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March 14, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition of A-I-M Imagery LLC for an Exemption Pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012

Dear Sir or Madam:

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

Act) and 14 C.F.R. Part 11, A-I-M Imagery LLC respectfully requests an exemption from several 

provisions of Title 14 of the Code of Federal Regulations (C.F.R.) to permit the use of unmanned 

aerial systems (UAS) for commercial filming, photography and inspections. 

A-I-M Imagery LLC will utilize unmanned aerial systems (UAS) for commercial 

applications to include but not limited to inspection of energy and utility infrastructures

including oil and gas pipelines, power lines, towers, wind turbines, surveying tasks, precision 

agriculture, cellular/radio antenna inspections, ranch and cattle operations, sport and athletic 

filming, search and rescue, real estate photography, Law Enforcement operations, and 

advertising and marketing. A-I-M Imagery LLC seeks to provide our clients with an alternative 

to conventional aircraft services, capturing data more quickly, accurately, economically, safely, 

and with reduced environmental impact. Operations under this exemption will be subject to strict 

operating requirements and conditions to ensure at least an equivalent level of safety to currently 

authorized operations using manned aircraft and under conditions as may be modified by the 

FAA as required by Section 333. Accordingly, the grant of an exemption is consistent with 

Congress’ intent, reflected in Section 333 of the FAA Modernization and Reform Act of 2012 

(Modernization Act), that safe systems be permitted in the national airspace prior to the issuance 

of final regulations governing general use of these systems. A summary of this request suitable 

for publication in the Federal Register is provided in section IX. Appendix A provides the 

manufacturers information regarding the design, aircraft performance, and features. We have 

provided manufacturer information related to operating limitations, normal and emergency

procedures, and maintenance and inspection procedures in the attachments. Also attached is A-IM’s UAS Operations Manual for flights covered under this Exemption Request. As we add 

aircraft designs, we will update all documentation appropriately.
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The contact information for Petitioner is as follows:

Alberto Velazquez

A-I-M Imagery LLC

Phone: 405-922-6300

Email: albert.velazquez@a-i-mfabrication.com

Address: 2408 Bellaire Dr.

 Moore, OK 73160

For your convenience, this Petition is organized as follows:

I. Description of Petitioner

II. Types of Operations

III. Relevant Statutory Authority

IV. A-I-M's Proposed UAS Operations Meet the Requirements of Section 333 of the

Reform Act

a. Approval is Warranted Based on the UAS's Size, Weight, Speed, and operational 

Capability

b. Approval is Warranted Based on the Operational Restrictions Set Forth in the 

Operations Manual

V. Regulations From Which Exemption is Sought

a. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 91.203

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

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

d. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. 

§ 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

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

Requirements

f. 14 C.F .R. § 91.103: Preflight Action

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

h. 14 C.F.R. § 91.119: Minimum Safe Altitudes

i. 14 C.F .R. § 91.121: Altimeter Settings

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

k. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections

l. 14 CFR § 61.113: Private Pilot Privileges and Limitations

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion

XI. Appendix A
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I. DESCRIPTION OF PETITIONER

A-I-M Imaging LLC is a full-service aerial photography, video, imaging, and inspection 

company that specializes in affordable aerial photography, agricultural mapping, virtual tours, 

and HD aerial video. We service many industries including energy and utility, commercial and 

residential real estate, construction, roofing contractors, movie and commercial production, and 

anyone in need of high-quality aerial drone photos, video, and media. We can carry large digital 

SLR and HD video cameras. We only use proven technology to provide the highest safety and 

quality services for our customers. What sets A-I-M apart is our safety & protection program. 

Pre-flight planning, inspections and checklists are part of every unmanned aerial photography

flight. While flying the aircraft, a member of the ground crew always has visual contact with the 

equipment. A thorough inspection of all equipment is conducted following each flight. We have 

years of experience with corporate quality and safety standards and apply them to every flight. 

