U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act 

and Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam:

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

2012 (the “Reform Act”) and 14 C.F.R. Part 11, Hunt Country Aerials, 

LLC, seeks an exemption from Federal Aviation Regulations (“FARs”) 

detailed below for (1) DJI Phantom 3 quadcopter, (1) DJI Inspire 1, 

and (1) DJI Spreading Wings S900 manufactured by DJI Innovations.

The requested exemption would support an application for a 

commercial Certificate of Authorization to use the system to support 

aerial photography and videography. The DJI Phantom 3 (3lb), DJI 

Inspire 1 (6.5lb) and DJI S900 (18lb) consist of a battery operated 

aircraft, a ground control station and/ a RC Controller, and associated 

communications equipment. The aircrafts carry an onboard georeferenced gimbaled camera that allows it to obtain photography and 

videography.

The Unmanned Aircraft System will be operated in the field with a 

PIC in accordance with FAA Policy N 8900.227 Section 14 

"Operational Requirements for UAS".

The PIC holds a Federal Communications Commission (FCC) 

Technician “HAM” Radio License

Hunt Country Aerials, LLC respectfully requests the grant of 

exemption allowing to operate lightweight, remote controlled UAS's 

lawfully and safely. 

Hunt Country Aerials, LLC also respectfully requests Exemption 

Request Section 333 from (but not limited to) the Specific Sections of 

Title 14 of the Code of Federal Regulations and part ll of the Federal 

Aviation. Regulations listed below. 
14 C.F.R.45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & 

(b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 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 extent of relief Hunt Country Aerials, LLC seeks and the reason 

why: 

Hunt Country Aerials, LLC is seeking relief from any applicable FARs 

which would prevent Hunt Country Aerials, LLC from conducting 

aerial shots of real estate, aerial mapping, events, and other possible 

legal flight operations. The weight of the UAS meets the definition of 

''small unmanned aircraft” found in section 331 "The Reform Act”. 

Hunt Country Aerials, LLC seeks to operate legally as a small 

business that cater mostly to real estate agents. Realtors are not 

allowed to use UAS's or hire unless they or the person they hire, is 

allowed by the FAA to fly a UAS. Hunt Country Aerials, LLC would 

satisfy the need for safe and affordable aerial shots. 

Hunt Country Aerials, LLC uses UAS that is considerably less than 55 

pounds including the camera that is attached. The UAS will be used 

at speeds under 50 mph because of the nature of the business and 

the limited physical capabilities of the UAS. It is designed to hover 

and take pictures. The UAS will be in accordance with flying well 

below 400ft. 

The UAS in which Hunt Country Aerials, LLC would be using only 

utilizes battery power for its operations. There are no combustible 

fuels used in the UAS that Hunt Country Aerials, LLC uses. The 

maximum flight time for our particular UAS is 25 minutes battery life. 

It will fly no more than 20 minutes maximum at one time at one 

location. The amount of time the UAS will be in the air, less than 

400ft, is minimal. 

A Safety system in place for Hunt Country Aerials, LLC UAS includes 

a GPS mode that allows the UAS to return home if communication is 

lost. Further, the GPS onboard allows the UAS to return back to its 

launched position if the battery life of the UAS is low.
THE GROUND STATION PART OF THE SYSTEM: 

A Pilot in Command (PIC) in operational control of a flight operation 

from beginning to end and who controls the UAS while in the air. 

Additionally, the line of site of the UAS will not leave the sight of the 

PIC. 

A radio transmitter/controller operated by the PIC to control the UAS 

while in flight; 

A radio receiver receiving live video,and flight data from the on-board 

camera and computer. It projects it all in one screen to the Pilot in 

Command 

The UAS, weighing less than 20lbs fully loaded, is powered by 

batteries and operates with no people on board which lowers the 

likelihood of death or serious bodily injury. With a small payload 

consisting of harmless electronics such as a camera and GPS, the 

UASs only purpose is to be used as a tool to take pictures and 

videos. 

Low level aerial photos and video from several angles are far more 

effective than ground based photos. Low level aerial video and 

pictures show the layout of properties with the advantage of seeing 

more in one photo or short video. 

Current applicants have used helicopters and small planes for this 

purpose but the cost of fuel, time, and emissions of such aircraft is 

not efficient enough for most customers to afford. 

The benefits of reduced cost and improved efficiency of the UAS 

allows future customers to afford this service with a faster turnaround 

time at a lesser cost.

Hunt Country Aerials, LLC will not operate a UAS near airports and

does not fly over crowds. Situational awareness is most important. 

The areas where Hunt Country Aerials, LLC conducts aerial 

photography is predetermined which allows for a controlled 

environment to operate safely. 
With allowing Hunt Country Aerials, LLC to conduct 

business with a light weight UAS, it could very well help the economy 

and benefit people in first response situations. Further, Hunt Country 

Aerials, LLC UAS is considerably lighter than the alternative, which is 

a helicopter or small plane. Currently, Hunt Country Aerials, LLC has 

2 UAS which only operates off 25 minutes of battery power. 

Therefore, the UAS used by Hunt Country Aerials, LLC would only 

have a flight time of 5 - 20 minutes at one time. The likelihood of 

injury or even death with such a small unmanned aircraft, compared 

to an aircraft flown by a person loaded with combustible fuel, is 

considerably low 

SUMMARY: 

Hunt Country Aerials, LLC is more than willing to follow the safety 

guidelines of the FAA Policy N 8900.227 Section 14 "Operational 

Requirements for UAS” with the appropriate exemptions for flying a 

small UAS. 

A-No flight will be made with a UA Gross weight exceeding 55lbs 

B- All operations must occur in FAA Class G airspace at no more 

than 400 ft. AGL, at an airspeed of not more than 45 knots and no 

further than 3/4 NM from the Pilot In Charge 

C- Operations will be restricted to flights over private property with the 

permission of the property owner 

D- All required permits will be obtained from state and local 

government prior to operation 

E- The UAS will not be operated over densely populated areas

F- The UAS will not be operated at air shows

G- The UAS will not be operated over any open-air assembly of 

people

H-The UAS will not be operated over heavily trafficked roads 
I-The UAS will not be operated within 5 NM of an airport or 

heliport 

J- Operations will be restricted to day only and weather conditions 

equivalent to VFR 

K- The PIC will notify property owner about the operation and risk 

before the first flight at each new location; 

L- No flight may be made without a Pre-Flight Inspection by the PIC 

before each operation to ascertain that the UAS is in a condition safe 

for flight (see Appendix A). 

Operations above are the bare minimum safety guidelines Hunt 

Country Aerials, LLC will follow.

Hunt Country Aerials, LLC believes flying its UAS as a small business 

within the safety parameters of the FAA, can help people and 

promote the economy. 

Respectfully,

Schuyler Knapp

Hunt Country Aerials, LLC

10001 Mount Airy Road

Upperville, VA 20184

(540) 454-5228