Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra	Hoover

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August	12,	2015

Docket Operations,	M-30

US	Department	of	Transportation

1200	New	Jersey Avenue,	SE

Room	W12-140,	West	Building	Ground	Floor

Washington, DC	20590-0001

Re:	Petition	for	exemption	under	FAA	Modernization	and	Reform	Act	of	2012	(P.L.	

112-95),	Section	33

Dear Sir	or	Madam:

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

and	14	CFR	Part	II,	Alexandra	Hoover	hereby applies	for	an	exemption	from	Federal	

Aviation	Regulations	(FARs)	listed	below	under	“Basis	for	Petition”.	Exemption	is	

being	sought	in	order	to	allow	Alexandra	Hoover	to	operate	her	unmanned	aircraft	

systems	(UAS)	commercially	for	the	purpose	of	aerial	videography	and	

photography,	precision agriculture	and	environmental	management	and	analysis,	

aerial	inspection	of	land	and	structures,	journalism	and	news	gathering,	real	estate	

marketing,	and	closed	set	motion	picture	and	television	film	making	and	production.	

INTRODUCTION	OF	THE	PETITIONAR

Alexandra	Hoover	provides	services	to	her	clients	to	enhance	a	variety	of	their	

business	and	personal	objectives by	providing	digital photography,	videography,	

cinematic	consulting	and	other	types	of	digital	imaging	and	related	services.	

Alexandra	Hoover	possesses over	15	years	of	experience	in	recreational/hobby	

aspects	of	R/C	aviation,	photography,	videography	and	UAS	piloting,	photo	and	

video	editing,	and	training	services.	Alexandra’s	objective	is	to	provide	professional	

quality	digital	imaging,	editing	and	analysis	for	a	variety	of	commercial, public,	

private	and	not	for	profit	organizations and	individuals,	including	but	not	limited	to:

• Closed	set	motion	picture	and	television	filming	and	production

• Photography	and	videography	for	journalism	and	news	gathering	purposes

• General	aerial	photography	and	inspection	of	land,	structures	and	

construction	projects

• Real	estate	marketing	photography	and	videography

• Digital	imagery and	data	acquisition	for	precision	agriculture,	environmental	

management	and	scientific	analysis
Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra	Hoover

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UNMANNED	AERIAL	SYSTEMS

DJI	Inspire	1,	DJI	Phantom	2,	DJI	Spreading	wings	S1000+,	DJI	Spreading	wings	

S900,	DJI	spreading	wings	S800	EVO

Alexandra	Hoover	seeks	an	exemption	to	operate	DJI	Inspire	1,	DJI	Phantom	2,	DJI	

Spreading	wings	S1000+,	DJI	Spreading	wings	S900,	DJI	spreading	wings	S800	EVO

for	compensation	or	hire	within	the	National	Air	Space	(NAS).	The	DJI	Inspire	1,	DJI	

Phantom	2,	DJI	Spreading	wings	S1000+,	DJI	Spreading	wings	S900,	DJI	spreading	

wings	S800	EVO are	all	vertical	takeoff	and	landing	(VTOL)	unmanned	aircraft. The	

DJI	Phantom	2	is	a	four-rotor	quad-copter	that	has	a	maximum	gross	weight	of	

approximately 3 pounds	3	ounces,	including	Zenmuse	H3-2D	gimbal	and	go-pro	

camera	systems,	and	a	maximum	speed	according	to	the	manufacturer	of	

approximately 33.5	miles	per	hour.	The	DJI	Inspire	1	is	a	four-rotor	quad-copter	

that	has	a	maximum	gross	weight	of	6	pounds	7.5	ounces,	including	onboard	gimbal,	

camera	systems,	and	batteries,	and	a	maximum	speed	of	approximately 48.5	miles	

per	hour.	DJI	spreading	winds	S1000+	is	an	eight-rotor octo-copter	and	has	an	

approximate	weight	of	9	pounds	11.21	ounces.	DJI	spreading	wings	S900 is	a	sixrotor	hexa-coptor	and	has	an	approximate	weight	of	7	pounds	4.4	ounces.	DJI	

spreading	wings	S800	EVO is	a	six-rotor	hexa-coptor	and	has	an	approximate	

weight	of	8	pounds	2.51	ounces.	Each	of	the	above	described	UAS	are	equipped	with	

rotors	and	propellers driven	by	lithium	polymer	battery	powered	electric	motors.	

