October 26, 2015

L2 AEROSPACE, LLC 

215 Baytree Drive, Suite B

Melbourne, FL 32940

Phone: 321-806-3532

Phone: 321-604-8866

Email: jroyston@l2aerospace.com

Email: sderiso@l2aerospace.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 2059

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments:

1. Aero-M-Spec-Sheet-v3.pdf

References:

1. FAA Exemption No. 11345, Regulatory Docket No. FAA−2015−0048 in the matter of the 

petition of MS. M. ANNE SWANSON for PRECISIONHAWK, INC.

2. FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the matter of the 

petition of DOUGLAS TRUDEAU

3. FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the matter of the 

petition of ADVANCED AVIATION SOLUTIONS LLC 

4. FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in the matter of the 

petition of FLYING CAM INC

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under 

section 333 of the FAA Modernization and Reform Act of 2012, L2 Aerospace, LLC, 

referred to hereafter as the petitioner, requests exemption from the following sections of Title 

14, Code of Federal Regulations §§ 

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409

(a)(1); 91.409(a)(2); 91.417(a) & (b)

In order to operate small unmanned aircraft systems (UAS’s) commercially in airspace regulated 

by the Federal Aviation Administration (FAA) for the purposes of aerial photography, 
cinematography, videography, mapping, crop surveying, inspections and other flight operations 

that could be performed safely and more cost effectively with the use of small UAS at low 

altitude within the U.S. national airspace system as compared to a manned aircraft. Operations

will be performed only at the request of and with the authorization and permission of clients or 

their authorized agents in order to facilitate commerce and raise awareness of the beneficial 

uses of small unmanned air systems. 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. The conditions identified and proposed by the petitioner are drawn from 

references 1-3.

The Federal Aviation Regulations (FARs)

The petitioner seeks exemption from the above mentioned FARs for the following reasons;

Section 61.113(a); 61.113(b)

The petitioner requests relief in order to facilitate the utilization of pilots, who hold a PRIVATE 

PILOT (or greater) certificate. Any pilots operating under this exemption would be required to

comply with any conditions as set forth and in a similar fashion to the previously granted 

exemptions.

Section 91.119(c)

As referenced in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 

feet to the ground may require that the UA be operated closer than 500 feet to essential 

persons, or objects that would not be possible without additional relief. The petitioner requests 

waiver for this condition to allow reasonable and responsible operations in areas of 

subdivisions and neighborhoods if required.

Section 91.121

As referenced in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not 

have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude 

information.

Section 91.151(a)

As referenced in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been 

granted for manned aircraft to operate at less than the prescribed minimums, including 

Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief has been granted 

in Exemption numbers 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides 

battery power remaining in percent to the PIC. The UA batteries provide approximately 20 to 60

minutes of powered flight. Information provided in the operating documents discusses 

procedures regarding remaining battery power management. Those documents contain a 

condition in which the PIC will initiate a landing procedure when battery remaining reaches a 

specified level. Given the limitations on proposed operations and the location of those 

proposed operations, the FAA found that a reduced minimum power reserve for flight in 

daytime VFR conditions was reasonable.
Section 91.405(a); 91.407(a)(1); 91.409(a)(1), 91.409(a)(2); 91.417(a); 91.417(b)

As referenced in Exemption 11138 (DOUGLAS TRUDEAU), the petitioner proposes to inspect 

and ensure that the UAS is in a condition for safe flight in accordance with the operating

documents. The FAA found that adherence to the petitioner’s operating documents and the 

conditions and limitations specified, describing the requirements for maintenance, inspection, 

and record keeping, were sufficient to ensure that safety would not be adversely affected.

