August 26, 2015

Exemption No. 12621

Regulatory Docket No. FAA–2015–2209

Mr. Gregory Bergin

Colorado Aerial Imaging LLC

15720 East Buffalo Gap Lane

Parker, CO 80134

Dear Mr. Bergin:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated May 21, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Colorado Aerial Imaging LLC (hereinafter petitioner or operator) for an exemption. 

The petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

photography, videography, and surveying for utility, fire, search and rescue, and law 

enforcement.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Flame Wheel F450, DJI Phantom 2 Vision+, 

and Quanum 680 UC Pro Hex-Copter.
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The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Colorado Aerial Imaging LLC is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Colorado Aerial Imaging LLC is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Flame Wheel 

F450, DJI Phantom 2 Vision+, and Quanum 680 UC Pro Hex-Copter when weighing 

less than 55 pounds including payload. Proposed operations of any other aircraft will 

require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

(AGL). Altitude must be reported in feet AGL.

5. The UA must 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 airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 
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exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

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

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

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

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

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

UAS is in a condition for safe flight. The pre-flight inspection must 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 is 

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 must follow the UAS manufacturer’s maintenance, overhaul, 

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

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 
5

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

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

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may 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 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may 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 must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

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

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 
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exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

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

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

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

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, 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 must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating 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 those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 
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reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must 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 this 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 or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

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 exemption holder or representative; and

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

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

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 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
May 21st, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act.

Dear Sir or Madam:

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

Reform Act), Colorado Aerial Imaging LLC., Greg Bergin, Mike Robinson and Matt 

Talafuse (the co-applicants) and planned operators of Small Unmanned Aircraft 

Systems (sUASs) equipped to conduct aerial photography, videography and survey for 

various industries hereby applies for an exemption from Federal Aviation Regulations 

(FARs) to allow commercial operation of their sUASs, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established 

by the FAA as required by Section 333.

Business Details

Colorado Aerial Imaging LLC.

Greg Bergin

15720 E. Buffalo Gap Lane

Parker CO, 80134

303-349-4685

greg@coaerialimaging.com

Colorado Aerial Imaging LLC. (CAI) is co-owned by Greg Bergin, Mike Robinson 

and Matt Talafuse. All are veterans and have served multiple tours to Iraq as UH60 

Crew Chiefs. Greg and Matt are professional firefighters and Mike is a safety officer for 

United Power utility company. All owners understand safety is paramount as they deal 

with life safety issues day in and day out in their daily jobs. Not only is CAI looking to 

use sUASs to deliver a product to a customer, we are also looking to be a champion of 

the sUAS industry by building relationships throughout the community. Being 

approachable, answering questions and upfront will go far in educating the public to 

merit of sUASs and that the word “drone” does not need to be a negative thing.

Previous exemptions granted to similar businesses

The following is list of recent exemptions granted to business with similar 

operations and equipment:

Exemption # 11458 5/5/2015 Christopher Gardner

Exemption # 11464 5/5/2015 Michaels Drone Photography

Exemption # 11455 5/5/2015 High Flight Photo
Type of Aircraft Operated by CAI

#1- DJI F450 

NAZA M V2 Flight Computer

Spektrum DX8 TX/ AR8000 RX

AUW- 4 lbs.

#2- DJI Phantom 2 Vision + V2

Stock setup with DJI TX

AUW 2.8 lbs.

#3- Quanum 680 UC Pro Hex-Copter

NAZA M V2 Flight Computer

Spektrum DX8 TX/ AR8000 RX

AUW – 7.9 lbs.

.How will our request benefit the public as a whole?

CAI is looking to provide affordable, safe options for aerial photography and 

power line/ substation inspections as well as various uses by Fire and Law entities.

Utilizing sUASs removes the need for full size aircraft, fuels and noise. Risk is mitigated 

by removing the required onboard crew from low and slow operating aircraft.

