# AERIAL IMAGES, LLC

October 26, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590
Re: Exemption Request Pursuant to Section 333 ofthe FAA Reform Act and Part llofthe 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); 14CFR 91.103;14 CFR 91.109; 14CFR 91.119(c); 14CFR 91.121; 14CFR 91.151(a); 14CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14CFR 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 ofthe FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, David C. Carroll, Jr., sole manager ofAerial 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 undertheconditions outlined herein oras mybe established bythe FAA as required by Section 333, for all operators ofsmall 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/orvideo for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. 2. Aerial video and/or photographyfor 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, orfederal government authorities. 4. Aerial video/photographyor providing live video feed to assist with search and rescue operations in cases ofan emergency or natural disaster only whenthe local authoritiesorgovernment 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 ofconventional aircraft being used today. Approval ofthis 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 ofsuch aircraft systems in the national airspace system."
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# 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 14CFR 45.23 (b) 14 CFR 61.113(a) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14CFR 91.103 14 CFR 91.109 14 CFR 91.119(c) 14CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) 

### & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14CFR 91.409 (a) (2) 14 CFR 91.417 (a) 

### & (b)
The small UAS's thatwill be used are multi-rotororfixed wing aircraft weighing less than SSibs. including payload. They will operate atspeeds of less than 100 Mph or 86 Knots at all times. They will be operated by line ofsightonlywith PIC and avisual observer as presently required obeying all other local and federal laws. There will be times where operation aftersundown will be required such as when thermal imaging is a requirementsuch as heat loss mappingfor an existing building orfrom search and rescue operations. These will only be carried outwith a PIC and VO and may be carried out with their own specific COA. Given the small size ofthe small UAS and the controlled environment provided the proposed operations will adhere tothe Reform Act's safety requirements. The approval ofthis application presents no national security issues. Regardingthe level ofsafetysurroundingthe 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 ofhuman life, the grant ofthe 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 6128 County Road 28 Slocomb, AL 36375 (334)793-3549 Page 2

# AERIAL IMAGES, LLC

The operation of the UAS as proposed will provide an equivalent or higher level of safety because operationswillfurtherenhancethesafetyofthe persons and/orpropertycompared to usingconventional 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 ofsight ofa pilot and/orobserver.
• Maximumflighttimeforeach operational flightwill be 30 minutes orwithinthe limitations ofthe UAS battery/fueling system. Flights will be terminated at 20% fuel/battery power reserve or 30 minutes offlight time.
• Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not morethan 200 feet above an elevated platform from which filming is planned.
• Minimum crewforeach operation will consist ofthesmall 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 ofall persons involved withthe planned operation and ensure thatonly consenting persons will be allowed within 100feet oftheflightoperation, and the radius may be reduced to 30feet based upon an equivalent level ofsafety determination, as required underthe 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 ofsmall UAS and receive up-to-date information for the particularsmall UAS to be operated and will be able to show upon request their competent abilityto operatethe small UAS and/or Camera.
• The PIC and VO will be able to communicate by voice, radio, and/ortext atall 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.
• Ifthe 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.

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

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# AERIAL IMAGES, LLC

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness 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 ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe 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 proximitytoairportsand populated areas ofthe particularsmall UAS. In all cases, an analysis of these criteria demonstrates that the small UAS operated without an airworthinesscertificate, in the restricted environmentand underthe conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe 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 underthis exemptionwill be tightlycontrolled and monitored by boththe 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 thatthere is no credible threatto national security posed by the small UAS, due to its size, speed of operation, location of operation, lack ofexplosive materials or flammable liquid fuels, and inabilityto carry asubstantial external load. 

### 14C.F.R. § 

### 45.23 (b). MarkingoftheAircraft The regulation requires: When marks include only the Roman capital letter "N" 

### and the registration number is displayed on limited, restricted or light-sportcategory aircraft orexperimental 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 morethan 6 inches high, thewords "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. We askfor an exemption from this requirement. 

### 14C.F.R. § 

### 61.113(a): Private PilotPrivilegesand Limitations: Pilotin Command Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot in command ofan aircraft that is carrying passengers or propertyfor 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 inherenttothe operationofsmall UAS arefarlessthan the risk levels inherent in thecommercial activities outlined in 14CFR 61. We askforan exemption fromthe PIC "current"status onlyasthemedical condition ofthe PIC will have little ifany impact ofthe actual flight ofthe UAS. We also believe the requirement of the biannual flight review is superfluous and wetherefore ask for exemption from this requirement. 