Each	are	also	equipped	with	the	industry	standards	in	GPS,	electronics,	guidance,	

propulsion,	telemetry,	safety	features	and	ease	of	operator functionality.	Detailed	

information	regarding	each	UAS	is attached	in	Appendices	A	through	E.	

It	should	be	noted	that	these	particular	UAS	have	each	been	approved	in	connection	

with	prior	Section	333	Grants	of	Exemption.	Each	UAS	is	recognized	in	the	UAS	

industry	as	a	leading	example	of	precision,	quality,	performance,	durability	and	

technological innovation.	These	UAS	will	offer	Alexandra	a	range	of	options	for	

matching	the	desired	flight	characteristics and	technology	with	the	desired	tasks,	

environmental	conditions,	and	navigational	demands,	thus	assuring	overall	safety	

and	completion	of	assigned	work	products and	desired results.	

BASIS	FOR	PETITION

Alexandra	Hoover,	pursuant	to	the	provisions	of	the	Federal	Aviation	Regulations	

(14	C.F.R.	Section	11.61)	and	the	FAA	Modernization	and	Reform	Act	of	2012	

(FMRA),	Section	333,	Special	Rules	for	Certain	Unmanned	Aircraft	Systems,	hereby	

petitions	the	Administrator	to	commercially	operate	the	DJI	Inspire	1,	DJI	Phantom	

2,	DJI	Spreading	wings	S1000+,	DJI	Spreading	wings	S900,	DJI	spreading	wings	S800	

EVO in	the	National	Airspace	System	(NAS),	and	for exemption	from	the	

requirements	of	14	C.F.R.	Sections	61.113(a)&(b),	91.7(a),	91.119(c),	91.121,	

91.151(a)(1),	91.405(a),	91.407(a)(1),	91.409(a)(1)&(a)(2),	and	91.417(a)&(b).	
Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra	Hoover

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The	granting	of	the	exemption	from	the	above	listed	FARs	will	allow	Alexandra	

Hoover	to	conduct	commercial	operations	of	her	UAS	to	efficiently	and	safely	deliver	

high-definition	digital	imagery	and	other	acquired	data	to	her	clients	and	customers	

more	cost-effectively than	traditional	methods.	Employing	UAS	technology	can	also	

be	safer	for	workers	because	in	many	instances	the	workers	may	avoid	dangerous	

or	precarious	hazards	or	physical	positions	involving	high	risk	of	injury.	Unmanned	

Aerial	Systems	also	enable	safe	inspection	of	difficult to	reach	or	environmentally	

sensitive	locations	without	the	use	of	heavy	trucks,	cranes,	booms	or	other	

equipment	requiring	greater	expense	or	creating undesirable	environmental	

impacts.		In	general,	UAS	operated	by	Alexandra	Hoover	will	economically	benefit	

her	customers	by	acquiring	important	and	aesthetic	digital	imagery	and	data	safely	

and	less	expensively	for	a	wide	variety	of	applications.	

Alexandra	Hoover	proposes	to	use	UAS	that	are	multi-rotor	craft	weighing	a	

maximum	of	21.75	pounds	fully	loaded,	or	less,	which	fly	at	a	speed	of	48.5	miles	per	

hour,	or	less.	The	craft	are	all	equipped with	built	in	safety	features	including	

sophisticated	navigation	controls	and	fail-safe	technology	to	assure	safe	and	

predictable	aerial	maneuvers,	take-off	and	landing.	

Proposed	operations	will	be	conducted	under	controlled	conditions	in	airspace	that	

is	limited,	predetermined,	access	controlled	and	under	constant	monitoring	before	

and	during	flight.	Operations	contemplated	under	the	exemption	will	be	subject	to	

strict	operating	parameters	to	ensure	at	least	an	equivalent	level	of	safety	to	

currently	authorized	and/or	exempted	operations.

