Elite Aerial Images

3210 Bird Dr - Erie - PA 16510

814-897-9637

1

U.S. Department of Transportation

Docket Management System March 16, 2014

1200 New Jersey Ave. SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam

I am submitting this petition on my own, on the behalf of my company Elite Aerial Images, Co. 

without the aid of legal council.

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

14 C.F.R. Part 11, Elite Aerial Images, Co. (EAI) which is owned and operated by Douglas 

Woodcrafters, Co., a sole proprietor, operating in the State of Pennsylvania. 

EAI who has been building and operating Small Unmanned Aircraft Systems for the past 5 years, 

wishes to apply for an exemption from the Federal Aviation Regulations (FAR) listed below to 

allow operation of our sUAS commercially in airspace regulated by the Federal Aviation 

Administration (FAA) so long as such operations are conducted with and under the conditions 

outlined herein or as may be established by the FAA as required by Section333.

The requested exemption would permit EAI to pursue its commercial interests in providing services 

to companies interested in aerial data that can only be captured by using newly developed sUAS in 

the following areas:

 Surveying and 3D aerial mapping

 Agriculture crop assessment and growth patterns

 Golf course management

 Insurance company claim assessment

 Special events

 Construction site and ecological impact assessment

EAI asserts that all sUAS flights that will occur over private or controlled access property will do 

so with the property owner’s consent and knowledge and that only people who have consented or 

otherwise have agreed to be in the area where flight activity is taking place. Additionally, I am a 

private pilot with 3,000 hours of flight time logged and am the sole operator of the sUAS we own 

and operate. Our observers will attend ground school to be taught the rules and regulation as they

pertain to operating private aircraft under Visual Flight Rules (VFR) over civilian population areas 

as described and set fourth in the Aeronautical Information Manual.
Elite Aerial Images

3210 Bird Dr - Erie - PA 16510

814-897-9637

2

The substance of this request is essentially the same as that granted to Falcon Sky Cam 

Regulatory Docket No. FAA-2014-0884 in that EAI is engaged in aerial photography of land, 

buildings, and insurance claims, by using remote controlled sUAS to see the condition of fields, 

crops, ecological impact, and financial losses do to destruction by fire and other natural disasters, 

without the need to drive over or climb on the property being so assessed.

EAI has equipped each of our sUAS aircraft GoPro cameras for aerial photography including video 

and still pictures and special lens adaptations to make them very accurate in the 3 D mapping 

activity. By doing so we have the ability to produce high-resolution photography of remote 

locations that would be difficult or dangerous to reach on foot. This would be especially

problematic while doing loss claim work for insurance companies.

EAI exemption request would permit us to operate lightweight, unmanned (remotely controlled in 

line of sight) sUAS’s in tightly controlled and limited airspace. Predetermined, specifically marked 

areas of operation as well as Global Positioning Satellite (GPS) navigation maps which incorporate 

restricted, no fly zones and control zones of airports, will allow EAI to operate within current safety 

parameters as well as the new ones being implemented.

The Extent of Relief EAI Seeks and Its Justification for Such Relief:

Regulation from EAI request exemption:

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. (91.401-91.417)

Unmanned Aircraft System

sUASs are seen as a better photographic platform to helicopters because these smaller devices are 

less expensive, they produce less noise, and they have much less environmental impact and are less 

likely to cause injury to the public and or property.
Elite Aerial Images

3210 Bird Dr - Erie - PA 16510

814-897-9637

3

I am petitioning for exemption to enable EAI to operate DJI Phantom2, v2, systems, equipped with 

a 3 axis Zenmuse Gimbal, and a GoPro Hero 4, Black camera. This sUAS has a built in capacity to 

limit the height it flies above the ground, to limit the radius of the distance it flies from the operator 

and to exclude it for Class B, C, and D airspace including No Fly Restricted Zones. The Phantom 

also has the failsafe feature of the Naza-M autopilot system which means when the communication 

between the main controller and the transmitter is lost, the Phantom will return to the home starting 

point and land safely.

The above specifications meet with the Model Aircraft Operating Standards as set below:

 The petitioner will only operate its sUAS in line of sight of a pilot/observer and will operate 

at sites that are sufficient distance from populated areas within the sterile area described in 

the FOPM. Such operations will insure that the sUAS will not create a hazard to users of 

the national airspace or the public.

 When flying sUAS within 3 miles of an airport, airport operators will be notified and the 

operator will give the right of way to avoid flying in the proximity of full scale aircraft.

 Maximum flight time for each operational flight will be 30 minutes.

 Flights will be terminated at 25% battery power reserve should that occur prior to the 30 

minute limit.

 The sUAS will be programmed so it will not be operated at an altitude of no more than 4oo 

feet AGL, and not more than 200 feet above a fixed platform from which operations are 

conducted.

 The minimum crew for each operation will consist of the sUAS pilot and the Visual 

Observer.

 The sUAS pilot will be an FAA licensed Private Pilot with a Second Class Medical 

Certificate.

 The sUAS will weigh less than 55 pounds including its payload of camera and gimbal.

 The sUAS will fly no more than 50 knots and can hover plus move horizontally and 

vertically.

 Given the small size of the sUAS, and the restricted airspace within which it will operate, I 

believe our sUAS operations will comply with both the spirit and the rules intended by the 

Reform Act safety requirements.

Additionally, the fact that I am a private pilot and hold a FFA Pilots License demonstrates that I 

have a high regard to safe operations with a through understanding of the FAR’s, preflight 

inspections, maintenance and repair, operations within airspace, as well as being trained to high 

safety standards.
Elite Aerial Images

3210 Bird Dr - Erie - PA 16510

814-897-9637

4

As part of this request for exemption, I (EAI) give my personal assurance that all persons involved 

in aerial operations have completed sUAS education and training including all applicable 

regulations and guidance documents.

I respectfully request exemption under Section 333 to enable EAI to operate efficient, limited, lowrisk commercial sUAS operations for the activities stated, respecting at all times, the space and 

privacy of citizens and property as we keep our skies safe.

Sincerely yours,

Douglas R. Duer

Owner/Elite Aerial Images, Co.

3210 Bird Drive

Erie, Pennsylvania 16510

814-897-0637