August 11, 2015

Exemption No. 12432

Regulatory Docket No. FAA–2015–1559

Mr. Paul Woessner

Aerial Enterprises, Inc.

73 Coquina Ridge Way

Ormond Beach, FL 32174

Dear Mr. Woessner:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 28, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Aerial Enterprises, Inc. (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct photographic 

data collection and closed set motion picture and television filming.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Spreading Wings S1000+ and 3D Robotics 

Iris+.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

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

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1and closed set motion picture and 

filming. The FAA has issued grants of exemption in circumstances similar in all material 

respects to those presented in your petition. In Grants of Exemption Nos. 11062 to Astraeus 

Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. 

FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 

11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the 

enhanced safety achieved using an unmanned aircraft (UA) with the specifications described 

by the petitioner and carrying no passengers or crew, rather than a manned aircraft of 

significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA 

good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Aerial Enterprises, Inc. is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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and closed set motion picture and filming. This exemption is subject to the conditions and 

limitations listed below.

Conditions and Limitations

In this grant of exemption, Aerial Enterprises, Inc. is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Spreading 

Wings S1000 + and 3D Robotics Iris + when weighing less than 55 pounds including 

payload. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 
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documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 
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government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 
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exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 
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reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
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Aerial Enterprises} Inc. 

73 Coquina Ridge Way, Ormond Beach, Florida 321741 Tel (386)-576-7404 

April 28, 2015 

U.S. Department of Transportation, Docket Operations 

Attn: Federal Aviation Administration (FAA) Administrator 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Dear Administrator, 

Aerial Enterprises (AE) would like the FAA to consider this letter as its Section 333 Waiver application 

to operate sUAS for photographic data collection for the insurance industry in a post catastrophe 

environment. 

AE was established in 1991 as a commercial operator of hot air balloons, Helium gas Balloons, Hot air 

Airships, and Helium Gas Airships providing a variety of aerial platforms to conduct a wide range of 

aerial work including operating under FAA Part 91 and 135. AE's aerial work includes operating 

manned balloons and blimps as aerial platforms for live television coverage of major sporting events, 

television commercial production, and filmmaking in "closed set" environments. 

In early 2014, a large insurance-adjusting firm who were seeking a sUAS aerial platform and operator 

that could aid them in their work to quickly settle claims through documenting post catastrophe wind 

and hail damage post tornado and/ or hurricane contacted AE. As the principal of AE I would like the 

Administrator to know that I am a Commercial Pilot of 35 years, an Academy of Model Aeronautics 

(AMA) member, an AUVSI member and have most recently become a Licensed Certified Insurance 

Adjuster or the States of Florida and Louisiana. I am on the roster of three (3) major insurance 

adjusting companies Renfroe, Worley, and National Claims who together serve State Farm, Liberty 

Mutual, Tower Hill, and Citizens insurance companies for all their property claims in the states of 

Florida and Louisiana. It is important to note that during times of post catastrophe states such as 

California, Texas, Alabama, North Carolina, South Carolina, Maryland and New Jersey all routinely 

issue emergency adjuster licenses to existing adjusters such as myself and other AE staff members. 

Furthermore, holders of Florida and Louisiana adjuster licenses enjoy reciprocity in nearly every state 

in the union except New York. For these reasons just mentioned and the unpredictability of where the 

next catastrophe will strike AE is seeking the Section 333 Waiver for this purpose for the entire 

continental United States. 

It is important for the Administrator to understand that insurance companies are required by law in a 

post catastrophe environment to "promptly investigate and adjust the claim" in order to help property 

owners return their property and life style to the pre-storm condition as quickly as possible. 

Insurance companies strive to make the first initial settlement within 10 days of the loss. In certain 

large catastrophic events such as Super Storm Sandy it can literally take years to settle all claims. In 

order to process the claim a licensed adjuster must document all the damage and estimate repairs. 

This data collection process is primarily done utilizing digital stili photography taken by a licensed 

adjuster climbing on rooftops. In a post catastrophe environment the infrastructure, such as roads and 

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Aerial Enterprises} Inc. 

