GENESIS PHOTO IMAGES COMPANY

2050 NE 56TH CT

FORT LAUDERDALE, FL 33308

Docket Operations, M-30

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE. Room W12-140 

West Building Ground Floor 

Washington, DC 20590-0001

November 8, 2015

Dear Sirs or Madam:

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

referred to as FMRA) and 14 CFR Part 11, The Genesis Photo Images Company (herein 

referred to as Genesis) hereby applies for an exemption from the listed Federal Aviation 

Regulations (FARs) to allow commercial operation of UAS for the acquisition of aerial 

data, so long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA. As detailed in this document and the 

attached Appendix of UAS, the requested exemption would permit the operation of 

UAS under controlled conditions in the United States. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation’s 

responsibilities to “...establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” 

Section 333(c) Reform Act. The name and address of the applicant is: Genesis Photo 

Images Company is owned and operated by Stephen R. Goddard Tel: 954-801-9656 

Email: stevesky@mac.com 

Regulations from which the exemption is requested: 14 CFR Part 21 14 CFR 45.23(b) 

14 CFR 61.113(a) & (b) 14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103 14 CFR 

91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) & (b) 14 

CFR 91.405(a) 14 CFR 407(a)(1) 14 CFR 409(a)(2) 14 CFR 417(a) & (b)

 AUTHORITY FOR EXEMPTIONS The Federal Aviation Act expressly grants the 

FAA authority to issue exemptions. This statutory authority includes exempting civil 
aircraft, as the term is defined under §40101 of the Act, including UAS, from the 

requirement that all civil aircraft will 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 USC §44701(f). See also 

49 USC §44711(a); 49 USC §44704; 14 CFR 91.203(a)(1). Section 333(b) of the 

Reform Act assists the Secretary in determining whether UAS may operate in the 

national airspace system without creating a hazard to the user, the public, or a threat to 

national security. In making this determination, the Secretary must consider: • The 

UAS’ size, weight, speed and operational capability; • Whether the UAS operates within 

the visual line of sight of the operator; • Whether the UAS operates outside of highly 

populated areas and away from close proximity to airports. Reform Act 333(a). If the 

Secretary determines that a UAS “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).

 BACKGROUND ON GENESIS. The Genesis business model is predicated on 

identifying aerial photography needs. Our clients require aerial photography for 

surveying building sites, promoting real estate, traffic accident investigations as well as 

roof top assessments in construction and insurance underwriting.

DESCRIPTION 

Genesis seeks to commercially operate a variety of UAS weighing less than 55 pounds 

including payload in the United States for the purpose of acquiring aerial data. The 

Appendix attached to this exemption petition lists the aircraft that Genesis contemplates 

operating. In addition, Genesis requests that it be granted permission to operate those 

aircraft already approved in previous Section 333 exemption petitions. Specifically the 

UAS Yuneec Q500 which has already been granted exemption in Exemption No. 11438 

Regulatory Docket No. FAA–2015–0188. As the operator of these aircraft, Genesis is 

committed to the following conditions and limitations on its operations. Genesis 

understands that failure to comply will be grounds for the immediate suspension or 

rescission any exemption granted. 

1. Operations are limited to the UAS listed in the Appendix and those UAS previously 

approved by the Secretary when weighing less than 55 pounds including payload. 

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

contemplated using UAS listed in the appendix and those approved under prior Section 
333 petitions. 

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

In no case will the aircraft be operated at airspeeds greater than the maximum aircraft 

operating airspeed recommended by the aircraft manufacturer.

4. The aircraft will be operated at an altitude of no more than 400 feet above ground 

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

5. The aircraft will be operated within visual line of sight (VLOS) of the Pilot in 

Command (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 U.S. 

driver’s license. 

6. All operations will utilize a visual observer (VO). The aircraft will be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. 

7. All operating documents needed to operate the UAS and will be accessible during 

UAS operations and made available to the Administrator upon request. The operator 

will also present updated and revised documents if it petitions for extension or 

amendment. 

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, will 

undergo a functional test flight prior to conducting further operations. 

9. Genesis 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 will conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. 

11. Genesis will 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 will comply with all manufacturer safety 

bulletins. 
13. PIC will hold either an airline transport, commercial, private, recreational, or sport 

pilot certificate. The PIC will 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 government. The PIC will 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. Genesis 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 to 

acquire aerial data, including evasive and emergency maneuvers and maintaining 

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

flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). 

