Crescent Aerial Imaging LLC 

2245 Beck St. New Orleans, La 70131 

Phone: 504-577-1147 

E-Mail: crescentaerialimaging@gmail.com

9 July, 2015

U.S. Department of Transportation, Docket Operations

Federal Aviation Administration

West Building Ground floor, Room W12-140

1200 New Jersey, Avenue, SE,

Washington DC 20590

Subject: Petition for exemption of applicable requirements of title 14, Code of Federal 

Regulations (14 CFR) for CrescentAI’s Small Unmanned Aircraft System (sUAS)

To whom it may concern,

Crescent Aerial Imaging LLC wishes to petition from specific regulations of Title 14 of the Code 

of Federal Regulations. These exemptions are pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012. PL 112-95, February 14, 2012, 126 Stat 11. 

Crescent Aerial Imaging (CrescentAI) aims to utilize Small Unmanned Aerial Systems (sUAS) 

to capture high quality video and still imagery for several industries. Our target market is RealEstate and land/Construction sites, motion picture and entertainment industry, and the oil & gas 

and electrical utilities industry. 

Providing the Real-Estate industry with high quality aerial still images will greatly increase value 

brought to their customers. Our high quality aerial video adds value through virtual property 

tours and will give our customers a competitive edge. This request is in-line with previously

approved exemptions (e.g. Exemption No. 11138). With Hollywood south based in New Orleans, 

CrescentAI will serve the motion picture and entertainment industry, bringing the same high 

quality of service. CrescentAI will also provide service to the oil & gas industry with a safer less 

costly method for Flare Tip Inspection/Assessments and will provide services for other aerial 

assets. Our use of unmanned aerial photography and video drastically reduces costs and risks 

associated with traditional aerial inspection practices currently in use. 
Our inspection methods using small unmanned aircrafts reduces operator expenses by orders of 

magnitude and eliminates nearly all personnel safety risks. 

We seek to provide aerial inspection services to the electrical utility industry for structural 

inspection/assessment (e.g. Tower and Electrical line damage). As in other industries, 

CrescentAI can mitigate costs and risks by using our (sUAS). 

The skills, experience, and technologies we've harnessed at CrescentAI enable us to provide a 

valuable service while maintaining the highest concern for safety and privacy. We hope (expect) 

the FAA will see the value in our services and recognize the importance we place on safety and 

privacy as addressed below.

With the permission of the FAA, CrescentAI plans to operate commercially at or below 400’ 

AGL as outlined in the FAA Modernization and Reform Act of 2012, section 333 for all possible 

scenarios pursuant to the above listed industries. CrescentAI understands that any mission 

outside of those industries listed above will require additional exemptions or modifications to 

this exemption. We also understand that this applies to the altitude requirements. 

CrescentAI will operate small unmanned aircraft (sUAS) weighing less than 50 pounds with full 

payload. Our aircraft have high visibility markings and characteristics should there be an 

unfortunate encroachment of our operating area by any general aviation manned aircraft. Our 

operating procedures require that all our flight operations cease immediately upon visual 

recognition of manned aircraft near or heading for our operational area. Our procedures allow 

that operations may only resume when the area is deemed entirely free from present or 

approaching manned aircrafts. All flight operations will be conducted in Visual Line-of-Sight 

(VLOS) and will not cause a hazard to life or property. CrescentAI flights will not cause any

hazard to the NAS or pose a threat to national security. Visual Meteorological Conditions 

(VMC) for weather minimums will be adhered to as prescribed in §91.155. CrescentAI will 

strictly comply with the minimum safe altitudes regulated under §91.119. All sUAS aircraft 

flown by CrescentAI will be operated at airspeeds less than 40 knots, for this is the maximum 

operating airspeed to acquire quality video and data collection for our clients. The vast majority

of our missions require slow deliberate movements. All of CrescentAI’s aircraft have built-in 

programmable failsafe systems in the event we have a loss of signal or communications between 

the transmitter and the receiver. This failsafe system allows for an automatic override of the 

autopilot system and forces a safe vertical landing at the coordinates automatically recorded at 

takeoff.. All CrescentAI flight crews will be equipped with several tools to ensure safe flight 

operations to include: 

● FAA NOTAM site https://pilotweb.nas.faa.gov/PilotWeb/

● SkyVector for Airport locations and maps http://skyvector.com/

● A variety of weather sites and apps for weather checks and clearances (e.g. 

http://www.accuweather.com/ , http://www.intellicast.com etc). 
As part of the pre-flight procedures, flight crews will be required to determine Go/ No-Go for 

flight operations according to weather, location, obstacles. 

