Precision Resource Management Imagery, LLC

Marc B. Allred

Stafford, VA 22556

(540) 300-6881

marc@prmimagery.com

Date: April 21, 2015

Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

RE: Petition of Precision Resource Management Imagery, LLC for Exemption Pursuant to 

Section 333 of the FAA Reform Act

Attn: To whom it may concern

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

and 14 C.F.R. Part 11, Precision Resource Management Imagery, LLC, operator of Small 

Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial photography and 

videography, hereby applies for an exemption from the listed Federal Aviation Regulations 

(“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA as required 

by Section 333.

As described more fully below, the requested exemption would permit the operation of small,

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1)

limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow

Precision Resource Management Imagery, LLC to conduct commercial operations of small 

unmanned aircraft systems (“UAS”) meeting or exceeding all of the operational and safety 

requirements Congress has set forth in Section 333. 

Precision Resource Management Imagery, LLC is an aerial imagery company owned and run by 

Marc B. Allred. Mr. Allred has a Department of Defense Certificate in Intelligence, Surveillance, 

Reconnaissance, and Collection Management. He has been conducting analysis on behalf of the 

Department of Defense for over 7 years. Precision Resource Management Imagery, LLC plans 

to exploit the capabilities of Unmanned Aerial Systems to offer a multitude of services, including:

- Aerial surveying

- Event Videography/Photography

- Agriculture imagery

- Real Estate Videography/Photography

- Aerial filmmaking and photography

- Construction site inspections and monitoring
Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”,

provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in

the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft

systems may operate safely in the national airspace system before completion of the

(comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance

required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Section

333 provides a mechanism for “expedited operation authorization” if several factors are met.

Petitioner meets all requirements to permit FAA approval of commercial UAS operations.

The Petitioner requests relief from the following:

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) and (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121Page 3

14 C.F.R. 91.151(a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 - 91.417)

Unmanned Aircraft System sUASs are oftentimes seen as superior to helicopters due to the

smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much

smaller environmental impact which promotes public safety.

We are petitioning for exemption to enable Precision Resource Management Imagery, LLC to 

operate an Iris+ equipped with a two-axis camera gimbal and using a High-Def camera. This 

sUAS has a built-in capability to limit the height it flies above the ground, to limit the radius of 

the distance it flies from the operator. The Iris+ also has the failsafe function of the autopilot 

system which means when the communication between the Main Controller and the transmitter 

is disconnected the outputs of all command sticks from controller will go to the center position. 

If the GPS signal is good enough, the system will automatically trigger Return to Home and will 

land safely.

Please refer to the included Iris+ Instruction Manual for the performance limitations and 

flight operations.

Aircraft weight is 24oz. with battery. The 2 Axis Camera Gimbal and Camera weigh 8oz. 

Gross weight will be 36oz.
A pre-flight inspection will be performed by the PIC in accordance with the factory instruction

manual. An added step will be the inspection of the propellers. A propeller will be replaced if it

has any nicks and cracks with a manufacturers authorized propeller.

The sUAS will be maintained in accordance with the manufacturer’s instruction manual and only

manufacturer's authorized replacement parts will be used.

FCC Information

The transmitter used for controlling the sUAS complies with part 15 of the FCC rules. Operation 

is subject to the following two conditions: (1) This device may not cause harmful interference, 

and (2) this device must accept any Interference received, including interference that may cause 

undesired operation. The radio transmitter used for controlling the sUAS is wireless technology 

which has been tested and found to be compliant with the applicable regulations governing a 

radio transmitter in the 2.400GHz to 2.4835GHz frequency range.

Antenna Separation Distance

When operating our transmitter, the PIC will maintain a separation distance of at least

5 cm between his body (excluding fingers, hands, wrists, ankles and feet) and the antenna to

meet RF exposure safety requirements as determined by FCC regulations.

