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Vertical Imagery LLC Section 333 Petition 

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

VERTICAL IMAGERY LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE 

REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS (14 

CFR) PART 21 SECTIONS; § 61.113(a) and (b), 91.7(a), 91.121, 91.151(b), 91.203(a) 

and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b).

CONCERNING OPERATION OF AN UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF THE

FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted on April 13, 2015 

Vertical Imagery LLC 

Ryan P. Corey 

P.O. Box 1345 

2275 Dead Indian Memorial Road 

Ashland, OR 97520 

 (541) 488-2880 

ryan@timberlandhelicopters.com
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Vertical Imagery LLC Section 333 Petition 

TABLE OF CONTENTS

Glossary of abbreviations 3

Summary 4

Introduction and interests of the petitioner 4

Background 5

Proven operational history of DJI T600 in 

the NAS 

6

Basis for petition 7

Name and address of petitioner 7

Specific sections of C.F.R. from which 

Vertical Imagery seeks exemption 

8

Reasons why granting Vertical Imagery's 

request would be in the public interest 

10

Flight Operations 11

Flight operations of Vertical Imagery's UAV 

is limited to line of sight of the PIC with a 

Visual Observer 

12

Operation of Vertical Imagery’s UAV will 

be conducted pursuant to the Standard 

Operating Procedures manual 

12

Conclusion 13

 
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Vertical Imagery LLC Section 333 Petition 

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

ATC Air Traffic Control 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

NAS National Airspace System 

PIC Pilot In Command 

Section 333 FAA Modernization and Reform Act of 2012, Section 333 

SOP Standard Operating Procedures 

UAS Unmanned Aircraft System 

UAV Unmanned Aerial Vehicle

UH Unmanned Helicopter 

VFR Visual Flight Rules 

VMC Visual Meteorological Conditions 

VO Visual Observer 

VTOL Vertical Take Off and Landing 
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Vertical Imagery LLC Section 333 Petition 

SUMMARY

Vertical Imagery LLC seeks exemption from the requirements of 14 C.F.R. §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), 

and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 

of the FAA Modernization and Reform Act of 2012. In consideration of the speed, 

weight, size, and limited operating area associated with the unmanned aircraft and its 

operation, Vertical Imagery LLC's operation of the DJI T600 "Inspire 1" Unmanned 

Helicopter meets the conditions of FMRA Section 333 and therefore, will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. This 

exemption will permit Vertical Imagery LLC to operate an Unmanned Aircraft System for 

the commercial purpose of conducting aerial data collection and research within the 

National Airspace System.

INTRODUCTION AND INTERESTS OF THE PETITIONER

 Vertical Imagery LLC (Hereinafter referred to as “Vertical Imagery”) is owned and 

managed by professional, highly experienced commercial helicopter pilots who are Part 

133, 135, and 137 current. Vertical Imagery's pilots have an extensive history of power 

line and utility patrol, wildlife survey, electronic news gathering, search & rescue, and 

firefighting work across the Pacific Northwest. Vertical Imagery has recently acquired 

and been flight testing a DJI Inspire 1 Unmanned Helicopter which it plans to use for 

commercial operations including power line and public utility inspections, wildland fire 

patrols, aerial surveys, electronic news gathering, and aid in search & rescue 

operations. Vertical Imagery's lead pilot on the project has over 2000 hours helicopter 

flight time, as well as over 20 years experience and thousands of hours of UAV flight 

time. Vertical Imagery plans to work side by side with its sister company to diversify 

their fleet of aircraft with an unmanned helicopter in order to meet the needs of a 

continually evolving market while striving for an ever increasing level of safety to their 

employees and customers. 
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Vertical Imagery LLC Section 333 Petition 

BACKGROUND

 Vertical Imagery seeks an exemption to operate a DJI model T600 unmanned 

helicopter known as the "Inspire 1" for compensation or hire within the national airspace 

system. The Inspire 1 is comprised of a 4 rotor helicopter with attached HD camera 

system and a transportable ground station. The Inspire 1 UH has a maximum gross 

weight of approximately six and a half pounds (6.5 lbs.) and the following technical and 

operational specifications: 

Weight (Battery and Camera included) ................................. 6.5 lbs. 

Dimensions ........................................................................... 17.3" x 17.8" x 11.9" 

Hover Accuracy (GPS Mode) 

 Vertical ....................................................................... 1.6 ft. 

 Horizontal ................................................................... 8.2 ft. 

Max Angular Velocity 

 Pitch ........................................................................... 300°/sec. 

 Yaw ............................................................................ 150°/sec. 

Max Tilt Angle ....................................................................... 35° 

Max Ascent Speed ................................................................ 16 ft./sec. 

