Soaring Eagle Imaging, LLC. 1 Exemption from Section 333

Soaring Eagle Imaging, LLC

Manager: William Paden

133 Glen Arbor Court

Brandon, MS 39042

soaringeagleimaging@yahoo.com

To Whom It May Concern:

Soaring Eagle Imaging, LLC ( its Operating Manager William Paden) is 

requesting an exemption from the requirements of 14 C.F.R §§ 61.23(a), 61.113(a) & 

(b), 61.195 (b)(1)(2), 91.7(a), 14 CFR Section 21 Subpart H, 91.109, 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 (FMRA). This exemption will permit SEI, LLC to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of aerial acquisition and research in support 

of Government entities, agriculture industry, utility companies, private and government 

infrastructure, scientific studies, wildlife monitoring, mining, surveying, real estate, 

aerial photography, training for UAS operators, and forestry.

SEI, LLC intends to operate the DJI PHANTOM 2+, DJI INSPIRE 1, AURORA

FLIGHT SCIENCES SKATE, and AEYRON SKYRANGER AND SCOUT. 

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

unmanned aircraft and its operation are all factors to be considered for this exemption. 

All of the Systems Soaring Eagle Imaging, LLC will be operated and maintained within 

the guidelines of the respected manufacturer recommendations.

The DJI Phantom 2+ and DJI Inspire 1 are vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic 
Soaring Eagle Imaging, LLC. 2 Exemption from Section 333

tablet or smart phone systems. The DJI Phantom 2+ has a maximum gross weight of 

approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 

inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI 

Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, 

width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 

knots. The DJI Phantom 2 and DJI Inspire 1UAs are equipped with four main rotors; 

driven by Lithium Polymer battery powered electric motors.

The Aurora Flight Sciences Skate is a VTOL winged UAV that is controlled with a 

ground station, weighing approximately 2.7 pounds operational. It is approximately 19 

inches long by 24 inches wide and is capable of approximately 5-50 knots.

The Aeyron SkyRanger is a four bladed VTOL system weighing approximately 

5.3 lbs. operational with a diameter of 40 inches deployed. It sits 9.3 inches high. It is 

controlled by a fully integrated Ground Station.

The Aeyron Scout is a smaller four bladed VTOL weighing approximately 3 pounds, 28 

inch diameter deployed, and 8.5 inches high. It is controlled using a fully integrated 

ground station. 
Soaring Eagle Imaging, LLC. 3 Exemption from Section 333

TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS................................................................................4

INTRODUCTION AND BACKGROUND OF PETITIONER.........................................5

NAME AND ADDRESS OF PETITIONER......................................................................5

THE SPECIFIC SECTIONS, EXTENT OF RELIEF, AND REASON FOR RELIEF OF 

14 C.F.R. FROM WHICH SEI, LLC SEEKS EXEMPTION............................................5

THE REASONS WHY GRANTING SEI, LLC'S REQUEST WOULD BE IN THE 

PUBLIC INTEREST .......................................................................................................8

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY..............................................................................................................9

CONCLUSION......................................................................................9

GLOSSARY OF ABBREVIATIONS
Soaring Eagle Imaging, LLC. 4 Exemption from Section 333

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

C.F.R. Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SOP Standard Operating Procedures

SEI, Soaring Eagle Imaging, LLC

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing

This petition for the exemption is being entered by William Paden, (Owner and 

Operator of Soaring Eagle Imaging, LLC) and will provide its clients with expertise and 
Soaring Eagle Imaging, LLC. 5 Exemption from Section 333

knowledge in advanced technologies and applications to increase efficiency, 

productivity and effectiveness. Mr. William Paden is a FAA rated Helicopter Pilot with 

Airline Transport License privileges; and also a FAA licensed mechanic with Airframe 

and Powerplant privileges. Mr. Paden has spent many years working in different aspects 

of aviation from maintenance to operator, civilian and military, in some of the most 

demanding situations. The commitment to safety will never be in question. With the 

granting of this exemption SEI will be able to safely serve the public and government in 

varying areas to provide services not previously available or economical.

Contact Information Follows:

William Paden

133 Glen Arbor Court

Brandon, MS 39042

soaringeagleimaging@yahoo.com

FAA Certificate Number 3370180

1. Extent Of Relief : SEI, LLC Seeks Relief From Section 61.23 (a)

Relief from Section 61.23(a): Operations requiring a medical certificate. Except as 

provided in paragraphs (b) and (c) of this section. Until a time in which the FAA

determines rules pertaining to UAS operators, the PIC for SEI, LLC operations will at a 

minimum maintain a Class 2 medical.

2. SEI, LLC Seek s Relief from Section 61.113 (a) (b)

Relief from Section 61.113 (a) (b) Private pilot privileges and limitations: Pilot in 

Command

(a) No person who holds a private pilot certificate may act as pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire: nor may that 

person, for compensation or hire, act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 
Soaring Eagle Imaging, LLC. 6 Exemption from Section 333

with any business or employment if:

(1)The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or

hire.

Due to the size and gross weight of the UAS systems utilized, SEI, LLC will not carry 

passengers or cargo for hire. Relief from this section will not jeopardize safety as all 

persons designated PIC for SEI, LLC will complete a training program prior to acting as 

PIC in a manner consistent with the operations specifications as described in this 

exemption and the Training Manual for SEI, LLC. This includes Emergency Training.

3. SEI, LLC seeks Relief from Section 61.195 (b) (1) (2) and Section 

91.109

Relief from Section 61.195 (b) (1) (2) A person who holds a flight instructor certificate 

is subject to the following limitations

(b) Aircraft Ratings. A flight instructor may not conduct flight training in any aircraft for 

which the flight instructor does not hold

(1)A pilot certificate and flight instructor certificate with the applicable 

category and class rating, and

(2)If appropriate, a type rating.