73 Coquina Ridge Way, Ormond Beach, Florida 321741 Tel (386)-576-7404 

power lines, are often compromised and large amounts of debris often times makes the job of the 

adjuster time consuming and dangerous attempting to get to the site of the loss to inspect the damage. 

This process is further slowed when a large event takes place wiping out entire neighborhoods. 

Unfortunately, this translates into long delays for property owners to get their first settlement check 

who are often times displaced from their homes for extended periods of time adding significant costs 

to their loss which only adds to insurance premium increases for all property owners. 

The benefits of using a sUAS operated by licensed pilots and observers for this purpose are both 

obvious and very much in the public interest. 

Upon the granting of this waiver application, AE intends to add multiple sUAS devices to its fleet and 

qualified personnel to its staff in order to address the specific need to conduct aerial photographic 

data collection in a post catastrophe environment for the insurance industry. 

Aerial Enterprises commends the Federal Aviation Administration's (FAA) recent action in publishing 

the new proposed sUAS rule and the Blanket COA provision for Section 333 Waiver holders. AE agrees 

with the FAA position that in some instances it is not necessary for the pilot and observer to hold an 

Airman's Certificate, however, AE firmly believes that in a post catastrophe environment where the 

airspace may become temporarily restricted it will be critical that AE sUAS pilot and observer teams 

are licensed under the CFR Title 14. AE understands that until the new rule becomes law the FAA still 

needs to ensure the safety of the NAS (National Airspace System) for all users. For that reason AE is 

staffed only with licensed pilots and subject matter experts (SME's) from the aviation, insurance, and 

photography industries. AE both already has and will continue to be trained in the best practices and 

standard operating procedures (SOPs) of the Original Equipment Manufacturer (OEM) for each sUAS 

AE intends to operate, while at the same time incorporating these same SOPs in AE's Operational 

Specifications (Ops Specs). 

AE has invested significant resources in sUAS platforms, as well as imaging and sensing devices in the 

effort to provide our customers with aerial photography services using only qualified and licensed 

pilot and observer operator teams who are familiar with applicable Federal Aviation regulations. 

It has been reported that there are now over 1 million sUAS platforms in operation today. Many of 

these ultra small lightweight (under 4.4lb) devices are currently being operated by hobbyists and 

people with no prior aviation experience in complete defiance and or ignorance of the FAA position on 

commercial operations of sUAS. In contrast AE will provide the same level of safety to its sUAS 

operations as it has for its manned Part 91 operations for the last 24 years, ensuring sUAS operations 

are also conducted within the legal guidelines as manned flight as well as any stipulations by the 

Administrator that may become part of this exemption if granted. 

It is the sincere hope of Aerial Enterprises, and its entire workforce, that the Administrator grants this 

exemption, as AE believes it has met the congressional mandate to "operate safely in the National 

Airspace System." 

Furthermore, it is AE's belief that in most cases AE can collect the photographic evidence insurance 

companies need without exceeding the 200ft. AGL stipulation contained in the FAA Blanket COA 

provision which adds another layer a safety to AE's proposed operations. 

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Aerial Enterprises} Inc. 

73 Coquina Ridge Way, Ormond Beach, Florida 321741 Tel (386)-576-7404 

Information Supporting this Petition as Specified in 14 C.F.R. §11.81 

A. Mailing address and other contact information: 

Paul Woessner 

Aerial Enterprises 

73 Coquina Ridge Way 

Ormond Beach, FL 32174 

Paul.woessner2 @gmail.com 

Cell 1-386-5 7 6-7 404 

B. The specific section or sections of 14 C.F.R from which Aerial Enterprises seeks exemption 

are as follows: 

1. 14 CFR Part 21, Subpart H: Airworthiness Certificates. 

2. 14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

3. 49 USC§ 44711 Prohibitions and exemption 

4. 14 CFR 45.23 Display of Marks; General and 45.29 Size of Marks. 

5. 14 CFR 91.9 Civil Aircraft Flight Manual, Marking, and Placard Requirements. 