NAME	AND	ADDRESS	OF	THE	PETITIONER	

The	name	and	address	of	the	petitioner	and	point	of	contact is:

Alexandra	Hoover

4042	Garth	Road	

Crozet,	Virginia	22932

(207)	272-6059

Email:	ahoover0915@gmail.com

OPERATING	DOCUMENTS	

The	comprehensive	operations	manuals/user	guides/safety	guides	and	other	

detailed	information	provided	by	the	UAS	manufactures	are	attached to	this	petition	

as	Appendix	“A”	(DJI	Inspire	1)	Appendix	“B”	(DJI	Phantom	2)	Appendix	“C”	

Spreading	wings	S1000+)	Appendix	“D”	(DJI	Spreading	wings	S900)	and	Appendix	

“E”	(DJI	Spreading	wings	S800	EVO).	The	appendices	are	comprehensive	and	

current	for	each	UAS,	and	offer	a	complete	description	of	each	aircraft,	including	

operating	features	and	protocols,	specifications,	maintenance,	recommendations	

and	guidance,	safety	and	navigation	information,	battery	maintenance	and	safety,	

aircraft	controls,	gimbals	and	more.	
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Attached	as	Appendix	“F”	is	Alexandra	Hoover’s	pre-flight	Checklist	and	In-flight	

safety	checklist;	Appendix	“G”	contains	Alexandra’s	flight	log	forms	and	monthly	

maintenance log	form;	Appendix	“H” is	Alexandra’s	Motion	Picture	and	Television	

Operations	Manual	and Flight	Operations Manual	for	use	in	closed	set	motion	

picture	and	television	filming	and	production.

THE	PILOT	IN	COMMAND	(PIC)

The	PIC	will:

• Hold	a	current	FAA	Sport	Pilot	certificate	or	higher	FAA	pilot	certification

• Hold	a	valid third	class	medical	certificate	or	valid	drivers	license

• Have	accumulated and	logged,	in	a	manner	consistent with	14	CFR	61.51	(b),	

a	minimum	of	25	hours	of	total	time	as	a	UAS	rotorcraft	pilot	and	at	least	10	

hours	logged	as	a	UAS	pilot	with	similar	UAS	type.	

• Have	accumulated	and	logged	a	minimum	of	five	hours	as	a	UAS	pilot	with	

the	make	and	model	of	UAS	to	be	utilized	for	operations under	the	exemption	

and	three	takeoffs and	landings	in	the	preceding 90	days	prior	to	an	

operation.	

• As	noted	below	in	“operating	parameters,	limitations,	conditions,	and	

requirements”,	the	Operator	will	not	allow	a	PIC to	operate	unless	the	PIC	

has demonstrated	that	the	PIC	is	able	to	safely	operate	the	UAS	in	a	manner	

consistent with	how	the	UAS	will	be	operated	under	the	exemption,	including	

evasive	and	emergency	maneuvers and	maintaining appropriate	distances	

from	people,	vessels,	vehicles,	and	structures.	

Visual	Observers	must	have	demonstrated	that	they	understand	the	conditions	and	

limitations	of	flight	noted	in	the	same	section	which	follows	immediately	below.	

OPERATING	PARAMETERS,	LIMITATIONS,	CONDITIONS	AND	REQUIREMNTS

Grant	of	the	exemptions will	be	subject	to	the	following	conditions,	which	provide	at	

least	an	equivalent	or	higher	level	of	safety	than	under	the	current	conditions.	These	

conditions	are	derived	from	Exemptions	11062	through 11067,	11080,	11109	and	

11110,	and	others.	

For	the	following	listing,	the	Petitioner Alexandra	Hoover	is	referred	to	as	the	

Operator.	

1. Operations	authorized	by	the	grant	will	be	limited	to	the	UAS	described	

above	and	manufactures’	upgraded	versions.

2. The	UAS	weigh	21.75	pounds	or	less,	including	batteries,	gimbals, camera	

systems	and	other	necessary attachments.
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3. The	UA	will	be	flown	at	a	maximum	ground	speed	of	50	miles	per hour.	In	no	

case	will	a	UA	be	operated	at	airspeeds	greater	than	the	maximum	UA	

airspeed	recommended by	the aircraft	manufacturer.	

4. The	UA	will	be	operated	at	an	altitude	of	no	more	than	400	feet	above	

ground	level (AGL).	Altitude	will	be	reported	in	feet	AGL.

5. The UA	will	be	operated	within	Visual	Line	of	Sight	(VLOS)	of	the	PIC	at	all	

times.	This	requires	the	PIC	to	be	able	to	use	human	vision	unaided	by	any	

device	other	than	corrective	lenses,	as	specified	on	the	PIC’s	FAA- issued	

medical	certificate or	U.S.	driver’s	license.

