NorthWest Aerial Perspectives

1 | Page – NWAP Exemption Request

April 30, 2015

April 28, 2015

Thomas M. Ethen

15414 W Bluegrass Rd

Nine Mile Falls, WA 99026

(509) 733-2928

teimages@sbcglobal.net

Petition of Northwest Aerial Perspectives

For Exemption Pursuant to Section 333 

Of the FAA Modernization and Reform Act of 2012

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR

Part 11, Northwest Aerial Perspectives (NWAP), hereby applies for an exemption from

Federal Aviation Regulations (FARs) identified below, to allow commercial operations of small 

unmanned aerial systems (i.e., sUAS).

This exemption is in accordance with protocols outlined in this petition for exemption, and any 

other requirements established by the FAA pursuant to Section 333 of the Reform Act.

This exemption would permit commercial operation by NWAP, which uses a DJI Phantom 2, a 

SynDrone X8 multirotor and a Gemini fixed wing sUAS to conduct:

- Aerial surveying

- Event Photography/Videography

- Agriculture purposes

- Real Estate Photography

- Aerial Filmmaking and Photography

- Construction Site Inspections and Monitoring, and

- News Gathering and First Responders.

NWAP’s operation under the exemption will be subject to strict operating requirements and 

conditions to ensure an equivalent level of safety to currently authorized operations using manned 

aircraft and under conditions as may be modified by the FAA as required by Section 333.

NWAP's sUAS will be operated under controlled VFR conditions at low altitudes. They will 

operate the sUAS’s with pilots who have comprehensive UAV / UAS / Drone flight training for 

competency and new FAA 333 and Part 107 commercial compliance requirements. Finally, when 

required, the FAA ATC will approve the airspace in which the sUAS will operate in advance.

NorthWest Aerial Perspectives respectfully submits this request for an exemption because it 

operates sUAS's. The FAA can have confidence that the operations will be conducted at an 

equivalent level of safety or greater. Approval of this exemption would thereby enhance safety and 

fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Section 
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April 30, 2015

333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems 

in the national airspace system.”

For your convenience, NWAP has organized this Exemption request as follows:

I. Petitioner's Description

II. Relevant Statutory Authority

III. Qualifications for Approval Under Section 333 of the Reform Act

IV. Description of Proposed Operations

V. Regulations From Which Exemption is Requested

VI. Public Interest

VII. Privacy

VIII. Federal Registry Summary

IX. Conclusion

I. Petitioner's Description:

NorthWest Aerial Perspectives, headquartered in Nine Mile Falls, WA, is a company that 

provides sUAS support to news and event videography, real estate and construction site 

photography, film and movie production, precision agricultural purposes, education, and 

demonstration flights in a compliant and safe environment. NWAP plans on providing a wide 

range of services as the sUAS market expands.

NWAP's goal is to operate in an accident-free environment by:

• Demonstrating a commitment by management and all employees to operate in a compliant 

manner.

• Identifying hazard and risk while eliminating or controlling all these risks.

• Using steps to intervene and report when unsafe work practices appear to exist.

• Training all employees involved in flight operations to operate at the highest standard level.

The contact information for Petitioner is as follows:

NorthWest Aerial Perspectives, 

15414 W Bluegrass Rd

Nine Mile Falls, WA 99026

Owners:

Thomas Ethen

Dave Plouffe

Office: (509) 733-2928

Email: teimages@sbcglobal.net

II. Relevant Statutory Authority:

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through 

(c) of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil 

unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the 

Reform Act, the FAA Administrator is to consider whether certain unmanned aircraft systems may

operate safely in the National Airspace ("NAS") before completion of the formal UAS rulemaking, 

based on the following considerations:

• The UAS's size, weight, speed, and operational capability;
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April 30, 2015

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within the visual line of sight of the operator.

If the Secretary determines that such vehicles "may operate safely in the National Airspace System, 

the Secretary shall establish requirements for the safe operation of such aircraft in the National 

Airspace System".

Additionally, the FAA Administrator has general authority to grant exemptions from its safety 

regulations and minimum standards, and has done so on numerous occasions, when the 

Administrator decides a requested exemption is in the public interest. A party requesting an 

exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, 

and (2) would not adversely affect safety (or how it would provide a level of safety at least equal to 

the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under 

40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness 

certificate and those regulations requiring commercial pilots to operate aircraft in commercial 

service:

The Administrator may grant an exemption from a requirement of a 

regulation prescribed under subsection (a) or (b) of this section or 

any of sections.

III. Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for expedited approval under 

Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are 

satisfied.

The proposed operations would permit NWAP the use of small UAS under controlled conditions 

in airspace that is: (1) predetermined; (2) controlled as to access; and that (3) provides an increased 

level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the 

same purpose.

NWAP uses sUASs that are multirotor, weighing less than 30 pounds including payload. They 

operate, under normal conditions, at speeds not to exceed 100 mph and have the capability to fly, 

hover, and move in the vertical and horizontal plane. NWAP’s sUASs will operate in line of sight, 

during daylight hours, and will only operate within a sterile area. NWAP will operate at or below 

500 feet AGL and will file a NOTAM for each flight operated in controlled airspace. All required 

permissions and permits would be obtained from territorial, state, county or city jurisdictions, 

including local law enforcement, fire, or other appropriate governmental agencies prior to 

operating a sUAS.

Given the small size of the sUAS’s involved and the restricted sterile environment within which 

they will operate, NWAP’s exemption falls within the zone of safety and demonstrates an 

equivalent level of safety, in which Congress desired the FAA to permit commercial UAS 

operations by exemption pending completion of formal rulemaking. Also, due to the size of the 

sUAS’s and the confined area in which the sUAS’s will operate, approval of the application 

presents no hazard in the NAS.

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, the grant of the requested exemptions is also in the 

public interest.
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April 30, 2015

IV. Description of Proposed Operations

To assist the FAA in its safety assessment of NWAP's proposed sUAS operations, below is a 

summary of operational limitations and conditions that will ensure an equivalent or higher level of 

safety to operations conducted under current regulatory guidelines:

1. The sUAS will weigh less than 30 pounds.

2. Flights will be operated within line of sight of the PIC and observer.

3. Maximum total flight time for each operational flight will be limited to the amount of time 

the sUAS can be flown and still maintain a reserve battery power of no less than 25%.

4. Flights will be operated at an altitude of no more than 500 feet AGL.

5. Flights will be operated at a lateral distance of least 100 feet from any inhabited structures, 

buildings, vehicles, vessels, people not associated with the operation or who have not 

signed a waiver in advance of the operation.

6. Minimum crew for each operation will consist of the sUAS Pilot in Command and a 

Visual Observer.

7. The sUAS Pilot in Command will hold at least a sport pilot or recreational pilot certificate 

and a valid U.S. drivers license. 

8. NWAP will designate a Pilot in Command (PIC) for each mission.

9. The sUAS will operate only within a confined "Sterile Area".

10. Prior to the operations at a particular location, a site inspection will have been conducted. 

On the day of the mission the management person with operational control and the PIC 

will concur on dispatching of the mission.

11. A briefing will be conducted in regard to the planned sUAS operations prior to each day's 

missions. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the sterile area be present for this briefing.

12. NWAP crew will use the checklist and callouts required in the Operations Manual.

13. All sUAS’s will be maintained in accordance with inspection program specified in the 

manufacturer’s guidelines.

14. In the event of an accident involving an NWAP sUAS, they will cease operations and 

report the accident to the NTSB and AFS-80.

15. Pilot in Command and Visual Observer will at all times be able to communicate by voice.

16. Pilot in Command, Visual Observer, Camera Operator, and Operational Personnel will 

have been trained and tested in accordance to FAA, NTSB, and AFS-80 best practices.

17. All required permissions and permits would be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire or other appropriate governmental 

agencies.

18. NWAP management will submit a written “Plan of Activities” to the local Flight Standards 

District Office (FSDO) having jurisdiction over the area of proposed filming three days in 

advance of operations during film or movie productions.

19. If the sUAS loses communications signal, the sUAS will have the capability to return to a 

pre-determined location within the Sterile Area and land.

20. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the pilot and the observer.

21. The sUAS PIC has the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

22. NWAP, by following FAA, NTSB, and AFS-80 best practices, will assure no individuals’ 

privacy is violated.
NorthWest Aerial Perspectives

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April 30, 2015

23. Procedures have been established in NWAP’s Operations Manual to contact ATC prior to 

operating in airspace other than G.

V. Regulations From Which Exemption is Requested

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”,

provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in

the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft

systems may operate safely in the national airspace system before completion of the

(comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance

required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Section

333 provides a mechanism for “expedited operation authorization” if several factors are met.

