Aerial Images LLC. 

Kevin Wilt

531 Beach ave.

Cambridge Springs, PA. 16403

October 5, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave.

Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 

91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 

91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 

91.417(a) and (b); FAA Policy 8900,227 Paragraph 16(c)(4) and Paragraph 16(e)(1).

Dear Sir or Madam :

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 

CFR Part 11, Aerial Images LLC. / Kevin Wilt, operator of an Unmanned Aircraft System (UASL

hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow 

commercial operation of its UAS, 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.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, 

would operate in the following manner:

1. Aerial video/photography or providing live video feed to assist with search and rescue operations in

cases of an emergency or natural disaster only when the local authorities or government has

requested it by contract or donation.

2. Aerial photography and/or video for public and/or private use including real estate, architecture,

land surveying, engineering and other related professional activities.

3. Aerial video and/or photography for public and/or private use including television, public events,

cinematography and news gathering.

4. Aerial inspection/photography of residential/commercial utility infrastructure including but not

limited to electrical power lines, wind turbines and cell towers.

As described fully below, the requested exemption would permit the operation of a UAS under 

controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will 

provide safety

enhancements to the already safe operations in the industry presently using conventional aircraft. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's 

(the FAA Administrator's) responsibilities to " .... establish requirements for the safe operation of such 

aircraft systems in the national airspace system."
The name and address of the applicant is:

Aerial Images LLC.

Kevin Wilt

531 Beach ave. 

Cambridge Springs, PA. 16403

Phone: 814-282-8345

Email: Kevinwilt@gmail.com

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

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 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

FAA Policy 8900,227 Paragraph 16(c)(4) and Paragraph 16(e)(1) 

Aerial Images LLC. will operate a DJI Inspire 1 Model T600 with a weight of 2935g or

6.471bs. The dimensions are 17.24 inches x 17.75 inches x 11.85 inches. Under still air the maximum 

speed is no more than 49mph with a cruising speed of 25mph. The DJI Inspire 1 has the ability to hover 

and move along a vertical and horizontal plane simultaneously. The DJI Inspire 1 has four motors, and is 

powered by a 6-cell Lithium Polymer battery. There are four propellers in use. The DJI Inspire 1 will be 

controlled with the C1 remote controller with an operating frequency of 2.400GHz- 2.483GHz. The live 

video feed will have an operating frequency of 5.728GHz- 5,850GHz. The applicant will operate the UAS 

in line of sight within a closed off and predetermined area owned and/ or operated by the property 

representative.

Given the small size of the UAS and the controlled environment provided the proposed operations will 

adhere to the Reform Act's safety requirements. The approval of this application presents no national 

security issues. Regarding the level of safety surrounding the proposed operations and the public 

benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, 

the grant of the requested exemption is in the public interest. Accordingly the applicant requests that 

the FAA grant the requested exemption with minimum delay.
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because operations will 

further enhance the safety of the persons and/or property using conventional aircraft.

These limitations and conditions to which the applicant agrees to adhere to when conducting 

commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual 

(FOM) include:

1. The UAS will weigh less than 55 lbs.

2. The UAS will have a maximum operating speed of no more than 50mph.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO).

4. Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25%

battery power reserve or 30 minutes of flight time whichever occurs first.

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not

more than 200 feet above an elevated platform from which filming is planned.

6. Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer {VO) and may

include but not limited to a Camera Operator.

7. The UAS pilot will be a designated Pilot in Command (PIC) will hold a Commercial Pilot's License

along with a Second or higher Class Medical Certificate. If the PIC feels another operator to be

qualified with the necessary skills to be PIC & possess a Second or higher Class Medical Certificate, that 

person may be designated PIC provided they have a minimum of 20 hours of flight time with the UAS.

8. A briefing will be performed regarding the planned UAS operations prior to each day's flight

consisting of all the days' production activities.

9. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

10. The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point

(ARP) of a tower controlled or uncontrolled airport or under the guidance of the local FAA.

11. If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) of

a tower controlled or uncontrolled airport the respective airports will be contacted advising them of

the estimated flight time, flight duration, elevation of flight and other pertinent information.

12. The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the requested

exemption, with the appropriate local Flight Standards District Office (FSDO) no more than 72 hours

but no less than 48 hours from planned operation.

13. The operator will obtain verbal/written consent of all persons involved with the planned operation

and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and

the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as

required under the FOM. With the advanced permission of the FSDO, operations at closer range may

be approved.

14. The PIC and VO will have been trained in operation of UAS and receive up-to-date information for

the particular UAS to be operated.

