Intelligent Aerials Media

1317 Avalon Drive

Rockledge, FL 32955

June 16, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor Room W12-140

Washington, DC 20590

RE: Intelligent Aerials Media, Petition for Exemption to Operate Unmanned

Aircraft Systems for Aerial Photography, Videography, and Photogrammetry

Dear Sir or Madam:

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

C.F.R. Part 11, Intelligent Aerials Media, Inc. hereby applies for an exemption from the Federal 

Aviation Regulations (FARs) listed herein and any other necessary to allow its operation of small

Unmanned Aircraft Systems (UAS) to provide aerial photography, videography and 

photogrammetry services. The requested exemption would permit the operation of DJI Spreading 

Wings S1000 and DJI Inspire 1 UAS to obtain aerial photographs and video for mapping, 

surveying, structural inspections, and real estate and business sales.

BACKGROUND

Henry Garrett Hinton founded Intelligent Aerials Media (iAerials) in 2012 and began producing 

professional grade aerial photography equipment as a Value Added Reseller (VAR) for his own 

use as well as for other photographers and videographers by assembling components from 

manufacturers such as:

DJI and 3D Robotics. Mr. Hinton’s professional background includes education as an mechanical

engineer and a professional career as a custom CAD draftsman. He also is a photographer and 

videographer and has built and flown radio control aircraft for the past

20+ years. All of these skills enable him to produce high quality reliable multirotor aircraft for 

professional aerial photography and video. Because of the current regulatory environment, sales 

have been limited to hobby use customers. iAerials would like to expand operations and provide

professional aerial photography, videography, and photogrammetry services to businesses and 

individuals in the Brevard County (Florida) area and surrounding counties of Orange, Osceola, 

Volusia, and Polk.

The Unmanned Aircraft (UA) described herein is smaller, lighter and more maneuverable than 

conventional aircraft running on combustible fuel, operates at lower altitudes with no people on 

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

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

minutes, this offers little or no risk to national security.
April 6, 2015 Page 2

Additionally iAerials requests to be allowed to use its system to benefit first responders nearby 

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

subject to all limitations cited herein as we do so.

THE UNMANNED AIRCRAFT (UA)

DJI Spreading Wings S1000

 S1000 Airframe

o Professional grade

o Under 20 pounds takeoff weight

o 8 motors

o 7 to 15 minute flight time depending on battery size

 DJI A2 - Flight Controller with GPS

o Provides Fail Safe features that allow the aircraft to return to the launch point 

and land automatically in the event the command and control signal is lost or 

the battery has reached a pre-determined threshold. If battery reaches a 

critical level, the aircraft will descend and land at the current location.

Control of the aircraft is maintained during descent to allow the PIC to guide 

it to a safe landing.

o Home Lock function allows safe return of the aircraft in the event of a motor 

failure

o Contains a database of airports and restricted airspace and automatically 

prevents operation in these areas

 DJI 5.8 GHz Video Downlink Transmitter – FCC Licensed.

 DJI iOSD Mark II - On Screen Display of Telemetry. The iOSD Mark II 

superimposes telemetry data on the video downlink to provide the pilot with heading, 

speed, height, distance, GPS information, and current battery voltage as well as 

indicating proximity to airports and restricted airspace. Direction back to launch

point is also indicated.

DJI Inspire 1

 DJI Inspire 1 – Reference Inspire 1 User Manual (EN) v1.0

 The Inspire 1 is a quadcopter UAS capable of capturing 4K video and transmitting an HD 

video signal to a ground station. Equipped with retractable landing gear, it can capture an 

unobstructed 360 degree view from its camera. The built-in camera has an integrated 

gimbal to maximize stability and weight efficiency while minimizing space. When no GPS 

signal is available, Vision Positioning technology provides hovering precision.

 Reference Inspire 1 Maintenance Manual v1.0 

 Reference Inspire 1 User Manual (EN) v1.0 [FCC Compliance – Appendix Pg 62]
April 6, 2015 Page 3

GROUND STATION EQUIPMENT

The ground station equipment is comprised of a dual control and audio communication 

equipment.

 Primary controller is for the Pilot in Command (PIC)

o 2.4 GHz radio control unit (FCC Licensed)

o 5.8 GHz video receiver (FCC Licensed)

o Display of video and telemetry

 Camera Controller operates the camera gimbal and does not affect aircraft control

o 2.4 GHz radio control unit. (FCC Licensed)

o 5.8 GHz video receiver (both PIC and Cameraman receive the same signal)

o Display of video and telemetry

o Directional antenna for improved video reception.

GROUND CREW

 Pilot in Command (PIC). The pilot in command will have at least 20+ years of 

R/C flying experience and over 1000 hours on each Unmannded Aircraft listed 

above as well as a third class medical.

 Camera Operator (optional). The Camera operator controls the camera onboard the 

aircraft for photography and videography missions. For photogrammetry missions, 

the camera is in a fixed position and the camera operator is not necessary.

 Visual Observer (VO). The visual observer will provide additional situational 

awareness during flight operations. This person will have been trained with 

over 100 hours of visual spotting, as well as be in radio communication with 

ground team members.

OPERATIONAL PARAMETERS

1. The UAS will weigh less than 55 pounds.

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

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 30 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet (122 meters) AGL.

Unless a specific COA is obtained, the limit will be according to the “blanket” COA of

200 feet (61 meters).

5. Minimum crew for each operation will consist of the UAS pilot and the Visual Observer, 

and one Camera Operator.