Petitioner meets all requirements to permit FAA approval of commercial UAS operations.

The Petitioner Requests Relief From the Following:

A. 14 CFR § 91.103: Preflight Action

NWAP requests an exemption from the preflight actions requirements of 14 CFR 91.113 that 

prescribes the preflight actions under which aircraft may operate:

Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight.

a. Flight under IFR or a flight not in the vicinity of an airport, weather reports 

and forecasts, fuel requirements, alternatives available if the planned flight 

cannot be completed, and any known traffic delays of which the pilot in 

command has been advised by ATC;

b. For any flight, runway lengths at airports of intended use, and the following 

takeoff and landing distance information:

i. For civil aircraft for which an approved Airplane or Rotorcraft Flight 

Manual containing takeoff and landing distance data is required, the 

takeoff and landing distance data contained therein; and

ii. For civil aircraft other than those specified in paragraph (b)(1) of this 

section, other reliable information appropriate to the aircraft, 

relating to aircraft performance under expected values of airport 

elevation and runway slope, aircraft gross weight, and wind and 

temperature.

NWAP will not operate sUAS’s under IFR conditions or when the ceilings are below 1000 feet 

and the visibility is below 3 statute miles. NWAP’s sUAS’s do not have a published approved 

Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data.

Equivalent Level of Safety

In adherence to FAA, NTSB, and AFS-80 best practices, the PIC along with the person having 

operational control must follow regulations to assure that the weather will be adequate to complete 

the mission in VFR condition. 

B. 14 CFR 91.113: Right-of-Way Rules

NWAP requests an exemption from 14 CFR 91.113 Right-of-way rules, requiring vigilance by each 

person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives 

another aircraft the right-of-way, the pilot shall give way to that aircraft and may not pass over, 

under, or ahead of it unless well clear. 

NorthWest Aerial Perspectives operates small pilotless UAS’s and cannot comply with these rules 

as they have been written.

Equivalent Level of Safety

NWAP operates sUAS’s at or below an altitude of 500 feet AGL, well below the normal operating 

altitude of other aircraft. NWAP management requires that the Pilot in Command with experience 
NorthWest Aerial Perspectives

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April 30, 2015

oversee each mission and has knowledge of the see-and-avoid rules. A Visual Observer will assist 

the PIC in looking for aircraft entering the operations area. It’s the responsibility of the PIC to 

cease operations and land the UAS immediately whenever an aircraft comes into the vicinity 

creating a potential threat. Operations will not recommence until the threat is clear.

C. 14 CFR. § 91.119: Minimum Safe Altitudes

NWAP requests an exemption from the minimum safe altitude requirements of 14 CFR 91.119 

that prescribes the minimum safe altitudes under which aircraft may operate:

• Over any congested area of a city, town, or settlement, or over any open air assembly of 

persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft.

• Over other than congested areas at an altitude of 500 feet above the surface, except over 

open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when it 

can be operated "without hazard to persons or property on the surface," provided that "each person 

operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters 

by the FAA."

To provide the intended operations, the sUAS is normally operated below 500 feet AGL. 

Additionally, due to the nature of the proposed operations, the sUAS will maintain a lateral 

distance of at least 100 feet from inhabited structures, buildings, vehicles, and vessels, and from 

people not associated with the operation.

Equivalent Level of Safety

Compared to normal aircraft, NWAP’s multi-rotor and fixed wing aircraft weigh a maximum of 30

pounds, and given the lack of flammable fuel, any risk associated with these operations is far less 

than those that presently exist with conventional aircraft. An equivalent level of safety will be 

achieved given the size, weight, and speed of the UAS, as well as the location where it is operated. 

As set forth in the FAA, NTSB, and AFS-80 best practices, the sUAS will be operated in a sterile 

area, where buildings and people will not be exposed to operations without their pre-obtained 

consent. Because of the advance notice to the property owners and participants, all affected 

individuals will be well aware of the planned flight operations prior to commencement of 

operations.

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with aircraft that are 

subject to the minimum safe altitude regulations. Finally, the successful safety record of the 

Phantom 2, Syndrone X8 and Gemini sUAS’s demonstrates that the sUAS can be safely used at 

these lower altitudes and closer operating environments.