Pilot in Command and Observer Qualifications and Duties

In addition to these flight restrictions, Precision Resource Management Imagery, LLC will 

further ensure safe operation by requiring that any PIC be thoroughly versed not only in airspace 

and communication issues pertaining to all aircraft operators but also in the unique aspects of 

UAS flight. As set forth in the Operations Manual, Pilots will have experience not only in UAS 

operations generally but have logged flight time in the specific make and model used for the 

operations before they are permitted to participate in commercial flights on behalf of Precision 

Resource Management Imagery, LLC. Petitioner believes that this system will provide a higher 

level of competency and proficiency for its pilots.

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties include

all preflight preparation, in flight operation, post flight requirements, all procedures including but

not limited to:

 Safe in flight operations

 Risk Mitigation to Persons and property

 Airfield Suitability

The Observer must have the visual acuity to observe the sUAS and be able to communicate

clearly with the PIC.

The Observers duties are;

 Warning the PIC of any impending obstacles in the flight path of the sUAS.

 Warning the PIC of any deviations in the planned flight path of the sUAS.

 Warning the PIC should any unauthorized personnel appear in the area of the planned 

flight.
The Observer will have the authority to order the PIC to terminate the flight should he feel the

flight cannot be conducted safely.

General Operating Standards

• Precision Resource Management Imagery, LLC will only operate its sUAS in line of sight of a 

pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas. 

Such operations will insure that the sUAS will "not create a hazard to users of the national 

airspace system or the public."

• Before an operation of a sUAS within 5NM of an airport with a control tower, the control tower 

will be called to gain permission to operate the sUAS. The PIC will give the position, altitude 

and the times the sUAS will be operated. The sUAS will not be operated at an altitude of over 

400 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling.

Before an operation of a sUAS within 5NM of a non-tower controlled, airport operators will be

notified and the PIC will give the right of way to avoid flying in the proximity of full-scale

aircraft. At no time will the sUAS be operated within the final approach course and the takeoff

course of any runway.

• Maximum flight time for each operational flight will be 15 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the 15 minute

limit.

• The sUAS will be programmed so that it will not be operated at an altitude of no more than

400 feet AGL and not more than 200 feet above an elevated platform from which filming is

planned.

• Minimum crew for each operation will consist of the sUAS Pilot, and Visual Observer.

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. 

camera, lens, and gimbals).

• The sUAS will operate at speeds of no more than 25 knots, can hover, and can simultaneously

move vertically and horizontally.

• Given the small size of the sUAS and the restricted sterile environment within which they will

operate, our sUAS operations adhere to the Reform Act's safety requirements.

The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft

running on combustible fuel, it operates at lower altitudes with no people on board and will

thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of

death or serious bodily injury. With a small payload and maximum flight time of only 15

minutes, this is offers little or no risk to national security.
Low level oblique photos and video from several angles are far more effective than ground based

imagery for displaying the characteristics of large, complex properties with several buildings and

large trees. The applicants in the past have chartered 2-seat full-sized helicopters for this purpose, 

which has proven more costly than many potential clients have been able to afford. The benefits 

of reduced cost and improved quality of presentation from the UA will be valuable to and benefit 

many buyers and sellers of real property.

Additionally, we request that we be allowed to use our system to benefit first responders nearby

who might require assistance, including fire fighters, the police, the sheriff, et al., while

remaining subject to all limitations cited in this application as we do so.

(a) No flight will be made with a Gross weight exceeding 55 pounds;

(b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an

airspeed of no more than 25 knots and no further than 3/4 NM from the PIC;

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to

communicate by voice at all times during a flight operation;

(d) Operations will be restricted to flights over private property with the permission of the

property owner;

(e) All required permits will be obtained from state and local government prior to operation;

(f) Precision Resource Management Imagery, LLC will not be operated over densely populated 

areas;

(g) Precision Resource Management Imagery, LLC will not be operating over any open-air 

assembly of people;

(h) Precision Resource Management Imagery, LLC will not be operating over heavily trafficked 

roads;

(i) Precision Resource Management Imagery, LLC will not be operating at night.

