10 March 2016

Mr. Thomas J. Dougherty

Lewis Roca Rothgerber LLP

Counsel for Imago Visual

1200 Seventeenth Street, Suite 3000

Denver, CO 80202

Dear Mr. Dougherty:

This letter is to inform you that we are unable to process your petition for an exemption. It explains 

why we cannot process your request and what you should do in the next 30 days.

Why We Cannot Process Your Request

We received your August 25, 2015, exemption request on behalf of Imago Visual filed in Docket 

No. FAA–2015–5883, but we are unable to process your request any further. Your petition does not 

comply with the requirements of § 11.81 (copy enclosed). For us to consider the request any further, 

you must send us all of the following:

 The reasons why granting the request would be in the public interest; that is, how it would benefit 

the public as a whole.

 Any additional information, views, or arguments available to support your request.

For more detailed information relating to submitting petitions for exemption, please visit 

http://aes.faa.gov/petition/index.html. This website helps the petitioner to meet Federal Aviation 

Administration (FAA) requirement outlines in § 11.81 and helps answer any questions you may have. 

What You Should Do

If you want us to process your request any further, you must submit the requested information within 

30 days. Please note that § 11.63(d) requires you to send your petition for exemption at least 120 days 

before the proposed effective date of the exemption. 
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If We Do Not Hear From You

If we do not receive the information, we will close the docket without notifying you further. If you 

have any questions you may call the 333 Information Line (202) 267-2999.

Sincerely,

\s\

Brittany Newton

Program Analyst, Airmen and 

 Airspace Rules Division

Enclosures
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Section 333 Petition Guidance & Checklist

Note: It is highly recommended petitioners carefully review the “Conditions and Limitations” section 

in the most recently granted exemptions. This will provide valuable insight as to what the FAA is 

approving under Section 333. 

Where can I find previously granted exemptions?

 https://www.faa.gov/uas/legislative_programs/section_333/333_authorizations/

 Write down the docket number in the exemption you are reviewing (it will be formatted like this: 

FAA-XXXX-XXXX).

 Search for that docket number at regulations.gov, and review the petition, as well as any supporting 

documents.

Ready to create your petition? 

Use the checklist below to ensure your petition contains all the necessary information. Failure to 

include the following information may result in delays in processing your request: 

 Operator’s name and address;

 The specific applicable regulations from which relief is required (CFRs);

 How the operator will maintain an equivalent level of safety or no adverse impact to safety;

 How granting the exemption would be in the public interest;

 The proposed operations; and,

 The make and model of the aircraft for proposed operations (aircraft manuals are not necessary).

Ready to submit your petition?

Note: Proprietary/Confidential documents should be clearly marked and emailed to 

333exemptions@faa.gov. Be sure to include your comment tracking number (received upon successful 

submission to regulations.gov) when emailing these documents. Do not submit them to 

regulations.gov. 

 Visit https://www.faa.gov/uas/legislative_programs/section_333/how_to_file_a_petition/

Please note that due to the large volume of petitions being submitted, it will take approximately 8-10 

weeks for submissions to be posted to the docket at regulations.gov and assigned a docket number. 

Questions?

Please reference our Frequently Asked Questions (FAQs) at: 

https://www.faa.gov/uas/legislative_programs/section_333/333_faqs/

If you didn’t find the answer to your question on our FAQ page, questions about the Section 333 

exemption process should be directed to 333exemptions@faa.gov. Questions about the operating 

conditions and limitations should be directed to 9-AFS-UAS-Inquiries@faa.gov.