Max Descent Speed .............................................................. 13 ft./sec. 

Max Air Speed ..................................................................... 49 mph 

Service Ceiling ...................................................................... 14,500 ft. 

Max Flight Time .................................................................... 18 min. approx. 

Motor Model .......................................................................... DJI 3510 

Rotor Blade Model ................................................................ DJI 1345 

Operating Temperature Range ............................................. -10° to 40° C 

Supported Battery ................................................................. DJI Intelligent Battery 

Type ...................................................................................... 6S Lithium Polymer 

Capacity 

 Standard Battery ........................................................ 4700 mAh, 22.2 V 

 Optional Battery ......................................................... 5700 mAh, 22.8 V 

 
Vertical Imagery LLC Section 333 Petition 

Operating Frequency ............................................................

 

EIRP .....................................................................................

 

 The Inspire 1 UH that will be operated by 

accordance with 49 U.S.C. 44103, 

Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, 

and Registration Marking. 

Figure 1: DJI T600 "Inspire

PROVEN OPERATIONAL HISTORY OF 

 Many DJI T600's are currently operating safely 

commercial UAV's. The UH has onboard stability systems, compass, ground sensing 

sonic altimeters, and GPS. All of these allow the UH to hover with pinpoint precision and 

also take off and land autonomously. There is a failsafe built into the system allowing 

the UH to return to a predetermined point 

altitude in the event of a control link failure between the aircraft and PIC.

automatically return home when the battery has reached a predetermined level, which 

ensures the aircraft will land before 

leader in UAS technology and 

Section 333 Petition 

............................................................ 2.4~2.483 GHz 

 5.725~5.825 GHz

EIRP ..................................................................................... 20 dBm @ 2.4G

 13 dBm @ 5.8G

that will be operated by Vertical Imagery will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R. Part 47, 

, and marked in accordance with 14 C.F.R. Part 45, Identification 

1" 

ROVEN OPERATIONAL HISTORY OF DJI T600 IN THE NAS

are currently operating safely within the NAS both as hobby and 

The UH has onboard stability systems, compass, ground sensing 

sonic altimeters, and GPS. All of these allow the UH to hover with pinpoint precision and 

also take off and land autonomously. There is a failsafe built into the system allowing 

n to a predetermined point (known as "home") at a predetermined 

altitude in the event of a control link failure between the aircraft and PIC.

return home when the battery has reached a predetermined level, which 

ensures the aircraft will land before the battery level becomes critical. DJI 

leader in UAS technology and also makes several other models which have logged 

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GHz 

5.725~5.825 GHz

20 dBm @ 2.4G

13 dBm @ 5.8G

will be registered in 

, as well as 14 C.F.R. Part 47, 

Identification 

NAS

both as hobby and 

The UH has onboard stability systems, compass, ground sensing 

sonic altimeters, and GPS. All of these allow the UH to hover with pinpoint precision and 

also take off and land autonomously. There is a failsafe built into the system allowing 

at a predetermined 

It will also 

return home when the battery has reached a predetermined level, which 

DJI is the world 

which have logged 
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Vertical Imagery LLC Section 333 Petition 

countless hours across the world with great success, giving DJI a reputation for some of 

the best technology, popularity, and reliability in the industry.

BASIS FOR PETITION

 Petitioner, Vertical Imagery, pursuant to the provisions of the Federal Aviation 

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

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator for an exemption from the requirements of 14 C.F.R. §§ 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & 

(b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012. In consideration of the speed, weight, size, and 

limited operating area associated with the unmanned aircraft and its operation, Vertical 

Imagery's operation of the DJI Inspire 1 UAS meets the conditions of FMRA Section 333 

and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. In accordance with 14 C.F.R. § 11.81, Vertical Imagery provides the 

following information in support of its petition for exemption: 

NAME AND ADDRESS OF THE PETITIONER

Vertical Imagery LLC 

P.O. Box 1345 

Ashland, OR 97520 

The point of contact for Vertical Imagery's petition and specific contact information is as 

follows: 

Ryan P. Corey 

Vertical Imagery LLC 

P.O. Box 1345 

Ashland, OR 97520 

(541) 488-2880 

ryan@timberlandhelicopters.com 
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Vertical Imagery LLC Section 333 Petition 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH VERTICAL IMAGERY 

SEEKS EXEMPTION

14 C.F.R. § 61.113(a) & (b): Private pilot privileges and limitations: Pilot in 

command.

 Sections 61.113(a) & (b) limit private pilots to non-commercial operations. 