Our pilots operate below 400 feet AGL (above ground level) and we take precautions to respect 

privacy. A-I-M will not conduct drone operations for one party to gather information about 

another party. We carefully plan each flight in advance to focus aerial photos or video on the 

subject of interest in order to maintain the privacy of others. All of our flights are conducted 

over property where we have the land owner’s permission. A-I-M seeks an exemption to 

continue our tradition of providing technologically driven and innovative solutions to solve 

important industry problems by using UASs for the commercial purpose of aerial photography, 

video, imaging, and inspection.

The contact information for Petitioner is as follows:

Alberto Velazquez

A-I-M Imagery LLC

Phone: 405-922-6300

Email: albert.velazquez@a-i-mfabrication.com

Address: 2408 Bellaire Dr.

 Moore, OK 73160

II. TYPES OF OPERATIONS

A-I-M	Imaging	desires	to	offer	aerial	videography	through	the	use	of	two	UASs	the	

Inspire 1	and	S1000	both	manufactured	by	DJI.	

The	Inspire 1	and	S1000	will	be	used	as	necessary for operations	such	as:
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 Oil pipeline inspections

 Gas pipeline inspections

 Solar installation inspections

 Detection of the spread of algae

 Power line / cable inspections

 Cooling tower inspections

 Critical infrastructure inspections

 Wind turbine inspections

 Bridge inspections

 Counting of animal populations

 Train line inspections

 Monument inspections

 Sport and athletic marketing

 Construction Progress Updates

 Golf Course Flyovers

 Agriculture Inspections

 Insurance Claim Adjustments

 Post-Disaster Documentation

 Industrial Security Surveys

 Cellular/Utility Towers

 Civic Special Events Promotion

 News and Accident Coverage

III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the

FAA Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA 

"to safely accelerate the integration of civil unmanned aircraft systems into the national airspace 

system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit

unmanned aircraft systems to operate in the National Air Space ("NAS") where it is safe to do so

based on the following considerations:

• The UAS's size, weight, speed and operational capability.

• Operation of the UAS in close proximity to airports and populated areas.

• Operation of the UAS within the visual line of sight (VLOS) of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the 

agency's safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 106 (f) (defining the authority of the

Administrator); 49 U.S.C. § 44701 (f) (permitting exemptions from§§ 4470l (a), (b) and §§ 

44702-44716, et seq.). A party requesting an exemption must explain the reasons why the 

exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or 

how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81

(Petitions for Exemption).
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IV. A-I-M'S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF

SECTION 333 OF THE REFORM ACT

A-I-M's proposed operations in this Petition for Exemption qualify for expedited approval 

pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors 

are satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and

Operational Capability

A-I-M will use the DJI Inspire 1 and DJI S1000 for the operations described in this

Petition for Exemption. These UASs have a take-off weight of less than 55 pounds including 

payload. The UAS will not be operated at an air speed greater than 87 knots (100 miles per hour) 

and in no case will the UAS be operated at airspeeds greater than the maximum UAS operating 

airspeed recommended by the aircraft manufacturer. These aircraft will not be flown in 

controlled airspace, and will be operated only in visual flight rules (VFR) conditions at an 

altitude of no more than 400 feet above ground level (AGL). All flights will be flown in such a 

way that they can be safely terminated with a reserve battery power of 25% of the battery's 

maximum charge. The DJI aircraft does not carry any flammable propellant or fuel. These UASs

also have an integrated GPS system that calculates the UASs position and height and relays that

information via a secure connection to the operator. All operations will utilize a visual observer 

(VO) and the UAS will be operated within the visual line of sight (VLOS) of the pilot in control 

(PIC) and VO at all times. As a further means of protection, the UAS contains a failsafe mode if 

its connection to the remote control is lost, and this system permits the UAS to return to a 

predetermined location and land without injury or damage. Prior to each flight, the PIC will 

conduct a pre-flight inspection and determine the UAS is in a condition for safe flight.

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the 

Operations Manual

Together, the A-I-M Operations Manual and the Manufacturer's Manuals contain all the

procedures and limitations necessary to successfully perform the operations specified in this 

Petition for Exemption. To assist the FAA in making a safety assessment of A-I-M's proposed 

operations, below is a summary of operational limitations and conditions that will ensure an 

equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The UAS weighs 55 pounds or less including payload.

