U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590 

Petition for Exemption Under 14 CFR § 11.81 to Allow Commercial 

Use of Unmanned Aircraft Systems 

Petitioner: 

DRONE AERIAL PHOTO & VIDEO 

CHRISTOPHER GRUSZCZYNSKI 

840 5th ST. SAN LEON, TX.77539 

Email: droneaerialphotovideo@yahoo.com 

Ph.832 446 2200 

To Whom It May Concern, 

This application is substantially based on the FAA's findings in Exemption No. 11351 granted to 

bizUAS Corp on Apri117, 2015, and in reliance on the analysis provided therein. 

1. Sections from which exemptions are sought: Application is hereby made for exemption 

from: 

a. FAA Modernization and Reform Act of2012, PL 112-95 FEB. 14, 2012, Section 

333 

b. 14 CFR Part 21, subpart H 

c. 14 CFR Part 61.113(a) and (b) 

d. 14 CFT Part 91: 

1. 91.103(b)(2) 

11. 91.105 

111. 91.109 

iv. 91.119 

v. 91.121 

VI. 91.151 

Vll. 91.405 

viii. 91.407 

IX. 91.409 

X. 91.417 

2. Relief sought: 

a. Drone Aerial Photo & Video wishes to operate small Unmanned Aircraft 

Systems (sUAS) for commercial purposes to include (but not be limited to) 
videography, cinematography, photogrammetry, industrial inspections and 

analyses. This relief is sought because commercial use of s UAS is currently 

prohibited by law unless performed under an exemption. 

b. This exemption will cover use of the following airframes, all of which will weigh 

less than 55 pounds including payload and energy sources: 

1.DIJ Phanthom 3 Professional 

2.DIJ lnspire1 

Other models to be added by future amendment to this exemption. 

3. Public benefit: 

a. Use of sUAS technology to obtain imagery, information and data currently 

obtained by use of manned flight or manual methods: 

1. Reduces statistical risk to human life due to manned aircraft accidents 

(e.g., power line inspections) and due to other dangerous activities that 

can be avoided (e.g., scaffolding/rigging failures during stack or bridge 

inspections). 

ii. Reduces the cost of obtaining such information, which benefits 

consumers and the economy. 

111. Reduces environmental impact by eliminating sources of hydrocarbon 

emissions from manned aircraft. 

4. Safety not adversely affected: 

a. Aircraft will be registered and marked in accordance with Section 44 711 and Part 

47 and Part 45, Subpart C. 

b. Aircraft will comply with maintenance and inspection requirements of the 

manufacturer. All repair and maintenance work will be conducted or approved by 

qualified personnel such as those authorized by Robotic Skies (or equivalent), and 

will require a test flight after such work. Records of all maintenance and repair 

work will be kept in a maintenance log for each aircraft. 

c. All flight operations will be conducted by at least two individuals (PIC and 

observer) who will maintain verbal communication capability with each other at 

all times during the flight, and who will remain stationary on the ground during 

the flight operations: 

1. A Pilot In Command (PIC) who possess the following credentials:· 

1. An Airman Certificate issued under 14 CFR 61 (private pilot 

license) screened by the TSA 

2. A Third Class medical certificate issued under 14 CFR 67. 

3. A bi-annual flight review under 14 CFR 6i.56 

4. A certificate of competency for UAS issued by UMEX (or 

equivalent certification). 

5. At least 200 cycles and 25 hours of flight experience in a UAS 

rotorcraft (or UAS fixed-wing in the case of fixed-wing flight 

operations under this exemption). Such cycles and hours may be 

gained during flights under this exemption if a safe distance is 

maintained from persons in accordance with 14 CFR 91.119. 

6. At least 5 hours of flight experience and 3 takeoffs and landings in 

make and model being flown in the prior 90 days. Such cycles and 
hours may be gained during flights under this exemption if a safe 

distance is maintained from persons in accordance with 14 CFR 

91.119. 

n. A Visual Observer. 

m. A Sensor Operator as necessary. 

d. All flight operations will be conducted in accordance with valid Certificates of 

Authorization. 

e. All flight operations will comply with the following: 

1. The manufacturers' Aircraft Flight Manuals and Operation Guideline 

2. Drone Aerial Photo & Video flight opt~rations policies including lost 

communication and other emergency and safety procedures. 

3. Conducted in VMC conditions duringdaylight hours. 

4. PIC and VO will maintain VLOS at all times. 

5. Pre-flight inspections (including ground control station, if any) and sa 

fety risk assessments will be conducted prior to each flight. 

6. Flight altitudes will remain below 400 feet above ground level. 

7. Flight ground speeds will not exceed 50knots. 

8. Not intrude into Class B, CorD airspace, or published approach, SID or 

STAR, or take place within 5 nautical miles of an airport. 

9. Not be made near persons as required in 14 CFR 

91.119 persons on the ground without their permission 

1 0 .Each flight will be logged in both the PIC's logbook and the aircraft 

logbook. 

11. Not exceed 75% of the batte1y or fuel capacity of the aircraft, or 30 

minutes, whichever occurs first. 

12. Any incidents will be reported to NTSB within 24 hours of occurrence. 

13. Drone Aerial Photo & Video will maintain liability insurance of at 

least $1,000,000 issued by a major aviation insurance underwriter. 

14. Any applicable local FSDO requirements. 

15. All other applicable regulations concemed with the operation of aitcraft. 

f. Aircraft will use 2.4 GHz for control of the aircraft, and 5.8 GHz for sending data 

with well- defined and tested lost link procedures. 

Please advise us of any additional information or changes that may be required. 

Sincerely, 

Christopher Gruszczynski 

CEO Drone Aerial Photo & Video 

07/10/2015