6. All operations	will	utilize	a	Visual	Observer	(VO).	The	UA	will	be	operated	

within	the	visual	line	of	sight	(VLOS)	requirement	as	long	as	the	PIC	always	

maintains VLOS	capability.	The	VO	and	PIC	will	be	able	to	communicate	

verbally	at	all	times.	Electronic	messaging or	texting	will	not	be	permitted	

during	flight	operations.	The	PIC	will	be	designated	before	the	flight	and	will	

not	transfer	his	or	her	designation	for	the	duration	of	the	flight.	The	PIC	will	

ensure	that	the	VO	can	perform	the	functions	and	duties	required	of	the	VO.	

7. The	operating	documents	and	the	grant	of	exemption	will	be	accessible

during	UAS	operations	and	made	available	to	the	Administrator	upon	

request.	The Operator	may	update	or	revise	Her operating	documents.	It	will	

be	the	Operator’s	responsibility	to	track such	revisions	and	present	updated	

and	revised	documents	to	the	Administrator	or	any	law	enforcement	official	

upon	request.	If	there	is	a	discrepancy between	the	exemption	conditions	

and	limitations	and the	procedures	outlined	in	the	operating	documents,	the	

conditions	and	limitations	in	the	grant	of	exception	take	precedence	and	will	

be	followed.	Otherwise the	Operator	will	follow	the	procedures	outlined	in	

Her operating	documents.	If the	Operator	determines	that	any	update or	

revision	would	affect	the	basis	upon	which	the	FAA may	grant	this	

exemption,	the	Operator	will	petition	the	FAA	for	amendment	to	the	

exemption.	

8. Any	UAS	that	has	undergone	maintenance or	alterations	that	affect	the	UAS	

flight	characteristics	or	operation,	e.g.	replacement	of	an	essential	flight	

component,	will	undergo	a	functional	test	flight	prior	to	conducting	further	

operations.	Functional	test	flights	will	be	conducted	by	a	PIC	with	a	VO	and	

will	remain	at	least	500	feet	from	other	people.	The	functional	test	flight	will	

be	conducted	in	such	a	manner	so	as	not	to	pose	an	undue	hazard	to	persons	

and	property.	

9. The	operator	will	be	responsible	for	maintaining	and	inspecting	the	UAS	to	

ensure	that	it	is	in	a	condition	for	safe	operation.	
Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra	Hoover

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10. Prior	to	each	flight	the	PIC	will	conduct	a	pre-flight	inspection	and	determine	

that	the	UAS	is	in	a	condition	for	safe	flight.	The	pre-flight	inspection	will	

account	for	all	potential	discrepancies,	e.g.	inoperable	components,	items,	or	

equipment.	If	the	inspection	reveals	a	condition	that	affects	the	safe	

operation of	the	UAS,	the	aircraft	will	be	prohibited	from	operating	until	the	

necessary	maintenance has	been	performed	and	the	UAS	is	found	to	be	in a	

condition	for	safe	flight.	

11. The	operator will	follow the	UAS	manufactures’	maintenance,	overhaul,	

replacement,	inspection,	and	life	limit	requirements	for	the	aircraft	and	

aircraft	components.	

12. Each	UAS	operated	under	the	exemption	will	comply	with	all	manufacturer	

safety	bulletins.

13. The PIC	will	posses	at	least	a	Sport	Pilots	Certificate	and	a	current	ThirdClass	FAA	Airman	Medical	Certificate.	The	PIC	will	also	meet	the	flight	

review	requirements	specified	in	14	CFR	61.56.