2. Flights will be operated within the visual line of sight of a pilot and an observer, and well 

within the secure communication range of the controller.

3. Maximum total flight time for each operational flight will be limited to the amount of 

time the UAS can be flown and still maintain a reserve battery power of no less than 

25%.
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4. Flights will be operated at an altitude of no more than 400 feet AGL and will not be 

conducted within navigable controlled airspace without prior written authorization from 

the FAA.

5. Flights will be operated at a lateral distance of at least 500 feet from any persons,

inhabited structures, vehicles or vessels that are not involved in the inspection unless 

permission has been received and appropriate waivers have been signed by the persons or 

property owners in advance.

6. Flights will be limited to a speed less than 100 mph and vertical ascent will be limited to

15 mph.

7. Minimum crew for each operation will consist of a pilot, who will be Pilot-in

Command (PIC) of the UAS, and one or more Visual Observers (Observer) as necessary

to safely conduct the mission.

8. The Observer designated for any operation will be in constant voice contact with the 

pilot.

9. The UAS will be operated and maintained according to the Manufacturer's Manuals and 

any manufacturer Safety Bulletins.

10. Prior to the operation, there will be a Mission Plan setting forth the operational 

limitations and conditions for the mission, as well as key personnel contact information 

and a description of any potential hazards on or in the vicinity of the survey site.

11. A-I-M will file a Notice to Airman ("NOT AM") with an appropriate air traffic control 

("ATC") facility at least 72 hours before the flight.

12. A Certificate of Authorization ("COA'') will be obtained prior to flight.

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

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

agencies.

14. A-I-M will coordinate operations with the appropriate Flight Standards District Office 

("FSDO") at least 72 hours before the flight.

15. If the UAS loses communication with the pilot, it will have the capability to return to a 

pre-determined location within the operational area and land safely.

16. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the PIC and the Observer.

17. The U AS will have the capability to abort flight in the case of unpredicted obstacles or 

emergencies.
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18. The PIC of the UAS will have hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC will also hold a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by the state, or the Federal 

government. The PIC will also meet the flight review requirements specified in 14 CFR § 

61.56 in an aircraft in which the PIC is rated on his or her pilot certificate and hold at 

least a current Class III Medical Certificate.

19. Observers must have at least a current Class III Medical Certificate.

20. All UAS operations will occur in daylight, VFR conditions. UAS Operations under 

Instrument Flight Rules, at night, or beyond visual line of sight are prohibited.

V. REGULATIONS FROM WHICH EXEMPTION IS SOUGHT

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions.

This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined 

under§ 40101 of the Act, including UASs, from its safety regulations and minimum standards

when the Administrator decides a requested exemption is in the public interest. A-I-M seeks an 

exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61 and 91 for purposes 

of conducting the requested operations using a UAS. Listed below are: (1) the specific sections 

of 14 C.F.R. for which exemption is sought, and; (2) the operating procedures and safeguards 

that Petitioner has established which will ensure a level of safety better than or equal to the rules 

from which exemption is sought. 

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. §

91.203(a)(1)

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.

Equivalent Level of Safety

The UASs selected by A-I-M are safe when taking into account their size, weight, speed, 

and operational capability. As set forth in Section II, supra, the UAS weighs less than 55 pounds 

and will be flown at less than 100 mph. Additionally, the UASs carry neither pilots nor 

passengers, carry no explosive materials or flammable liquid fuels, and operate exclusively

within the parameters stated in the Operations Manual. Operations conducted under this 

exemption will be closely controlled and monitored by the operator and will be conducted in 
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compliance with local public safety requirements, to provide security for the area of operation. 

A-I-M will also provide the FAA with advance notice of all operations via NOTAMs and 

coordination with the local FSDO. In all cases 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. See Grant of Exemption, Docket FAA-2014-0352 at 13. In addition, no 

sense-and-avoid technology is necessary on the UAS because it will be operated at all times in 

VFR conditions and within visual line of sight. 