Because the UAV will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety of current operations by requiring the PIC 

operating the aircraft to have a private pilot’s license rather than a commercial pilot’s 

license to operate the small UAV. Unlike a conventional aircraft that carries the pilot and 

passengers, Vertical Imagery's UAV is remotely controlled with no living thing on board. 

The area of operation shall be controlled and restricted, and all flights are planned and 

coordinated in advance as set forth in the Vertical Imagery SOP. The level of safety 

provided by the requirements included in the SOP exceeds that provided by a single 

individual holding a commercial pilot’s certificate operating a conventional aircraft. The 

risks associated with the operation of the UAV is so diminished from the level of risk 

associated with commercial operations contemplated by Part 61 when drafted, that 

allowing operations of this UAV as requested with a private pilot as the PIC exceeds the 

present level of safety achieved by 14 C.F.R. §61.113(a) & (b). 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

 The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should Vertical Imagery's exemption be granted, no FAA regulatory standard will exist 

for determining airworthiness. Given the small size and simplicity of the aircraft and the 

requirements contained in the SOP and Maintenance Manual for maintenance and use 

of preflight check lists prior to each flight, an equivalent level of safety will be provided. 

14 C.F.R. §91.121 Altimeter settings. 

 The regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure 
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Vertical Imagery LLC Section 333 Petition 

airport or an appropriate altimeter setting available before departure.” As the UAS does 

not have a barometric altimeter, but instead a GPS height AGL read out and a sonic 

ground proximity sensor, an exemption may be needed. An equivalent level of safety 

will be achieved by way of the UAS recording its position as zero feet AGL upon 

powering on, and during flight the height AGL is displayed in real time to the PIC's 

display. The UH is also equipped with a sonic ground proximity sensor which detects 

height AGL and automatically corrects the flight altitude to help prevent inadvertent flight 

into terrain.

14 C.F.R. § 91.151(b): Fuel requirements for flight in VFR conditions. 

 Section 91.151(b) prohibits an individual from beginning “a flight in a rotorcraft 

under VFR conditions unless (considering wind and forecast weather conditions) there 

is enough fuel to fly to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 20 minutes.” The batteries powering the Inspire 1 

provide approximately 18 minutes of powered flight, therefore meeting the 20 minute 

reserve requirement is not possible. Vertical Imagery believes that an equivalent level of 

safety can be achieved by limiting flights to 25% of remaining battery power. The UAS is 

also equipped with an audio warning which is set to notify the pilot at a predetermined 

battery level remaining. If the battery drops below this level, the UH will automatically 

return home and land, preventing the UH from being in the air when the battery reaches 

critically low levels. Vertical Imagery's 25% restriction and the UAS's automated 

systems would be more than adequate to return the UH to its planned landing zone 

from anywhere in their limited operating area. 

14 C.F.R. §91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections. 

 Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Vertical Imagery. Maintenance will be 

accomplished by Vertical Imagery pursuant to the SOP, User Manual, and Maintenance 

Manual. An equivalent level of safety will be achieved because the UAS will still receive 

both scheduled and preventative maintenance. As provided in the SOP, Vertical 

Imagery will ensure that the Inspire 1 is in working order prior to initiating flight, perform 
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Vertical Imagery LLC Section 333 Petition 

required maintenance, and keep a log of any maintenance performed. Moreover, the 

operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety. 

REASONS WHY GRANTING VERTICAL IMAGERY'S REQUEST WOULD BE IN THE 

PUBLIC INTEREST

 Granting the present petition will further the public interest by allowing Vertical 

Imagery to safely, efficiently, and economically assist its sister company in performing 

aerial inspection services of power transmission towers, lines and other public utilities, 

along with conducting aerial surveys, electronic news gathering, wildland fire perimeter 

patrols, and aiding is search & rescue operations. 

 Use of the Vertical Imagery UH for public utilities will increase worker safety by 

reducing human exposure to climbing towers and reduce the need to fly manned 

helicopters close to transmission towers for inspection purposes. This will also reduce 

the amount of time required to perform both routine and emergency inspections of the 

utilities. 

 Conducting aerial surveys with the UH will reduce the need to fly biologists low 

and slow over sometimes heavily forested areas in order to take accurate counts. This 

will also greatly reduce harassment to wildlife due to the UH having a much smaller, 

almost imperceptible, noise signature. 

 Smaller news stations often don't have the budget to pay full sized helicopters to 

perform aerial work. Utilizing Vertical Imagery's UAS will allow local stations to better 

gather information and provide the public with more timely and accurate news. 

 Vertical Imagery works in conjunction with many fire agencies including local, 

state, and federal who are very interested in the benefits of a UAS to provide better 

understandings of wildland fire perimeter conditions. This can greatly benefit fire 

agencies by allowing them to quickly get aerial views of the fire, allowing them to make 

faster, more informed decisions. 

