Jeffrey Hall, Phoenix Aerial Imaging Page 1 

Jeffrey Hall 

Phoenix Aerial Imaging 

27 Michele Drive 

Portland, CT 06480 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590-0001 

October 19, 2015 

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 and Part 11 of the Federal 

Aviation Regulations. 

Dear Sir or Madam; 

In accordance with the Public Guidance for Petitions for Exemption filed under Section 333, I, Jeffrey

Hall of Phoenix Aerial Imaging request exemption from the Federal Aviation Regulations to allow for 

commercial sUAS (small Unmanned Aerial System) operations of the following: 

1. Spreading Wings DJI S900 

2. Kong FH800/PixHawk Hexacopter (equivalent to the DJI S900 in size, shape and operation) 

3. DJI Flamewheel 450 

4. HMF 580/PixHawk Quadcopter (similar to the DJI Flame wheel 450 in size, shape and operation) 

5. DJI Inspire 1 

6. DJI Phantom III 

7. 3DR Solo 

The above mentioned sUAS platforms would be useful for the purpose of aerial photography/remote 

sensing data collection of the following: 

• Local civil/commercial utility infrastructure including but not limited to electrical power lines, 

wind turbines, cell towers, bridges, highways and natural gas pipelines. 

• Real estate marketing, surveying and engineering projects. 

• Archeological studies. 

• Agricultural monitoring and mapping. 

• Estuarine coastal studies and mapping. 

• Provide assistance in local search and rescue operations in cases of emergency or natural disasters 

if local authorities request such help. 

• Aerial film making and photography. 

• Construction site inspections and monitoring. 

• Wildlife and forestry monitoring. 

I feel that the above mentioned and other flight operations could be performed safely and more cost 

effectively than with a traditional manned aircraft. 

 
Jeffrey Hall, Phoenix Aerial Imaging Page 2 

Name and address of applicant: 

Jeffrey Hall 

Phoenix Aerial Imaging 

27 Michele Drive 

Portland, CT 06480 

(860) 682-5472 

Attachments: 

1. sUAS User Manuals 

2. sUAS Safety Guidelines (AMA sUAS Flight Safety Guidelines) 

3. sUAS Maintenance Guidelines 

Regulations from which the exemption is requested: 

14 CFR 21, Subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b)(2) 

14 CFR 91.103 (b)(2) 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a)(l) 

14 CFR 91.409 (a)(l) & (a)(2) 

14 CFR 91.417 (a) & (b) 

14 CFR 21, Subpart H- In consideration of the size (less than 3feet in diameter), weight (approximately 

10 lbs), speed (less than 40 mph), and limited operating area associated with this sUAS and its operation, 

I request relief from 14 CFR part 21, Subpart H, and any associated noise certification and testing 

requirements of part 36. The sUAS will carry neither pilot, passenger, explosive materials nor flammable 

liquids. 

14 CFR 45.23 (b)- Even though the sUAS will have no airworthiness certificate, an exemption may be 

needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the N-Number 

can be placed. Given the size of the sUAS, two-inch lettering will be impractical. Markings (N-Number)

will be placed on the fuselage in as large a size as practiable in compliance with 14 CFR part 45, Subpart 

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

by §45.29 (f) where the pilot, observer and others working with the sUAS will see the identification of the 

sUAS. 

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)- Since the sUAS will not carry a pilot or passengers I 

request a relief from these regulations. Any pilot in command or (PIC) operating the sUAS will hold a 

Recreational Pilot (or greater) certificate. A visual observer or (VO) will be utilized and required to 

communicate verbally at all times. The sUAS will be limited to operations within visual line of sight of 

both the PIC and VO. All sUAS operations will take place in a controlled area with permission granted by 
Jeffrey Hall, Phoenix Aerial Imaging Page 3 

the client/property owner. The risks associated with the use of a sUAS are far less than similar 

commercial aircraft operations. 

14 CFR 91.7 (a)- Since the sUAS will not carry a pilot or passengers there will be no airworthiness 

certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard exists for 

determining airworthiness. Given the size of the aircraft, maintenance, and use of safety checklist prior to 

each flight, an equivalent level of safety will be provided. All flights will be in accordance with the safety 

and maintenance recommendations found in the attachments. 

14 CFR 91.9 (b)(2)- Given the size and configuration, the sUAS has no ability to carry a flight manual on 

the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An 

equivalent level of safety will be maintained by keeping the flight manual at the ground station where the 

sUAS pilot will have immediate access to it. 

14 CFR 91.103 (b)(2) - As no FAA approved flight manuals will be provided for the aircraft an 

exemption is needed. Alternate procedures including but not limited to reviewing weather conditions, 

checking flight battery requirements, checking takeoff and landing distances along with those found in the 

attached "AMA sUAS Flight Safety Guide" will be implemented. These actions will provide an 

equivalent or higher level of safety. 

