serial number is not available, the previously mentioned placard will be affixed to the sUAS 

consisting of the model name and number of the sUAS, as well as a contact telephone number.

14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft marking & identification requirement

91.9(c) provides that no person may operate a U.S.-registered civil aircraft unless that aircraft is 

identified in accordance with Part 45 of this chapter.

45.23(b) states that 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.

45.27(a) states that each operator of a rotorcraft must display on that rotorcraft horizontally on 

both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these 

requirements was warranted provided that the aircraft "have identification (N-Number) markings 

in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable." FAA 

Docket No. FAA-2014-0352. In order to obtain an equivalent level of safety, all UAS flown by 

AerialWorks Imagingwill bear N-number markings that are as large as practicable in accordance 

with 14 C.F.R. Part 45, Subpart C.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. The intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to 

this requirement since the sUAS cannot carry such a manual, and if the sUAS did carry such 

manual, it would be unavailable to the crew for review. To obtain an equivalent level of safety 

and meet the intent of 91.9, we propose that a current, sUAS operation manual or equivalent be 

available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight instruction; Simulated instrument flight and certain flight

tests.

The regulation provides that “No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls.” The controls for a sUAS do 

not currently have a set of fully functioning dual controls. If a sUAS pilot is being trained, the 

pilot performing the training would be directly supervising and could take over the controls from 

the pilot in training if the need arose. This would be similar to the technique of a “throw-over 
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type” control wheel in some fixed wing aircraft. We feel that this technique meets the intent of 

91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of this sUAS 

would be photography or survey of persons, vessels, vehicles or structures it would be necessary 

to operate closer than 500 feet to the items listed. Operations will only be flown over property or 

persons where permission has been obtained, and careful pre-planning has been performed. 

Further, sUAS aircraft operate at a very slow airspeed, and a low mass, and do not need as much 

space to operate safely, as outlined in 91.119. We believe the slower speed, smaller mass and 

careful pre-planning would provide an equivalent level of safety. 

14 CFR 91.121Altimeter settings.

The regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 nautical miles of the aircraft. The sUAS will always fly below 500 

feet AGL, and in line of sight of the PIC and visual observer (VO). This line of sight operation 

will provide separation from other aircraft, obstructions and terrain, and would override the use 

of an altimeter for such a purpose. We feel that this will provide an equivalent level of safety.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph it to provide a reasonable 

reserve of energy to plan for a safe landing should there be a delay in landing. The close 

proximity to the ground station, the ability for both rotorcraft and small fixed wing aircraft to 

land in a very small space and the built in energy level monitoring of the sUAS we feel provide 

an equivalent level of safety if the flight is planned to be completed with 20% battery energy 

remaining. We request an exemption to the word “fuel” and ask for an equivalent interpretation 

with the word “energy”.

14 CFR Subpart E (91.401 -91.4171)- Maintenance, Preventive Maintenance, and

Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 

require that the aircraft be “approved for return to service by a person authorized under 43.7” 

after maintenance and inspection. It is our intention that the PIC perform maintenance and 

inspection of the aircraft and “be authorized to approve the aircraft for return to service.” Prior to 

every flight, the PIC will inspect the aircraft to ensure that it is in an airworthy condition. Any 

general maintenance procedures or replacement of consumable items outlined by the sUAS 

manufacturer, if applicable, will be complied with by the PIC. In no circumstance will a sUAS be 

operated in a condition that is deemed, or suspected to be, unsafe. If such a determination is 

reached, and the problem cannot be remedied to the satisfaction of the PIC, the sUAS will not be 

operated until consulting with the manufacturer or one of its authorized dealers to complete 

necessary repairs. We feel that due to the size, construction, and simplicity of the aircraft, the PIC 

can ensure an equivalent level of safety.
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FLIGHT RESTRICTIONS

(a) No flight will be made with a sUAS Gross weight exceeding 55 pounds;

(b) Operations will occur at no more than 500’ AGL, at an airspeed of no more than 87 knots and 

within visual line of sight (VLOS) of the PIC;

(c) All operations will utilize a visual observer (VO). The VO and PIC will be able to communicate 

verbally at all times during a flight operation;

(d) All operations will be conducted over private or controlled-access property with permission from 

the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted.

(e) The PIC will have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a 

minimum of 100 flight cycles and 25 hours of total time as a sUAS rotorcraft pilot and at least ten 

hours logged as a sUAS pilot with a similar sUAS type; 5 hours as sUAS pilot operating the make 

and model of sUAS as well as 3 takeoffs and landings in the preceeding 90 days.