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

Rotorcraft

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

category rotorcraft. To the extent the Petitioner's UAS would otherwise require certification 

under Part 2, 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, supra.

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

A-I-M’s	aircraft	will	be	registered	but	will	not	require	an	airworthiness	certificate	as

contemplated	by	traditional	means.	A-I-M 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 Section 

91.7 be treated in accordance with Section V(A), supra.

D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and

Registration

Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft-

(2) For which an Airplane or Rotorcraft Flight Manual is required by§ 21.5 of this chapter, 

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.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it 

the following:

(1) An appropriate and current airworthiness certificate ...
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(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section 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.

Given the small size and configuration of the UAS, it would be impossible to keep

airworthiness documents and other aircraft manuals on board the UAS because there is simply no 

room. Also the UAS has no cabin or cockpit.

Equivalent Level of Safety

As acknowledged in an FAA Office of Chief Counsel's Opinion dated August 8, 2014, prepared 

by Dean E. Griffith, Attorney, AGC-220, the intent of 14 C.F.R. 91.9(b) and 91.203(a) and (b) is 

met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration 

certificate, and other required documents from the ground control station from which he or she is 

operating the aircraft. The intent of the ru1e is to ensure the pilot has access to these key

documents during flight. Therefore, an equivalent level of safety will be achieved by ensuring 

the pilot has access to the documents at the ground control station from which he or she is 

piloting the UAS.

E. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and

Identification Requirements

A-I-M seeks an exemption from the aircraft marking and identification requirements 

contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

• 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, 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.

• 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

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.

• 14 C.P.R. § 45.27(a), Rotorcraft, states:

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 
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C.F.R Part 45, Subpart C if the markings are as large as practicable."FAA Docket No. 

FAA-2014-0352.

Equivalent Level of Safety

A-I-M will mark all UAS with their N-Number on the fuselage. The markings will be

made as large as feasible. 

F. 14 C.F.R. § 91.103: Preflight Action

A-I-M seeks an exemption from 14 C.P.R.§ 91.103, which requires a PIC to become 

familiar with specific information before each flight, including information contained in the 

FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all

information necessary to safely conduct the flight, an exemption is requested to the extent that an 

FAA-approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the A-I-M Operations Manual 

and the Manufacturer's Manuals. The PIC will take all required preflight actions - including 

performing all required checklists and reviewing weather, flight requirements, battery charge, 

landing and takeoff distance, aircraft performance data, and contingency landing areas before 

initiation of flight. The Operations Manual and the Manufacturer's Manuals will be kept at the 

ground control station and will be accessible to the PIC at all times while operating the UAS.

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

A-I-M seeks an exemption from 14 C.P.R.§ 91.109(a), which provides 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." UASs and remotely piloted aircraft, by

their design, do not have functional dual controls. Instead, flight control is accomplished through 

the use of a device that communicates with the aircraft via radio communications.

Equivalent Level of Safety

Given the size and speed of the UAS that A-I-M intends to use, an equivalent level of safe 

training can still be performed without dual controls because no pilot or passengers are aboard 

the UAS, and as required by the Operations Manual, all persons will be a safe distance away in 

the event that the UAS experiences any difficulties during flight instruction. Moreover, Petitioner 

will conduct flight operations at sites in which are located on property it owns, leases or controls. 

As required by the Operations Manual, these flights operations will be conducted in controlled 

and sterile areas where only persons who are participating in the work will be permitted. As a 

whole, the safety procedures provided for in Petitioner's Operations Manual ensure that the 
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proposed UAS operations provide an equivalent or higher level of safety than the flight 

instruction regulations.

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes

A-I-M requests an exemption from the minimum safe altitude requirements of 14 C.F.R.

§ 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not 

operate, including 500 feet above the surface and away from any person, vessel, vehicle, or 

structure in non-congested areas. See 14 C.P.R.§ 91.119(c). Section 91.119(d) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated "without 

hazard to persons or property on the surface," provided that "each person operating the helicopter

complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

An exemption is required because in order to perform the intended aerial surveys and 

inspections, the UAS will need to be operated lower than 400 feet AGL. Further, due to the 

nature of the proposed operations, the PIC and Observer(s) may at times be less than 500 feet 

away from the UAS.

