1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations from: 14 CFR Part 21, Subpart H; 61.23(a); 

61.113(a)and (b); 91.103; 91.109; 91.119(c); 91.121; 91.151(a); 91.405(a); 

91.407(a)(1 ); 91.409 (a)(1) and (2); 91.417(a) and (b). 

Dear Sir or Madam: 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (the 

"Reform Act") and 14 C.F.R. Part 11, Extreme Aerial Imagery, an operator of Unmanned 

Aircraft Systems ("UASs") for aerial photography and video on the real estate industry, 

surveying, agriculture industry, construction industry, motion picture industry, television 

industry, and special events, hereby applies for an exemption from the Federal Aviation 

Regulations (11FAR") to allow commercial operation of its UASs, so long as such 

operations are conducted within and under the conditions outlined herein or as 

established by the FAA as required by Section 333. 

The pursuant, Extreme Aerial Imagery, respectfully requests no delay action to this 

petition based on the following: requested relief is identical to exemptions previously 

granted, specifically, Exemption No. 11680. 

An exemption is being requested because (1) Extreme Aerial Imagery can provide a 

level of safety that is equal (or greater than many cases) to those provided by existing 

rules and (2) the request is in the public interest. The FAA's authority to issue 

exemptions from operating rules, and the Secretary's authority granted by Section 333 

of P .L. 112-95, Special Rules for Certain Unmanned Aircraft Systems, provides an 

opportunity to authorize certain UAS operations in the National Airspace System (NAS) 

prior to implementation of the UAS rule. The incremental step and opportunity will allow 

Extreme Aerial Imagery to safely and legally enter into the NAS. 

The requested exemption would permit Extreme Aerial Imagery to operate UASs under 

controlled conditions in airspace that is (1) limited; (2) predetermined; (3) subject to 

controlled access, and (4) would provide safety enhancements to the already safe 

operations of those aircrafts of similar size, weight, speed, and operating capabilities 
that have been granted entry into the NAS via the rules in Academy of Model 

Aeronautics (AMA) National Aircraft Safety Code. 

Photos and videos from several angles and heights are far more effective than groundbased imagery for displaying the characteristics of large, complex properties with 

several buildings where helicopters cannot reach. It is known that charting a 2 seat fullsized helicopter or airplane for this purpose. has proven very costly and has limitations. 

The benefits of reduced cost, reduced noise interference, safety and improved quality of 

presentation from the UASs will be valuable to and benefit many industries such as: real 

estate industry, television industry, surveying and special events. The site based 

photography occurs in restricted or other areas where access to the public is strictly 

limited and controlled. Under virtually all circumstances, all of the property or structures 

near the sites are owned and operated by the same entity soliciting the aerial 

photography services. As a result, the operation has no substantial impact on any third 

person not involved in the actual site project. As established by the exemptions already 

granted by the FAA, approval of Extreme Aerial Imagery would enhance safety, new 

windows of opportunities, and fulfill the Secretary of Transportation's (the FAA 

administrator's) responsibilities to " ... establish requirements for the safe operation of 

such aircraft systems in the national airspace." Section 333(c) of the Reform Act. 

Operation Overview 

UASs operated by Extreme Aerial Imagery weigh less than 7.5 pounds, including the 

payload (first person view system, camera and gimbal). They operate at speeds of no 

more than 43 knots, can hover, and can simultaneously move vertically and horizontally. 

Extreme Aerial Imagery will only operate its UASs in the line of sight (VLOS) and will 

operate only within the operating manuals and authorize airspace. They will routinely 

be operated below 200 feet above ground level (AGL), and never above 400 feet AGL. 

Operations will always be conducted in areas that are clear of all people, except the 

pilot in commend (PIC), visual observer (VO), PIC's helper(s) or/and production crew. 

Such operations will insure that the UAS will "not create a hazard to users of the 

national airspace system or the public." 