Fire, Rescue and Law

Having knowledge of all aspects of fire rescue, CAI is hoping to nurture 

relationships with local Fire, Law and Rescue entities to provide much needed services. 

CAI envisions sUASs being utilized on all types of incidents. 

At a structure fire, an incident commander’s inability to visualize the roof under 

which firefighters are operating has proven to contribute to injuries and fire ground 

deaths. Roof conditions, locations of HVAC units and just an overall view of building 

layout will go far for increasing firefighter safety. 

Located in the foothills of Colorado, local fire departments are routinely called to 

injured hikers, crashed mountain bikers and lost parties. Unfortunately, many of these 

parties are unfamiliar with the trail systems. Cell phone “pinging” will get the general 

vicinity of the call, but the use sUASs as an “eye in the sky” will greatly reduce the trial 

and error approach of determining which trail the victim is located on. 

Law enforcement routinely contacts fire departments to provide a ladder truck 

for “aerial photographs” of accident or crime scenes. The downside to this operation is 

the fact that ladder truck is now out of service or out of position for emergency calls. 

The use of sUASs for law enforcement photography allows the fire trucks to remain 

available for other emergency calls. 

These are just 3 examples of use of sUASs in coordination with Fire and Law. The 

more discussions that occur, the more benefits will be realized. 
Utility

Utility workers are regularly exposed to high voltage, electrical flash, Heights, and 

environmental dangers. Multicopter operations would potentially eliminate, or mitigate 

all of those risks to utility linemen. To ensure the reliability of our electrical system, 

power lines must be patrolled regularly through harsh and unforgiving terrain. When 

there is need for a closer inspection there is no choice but to have a lineman climb up 

for a closer look, exposing them to electrical flash, electrical contact and falling hazard. 

Multicopters will remove a person from those unnecessary exposures. It will also allow 

faster and more cost efficient inspections ensuring system reliability. When the use of 

thermal imaging is added to the process, it could find a potential problem before it 

causes system damage or more importantly injury to an employee or a member of the 

public. The use of Multicopters in these dangerous jobs will lower risk, increase system 

reliability, and most importantly protect lives. CAI working in conjunction with United 

Power Utility is hoping to create operating standards for the integration of sUASs 

within the utility industry. See attached letter.

Photography

Utilizing sUASs as an aerial based photography platform provides opportunities 

for photographic shots not provided by other means. For the lay public or small 

business, full size aircraft for projects is just not feasible. CAI will bring aerial 

photography/videography to more businesses and artists. 

How will our request not adversely affect safety or 

provide a level of safety equal to an existing rule?

The Reform Act directs the Secretary of Transportation to consider whether 

operation of UAVs can occur in the national airspace system (NAS) before the 

completion of the rulemaking required under Section 332 of the Reform Act.

CAI and all involved parties believe it is possible to operate sUASs so to not create a 

hazard to the National Airspace System (NAS), the public or pose a threat to national 

security. CAI has demonstrated their willingness to act safely and responsibly by not 

engaging in commercial sUAS operations until the 333 exemption is granted. During 

our feasibility study, we determined that there are many operators offering their 

services to real estate agencies and parties in need of aerial photos. It is our feeling 

that these type of operations, while may offer a quick fix, contribute to the negative 

attitude of the UAV. CAI is hoping to increase the safety by being professional, trained, 

insured and FAA compliant.
CAI operators will operate under the following conditions, which provide for safety 

equivalent to, if not exceeding the level required for manned aircraft

 Safety will be the first and foremost consideration in any sUAS operation

 The sUASs planned to be operated are rotorcraft and fixed wing aircraft, each 

weighing far less than 55 pounds including payload

 They would operate, under normal conditions, at a speed of no more than 50 

knots. 

