SRQ360INC Robert Dennison 115 S Houle Ave Sarasota FL 34232 

78248 FAA Rulemaking Section 333 Of the FAA Reform Act and Part 11 July 13. 2015 U.S. 

Department of Transportation Docket Management System 1200 New Jersey Ave, SE 

Washington, DC 20590 

Attention: FAA Administrator Re: Exemption Request Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations form 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 

CFR91.119; 14 CFR91.121; 14 CFR91.151 (a); 14 CFR91.203 (a) & (b); 14 CFR 91.215 (a) & 

(b); 14 CFR 91.131 (d); 14 CFR 91.405 (a); 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); 14 CFR 

417 (a) & (b) Dear Administrator, Pursuant to the Section 333 of the FAA Modernization and 

Reform Act of 2012 (The Reform Act) and 14 CFR Part 11, Terry Camnitz (LAI.)is the operator 

of Small Unmanned Aircraft Systems (sUAS) equipped to conduct aerial photography and 

cinematography services hereby applies for an exemption from the listed Federal Aviation 

Regulations (FARs) to allow commercial operations of its sUAS 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 in more detail below, the requested exemption would 

permit the operation of small, unmanned and relatively inexpensive sUAS under controlled 

conditions in the NAS that is both limited and predetermined. 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 operations of such aircraft system sin the 

national airspace system. ”Section 333 (c) of the Reform Act. Regulations from which the 

exemption is requested:

14 CFR Part21 14 CFR45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR91.7 (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 91.215 (a) & (b) 14 CFR 91.131(d) 14 CFR 91 405(a) 14 CFR 407 

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

This exemption application is expressly submitted to fulfill Congress’ goal in passing

Section333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (NAS) before completion of the rulemaking required under Section 332 of the Reform 

Act. In making this determination, the Secretary isr equired to determine which types of sUASs 

do not create a hazard to users of the NAS or the public or pose a threat to national security in 

light of the following: • The sUAS’s size, weight, speed, and operational capability; • Operation 

of the sUAS in close proximity to airports and populated areas • Operation of the sUAS within 

visual line of sight (VLOS) of the Pilot/”Operator” Reform Act § 333 (a). Lastly, if the Secretary 

determines that such vehicles “may operate safely in the national airspace system, the Secretary 

shall establish requirements for the safe operation of such aircraft international airspace system.” 

Id.§333(c). The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority by its terms includes exempting civil aircraft, as the terms 

defined under §40101 of the Act, that includes UASs, from the requirement that all civil aircraft 

must have a current airworthiness certificate. The Administrator may grant an exemption from 

the 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 U.S.C §44701(f) See also 49 USC §44744(a); 49 USC §44704l 14 CFR §91.203 (a) (1). Low 

Altitude Imaging Inc. UASs are rotorcraft weighting 55 or fewer lbs. including payload. They 

operate under normal conditions at a speed of no more that 50 kts and have the capability to 

hover, and move in the vertical and horizontal plan simultaneously. They will operate only in 

line of sight of the Pilot/”Operator” and will operate with the permission of the property owner 

or a representative. Such operations will insure that the sUAS will “not create a hazard to users 

of the national airspace system or the public” as per the Reform Act Section 333 (b). Applicant 

submits the attached (LAI), Safety Policy and (LAI). Operations Checklist as confidential 

documents under 14 CFR 11.35 (b) as these documents contain proprietary information that the 

applicant has not and will not share with others. The safety policy contains operating conditions 

and procedures that are not available to the public and are protected from release under the 

Freedom of Information Act 5 USC552 et. seq. Given the small size of the sUASs involved and 

the limited environment within which that will operate, the applicant falls squarely within that 

zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, 

by exemption, allow commercial operations of sUASs to commence immediately. Also due to 

the size of the sUASs and the limited areas in which the relevant sUASs will operate, approval of 

the application presents no national security issue. Given the clear direction in Section 333 of the 

Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations, and the significant public benefit, 

including enhanced safety with allowing sUASs for commercial aerial videography and 

photography operations, the grant of the requested exemptions is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption 

without delay. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes

that the exemption requested herein apply to civil aircraft that have the characteristics and they 

operate with the limitations listed herein. These limitations provide for at least and equivalent or 

even higher level ofsafety of operations under the current regulatory structure because the 

proposed operations are conducted on closed off property under the permission of the property 

owner or property representative. These limitations and conditions to which (LAI) agree sto be 

bound when conducting commercial operations under an FAA issued exemption include: 1. The 

sUAS will weigh less than 55 lbs. 2. Flights will be operated within visual line of sight (VLOS) 

of a Pilot/”Operator” and/or observer. 3. Maximum total flight time for each operational flight

will be 30minutes.Flightswill be terminated at 20% battery power reserve should that occur prior 

to the 30 minute limit. 4. Flights will be operated at an altitude of no more than 500 feet AGL or, 

when photographing a structure taller than 500 feet, the sUAS will not be operated more than 

100’ above the highest point on the structure. 5. Minimum crew for each operation will consist of 

the sUAS Pilot/”Operator”, and the Visual Observer. 6. sUAS Pilot/”Operator” will be Pilot in 

Command (PIC). If the Pilot/”Operator” deems another “Pilot/”Operator” “ to be qualified with 

the necessary skills to be the “Pilot/”Operator”, that person can also be designated as 

“Pilot/”Operator” “ provided they have a minimum of 40 hours of flight time with the sUAS. 7. 

Flights will be operated at a lateral distance of at lest 50 feet from any inhabited structures, 

buildings, vehicles, vessels, or people not associated with the operation. 8. A briefing will be 

conducted in regard to the planned sUAS operations prior to each flight activity. It will be 

mandatory that all personnel involved with the operational duties of the flight be present for this 

briefing. 9. Pilot/”Operator” and observer will have been trained in operation of sUAS generally 

and received up--to--date information on the particulars UAS to be operated. 10. The 
“Pilot/”Operator” “ will have at least a class 3 medical certificate. 11. Observer and 

Pilot/”Operator” will at all times be able to communicate by voice, radio, and/or text. 12. Written 

and/or oral permission from the relevant property holders or property representatives will be 

obtained. 13. If the sUAS loses communications or loses its GPS signal, the sUAS will have the 

capability to return to a pre--determined location and land autonomously. 14. The sUAS will 

have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies. 14 

CFR §91.109: Flight Instruction No 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. sUAS and remotely piloted aircraft, by their design do not have fully functional dual. 

Flight control is accomplished through the use of a control box that communicates with the 

aircraft via radio communication. The FAA has approved exemptions for flight training without 

full functional dual controls for a number of aircraft and for flight instruction in experimental 

aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety is provided by the 

fact the neither a pilot nor passengers will be carried in the aircraft and by the size and speed of 

the aircraft. 14CFR§91.119:MinimumSafe Altitudes Section 91.119 established safe altitudes for

operation of civil aircraft. Section 91.119 (d) allows that helicopter may be operated at less than 

the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating 

the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the 

FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority 

to operate at altitudes up to 500 feet AGL, an exemption may be needed to allow such 

operations. As set forth herein, the sUAS will never operate higher that 500 AGL with the 

exception that in circumstances where the sUAS is used to survey or photograph a structure 

whose height exceeds 500 feet AGL, the sUAS will not be operated more than 100 feet above the 

highest point on the structure. The equivalent level of safety will be achieved given the size, 

weight, speed of the sUAS as well as the location where it is operated. No flight will be taken 

without the permission of the property owner. Because of the advance notice to the property 

owner and other participants in the activity, all affected individuals will be aware of the planned 

flight operations. Compared to flight operations with aircraft or rotorcraft weighing far more than 

the maximum 55 lbs. 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 feet AGL. In addition, the low--altitude operations of the sUAS will ensure 

separation between the sUAS operations and the operations of conventional aircraft that must 

comply with Section 91.119. 14 CFR §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 sUAS may not have a barometric altimeter, but instead a GPS altitude 

readout, and exemption may be needed. An equivalent level of safety will be achieved by the 