Given the small size of Extreme Aerial Imagery's UASs and the restricted sterile 

environment within which they will operate, Extreme Aerial Imagery's UAS operations 

adhere to the Reform Act's safety requirements. Additionally, due to the size of the 

UASs and the limited areas in which they will operate, approval of this application 

presents no national security issues. Based on the substantial level of safety 

surrounding the proposed operations, and the significant public benefit (enhanced safety)

reduction in environmental impacts (reduced emissions and noise)

the grant of 
Aircraft 

OJ/ Inspire 1 Specification 

Model 

T600 

Weight (Battery Included) 

2935 g 

Hovering Accuracy (GPS Mode) 

Vertical: 0.5 m 

Horizontal: 2.5 m 

Max Angular Velocity Pitch: 300°/5 

Yaw: 150°/s 

Max Tilt Angle 

35° 

Max Ascent Speed 

5 m/s 

Max Descent Speed 

4 m/s 

Max Speed 

22 m/s (ATTI mode, no wind) 

Max Flight Altitude 

4500 m 

Max Wind Speed Resistance 

10 m/s 

Max Flight Time 

Approximately 18 minutes 

Motor Model DJI 3510 

Propeller Model 

DJI 1345 

Indoor Hovering 

Enabled by default 

3 
Gimbal 

Camera 

Operating Temperature Range 

-10 to C 

Diagonal Distance 

5591o 581 mm 

Dimensions 

438x451 x301 mm 

Model 

ZENMUSE X3 

Output Power (With Camera) 

Stat1c: 9 W 

In Motion: 11 W 

Operating Current 

Stat1on: 750 rnA 

Mot1on: 900 rnA 

Angular Vibration Range 

±0.03 

Mounting Detachable 

Controllable Range 

P1tch: -90' to +30' 

Pan: ±320 

Mechanical Range 

Pitch: -125'' to +45 

Pan: ±330" 

Max Controllable Speed 

P1tch: 120°/S 

Pan: 180°/S 

Name 

X3 

Model 

FC350 

Total Pixels 

12.76M 

Effective Pixels 

12.4M 

Image Max Size 

4000x3000 

ISO Range 

1 00-3200 (video) 

100-1600 (photo) 

Electronic Shutter Speed 

Bs

1/BOOOs 
Remote Controller 

FHD: 1920x1 080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 

Max Bitrate Of Video Storage 

60 Mbps 

Supported File Formats 

FAT32/exFAT 

Photo: JPEG, DNG 

Video: MP4/MOV (MPEG-4 AVC/H.264) 

Supported SO Card Types 

Micro SD Max capacity: 64 GB. Class 10 or UHS-1 rating required. 

Operating Temperature Range 

oo to 40° C 

Name 

C1 

Operating Frequency 

922.7-927.7 MHz (Japan Only) 

5.725-5.825 GHz 

2.400-2.483 GHz 

Transmitting Distance (Outdoor And Unobstructed) 

2km 

EIRP 

10dBm@900m, 13dBm@5.BG, 20dBm@2.4G 

Video Output Port 

USB, mini-HDMI Power Supply 

Built-in battery 

Charging 

DJI charger Dual User Capability 

Host-and-Slave connection 

Mobile Device Holder 

Tablet or Phone 

Max Mobile Device Width 

170mm 

/ 

Output Power 

9W 

Operating Temperature Range 

·10° to 40° C 

Storage Temperature Range 

Less than 3 months: -20° to 45° C 

More than 3 months: 22° to 28° C 

s 
Charger 

Battery (Standard) 

Battery (Optional) 

Charging Temperature Range 

0-40° c 

Battery 

6000 mAh LiPo 2S 

Model 

A14-100P1A 

Voltage 

26.3 v 

Rated Power 

100W 

Name 

Intelligent Flight Battery 

Model 

TB47 

Capacity 

4500 mAh 

Voltage 

22.2 v 

Battery Type 

L1Po 6S High voltage battery 

Energy 

99.9Wh 

Net Weight 

570 g 

Operating Temperature Range 

-10 to 40 C 

Storage Temperature Range 

Less than 3 months: -20 to 45 C 

More than 3 months· 22 C to 28° C 

Charging Temperature Range 

0 to 40 C 

Max Charging Power 

1BOW 

Name 

Intelligent Flight Battery 

Model 

TB48 

Capacity 

5700 mAh 

Voltage 
Vision Positioning 

DJI Pilot App 

180W 

Velocity Range 

Below 8 m/s (2m above ground) 