 All operations will be conducted below 400' AGL. Altitude will be monitored via 

on screen display or telemetry

 Operations will be conducted during the day under visual meteorological 

conditions

 Aircraft will remain within Visual Line of Sight of the PIC or VO (visual observer)

at all times

 PIC and VO will remain in voice contact during the entire flight

 PIC shall complete a full pre-flight inspection

 CAI will utilize additional observers or signage when operations are conducted 

close to public activity

 Operations will only be conducted with permission from the appropriate 

land/property owner

 All required permits will be obtained from state and local government prior to 

operation

 The aircraft will not be operated over populated areas, large gatherings or 

heavily traveled roads.

 Flight planning will include flight completion with at least 25% battery power 

remaining as measured by the sUAS flight computer or appropriate timing

 All aircraft are equipped with and will utilize GPS navigation, failsafe, return-tohome (RTH) and/or flight abort safety features

 The aircraft will not be operated within 5 NM of a public airport or heliport

 A briefing will be conducted in regard to the planned sUAS operations prior to 

operation at each new location. All personnel who will be performing duties 

within the boundaries of the area of operation will be present for this briefing

 The sUAS pilot will be trained in advance for the safe operation of the sUAS to be 

operated. This will include operation of the sUAS both in normal and emergency 

modes of operation, and will include familiarization with the operation manual. 

Training will also include types of maneuvers to be performed and the safe 

operation in relation to persons, property and applicable airspace.

Routine maintenance and repairs are instrumental in safe operations. All 

maintenance/overhauls/repairs will be completed according to manufacturer 

instructions. Following all maintenance procedures, a test flight will be conducted in a 

remote area to assure all systems are operational prior to any operations for 

customers. Repairs and flight times will be documented to aid in tracking the life cycle 

of critical components (ie; batteries, motors and speed controls)
The regulations from which the exemption is requested 

as well as how CAI intends to provide an equal to or 

greater level of safety are as follows: 

-14 CFR 45.23, 45.27 and 45.29 - Display of Marks, Location and Size

Due to the size of the sUAS, the required markings will be difficult to meet the 

minimum size standards. Also, due to the fact there is no cockpit and no persons shall 

be transported on sUASs, displaying “experimental” at any location on the aircraft is 

not necessary. “Colorado Aerial Imaging” as well as contact information shall be 

displayed on all aircraft in an easy to locate location.

-14 CFR Part 21 Subpart H, 91.7(a) and 91.203(a) and (b) - Civil Aircraft: 

Certifications Required

Carrying of civil aircraft certifications “onboard” or “displayed at the cabin or 

cockpit entrance” is not feasible due to size and no cockpit in the sUAS. All applicable 

documentation shall be available on location where the pilot has immediate access to 

them.

-14 CFR 61.113 and 14 CFR 61.133- Private Pilot Privileges and Limitations: Pilot 

In Command

Private pilots may not act as pilot in command and may not carry passengers or 

property for compensation. The objective of CAI is to conduct flights for compensation, 

although an equivalent or higher level of safety is achieved due to the fact there will be 

no pilots or persons on board. All equipment carried shall be the property of CAI. 

While helpful, a commercial pilots’ license will not ensure remote control piloting skills. 

The risks of operating a sUAS are far less than the risk levels inherent in the commercial 

activities. 

An equal to or higher level of safety will be achieved through following methods:

 All CAI pilots have at least 12 years of RC experience and are current AMA 

members with no major accidents/injuries. This experience includes fixed wing, 

rotary and multirotor aircraft. 

 CAI pilots have conducted numerous “practice flights” as a hobbyist to assist in 

determining the feasibility of starting a business. Each pilot has over 150 flights 

with their aircraft in various temperatures, winds and weather

 Utilization of computer based simulator to maintain proficiency and allow 

practice in all conditions as well as emergency procedures for simulated failures

(Phoenix Flight Sim, Real Flight Simulator)
 Training through some of the many online/hands-on offerings from respected 

sUAS training facilities (Unmanned Aerial Experts, UAVSA)

 We are aware of the reference to the Unmanned Aircraft Operator Certificate with 

Small UAS Rating as well as the Initial Aeronautical Knowledge Test referenced in 

NPRM 14 CFR Part 107 and Vol. 80, No. 35 Federal Register dated February 23rd, 

2015. CAI strongly agrees with this proposed course of action and will await a 

final ruling.

