August 10, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

RE: Request for Exemption pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 and 14. C.F.R. Part 11 

UAV Aerial Solutions, LLC 

Nicholas Pagerly, Partner 

21 Focht Rd 

Robesonia, PA 19551 

610-823-8922 

nap@uav-aerialsolutions.com 

This petition is being submitted on our behalf without legal counsel or consulting 

services. 

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

Reform Act), and 14 C.F.R. Part 11, Aerial Solutions, LLC, a full service digital 

imaging company, hereby applies for an exemption from the Federal Aviation 

Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft 

System (sUAS) commercially in airspace regulated by the Federal Aviation 

Administration (FAA) so long as such operations are conducted with and under the 

conditions outlined herein or as may be established by the FAA as required by 

Section 333. 

The requested exemption would permit Aerial Solutions, LLC to pursue its 

commercial interests in providing services to clients using a small advanced sUAV in 

the following areas: 

 Commercial And Industrial Aerial Imaging 

 Bridge, Tower and Structure Inspection

 Aerial Surveying For Data Collection 

 Utility Inspection 

 Agricultural Survey And Crop Monitoring 

 Real Estate 

 Marketing 

 Industrial 

 Special Events 

 Local and National Natural and Man Made Disaster Rescue 

ABOUT AERIAL SOLUTIONS, LLC 

Aerial Solutions, LLC is based in Robesonia, PA. Aerial Solutions, LLC is a small, 

yet, rapidly growing company that is dedicated towards addressing a wide variety 
of aerial photographic applications. Aerial Solutions, LLC foresees an abundance of 

opportunity and discovery. Our initial requests for service have come with a strong 

demand from the Telecommunication and Real Estate markets. However, as the 

technology quickly proves its value, we will be heavily focused on bridge, tower and 

structure inspection agricultural survey and monitoring of growth, development and 

deficiencies, as well as, commercial advertising, public safety services, such as, 

search and rescue emergencies, and first responder for hazardous condition 

assessments like material spills and fires, both controlled and wild. 

We also project a wide variety of Environmental Safety and Conservation 

applications in the near future. This could include botanical and wildlife studies and 

safety assessments, as well as, forest canopy monitoring and expedited detection of 

invasive species like the Pine Bark Beetle, Emerald Ash Borer or the Forest Tent 

Caterpillar. 

SAFETY 

Safety is a fundamental core value in all Aerial Solutions, LLC operations. 

Aerial Solutions, LLC strongly believes the safe integration of sUAS’s into National 

Air Space (NAS) is of the utmost importance and is wanting/willing to adhere to any 

additional regulations imposed by the FAA in order to maintain the NAS safety and 

security, therefore 

As an ambassador of an amazingly new technology, Aerial Solutions, LLC will 

always strive to be an exemplary representative of proper sUAS integration into 

National Air Space (NAS) for commercial applications. 

All sUAS flights will occur over private or controlled access property. Aerial 

Solutions, LLC will conduct flights with the property owner’s consent and 

knowledge. Access during flights will be limited to people who have consented or 

otherwise have agreed to be in the area where videography will take place. 

PILOT IN COMMAND (PIC) TRAINING REQUIREMENTS

In order to maintain and advance those necessary safety and security protocols of 

an emerging industry, Any/All Aerial Solutions, LLC PIC’s must possess and 

complete the following FAA and Operator requirements before any consideration for 

commercial flight takes place: 

1. All PIC’s must possess a commercial, private or sport pilot license and a 

current FAA Medial Certificate or valid driver’s license 

2. All PIC’s must complete and log a minimum of 50 hours of advanced flight 

simulation time using a flight simulation training program. 

3. All PIC’s must complete and log a minimum of 40 hours actual hands on 

flight training. 

4. All PIC’s must possess advanced safety training and knowledge, as well as, 

advanced training in Pre & Post flight planning, maintenance, checklists, etc.. 
5. All PIC’s must pass Aerial Solutions, LLC’s strictly monitored final flight tests. 