Altitude Range 

5-500 em 

Operating Environment 

Brightly lit (lux > 15) patterned suriaces 

Operating Range 

0-250 em 

Mobile Device System Requirements 

iOS 8.0 or later 

Android 4.1.2 or later 

Supported Mobile Devices 

• Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + 

Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-F1 + 

Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for 

iPhone 5s, iPhone 6, and iPhone 6 Plus. 

• Samsung 85, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, 

Mi 3, Nubia Z7 mini 

*Support for additional Android devices available as testing and development 

continues 

7 
Aircraft 

Gimbal 

Camera 

DJI Phantom 2 Vision+ Specification 

\\\\\\ I/IUJ 

Supported Battery 

DJI5200mAh L1Po Battery 

-

Weight (Battery & Propellers Included) 

1242g 

Hover Accuracy (Ready To Fly) 

Vert1cal: O.Bm; Honzontal: 2.5m 

Max Yaw Angular Velocity 

200 /s 

Max Tillable Angle 

35° 

Max Ascent I Descent Speed 

Ascent: 6m/s; Descent: 2m/s 

Max Flight Speed 

15m/s (Not Recommended) 

Diagonal Motor-Motor Distance 

350mm 

Working Current 

Static : 750mA: Dynamic ; 900mA 

Control Accuracy 

±0.03° 

Controllable Range 

Pitch : -90°-oo Maximum Angular Speed Pitch : 90°/s 

Operating Environment Temperature 

0°C-40°C 

Sensor Size 
Range Extender DJI VISION App 

Receiver Sensitivity (1 %PER) 

-93dBm 

Transmitter Power 

CE Compliance: 25mW; FCC Compliance: 1 OOmW 

Working Voltage 

120 mA@3.7V 

Built-In LiPo Battery Working Current/Capacity 

3.7V, 2000mAh 

Operating Frequency 

2412-2462MHz 

Communication Distance (Open Area) 

500-700m 

Transmitter Power 

20dBm 

Power Consumption 

2W 

System Requirement Of Mobile Device 

iOS version 6.1 or above/ Android system version 4.0 or above 

Mobile Device Support 

• iOS recommended: iPhone 4s, 1Phone 5, iPhone 5s, iPhone 6, iPhone 6 Plus, 

iPod touch 5 (available but not recommended: iPad 3, iPad 4, iPad mini) 

• Android recommended: Samsung Galaxy S3, S4, Note 2, Note 3 or phones of 

similar configuration 

9 
Aircraft 

Camera 

DJI Phantom 3 Specification 

Weight (Including Battery And Propellers) 

1280 g 

Diagonal Size (Including Propellers) 

590mm 

Max Ascent Speed 

5 m/s 

Max Descent Speed 

3 mls 

Hover Accuracy 

• Vert1cal: +1- 0.1 m (when Vision Positioning is act1ve) or +1- 0.5 m 

• Honzontal: +1- 1 .5 m 

Max Speed 

16 m/s (A TTl mode, no wind) 

Max Altitude Above Sea Level 

6000 m 

Operating Temperature 

o=c to 40' C 

GPS Mode GPS/GLONASS 

Sensor 

Sony EXMOR 1/2.3" Effect1ve pixels: 12.4 M (total pixels: 12.76 M) 

Lens 

FOV 94v 20 mm (35 mm format equivalent) f/2.8, focus at"" 