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum

weights proposed herein, and given the lack of flammable fuel with the UASs, any risk 

associated with these operations is far less than those that presently exist with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the

UASs, as well the controlled and sterile location where the operations will occur. In order to

avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL or below.

As set forth in the Operations Manual, the UASs will be operated in a restricted area, away from 

persons or structures not involved in the operation.

I. 14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F .R. § 91.121, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that 

is set to the elevation of the departure airport or barometric pressure. An exemption is required to 

the extent that the UASs do not have a barometric altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F .R. §

91.121 can be achieved in circumstances where: (1) the UASs will be operated at 400 feet AGL 

or below, (2) within visual line-of-sight, (3) where GPS based altitude information is relayed in 

real time to the operator at a ground-based on-screen display and, (4) where prior to each flight, a 

zero altitude initiation point is established for the PIC to confirm accuracy of the onboard GPS.

See Grant of Exemption to Astraeus Aerial, Docket No. FAA-2014-0352 at 21. As the attached 

Operations Manual demonstrates, the UASs A-I-M intends to use meet these requirements. 

Moreover, our operating procedures require that a zero altitude initiation point be obtained prior 
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to flight. The UASs we intend to use, and the safety procedures contained in our Operations 

Manual, both ensure that an equivalent level of safety will be achieved, and a grant of exemption 

to the requirements of § 191.121 is therefore appropriate.

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

Conditions

A-I-M requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in 

VFR conditions. Section 91.151 states: (a) No person may begin a flight in an airplane under 

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 - (1) During the 

day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 

minutes. Here, the technological limitations on UAS battery power means that no meaningful

flight operations can be conducted while still maintaining a 30-minute battery reserve. An

exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety can be achieved by requiring that

each UAS operation be completed within 30 minutes flight time or with 25% battery power 

remaining, whichever occurs first. See Grant of Exemption to Astraeus Aerial, Docket No.

FAA-2014-0352. The Operations Manual conforms to this limitation, and therefore provides an 

equivalent level of safety.

K. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b):

Maintenance Inspections

A-I-M seeks an exemption from the maintenance inspection requirements contained in

14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. §

91.405(a) (stating that each owner or operator of an aircraft "shall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ... have discrepancies 

repaired as prescribed in part 43 of this chapter"). An exemption from these regulations is needed 

because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which 

the UAS will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the Manufacturer's Manuals and any applicable manufacturer 

Safety Bulletins. Further, as required by the Operations Manual, flights will not be conducted 

unless a pre-flight checklist covering all flight critical components of the UAS has been 

completed. The Operations Manual also contains recordkeeping requirements for routine, 

interval and post-flight maintenance. As a whole, the maintenance and inspection procedures in 

the Operations Manual ensure that an equivalent level of safety will be achieved.
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L. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Petitioner seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate

holders from flying aircraft for compensation or hire, and would also require a second class 

medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC 

matches the airspace in which the PIC will be operating, as well as requiring certifications if the 

private pilot is carrying passengers or cargo for hire. In this case, while the UASs will be 

operated as part of a commercial operation, it carries neither passengers nor cargo. In the Grant 

of Exemption to Astraeus Aerial (FAA Docket No. FAA-2014-0352), the FAA determined that 

the unique characteristics of UAS operation outside of controlled airspace did not warrant the 

additional costs and restrictions attendant with requiring the PIC to have a commercial pilot 

certificate and Class II Medical Certificate. The restrictions A-I-M has placed on its UAS 

operations meet or exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket 

No. FAA-2014-0352. A-I-M will only perform UAS operations in controlled and sterile areas 

away from persons and property not involved in the operation. The UASs will be flown based on 

visual line of sight at 400 feet AGL or below. Moreover, a NOT AM will be issued between 48 

and 72 hours before the flight is to occur, and the flight will be conducted in coordination with 

the applicable FSDO.

