AERIAL IMAGES, LLC 

October 26, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91. 7(a); 14 CFR 

91.9(b)(2); 14 CFR 91.103;14 CFR 91.109; 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)(l) and (2); 14 CFR 

91.417(a) and (b) 

To whom it may concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, David C. 

Carroll, Jr., sole manager of Aerial Images, LLC, hereby applies for an exemption from the listed Federal 

Aviation Regulations to allow commercial operation of a small UAS, so long as such operations are 

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

by Section 333, for all operators of small Unmanned Aerial Systems (UAS) working for Aerial Images, LLC. 

Commercial operation small UAS, as described herein, which are equipped with cameras and sensors, 

would operate in the following manner: 

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

land surveying, engineering and other related professional activities. 

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

and cinematography. 

3. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local, state, or federal government authorities. 

4. 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. 

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

controlled conditions in the NAS that would be limited, controlled, predetermined, and will provide 

additional safety features to compliment the existing safe operations of conventional aircraft being used 

today. Approval of this exemption would thereby compliment or 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." 

6128 County Road 28 

Slocomb, AL 36375 

(334)793-3549 Page 1 
AERIAL IMAGES, LLC 

Full Applicant Information: 

Phone: 

Email: 

Address: 

Aerial Images, LLC 

David C. Carroll, Jr. - Manager 

(334) 793-3549 

dccarroll@centurytel.net 

6128 County Road 28 

Slocomb, Al36375 

Regulations from which the exemption is requested: 14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113(a) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

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) 

The small UAS's that will be used are multi-rotor or fixed wing aircraft weighing less than SSibs. including 

payload. They will operate at speeds of less than 100 Mph or 86 Knots at all times. They will be operated 

by line of sight only with PIC and a visual observer as presently required obeying all other local and federal 

laws. There will be times where operation after sundown will be required such as when thermal imaging 

is a requirement such as heat loss mapping for an existing building or from search and rescue operations. 

These will only be carried out with a PIC and VO and may be carried out with their own specific COA. 

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

will adhere to the Reform Act's safety requirements. The approval ofthis 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 exhaust and noise emissions 

and the virtual elimination the possibility of loss of human life, 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 

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AERIAL IMAGES, LLC 

The operation of the UAS as proposed will provide an equivalent or higher level of safety because 

operations will further enhance the safety of the persons and/or property compared to using conventional 

aircraft. UAS 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: 

• Any small UAS will weigh less than 55 lbs. 

• Flights will be operated within line of sight of a pilot and/or observer. 

• Maximum flight time for each operational flight will be 30 minutes or within the limitations of the 

UAS battery/fueling system. Flights will be terminated at 20% fuel/battery power reserve or 30 minutes 

of flight time. 

• 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. 

• Minimum crew for each operation will consist of the small UAS Pilot in Command (PIC), the Visual. 

Observer (VOL and may include a Camera Operator. 

• A pre-flight briefing will be performed regarding the planned UAS operations prior to the first 

flight and may include others as necessary for safe and responsible flight and will cover the day's 

production activities. 

• The PIC 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 or direction of the FSDO, operations at closer range may be 

approved. 

• The PIC will have been trained in operation of small UAS and receive up-to-date information for 

the particular small UAS to be operated and will be able to show upon request their competent ability to 

operate the small UAS and/or Camera. 

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

• 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 when 

needed. 

• If the small UAS loses communications or loses GPS signal, the small UAS will have the capability 

to return to a pre-determined location within a designated location and land autonomously. 

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

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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 small 

UAS. In all cases, an analysis of these criteria demonstrates that the small 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 small 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 PIC and VO, 

and in compliance with local public safety requirements. 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 small 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," "light-sport," "experimental," or "provisional," as applicable. We ask for an exemption from 

this requirement. 

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

Pursuant to 14 CFR 61.113 (a), 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. Our small UAS 

do not carry any pilots or passengers nor property therefore I am seeking an exemption to 14 CFR 

61.113(a). Although helpful, a pilot's license will not ensure remote control piloting skills. The risks 

inherent to the operation of small UAS are far less than the risk levels inherent in the commercial activities 

outlined in 14 CFR 61. We ask for an exemption from the PIC "current" status only as the medical condition 

of the PIC will have little if any impact of the actual flight of the UAS. We also believe the requirement of 

the biannual flight review is superfluous and we therefore ask for exemption from this requirement. 

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 

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

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

and use of safety checklists prior to each flight an equivalent level of safety will be provided. We therefore 

ask for an exemption from this requirement. 

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

Section 91.9 (b) (2} 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 small UAS, given its size and configuration has no ability or 

place to carry such a flight manual on the aircraft 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 small UAS will have immediate access to it. We therefore 

ask for an exemption from this requirement. 

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. The FAA currently does not have or offer approved flight manuals for these aircraft. The PIC will 

take all actions including reviewing weather, fueling/battery requirements, landing and takeoff distances 

and aircraft performance data and inspect the aircraft prior to initiation of flight. We therefore ask for an 

exemption from this requirement. 

14 C.F.R. §91.109: Flight Instruction 

Section 91.103 provides that 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. Small UAS and 

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of 

safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size 

and speed of the aircraft. We therefore ask for an exemption from this requirement. 