ISO Range 
Gimbal 

Vision Positioning 

Phantom 3 Professional 

• UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 

• FHD: 1920x1 DSDp 24/25/30/48/50/60 

• HD: 1280x720p 24/25/30/48/50/60 

Phantom 3 Advanced 

• FHD: 1920x1 080p 24/25/30/48/50/60 

• HD: 1280x720p 24/25/30/48/50/60 

Supported SO Card Types 

Micro SO Max capacity: 64GB. Class 10 or UHS-1 rating required 

Max Bitrate Of Video Storage 

Phantom 3 Professional 

60 Mbps 

Phantom 3 Advanced 

40 Mbps 

Supported File Formats 

• FAT32/exFAT • Photo: JPEG, DNG • Video: MP4, MOV (MPEG-4 AVC/H.264) 

Operating Temperature 

ace to 40°C 

Controllable Range 

Pilch .goo to +30° 

Stabilization 

3-axis {pitch, roll, yaw) 

Max Velocity 

Less than 8 m/s (when 2 m above ground) 

Altitude Range 

30 cm-300 em 

Operating Range 

30 cm-300 em 

Operating Environment 

Surface with clear pattern and adequate lighting (Lux > 15} 

11 
Remote Controller 

Battery Charger 

Intelligent Flight Battery 

Operating Frequency 

2.400 GHz-2.483 GHz 

Max Distance 

2000m (outdoors and unobstructed) 

Video Output Port 

USB 

Operating Temperature 

0 C- 40°C 

Battery 

6000 mAh LiPo 2S 

Mobile Device Holder 

For tablet or phone 

Receiver Sensitivity {1 %PER) 

-1 01 dBm ±2 dBm 

Transmitter Power {EIRP) 

• FCC: 20 dBm 

• CE: 16 dBm 

Working Voltage 

1.2 A @7.4 V 

Voltage 

17.4V 

Rated Power 

Phantom 3 Professional 

• 100W 

Phantom 3 Advanced 

• 57W 

Capacity 

4480 mAh 

Voltage 

15.2 v 

Battery Type 

LIPO 4S 

Energy 

68Wh 

Net Weight 

365 g 

Max Flight Time 
Required Operating Systems 

• iOS 8.0 or later 

• Android 4.1.2 or later 

Recommended Devices 

• iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, 

iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, 

iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 

5s, iPhone 6, and iPhone 6 Plus 

• Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google 

Nexus 9, Mi 3, Nubia Z7 mini 

• *Support for additional Android devices available as testing and development 

continues 

Such highly advanced capabilities from the above mentioned specifications will ensure 

that the UASs can be safely operated and "not create a hazard to users of the national 

airspace system or the public." As per Reform Act Section 333 (b). 

Equivalent Level of Safety 

The operating limitations proposed by Extreme Aerial Imagery provide for at least, or 

higher level of safety. In an effort to join the FAA in its mission to provide the safest, 

most efficient aerospace system in the world and to minimize the risk to the NAS or to persons and property on the ground. Extreme Aerial Imagery agrees to be bound by 

the following limitations and conditions when conducting commercial operations under 

an FAA issued exemption as set forth in operator's manual and UASs will be operated 

within the standards that the FAA has allowed in the AMA National Model Aircraft Safety 

Code. 

1. The UAS will weigh less than 55 pounds. 

2. The UAS will not be flown in a careless and reckless manner. 

3. The UAS will not be flown at a location where UASs activities are 

prohibited. 

4. Flights will be operated within line of sight of a pilot and/or observer. 

13 
5. Maximum flight time for each operational flight will be 25 minutes. Flights 

will be terminated at 25% battery power reserve and will occur prior to the 

25 minute limit, at about 12-15 minute flight time. 

6. Flights will be operated at an altitude of no more than 400 above ground 

level (AGL), and not more the 200 feet above an elevated platform from 

which filming is planned. 

7. Minimum crew for each operation will consist of the UAS Pilot/Operator, 

the Visual Observer, and production staff. No person will act as an 

operator or visual observer for more than one unmanned aircraft operation 

at one time. 