6. 14 CFR 91.119 Minimum Safe Altitudes. 

7. 14 CFR 91.121 Altimeter Settings. 

8. 14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions. 

9. 14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, and Alterations. 

10. FAA Notice 8900.227 Paragraph 16(c) (4) PIC Medical and Paragraph 16(e)(1) Observer 

Medical. 

C. The extent of relief AE seeks, and the reason AE seeks the relief. 

Aerial Enterprises is requesting relief from multiple regulatory constraints under Title 14 of the Code 

of Federal Regulations (CFR) Parts 21, 45, 61, 65,91 as well as other UAS regulatory guidance under 

FAA Notice 8900.227, Public Law 112-95, Title 49 United States Code (USC), with regards to 

Unmanned Aerial System (UAS) operations, more specifically small UAS (sUAS) operations for 

commercial operations. 

AE would like, with the permission of the Administrator, to provide sUAS aerial imaging and sensing 

services with the intended use to include but not limit the following: 

• Aerial work including aerial photography, cinematography and survey 

• Surveying improved or unimproved properties 

o Roof tops and other structures 

o Exterior walls 

o Exterior appliances 

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Aerial Enterprises, Inc. 

73 Coquina Ridge Way, Ormond Beach, Florida 321741 Tel (386)-576-7404 

o Power lines and poles 

o Gas line and refinery 

o Marinas and boat slips 

o Infra structure assessment at post natural disaster and or other catastrophic event 

sites 

Detailed below is a list of operational safeguards AE believes are essential for safe operations of which 

many have been previously approved by the Administer for similar sUAS operations. In addition, AE 

will not commence a sUAS operation that would create an undue hazard to users of the national 

airspace system (NAS), the public, or pose a threat to national security. 

AE believes this request is consistent with the congressional mandate in Section 333 of the FAA 

modernization and Reform Act of 2012 and will allow AE to operate sUAS in a legal, safe, and publicly 

beneficial way which far exceed the standards currently permitted for recreational use. 

D. The reasons why granting Aerial Enterprises' request would be in the public interest; that 

is, how it would benefit the public as a whole. 

By granting this exemption the public will directly benefit by aiding insurance companies to more 

quickly handle their property loss claims without compromising the safety of the public. Indirectly the 

public gains by insuring that the only sUAS devices permitted to be operating over a natural disaster 

site will be conducted by safe, professional, and accountable operators who will be conducting work in 

the public's interest under the parameters set forth in the requested Section 333 Waiver approval and 

under the jurisdiction of the FAA. 

The benefits of s UAS operations is exhaustive and the uses of these devises will allow public, private, 

and personal entities to benefit from the expertise AE has to offer while mitigating the physical safety 

hazards of the current legally approved imaging methods, as well as, the cost reduction and total time 

required to inspect made possible by sUAS platforms. 

• Public safety 

• United States infrastructure 

o Bridges inspection 

o Utility inspection 

• Power 

• Communication 

• Unimproved Property Imaging 

o Agricultural 

• Surveying 

• Crop Inspection 

• Improved Property Imaging 

o Commercial and Residential 

o Structural inspection 

o Exterior appliance inspection 

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Aerial Enterprises, Inc. 

73 Coquina Ridge Way, Ormond Beach, Florida 321741 Tel (386)-576-7404 

• Economic Development Benefits 

• Advertisement 

AE is confident that the granting of this exemption will allow AE to begin providing a high quality 

solution for the insurance adjusting industry while minimizing the risk of accidents andfor damage to 

persons or property. The positive impact of getting a community "back up on its feet" after a storm 

will be felt by the families of our employees and the improved safety of our neighbors. 

E. The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which Aerial Enterprises seeks the exemption: 

As previously stated AE sUAS operations will provide a level of safety that far exceeds the level of 

safety currently required by the FAA for hobbyist, as well as, manufacturers of model aircraft. The 

following operating procedures will apply during all sUAS operations under this exemption. 