D. 14 C.F.R. § 91.121: Altimeter Settings

NWAP seeks an exemption from 14 CFR 91.121, which requires a person operating an aircraft to 

maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of 

the departure airport or barometric pressure. An exemption is required because the sUAS does 

not have a barometric altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in the FAA, 

NTSB, and AFS-80 best practices. NWAP will confirm the altitude of the launch site shown on 

the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicator to 

constantly monitor the sUAS's height, thus ensuring operation at safe altitudes.

E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions
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NWAP requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR 

conditions. Section 91.151 states:

a. No person may begin a flight in an airplane 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 –

i. During the day, to fly after that for at least 25 minutes; or

ii. At night, to fly after that for at least 45 minutes.

The batteries powering NWAP’s Phantom 2 and Syndrone X8 provide approximately 25-35

minutes of powered flight while the Gemini's provide 2 to 3 hours of powered flight. To meet the 

30 minutes reserve requirement in 14 CFR 91.151, X8 sUAS flights could not be conducted. 

Given the limitations on the sUAS's proposed flight area and the location of its proposed 

operations within a predetermined area, a safety margin based on a reserve amount of battery life is 

needed. NWAP will not be conducting any sUAS flights at night.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be conducted on-site 

without significant transit time by the sUAS. All flights will be planned to terminate with no less 

than 25% reserve battery power still available. This restriction would be more than adequate to 

return the sUAS safely to its planned landing zone from anywhere in its confined area of operation 

even in the event of an unexpected occurrence. Operation of the sUAS with less than 30 minutes

of reserve fuel does not include the type of risks that Section 91.151(a) was intended to alleviate 

given the size and speed of the small UAS, and the proximity of the flight operation to the landing 

zone. Moreover, operation will be limited to controlled areas where only people and property 

owners, or official representatives who have signed waivers will be allowed.

F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections

NWAP also seeks an exemption from the maintenance inspection requirements contained in 14 

CFR 91.405(a), 91.407(a) (1), 91.409(a) (2), 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 CFR Part 43. 14 CFR 91.405(a) (stating 

that each owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart 

E of this part and shall between required inspections ...have discrepancies repaired as prescribed in 

part 43 of this chapter"). An exemption to these regulations is needed because Part 43 and these 

sections only apply to aircraft with an airworthiness certificate, which the sUAS will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with FAA, NTSB, and AFS-80 best practices. The operator will ensure 

that the sUAS is in working order prior to initiating flight, perform required maintenance, and 

keep a log of any maintenance performed. 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.

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight operations 

will only take place in restricted areas for limited periods of time during daylight hours, creates less 

risk than that associated with conventional rotorcraft or fixed wing aircraft performing the same 

operation.

VI. PUBLIC INTEREST

Granting NorthWest Aerial Perspectives an exemption furthers the public interest in and around 

the states of Washington, Oregon, Idaho and Montana. National policy set by Congress favors 

early integration of sUAS into the national airspace in controlled, safe working environments such 
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April 30, 2015

as those propose in this petition. The one vision of NWAP is to help facilitate safe integration of 

sUAS’s into mainstream USA in the following areas:

• Aerial Surveying

o As with construction imaging, aerial imaging flights will be used to capture aerial 

photos for the purpose of creating orthomosaics (image maps). The image maps 

will be used to compute volume, create 3D models, DSM’s, DTM’s, profile and 

contour lines. 

• Movies and Event Photography

o Whether the shot requires unique views and expansive panning or altitude with 

radical views, the sUAS is designed to hold up under demanding conditions. 

Because of the autopilot feature with pre-designed mission management and R/C 

control interrupt, the pilot and camera operator can easily create the ultimate shot 

with HD video or HD still photos. When working close in on a closed set the 

hazards to the actors are substantially reduced due to the size of the sUAS.

• Precision Agriculture

o This technology, which uses a variety of spectral data, has potential for several 

agricultural uses, including: early-generation crop breeding line evaluations, quick 

and wide-scale scouting of croplands for crop conditions and weed densities, 

grassland conditions and production evaluation, detection of noxious weeds and 

detection of blue green algae blooms in ponds and reservoirs. In addition, the 

technology allow the monitoring of water use and will allow the land owner to 

directly control the quantity of water use.

• News Gathering

o Similar to movies and event photography, each news assignment may require a 

completely different shot or view of a scene. With budgets for traditional helicopter 

use being greatly reduced, the sUAS is the perfect solution to allow for easy news 

gathering for a fraction of the cost. The sUAS can and will be operated in a sterile 

area away from the public, while the traditional helicopter must hover over persons 

and property increasing the danger to individuals.