8. A UAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder 

other than the UAS Pilot, who possesses the necessary PIC qualifications, 

is also present on set, that person can also be designated as PIC. 

9. A briefing will be conducted for planned UAS operations prior to each 

day's flight. All personnel performing duties within the boundaries of the 

safety perimeter are required to attend. 

10. The operator will file an FAA Form 7711-1, or its equivalent, as modified in 

light of the requested exemption, with the appropriate Flight Standards 

District Office ("FSDO"). 

11 . The operator will obtain consent of all persons involved the filming and 

ensure that only consenting persons will be allowed within 1 00 feet of the 

flight operation. With the advanced permission of the FSDO, operations at 

closer ranges can be approved. 

12. When required, the operator will submit a written Plan of Activities to the 

FSDO three (3) days before the proposed shooting. 

13. The pilot and observer must be trained in UAS operations and have 

received current information on the particular UAS to be operated. 

14. The pilot and observer will at all times be able to communicate by voice 

and visual signals. 

15. Written and/or oral permission from the relevant property holders will be 

obtained. 

16. All required permits wilt be obtained from territorial, state, county, or city 

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

governmental agencies. 

17

1f the UAS loses communication or loses its GPS signal

the UAS will have 
g

p

p

known safety precautions and/or safety precautions suggested by the manufacturer ar 

being accounted for. 

Preventive Maintenance 

Comprehensive preventive maintenance plan will be followed in order to ensure the 

UAS's software is up-to-date, the power source is in good health, and the aircraft itself 

is always ready for safe flight. 

Privileges and Limitations 

Pilot in Command Sections 61.113 (a) and (b) limit private pilots to non-commercial 

operations. Because the UAS will not carry a pilot or passenger, the proposed 

operations can achieve the equivalent level of safety of current operations by requiring 

the PIC operating the aircraft to have a private pilot's license rather than a commercial 

pilot's license to operate a small UAS. Unlike a conventional manned aircraft, a UAS is 

remotely controlled by a ground-based operator. The operational area is controlled and 

restricted, and all flights are planned and coordinated in advanced. The level of safety 

exceeds that provided by a single individual holding a commercial pilot's certificate 

operating a conventional aircraft. The risks associated with the use of a UAS are so 

diminished from the level of risks associated with commercial operations contemplated 

by Part 61 allowing UAS use by a private pilot as the PIC exceeds the present level of 

safety sought by 14 C.F.R. §61.113 (a) and (b). 

14 C.F.R. §91.1 03: Preflight Action 91 .103 requires each pilot to preflight an aircraft 

before flight to insure the safety of the flight. As FAA approved rotorcraft flight manuals 

will not be used, an exemption is requested. However, an equivalent level of safety will 

be provided. The PIC will take all actions, including reviewing weather, flight battery 

requirements, landing and takeoff distances, and aircraft performance data before 

commencement of flight. 

14 C.F.R. §91.119(c): Minimum Safe Altitudes 

Section 91 .119 establishes safe altitudes for operation of civil aircraft. Section 91 .119 

provides, in pertinent part, that: "except when necessary for takeoff or landing, no 

person may operate an aircraft below the following altitudes: ... 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, any aircraft may not be 

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

15 
Because Extreme Aerial Imagery requests authority to operate at altitudes only up to 

200 feet and never above 400 feet, and not more than 200 feet above an elevated 

platform from which filming is planned, an exemption is needed to allow such 

operations. The UAS will never operate higher than 400 AGL. It will, however, be 

operated in a restricted area within a security perimeter, where buildings and people will 

not be exposed to operations without their pre-obtained consent. 

The 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. No flight will be taken without the 

permission of property owners or local officials. Because of the advanced notice to the 

property owners and participants in the filming activity, all affected individuals will be 

informed of the planned flight operations. Compared to flight operations for manned 

aircraft and the lack of flammable fuel, any risk associated with the proposed UAS 

operations is far less than conventional aircraft operating at or below 500 feet AGL. In 

addition, the low-altitude operations of the UAS will ensure separation between a UAS and conventional aircraft. 