Aerial Solutions, LLC sUAS pilots are highly experienced and fully licensed 

commercial aircraft and rotorcraft pilots. Each has 1000’s of hours of commercial 

experience operating within the National Airspace System. Aerial Solutions, LLC 

pilots will always fly in observance of all FAA Laws, Rules, Guidelines and 

stipulations. 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Aerial Solutions, LLC requests an exemption from the following regulations as well 

as any additional regulations that may technically apply to the operation of the 

sUAS System: 

 14 CFR Part 21, Subpart H 

 14 CFR 21.191 

 14 CFR Part 27 

 14 CFR sections 45.23(b) 

 14 CFR 45.27 (a) 

 14 CFR Part 61.23(a) and (c) 

 14 CFR Part 61.101(e)(4) and (5) 

 14 CFR Part 61.113(a) and (b) 

 14 CFR Part 61.315(a) 

 14 CFR Part 91.7 (a) 

 14 CFR Part 91.9 

 14 CFR Part 91.103 

 14 CFR Part 91.105 

 14 CFR Part 91.109 

 14 CFR Part 91.119 

 14 CFR Part 91.121 

 14 CFR Part 91.151(a) 

 14 CFR Part 91.203(a) and (b) 

 14 CFR Part 91.405(a) 

 14 CFR Part 91.407(a)(1) 

 14 CFR Part 91.409(a)(2) 

 14 CFR Part 91.417(a) and (b) 

14 CFR Part 21 Subpart H, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. 

 While the FAA continues to work to develop airworthiness standards for 

Unmanned Aerial Systems, we request an experimental certificate be issued 

for the DJI Phantom 3, Inspire 1, and S900 under either, or both, of the 

following provisions: 
14 CFR 21.191 Experimental Certificates. Experimental certificates are issued 

for the following purposes: 

a) Research and development. Testing new aircraft design concepts, new aircraft 

equipment, new aircraft installations, new aircraft operating techniques, or new 

uses for aircraft. 

b) Showing compliance with regulations. Conducting flight tests and other 

operations to show compliance with the airworthiness regulations including 

flights to show compliance for issuance of type and supplemental type 

certificates, flights to substantiate major design changes, and flights to show 

compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as 

market surveys, sales demonstrations, and customer crew training, we would 

expect that an experimental certificate would permit our commercial purpose as 

well. The aircraft will not carry persons or property, will not carry fuel, and will 

only fly under strict operational requirements. Combined with the sUAS's 

lightweight, being constructed primarily of carbon fiber and plastic, we propose 

that the sUAS will be at least as safe, if not safer, than a conventionally 

certificated aircraft performing the same mission. If an experimental 

airworthiness certificate is not appropriate for this application, then we request 

an exemption of 14 CFR Part21, Subpart H, and the requirement for 

airworthiness certificate in general, citing the equivalent level of safety outlined 

in the previous paragraph. 

14 CFR 21.191 Experimental Certificates: 

Experimental certificates are issued for the following purposes: 

a) Research and development. Testing new air craft design concepts, new aircraft 

equipment, new aircraft installations, new aircraft operating techniques, or new 

uses for aircraft. 

b) Showing compliance with regulations. Conducting flight tests and other 

operations to show compliance with the airworthiness regulations including 

flights to show compliance for issuance of type and supplemental type 

certificates, flights to substantiate major design changes, and flights to show 

compliance with the function and reliability requirements of the regulations. 

 Since the experimental certificate can be used for commercial purposes such 

as market surveys, sales demonstrations, and customer crew training, we 

would expect that an experimental certificate would permit our commercial 

purpose as well. The aircraft will not carry persons or property, will not carry 

fuel, and will only fly under strict operational requirements. Combined with 

the aUAS's lightweight, being constructed primarily of carbon fiber and 

plastic, we propose that the UA will be at least as safe, if not safer, than a 

conventionally certificated aircraft performing the same mission. If an 

experimental airworthiness certificate is not appropriate for this application, 
then we request an exemption of 14 CFR Part 21, Subpart H, and the 

requirement for an airworthiness certificate in general, citing the equivalent 

level of safety outlined in the previous paragraph. 

