September 22, 2015

U.S. Department of Transportation Docket Management System

West Building Ground Floor, Room W12-140

1200 New Jersey Ave., SE

Washington, D.C. 20590

Dear Sir or Madam ,

I, Howard A. Griffin, Jr. President/Owner/Operator, d.b.a. Airtacc Aerial Video System, LLC, 

petition the Federal Aviation Administration (FAA) for an exemption from part 21 and §§ 45.23(b), 

61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 

91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of the Federal 

Regulations (14 CFR). The proposed exemption would allow Airtacc Aerial Video System, LLC, 

LLC to operate its unmanned aerial system (UAS) for aerial video and photography, including but 

not limited to operations: (1) over land, waterways, and oceans; (2) operation over and/or in 

unrestricted National Parks, National Forests, and non-navigable airspace using nonintrusive 

recording devices; and (3) operation in otherwise unrestricted U.S. States and Territories. All 

proposed operations would be conducted under controlled conditions in airspace that is: (1) limited, 

(2) predetermined, and (3) access controlled. 

The President/Owner/Operator, Airtacc Aerial Video System, LLC, currently holds an Airline 

Transport Pilot, Advanced Ground Instructor and Instrument Ground Instructor Certificate. The 

President/Owner/Operator served ten years as an Army Aviation Officer, serving in several positions 

to include Commander of an Aerial Intelligence Company. The President/Owner/Operator has flown 

Part 91 and 135, is typed in the Dash 8, Saab 2000, Lear 60, Citation 750, Gulfstream 350/450/550 

and V. The President/Owner/Operator is currently working as a ground/simulator instructor for a 

leading Part 142 Flight Training Center. The President/Owner/Operator possess the professionalism, 

the experience, the knowledge, the resources, and vested interests in conducting and maintaining safe 

UAS operations, as well as concern of the public’s general welfare at large.

Airtacc Aerial Video System, LLC requests relief from the following regulations: 

Part 21, Certification Procedures for Products and Parts, prescribes, in pertinent part, the procedural 

requirements for issuing and changing design approvals, production approvals, airworthiness 

certificates, and airworthiness approvals. 

Section 45.23(b) prescribes, in pertinent part, 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. 
Section 61.113(a) and (b) prescribes that—

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an 

aircraft that is carrying passengers or property for compensation or hire; nor may that person, 

for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with 

any business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy 

condition. 

Section 91.9(b)(2) prescribes, in pertinent part, that no person may operate a U.S.-registered civil 

aircraft 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. 

Section 91.103 prescribes that each PIC shall, before beginning a flight, become familiar with all 

available information concerning that flight, to include—

(a) For a flight under instrument flight rules (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 traffic delays of which the PIC has been advised by air 

traffic control (ATC); 

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information: 

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data is required, the takeoff and landing 

distance data contained therein; and 

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, 

other reliable information appropriate to the aircraft, relating to aircraft performance 

under expected values of airport elevation and runway slope, aircraft gross weight, 

and wind and temperature. 

Section 91.109 prescribes, in pertinent part, that 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. 

Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may operate 

an aircraft below the following altitudes: 

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without 

undue 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 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) Helicopters, powered parachutes, and weight-shift-control aircraft. 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 paragraph (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. 

Section 91.121 prescribes, in pertinent part, that each person operating an aircraft shall maintain the 

cruising altitude by reference to an altimeter that is set when operating below 18,000 feet mean sea 

level (MSL) to the elevation of the departure airport or an appropriate altimeter setting available 

before departure. 

Section 91.151(a) prescribes that no person may begin a flight in an airplane under visual flight rules 

(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—

(a) During the day, to fly after that for at least 30 minutes; or 

(b) At night, to fly after that for at least 45 minutes. 

Section 91.203(a) prescribes, in pertinent part, that no person may operate a civil aircraft unless it has 

within it—

(a) An appropriate and current airworthiness certificate; and 

(b) An effective U.S. registration certificate issued to its owner or, for operation within the 

United States, the second copy of the Aircraft Registration Application as provided for in § 

47.31(c). 

Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft unless the 

airworthiness certificate 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. 

Section 91.405(a) prescribes, in pertinent part, that each owner of an aircraft 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, 

Maintenance, Preventive Maintenance, Rebuilding, and Alteration.
Section 91.407(a)(1) prescribes that no person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for return 

to service by a person authorized under § 43.7 of this chapter. 

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness 

certificate in accordance with part 21. 

Section 91.417(a) and (b) prescribe, in pertinent part, that—

(a) Each registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records 

of the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, 

rotor, and appliance of an aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature and certificate number of the person approving the aircraft 

for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft that are 

required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the aircraft 

and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) for each major alteration to 

the airframe and currently installed engines, rotors, propellers, and 

appliances. 
(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the 

work is repeated or superseded by other work or for 1 year after the work is 

performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service. 

Airtacc Aerial Video System, LLC supports its request with the following information: 

The petition and the following supporting documentation are hereinafter referred to as the operating 

documents: 

(a) Contract Checklist

(b) Preflight Checklist 

(c) DJI Inspire 1 User Manual V1.0

The petitioner’s information is organized into five sections: (1) the unmanned aircraft system (UAS), 

(2) the UAS pilot in command (PIC), (3) Aircraft and Equivalent Level of Safety, (4) the UAS 

operating parameters, and (5) the public interest.

Unmanned Aircraft System 

DJI Inspire 1 Specifications:

Model T600

Weight (Including Battery) 6.8 lbs.

Hovering Accuracy (P Mode) Vertical: 1.69 ft

Horizontal: 8.2 ft

Max Angular Velocity Pitch: 300o/s

Yaw: 150o/s

Max Tilt Angle 35O

Max Ascent Speed 42.7 fps (ATTI mode, no wind)

Max Flight Altitude 14,763 ft

Max Wind Speed Resisitance 32.8 fps

Max Flight Time 18 minutes

Motor Model DJI 3510

Propeller Model DJI 1345 (2), DJI 1345R (2)

Operating Temperature Range -10oF to 40oF

Diagonal Distance 22” to 22.8”

Dimensions (LxWxH) 17.2”x17.7”x11.8”
Airtacc Aerial Video System, LLC will use the Dual Control DJI Inspire 1, multi-rotorcraft UAS 

with four motors and propellers in a quadcopter configuration weighing 7 pounds or less, including 

camera. Any modifications to the UAS will be approved modifications by the manufacture. In these 

cases, total weight may be affected. Therefore, request a max operating weight of 20 pounds which 

would take into account future manufacture approved modifications. 

The UAS is also equipped with an onboard computer stabilization controller and Global Positioning 

System (GPS), operating under normal conditions, at speeds of 5 to 50 knots, (Note: the petition 

states 5 to 50 knots, however the Inspire 1 User Manual indicates the maximum speed is 22 

meters/second or 42.7 knots. The UAS has the capability to hover and move in the vertical and 

horizontal planes independently and simultaneously. All flight operations will be conducted within 

visual line of sight (VLOS) of the pilot and/or observer and will not create a hazard to users of the 

National Airspace System (NAS) or the public. 

Given the size and limited operating area associated with the UAS, an exemption from part 21, 

subpart H, Airworthiness Certificates, subject to certain conditions and limitations, is requested and 

meets the requirements for an equivalent level of safety under 14 CFR part 11, General Rulemaking 

Procedures, and section 333 of Public Law 112–95. The petitioner further states its UAS will be 

operated without an airworthiness certificate under the conditions and limitations proposed and 

therefore will be at least as safe as, or safer than, a conventional aircraft (fixed-wing or rotorcraft) 

operating with an airworthiness certificate issued under part 21, subpart H. 

The UAS does not carry neither a pilot nor a passenger, explosive materials, flammable liquid fuels, 

and operates exclusively within a limited flight area. In the event the UAS loses communications or 

its GPS signal, the unmanned aircraft (UA) will have the capability to return to a predetermined 

location, a.k.a. “Return to Home”, within the security perimeter and land. The UA will also have the 

capability to abort a flight in the event of unpredicted obstacles or emergencies. 