CrescentAI currently possess only one sUAS for commercial operation however would like to 

expand in the future and operate several more flight crews and aircraft. Any future aircraft 

operated by CrescentAI will have the same characteristics as our current one. A description and 

specifications are enclosed.

CrescentAI currently operates the Tarot T810 Hexacopter. The hexacopter affords an additional 

degree of safety as the “Quad-Copter” does not. The hexacopter can be landed safely in the event 

of a motor failure. The autopilot can compensate for the loss and allow the pilot/operator to land 

it in a safe area preventing damage to property and injuries on the ground. The specifications are 

as follows:

Specifications :

- Frame weight : 1020g

- Arms diameter : 25mm

- Aircraft diameter : 810mm

- End to end : 850mm

- Center body dimension : 210 x 210 x 2.0mm

- Mount mounting hole : 16mm / 19mm / 25mm / 27mm triangular shaped mounting

- Aircraft weight (everything it needs to fly) : around 4.3kg

- Aircraft all-up-weight (when it lift the ground with payload) : around 4.5~6kg

- Payload (it can carry) : 1.5~2kg

Our Flight Reference :

- Battery Supply : 2 x 6S 22.2V, 5000mah for 15-17 Minutes flight time

- Motor : Tarot 4114 320kv Motor

- ESC : Hobbywing Platinum 30A-OPTO 

- Propellers : Tarot 1355 Carbon Fiber Propellers with 1245’s as a Backup

- Flight Autopilot Controller : NAZA-M V2 Multirotor Autopilot w/GPS and Telemetry capable 

- Radio Set : 2.4 GHz Futaba T8J 

Payload: 

- Carrying: 2 Axis BGC 3.1 Alex MOS Brushless Motor Gimbal

-TS352 FPV System (Not Goggles, monitors only)

-GoPro Hero 3 

This Tarot T810 in its current configuration will be flown in GPS mode and/or attitude mode. 

We plan to launch missions using fully autonomous flight as the need arises and the resources 

become available. We seek approval for use of autonomous guidance systems for future use. We 

would also like to upgrade our camera and gimbal system in the future to accommodate a DSLR 

camera and 3 axis gimbal. 
We request that the FAA permits this for future equipment upgrade in this exemption in order to 

simplify these anticipated equipment upgrades which do not alter the nature of the aircraft.

Request for Exemption From:

● § 21.1 Subpart H Airworthiness Certificates

Exemption Justification

Based on the size, weight and operational area of CrescentAI’s (sUAS)’s exemption from 

part 21 is permitted due to CrescentAI meeting an equivalent level of safety pursuant to Section 

333 of the reform act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both (49 U.S.C. § 44701) (f) and Section 333 of the reform act. 

Both pieces of legislation permit the FAA to exempt sUAS’s from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability, and proximity of areas 

such as airports and dense populations. CrescentAI will meet or exceed these elements.

● § 45.23 (a) (b) Display of marks; general

Exemption Justification

Given the type and size of CrescentAI’s sUAS aircraft, it is not possible to follow § 45.23 (a) 

(b) requirements for display of marks. If in the future the FAA requires “N” numbers for sUAS’s 

we ask for an exemption from mounting marking on the aircraft and that we be allowed to 

include that information with the ground flight crew documentation which would allow for 

availability for inspection upon request. 

● § 61.113 (a) : Except as provided in paragraphs (b) through (h) of this section, no person 

who holds a private pilot certificate may act as pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as pilot in command of an aircraft.

Exemption Justification

CrescentAI will not pilot any aircraft carrying passengers or cargo/property; however it 

requests approval to operate in a commercial capacity for compensation or hire its sUAS aircraft 

for collecting aerial photographs and video for all industries outlined above until such time as the 

administration establishes a standard for national regulation for unmanned aircraft operations 

pursuant to Public Law 112-95.

● § 91.119 Minimum safe altitudes
Exemption Justification

14 CFR § 91.119 allows for helicopters to operate at lower altitudes in certain conditions. 

Mentioned previously in this request, CrescentAI has no intentions of flying above 400’ AGL. 