14 CFR 27 Airworthiness Standards: Normal Category Rotorcraft 

This part prescribes airworthiness standards for the issue of type certificates, and 

changes to those certificates, for normal category rotorcraft with maximum weights 

of 7,000 pounds or less and nine or less passenger seats. 

 Since the sUAS is not a normal rotorcraft as described in the above 

mentioned regulation we do not believe that this regulation would apply. We 

therefore request an exemption from 14 CFR 27. 

14 CFR 45.23 (b) Display of Marks; General and 14 CFR 45.29 Size of Marks 

The regulation requires: 

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. 

Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on 

which the word “Experimental” 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 sUAS will not have an airworthiness certificate, but as required by the 

333 Exemption it will be registered and each sUAS will have its own “N” 

number. The N-number will be permanently applied to the sUAS. The Nnumber will be as large as is practical and prominently displayed. 

14 CFR 45.27 (a) Location of Marks; Nonfixed - Wing Aircraft 

This part describes the required positioning and size of markings on nonfixed - wing 

aircraft 

 Since the size of the sUAS restricts the size and placement of the required 

markings we propose any required markings will be permanently applied to 

the sUAS. Furthermore said markings will be as large as is practical and 

prominently displayed. 
14 CFR 61.23 (a) (c) Medical Certificates: Requirement and Duration 

This part describes those operations requiring a medical certificate and operations 

requiring either a medical certificate or U.S. driver's license. 

 All PIC’s will possess either a FAA Medical Certificate or valid driver’s license 

as appropriate 

14 CFR 61.101 (e) (4) (5) Recreational Pilot Privileges and Limitations 

This part describes the limitations of a recreational pilot certificate holder. In 

particular, the fact that a recreational pilot certificate holder is prevented from 

operating an aircraft for compensation or hire 

 The PIC requirements stated in the 333 Exemption state that the sUAS PIC 

must hold either a private, commercial or sport pilot’s license in order to 

operate the sUAS for commercial purposes. Therefore we request an 

exemption from these regulatory requirements 

14 CFR 61.113 (a) (b) Private Pilot Privileges And Limitations: Pilot in 

Command and 61.133 Commercial pilot privileges and limitations. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

 Because the sUAS will not carry a pilot or passengers, the proposed 

operations can achieve the equivalent level of safety of current operations by 

requiring the PIC operating the aircraft to operate under the supervision of a 

private pilot’s license holder rather than a commercial pilot’s license holder. 

 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 restricted, and all flights are planned and coordinated in 

advance. 

 The risks associated with the operation of the sUAS are so diminished from 

the level of risk associated with commercial operations contemplated by Part 

61 when drafted, that allowing operations of the sUAS as requested with a 

private pilot in a supervisory role aiding the PIC exceeds the present level of 

safety achieved by 14 CFR 61.113 (a) & (b). 

14 CFR 61.315 (a) (c) (2) (3) What Are the Privileges and Limits of My 

Sport Pilot Certificate 

Sections 61.315 (a), (b), (2), and (3) limit Sport Pilots to non-commercial 

operations. 

 Since a Sport Pilot Certificate is listed as one of the approved airman 

certificates required for commercial operation of a sUAS Aerial Solutions, LLC 

requests an exemption from the parts of the regulation as noted above 
14 CFR 91.7 Civil Aircraft Airworthiness 

 This regulation prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated 

by the FARs, this Regulation is inapplicable. 

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. We assume that 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 aircraft is not only too small to carry documentation; 

the documentation would not be available to the crew during flight 

operations. 

 To obtain an equivalent level of safety and meet the intent of 91.9, we 

propose that a current, approved sUAS Flight Manual must be available to 

the crew at the ground station anytime the aircraft is in, or preparing for, 

flight. 