1. The sUAS's that AE has chosen to add to it's fleet with are as follows: 

i. DJI Spreading Wings S1000+ with an MTOW of 24lbs. 

a. Optional DJI Lightbridge (Advanced Data link System) 

ii. 3D Robotics Iris+ with a MTOW of 4.6 lbs. 

For detailed specifications, operational procedures, and optional equipment please see 

included documentation. 

2. Approved airframes will not exceed an airspeed of 87 knots (100 miles per hour) or 

"maximum never-exceed speed (VNE)" published and/or recommended by the airframe 

manufacturer, whichever is lower. 

3. AE's sUAS operations will not exceed the reported absolute altitude of 400 feet or 50 feet 

above and 50 feet laterally from the highest point of the target structure. 

4. All AE's sUAS PIC's will operate with visual line of sight (VLOS) at all times where the VLOS 

will be human unaided vision by any devise other than corrective lenses as specified on the 

PIC's FAA-issued airman medical certificate or U.S. driver's license. 

5. Operations- AE's use of Visual Observers (VO) 

• All AE sUAS operations not employing geo-fencing technology. 

• All AE operations operating more than 50 feet laterally of a target structure andfor 

over 100 feet AGL. 

• All AE operations where individuals not associated with the operation are within 

visual line of sight (VLOS) of the operation. 

6. Visual Observer requirements 

• All AE sUAS devices will be operated within VLOS of the PIC and VO at all times. 

i. The VO will be used to satisfy the VLOS requirement as long as the 

PIC always maintains VLOS capability. 

ii. The VO and PIC will be able to communicate verbally at all times. 

iii. The PIC will be designated before the flight. The PIC will ensure 

that the VO can perform the duties required of the VO. 

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Aerial Enterprises, Inc. 

73 Coquina Ridge Way, Ormond Beach, Florida 321741 Tel (386)-576-7404 

iv. The VO shall be a AMA member in good standing and abide by the 

AMA Code of Ethics 

7. The PIC will have all available information available required ensuring successful flight. This 

information will be accessible during sUAS operations. 

• All available information will include the following: 

i. All documents needed to operate the sUAS and conduct its operations in 

accordance with the conditions and limitations stated in the exemption, if 

granted. 

ii. The PIC/VO team will follow the procedures as outlined in its operating 

documents and will provide them to the Administrator or any law enforcement 

official upon request. 

8. AE will be responsible for maintaining and inspecting the UAS to ensure that it is in a condition 

for safe operation. 

9. Prior to each flight, AE's PIC will conduct a pre-flight inspection and determine the UAS is in a 

condition for safe flight. 

10. AE will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and 

life limit requirements for the aircraft and aircraft components and will comply with all 

manufacturer safety bulletins. 

11. All AE PIC's will hold a Private Pilot certificate with Instrument Flight endorsement issued 

under 14 CFR Part 61. 

• All AE PIC's will also hold a current FAA airman medical certificate. 

• All AE PIC's shall be an AMA member in good standing and abide by the AMA Code of 

Ethics 

12. AE will not permit any PIC to operate unless the PIC demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles 

and structures. 

• AE will only utilize a PIC who has completed OEM training and has minimum 

documented flight experience prior to any exempted commercial operation 

contemplated and requested in this application as follows: 

i. 25 hours total time in sUAS devices 

ii. 10 hours on each sUAS device category 

a. Fixed wing 

b. Vertical takeoff 

m. 5 Hours on each sUAS model AE operates or intends to operate> 

• PIC qualification flight hours and currency will be logged in a manner consistent with 

14 CFR § 61.51(b). 

13. AE sUAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All AE 

operations will be conducted under visual meteorological conditions (VMC). 

14. AE sUAS will not operate at or above 400 feet above the ground (AGL) or within 5 nautical 

miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility 

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Aerial Enterprises, Inc. 

73 Coquina Ridge Way, Ormond Beach, Florida 321741 Tel (386)-576-7404 

Directory (AFD) or for airports not published aeronautical chart, unless a letter of agreement 

with that airport's management is obtained or otherwise permitted by a COA issued to AE. 