Until the FAA quantifies a category or type rating for UAS systems; All training for 

UAS operations for SEI, LLC, its Contractors, and Clients will be conducted by trained 

instructors. The trainer qualifications and training syllabus will be covered in the 

training manual that may be submitted to the FAA separately for proprietary reasons. 

The owner and operator of SEI, LLC is an Army trained Instructor Pilot with many years 

of experience. The training program will center on the safe operations of UAS systems 

within the NAS.
Soaring Eagle Imaging, LLC. 7 Exemption from Section 333

4. SEI, LLC seeks Relief from Section 91.7(a). And 14 CFR Part 21 

Subpart H

Section 91.7(a) Civil aircraft airworthiness. No person may operate a civil aircraft unless 

it is in an airworthy condition.

14 CFR Part 21 Subpart H Airworthiness Certificates

The UASs that SEI, LLC intends to operate are not able to meet multiple requirements 

set forth in both Sections being requested relief from. Therefore, no designated PIC for 

SEI will operate an UAS without first ensuring the system is airworthy per the 

manufacturer manuals and SEI Operations Manual. The operation will terminate if at 

any point it is determined that the UAS is no longer airworthy. All operations will follow 

the guidelines set forth in this exemption.

5. SEI, LLC seeks Relief from Section 91.121

Section 91.121 Altimeter Settings.

Due to the size and use of the UASs operated by SEI, the capability to have on board 

Altimeter equipment would make the UAS either too large or heavy to efficiently 

operate. The systems proposed to be used by SEI are equipped with a barometric 

pressure sensor and GPS equipment, which automatically ensures that a ground level 

pressure setting will be established prior to each flight, and provides the PIC with 

altitude information of the UA on the heads-up display of the GCS. This information 

will be available for ATC as discussed during operations within controlled airspace. All 

operations in controlled will be outlined in the SEI operations manual that may be

submitted confidentially to the FAA for proprietary reasons.

6. SEI, LLC seeks Relief from Section 91.151

Section 91.151 Fuel requirements for flight in VFR conditions

The proposed operations by SEI will be conducted during daylight VMC conditions. Per 

Section 91.151 no person may begin any flight unless that person has enough fuel to fly 

to the first point of intended landing and assuming normal cruising speed, to fly after 
Soaring Eagle Imaging, LLC. 8 Exemption from Section 333

that for at least 20 minutes. The systems used by SEI are powered by rechargeable 

lithium ion batteries. The average flight time for all systems, except the Aeyron 

SkyRanger, is approximately 20 minutes. The SkyRanger has an estimated flight time of 

50 minutes. The SkyRanger will be used as per outlined in the SEI Operations Manual.

7. SEI, LLC seeks Relief from section 91.405 (a), 91.407 (a) (1), 91.409 (a) 

(1) (2), and 91.417 (a) (b)

Since Sections 91.405(a), 91.407(a) (1), 91.409(a) (1) & (a) (2), and 91.417(a) (b) only

apply to aircraft with an airworthiness certificate, SEI requests relief from these Sections 

because the UASs do not require airworthiness certifications. 

The maintenance program will be overseen by a trained and qualified FAA

licensed mechanic with Airframe and Powerplant privileges. The maintenance program 

will be outlined in the SEI, LLC Maintenance Operations Manual that may be submitted 

to the FAA confidentially for proprietary reasons. All maintenance procedures will 

adhere to the manufacturer manuals and guidelines. All maintenance will be documented 

for future inspection by authorized FAA personnel. After any maintenance is performed 

a flight check will be performed as outlined in the SEI, LLC Maintenance Operations 

Manual. 

The granting of an exemption for Soaring Eagle Imaging, LLC will be in the best 

public interest. Use of a UAS can decrease operating cost for business in the fields of 

marketing and surveying. The public will be afforded the opportunity to use marketing 

images to help sell their products, helping to stimulate local economies and increase 

business growth. The largest impact will be on research with Government agencies and 

universities. The UAS will provide aerial imaging at cost far below the tradition aerial 

imaging used in current applications. 

The granting of this exemption for Soaring Eagle Imaging, LLC will not adversely 

affect safety because Mr. Paden has many years working in the Aviation field and Safety 

is at the core of his business. He has performed maintenance on aircraft used in EMS to 
Soaring Eagle Imaging, LLC. 9 Exemption from Section 333

transport patients in time critical emergencies and understands how important even the 

smallest task can be for the safest outcome for all parties involved. Mr. Paden is also a 

FAA Licensed Helicopter Pilot with ATP privileges tasked with carrying passengers for a 

Part 135 Operator in the Gulf of Mexico. On a daily basis Mr. Paden is entrusted to 

make decisions on weather, proper documentation, and proper procedures to ensure all 

personnel are safely transported. In addition to a properly trained pilot, all operations 

will have a Visual Observer trained and on hand. No flights will be conducted above 400 

feet AGL. The years of experience and safe decision making ensure Soaring Eagle 

Imaging, LLC will maintain the highest level safety in all aspects of business. 

In conclusion, the level of experience in all aspects of aviation provide Soaring 

Eagle Imaging, LLC to perform aerial imaging within the NAS while maintaining a 

level of safety equal to any other aviation operation. The future of aerial imaging will be 

deeply affected by Unmanned Aerial Systems and ensuring safety is top priority.

Thank you for your time and consideration in this matter.

Sincerely, 

William Paden