Equivalent Level of Safety

In addition to these flight restrictions, A-I-M will further ensure safe operation by

requiring that any PIC be thoroughly versed not only in airspace and communication 

requirements of Part 91 applicable to all aircraft, but also in the unique aspects of UAS flight.

Petitioner's pilots will be required to maintain an understanding of all normal, abnormal and 

emergency procedures of the UAS he or she is operating. Pilots will also be required to 

accumulate and log, in a manner consistent with 14 C.F.R. § 61.5l(b), a minimum of 200 flight 

cycles and 25 hours of total time as a UAS rotorcraft pilot, and at least 10 hours piloting the UAS 

used to perform operations under this exemption. Petitioner's pilots will also be required to log at 

least 3 takeoffs and landings of the UAS used to perform operations under this exemption.

The pilot currency requirements in our Operations Manual also require the pilot to have 

conducted at least 3 launch and recovery operations, and have accrued at least 5 hours of flight 

time with the UAS in the preceding 90 days to be considered current. The Operations Manual, 

including it pilot qualification, training, and currency requirements, ensure that our pilots are 

competent and proficient in the UAS they are operating. These procedures ensure that an 

equivalent or higher level of safety will be achieved.

VI. DRUG AND ALCOHOL PROGRAM

A-I-M has policies in place to ensure that no person may participate as a member of the flight 

team if they are under the influence of alcohol or any non-prescribed drugs or prescribed drugs 

that prevent operation of a motor vehicle.
14

VII. PUBLIC INTEREST

The public interest will be served by granting A-I-M’s Petition for Exemption. Congress has 

established a national policy that favors early integration of UAS into the National Airspace 

System ("NAS") in controlled, safe working environments such as those proposed in this 

Petition. Granting this Petition for Exemption helps fulfill Congress' goal in passing Section 

333(a) through (c) of the Reform Act-the FAA Administrator's assessment of whether certain

UAS may operate safely in the NAS before completion of the statutorily required rulemaking.

The proposed UAS operations in this Petition for Exemption significantly improve safety and 

reduce risk by alleviating the public's exposure to danger and emissions associated with 

traditional cinematography, aerial survey, and inspection methods, namely, full size fixed-wing 

aircraft and rotorcraft. The UASs A-I-M intends to use are battery powered and create no 

emissions. Moreover, in the unlikely event that one of Petitioner's UASs crash, there is no fuel to 

ignite and explode. Any accident involving Petitioner's lightweight UASs will present 

significantly less danger to the pilot and other individuals on the ground than one involving a full 

size helicopter. The public as a whole will benefit from the services that A-I-M provides. 

Infrastructures such as pipelines and transmissions lines will be monitored for operation or rapid 

trouble shooting should repairs be needed. Large real estate will benefit from high definition 

aerial views of facility integrity. New and unique marketing and advertising promotions will help 

to stimulate local business and community growth. 

VIII. PRIVACY

All A-I-M UAS operations shall be conducted in accordance with applicable federal, state, or 

local laws regarding privacy. A-I-M will not conduct flight operations over property that it does 

not own or control without the prior consent and knowledge of the property owner. Moreover, AI-M will not capture or use images from neighboring properties within the vicinity of UAS flight 

operations.

IX. FEDERAL REGISTER SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal

Regulations:

Part 21 , Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c);

91.103; 91.109(a); 91.119; 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1);

91.409(a)(2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the general public and property owners 

from the substantial hazards associated with performing equivalent cinematography, aerial 

surveys, and inspections with conventional fixed-wing aircraft, rotorcraft, or other methods.
15

X. CONCLUSION

A-I-M Imagery LLC’s Petition for Exemption satisfies the criteria articulated in Section 333 

of the Reform Act of 2012 including weight, speed, operating capabilities, proximity to airports 

and populated areas, operation within visual line of sight and national security. The proposed 