Genesis will operate flights for the purposes of training Genesis PICs and VOs (training, 

proficiency, and experience building) and determining the PIC’s ability to safely operate 

the UAS. 

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

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

16. The aircraft will 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. 

17. The aircraft will 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 aircraft will return to a 

pre-determined location. 

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

20. The PIC will be prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power or fuel for the aircraft to 

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

the reserve power or fuel recommended by the manufacturer if greater. 
21. All operations shall be conducted in accordance with an ATO-issued COA if the 

blanket COA does not cover the intended operation. 

22. All aircraft operated will 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 will be as large as practicable. 

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

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

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

24. The aircraft will remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may be operated by the PIC from a moving device or vehicle; however, 

specific requests will be made via subsequent COA. 

26. All flight operations will 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 aircraft or debris in the event of an 

accident; or b. The owner/controller/operator of any vessels, vehicles or structures has 

granted permission for operating closer to those objects and the PIC has made an 

assessment of the risk of operating closer to those objects and determined that it does 

not present an undue hazard. 

27. The PIC, VO, operator trainees or essential persons will not be considered 

nonparticipating persons under this exemption. 

28. All operations conducted over private or controlled-access property will be 

conducted with the 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. 

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

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

the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions contained 

on the NTSB Web site: www.ntsb.gov. 
DESCRIPTION OF SPECIFIC REGULATIONS 

14 CFR Part 21, Subpart H: Airworthiness certificates Subpart H, establishes the 

procedural requirements for the issuance of airworthiness certificates as required by 

FAR §91.203(a)(1). Given the size and limited operating area associated with the 

aircraft to be utilized by Genesis, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the 

Reform Act. The Federal Aviation Act (49 USC §44701(f)) and Section 333 of the 

Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational 

capability and proximity to airports and populated areas of the particular UAS. In all 

cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions 

proposed, will be at least as safe, or safer, than a conventional aircraft operating with an 

airworthiness certificate without the restrictions and conditions proposed. 14 CFR 

45.23(b): Marking of the aircraft This regulation requires that certain experimental, 

provisionally certified aircraft, or lightsport category aircraft to be marked with letters 

between 2 inches and 6 inches high “limited”, “restricted,” “light-sport,” 

“experimental,” or “provisional,” near each entrance to a cabin, cockpit or pilot station. 

Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which 

the word “Experimental” can be placed. Given the size of the UAS, 2 inch lettering may 

be impossible. Genesis will mark the UAS as practicable. 

14 CFR § 61.51(b), a minimum of five hours as UAS pilot operating the make and 

model of UAS to be utilized for operations under the exemption and three take-offs and 

three landings in the preceding 90 days. Training, proficiency, experience-building, and 

take-off and landing currency flights can be conducted to accomplish the required flight 

time and 90 day currency. During training, proficiency, experience-building, and takeoff and landing currency flights all persons not essential for flight operations are 

considered non-participants, and the PIC will operate the UA with appropriate distance 

from non-participants in accordance with 14 CFR § 91.119. 

Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), a flight demonstration, administered by an operator-approved and -qualified 

pilot will have successfully completed and documented. Because the knowledge and 
airmanship test qualifications have been developed by the operator, and there are no 

established practical test standards that support a jurisdictional FAA Flight Standards 

District Office (FSDO) evaluation and approval of company designated examiners, the 

petitioner will conduct these tests in accordance with the operator’s manual. 

The UA will not be operated directly over any person, except authorized and consenting 

production personnel, below an altitude that is hazardous to persons or property on the 

surface in the event of a UAS failure or emergency. Regarding the distance from 

participating persons, the operator’s manual has safety mitigations for authorized and 

consenting production personnel. At all times, those persons will be essential to the 

closed-set film operations. Regarding distance from non-participating persons, the 

operator will ensure that no persons are allowed within 500 feet of the area except those 

consenting to be involved and necessary for the filming production and no less than 200 

feet when not adversely affecting safety consistent with FAA Order 8900.1, V3, C8, S1. 

If the UAS loses communications or loses its Global Positioning System (GPS) signal, 

the UA will return to a pre-determined location within the security perimeter and land or 

be recovered in accordance with the operator’s manual. The UAS will abort the flight in 

the event of unpredicted obstacles or emergencies in accordance with the operator’s 

manual. 

