U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W12-140

Washington, DC 20590

RE: Petition for Exemption under Section 333 of the FAA Modernization and

Reform Act and Part 11.81 of the Federal Aviation Regulations

Docket ID:__________________________

September 4, 2015

Petitioner:

Precision Aero-Graphics & Imaging

James F. Spicer

1119 East 2nd. St.

Sulphur, OK 73086

TEL: (580) 277-0233

Email: lowlevlflyer@gmail.com
Dear Sir or Madam,

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

and 14 C.F.R. Part11.81, Precision Aero-Graphics & Imaging hereby applies for an exemption 

from the listed Federal Aviation Regulations ("FARs"), to allow commercial operation of its 

small, unmanned aircraft for, but not limited to general photography and real estate

applications, aerial inspection and survey, agricultural imaging and survey, and search and 

rescue. All operations shall be conducted within and under the conditions and limitations 

outlined previously by the FAA as required by Section 333 and conducted in compliance with 

the attached operator’s manuals. No commercial operations have been conducted thus far and 

will not be conducted until a petition is granted.

1. Sections from which exemptions are sought: Application is hereby made for exemption from:

a. 14 CFR Part 21, subpart H

b. 14 CFR Part 61.113(a) and (b)

c. 14 CFR Part 91:

i. 91.103

ii. 91.105

iii. 91.109(a)

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.203 (a) & (b)

viii. 91.405

ix. 91.407

x. 91.409

xi. 91.417
2. Relief sought:

a. Ghost Drone Imaging wishes to operate small Unmanned Aircraft Systems (sUAS) for 

commercial purposes to include (but not be limited to) general photography and real estate.

This relief is sought because commercial use of sUAS is currently prohibited by law unless 

performed under an exemption.

b. This exemption will cover use of the following airframes, all of which will weigh less than 55 

pounds including payload and energy sources:

i. DJI Inspire 1 (See http://www.dji.com/product/inspire-1) 

ii. Other models to be added by future amendment to this exemption.

3. Public benefit:

a. Use of UAS technology to obtain imagery, information and data currently obtained by use of 

manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure 

inspections) and due to other dangerous activities that can be avoided.

ii. Reduces the cost of obtaining such information, which benefits consumers and the economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from 

manned aircraft.

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 

45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. All 

repair and maintenance work will be conducted or approved by qualified personnel such as 

those authorized by DJI (or equivalent), and will require a test flight after such work. Records of 

all maintenance and repair work will be kept in a maintenance log for each aircraft.

c. All flight operations will be conducted by at least two individuals (PIC and observer) who will 

maintain verbal communication capability with each other at all times during the flight, and 

who will remain stationary on the ground during the flight operations:

i. The Pilot In Command (PIC) possess the following credentials:

1. An Airman Certificate issued under 14 CFR 61 (commercial pilot license) screened by the TSA

2. A current Second Class medical certificate issued under 14 CFR 67.

3. A bi-annual flight review under 14 CFR 61.56
4. Successful completion of a UAS knowledge test in a specified form.

5. 12,500 hrs of flight experience in manned aircraft. At least 25 hours of flight experience in a 

UAS rotorcraft (or UAS fixed-wing in the case of fixed-wing flight operations under this 

exemption). Such hours may be gained during flights under this exemption if a safe distance is 

maintained from persons in accordance with 14 CFR 91.119.

6. At least 5 hours of flight experience and 3 takeoffs and landings in make and model being 

flown in the prior 90 days. Such cycles and hours may be gained during flights under this 

exemption if a safe distance is maintained from persons in accordance with 14 CFR 91.119.

ii. A Visual Observer.

iii. A Sensor Operator as necessary.

d. All flight operations will be conducted in accordance with valid Certificates of Authorization.

e. All flight operations will comply with the following:

i. The manufacturers’ user manuals.

ii. Precision Aero-Graphics & Imaging’s Flight Operations and Procedures Manual (FOPM) and 

Aircraft Flight Manuals (AFM) which include lost communication and other emergency and 

safety procedures.

iii. Conducted in VMC conditions during daylight hours.

iv. PIC and VO will maintain VLOS at all times.

v. Pre-flight inspections (including ground control station, if any) and safety risk assessments 

will be conducted prior to each flight.

vi. Flight altitudes will remain below 400 feet above ground level.

vii. Flight ground speeds will not exceed 50 knots.

viii. Not intrude into Class B, C or D airspace, or published approach, SID or STAR, or take place 

within 5 nautical miles of an airport.

ix. Not be made near persons as required in 14 CFR 91.119 and not over persons on the ground 

without their prior permission.

x. Each flight will be logged in both the PIC’s logbook and the aircraft logbook.

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 20 minutes, whichever 

occurs first.

xii. Any incidents will be reported immediately.

xiii. Any applicable local FSDO requirements.
xiv. All other applicable regulations concerned with the operation of aircraft.

f. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with welldefined and tested lost link procedures.

Please advise us of any additional information or changes that may be required.

Sincerely,

James F. Spicer, owner, chief pilot

Precision Aero-Graphics & Imaging