Although the UAS does not require an airworthiness certificate, an exemption may be needed from 

14 CFR § 45.23 as the UA will have no entrance to the cabin, cockpit, or pilot station on which the 

word “experimental” can be placed. Given the size of the UA, the petitioner notes that the 2-inch 

lettering will be impossible. An equivalent level of safety will be provided by having the UA marked 

with the word “experimental” on the fuselage in compliance with 14 CFR § 45.29(f), in a location 

where the pilot, observer, and others working with the UA will see the identification. 

Although maintenance requirements in §§ 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and 

(b) are only applicable to aircraft with an airworthiness certificate, routine maintenance and 

preflights will be accomplished by the operator. Routine maintenance and preflights will be logged 

and available for inspection.

Airtacc Aerial Video System, LLC pilot and/or operator is most familiar with the UA and best suited 

to maintain it in an airworthy condition to provide an equivalent level of safety. If a mechanical 

issue arises, the UA can land immediately, and given its small size, it poses minimal risk to persons 

or property. 

UAS Pilot In Command (PIC) 
Prior to designation, a PIC must meet the following requirements:

(a) Have a Private Pilot License*

(b) Have a current Class III Medical Certificate*

(c) Have a minimum of 25 hours of total flight time as a UAS rotorcraft pilot of which 5 

hours can be simulated.

(d) Complete the Airtacc, LLC indoctrination.

(e) Must accumulate and log a minimum of 1 hour of actual flight training as UAS pilot 

operating the make and model of UAS as well as 3 takeoffs and landing in the proceeding 90 

days of a commercial flight. Training will include maneuvers to be performed during 

normal operations including safe operations in relation to persons, property and applicable 

airspace. 

Note: *Until regulatory changes have been approved by FAA

Because the UAS will not carry a pilot or passengers on board, the proposed operations can achieve 

an equivalent level of safety by requiring the pilot and/or observer to review the following FAA and 

DJI Inspire 1 system related information:

(a) FAA related

(1) Airspace.

(b) DJI Inspire System (Current Version)

1. DJI Inspire 1 User Manual 

2. DJI Inspire 1 Safety Guidelines 

3. Intelligent Flight Battery Safety Guidelines 

4. 1345 Propeller Locks Quick Start Guide

5. Preflight/Preflight Checklist

6. Tutorial “Pilot App”

7. Tutorial “How to Fly”

8. Tutorial “Dual Operator” 

9. Normal Modes of Operation

10. Emergency Modes of Operation

11. Maneuvers

The UAS aircraft will be operated within controlled and restricted areas, and all flights will be 

planned and coordinated in advance such that a commercial pilot certificate is unwarranted. Risks 

associated with the operation of UAS are so diminished from the level of risk associated with 

commercial operations contemplated by 14 CFR part 61, Certification: Pilots, Flight Instructors, and 

Ground Instructors, when drafted, that allowing operations of the UAS with a private pilot as the 

operator, as requested, exceeds the current level of safety achieved by 14 CFR § 61.113(a) and (b). 

Aircraft and Equivalent Level of Safety
The operating limitations proposed by Airtacc Aerial Video System, LLC provide for a higher level 

of safety because UAS operations further enhance safety of aerial photography operations over using 

conventional aircraft.

As set forth herein by Airtacc Aerial Video System, LLC, the limitations and conditions include:

a. The UAS will weigh less than 55 pounds.