UAS operations will benefit the public as a whole by improving safety and reducing risk by

alleviating human exposure to danger. The public also benefits from improving the quality and 

cost effectiveness of comparable cinematography, aerial surveys, and inspections completed with 

conventional flight operations. In consideration of the foregoing, the Petition provides the FAA 

with more than adequate justification for granting of the requested exemptions allowing A-I-M 

to perform inspections of energy and utility infrastructures including oil and gas pipelines, power 

lines, towers, wind turbines, surveying tasks, precision agriculture, cellular/radio antenna 

inspections, ranch and cattle operations, sport and athletic film, search and rescue, real estate 

photography, Law Enforcement operations, and advertising and marketing with this Petition and 

the attached Operations Manual. Thank you for your time and consideration we look forward to 

the opportunity to provide our customers with safe and legal services outlined by the Department 

of Transportation.

Respectfully, 

Alberto Velazquez

Owner Operator

A-I-M Imagery LLC
16

XI. APPENDIX A.

 DJI INSPIRE 1

AIRCRAFT

Model T600

Weight (Battery Included) 2935 g

Hovering Accuracy (GPS mode) Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea 

Level

4500 m (Default altitude limit: 120 m above takeoff 

point)

Max Wind Speed Resistance 10 m/s
17

Max Flight Time Approximately 18 minutes

Motor Model DJI 3510H

Propeller Model DJI 1345T

Indoor Hovering Enabled by default

Operating Temperature Range -10° to 40° C

Diagonal Distance 559 to 581 mm

Dimensions 438x451x301 mm

Power Spectral Density 9.06mW/MHz

REMOTE CONTROLLER

Name C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Maximum Transmitting 

Distance

Up to 5 km or 3.1 miles (unobstructed, free of 

interference) when FCC compliant

Up to 3.5 km or 2.1 miles (unobstructed, free of 

interference) when CE compliant

EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port USB, mini-HDMI

Power Supply Built-in battery

Charging DJI charger

Dual User Capability Host-and-Slave connection

Mobile Device Holder Tablet or Phone

Max Mobile Device 

Width 170mm

Output Power 9 W

Operating Temperature 

Range -10° to 40° C

Storage Temperature 

Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature 

Range 0-40° C

Battery 6000 mAh LiPo 2S

BATTERY 

Name Intelligent Flight Battery

Model TB48

Capacity 5700 mAh

Voltage 22.8 V

Battery Type LiPo 6S

Energy 129.96 Wh

Net Weight 670 g
18

Operating Temperature Range -10° to 40° C

Storage Temperature Range Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range 0° to 40° C

Max Charging Power 180 W

 DJI S1000

FRAME

Diagonal Wheelbase 1045mm

Frame Arm Length 386mm

Frame Arm Weight

(Including Motor, ESC, Propeller ) 325g

Center Frame Diameter 337mm

Center Frame Weight (with Landing Gear 

Mounting Base, Servos) 1520g

Landing Gear Size 460mm(Length)×511mm(Width)×305mm(Height)

MOTOR
19

Stator Size 41×14mm

KV 400rpm/V

Max Power 500W

Weight(with Cooling Fan) 158g

ESC

Working Current 40A

Working Voltage 6S LiPo

Signal Frequency 30Hz ~ 450Hz

Drive PWM Frequency 8KHz

Weight(with Radiators) 35g

FLIGHT PARAMETERS

Takeoff Weight 6.0Kg ~ 11.0Kg

Total Weight 4.4Kg

Power Battery LiPo (6S,10000mAh~20000mAh,15C(Min))

Max Power Consumption 4000W

Hover Power Consumption 1500W (@9.5Kg Takeoff Weight)

Hover Time 15min (@15000mAh & 9.5Kg Takeoff Weight)

Working Environment Temperature -10 °C ~ +40 °C

(The following attached items contain proprietary and commercial information exempt from 

disclosure under the Freedom of Information Act 5 U.S.C. § 522 et eq., and should be held in a 

separate file pursuant to 14 C.F.R. § 11.35(b)).

Attachment A: The A-I-M Imagery UAS Operations Manual

Attachment B: DJI Inspire 1 User Manual

Attachment C: DJI Smart Flight Battery Safety Guidelines

Attachment D: DJI S1000 User Manual