14 CFR 91.103 Preflight Action 

This regulation describes the information each pilot in command shall obtain prior 

to beginning a flight 

 Pre and Post Flight Checklist/Inspections To include, but not be limited to the 

following: 

1. Inspect all parts and system components for proper working condition. 

Including, but not limited to: 

a. Actuators/Servos 

b. All Motors 

c. Wiring and Connectors 

d. Propellers, cleaned, inspected for damage, mounted correctly 

e. Electronic Speed Controllers 

f. Batteries Levels and Condition of all power supplies. 

g. Remote Control Functions and Settings 

h. Ground Station equipment and connections 

2. Conduct preflight safety discussions and assessments including but not 

limited to weather and other areas of concern: and take steps to 

mitigate or eliminate all safety risks prior to flight. 

3. Obtain proper clearance of NAS, if need be, and proper permission for 

land use. 

4. Strictly manage Spectator, Crew and Public Safety. 

5. Have on hand all necessary flight documents, handbooks, exemptions, 

etc. 
6. Conduct all preflight inspections and operational testing recommended 

in the sUAS user and operational manuals. 

7. Aerial Solutions, LLC will only conduct operational flights under ideal 

visual meteorological conditions (VMC) and as follows: 

a. No flights will take place in obstructed view locations or during 

unpredictable weather conditions. 

b. No flights will be conducted less than 500 feet below or less 

than 2,000 feet horizontally from a cloud or when visibility is 

less than 3 statute miles from the PIC. 

c. No flight operations will be conducted at night. 

d. All flights will be aborted in the event of unpredicted obstacles 

or emergencies. 

14 CFR 91.105 Flight Crewmembers at Stations 

This regulation states the requirement for when flight crewmembers must be at 

their stations 

 The sUAS is unmanned and therefore this regulation would not apply. During 

operation the sUAS PIC will maintain “hands on” the controller at all times 

14 CFR 91.109 Flight Instruction; Simulated instrument light and certain 

flight tests

The regulation states "No person may operate a civil aircraft that is being used for 

flight instruction unless that aircraft has fully functioning dual controls.” 

 The sUAS System ground-based control station consists of a hand-held radio 

transmitter and while it does not offer a second set of "controls", both the 

student and instructor can, and will, operate the single set of controls 

simultaneously. With both student and instructor having "hands-on" the 

controls during flight, this technique meets the intent 91.109 and provides an 

equivalent level of safety. 

14 CFR 91.119 Minimum Safe Altitudes: General. 

The regulation states that over sparsely populated areas the aircraft cannot be 

operated closer than 500 feet to any person, vessel, or structure. 

 Since the typical mission of the 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 preplanning has been performed. The aircraft will be operated at a low altitude 

allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. Therefore we maintain that due to the 

small size of the sUAS, the hazard to persons, vehicles and structures is 
minimal compared to manned aircraft, which should be considered in 

granting the exemption. 

14 CFR 91.121 Altimeter settings 

The regulation requires that aircraft shall maintain cruising altitudes by reference to 

an altimeter setting available within 100NM of the aircraft. 

 The sUAS will always fly below 400 feet AGL and will not need to maintain 

cruising altitudes in order to prevent conflict with other aircraft. An Above 

Ground Level altimeter measurement above the take off point is transmitted 

via radio from the sUAS on-board computer to the display screen held by the 

PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 (a) Fuel requirements for flight in VFR conditions 

The regulation provides that no person may begin a flight in an airplane under dayVFR 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 is to provide an energy reserve as a 

safety buffer for delays to landing. The sUAS is battery operated and the 

maximum duration of flight from a single battery charge is 12 minutes with a 

20% reserve. Since the aircraft will never fly more than 3/4NM from the 

point of intended landing, a full battery charge at launch will ensure that we 

meet the reserve energy requirement of this paragraph. We request an 

exemption to the word "fuel" and ask for an equivalent interpretation with 

the word "energy". 