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. As set forth herein, the small UAS 

will never operate at higher than 400 AGL with the exception that in circumstances where the small UAS 

is used to survey or photograph a structure whose height exceeds 400 feet AGL, the small UAS will not be 

operated more than 100' above the highest point on the structure. It will however be operated in a 

restricted area with security perimeter, where property and human life will not be exposed to operations 

without previous permissions and consent. An equivalent level of safety will be achieved given the size, 

weight, speed of the small 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 advanced flight notice to the 

property owner and participants, all affected individuals will be aware of the planned flight operations. 

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AERIAL IMAGES, LLC 

Compared to flight operations with aircraft or rotorcraft weighting 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 AGL In addition, the lowaltitude operations and the line of sight flight rules by the PIC/VO team of the small UAS will ensure 

separation between these small- 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." The small UAS does not have a barometric altimeter, but instead a GPS 

altitude read out. 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. We therefore ask for an exemption from this requirement. 

14 C.F.R. § 91.1SI(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 small UAS 

provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 

CFR §91.151, small UAS flights would be limited to approximately 10 minutes in length or less. Given the 

limitations on the small 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 small 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 small 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 will be achieved 

by limiting flights to 30 minutes or 20% of battery power remaining- whichever occurs first. This restriction 

would be more than adequate to return the small UAS to its planned landing zone from anywhere in its 

limited operating area. We therefore ask for an exemption from these requirements. 

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 .... 

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(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 small UAS fully loaded weighs no more than SSibs. and is operated without an on board pilot. As such, 

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

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

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

applicable to the small UAS. We therefore ask for an exemption from this requirement. 

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) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis 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 do not seem to apply to this 

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 these small UASs are very limited in size, 

will carry a small payload, and will operate only in restricted areas for limited periods of time causing very 

limited jeopardy to property or human life. If mechanical issues arise the small UAS can land immediately 

and will be operating from no higher than 400 feet AGL. The operator will ensure that the small UAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance 

performed. 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 small UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual (AOM}. As 

provided in the FOM, the operator will ensure that the small UAS is in working order prior to initiating 

flight and perform required maintenance needed. We therefore ask for an exemption from these 

requirements. 

Small UAS Information 

Small UAS's to be used are as follows but not limited to providing they are within the scope of the 

exemption granted by the FAA: 

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AERIAL IMAGES, LLC 

Yuneec Typhoon QSOO+ Aircraft 

• Flight Time Up to 25 Minutes 

• Dimension 16.5x16.5x9.5in (420x420x240mm) 

• Diagonal Length without Rotor Blades 22.2in (565mm) 

• Propeller/Main Rotor Diameter 13.0in (330mm) 

• Weight without Battery and Payload 40.0oz (1130g) 

• Battery 5400mAh 3S 11.1 V LiPo (included) 

• Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter 

• Transmitter 10channel 2.4GHz with 5.8GHz video downlink 

• 3 Flight Modes Smart, Angle and Home Modes 

• Maximum Flying Height Default 122m (400ft) Above Ground Level (Adjustable via the QSOO GUI) 

• Maximum Rotation Rate 65°/ s 

• Maximum Roll Angle 35° 

• Operating Temperature Range - 5 octo 80 oc 

Gimbal/Camera 

• Dimension 4.5x1.4x2.9in (11Sx135x74mm) 

• Weight 6.5oz (185g) 

• Focusing System Aerial Optimized Fixed Focus 

• Field of View 130° 

• Video Transmission Range FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 

ft) with ST10 

• Video Resolution FULL HD 1080p Adjustable 60, 50 or 48 FPS 

• Photo Resolution 16 Megapixels 

• Storage (memory) microSD Class 10, 4 to 128GB 

• Control Angle Accuracy± 0.02° 

• White Balance Automatic White Balance 

• Transmission Band 5.8GHz 

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AERIAL IMAGES, LLC 

• Input/Operating Voltage 7.0V to 14.0V DC 

• Working Temperature ooc- 50°C 

• Storage Temperature 20°C- 60°C 

• Angular Vibration Range± 0.02° 

• Control Range- Pitch : between 90° and oo Yaw between oo and 360° 

Ground Station 

• Operating System AndroidTM 

• Number of Channels 10 

• Control Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 800m (2624.67 ft) 

CE Compliance: Up to 400m (1312.34 ft) 

• Robust Radio Control Modulation Yuneec Protocol 

• Video link Frequency Band 5.8GHz 

• Video Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) 

CE Compliance: Up to 300m (984.252 ft) 

• Flight Systems Telemetry Data On Screen Display (OSD) Yes 

• LED Backlit LCD Screen Capacitive MultiTouch 5.5" 

• Tactile (Vibrating) and Audible Feedback Yes 

• Built-In LiPo Battery Voltage I Capacity 3.6V/5200mAh 18.72Wh 

• Charger AutoCharge Mode via MicroB USB Cable with ACto 5V DC USB Power Supply (Included) 

Respectfully Submitted, 

David C. Carroll, Jr. 

Aerial Images, LLC 

6128 County Road 28 

Slocomb, AL 36375 

(334)793-3549 Page 9