Pilot/”Operator”, pursuant to the safety checklist and live flight data monitoring, 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 Sections 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 sUAS provides

less than 30minutes of powered flight. To meet the 30minute reserve requirement in 

14CFR§91.151,sUASflightswould be limited to approximately 10minutesin length. Given the 
limitations of the sUAS’s proposed flight area and the location of its proposed operations within 

a predetermined area, a longer timeframe for flight in daylight or twilight CFR conditions is

reasonable. Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope 

of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate 

without compliance with FAR 91.151 (a)). Operating the sUAS, in a limited area where only 

people and property owners or representative with less than 30 minutes of reserve fuel, does not 

engender the type of risk that Section 

91.151(a)wasintendedtoalleviategiventhesizeandspeedofthesUAS.Additionally,limitingthesUAS 

flight 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 

30minutes or 20% of battery power – whichever happens first. This restriction would be more 

than adequate to return the sUAS to its planned landing zone from anywhere in its limited 

operating area. Similar exemptions have been granted to other operations, including Exemptions 

2689F, 5745, 10673, and 10808. 14 CFR §91.203 (a) and (b): Carrying Civil Aircraft 

Certification and Registration The regulation provides in the pertinent part: (a) Except a 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 sUAS fully loaded weighs less that 55 lbs. and is operated 

without an onboard pilot. As such, there is no ability to place to carry certification and 

registration documents or to display them on the sUAS. An equivalent level of safety will be 

achieved by keeping these documents at the ground control point where the Pilot/”Operator” 

flying the sUAS will have immediate access to the documents to the extent they are applicable to 

the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample 

of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797 9797A, and 10700. 

14CFR§91.215 (a) and (b); 14CFR§91.131 (d);ATC transponder and altitude reporting 

equipment and use The pertinent section of 91.215 (a) & (b) requires the “(a) All airspace: U.S.--

registered civil aircraft. For operations not conducted under part 121 or 135 of this chapter, ATC 

transponder equipment installed. . . (b) All airspace. Unless otherwise authorized or directed by 

ATC, no person may operate an aircraft in the airspace described in paragraphs (b)(1) through 

(b)(5) of this section, unless that aircraft is equipped with an operable coded radar beacon 

transponder”. . . This requirement applies (1) All aircraft. In Class A, Class B, and Class C 

airspace areas; (2) All aircraft. In all airspace within 30 nautical miles of an airport listed in 

appendix D, section 1 of this part from the surface upward to 10,000 feet MSL; Likewise, the 

pertinent section of 91.131 (d); Operating Rule in Class B Airspace (d) other equipment

requirements. “No person may operate an aircraft in a Class B airspace area unless the aircraft is 

equipped with (1) The applicable operating transponder and automatic altitude reporting 

equipment specified in §91.215 (a) . . . and (2) After January 1, 2020 , the applicable Automatic 

Dependent Surveillance--Broadcast Out equipment specified in §91.225.” Because of the small 

size and limited lifting capacity of the sUAS, the sUAS cannot be fitted with and operate a 

transponder and automatic altitude reporting equipment specified in paragraph of 91.215 (a) and 

(b) and 91.131 (d). An exemption from these requirements is requested. The equivalent level of 

safety can be assured using the procedures defined for each class of airspace. Within the surface 

areas of Class “B” ,Class “C”, Class “D” airspace Within the lateral boundaries of the airspace, 

the Pilot/”Operator” “ will establish 2 way communications with the ATC facility having 
jurisdiction for that area. The Pilot/”Operator” will provide the location (heading and distance) 

relative to the center of the airspace and request clearance to “Maneuver” above that location at 

or below 400 feet AGL. The Pilot/”Operator” will be responsible for “see and avoid” traffic 

conflicts. The Pilot/”Operator” will at all times yield right of way to ANY and ALL manned 

flight operations. All operations within 2 miles of the primary airport will be pre--arranged with 

that controlling facility. Any and all restrictions placed on the operations will be complied with 

so that all manned operations can be conducted without negatively impacting flight safety. 