-14 CFR 91.9 (b)(2): Civil Aircraft Flight Manual, Marking and Placard 

Requirements

Carrying of a flight manual onboard is not applicable due to the size of the sUAS.

An equal to or higher level of safety will be achieved by through familiarization of 

manufacturer limitations and procedures. All manuals will be easily accessible for 

reference at the location of the flight.

-14 CFR 91.103- Preflight Action

Prior to arriving at flight location, current and predicted weather, distances from 

airports as well as local hazards (power lines, towers, high occupancy areas) will be 

obtained. As stated above, a preflight briefing shall occur to include discussion 

regarding weather, emergency procedures, hazards and alternate landing locations.

-14 CFR 91.109- Flight Instruction: Simulated Instrument Flight and Certain 

Flight Tests

Dual controls for the purpose of flight instruction is not applicable in the sUAS

operation. Should a need for instruction arise, several methods of training are available. 

During designated training flights, the utilization of a “buddy box” system with 2 

transmitters will provide an equivalent to or higher level of safety. Additionally the use 

of computer based flight simulators provide the ability to conduct training with no 

safety concerns.

-14 CFR 91.119- Minimum Safe Altitudes: General

The sUAS shall be operated well below 400 AGL standard. As a PIC of the sUAS, 

being aware of the altitude minimums (with an emphasis on helicopters as they may be 

operated lower altitudes more often) is integral to safely operating sUASs. 

-14 CFR 91.121- Altimeter Settings

All sUASs operated by CAI utilize GPS altitude and/or barometric altimeters

(Spektrum) with data transmitted to the operator via telemetry and on screen displays.

-14 CFR 91.151 (A): Fuel Requirements For Flight In VFR Conditions

An equivalent or higher level of safety is achieved in the fact that sUASs do not 

carry fuel. As stated above, all flights shall be planned and conducted with a minimum 

of 25% remaining battery power. 
-14 CFR Subpart E (91.401-91.417) - Maintenance, Preventative Maintenance And 

Alterations

These regulations apply to aircraft requiring an airworthiness certificate. Adhering 

to manufacturer recommended maintenance, full pre-flight and post flight inspections 

as well as documenting all maintenance performed will provide an equal to or greater 

than level of safety. After any maintenance has been completed, a test flight shall be 

conducted in a safe, non- populated area prior to any commercial flight.

Summary

As the demand grows for aerial based photography applications, so will the 

temptation of individuals to utilize non-compliant operators. CAI can deliver a product, 

safely by abiding by all the rules and regulations. It is the applicant's belief that the 

size, speed, operating environment, limitations and level of applicant's experience 

outlined provides an "equivalent level of safety or better” when operating a sUAS for 

the public interest as outlined in Section 333 in the FAA Modernization and Reform Act 

of 2012. lt is requested that the FAA issue an exemption to permit safe, legal, 

commercial sUAS operation by the applicant as soon as possible.

ReferencesDue to the size of the files, attaching them to this document did not seem prudent. The 

operator manuals can be accessed at utilizing the following links:

DJI Naza M V2 Flight Control Module –

http://download.dji-innovations.com/downloads/nazam-v2/en/NAZAM_Quick_Start_Guide_v1.26_en.pdf

DJI Phantom 2 Vision + -

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_

Manual_v1.8_en.pdf

DJI F450 Flamewheel –

http://download.djiinnovations.com/downloads/flamewheel/en/F450_User_Manual_v2.1_en.pdf

Spektrum DX8 -

http://www.horizonhobby.com/pdf/SPM8800-Manual_EN.pdf