b. Airport owners and/or local air traffic control facilities will be contacted and notified if 

operations within the designated distance from that airport, pursuant

c. to any conditions of COAs issued for commercial UAS flight activities Flights will be 

operated at an altitude of no more than 400 feet AGL as indicated by onboard GPS system

d. Minimum crew for each operation will consist of the UAS pilot, the observer/ camera 

operator

e. A UAS pilot will be Pilot in Command (PIC)

f. A UAS pilot will be an FAA certificated airman with at least a Private Pilot’s certificate and 

at least a current third class Medical

g. An established “Security Perimeter” for the flight operations area

h. A briefing will be conducted for planned UAS operations prior to each flight

i. All personnel performing duties within the boundaries of the safety perimeter are required to 

participate

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

requested exemption, with the appropriate Flight Standards District Office when applicable 

for the specified flight requiring a specific COA, above and beyond the blanket COA 

authorized by the FAA on March 23, 2015, once such blanket COA is issued to this operator

k. The operator will attempt to verbally notify all persons involved in the filming and the 

operations, and ensure that they will stay no closer than the specified safety distance (vertical 

and lateral) of the flight operation, when applicable

l. The operator will submit a written Plan of Activities to the FSDO at least 1 calendar day, 

including non-business days, before the proposed operations commence if operations require 

a specific COA when operations occur outside the blanket COA, unless the specific COA 

does not require the additional notification

m. The Pilot and Observer will at all times be able to communicate by voice and may augment 

verbal communication by electrical means because of ambient noise levels if necessitated for 

safety and/or if deemed helpful to the safe operation of the UAS, as determined by the PIC

n. Written and/or oral permission from the relevant property owners will be obtained.

o. All required permissions and permits will be obtained from territorial, state, county, or city 

jurisdictions, including local law enforcement, fire, or other managing governmental 

agencies, if applicable

p. If the UAS loses communications or loses its GPS signal, the UAS will and does have the 

capability to return to a pre-determined location within the Security Perimeter and land safely

q. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies

Lastly, Airtacc Aerial Video System, LLC will establish a working relationship with a representative 

at the local Flight Standards district Office (FSDO) with which to annually review safety procedures 

and other operations to further enhance safety.

UAS Operating Parameters 
All flights will be operated within VLOS of a pilot and/or observer to maintain safe separation from 

certificated aircraft in the airspace. In addition, all UA flights will be limited to a maximum altitude 

of 4I00 feet above ground level (AGL) and restricted to class E and G airspace. An equivalent level 

of safety can be achieved given the size, weight, and speed of the UA, as well as the location where it 

is operated. 

Request an exemption from 14 CFR 91.7(a), which prohibits the operation of an aircraft without an 

airworthiness certificate. Since no such certificate will be applicable in the form contemplated by 

FAA regulations, this regulation is inapplicable. 

Request an exemption from 14 CFR §§ 91.9(b)(2) and 91.203(a) and (b), which requires an aircraft 

flight manual, and other documents (airworthiness certificate and registration) be carried in the 

aircraft. The UAV carries no pilot and given the size of the UAV, carriage of these documents 

aboard the UAV is not possible. An equivalent level of safety will be achieved by maintaining these 

documents at the ground control point where the pilot flying the UAV will have immediate access to 

them.

Request an exemption from 14 CFR § 91.103, because it will not have approved rotorcraft flight 

manuals. An equivalent level of safety will be achieved by the operator taking all preflight actions 

including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft 

performance data before initiation of flight using appropriate checklists. Additionally, a briefing will 

be conducted before each day’s production activities and will be mandatory for all personnel who 

will serve as either the operator or visual observer/camera operator. 

Request an exemption from the requirement to have fully functional dual controls in aircraft used for 

flight instruction, prescribed by 14 CFR § 91.109. Remotely piloted aircraft, by their design do not 

have fully functional dual controls. Flight control is accomplished through the use of a radio 

transmitter that communicates with the aircraft via a receiver in the UA. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of aircraft. An 

equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in 

the aircraft and by the size and speed of the aircraft. 

14 CFR § 91.119 establishes safe altitudes for operation of civil aircraft. 14 CFR § 91.119 (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 the FAA. 