• Construction and First Responders

o Low level oblique photos and video from several angles are far more effective than 

ground based imagery for displaying the characteristics of large, complex properties with 

several buildings and large trees. The applicants in the past have chartered 2-seat fullsized helicopters for this purpose, which has proven more costly than many potential 

clients have been able to afford. The benefits of reduced cost and improved quality of 

presentation from the UA will be valuable to and benefit many buyers and sellers of real 

property. Additionally, we request that we be allowed to use our system to benefit first 

responders nearby who might require assistance, including fire fighters, the police, the 

sheriff, et al., while remaining subject to all limitations cited in this application.

• Real Estate

o The sUAS can be used in all areas of real estate, including commercial, residential 

and industrial properties. Using a sUAS, real estate professionals can create 

promotional videos, photos and unique shots that normal camera aspects cannot 

capture. NWAP’s easy-to-use video and photo platforms enable properties to stand 

out, providing dazzling views that are typically shown via expensive computer 

animation or costly helicopter rentals. Imagine shooting a view from a high-rise 

condo in stunning high definition that shows your potential customer the actual 
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view from the residence. The remote platform is great for new planning, zoning and 

large developments. Simple and easy-to-use video and photos allow for multiple 

height pictures and elevation views.

VII. Privacy

NorthWest Aerial Perspectives is deeply committed to protecting public privacy. NWAP knows 

that many individuals have concerns about privacy from the operations of sUAS’s. NWAP has 

created a privacy notice that informs residents, commercial property owners, churches, schools, 

and governmental organizations of our intent to conduct commercial drone operations in 

proximity to their property.

VIII. Federal Registry Summary

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed:

NorthWest Aerial Perspectives, seeks an exemption from the following rules:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

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. 91.121Page 3

14 C.F.R. 91.151(a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

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

Approval of this exemption request allows NWAP to conduct commercial operations with small 

and lightweight unmanned aerial systems. NWAP’s singular vision is to enhance safety of sUAS 

operations in the NAS while reducing risk to the general public and property owners.

The SynDrone, the Phantom 2 and Gemini sUAS, each weighing less than 30 pounds and 

powered by batteries, eliminates virtually all of that risk given the reduced mass and absence of 

combustible fuel carried on board. The sUAS is transported to the designated mission area and set 

up there. The sUAS will carry no passengers or crew and, therefore, will not expose them to the 

risks associated with manned aircraft flights.

The operation of this small UAS will provide an equivalent level of safety supporting the grant of 

the exemptions requested herein, including exempting the applicant from the requirements of 

several regulations and allowing commercial operations. These lightweight sUAS’s operate at slow 

speeds, close to the ground, and in a sterile environment. As a result, they are far safer than 

conventional aerial survey and inspection operations conducted with fixed wing aircraft or 

helicopters.
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If additional information is required, or if you have any questions regarding this Petition for 

Exemption, please contact the undersigned at:

IX. Conclusion

The petitioner is requesting this exemption for the purposes of aerial surveying, precision 

agriculture, real estate photography, aerial filmmaking and photography, construction site 

inspections and monitoring, news gathering and other flight operations. The reason for such a 

general and broad based request is that the petitioner wishes to utilize a business strategy of 

horizontal integration and maximize economies of scope in order to capitalize on opportunities as 

they may arise in the future without the long turnaround time associated with additional 

exemptions. The petitioner's business model is based on the idea of offering ad hoc small UAS 

services to individuals or companies who wish to employ these services as a safe, effective, and

legal option to enhance their business or hobby. The petitioner’s own market research shows pent 

up demand for these services currently exists in the real estate market, construction, movie-making, 

and other markets are just beginning to emerge. The petitioner has identified Universities and 

other agencies that could benefit from the operation requested in this application. A quick internet 

search will show that many are currently operating similar UAS in exactly this fashion without, it is 

assumed, FAA authorization. The petitioner has refrained from engaging in commercial use of the 

UAS. The primary purpose of seeking this exemption is to obtain the capability to offer those 

services while remaining in compliance. The petitioner has 20 years of experience in the radio 

control model aircraft hobby

With Best Regards,

Thomas Ethen, President

NorthWest Aerial Perspectives 

Office: (509) 733-2928

Email: teimages@sbcglobal.net