14CFR§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 oft his 

chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given 

that these sections 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 

Pilot/”Operator” pursuant to the flight manual and operating and handbook. An equivalent level 

of safety will be achieved because these small sUASs are very limited in size and will carry 

small payload and operate only in limited areas for short periods of time. If mechanical issues 

arise the sUAS and land immediately and will be operating from no higher than 500 feet AGL. 

The Pilot/”Operator” will ensure that the sUAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance performed. Moreover, the 

Pilot/”Operator” is the person most familiar with the aircraft and is 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 and accordance 

with the sUAS manufacturer’s manual, as referenced in the Aircraft Operations Manual. As 

provided in the Operations Manual, the Pilot/”Operator” will ensure that the sUAS is in working

order prior to initiating flight and perform required maintenance needed. Additional Views and 

Information Of the applicant, David Simmons has been involved in building and piloting of radio 

controlled vehicles for over 10 years without incident. Summary Pursuant to 14 CFR Part 11, the 

following summary is provided for publication in the Federal Register, should it be determined 

that publication is needed: Applicant seeks an exemption from the following rules: 14 CFR Part 

21, subpart H; 14 CFR 45.23(b); 14 CFR61.113 (a) & (b); 14CFR91.7 (a); 14CFR91.9 (b)(2); 

14CFR91.103; 14CFR91.109; 14CFR 91.119; 14 CFR 91.121; 14 CFR 91.151 (a); 14 CFR 

91.203 (a) & (b); 14 CFR 91.215 (a) & (b); 14 CFR 91.131 (d); 14 CFR 91.405 (a); 14 CFR 407 

(a) (1); 14 CFR 409 (a) (2); 14 CFR 417 (a) & (b) to commercially operate a small unmanned 

vehicle (55 lbs. or less) equipped to conduct aerial photography and cinematography services. 

Approval of exemptions allowing commercial operations of sUAs to conduct aerial photography 

and cinematography services will enhance safety by reducing risk. Conventional photography 

operations, using jet or piston powered aircraft, at extremely low altitudes, often very close to the 

subject being filmed and in close proximity to people and structures; and present the risks 

associated with vehicles that exceed 3,000 lbs., carrying large amounts of jet A or other fuel. In 

contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of 

the risk given the reduced mass and lack of combustible fuel carried onboard. The sUAS is 

carried to the location. The sUAS will carry no passengers or crew and, therefore, will not 

expose them to the risks associated with manned aircraft flights. The operation of small sUASs, 

weighing less than 55 lbs., conducted in the conditions outlined above, will provide an 

equivalent level of safety supporting the granting of the exemptions requested herein, including 
exempting the applicant from the requirements of Part 21 and allowing commercial operations. 

These lightweight aircraft operate at slow speeds, close to the ground but under 400 feet AGL, 

and within the limited area and, as a result, are far safer than conventional flight operations 

conducted with turbine helicopters operating in close proximity to the ground and people. 

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

representative or owner’s prior consent and knowledge .Filming will be of people who have also 

consented to being filmed or otherwise have agreed to be in the area where filming will take 

place. All flights will occur in accordance with any state or local laws regarding privacy. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012—size, weight,

speed, operating capabilities, proximity to airports and populated areas and operations within 

visual line of sight (VLOS) and national security – provide more than adequate justification for

the granting of the requested exemptions allowing commercial operation of applicants sUAS in

the aerial photography and cinematography Real Estate services industry.

UAV: DJI Inspire 1

Pilot Experience 15 Years with out incident.

robert@srq360.com

Use of UAV:

SRQ360 INC will benefit the active Real Estate Industry in Sarasota, FL and near by areas.

SRQ360 INC has been actively Photographing and filming this industry for the past 10 years.

Sincerely, Robert Dennison SRQ360 INC.