• AE hereby additionally requests to operate below an altitude of 200 feet AGL providing 

AE has gained prior written approval from the air traffic authority responsible for the 

restricted airspace. 

15. AE will not operate its sUAS less than 500 feet below or less than 2,000 feet horizontally from 

a cloud or when visibility is less than 3 statute miles from the PIC. 

16. All AE's sUAS are equipped with a Lost Signal Return to Base fail safe system so if the device 

loses communications or loses its GPS signal it is reprogramed to return to a pre-determined 

launch location that is free and clear of hazards and people. 

17. In the event ofunpredicted obstacles or emergency AE's PIC will immediately abort the flight. 

18. AE's PIC will not begin a flight unless there is enough available power for AE's sUAS to conduct 

the intended operation and to operate after that for at least five minutes taking into 

consideration the local weather conditions. 

19. AE anticipates and agrees in advance to identify all of its sUAS by serial number, registered in 

accordance with 14 CFR part 47, and have identification (N- Number) markings in accordance 

with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 

20. All documents used by AE will ensure the safe operation and flight of the sUAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 and will be available to the AE PIC at 

the Ground Control Station of the sUAS any time the aircraft is operating. All documents are 

available upon request. 

21. AE's sUAS will remain clear and give way to all manned aviation operations and activities at all 

times. 

22. AE's UAS will not be operated by the PIC from any moving device or vehicle. 

23. All AE Flight operations will be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: 

• Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA andjor debris in the event of an accident. 

• The owner j controller of any vessels, vehicles or structures has granted permission to 

AE for operating closer to those objects and the AE PIC will make a safety assessment 

of the risk of operating closer to those objects and determined that it does not present 

an undue hazard. 

24. All AE sUAS operations will be conducted over private or controlled-access property with 

permission from the property owner j controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each flight 

to be conducted. 

25. In the event of any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area AE will report to the FAA's UAS Integration Office 

(AFS-80) within 24 hours of such an event. Accidents will be reported to the National 

Transportation Safety Board (NTSB). 

26. When AE operations are for the purpose of closed-set motion picture and television filming 

and production AE will observe and abide by all procedures as is contained in a motion picture 

and television operations manual (MPTOM). (Copy attached hereto for reference) 

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Aerial Enterprises} Inc. 

73 Coquina Ridge Way, Ormond Beach, Florida 321741 Tel (386)-576-7404 

27. For any AE operations outside ofthe "blanket" COA as described on the www.FAA.gov website, 

regarding UAS operations under 200 feet, AE will, at least 3 days before the scheduled aerial 

filming, submit a written Plan of Activities to the local Flight Standards District Office (FSDO) 

with jurisdiction over the area of proposed filming. 

• The plan of activities will include the following: 

i. Dates and times for all scheduled flights 

ii. Name and phone number of AE's PIC and VO for the scheduled 

sUAS aerial filming 

iii. Name and phone number of the PIC and VO responsible for the onscene operation of AE's sUAS 

iv. Make, model, and serial or N-Number of the sUAS AE intends on 

using 

v. Name and certificate number ofUAS PICs 

vi. A copy of written permission from property owners and/ or local 

officials to conduct the filming production event counter signed by 

the principal and owner of AE. 

vii. A description of the flight activity, including maps or diagrams of 

any area, city, town, county, and/ or state over which filming will be 

conducted and the altitudes essential to accomplish the operation. 

28. For flight operations closer than 500 feet from participating persons consenting will be 

conducted in accordance with and as specified in AE's MPTOM. 

F. Additional information and AE's view 

Aerial Enterprises would ask that the Administrator consider all previously awarded exemptions as 

supporting arguments to this exemption request. 

Aerial Enterprises and all of its employees would like to thank you for your consideration as we 

anxiously await a positive outcome to this request. 

Should the Administrator require any additional information or clarification please do not hesitate to 

contact me directly. 

Respectfully, 

73 Coquina Ridge Way 

Ormond Beach, FL 32174 

Tel +1-386-576-7404 

Paul.woessner2@gmail.com 

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