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 (b) provides that the airworthiness certificate 

be "displayed at the cabin or cockpit entrance so that it is legible to passengers or 

crew." 

 At a maximum gross weight of under 6.5 pounds, the 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 that the information found on airworthiness and 

registration certificates be permanently affixed to the aircraft via placard 

containing the following information plus the word "EXPERIMENTAL" to 

satisfy the requirement of 14 CFR 45.23. 
14 CFR Subpart E 91.401 - 91.417 - Maintenance, Preventive Maintenance, 

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 14 CFR 43.7 "after maintenance and 

inspection. 

 It is our intention that the PIC will perform routine maintenance and 

inspections of the aircraft and "be authorized to approve the aircraft for 

return to service." 

 The PIC will ensure that the aircraft is in an airworthy condition prior to every 

flight and in addition conduct detailed inspections after every two hours of 

flight. 

 Maintenance performed by the PIC is limited to: 

o repairing small cracks, 

o replacing a propeller, 

o checking electrical connections and 

o updating software and firmware for the on-board computer 

 All other maintenance will be performed by the manufacturer or their 

designated repair facility. 

 The PIC will document work performed in accordance with 91.417. 

 We feel that due to the size, construction, and simplicity of the aircraft, the 

PIC can ensure an equivalent level of safety. All preflight checks will be 

signed, dated and retained and available at the request of the FAA. 

PROPOSED UAS’S FOR EXEMPTION AND THEIR PHYSICAL DESCRIPTIONS 

Depending on our aerial imaging, environmental safety and/or atmospheric 

conditional needs, Aerial Solutions, LLC proposes to use the following models of 

sUAS’s in its business operations. At this time we formally request exemption for 

the: 

 DJI Phantom 3 Professional, 

 DJI Inspire 1 

 DJI Spreading Wings S900 

All of these types of sUAS have had precedent rotorcraft UAS Section 333 

exemption approval by the FAA. 

sUAS performance and safety technologies are quickly advancing, consequently we 

too must advance with them. Therefore, we respectfully request the approval to 

update our DJI series systems software and hardware when need be as long as 

they fit within the FAA’s sUAS size and weight parameters and follow all further 

imposed regulations. 
These are the latest models in their class from DJI, a worldwide leader in 

technologically advanced small rotorcraft, radio controlled (RC) aircraft. Each of 

the proposed models are equipped with highly advanced control and navigational 

features and fit within the prior safety requirements set forth by the FAA. The DJI 

sUAS aircraft feature a built-in stabilized HD camera and GPS safety features which 

limit its ability to limit the height it flies above ground level (AGL), to limit the 

radius of the distance it flies from the operator and to exclude it from operations 

within designated Class B, C and D airspace including a no-fly zone feature. The DJI 

Phantom and DJI Inspire 1 also have a failsafe function that is triggered in the 

event communication is lost between the sUAS and the main controller transmitter 

and secondary controller. At that time, the sUAS will return to its point of takeoff 

and land safety. If the connection is restored, the PIC can regain control of flight 

and land manually. 

The specifications of the proposed DJI models listed above meet with the Model 

Aircraft Operating Standards as set below: 

 Aerial Solutions, LLC will only operate its sUAS in line-of-sight of a pilot 

and/or observer and will operate at sites that are ‘sufficient distance’ from 

populated areas. Such operations will ensure that the sUAS will “not create a 

hazard to users of the national airspace system or the public.” 

 When flying an sUAS within three (3) miles of an airport, airport operators 

will be notified and the operator will give the right-of-way to avoid flying in 

the proximity of full-scale aircraft 

 Maximum flight time for each operation will be 30 minutes. 

 Flights will be terminated when battery levels reach 25%, allowing sufficient 

reserve flight time to safely land the sUAS. 

 All sUAS models operated by Aerial Solutions, LLC will be programmed so 

they are not operated at an altitude that exceeds 400 feet AGL, or more than 

200 feet above an elevated platform from which videography is planned. 

