July 10, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 

91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 

91.417(a)&(b) 

Dear Sir or Madam, 

AerialVid, LLC, (“AerialVid”), a Louisiana limited liability company, is writing pursuant 

to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 

C.F.R. 11, to request that AerialVid, an owner and operator of small unmanned aircraft, be

exempted from the Federal Aviation Regulations (“FARs”) listed below so that AerialVid may

operate its small ultra light weight unmanned aircraft systems (“UAS”) commercially in airspace

regulated by the Federal Aviation Administration (“FAA”).

As a threshold matter, AerialVid calls the examining officials’ attention to previous 

exemptions recently granted by the FAA, namely Exemption Nos. 11062, 11109, 11112, 11213, 

and 11594. 

As described herein AerialVid Members, are Certified Commercial Pilots in the United 

States; experienced in flying hobby helicopters for recreational purposes. Our Inventory 

includes: (1) DJI Spreading Wings S900; (2) DJI Spreading Wings S1000; and (3) an Inspire 1.1 

All of these platforms are equipped with a camera for the purpose of aerial 

videography/cinematography and are controlled from the ground by a Futaba Controller device. 

AerialVid’s primary commercial activities, upon approval of its exemptions from the FAA, will 

include the surveying of industrial construction sites, agricultural properties, and real estate 

listings. These activities will enhance the ability of clients in these industries to conduct site 

monitoring and will contribute to the economic development and commercial activity of northern 

Louisiana. 

Craig Roberson is the managing member of AerialVid and has flown small RC electric 

helicopters for over five (5) years without incident. AerialVid is committed to safety with each 

flight. 

1

See Exhibits A, B, and C for these platforms’ manuals. 
AeriaVid LLC., West Monroe, LA - Section 333 Exemption Petition

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This exemption request will permit AerialVid to operate lightweight, unmanned and 

comparatively inexpensive UAS’s in tightly controlled and limited airspace. The airspace in 

which AerialVid will operate is sufficiently distant from the general public, airports, heliports 

and vehicular traffic, such that its flights will neither disrupt commercial activity nor endanger 

the general public. Further, AerialVid is committed to respecting existing property boundaries, 

the rights of private property owners, and the privacy of the general public during the course of 

performing its own commercial operations of taking aerial photographs and videos. Thus, 

AerialVid will obtain all necessary permissions for overflights of private property. Currently, 

similar lightweight, remote-controlled UAS's are legally operated by unmonitored amateur 

hobbyists with no safety plan or controls in place to prevent catastrophe. AerialVid has 

developed and adopted a Standard Operating Procedure (“SOP”)2 to avoid and prevent public 

any hazards to the public interest by its devices. Further, AerialVid records flight data and other 

information gained through permitted flight operations and will share its records with the FAA 

pursuant to any FAA-required reports. 

The granting of AerialVid’s request comports with the Federal Aviation Administration’s 

(“FAA”) responsibilities and authority to integrate UAS's into the national airspace system, and 

to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the 

national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's 

for tracking industrial construction sites, real estate listings, and surveying farm land. Further, 

AerialVid will conduct its operations in compliance with the protocols described herein or as 

otherwise established by the FAA. 

For the reasons stated below, AerialVid respectfully requests this exemption for the 

purpose of permitting it to operate ultra lightweight, remote-controlled UAS’s for the purpose of 

aerial videography/cinematography to track industrial construction sites, promote real estate 

listings, and survey farm land. Most of AerialVid’s clients in those arenas cannot afford to hire 

manned aircraft for those purposes. Thus, AerialVid’s commercial operations will fill a gap in 

northern Louisiana’s economy and help foster regional economic development. Finally, 

AerialVid’s operations will promote public safety by keeping heavier manned aircraft, which 

contain combustible fuel, from being employed in situations where UAS’s are better, namely the 

operation of photography and video equipment at low altitudes. 

I. Contact Information

AerialVid, LLC. 