14. The Operator	may	not	permit	any	PIC	to	operate	unless	the	PIC	has	

demonstrated that	the	PIC	is	able	to	safely	operate	the	UAS	in	a	manner	

consistent with	how the	UAS	will	be	operated	under	the	exemption,	

including	evasive	and	emergency	maneuvers and	maintaining	appropriate	

distance	from	people,	vessels,	vehicles,	and	structures.	PIC	qualification	

flight	hours	and	currency	will	be	logged	in	a	manner	constant	with	14	CFR	

Section	61.51(b).	Flights for	the	purposes	of	training	the	Operators, PICs,

and	VOs	(training,	proficiency,	and	experience-building)	and	determining	

the	PICs ability	to safely	operate	the	UAS	in	a	manner	consistent with	how	

the	UAS	will	be	operated	under	the	exemption	will	be	permitted	under	the	

terms	of	this	exemption.	However,	training	operations	will	only be	

conducted	during	dedicated	training	sessions.	During	training,	proficiency	

and	experience	building	flights,	all	persons	not	essential	for	flight	operations	

are	to be	considered	non-participants	in	accordance	with	14CFR	Section	

91.119

15. UAS	operations	will	not	be	conducted	during	night,	as	defined	in	14	CFR	

Section	1.1.	All	operations	will	be	conducted	under	Visual	Meteorological	

Conditions	(VMC).	Flights under	Special	Visual	Flight	Rules	(SVFR)	will	not	

be	conducted.	
Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra	Hoover

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16. The	UA	will	not	operate	within 5	nautical	miles	of	an	airport	reference point	

(ARP)	as	denoted	in	the	current	FAA	Airport/Facility	Directory	(AFD) or,	for	

airports not	denoted	with	an	ARP,	the	center	of	the	airport	symbol	as

denoted	on	the	current	aeronautical	chart	published	by	the	FAA,	unless	a	

letter	of	agreement	with	that	airports	management is	obtained	or	otherwise	

permitted	by	a	COA	issued	to	the	exemption	holder.	The	letter	of	agreement

with	the	airport	management	will	be	made	available	to	the	Administrator	or	

any	law	enforcement official	upon	request.	

17. The	UA	will	not	be	operated	less	than	500	feet	below	or	less	than	2,000	feet	

horizontally	from	a	cloud	or	when	visibility	is	less	than	3	statute	miles	from	

the	PIC.	

18. If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UA will	return	to	

a	pre-determined	location	or	recovery	point	within	the	private	or	

controlled-access	property.	

19. The	PIC	will	abort	the	flight	in	the	event	of	unprecedented	obstacles or	

emergencies.	

20. The	PIC	will	not	begin	a	flight	unless	(considering	wind and	forecast weather	

conditions)	there	is	enough	available power	for	the	UA	to	conduct	the	

intended	operation and	still	maintain	a	reserve	battery power	of	no	less	than	

25%.

21. The	operator	will	apply	for	and	obtain	an	Air	Traffic	Organization	(ATO)	

issued	Certificate	of	Waiver	or	Authorization	(COA)	prior	to	conducting	any	

operations	under	the	Grant	of	Exemption.

22. All	aircraft	operated	in	accordance	with	the	exemption	will	be	identified	by	

serial	number	or	equivalent,	registered	in	accordance	with	14	CFR	part	47,	

and	have	identification	(N-number)	markings	in	accordance	with	14	CFR	

part	45,	subpart	C.	Markings	will	be	as	large	as	practical.	

23. Documents used	by	the	Operator	to	ensure	the	safe	operation	and	flight	of	

the	UAS	and	any	documents	required	under	14	CFR	Sections	91.9	and	

91.203	will	be	available	to	the	PIC	at	the	Ground	Control	Station	of	the	UAS	

at	any	time	the	aircraft	is	operating.	These	documents	will	be	made	available	

to	the	Administrator	or	any	law	enforcement	official	upon	request.	

24. The	UA	will	remain	clear	and	give	way	to	all	manned	aviation	operations	and	

activities	at	all	times.	

25. The	UAS	will	not	be	operated	by	the	PIC	from	any	moving	device	or	vehicle.
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26. All	flight	operations	will	be	conducted	at	least	500	feet	from	all	non	

participating	persons,	vessels,	and	structures unless:	

a. Barriers	or	structures	are	present	that	sufficiently	protect	nonparticipating	persons from	the	UA	and/or	debris	in	the	event	of	an	

accident.	The	operator	will	insure	that	non-participating	persons	remain	

under	such	protection.	If	a	situation	arises	where	non-participating	

persons	leave	such	protection and	are	within	500	feet	of	the	UVA,	flight	

operations	will	cease	immediately	in	a manner	insuring	the	safety	of	

non-participating	persons;	and,

b. The	owner/controller	of	any	vessels,	vehicles,	or	structures has	granted	

permission for	operating	closer	to	those	objects	and	the	PIC	has	made	a	

safety	assessment	of	the	risk	of	operating	closer	to	the objects	and	

determined	that	it	does	not	present an	undue	hazard.	The	PIC,	VO,	

Operator, trainees	or	essential	persons	will	not	be	considered	nonparticipating	persons	under	the	exemption.	