This will allow for a level of safety equivalent to the minimum safe altitudes prescribed by 14

CFR § 91.119. As a standard practice and part of CrescentAI’s SOP (Standing Operating 

Procedure), we will operate in cordoned off areas, clearly marked and Restricted to CrescentAI 

personnel. Given the size, weight, maneuverability, and speed of CrescentAI’s (sUAS)’s, an 

equivalent level of safety will be achieved. 

● § 91.203 (a) (2) Except as provided in § 91.715, no person may operate a civil aircraft 

unless it has within it the following: An effective U.S. registration certificate issued to its 

owner or, for operation within the United States, the second copy of the Aircraft 

registration Application as provided for in § 47.31(c), or a registration certification issued 

under the laws of a foreign country.

Exemption Justification

CrescentAI requests an exemption from producing a registration for its (sUAS). This 

request goes hand-in-hand with the above request for exemption from § 21.1 Subpart H. This 

request acknowledges Order 8130.20 regarding registration requirements for United States civil 

aircraft seeking airworthiness and requests relief until such time as the administration establishes 

a standard for national regulation for unmanned aircraft operations pursuant to Public Law 

112-95.

● § 91.203 (b) Civil aircraft: Certifications required-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.

Exemption Justification

Due to the fact that CrescentAI’s aircraft are unmanned, we ask that it be approved to 

allow airworthiness documentation or FAA approved equivalent accessible to the ground based 

flight crew at all times. This documentation will be part of the aircraft flight log book and other 

documentation required by company policy.

 § 91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.

Exemption Justification

In consideration of the weight, size, speed, type, maneuverability and pursuant to 

§ 21.1 Subpart H, CrescentAI is requesting an exemption from § 91.407 Operation after 

maintenance, preventive maintenance, rebuilding, or alteration. The sUAS that CrescentAI

operates is nothing more than a hobbyist aircraft and does not have the same maintenance and 

repair requirements as the typical civil aircraft. CrescentAI’s owner/operator is also A&P 

Certified and will oversee any maintenance and repairs completed by employees of CrescentAI.
● § 91.9 Civil aircraft flight manual, marking, and placard requirements. For which an 

Airplane or Rotorcraft Flight Manual is not 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.

Exemption Justification

Due to the fact that CrescentAI’s aircraft are unmanned and it is not possible to stow 

manuals on-board the aircraft, we ask that it be approved to allow for the aircraft manual, if 

applicable, to be present with the ground flight crew in lieu of aircraft manual available in the 

aircraft. The FAA has previously issued exemptions to this regulation in exemptions 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

Crescent Aerial Imaging LLC has strict operating procedures for the safety of 

personnel and equipment on the ground. Displayed below are items used by ground personnel 

while operating our (sUAS)’s. 

Ground Equipment

● Safety Helmet (When Applicable)

● High Visibility Clothing (Hi-Vis as needed)

● Orange Cones for cording off work area (When Applicable)

● Cell Phone, Tablet, Laptop etc. for planning, weather checks, and emergencies

Our Pre-Flight Checklist

(Continuously updated as needed) 
Additional Information

The Applicant, Keith J Stoltz is the owner and sole operator of Crescent Aerial Imaging LLC 

(CrescentAI). He is a twenty eight year veteran of the Army and Louisiana Army National Guard with 

twenty five of those years as Military Aviation Experience which includes operating as a member of the 

flight crew for multiple Rotor Wing Aircraft including the UH60 Blackhawk, OH58 A/C, and the UH-1 

Huey. He holds a Federal Aviation Administration Airframe & Powerplant Certification and has 

completed the Eurocopter factory course for the BK117/UH72 Lakota. He also has completed the OSHA 

40 hour Compliance Course and is a TWIC card holder. 

It is the hopes of CrescentAI that the FAA will see the value their service brings to the market place and 

will approve all exemption requests. By satisfying the criteria provided in Section 333 of the Reform act 

of 2012, we believe it will be adequate justification for granting of all exemptions thereby allowing for 

the commercial operation of the applicants sUAS. 

On behalf of Crescent Aerial Imaging LLC, I thank you for your consideration of this petition for 

exemption and look forward to your comments and suggestions so that we may continue to work towards 

a common objective.