Craig Roberson, Manager 

123 Orleans Place 

2

See Exhibit D. 
AeriaVid LLC., West Monroe, LA - Section 333 Exemption Petition

3 

West Monroe, Louisiana 

71291 

Phone: (318) 599-9876 

Email: Craig@AerialVid.com 

II. Sections of Title 14 of the Code of Federal Regulations from which AerialVid

requests exemptions

14 C.F.R. § 21.1 (airworthiness certificates); 

14 C.F.R. § 45.23(b) (display of markings); 

14 C.F.R. § 61.113 (a) & (b) (limitations as to private pilots); 

14 C.F.R. 91, et seq (general operating and flight rules); 

14 C.F.R. § 91.407(a)(1) (operation after maintenance); 

14 C.F.R. § 91.409(a)(2) (inspections); and 

14 C.F.R. § 91.417 (a) & (b) (maintenance records). 

III. The extent of relief AerialVid seeks and the reason such relief is sought.

AerialVid submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 

331-334, seeking relief from any currently applicable FAA regulations operating to prevent

AerialVid’s contemplated flight operations within the national airspace system. Section 332 of

the Reform Act provides for the integration of civil unmanned aircraft systems into the national

airspace system. AerialVid’s, UAS’s meet the definition of “small unmanned aircraft” as

defined in Section 331 and are thus expressly contemplated by the Reform Act. AerialVid

desires to operate its UAS’s prior to the time period by which the Reform Act requires the FAA

to promulgate rules governing such craft. The Reform Act guides the Secretary in determining

the types of UAS's that may operate safely in our national airspace system. Considerations

include the: weight, size, speed and overall capabilities of the UAS; whether the UAS will be

operated near airports or heavily populated areas; and if the UAS will be operated by line of

sight. See 112 P.L. 95 § 333. Each of these items weight in favor of an exemption for

AerialVid. AerialVid’s fleet of UAS’s utilize four (4), six (6), and eight (8) counter-rotating

propellers for balance, control and stability, respectively. Each UAS is equipped with GPS and

auto return safety technology. All of AerialVid’s systems weigh less than twenty (20) pounds

(below the maximum fifty-five pound limitation), which includes the camera with gimbal.

AerialVid considers safety as its foremost concern with each flight. Its UAS’s are 

designed to hover in place via GPS and operate in winds of less than 13 knots (15 miles per 

hour). Per its SOP, AerialVid will not conduct UAS operations when winds exceed 13 knots (15 

mph). Built-in safety systems include a GPS mode that allows the UAS’s to hover in place when 

radio controls are released. With three operating modes to choose from, AerialVid utilizes the 
AeriaVid LLC., West Monroe, LA - Section 333 Exemption Petition

4 

Safe Mode for aerial videography/photography. This is the safest, most reliable and stable mode 

to prevent accidents and hazards to the public. When pilot communication is lost the UAS’s are 

designed to slowly descend to their point of takeoff. AerialVid will not conduct UAS operations 

near airports, hospitals or police heliports. Further, AerialVid’s operations will not take place in 

areas where the general public is within fifty to one hundred yards depending on location, 

conditions and weather. AerialVid will be constantly on the lookout for any manned aircraft and 

will be prepared to immediately land and/or abort to the nearest and safest ground point should a 

manned aircraft approach our location or we suspect manned aircraft may approach near our 

location. Its UAS fleet is capable of vertical and horizontal operations, and is flown only within 

line of sight of the remote control pilot. Utilizing battery power rather than combustible fuels, 

flights generally last between ten to fifteen minutes, with an altitude not to exceed three hundred 

(300) feet. AerialVid’s operators will utilize a fully charged battery with each flight as a safety

precaution. The full flight time limit for each battery is ten (10) to fifteen (15) minutes as tested.

Its UAS’s will not operate below manufacturer recommend minimum charge levels for

operation; thus, they will remain within a safe operating range to ensure adequate

communication between radio control and UAS to eliminate the potential for crash, loss of

control, or other hazard. Reserve batteries are on hand with each flight to ensure replacement for

sufficient safe level of operation. AerialVid will mitigate any risks that may cause a crash, create

a hazard to the public, property, manned aircraft, or loss of its own investment in equipment. We

have clocked numerous practice flights in remote areas as a hobbyist simulating flights for future

commercial use to gain familiarization with the characteristics of the specific UAS's performance

under different temperature and weather conditions. AerialVid has also developed a training

course manual and outline for its operators.

AerialVid is extremely cautious when operating its UAS’s and will not “create a hazard 

to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). The small size and 

weight of the UAS’s ensure that they fall well within Congress’s contemplated safety zone when 

it promulgated the Reform Act and the corresponding directive to integrate UAS's into the 

national airspace system. AerialVid’s devices, which have been used in hobby flight, have a 

demonstrable safety record and do not pose a threat to the general public or national security. 