### 14C.F.R. §91.7(a): 

### Civil AircraftAirworthiness. The regulation requires that no person mayoperate a civil aircraft unless it is in airworthy condition. As therewill be no airworthiness certificate issued fortheaircraft, should this exemption be granted, no FAA 6128 County Road 28 Slocomb, Al36375 (334)793-3549 

### Page 4

# AERIAL IMAGES, LLC

regulatorystandard will existfor determiningairworthiness. Given thesize oftheaircraftfor maintenance and use ofsafety checklists priorto each flight an equivalent level ofsafetywill be provided. Wetherefore ask for an exemption from this requirement. 14C.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 ofthis chapter, unless there is available in the aircrafta currentapproved 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 abilityor 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 ofsafety will be maintained by keeping the flight manual atthe ground control point where the pilotflyingthe small UAS will have immediate access to it. We therefore ask for an exemptionfrom this requirement. 14C.F.R. § 91.103: Preflight Action This regulation requires each Pilot-in-Command to take certain actions before flight to insure the safety offlight. The FAA currently does not have or offer approved flight manuals forthese aircraft. The PIC will take all actions including reviewing weather, fueling/battery requirements, landing and takeoffdistances and aircraft performance data and inspect the aircraft priorto initiation offlight. We therefore askfor an exemption from this requirement. 14C.F.R. §91.109: Flight Instruction Section 91.103 providesthat no person mayoperate acivil 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 controlsfor a number ofaircraftand forflight instruction in experimental aircraft. The equivalent level of safety provided bythefactthat neither a pilot nor passengers will be carried in the aircraftand by

### thesize and speed ofthe aircraft. Wetherefore ask for an exemption from this requirement. 14C.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 feetAGL, 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 ofthe small UAS as well as the location where it is operated. Noflight 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 ofthe planned flight operations. 

### 6128 County Road 

### 28 Slocomb, AL 36375 (334}793-3549 Page 5

# AERIAL IMAGES, LLC

Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55 lbs. proposed herein and the lack offlammable fuel, any risk associated with these operations isfar less than those presently presented with conventional aircraft operating atorbelow 500AGL 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 complywith Section 91.119. 14C.F.R. §91.121AltimeterSettings This regulation requires each person operating an aircraftto 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 ofsafety will be achieved bythe operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicatorbeforeflight. Wetherefore askfor an exemptionfrom this requirement. 14C.F.R. § 91.1SI(a): Fuel Requirementsfor 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 flytothe first point of intended landing, and, assuming normal cruising speed- (1) Duringthe day, tofly afterthat 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 14CFR §91.151(a) falls withinthe scope ofprior 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 ofthe small UAS. Additionally, limitingsmall UAS flights to 10 minuteswould greatly reduce the utilityfor whichthe exemption will be granted. Applicant believesthatan equivalent level ofsafetywill be achieved by limitingflightsto30minutesor20% ofbatterypowerremaining-whicheveroccursfirst.This restriction would be more than adequate to return the small UAS to its planned landing zone from anywhere in its limited operating area. Wetherefore ask for an exemptionfrom these requirements. 14C.F.R. §91.203 (a) and (b): Carrying Civil AircraftCertification 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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### 28 Slocomb, AL 36375 (334)793-3549 Page 6

# AERIAL IMAGES, LLC

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or aspecial flight authorization issued under §91.715 is displayed atthe cabin orcockpit entrance so that it is legible to passengers or crew. The small UASfully loaded weighs no morethan SSibs. and is operatedwithout an onboard pilot. As such, there is noabilityor place tocarrycertification and registration documentsortodisplaythem 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 applicableto the small UAS. We therefore ask for an exemption from this requirement. 14C.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 thatthese section and Part 43 apply only to aircraft with an airworthiness certificate, these sections do not seem to apply to this applicant. Maintenancewill be accomplished bytheoperator pursuanttotheflight manual and operating handbook. An equivalent level ofsafetywill be achieved because thesesmall UASs are very limited in size, will carry asmall payload, and will operate only in restricted areas for limited periods oftime causingvery limitedjeopardyto property or human life. Ifmechanical issues arise the small UAS can land immediately and will be operating from no higherthan 400 feet AGL. The operatorwill ensure thatthe small UAS is in working orderpriorto initiatingflight, perform required maintenance, and keep a log ofany 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: 6128 County Road 28 Slocomb, AL 36375 (334)793-3549 Page 7

# 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 11.1V 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 ofView 130° • Video Transmission Range FCC Compliance: Up to600m (1968.5 ft)CE Compliance: Upto300m (984.252 ft) with ST10
• Video Resolution FULL HD 1080pAdjustable 60, 50 or48 FPS
• Photo Resolution 16 Megapixels
• Storage (memory) microSD Class 10, 4to 128GB
• Control Angle Accuracy±0.02°
• White Balance AutomaticWhite Balance
• Transmission Band 5.8GHz 6128 County Road 28 Slocomb, AL 36375 (334)793-3549 Page 8

# . . 

# AERIAL IMAGES, LLC

• Input/OperatingVoltage 7.0V to 14.0V DC
• WorkingTemperature

# 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 ofChannels 10
• Control Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34ft)
• 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 Modevia MicroB USB Cable with ACto 5V DC USB Power Supply (Included) 

### Respectfully Submitted,

David C. Carroll, Jr. Aerial Images, LLC

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