6. UAS pilot will have at least 1000 hours flying the above listed Unmanned aircraft and 

20+ years of remote controlled flying experience and third class medical. PIC will have

completed operator and safety training from iAerials. PIC will also have accumulated and 

logged at least 25 hours total time as a UAS rotorcraft pilot including at least 10 hours 

logged as a UAS pilot with a multi-rotor UAS and 5 hours in the same make and model 

of UAS proposed under this exemption request. Local AMA flying fields and rules will 

be used to accumulate flying time and practice
April 6, 2015 Page 4

emergency procedures. PIC will also remain current for the type of aircraft for which the

PIC is licensed.

7. Written and/or oral permission will be obtained from the property owner.

8. Pilot and observer will be able to communicate by voice at all times during the operation.

Communication may be assisted by VHF or UHF radio when necessary. Text 

communications are not allowed.

9. The UAS will only be operated during daytime hours in VFR weather conditions.

10. Operations may not be conducted aboard a moving device or vehicle.

11. Operation near airports will be conducted according to the “blanket” COA unless another

COA is obtained.

 5 nautical miles (NM) from an airport having an operational control tower; or

 3 NM from an airport with a published instrument flight procedure, but not an 

operational tower; or

 2 NM from an airport without a published instrument flight procedure or an 

operational tower; or

 2 NM from a heliport with a published instrument flight procedure

12. Maximum speed 50 knots.

PRE-FLIGHT CHECKLIST

1. Weather conditions are suitable for VFR flight and wind is 18 mph or less.

2. Measure battery voltage to make sure batteries are sufficiently charged before takeoff.

3. Verify that all wiring connections are tight.

4. Raise and lock all rotor arms. Inspect for cracks, damage, and loose hardware.

5. Check to make sure propellers are secure and free from dirt, cracks and chips.

6. Install main battery and check balance.

7. Turn on camera equipment.

8. Verify all switch positions on the RC transmitters. Generally they are all in the forward 

position with the exception of the Mode which should be set to “GPS”.

9. Turn on radio control transmitters and video equipment.

10. Connect the UAS main battery. Check for radio connection with RC transmitters and 

video downlink.

11. During warmup, check the A2 Flight Controller LED indicator. One green flash 

indicates GPS mode. Wait for both of the following LED indications:

a. A string of 10 or more green flashes indicating that the forward direction has been 

recorded.

b. 2 or less red flashes to indicate that 5 or more GPS satellites have been obtained.

This may also be observed in the video telemetry information.

12. Announce your intention to take off by announcing “Take Off”.
April 6, 2015 Page 5

DOCUMENTATION

The following documents are attached and provided to support this petition.

 DJI Spreading Wings S1000 User Manual Version 1.10

 DJI Inspire 1 Version 1.0

 A2 Flight Controller System User Manual Version 1.20

 iOSD (On Screen Display) User Manual Version 2.10

 iAerials Preflight Checklist

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN

EXEMPTION

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

Command.

These regulations limit private pilots to non-commercial operations. Because the UAS will not 

carry a pilot or passengers and be operated within limited areas and altitudes, the proposed 

operations can achieve the equivalent level of safety of current operations by requiring the PIC 

operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to 

operate this small UAS.

B. 14 C.F.R. § 91.7(a) Civil Aircraft Airworthiness

While the UAS will not have an airworthiness certificate in accordance with 14 C.F.R. part 21, 

Subpart H, the airworthy condition of the UAS will be the responsibility of the PIC in 

accordance with 14 C.F.R. § 91.7(b).

C. 14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and other areas

This regulation establishes safe altitudes for operation of civil aircraft over areas other than 

congested areas. BEAP requests relief from this section with respect to persons involved in the 

operation as well as vehicles and structures. The UAS will not be operated above 400 feet 

altitude. It will be operated in a defined area where people and buildings will not be exposed to 

operations without their pre-obtained consent.

D. 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 does not have a barometric altimeter, 

an exemption is requested. The UAS Flight Controller utilizes GPS equipment aided by a static 

pressure sensor to determine and maintain altitude. The aircraft altitude above the takeoff point 

is provided in the video downlink telemetry information and provides sufficient information for 

the PIC to maintain altitudes at or below the 400 foot (122 meter) limitations.
April 6, 2015 Page 6

E. 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 cursing 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.”

Given that the UAS aircraft only fly for a maximum of 30 minutes and typically carry about 15 

minutes of batter power, an exemption is requested. The UAS operations are always conducted 

within a few minutes of the takeoff and landing point and within a restricted area. BEAP 

believes that terminating the flight with 25% remaining battery power provides an equivalent 

amount of safety that is intended by section 191.151(a).

F. 14 C.F.R. § 91.405(a) Maintenance Required;

14 C.F.R. § 91.407(a)(1) Operation after maintenance, preventative maintenance, 

rebuilding or alteration;

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

14 C.F.R. §§ 91.417(a) and (b) Maintenance Records

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 the sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

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

pursuant to the Owner’s Manuals. An equivalent level of safety will be achieved because these 

small UAS are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods 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 initial 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. The FAA issued exemption to these regulations in Exemption No. 11062.
April 6, 2015 Page 7

SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER

Petitioner: Intelligent Aerials Media.

Sections of 14 C.F.R Affected: §§ 61.113(a) and (b); § 91.7(a); § 91.119(c); § 91.121; §

91.151(a); § 91.405(a); § 91.407(a)(1); §§ 91.409(a)(1) and (2); §§ 91.417(a) and (b)

Description of Relief Sought: Intelligent Aerials Media, seeks relief from the requirements of 

14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14

C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14

C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b) to operate small unmanned 

aircraft systems (UAS) for the purpose of aerial photography, videography, and 

photogrammetry.

Respectfully Submitted

Henry Garrett Hinton

President

Intelligent Aerials Media

1317 Avalon Drive

Rockledge, Florida- 32955

Phone: 321-482-8004