(f) All required permits will be obtained from state and local government prior to operation;

(g) The sUAS System will not be operated over densely populated areas;

(h) The sUAS System will not be operated at air shows;

(i) The sUAS System will not be operated over any open-air assembly of people;

(j) The sUAS System will not be operated over heavily trafficked roads;

(k) The sUAS System will not be operated within 5 nautical miles of an airport unless the operator 

obtains a letter of agreement with that airport’s management or is otherwise permitted by a COA, 

and within 48 hours, but not more than 72 hours issues an appropriate NOTAM;

(l) Operations will be restricted to day only and weather conditions equivalent to VFR;

(m) The PIC will brief the VO and property owner about the operation and risk before the first flight 

at each new location;

(n) No flight may be made without a successful Pre-Flight Inspection by the PIC before each 

operation to ascertain that the sUAS is in a condition safe for flight.

PRE-FLIGHT CHECKLIST

(1) Determine that sUAS battery, remote controller, and mobile device are fully charged in order to 

prevent unexpected premature descent;

(2) Check all wiring connections are tight;

(3) Check all propellers are undamaged and no cracks exist in any structural members of the sUAS; 

(4) Turn on radio controller, check for adequate voltage, set it to connect to the sUAS, move all 

control switches the appropriate preflight position;

(5) Connect the sUAS main battery, check for radio contact with sUAS’s radio receiver;

(6) At a location different from previous flight, re-set GPS and compass to current location;

(7) Turn on transmitter, gimbal and camera.

OPERATING DOCUMENTS

Petitioner submits its Operations Manual with Training Syllabus as Confidential documents 

under 14 C.F.R. § l l .35(b) as they contain proprietary information that Petitioner has not and 

will not share with others. The documents contain operating conditions and procedures that are 

not available to the public and are protected from release under the Freedom of Information Act, 

5 U.S.C. § 552.
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The petition and the following supporting documentation are referred to as the operating 

documents:

1) Training Syllabus included in Operations Manual:

Cautions, Warnings, Basic Flight Maneuvers, Advanced Flight Maneuvers as per 

the DJI Pilot Training Guide and Mission Specific Flight Maneuvers

2) Operations Manual including:

Phantom 3 Professional User Manual:

Phantom_3_Professional_User_Manual_v1.4_en

Phantom 3 Professional Quick Start Guide v1.2:

Phantom_3_Professional_Quick_Start_Guide_en_v1.2

Phantom Pilot Training Guide:

Phantom_Pilot_Training_Guide_en

 Phantom 3 Professional Safety Guidelines and Disclaimer

Safety_Guidelines_Disclaimer_en

Phantom 3 Professional Release Note 2015.8.4

Phantom_3_Professional_Release_Note_en_0804

Intelligent Flight Battery Safety Guidelines

Intelligent_Flight_Battery_Safety_Guidelines_en

Inspire 1 User Manual

Inspire_1_User_Manual_v1.4_en

Inspire 1 Quick Start Guide

Inspire_1_Quick_Start_Guide_v1.4_en

Inspire 1 Maintenance Manual

Inspire_1_Maintenance_ManualV1.0_en

Inspire 1 Safety Guidelines

Inspire_1_Safety_Guidelines_en

Inspire 1 Disclaimer and Warning

Inspire_1_Disclaimer_and_Warning_en

Inspire 1 Release Notes 2015.8.4

Inspire_1_Release_Notes_en_0813

Intelligent Flight Battery Safety Guidelines

Intelligent_Flight_Battery_Safety_Guidelines_en.
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Materials to be readily available to the PIC:

Operations Manual including:

 Phantom 3 Professional User Manual

 Phantom Pilot Training Guide

 Phantom 3 Professional Safety Guidelines and Disclaimer

 Smart Flight Battery Safety Guidelines

 Inspire 1 User Manual

 Inspire 1 Maintenance Manual

 Inspire 1 Safety Guidelines

 Intelligent Flight Battery Safety Guidelines

 Current Sectional and TAC Aeronautical charts

 sUAS logbook and Defect Sheet(s)

 Personal pilot logbook

Petitioner submits its Operations Manual and Training Syllabus as 

Confidential documents under 14 C.F.R. § l l .35(b) as they contain 

proprietary information that Petitioner has not and will not share with 

others. The documents contain operating conditions and procedures that are 

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

of Information Act, 5 U.S.C. § 552.

CONCLUSION

Satisfaction of the criteria provided in Section 333 of the FMRA regarding size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of 

sight, and national security, provide more than adequate justification for the grant of the 

requested exemption allowing operation of Petitioner's sUAS for survey and aerial data 

collection for real estate and various industries pursuant to the Operations Manual.

Please do not hesitate to contact me with any questions regarding this filing:

Elliot Rivera

Helifly83@gmail.com

308-293-3260

Sincerely,

Elliot Rivera

Comm, CFII 3072198

CEO AerialWorks Imaging

Attachments:

AerialWorks Imaging Confidential Operations Manual