27. All	operations	shall	be	conducted	over	private	or	controlled-access	property	

with	permission	from	the	land	owner/controller	or	authorized	

representative.	Such	permission	will	be	obtained	for	each	flight.

28. Any	incident,	accident,	or	flight	operation	that	transgresses	the	lateral	or	

vertical	boundaries of	the	operational	area	as	defined	by	the	applicable	COA	

will	be	reported	to	the	FAA’s	UAS	Integration	Office	(AFS-80)	within	24	

hours.	Accidents	will	be	reported	to	the	National	Transportation	Safety	

Board	(NTSB)	per	instructions	contained	on	the	NTSB	Web	site:	

www.ntsb.gov.

29. The Operator	will	engage	in	closed-set	motion	picture	and	television	filming	

and	production	in	accordance	with	the	conditions	enumerated	and	

described	in	the	flight	operations	and	procedures	manual	(FOPM),	and	

approved	motion	picture	and	television	operation	manual	(MPTOM)	to	be	

attached to	this	petition	as	appendix	“H”.

30. At	least	3	days	before	aerial	filming,	the	Operator	of	the	UAS	which	is	subject	

to	this	exemption	will	submit	a	written	Plan	of	Activities to	the	local	Flight	

Standards	District	Office	(FSDO)	with	jurisdiction	over	the	area	of	proposed	

filming.	The	3-day	notification	may	be	waived	with	the	concurrence	of	the	

FSDO.	The plan	of	activities	must	include	at	least	the	following:

a. Dates	and	times	for	all	flights;

b. Name	and	phone	number	of	the	operator for	the	UAS	aerial	filming	

conducted	under	the	grant	of	exemption;

c. Name	and	phone	number	of	the	person	responsible	for	the	on-scene	

operation	of	the	UAS;

d. Make,	model,	and	serial	number	or	N-Number	of UAS	to	be	used

e. Name	and	certificate	number	of	UAS	PICs	involved	in	the	aerial	filming;
Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra	Hoover

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f. A statement	that	the	operator	has	obtained	permission	from	property	

owners	and/or	local	officials	to	conduct	the	filming	production	event;	the	

list	of	those	who	gave	permission must	be	made	available	to	the	

Inspector	upon	request;

g. Signature	of	the	exemption holder	or	representative;	and

h. A description	of	the	flight	activity,	including	maps	or	diagrams	of	any	

city,	town,	county,	and/or	state	over	which	filming	will	be	conducted	and	

the	altitude	essential	to	accomplish	the	operation.	

31. Flight	operations	may	be	conducted	closer	than 500	feet	from	participating	

persons	consenting	to	be	involved	and	necessary	for	the	filming production,	

as	specified	in	the	MPOTM.

THE	PUBLIC	INTEREST

The	public	interest	in	granting	this	exemption	request	is	served	by,	among	others,	

the	following:

• The	use	of	UAS	improves	public	safety	and	reduces	risk	by	alleviating	the	

public’s	exposure	to	danger	and	emissions	associated	with	conventional	

aerial	methods	(full	size	aircraft)	that	are	very	heavy,	fast,	carry	passengers,	

and	contain	flammable fuel	and	cargo.

• A	myriad of	ecological	ad	environmental	benefits	and	improved	economic	

efficiency	and	scientific	information	and	data	acquisition	are	potential	public	

benefits	accomplished	through	the	use	of	UAS	for	precision	inspections	of	

infrastructure	and	industrial	plant	equipment	such	as	energy	pipelines,	

power	lines,	smokestacks,	towers,	and	other	man-made	structures,	which	can	

be	observed	and	later	analyzed	safely,	accurately	and	un-obtrusively.

• Commerce	can	be	improved	through	data	and	image	acquisition	for real

estate,	construction,	precision	agriculture,	surveying	and	other	applications

of	UAS	technology.

• The	visual	arts	such	as	film,	photography	and	television	are	improved	

through exciting	and	beautiful	images	captured	via	the	versatile	aerial	

platform	UAS	provides,	which	benefits	the	collective	cultural	and	aesthetic	

demands	and	desires	of	an	appreciative	public.	

• UAS	may	be	an	exceptional	tool	for	journalists	and	all	manner	of	news	

gathering	and	reporting	media,	to	serve	the	public	good	in	enhancing

accurate	dissemination	of	news	worthy and	relevant	information	to	

interested	citizens.

