Stone Aerial Photography LLC

Jeremy Wayne Stone

511 Cardinal Rd 

Muskogee, OK 74403

Federal Aviation Administration

US Department of Transportation

Docket Management System

1200 New Jersey Ave S.E.

Washington, DC 20590

December 22, 2015

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

14 CFR Part 11: 14 CFR 21 Subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.103; 14 CFR 

91.109; 14 CFR 91.119(a); 14 CFR 91.151(b); 14 CFR 91.7(a) & (b); 14 CFR 91.9(a) & (b)(2); 14 CFR 92.121; 

14 CFR 91.151(a); 14 CFR 203(a) & (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(2), 14 

CFR 91.417(a) & (b)

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

CFR Part 11; Stone Aerial Photography LLC, henceforth referred to as the petitioner or operator, hereby 

applies for an exemption from the Federal Aviation Regulations (FAR) 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 Section 333. 

The petitioner will be operating a DJI Phantom 2 Vision+ V3.0 and DJI Phantom 3 Advanced (most recent 

manuals attached). The petitioner may add additional rotorcraft as needed from DJI or other companies 

and will follow the registration process with AC form 8050-1. The petitioner will operate the rotorcraft 

within its design parameters for the following purposes:

• Aerial photography and videography for public or private use including real estate, architecture, 

land surveying, farming, engineering and other related professional activities

• Aerial photography and videography for public or private use including television, public events, 

cinematography and news gathering

• Aerial photography and videography for residential or commercial building structures under 

contract with the owners or local government authority

• Aerial photography and videography of residential or commercial utility infrastructure including 

but not limited to electrical power lines, wind turbines, and cell towers

• Aerial photography and videography or providing live video feed to assist with search and rescue 

operations in cases of emergency or natural disaster only when local authorities or government 

has requested it by contract or donation

• Training to persons individually or belonging to private or public organizations that have 

interests in the use and application of (small UAS) for the purpose of enhancing the National Air 

Space (NAS) as well as persons and property
The request for this exemption is in the Public Interest as there are many consumer applications for the 

services that can be provided by UAS that are currently conducted by manned aircraft. Using a UAS for 

many of these applications creates an environmentally friendly, lower cost solution to both the operator 

and consumer. These aircraft can be operated without risk of loss of life or limb, and without significant 

financial impact to the operator or any person or property on the ground in the event of the loss of an 

aircraft. Utilizing these UAS will create a safe and more productive work environment, reduce 

environmental pollution and have a positive impact on the local economy which is in the Public Interest. 

Finally the petitioner believes that granting this exemption would help to further the success of UAS 

integration into the National Air Space (NAS) by creating an environment where prospective new UAS 

pilots could receive type specific training and experience to be used as these systems become more 

widely utilized.

The limitations and conditions to which the petitioner agrees to strictly follow when conducting 

commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual 

(FOM) include:

• All flights will occur in ordinance with any state or local laws regarding privacy.

• The UAS will weigh less than 55 lbs.

• Flights will be operated within visual line of sight (VLOS) with the Pilot in Command (PIC) and/or 

Visual Observer (VO).

• Maximum flight time for each operational flight will be 20-25 minutes as determined by the 

flight telemetry. Flights will be aborted at 25% battery power reserve or 20 minutes whichever 

occurs first.

• Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and 

not more than 200 feet above an elevated platform from which filming is planned.

• Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO), and 

may include an additional camera operator depending on the UAS.

• The petitioner will be the designated UAS Pilot in Command (PIC) and will follow all necessary 

certifications currently being approved by the FAA for commercial use.

• A briefing will be performed regarding the UAS operations prior to each day’s flight consisting of 

all the planned production activities.

• All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

• The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference 

Point (ARP) of a tower controlled or uncontrolled airport. The DJI Phantom 2 Vision+ V3.0 and 

DJI Phantom 3 Advanced have built-in software which automatically updates for all FAA 

regulated ‘NO FLY ZONES’ and is continually being updated to prevent any possible flights 

occurring within these no fly zones.

• If operations will be within a 5 mile radius of the geographic center/Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport the respective airports will be contacted 

advising them of the estimated flight time, flight duration, elevation of flight, and other 

pertinent information.

• The Pilot in Command (PIC) will file FAA Form 7711-1 or its equivalent, as modified in light of the 

requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more 

than 72 hours but no less than 48 hours from planned operation.

• The Pilot in Command (PIC) will obtain verbal or written consent of all persons involved with the 

planned operation and ensure only consenting persons will be allowed within 100 feet of the 

flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of 

safety determination, as required under the Flight Operations Manual (FOM). With the 
advanced permission of the Flight Standards District Office (FSDO), operations at closer range 

may be approved.

• The Pilot in Command (PIC) and Visual Observer (VO) will have prior training in operation of the 

UAS and receive up-to-date information on the particular UAS to be operated.

• The Pilot in Command (PIC) and Visual Observer (VO) will be able to communicate by voice, 

radio, or cellular phones at all times.

• Written or verbal permission and permits will be obtained from territorial, state, county, or city 

jurisdictions including law enforcement, fire or other appropriate governmental agencies.

• If the UAS loses communications with the remote controller or loses GPS signal, the UAS has the 

capability to return to a pre-determined location and land autonomously.

• The UAS has the capability to abort a flight at any time in case of unpredicted obstacles, 

weather, or emergencies.

All planned operations utilizing the UAS will be completed safely. With the combination of the preflight 

safety risk assessments and the inherently reduced risk of flying a UAS compared to a traditional 

manned aircraft, the Pilot in Command (PIC) will be able to provide a level of safety greater than the 

traditional method of performing aerial based photography, videography, survey operations, and data 

collection. Granting this exemption would reduce the need for these traditional methods mentioned 

above and the cost of UAS operations is significantly lower also making these services available to 

smaller businesses or individuals that otherwise might not be able to afford them. This in turn allows 

businesses to better serve their clients, increasing the public benefit as a whole.

All commercial UAS flights by the petitioner shall satisfy the criteria provided in Section 333 of the 

Reform Act of 2012 including: size, weight, flight within Visual Line of Sight (VLOS), and distance for Pilot 

in Command (PIC), distance from airports and other protected services, operation capabilities of the 

UAS, maintaining safety, and the benefit to the public. These qualifications more than justify granting 

the petitioner, Stone Aerial Photography LLC, with an exemption to the stated sections of title 14 CFR.

The requests of this petition are similar to Exemption Nos. 11062, 11109, 11112, 11213, and 12645. 

Thank you for your time and consideration.

Sincerely,

Jeremy Wayne Stone

Stone Aerial Photography LLC