15. The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

16. Written and/or verbal permission and permits will be obtained from territorial, state, county or city

jurisdictions, including law enforcement, fire or other appropriate governmental agencies.

17. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have

the capability to return to a pre-determined location within a designated location and land

autonomously.

18. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or

emergencies.
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, 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 the Applicant, 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 U.S.C.§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 (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated 

hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive 

materials or flammable liquid fuels, and operates exclusively within a secured and designated area. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by 

both the operator and under the requirements and in compliance with local public safety requirements. 

The FAA will have advance notice of all operations. These safety enhancements provide a greater degree 

of safety to the public and property owners than conventional operations conducted with airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria

demonstrates that there is no credible threat to national security posed by the UAS, due to its size, 

speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and 

inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "lightsport," "experimental," or "provisional," as applicable. 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, two-inch lettering 

will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by

§45.29 (f) where the pilot, observer and others working with the UAS will see the identification of the 

UAS as "Experimental."

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a) & {b), no person who holds a private pilot certificate may act as a pilot in

command of an aircraft that is carrying passengers or property for compensation or hire Aerial Images 

LLC. / Kevin Wilt may achieve an equivalent level of safety as achieved by current Regulations because 

the applicant's UAS do not carry any pilots or passengers nor property. The risks attendant to the

operation of UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR 

61. The PIC of the UAS will have Commercial Pilot's License along with a current Second Class or higher 

Medical exceeding the current safety levels in relation to 14 CFR 61.113 (a) & (b). I feel the operation 

and limitations set forth in the FOM will equate to the safe operation of the UAS.
14 C.F.R. §91.7 (a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

here will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of safety check lists prior to each flight an equivalent level of safety will be 

provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) provides: No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. 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 flight manual at the ground control point 

where the pilot flying the UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety 

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption 

will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures 

including but not limited to reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption 

is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption 

may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 

400 AGL with the exception that in circumstances where the UAS is used to survey or photograph a 

structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above 

the highest point on the structure. It will however be operated in a restricted area with security 

perimeter, where buildings and people will not be exposed to operations without their pre-obtained 

consent. The equivalent level of safety will be achieved given the size, weight, 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 or local officials. Because of the advance notice to the property owner and participants in the 

filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight 

operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and 

the lack of flammable fuel, any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude 

operations of the UAS will ensure separation between these UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119.
14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating an 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 operator, 

pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch 

site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed-

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes."

The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 

minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 

minutes in length. Given the limitations on the UAS's proposed flight area and the location of its 

proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight 

VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within 

the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and 

property owners or official representatives who have signed waivers will be allowed, with less than 30 

minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the small UAS. Additionally, limiting UAS flights to 10 minutes 

would greatly reduce the utility for which the exemption will be granted. Applicant believes that an 

equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery powerwhichever happens first. This restriction would be more than adequate to return the UAS to its planned 

landing zone from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the 

following:

(1) An appropriate and current airworthiness certificate ....

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, 

there is no ability or place to carry certification and registration documents or to display them on the 

UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the UAS will have immediate access to them, to the extent they are 

applicable to the UAS.
14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ... ," 

and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to 

the flight manual and operating handbook. An equivalent level of safety will be achieved because the 

UAS is very limited in size and will carry a small payload and operate only in restricted areas for a limited 

period of time. If mechanical issues arise the UAS can land immediately and will be operating from no 

higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating 

flight and perform required maintenance. Moreover, the operator is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level 

of safety. An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the 

operator will ensure that the UAS is in working order prior to initiating flight and perform required 

maintenance needed.

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1): Observer Medical.

This policy provides that both the PIC and VO must have a valid FAA second-class medical

certificate issued under part 67 in order to perform as a pilot or observer. The UA maximum

gross weight is 6,5 pounds, it is constructed of carbon fiber and plastic and the PIC is not on

board. Both the PIC and the VO are required to be in VLOS. Given the unlikely event that both

the PIC and VO become medically incapacitated while the aircraft is in flight, the UA will return

autonomously to the site of launching and land without crew intervention. Therefore, requiring the PIC 

and VO to meet the same medical requirements as a commercial pilot carrying passengers in a large 

aircraft is an unnecessary burden. We propose that the minimum medical requirements for the VO be 

vision corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will 

ensure that the VO can see and avoid air traffic; a licensed driver is medically qualified to operate a

much larger vehicle.

Sincerely,

Kevin Wilt

Aerial Images LLC.