• Approval	of	this	exemption	will	provide	immediate	employment	

opportunities	for	individuals	and	businesses	whose	livelihood	may	be	

directly or	indirectly	improved	though	career	opportunities and	job	creation

in	a	growing	technology	sector	of	the	economy.	
Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra	Hoover

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• Congress	has	established	a	national	policy	that	favors	prompt	integration	of	

UAS	into	the	NAS,	provided	that	judicious	and	reasoned	agencies	and	officials	

guide	the	process	prudently	and	with	due	emphasis	on	public	safety	and	

efficiency.	The	granting	of	this	petition	for	exemption	will	serve	this	public	

policy	mandate	and	result	in	the	attendant	benefits	perceived	by	this	policy.	

SUMMARY	FOR	PUBLICATION

For publication	in	the	Federal	Register,	Alexandra	Hoover	provides	the	following	

summary:

An	exemption	is	requested	from	the	following	regulations	in	order	to	allow	

commercial	operation	of	her	Unmanned	Aircraft	Systems	involving	aerial	

applications	such	as	closed–set	motion picture	and	television	filming,	general	aerial	

photography	and	videography	for	inspection	of	land,	structures,	construction	

projects	and	real	estate,	videography	and	photography	for	journalism	and	news	

gathering	purposes,	digital	imagery	and	data	acquisition	for	precision	agriculture,	

environmental	management,	and	scientific	analysis.	

14	CFR	Section	61.113	(a)	and	(b)

14	CFR	Section	91.7	(a)

14	CFR	Section	91.119	(c)

14	CFR	Section 91.212

14	CFR	Section91.151	(a)	(1)

14	CFR	Section	91.405	(a)

14	CFR	Section	91.407	(a)	(1)

14	CFR	Section	91.409	(a)	(1)	and	(a)(2)

14	CFR	Section91.417	(a)	and	(b)

CONCLUSION

Alexandra	Hoover	seeks	an	exemption,	pursuant	to	14	CFR	Section	11.61	and	

Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(FMRA),	which will	

permit	Alexandra	Hoover	to	safely	operate	UAS	commercially	for	the	purposes	and	

operations	described	herein.	In granting	this	Petition,	the	FAA	Administrator	will	be	

fulfilling	the	congressional	mandate	and	policy	of	FMRA,	while	also	providing	a	

significant	number	of	benefits	to	the	public,	the	environment	and	the	economy.	The	

exemption	will	enable	Alexandra	Hoover	to	utilize	her	technological	expertise,	

advanced	aircraft	knowledge,	and	entrepreneurial vision	to	enhance	the	safety,	

beauty	and	economic	progress	of	the	public	and	private	sectors	and	advancing	the	

interest	of	society	at	large.	

Alexandra	Hoover	respectfully	requests	that	the	Administrator	grant	this	Petition	

for	an	exemption from	the	requirements	discussed therein,	and	permit	Alexandra	to	

operate	commercially	the	Unmanned	Aircraft	Systems	in	the	aerial	operations	set	

forth	herein.	
Petition	for	Exemption	FAA	Modernization	&	Reform	Act	of	2012 Alexandra	Hoover

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Thank	you	for	your	consideration.	

Sincerely,	

/s/Alexandra	Hoover

Alexandra	Hoover

ATTACHMENTS

(Appendix A	through	E files	are too	large	to	upload	to	the	regulations	docket,	please	

accept	these	links	to	the	documents	online)

Appendix	A	– Manual	and	Safety	guide	for	the	Inspire	1

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

Appendix	B	– Manual	and	Safety	Guide	for	the	Phantom	2

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.8_

en.pdf

Appendix	C	– Manual	and	Safety	Guide	for	the	Spreading	Wings	S1000+

http://download.djiinnovations.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf

Appendix	D	– Manual	and	Safety	Guide	for	the	Spreading	Wings	S900

http://download.dji-innovations.com/downloads/s900/en/S900_User_Manual_v1.2_en.pdf

Appendix	E	– Manual	and	Safety	Guide	for	the	Spreading	Wings	S800	EVO

http://download.djiinnovations.com/downloads/s800evo/en/S800_EVO_User_Manual_v1.10_en.pdf

Appendix	F	– Pre-Flight	Checklist	and	In-Flight	Safety	Checklist

Appendix	G	– Flight	Log	forms	and	Maintenance	Log	forms

Appendix	H	– Motion	Picture	and	Television	Operation	Manual