UAS’s: 3drobotics’ Aero/Aero-M, PrecisionHawk’s Lancaster, and L2 Aerospace 

Experimental Fixed Wing Unmanned Aircraft (drones)

The requested exemption would permit commercial operation of L2 Aerospace, LLC’s UAS's, 

which weigh between 5 and 25 lbs. and perform precision services that consist of high quality 

still photographs and videography taken by onboard cameras. UAS’s for aerial services reduce 

the need to utilize conventional manned aircrafts for the same purpose at a fraction of the cost; 

additionally, UAS’s services can provide an increase in efficiency and productivity for the 

affected activities and a decrease in fuel emissions providing environmental benefits. 

Operations under the exemption will be subject to strict operating requirements and conditions 

to ensure, at minimum, 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. 

The L2 Aerospace experimental fixed wing drone is similar in performance and specifications to 

the 3DRobotic’s Aero/Aero-M and PrecisionHawk’s Lancaster fixed wing drones. Exemption No. 

11345, Regulatory Docket No. FAA−2015−0048 is referenced as an approved exemption 

covering PrecisionHawk’s Lancaster aircraft. The specification for the 3DRobotic’s Aero-M is 

included as a reference.

The referenced unmanned aircraft websites are:

1. https://3drobotics.com/kb/aero

2. https://3drobotics.com/kb/aero-m

3. http://www.precisionhawk.com

4. http://www.l2agsolutions.com (L2 Aerospace, LLC)

The UAS's will be operated under controlled conditions at low altitude in airspace that is limited 

in scope, as described herein; it will have automated control features, as described in the 

attached manuals. The UAS’s also will be operated by an individual who possesses an FAA 

Private Pilot Certificate and valid US Driver’s License. Finally, the airspace in which the UAS will 

operate will be Class G airspace or airspace approved by the FAA in advance. Approval of these 

exemptions would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish 

requirements for the safe operation of such aircraft systems in the national airspace system.”
The petitioner has reviewed FAA exemptions references 1-3 Conditions and Limitations 

section and agrees that the procedures specified therein are reasonable and will be utilized in 

order to manage and mitigate risk and ensure public safety. A preflight checklist will be 

developed and employed to ensure that the UAS’s airworthiness will be verified prior to each 

launch. The petitioner request that in a manner similar as described in reference 3, he be 

allowed to operate within 5 miles of an airport provided that:

“The UA may not operate in Class B, C, or D airspace without written approval 

from the FAA. The UA may not operate within 5 nautical miles of the geographic 

center of a non-towered airport as denoted on a current FAA-published 

aeronautical chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a NOTAM as 

required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request.”

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is 

requesting a mechanism to facilitate such activities without requesting a new and separate 

exemption(s) should the need arise. Operations within class B airspace are not requested due 

to the lack of mode C transponder.

Public interest

Use of the UAS’s in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircrafts. 

Additionally, use of the UAS’s in order to facilitate commerce could lead to economic growth. 

Operations for this petition will enable service for property owners or their designees seeking 

an enhanced perspective for characteristics, amenities, and benefits of their desired 

photographic subjects that cannot be displayed through ground level photography or 

videography. The petitioner will provide clients with photographic data for these purposes on a 

‘for hire’ basis acting as an independent contractor; a visual observer will be utilized. Liability 

insurance will be obtained commensurate with the granting of this request for exemption. Data 

may be submitted to FAA by traditional means, e.g. COA Monthly Reports, or other means as 

required or requested.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial photography, 

cinematography, videography, mapping, crop surveying, inspections and other flight 

operations”. The petitioner's business model is of the idea of offering ad hoc small UAS’s 

services to individuals or business entities who wish to employ these services as a safe, 

effective, and legal option to enhance their business or hobby.

Currently, many other UAS operators are conducting business in exactly as described above 

without FAA authorization. The petitioner has refrained from engaging in commercial use of the 

UAS’s. The primary purpose of seeking this exemption is to obtain the capability to offer those 
services while remaining in compliance. The petitioner employs personnel with private pilot 

licenses or higher with significant flight experience.

Respectfully submitted,

Sam C. Deriso, Jr

L2 Aerospace, LLC

Director, ISR & Flight Systems