Airtacc Aerial Video System, LLC requests relief to operate at maximum altitudes up to 400 AGL, 

underneath navigable airspace and in class E and G airspace. An equivalent level of safety will be 

achieved given the size, weight, speed of the UAV 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, attempts will be made 

to contact all affected individuals regarding the planned flight operations. Compared to flight 

operations with aircraft or rotorcraft weighting far more than the UA proposed herein, and the lack of 

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

with conventional aircraft. In addition, the low-altitude operations of the UA will ensure separation 

between these UA operations and the operations of conventional aircraft that must comply with § 

91.119.
Airtacc Aerial Video System, LLC, may need an exemption from § 91.121, as its UAS has a GPS 

altitude readout instead of a barometric altimeter. The UAS requires a compass alignment, which is 

part of the preflight, for location accuracy. The UAS flight failsafe requires GPS satellite 

connectivity prior to flight. An equivalent level of safety will be achieved via the operating 

documents requiring confirmation of the altitude of the launch site shown on the GPS altitude 

indicator before flight.

Regarding the fuel requirements, 14 CFR § 91.151 requires a 30-minute reserve which results in a 

UAS flight limited to approximately 10 minutes. Due to the limitations on the UA’s proposed flight 

area and the location of its proposed operations within a predetermined area, a longer timeframe for 

flight in day VFR conditions is reasonable. An equivalent level of safety can be achieved by limiting 

flights to 15 minutes or not less than 20 percent of battery power, whichever occurs first. 

Public Interest 

Given the small size of the UAV involved and the limited environment within which it will operate, 

its proposed operation “falls 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 UAS 

to commence immediately.” Also because of the size of the UA and the restricted areas in which the 

UAS will operate, approval of the application presents no national security issue. 

Granting the requested exemptions is in the public interest because of;

(1) the clear direction in section 333 of Public Law 112–95, 

(2) the strong equivalent level of safety surrounding the proposed operations, and 

(3) the significant public benefit, including enhanced safety and reduction in environmental impacts 

(such as reduced emissions associated with allowing UAS for photography and inspection 

operations). 

Summary for Publication

As established by the UAS exemptions already granted by the FAA, allowing commercial

operations of UAS in the aerial photography industry will enhance safety by reducing risk.

Conventional aerial photography operations, using varying types of conventional aircraft, operate

at low altitudes and present the risks associated with aircraft that weigh at least 2,000 pounds and

upward, and which carry large amounts of varying types of aviation fuel. Such aircraft must also

fly to and from the shoot location at speeds that can exceed 50 knots over non-Safety Perimeter

areas. In contrast, a UAS weighing fewer than 55 pounds and powered by batteries eliminates

virtually all of that risk, given the small size and lack of combustible fuel. The UAS is carried,

and not flown, to a job site. In this regard, the UAS carries no passengers or crew and, therefore,

will not expose them nor person and property on the ground to the risks associated with manned

relocation flights.

The operation of UASs conducted in the strict conditions outlined within this exemption request

provide at least an equivalent level of safety supporting the grant of the exemption requested

herein. The UASs operate at slow speeds, close to the ground, and in a sterile environment.

UASs also have far less impact on the environment compared to the conventional aerial

photography practices it replaces. As a result, they are far safer than conventional operations
conducted with aircraft including, but not limited to, turbine helicopters or small single-engine

aircraft flying near the ground, property, and people.

Satisfaction of the criteria provided in Section 333 of the FAA Modernization and 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 to grant Airtacc, LLC requested exemption, allowing for Airtacc, LLC. UAS

commercial operations.

Any future requirements issued by the FAA pertaining to operating UASs commercially (e.g.

written test, logging flight time experience, etc.) will be complied with as it is understood this is

a rapidly evolving sector of the aerospace industry with little regulatory affirmations as of yet.

Additionally, Airtacc Aerial Video System, LLC may receive request to conducted business and 

commercial UAS operations in and/or over the country of Canada and Mexico. Therefore, Airtacc, 

LLC finishes this exemption request with the consideration of 14 CFR 11.81 (h), allowing for 

commercial UAS operations with the need to “exercise the privileges of our exemption outside the 

United States” with the aforementioned reasons.

If you have any questions or need any additional information, please contact the undersigned at

734-657-9629 or hagriff@gmail.com.

.

Respectfully yours,

Howard A. Griffin, Jr.

President/Operator/Owner

Airtacc Aerial Video System, LLC