IV. AerialVid’s request will benefit the general public.

Aerial videography for geographical awareness and for real estate marketing has long 

been available through manned fixed-wing aircraft and helicopters. The expense of such aerial 

videography is cost prohibitive for many small businesses and farmers. Further, the unnecessary 

use of manned aircraft poses a threat to the public through potential crashes where combustible 

fuel may explode and burn on impact. AerialVid’s devices pose no such threat since their small 

size and lack of combustible fuel alleviates any potential public threat. 
AeriaVid LLC., West Monroe, LA - Section 333 Exemption Petition

 

 

5 

Congress has proclaimed that it is in the public’s interest to integrate commercially flown 

UAS's into the national airspace system through its passage of the Reform Act. Granting this 

exemption request benefits the public interest by furthering awareness of the geographical 

features in and around the area of operation. AerialVid’s ultra lightweight UAS is battery 

powered and creates no emissions that can harm the environment. 

 

Granting AerialVid an exemption pursuant to Section 333 will further the public’s

interest by minimizing ecological and crash threat by permitting aerial video/photo capture 

through our battery operated, ultra light weight UAS's. Granting this exemption request 

substantially furthers the economic impact for our community and small companies looking to 

grow their business, both of which will further local economic development. 

 

V. AerialVid’s exemption will not adversely affect public safety.

 

For the reasons stated above, permitting AerialVid to operate in FAA-controlled airspace will 

allow it to cooperate with local government officials and the business community as they 

collaborate on the development and implementation of safety regulations for UAS’s. 

Below is a summary of AerialVid’s operational and physical safety features: 

 

● All of its UAS’s weighs less than 15 pounds complete with gimbal and high resolution 

Camera; 

● AerialVid will only operate its UAS’s below 300 feet (which is within the 400 foot 

ceiling set by the FAA Modernization and Reform Act of 2012); 

● The UAS’s operate for only 10 to 15 minutes per flight; 

● AerialVid lands its devices prior to any manufacturer recommended minimum level of 

operational battery power; 

● AerialVid pilots its devices through remote control and only by line of sight; 

● AerialVid utilizes GPS, which permits the flight safety feature whereby its devices will 

hover and then slowly land at the original takeoff site if communications are lost between 

the device and its operator; 

● AerialVid will record and analyze flight data to constantly update and enhance safety 

protocols; 

● AerialVid only operates in reasonably safe environments and in favorable weather 

conditions and takes care to avoid power lines, elevated lights, airports and actively 

populated areas; 

● AerialVid conducts extensive pre-flight safety inspections; 

● AerialVid will obtain all necessary permissions prior to operation; and, 

● The SOP addresses contains guidance on procedures to abort flights in the event of safety 

breaches or potential danger. 
AeriaVid LLC., West Monroe, LA - Section 333 Exemption Petition

6 

● AerialVid has an active commercial general liability policy and will maintain such policy

throughout its operational existence.3

AerialVid’s, safety protocols, as contained within our SOP, provide a level of safety equal to 

or exceeding existing rules. It is important to note that absent the integration of commercial 

UAS’s into our national airspace system, helicopters are the primary means of aerial video and 

photography for industrial construction, real estate and farm surveying. UAS’s are able to do 

much of that work in a safer manner because of their battery-powered operations. 

● First, the potential loss of life is diminished because UAS's carry no people on board and

we only operate our UAS in specific areas away from mass populations.

● Second, UAS’s are battery-powered and do not carry combustible fuel; thus the potential

for fire or explosions is greatly diminished.

● Third, the small size and extreme maneuverability of our UAS allows us to remotely pilot

away from and avoid hazards quickly and safely.

VI. A Summary that the FAA may publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates and Manuals

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The 

size, weight and enclosed operational area of AerialVid’s UAS’s permits exemption from 

Part 21 because its devices meet and exceed an equivalent level of safety pursuant to Section 

333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both 49 U.S.C. § 44701(f) and Section 333 of the Reform Act. 

Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability and proximity to 

areas such as airports and dense populations. AerialVid’s current and projected UAS's meet 

or exceed each of the elements. 

14 C.F.R. 91.7(a) 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 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no 

onboard pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. 

3

See Exhibit E. 
AeriaVid LLC., West Monroe, LA - Section 333 Exemption Petition

7 

An equivalent level of safety will be achieved by maintaining a safety/flight manual 

delineating areas of where safety can be defined. The FAA has previously issued exemptions 

to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as our UAS utilizes 

electronic global positioning systems with a barometric sensor. 

14 C.F.R. § 91.203 (a) and (b) require the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent 

level of safety will be achieved by maintaining any such required certifications and 

registrations by AerialVid. 

B. 14 C.F.R. § 45.23: Marking of The Aircraft.

Current regulations require that aircraft be marked according to certain specifications. 

