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March 14 , 2016 U.S. Department of Transportation Docket Management Sy stem 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 Moderni zation and Reform Act of 2012 ( Reform Act) and 14 C.F .R. Part 11, A - I - M Imagery LLC respectfull y 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 s ys tems (UAS) for commercial filming, photography and inspections . A - I - M Imagery

LLC will utilize unmanned aerial sy stems (UAS) for commercial applications to include but not limited to inspection of energy and utility infrastructure s including oil and gas pipelines , power lines, towers, wind turbi nes, surveying tasks, precision agriculture, cellular/radio antenna inspections, ranch and cattle operations, sport and athletic film ing , search and rescue, real estate photography , L aw 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 quickl y, accurately , economically , safel y, 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 currentl y authorized o perations using manned aircraft and under conditions as may be modified by

the FAA as required b y Section 333. Accordingl y, 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 s ys tems be permitted in the national airspace prior to the issuance of final regulations governing general use of these sy stems. A summary of this request suitable for publ ication 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 em ergency procedures, and maintenance and inspection procedures in the attachments . Also attached is A - I M’s UAS Operations Manual for flights covered under this Exemption Request . As we add aircraft designs, we will update all documentation appropriatel y.2

The contact informatio n for Petitioner is as follows: Alberto Velazquez A - I - M Imagery

LLC Ph one : 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. Ty pes 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 o perational 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 Airworthi ness 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): CarryingCivil 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 A3

**I. DESCRIPTION OF PETITIONER**  A - I - M Imaging LLC is a full - service aerial photograph y, video, imaging, and inspection compan y 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. W e 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 alway s has visual contact with the equipment. A thorough inspection of all equipment is conducted following each flight. We have ye ars 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 in formation 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 other s. 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 traditio n of providing technologically driven and innovative solutions to solve important industry

problem s 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 Ph one : 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	use d	as	necessary for operations	such	as :4

 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 Fl yovers  Agriculture Inspectio ns  Insurance Claim Adjustments  Post - Disaster Documentation  Industrial Security Surveys  Cellular/Utility

Towers  Civic Special Ev ents 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 s ys tems into th e national airspace sy stem." Pursuant to Section 333 of the Ref orm Act, the FAA Administrator is to permit unmanned aircraft s ys tems 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, s peed 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 Adm inistrator); 49 U.S.C. § 44701 (f ) (permitting exemptions from§§ 4470l (a), (b) and §§ 44702 - 4471 6, 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 f

or E xemption).5

**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 DJ I Inspire 1 and DJ I S1000 for the operations described in this Petition for Exemption. The s e UAS s hav e a take - off weight of less than 5 5 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 UA S be operated at airspeeds greater than the maximum UA S operat ing airspeed recommended by the aircraft manufacturer. These aircraft will not be flown in controlled airspace, and will be operated onl y 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 do es not carry any flammable propellant or fuel. The se UAS s also have an integrated GPS system that calculates the UAS s position and height and relay s that information via a secure connection to the operator. All operations will utilize a visual observer (VO) and the UAS will be operated with in the visual line of sight (VLOS) of the pilot in control ( PI C ) 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 sy stem permits the UAS to return to a predete rmined 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 Operat ional 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 5 5 pounds or less including payload . 2. Flights will be operated within the visual line of si ght 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 am ount of time the UAS can be flown and still m aintain a reserve battery power of no less than 25%.6

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 appropri ate waivers have been signed b y 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 ( PI C ) of the UAS, and one or more V isual Observers (Observer) as necessary to safel y 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 s etting forth the operational limitations and conditions for the mission, a s 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 ob tained 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 an d land safel y. 16. Contingency

plans will be in place to safel y terminate flight if th ere is a loss of communication between the PI C and the Observer. 17. The U AS will have the capability to abort fl ight in the case of unpredicted obstacles or emergencies.7

18. The PI C 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 PI C is rated on his or her pilot certificate and hold at least a current Class III Medical Certificate. 19. Observers must have at lea st 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 min imum standards when the Administrator decides a requested exemption is in the public interest. A - I - M seeks an exemption from several i nterrelated provisions of 14 C.F .R. Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using a UA S. L isted 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 applicati on. These criteria are met, and therefore no exemption is needed. See Grant of Exemption to A straeus Aerial, Docket No. FAA - 2014 - 0352 at 13 - 14, 22. If, however, the FAA determines that th ere 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 i nto account their size, weight, speed, and operational capability . As set forth in Section II, supra, the UAS weighs less than 5 5 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 clos ely controlled and monitored by the operator and will be conducted in8

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 coordinatio n with th e 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 PI C and Observer, who are not onboard. See Grant of Exemption, Docket FAA - 2014 - 0352 at 13. In a ddition, 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 Petitione r'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 exempti on 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. Accordingl y, Petitioner requests that the requirements for Section 91.7 be tre ated 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 b y§ 21.5 of this chapter, unless there is available in the aircr aft a current approved Airplane or Rotorcraft Flight Manual, approved manual materi al, markings, and placards, or an y 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 ...9

(b) No person may

operate a civil aircraft unles s the airworthiness certificate required b y paragraph (a) of this section or a spec ial 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 a ccess 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 b y 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 4 5.27(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 civi l 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 o r light - sport category aircraft or experimental or provisionally

certificated aircraft, the operator must also display on that aircraft ne ar each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inch es 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 deter mined that exemption from these requirem ents was warranted provided that the aircraft "have identification (N - Number) markings in accordance with 1410