 The minimum crew for each operation shall consist of: sUAS pilot, and a 

sUAS visual observer. 

 The sUAS PIC will be an experience sUAS pilot 

 All sUAS models operated by Aerial Solutions, LLC weigh less than 25 

pounds, including all payloads (i.e. camera, lens, and stabilized gimbal). 

 All sUAS models operated by Aerial Solutions, LLC will operate at speeds of 

no more than 50 knots, can hover, and can simultaneously move vertically 

and horizontally. 

Given the small size of the sUAS and the restricted sterile environment within which 

it will operate, Aerial Solutions, LLC operations adhere to the Reform Act’s safety 

requirements. 

Included with this petition for exemption are the proposed flight safety guidelines, 

battery safety guidelines and maintenance manuals for the DJI Phantom Series, 

Inspire 1, and Spreading Wing S900 aircraft. Due to the large size data files of the 
pilot training manual and user manuals (exceeding the 10MB file maximum allowed 

for online submissions) and prior precedent exemption grants by the FAA for each 

proposed UAS, full user manuals (containing all specifications) are not included with 

this petition. 

They are available upon request or at the following website links: 

DJI Inspire 1: 

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manu

al_v1.0_en.pdf 

DJI Spreading Wings S900 

http://download.djiinnovations.com/downloads/s900/en/S900_User_Manual_v1.2_

en.pdf 

DJI Phantom 3 Professional: 

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professi

onal_User_Manual_v1.2_en.pdf 

UAS RADIO FREQUENCIES 

All devices used will comply with the FCC usage and emissions regulations and 

guidelines. The radio frequencies used will also comply with the allotted FCC 

frequencies for data transmission and vehicle control in unlicensed frequency 

bands. (More on radio frequencies provided on the specification/user manuals 

included with this petition.) 

BENEFITS TO THE PUBLIC 

Aerial Solutions, LLC is very excited to be a participant in such an extraordinary and 

electrifying new industry. As mentioned before, flight safety is of the highest 

importance and we are committed to comply with all regulations and guidelines. 

This new sUAS technology benefits both the environmental and economy on a level 

never before explored in the aerial imaging industry. Traditional methods of piloted 

aircraft for aerial imaging purposes have historically been extremely expensive and 

produce high levels of toxic emissions into the atmosphere, carry large payloads of 

flammable fuel and greatly increase the risk of human endangerment. 

Our small, lightweight, micro UAS’s run on rechargeable LiPo batteries and produce 

zero toxic emissions during flight. They’re highly controllable with advanced safety 

features for stabilization, GPS navigations, electronic speed controllers, autopilot 

safety modes and real-time data transmissions and recording. Overall, the use of 

the proposed sUAS’s greatly increases public safety as compared to conventional 

methods of aerial imaging. 
Under the requested exemption, Aerial Solutions, LLC ensures all operators have 

completed sUAS education and training programs including all applicable 

regulations and guidance documents; including aeronautical background 

information such as charts, NOTAMS and Aircraft Circulars; Radio Communications 

Procedures; Human Factors and Crew Resource Management; Basic sUAS 

Aerodynamics; Weather factors; Airmanship and Decision-making and Safe 

Operations Procedures. 

CONCLUSION 

The FAA has granted prior exemptions in circumstances similar in all material 

respects to those presented in this petition. Aerial Solutions, LLC respectively 

requests exemption under Section 333 to enable Aerial Solutions, LLC to operate 

efficient, limited, low-risk commercial sUAS operations for the activities stated 

within this petition. 

During every flight Aerial Solutions, LLC is committed to respecting the privacy of 

citizens and their property while operating safely within the national airspace 

system. 

Thank you for your consideration. 

Sincerely, 

Nicholas Pagerly 

Aerial Solutions, LLC 

21 Focht Rd 

Robesonia, PA 19551 

610-823-8922