14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements The 

UAS, given its size and configuration has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board, but because there is 

no room or capacity to carry such an item on the aircraft. The equivalent level of safety 

will be maintained by keeping the Operating Manuals at the ground control point where 

the pilot flying the UAS will have immediate access to it. 14 CFR 91.103: Preflight 

action This regulation requires each pilot in command take certain actions before flight 

to ensure the safety of flight. An exemption is needed from this requirement, as the pilot 

will take separate preflight actions, including checking for weather conditions, checking 

flight battery or fuel requirements, checking takeoff and landing distances, and all other 

actions in the Operating Manual and safety checklists. These actions will provide an 

equivalent level of safety. 

14 CFR 91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for 

operation of civil aircraft. The UAS will never operate at altitude higher than 400 AGL 

and all operations will occur during daylight hours under Visual Meteorological 

Conditions (VMC) only. 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 the property owner. Because advance notice to the 

property owner and any onsite personnel, as well as the precautions outlined below, all 

affected individuals will be aware of the planned flight operations. Flight operations will 

be conducted at least 500 feet from all non-participating persons (persons other than the 

pilot in command (PIC) or visual observer (VO)), vessels, vehicles and structures, 

unless operations do not present an undue hazard. The UAS will remain within visual 

line of sight of the PIC or VO. Flight operations will be conducted at least 5 miles from 

an airport. The PIC or VO will provide notification to the local Flight Standards District 

Office and airport controller of all operations within 5 miles of an airport. The FAA will 

have advance notice of all operations through the filing of notices-to-airmen. Compared 

to flight operations with aircraft or rotorcraft weighing far more than the UAS proposed 

herein, any risk associated with our operations is far less than those presently presented 

with helicopters and other conventional aircraft operating at or below 500 feet AGL. In 

addition, the low-altitude operations of the UAS will ensure separation between these 

UAS operations and the operations of conventional aircraft that will comply with 

Section 91.119. 

14 CFR 91.121: Altimeter Settings This regulation requires each person operating the 

aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the 

elevation of the departure airport or an appropriate altimeter setting available before 

departure.” As the UAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an exemption may be needed. An equivalent level of safety will be achieved 

by the PIC confirming the altitude of the launch site shown on the GPS altitude indicator 

before flight. 14 CFR 91.151(a): Fuel requirements for flight in VFR conditions Section 

91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Relief 

from Section 91.151(a)(1) is requested to the extent that any UAS approved for use will 

only be flown in commercial operations with enough available power for the UAS to 

conduct the intended operation and to operate after that for at least 5 minutes or with the 

reserve power recommended by the manufacturer if greater. While flying in “closed-set” 

operations each UAS operation will be completed within 30 minutes flight time or with 

25% battery power remaining, whichever occurs first.

PUBLIC INTEREST 

Approval of exemptions allowing commercial operations of UASs for aerial acquisition 

of data enhances safety while reducing risk. Manned aircraft in certain application such 

as pipeline monitoring create a greater risk because the aircraft are much larger and 

carry an onboard human pilot. In contrast, a UAS weighing 55 pounds or less will carry 
no passengers or crew and, therefore, will not expose them to the risks associated with 

manned aircraft flights. In addition, additional streams of aerial data will allow 

commercial entities to make decisions about how to best deploy ground resources and 

ensure the safety and cost-effectiveness of their operations. 

EQUIVALENT LEVEL OF SAFETY Genesis proposes that the exemption requested 

herein apply to civil aircraft that have the characteristics and that operate within the 

limitations listed herein. These limitations provide for at least an equivalent or even 

higher level of safety to operations under the current and proposed regulatory structure. 

PRIVACY 

All flights will occur over private or controlled access property with the property 

owner’s prior consent and knowledge. Images or video taken of individuals will have 

consented to being filmed or otherwise they will be made anonymous. NATIONAL 

SECURITY Given the small size of the UAS involved and the restricted environment 

within which they will operate, our petition presents no national security issue. 

FEDERAL REGISTER SUMMARY Docket No.: No. FAA-2015-____ Petitioner: 

Genesis Photo Images Company Part 21 and §§ 45.23(b), 61.113(a) and (b), 91.7(a), 

91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 

407(a)(1), 409(a)(2), 417(a) and (b) of Title 14, Code of the Federal Regulations (14 

CFR). Description of Relief Sought: Genesis is seeking an exemption to conduct 

commercial acquisition of aerial data using unmanned aircraft systems. Based upon the 

foregoing, Genesis requests that the FAA grant it the necessary exemptions under 

Section 333 of the FAA Reform Act as requested herein to allow for commercial 

operations of UAS within the United States.

Regards,

Stephen R Goddard

Owner and Operator 

Genesis Photo Images Company