 Vertical Imagery also works with several public agencies conducting search and 

rescue operations. These operations can be enhanced with a UAS by allowing an "eye 

in the sky" to quickly and efficiently aid in searches. 
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Vertical Imagery LLC Section 333 Petition 

FLIGHT OPERATIONS

 Operations will only be conducted in the continental United States. As stated in 

Vertical Imagery's SOP, proposed areas of aerial operations include areas that are: 

1. Not over congested areas or near large gatherings of people. 

2. Not within 5 miles of any airport without airport manager's permission. 

3. Not within 100 yards of persons or property non-essential to the mission. 

5. UH will remain within visual line of sight of the PIC and VO. 

6. No flight above 400 feet AGL. 

 14 C.F.R. §1.1 defines rotorcraft as "a heavier-than-air aircraft that depends 

principally on its support in flight on the lift generated by one or more rotors." It also 

defines helicopter as "a rotorcraft that, for its horizontal motion, depends principally on 

its engine driven rotors." The Inspire 1 meets these criteria and therefore should not 

require a waiver to operate under §91.119 since it can fulfill the requirements of 

§91.119(d). However, Vertical Imagery will take an added level of safety and not 

operate over any congested area in addition to operating with extra requirements as per 

its SOP. 

 Vertical Imagery will operate its UAV by regulations such as the ICAO 

(International Civil Aviation Organization) and the FAA’s own national airspace 

regulations. In order to increase flight safety and prevent accidental flights in restricted 

areas, thorough preflight action will be taken to ensure no airspace violations will occur. 

As stated in the SOP, extra measures will also be taken to ensure operations are 

always conducted in class G airspace in day VMC with 3 miles visibility. Vertical 

Imagery's customers often require flights to occur with as little as 2-3 hours notice, 

therefore a requirement to obtain a NOTAM prior to each flight will greatly hinder the 

ability of Vertical Imagery to fulfill its customers' needs. These are jobs which are 

normally performed by Vertical Imagery's sister company with a manned helicopter, and 

being able to do these missions with an unmanned helicopter will not only provide an 

equivalent level of safety, but introduce an added level of safety and service to Vertical 

Imagery's customers. 
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Vertical Imagery LLC Section 333 Petition 

FLIGHT OPERATIONS OF VERTICAL IMAGERY'S UAV IS LIMITED TO LINE OF 

SIGHT OF THE PIC WITH A VISUAL OBSERVER

 Vertical Imagery will only utilize PIC’s with a valid Private Pilot rating certificate 

issued by the FAA for operation of the UAS and a valid Class II Medical Certificate 

along with extensive company training as listed in the SOP. Additionally, all pilots will be 

assisted by a Visual Observer. The PIC and VO must meet the requirements as set 

forth by the SOP which include training, briefings, and remaining within voice 

communication range throughout the flight. Both the VO and PIC will remain within line 

of sight of the UH during the operation. 

OPERATION OF VERTICAL IMAGERY’S UAV WILL BE CONDUCTED PURSUANT 

TO THE STANDARD OPERATING PROCEDURES MANUAL

 Vertical Imagery's SOP will control operation of the UAS and will significantly 

contribute to maintaining the level of safety contemplated by the airworthiness certificate 

requirements from which Vertical Imagery now seeks relief. Pursuant to the 

Maintenance Manual, User Manual, SOP, and 14 C.F.R. § 43.13, entitled Performance 

Rules (general), each person performing maintenance, alteration, or preventive 

maintenance on Vertical Imagery's UH, motors, rotors, hardware, guidance systems or 

appliances shall use the methods, techniques, and practices prescribed in the current 

manufacturer's Maintenance Manual or Instructions for Continued Airworthiness 

prepared by its manufacturer, or other methods, techniques, and practices acceptable 

to the Administrator. Each person shall use the tools, equipment, and test apparatus 

necessary to assure completion of the work in accordance with accmkojnnk;epted 

industry practices. A copy of the SOP, Maintenance Manual, and Flight Record & 

Maintenance Log which is proprietary information to Vertical Imagery, is attached hereto 

as Exhibit B, and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b) 
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Vertical Imagery LLC Section 333 Petition 

CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of 

applicant’s UAS pursuant to the manual's appended hereto. 

_____________________________ 

Submitted on April 13, 2015 

Ryan P. Corey 

Vertical Imagery LLC 

P.O. Box 1345 

2275 Dead Indian Memorial Road 

Ashland, OR 97520 

(541) 488-2880 

ryan@timberlandhelicopters.com