Photo Flight LLC

2044 Utley Rd – Suite 1

Flint, MI 48532

(810) 309-9160

April 9, 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

Dear Sir/Madam,

This petition is being submitted on our own behalf without legal counsel or consulting services. 

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

14 C.F.R. Part 11, Photo Flight LLC, a Michigan based limited liability company operating a Small 

Unmanned Aircraft System (sUAS) equipped to conduct aerial photography and survey for various 

industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed 

below to allow operation of our sUAS commercially in airspace regulated by the Federal Aviation 

Administration (FAA) so long as such operations are conducted with and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit Photo Flight LLC to pursue its commercial interests in 

providing services to consumers interested aerial data capture using small advanced sUAS in the 

following areas:

 Real Estate Photography

 Agricultural Surveying

 Special Events Photography

Photo Flight LLC states that all sUAS flights will occur over private or controlled access property 

and will only do so with the property owner's prior consent and knowledge and not before a 

thorough inspection and survey of the property.

Photo Flight LLC sUAS operators have completed a minimum of 80 hours of flight and training 

including at least 40 hours indoor flight training regarding safety, maintenance, calibrations, 

maneuvering and controls with an additional 40 hours minimum of outdoor flight training and 

practice before being permitted to fly commercially. All sUAS operators must pass a physical and be

in good sound medical and mental health.
Photo Flight LLC is requesting exemption from the following regulations:

 14 C.F.R. Part 21

 14 C.F.R. 45.23 (b)

 14 C.F.R. 61.113(a) and (b)

 14 C.F.R. 91.7 (a)

 14 C.F.R. 91.9 (b) (2)

 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) & (b)

 14 C.F.R. 91.205 (b)

 14 C.F.R. 91.215

 14 C.F.R. (91.401 - 91.417)

Unmanned Aircraft System

sUAS are a feasible method to obtain information of agricultural cropland to determine optimum 

inputs that result in cost savings to farmers, yield security, and reduce environmental impact of 

excess fertilizers and chemicals in the soil. Additionally Aerial Real Estate Photography is growing

in popularity and is a chosen method for highlighting and showing overviews of property for 

potential sale.

We are petitioning for exemption to enable Photo Flight LLC to operate a DJI Phantom 2 Vision 

Plus multi-rotor equipped with a three-axis gimbaled camera, a DJI Inspire 1 multi-rotor equipped 

with a three-axis gimbaled camera, and a BLADE 350 QX3 AP multi-rotor equipped with a threeaxis gimbaled camera. These sUAS all weigh less than 25 lbs., have a built-in capability to limit 

the height it flies above the ground and to limit the radius of the distance it flies from the 

operator. Each system also has the failsafe function of the autopilot Return Home feature. This

feature can be activated manually by the sUAV operator and is activated automatically if

communication between the Main Controller and the transmitter is lost. Once activated either 

manually or by a transmitter communication error, the system will automatically trigger Return to 

Home and the sUAS will land safely near the GPS coordinates in which it raised from.

Safety is of the top most concern at Photo Flight LLC. We have implemented policy and 

procedures to ensure safe operations. The following are some of the basic safety rules and 

procedures in place:

 All sUAS equipment has firmware coded flight restrictions limiting above ground flight to 

115 meters (approximately 377 feet) above ground and 200 meters (approximately 656 

feet) Geo Fence restricting the sUAS to travel no further than 200 meters from the sUAS 

operator.

 Once a week Accelerometer and Pressure sensor calibrations will be done in a controlled 

environment.

 Once a month calibrations will be monitored through diagnostics software and firmware’s

verified and updated if necessary. 

 Any updated firmware will be fully tested in a controlled environment for at least 1 hour 

worth of flight time before being flown commercially.

 No flights will be permitted after 30 minutes before sunset and sUAS will never be flown in 

the path of any aircraft.

 Before each flight a compass calibration will be done on site along with preflight 

mechanical inspections including battery levels in the sUAS and transmitter.
 Before each flight a property survey will be done checking for power lines, antennas, trees, 

and any overhead objects. Wind conditions will be monitored and also be factored before 

flying.

 Only a fully charged and balanced battery is to be used at each take off.

 While in flight either the sUAS operator or secondary visual observer must be able to see 

the indicator LED light affixed to the sUAS.

 No flight will ever exceed 8 minutes. At the beginning of each flight a timer will be

activated. At 7 minutes the timer will go off alerting the sUAS operator to begin to land. 

If a battery alert is indicated on the always visible LED prior to the 7 minute timer

expiration the sUAS is to be landed immediately and the battery recycled or discarded

safely as it proved to be defective.

The above specifications and safety precautions meet and exceed standards listed below, some 

derived in accordance with the Model Aircraft Operating Standards:

 The petitioner will only operate its sUAS in line of sight of the sUAS operator and

secondary visual observer and will operate at sites that are a 'sufficient distance' from 

populated areas within the sterile area described in the operator’s manual. Such 

operations will insure that the sUAS will "not create a hazard to users of the national 

airspace system or the public."

 Maximum flight time for each operational flight will be 8 minutes.

 Flights will be terminated at 25% battery power reserve should that occur prior to the 8 

minute limit.

 The sUAV will be programmed so that it will be operated at an altitude of no more than 

378 feet AGL.

 Minimum crew for each operation will consist of the sUAS Operator and a second Visual 

Observer. At no time will the sUAS pilot or the secondary observer be out of line of sight 

from the sUAS.

 The sUAS operated by the petitioner weighs less than 25 pounds, including the payload 

(i.e. camera, lens, and gimbal).

 The sUAS will operate at speeds of no more than 55 knots.

 Given the small size of the sUAS and the restricted sterile environment within which they 

will operate, our sUAS operations adhere to the Reform Act's safety requirements.

We respectfully request exemption under Section 333 to enable Photo Flight LLC to operate safe, 

low-risk commercial sUAV operations for the activities stated. Photo Flight LLC at all times will 

respect the space and privacy of citizens and property while keeping our skies safe.

Sincerely,

Scott T. Tabor

CEO / Photo Flight LLC

2044 UTLEY RD SUITE 1

Flint, MI 48532

(810) 309-9160