14 CFR 91.109- sUAS and remotely piloted aircraft do not have fully functional dual controls. Flight 

control is achieved through the use of a control box that communicates with the aircraft via radio 

communications. An equivalent level of safety will be achieved using the real time ground station data

and given the sUAS will carry neither a pilot nor passengers. 

14 CFR 91.119 (c)- The sUAS will never be operated at an altitude higher than 400 feet above ground 

level (AGL). The sUAS will operate in safe areas away from public and traffic and only with permission

of the property and structure owners. The sUAS will also be restricted by the flight controller to a 

maximum vertical height of 400 feet AGL, and Visual Line of Sight horizontally. Given the size, weight, 

maneuverability and speed of the sUAS, an equivalent or higher level of safety will be achieved. 

14 CFR 91.121- As the sUAS may not have a barometric altimeter, but instead a GPS barometric sensor 

for altitude information an exemption may be required. An equivalent level of safety will be achieved 

using a ground station which links to a telemetry data link. This will provide the pilot with live flight data 

monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator prior to flight. 

14 CFR 91.151 (a)- The sUAS has a limited range and will be limited to operations in a controlled 

environment. The battery power for the UAS provides approximately 20 minutes of flight time. The 

sUAS is unable to meet the 30 minute reserve requirement and therefore requires an exemption. An 

equivalent level of safety will be achieved by monitoring the battery through the ground station and 

landing with a minimum of 30 percent battery power remaining. 

14 CFR 91.203 (a) & (b)- Given the size and configuration, the sUAS has no ability to carry a flight 

manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. 

An equivalent level of safety will be maintained by keeping the flight manual at the ground station where 

the sUAS pilot will have immediate access to it. 

Given the following sections only apply to aircraft with an airworthiness certificate, these sections do not 

apply to this applicant. As a safety precaution, the operator will perform preflight inspections and ensure 

sUAS is in working condition before initiating each flight: 
Jeffrey Hall, Phoenix Aerial Imaging Page 4 

14 CFR 91.405 (a) 

14 CFR 91.407 (a)(1) 

14 CFR 91.409 (a)(l) & (a)(2) 

14 CFR 91.417 (a) & (b) 

Equivalent Level of Safety 

In addition to the safety standards mentioned above the sUAS will adhere to the following additional 

guidelines: 

1. The sUAS will not be operated within 5 miles of an airport unless prior contact to Air Traffic 

Control has been established. 

2. Flights will not exceed an airspeed of 40 mph (34.8 knots). 

3. Flights will be operated at or below an altitude never exceeding 400 feet AGL. 

4. The PIC and VO will communicate verbally at all times. 

5. sUAS operations will not be conducted during night.

6. All operations will be conducted under visual meteorological conditions. 

7. The sUAS will land with a minimum 20 percent battery reserve remaining. 

8. The sUAS will only be piloted within visual line of sight. 

9. The sUAS will utilize an internal flight safety feature that will return to a preprogrammed 

position and land if communication with the remote control is lost. 

10. Preflight inspections and protocol will be followed prior to all operations. 

11. The sUAS PIC will abort flight in the event of unpredictable obstacles or emergencies. 

Public Interest 

I believe the use of a sUAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact compared to similar operations conducted with a manned aircraft carrying a crew 

and flammable fuel. The inspections of cellular communication towers, buildings, bridges or similar 

structures will eliminate the risks associated with persons attempting to climb these structures. The 

photographs and video collected will provide engineers with valuable information as to the safety of these 

structures. The monitoring of agricultural crops, archeological studies and mapping, and estuarine coastal 

studies and mapping could all benefit from the use of the sUAS as a mapping tool due to its ability to

perform safely and more cost effectively than with a traditional manned aircraft. The use of a sUAS in the 

real estate industry provides both the buyer and seller with a higher level of marketing and service. The 

sUAS is able to provide a view which encompasses the entire property in a single photo or short video 

clip. When compared to similar operations, utilizing a sUAS poses much less of a safety concern for the 

general public with less fuel, time, noise and other resources. 

Privacy 

All flights will occur over private or controlled areas with the owner's consent. Capturing people in 

images will rarely occur. If a person is captured in a collected image they will have consented prior to 

filming or otherwise have agreed to be in the area prior to the filming taking place. 

Sincerely, 

Jeffrey Hall 

Phoenix Aerial Imaging 
Attachments 
Attachment 1 

User Manuals 
Attachment 2

Safety Guidelines 

(AMA sUAS Flight Safety Guidelines) 

 
Attachment 3 

Maintenance Guidelines