C.F.R Part 45, Subpart C if the marking s 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 informatio n contained in the FAA - approved Flight Manual on board the aircraft. While the PI C will be familiar with all information necessary

to safel y conduct the flight, an exemption is requested to the extent that an FAA - app roved 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 Manu facturer's Manuals wil l be kept at the ground control station and will be accessible to the PI C 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 "n o 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 contr ols." UASs and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight co ntrol 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 bec ause 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 i nstruction. Moreover , Petitioner will conduct flight operations at sites in which are located on property it owns, leases or controls. As required b y the Operations Manual, these flights operations will be conducted in controlled and sterile areas where only persons wh o are p articipating in the work will be permitted . As a whole, the safety

procedures provided for in Petitioner's Operations Manual ensure that the11

proposed UAS operations provide an equiv alent 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 altitud es under which aircraft may not operate, including 500 feet abov e the surface and away from an y 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 survey s and inspections, the UAS will need to be operated lower than 40 0 feet AGL. Further, due to the nature of the proposed operations, the PI C 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 flammabl e fuel with the UASs, any risk associated with these operations is far less than those that presentl y exist with conventional aircra ft. 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 an y 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 exemp tion 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 pre ssure. An exemption is required t o 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 w ill be operated at 400 feet AGL or below, (2) within visual line - of - sight, (3) where GPS based altitud e 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 PI C 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 prior12

to flight. The UASs we intend to use, and the safety procedures contained in our Operati ons Manual, both ensure that an equivalent level of safety will be achieved, and a grant of ex emption 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 con ditions. Section 91.151 states: (a) No person may begi n 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 fl y after that for at least 30 minutes; or (2) At night, to fly afte r 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 S**

**afety** 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 exe mption 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 "s hall have the aircraft inspec ted 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 e xemption from these regulations is needed because Part 43 and these sections only appl y 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 app licable manufacturer Safety Bulletins. Further, as required by the Operations Manual , flights will not be conducted unless a pre - flight checklist coverin g all flight critical components of the UAS has been completed. The Operations Manual also contains recordke eping requirements for routine, interval and post - flight maintenance. As a whole, the maintenan ce and inspection procedures in the Operations Manual ensure that an equivalent level of safety will be achieved.13

**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 fl yi ng aircraft for compensation or hire, and wo uld also require a second class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of an y P IC matches the airspace in which the PI C will be operating, as well as requiring certifications if th e private pilot is carrying passengers or cargo for hire. In th is case, while the UASs will be operated as part of a commercial operation, it carrie s 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 pers ons 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 P IC be thoroughl y versed not onl y 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 an d 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 pilo ts 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 reco very operations, and have accrued at least 5 hours of fli ght time with the UAS in the preceding 90 day s to be considered current. The Operations Manual, including it pilot qualification, training, and currency requireme nts, ensure that our pilots are compe tent 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 drug s or prescribed drugs that prevent operation of a motor vehicle .14

**VII. PUBLIC INTEREST**  The public interest will be served b y granting A - I - M’s Petition for Exemption. Congress has established a national policy that favors earl y integration of UAS into the National Airspace Sy stem ("NAS") in controlled, safe working environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill Co ngress' 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 Exempti on 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, namel y , full size fixed - wing aircraft and rotorcraft. Th e UASs A - I - M intends to use are battery p owered 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 signific antl y less danger to the pilot and other individuals on the ground than one involving a full size helicopter. The pu

blic as a whole will benefit from the services that A - I - M provides. In frastructures such as pipeli nes and transmissions lines will be monito red 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. P**  **RIVACY** 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, A I - M will not capture or use images from neighboring properties within the vicinity o f 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) ; 6 1.113; 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 b y reducing risk to the general public and property owners from the substantial hazards associated with performing equivalent cinematography , aerial survey s, and inspection s with conventional fixed - wing aircraft, rotorcraft, or other methods.15

**X. CONCLUSION**  A - I - M Imagery

LLC’s Petition for Exemption satisfies the crite ria articulated in Section 333 of the Reform Act of 2012 including weight, speed, operating capabili ties, 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 e ffectiveness of comparable cinematograph y, aerial survey s, and inspection s completed with convent ional flight operations. Inconsideration 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 inspection s of energy and utility infrastructure s including o il and gas pipelines , power lines, towers, wind turbi nes, surveying tasks, precision agriculture, cellular/radio antenna inspections, ranch and cattle operations, sport and athletic film , search and rescue, real estate photograph y , Law Enforcement operations, and advertising and marketing w ith 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 o f Transportation. Respectfully , Alberto Velazquez Owner Operator A -I - M Imagery LLC16

**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/s17

Max Flight Time Approximately 18 minutes Motor Model DJI3510H Propeller Model DJI1345T Indoor Hovering Enabled b y 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 L iPo 2S **BATTERY** Name Intelligent Flight Battery Model TB48 Capacity 5700 mAh Voltage 22.8 V Battery Ty pe LiPo 6S Energy 129.96 Wh Net Weight 670 g18

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 L anding Gear Mounting Base, Servos) 1520g Landing Gear Size 460mm(L ength)×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 L iPo 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 fi le pursuant to 14 C.F.R. § 11.35(b)). **Attachment A**  : The A - I - M Imagery UAS Operations Manual **Attachment B:** DJ I Inspire 1 User Manual **Attachment C**  : DJ I Smart Flight Battery Safety Guidelines **Attachment D:** DJ I S1000 User Manual