U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE Washington, DC 20590 

Air Imaging LLC 

3778 Kay Drive 

Stow Ohio 44224 

330-815-5329 

rodeo428@yahoo.com 

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Subj: Petition for Exemption to Operate the DJI Phantom 2 sUAS for the Purpose of Real Estate 

Photography. 

Dear Sir or Madam, 

Air Imaging LLC (AI) is requesting exemption from the Federal Aviation Administration 

for certain Federal Aviation Regulations so that (AI) may use a sUAS in conducting the 

business of providing aerial photography in the real estate market. (AI) intends to offer 

aerial photography services to any concern where a sUAS can replace putting a human 

in dangerous situations. 

The sUAS that (AI) will be using is the DJI Phantom 2 Quadcopter. The DJI Phantom 2 

has safety features that include Return Home Automatically if the sUAS should exceed 

its control range and a No Fly Zone warning feature that alerts the PIC and VO if the 

sUAS gets to close to an airport. The sUAS will return to its launch point automatically 

when it determines the battery levels are too low. The Phantom 2 has a take-off weight 

of 1250g and operates at 5.8 GHz. Accent/decent speed is 6m/s. Maximum flight speed 

is 10m/s. 

RE: Request for Exemptions Pursuant to Section 333. 

Part 11,14 CFR-Part21-Subpart H; Part36; 45.23; Part61.113(a)&(b); 91.7(a); 

91.9; 91.103; 91.109; 91.119; 91.121; 91.151(a)-(1); 91.203; 91.405(a). 

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14 CFR-Part 21 Subpart H -Airworthiness Certificate, Certification Procedures. 

14 CFR-Part 36- Noise Regulations. 

14 CFR-45.23 - Display Markings. 

14 CFR-Part 61.113(a)&(b)- Certifications for Instructors and Pilots. 

14 CFR-91.7- Civil Air Worthiness. 

14 CFR-91.9- Flight Manuals and Marking Requirements. 

14 CFR-91.1 03- Preflight Actions. 

14 CFR-91.1 09 - Flight Instruction. 

14 CFR-91.119 - Minimum Safe Altitudes. 

14 CFR-91.121 -Altimeter Settings. 

14 CFR-91.151- VFR Requirements for Fuel. 

14 CFR-91.203- Certificates Required for Civil Aircraft. 

14 CFR-91.405(a)- Maintenance Required. 

14 CFR Part 21-Subpart H- (AI) asks for exemption from an Airworthiness Certificate 

because of the size, weight and speed of the sUAS in comparison to manned aircraft 

makes the risks involved negligible in comparison. 

14 CFR Part 36 - (AI) asks for exemption from noise standards due to the sUAS size 

and low noise impact. 

14 CFR 45.23 - (AI) asks for exemption from the marking requirements for aircraft. The 

size of the sUAS will not accommodate the minimum 2" letters. 

14 CFR Part 61.113(a)&(b)- (AI) asks for exemption from the certification requirements 

for pilots. While the sUAS will only be operated over private property with the consent of 

that property owner it is our belief that the 40 plus hours of operating the sUAS by the 

PIC and the VO with the full understanding of the FAA Rules and Regulations governing 

the use of sUAS is sufficient to operate it safely in the NAS. 

14 CFR 91.7- (AI) asks for exemption from this FAR for the same reasons being 

requested for Part 21-Subpart H. 

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14CFR 91.9- (AI) asks for exemption from this FAR for the same reasons being 

requested for Part 21-Subpart H, as placards and on-board flight manuals are 

impractical on a sUAS. 

14 CFR 91.1 03 - (AI) asks for exemption from this FAR as it pertains to manned 

aircraft. All appropriate pre-flight actions will be taken with the sUAS. 

14CFR 91.109- (AI) asks for exemption from this FAR as the sUAS uses a single 

ground controller. 

14 CFR 91.119- (AI) asks for exemption from Minimum Safe Altitudes over various 

areas in order to accomplish the intended mission. 

14 CFR 91. 121 - (AI) asks for exemption from this FAR as the sUAS does not have an 

altimeter that this FAR refers to. Our sUAS has a flight ceiling of 300' AGL and will be 

monitored by the PIC. 

14 CFR 91.151- (AI) asks for exemption from the VFR-Fiight Fuel carrying 

requirements as our sUAS is battery powered. 

14 CFR 91.203- (AI) asks for exemption from this FAR as it requires an Airworthiness 

Certificate. (AI) requested relieffrom an Airworthiness Certificate in Part 21-Subpart H. 

14 CFR 91.207- (AI) asks for exemption from operating our sUAS with an Emergency 

Locator Transmitter. Our sUAS will always be flown within VLOS rules. 

14CFR 91.405- (AI) asks for exemption from this FAR as all maintenance will be done 

by the PIC and VO as recommended by the manufacturer. 

Our mission for safe operation in the NAS will be to always stay below the 300' ceiling, 

operate only within VLOS by the PIC and the VO and to end all flights when battery 

capacity reaches 25%. Additionally (AI) will not operate the sUAS in public places or 

above crowded areas. Before we deploy the sUAS we will stand signs at each end of 

the operating area to alert the public that aerial photography is taking place. Prior to 

each flight the PIC and the VO will examine the flight area for overhead power lines, 

trees, 

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and any other obstacles that could threaten public safety. Weather conditions would be 

the final determining factor before each flight. 

I will be the PIC. I have over 40 hours flying time with the OJI Phantom 2. The VO has 

over 20 hours of flying time with the Phantom 2. Our sUAS will be flown only during 

daylight hours and only under VLOS rules. (AI)'s goal is to provide a quality service 

while adhering to all FAA rules for safe flight. 

Before and after each flight the PIC and the VO will visually inspect all rotor blades, 

electrical connections, battery conditions and levels and test the link between the sUAS 

and the controller. 

It is our belief that by using a sUAS in place of manned aircraft greatly increases the 

safety of the general public. Our sUAS is compact, lightweight, carries no flammable 

fuel and has no humans on board. Coupled with the sUAS relatively slow air speeds 

and that it is being operated within VLOS and under 300' AGL by a qualified PIC and 

VO we feel that the risks of using a sUAS to conduct aerial photography have been 

greatly reduced. 

Thank you for your consideration, 

Respectfully, 

f'7~ Jay Thierfelder 

President 

Air Imaging LLC 

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