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Precision Resource Management Imagery, LLC requests an exemption from the following 

regulations as well as any additional regulations that may technically apply to the operation of 

the sUAS System:

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the

FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we

request an experimental certificate be issued for the Iris+ under either or both of the following 

provisions:
21.191 Experimental certificates. Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment,

new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and customer crew training, we would expect that an experimental 

certificate would permit our commercial purpose as well. The aircraft will not carry persons or 

property, will not carry fuel, and will only fly under strict operational requirements.

Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we

propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft 

performing the same mission. If an experimental airworthiness certificate is not appropriate for 

this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the 

requirement for airworthiness certificate in general, citing the equivalent level of safety outlined 

in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration

number in letters at least 3 inches high. Additionally, the aircraft must display the word

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or

pilot station. The sUAS does not have an entrance in which the word "EXPERIMENTAL" can

be placed, and may not have a registration number assigned to it by the FAA. We propose to

achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard

on the top of the aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual

Observer) and others in the vicinity of the aircraft while it is preparing for launch will be able to

see the designation. Additionally, we feel that the permanent placard discussed in the previous

paragraph will provide the aircraft's registration information at the ground station. Finally, we

will display at the ground station a high contrast flag or banner that contains the words

"Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will

operate within 3/4 NM of the ground station, the banner should be visible to anyone that

observes the aircraft and chooses to investigate its point of origin.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133

Commercial pilot privileges and limitations.

Precision Resource Management Imagery, LLC seeks exemption from 14 CFR § 61.113, which 

restricts private pilot certificate holders from flying aircraft for compensation or hire, and would 

also require a second class medical certificate. The purpose of Part 61 is to ensure that the skill 

and competency of any PIC matches the airspace in which the PIC will be operating, as well as 

requiring certifications if the private pilot is carrying passengers or cargo for hire. In this case, 

while the UASs will be operated as part of a commercial operation, it carries neither passengers 

nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA determined 

that the unique characteristics of UAS operation outside of controlled airspace did not warrant 

the addition cost and restrictions attendant with requiring the PIC to have a commercial pilot

certificate and class II medical certificate.
The restrictions Precision Resource Management Imagery has placed on its UAS operations meet 

or exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA-2014-

0352. Precision Resource Management Imagery, LLC will operate away from persons and 

property not involved in the operation, and flights will be conducted using VLOS at 400' AGL or 

below. A NOTAM will be issued between 48 and 72 hours before the flight is to occur, and the 

flight will be coordinated with the applicable FSDO.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation 

is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight

manual information is available to the aircrew while operating the aircraft. We request an

exemption to this requirement since the aircraft is not only too small to carry documentation, but 

the documentation would not be available to the crew during flight operations. To obtain an

equivalent level of safety and meet the intent of 91.9, we propose that a current, approved sUAS

Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or

preparing for, flight.

14 CFR 91.109 Flight Instruction; 

14 C.F.R. § 91.109(a) states "[n]o person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls." UASs and remotely piloted aircraft, by their design, do not have functional dual 

controls. Instead, flight control is accomplished through the use of a device that communicates 

with the aircraft via radio communications. Accordingly, an exemption will be required for the 

flight instruction requirements of 14 C.F.R. § 91.109(a). Given the size and speed of the UAS 

that Precision Resource Management Imagery, LLC intends to use, an equivalent level of safe 

training can still be performed without dual controls because no pilot or passengers are aboard 

the UAS and all persons will be a safe distance away in the event that the UAS experiences any 

difficulties during flight instruction. Moreover, all flight training will be conducted in controlled 

and sterile environment. As a whole, Precision Resource Management Imagery, LLC safety 

procedures ensure that the proposed UAS operations provide an equivalent or higher level of 

safety than that provided by the flight instruction regulations.

