Sections we are seeking relief from

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

(“Section 333”), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, 4K Aerial Imaging, 

LLC requests an exemption from the following Federal Aviation Regulations (“FARs”): 14 

C.F.R. Part 21; 14 C.F.R. 61.113(a) and (b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 

91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 

91.409(a)(1) and (2); 14 C.F.R. 91.417(a) and (b).

Public Interest

UAV Aeronautics Investigation & Logistics use of UAS for videoing and photographing utility

components (e.g., Accident investigation, fire, train track inspection, search and rescue) as well 

as survey mapping can reduce the required manpower as well as the likelihood of inspection 

related injuries. A small UAS can be used to safely inspect powerlines instead of a large 

helicopter hovering within a close proximity of powerlines carrying persons onboard with 

hundreds of gallons of combustible fuel. The environmental impact can also be reduced when 

using small UAS instead of traditional methods of utility inspection. Small UAS can inspect, 

photograph and collect data in hard to reach areas that otherwise would require worker 

inspection. Manned aircraft have a greater possibility of becoming a threat to the general public 

through potential catastrophic crashes resulting in loss of life. Our small UAS pose no such 

threat due to their small size (each weighing less than 10 pounds), no onboard pilot, and lack of 

combustible fuel. This alleviates a large amount of potential threats to the public. Additionally, 

small UAS reduce the environmental impact by dramatically decreasing the energy used for 

aerial imaging. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the

characteristics and that operate with the limitations listed herein. These limitations provide for at 

least an equivalent or even higher level of safety to operations under the current regulatory

structure because the proposed operations represent a safety enhancement for current Aerial 

photography services that use conventional, ‘full scale’, piston/jet driven aircraft. These 

limitations and conditions to which UAV Aeronautics Investigation & Logistic LLC., the 

applicant, agrees to be bound when conducting commercial operations under an FAA issued 

exemption include:

4 Reform Act Section 333 (b).

Regulations from which the exemption is requested: 14 C.F.R Part 21 14 C.F.R. 45.23(b) 14 

C.F.R 61.113 (a) & (b)

14 C.F.R. 91.7 (a)14 C.F.R 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F.R. 91.119

14 C.F.R. 91.121 14 C.F.R 91.151 (a) 14 C.F.R 91.203 (a) & (b) 14 C.F.R 91.405 (a) 14 C.F.R 

407 (a) (1) 14 C.F.R 409 (a) (2) 14 C.F.R 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 

333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (NAS) before completion of the rulemaking required under Section 332 of the Reform 

Act. In making this determination, the Secretary is required to determine which types of UASs 
do not create a hazard to users of the NAS or the public or pose a threat to national security in 

light of the following:

• The UAS’s size, weight, speed, and operational capability; • Operation of the UAS in close 

proximity to airports and populated areas; and • Operation of the UAS within visual line of sight 

of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely 

in the national airspace system, the Secretary shall establish requirements for the safe operation 

of such aircraft in the national airspace system.” Id. §333(c) .

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined under 

§40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a 

current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator 

finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 

USC §44704; 14 CFR §91.203 (a) (1).

UAV Aeronautics will be using the DJI Phantom 2+ and the DJI Phantom3 professional.

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DJI Phantom 2 Vision + Owner’s Manual with pre-flight checklist and maintenance procedures:

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DJI’s Website resource to locate NO FLY ZONEs near your current location:

http://www.dji.com/fly-safe/category-mc