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

Section 91.121 requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set u •• • to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As a UAS may not have a 

barometric altimeter, but a GPS altitude data, an exemption is needed. An equivalent 

level of safety will be achieved by the operator. 

14 C.F.R. §91.151 (a): Fuel Requirements for Flight in VFD Conditions 

Section 91.151 (a) prohibits an individual from beginning "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 - (1) During the day, to fly after that for at least 30 minutes." 

The battery powering the Extreme Aerial Imagery UASs provides approximately 25 

minutes of powered flight. To meet the 30 minute reserve requirement in 14 C.F.R. 

§91.151, UAS flights will be limited to approximately 12-15 minutes in length. Given the 

limitations on the UAS's proposed flight area and its proposed operations within a 

predetermined location, a longer time frame for flight in daylight VFR conditions is 

reasonable. Furthermore, operating the UASs in a tightly controlled area where only 

people, property owners, or official representatives who have signed waivers will be 

allowed

less than 30 minutes of reserve of reserve fuel does not engender the type of 
p

p

p

,

p

in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Extreme Aerial Imagery operations. 

Maintenance will be accomplished by the operator. An equivalent level of safety will be 

achieved because these small UASs are limited in size, will carry a small payload, and 

operate only in restricted areas for limited periods of time. If mechanical issues arise, 

the UAS can land immediately and will be operating from no higher than 400 feet AGL. 

As provided in the manufacturer's manual, the operator will ensure that the UAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log of 

any maintenance performed. Moreover, 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 the operator encounters a maintenance issue which cannot 

be addressed, the UAS will be returned to the manufacturer or a qualified repair facility 

where such repairs or maintenance can be performed. 

Privacy 

All flights will occur over private or controlled access areas with the property owner's 

prior consent and knowledge. Filming will be only of people who have given their 

consent or otherwise have agreed to be in the area where filming will take place. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, 

weight, speed, operating capabilities, proximity to airports, and populated and 

operations within visual line of sight and national security) provide more than adequate 

justification to grant Extreme Aerial Imagery requested exemption, allowing for Extreme 

Aerial Imagery UAS commercial operations for the aerial photography and video on real 

estate industry, agriculture industry, construction industry, motion picture, television 

industry, surveying, and special events. 

Summary of Publication 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

17 
Extreme Aerial Imagery seeks an exemption under Section 333 from the following rules: 

14 C.F.R. Part 21, Subpart H; 61.23(a); 61.113(a) and (b); 91 .1 03; 91.1 09; 91 .119(c); 

91 .121; 91.151(a); 91.405(a); 91.407{a){1); 91.409 (a)(1) and (2); 91.417(a) and (b) to 

operate commercially a small unmanned aerial vehicle or UAS. 

As established by the UAS exemptions already granted by the FAA, allowing 

commercial operations will enhance safety by reducing risk. Conventional film 

operations, using turbine aircraft or helicopters, operate at low altitudes and present the 

risks associated with aircraft that weigh around 4,000 pounds, and which carry large 

amounts of Jet A fuel. Such aircraft must also fly to and from the film location. In 

contrast, a UAS weighing fewer than 7.5 pounds and powered by batteries eliminates 

virtually all of the risk given the small size and Jack of combustible fuel. The UAS is 

carried, and not flown, to a film set. In this regard, the UAS carries no passengers or 

crew and, therefore, will not expose them to the risks associated with manned flights. 

The operation of UASs conducted in the strict conditions will provide an equivalent level 

of safety supporting the grant of the exemption requested herein. The UASs operate at 

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

safer than conventional operations conducted with turbine airplanes or helicopters 

carrying fuel and flying near the ground and people. 

For any questions or additional information needed, please contact the undersigned at 

(787)930-3644 or ExtremeAeriallmaqery@ qmail.com. 

Sincerely, 

Neris 

Extreme Aerial Imagery