AerialVid’s UAS’s are, by definition, unmanned. Thus, they do not have a cabin, cockpit or 

pilot station on which to mark certain words or phrases. Further, two-inch lettering is 

difficult to place on such small aircraft. Accordingly, AerialVid will mark its UAS in the 

largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required 

by 14 C.F.R. §45.29 (f) so that viewing the UAV will see the markings. The FAA has 

previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 

10167A and 10700. 

C. 14 C.F.R. § 61.133: Commercial Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. § 61.133(a), commercial pilots are not limited to commercial 

operations. AerialVid can achieve an equivalent level of safety as achieved by current 

regulations because its UAS’s do not carry any pilots or passengers. Further, while helpful, 

our operators are required to hold this certification to pilot UAS’s. The risks related to the 

operation of AerialVid’s UAS’s are far less than the risk levels inherent in the commercial 

activities outlined in 14 C.F.R. § 61, et seq. AerialVid operational capabilities currently meet 

or exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). 

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

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. AerialVid will never 

operate at an altitude greater than 300 feet above ground level (“AGL”), which is safely 

below the standard of 400 feet AGL. AerialVid will operate in safe areas away from public 
AeriaVid LLC., West Monroe, LA - Section 333 Exemption Petition

8 

and traffic, providing a level of safety at least equivalent to or greater than those in relation to 

minimum safe altitudes. Given the size, weight, maneuverability, and speed of its devices, 

an equivalent or higher level of safety will be achieved. 

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

The above-cited Regulations require, among other things, aircraft owners and operators to 

“have [the] 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 . . .” 

These Regulations only apply to aircraft with an airworthiness certificate. Thus, they do not 

apply to AerialVid’s, UAS’s. However, as a safety precaution AerialVid will inspect its UAS’s 

before and after each flight and maintain a detailed maintenance log. 

A Summary The FAA May Publish in the Federal Register: 

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and 

enclosed operational area of our UAS permits exemption from Part 21 because AerialVid’s 

UAS’s meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA 

is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act 

(49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the 

FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the 

weight, size, speed, maneuverability and proximity of operations to airports and densely 

populated areas. AerialVid’s devices meet or exceed each of those elements. 14 C.F.R. 91.7(a) 

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 

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or

passengers, and given the size of the UAS's, this Regulation is also inapplicable. An equivalent

level of safety will be achieved by maintaining applicable manuals and standard operating

procedures with the operators of the devices. Finally, AerialVid will implement a maintenance

program that involves regular software updates and curative measures for any damaged

hardware. Therefore, AerialVid will achieve an equivalent or greater level of safety to the FAA’s

current requirements. The FAA has previously issued exemptions to this regulation in

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, and 10167.

In summary, AerialVid seeks an exemption from the following regulations:
AeriaVid LLC., West Monroe, LA - Section 333 Exemption Petition

9 

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 

14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 

C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a);

14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R.

§§ 91.417 (a) & (b) to operate AerialVid's, small unmanned aerial systems for the commercial

purposes of construction, real estate, and farm surveying. Currently, site tracking and aerial

videography/photography relies primarily on the use of larger aircraft running on combustible

fuel, which poses a potential risk to the public. Granting AerialVid’s request for exemption will

reduce current risk levels and thereby enhance public safety. AerialVid’s devices do not contain

combustible fuel, are smaller, lighter and more maneuverable than manned aircraft and will

require less flight time to perform the same commercial surveying operations as manned aircraft.

Further, AerialVid’s devices operate at lower altitudes and in controlled airspace eliminating

potential public risk inherent in takeoffs and landings from established airfields. AerialVid has

been informally analyzing flight information and will compile safety protocols and the

implementation of a flight operations manual for construction, real estate and farm surveying

usage that exceeds currently accepted means and methods for safe flight. Formal collection of

information shared with the FAA will enhance the FAA's internal efforts to establish protocols

for complying with the FAA Modernization and Reform Act of 2012. There are no personnel

onboard AerialVid’s UAS’s and therefore the likelihood of death or serious bodily injury is

significantly diminished. AerialVid’s, operation of devices weighing less than 20 pounds and

travelling at low speeds within limited areas will provide an equivalent level of safety as current

FARs require. Accordingly, AerialVid respectfully requests that the FAA grant its request for

exemption and is willing to cooperate in sharing information to benefit the FAA, safety of

manned aircraft, and the general public at large.

Respectfully submitted, 

__________________________________ 

Craig Roberson 

AerialVid, LLC 

123 Orleans Place 

West Monroe, Louisiana 

71291