91.119 Minimum safe altitudes:

The regulation states that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the one of the missions of the

sUAS would be photography or survey of persons, vessels, vehicles or structures it would be

necessary to operate closer than 500 feet to the items listed. Operations will only be flown over

property or persons where permission has been obtained and careful pre-planned flight path has

been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an

emergency landing without undue hazard to persons or property on the surface. Therefore we

maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is

minimal compared to manned aircraft, which should be considered in granting the exemption.
CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter

setting available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL

and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An

Above Ground Level altimeter measurement above the takeoff point is transmitted via radio

from the sUAS on-board computer to the display screen held by the PIC, providing a constantly

updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-vFR

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after

that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy

reserve as a safety buffer for delays to landing. The sUAS is battery operated and the maximum

duration of flight from a single battery charge is 12 minutes with a 20% reserve. Since the

aircraft will never fly more than 3/4 NM from the point of intended landing, a full battery charge

at launch will ensure that we meet the reserve energy requirement of this paragraph. We request 

an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy."

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

The regulation provides that an airworthiness certificate, with the registration number assigned to 

the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph 

(b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew." The sUAS is too small to carry documentation, does not 

have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent 

level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for 

this aircraft by the FAA will be with the crew at the ground control station and available for 

inspection upon request. In order to identify the aircraft, we propose that the information found 

on airworthiness and registration certificates be permanently affixed to the aircraft via placard 

containing the following information plus the word "EXPERIMENTAL" to satisfy the 

requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventative Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409

require that the aircraft be "approved for return to service by a person authorized under 43.7"

after maintenance and inspection. It is our intention that the PIC perform maintenance and

inspection of the aircraft and "be authorized to approve the aircraft for return to service." The

PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition

conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC

is limited to repairing small cracks, replacing a propeller, checking electrical connections and

updating software and firmware for the on-board computer. All other maintenance will be

performed by the manufacturer or their designated repair facility. The PIC will document work

performed in accordance with 91.417. We feel that due to the size, construction, and simplicity

of the aircraft, the PIC can ensure an equivalent level of safety.
Safety and Benefits of the UAS

Precision Resource Management Imagery, LLC will be using the UAS in a variety of 

applications that generally require expensive full-size manned aircraft to complete. Small, light, 

unmanned aerial vehicles offer a myriad benefits over the use of full-sized manned aircraft for 

electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and still 

photography, just to name a few. Replacing significantly larger manned aircraft carrying crew 

and flammable fuel with small UAS carrying no passengers or crew creates a much greater 

margin of safety for the pilots and crew. By granting Precision Resource Management Imagery, 

LLC‘s requested exemptions, the FAA will help drive development of safe and successful 

commercial UAS operations and will advance the public knowledge base for such operations. 

Precision Resource Management Imagery, LLC is committed to promoting the UAS research 

efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing data from its 

commercial UAS operations and serving as a resource for future UAS research operations. Thus, 

the FAA has good cause to grant this Petition.

Conclusion

As pointed out in this application, all the SUAs which our company would use, under

authorization by the US DOT-FAA, are small, light-weight devices operated within the line of

sight of the Pilot-in-Command (PIC), less than 400 feet above the ground and outside 5 miles

from any airport, heliport, seaplane base, spaceport, or other location with aviation activities,

unless the air traffic control authorities (ATC) have been notified and have authorized each flight

within a radius of this distance.

All our SUAs have proven capability for controlled flight. They are devices offered for general

sale on the market around the world and have often been used as Model Aircraft in the USA.

We are certain that the studies conducted until now by the FAA, about Section 332, Public Law

112-95, 2014, have already provided you with the assurances on the airworthiness of SUAs such 

as ours.

For the foregoing reasons, the exemptions requested herein should be granted and Precision 

Resource Management Imagery, LLC should be permitted to conduct small UAS operations in 

accordance with its manuals and all other operating parameters deemed necessary and 

appropriate by the FAA. The submission of this application and its contents is the best 

demonstration that indeed it is possible to pursue the authorization process so that some SUAs 

may be used for legitimate commercial activities and under reasonably safe conditions.

Signed

Marc B. Allred

Owner of Precision Resource Management Imagery, LLC