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July 13, 2015

F5 Graphics, Inc.

6245 Indian Trail Drive

Loxahatchee, FL 33470

(561) 795-4826

Email: F5Graphics@att.net

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 2059

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

References:

1. FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the matter of the

petition of DOUGLAS TRUDEAU

2. FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the matter of the

petition of ADVANCED AVIATION SOLUTIONS LLC

3. FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in the matter of the

petition of FLYING CAM INC

4. FAA Exemption No. 11957 Regulatory Docket No. FAA-2015-1401 in the matter of the 

petition of DRONEEYE IMAGING, LLC

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under 

section 333 of the FAA Modernization and Reform Act of 2012, F5 Graphics, Inc., referred 

to hereafter as the petitioner, requests exemption from the following sections of Title 14,

Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409

(a)(1); 91.409(a)(2); 91.417(a) & (b);

In order to operate small unmanned aircraft systems (UAS’s) commercially in airspace regulated

by the Federal Aviation Administration (FAA) for the purposes of aerial photography,

cinematography, videography, mapping, crop surveying, inspections and other flight operations

that could be performed safely and more cost effectively with the use of small UAS at low

altitude within the U.S. national airspace system as compared to a manned aircraft. Operations

will be performed only at the request of and with the authorization and permission of clients or

their authorized agents in order to facilitate commerce and raise awareness of the beneficial
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uses of small unmanned air systems. 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. The conditions identified and proposed by the petitioner are drawn from

references 1-3.

The Federal Aviation Regulations (FARs)

The petitioner seeks exemption from the above mentioned FARs for the following reasons;

Section 61.113(a); 61.113(b)

The petitioner requests relief in order to facilitate the utilization of pilots, who hold a Sport

Pilot (or greater) certificate. Any pilots operating under this exemption would be required to

comply with any conditions as set forth and in a similar fashion to the previously granted

exemptions.

Section 91.119(c)

As referenced in Exemption 11138 (DOUGLAS TRUDEAU) and Exemption 11957 (DRONEEYE 

IMAGING, LLC) , operations conducted closer than 500 feet to the ground may require that the 

UA be operated closer than 500 feet to essential persons, or objects that would not be possible 

without additional relief. The petitioner requests waiver for this condition to allow reasonable 

and responsible operations in areas of subdivisions and neighborhoods if required.

Section 91.121

As referenced in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not

have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude

information.

Section 91.151(a)

As referenced in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been

granted for manned aircraft to operate at less than the prescribed minimums, including

Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief has been granted

in Exemption numbers 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides

battery power remaining in percent to the PIC. The UA batteries provide approximately 20

minutes of powered flight. Information provided in the operating documents discusses

procedures regarding remaining battery power management. Those documents contain a

condition in which the PIC will initiate a landing procedure when battery remaining reaches a

specified level. Given the limitations on proposed operations and the location of those

proposed operations, the FAA found that a reduced minimum power reserve for flight in

daytime VFR conditions was reasonable.

Section 91.405(a); 91.407(a)(1); 91.409(a)(1), 91.409(a)(2); 91.417(a); 91.417(b)

As referenced in Exemption 11138 (DOUGLAS TRUDEAU), the petitioner proposes to inspect

and ensure that the UAS is in a condition for safe flight in accordance with the operating

documents. The FAA found that adherence to the petitioner’s operating documents and the
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conditions and limitations specified, describing the requirements for maintenance, inspection,

and record keeping, were sufficient to ensure that safety would not be adversely affected.

UAS’s; DJI Phantom 3 Professional 

The requested exemption would permit commercial operation of F5 Graphics, Inc. UAS, which weigh less 

than 5 lbs. and perform precision services that consist of high quality still photographs and

videography taken by onboard cameras. UAS’s for aerial services reduce the need to utilize conventional

manned aircrafts for the same purpose at a fraction of the cost; additionally, UAS’s services can provide

an increase in efficiency and productivity for the affected activities and a decrease in fuel emissions

providing environmental benefits. Operations under the exemption will be subject to strict operating

requirements and conditions to ensure, at minimum, an equivalent level of safety to currently

authorized operations using manned aircraft and under conditions as may be modified by the FAA as

required by Section 333.

The UAS's will be operated under controlled conditions at low altitude in airspace that is limited in

scope, as described herein; it will have automated control features, as described in the attached

manuals. The UAS’s also will be operated by an individual who possesses an FAA Sport Pilot Certificate

or greater and valid US Driver’s License. Finally, the airspace in which the UAS will operate will be Class 

G airspace or airspace approved by the FAA in advance.

Approval of these exemptions would thereby enhance safety and fulfill the Secretary of Transportation’s

(the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish

requirements for the safe operation of such aircraft systems in the national airspace system.”

The petitioner has reviewed FAA exemptions references 1-4 Conditions and Limitations 

section and agrees that the procedures specified therein are reasonable and will be utilized in 

order to manage and mitigate risk and ensure public safety. A preflight checklist will be 

developed and employed to ensure that the UAS’s airworthiness will be verified prior to each 

launch.

The petitioner request that in a manner similar as described in reference 3, he be allowed to

operate within 5 miles of an airport provided that:

“The UA may not operate in Class B, C, or D airspace without written approval from the 

FAA. The UA may not operate within 5 nautical miles of the geographic center of a 

nontowered airport as denoted on a current FAA-published aeronautical chart unless a 

letter of agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA. The letter 

of agreement with the airport management must be made available to the Administrator 

upon request.”

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is

requesting a mechanism to facilitate such activities without requesting a new and separate

exemption(s) should the need arise. Operations within class B airspace are not requested due

to the lack of mode C transponder.
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Public interest

Use of the UAS’s in lieu of a manned aircraft would enhance safety and reduce the

environmental impact as compared to similar operations conducted with manned aircrafts.

Additionally, use of the UAS’s in order to facilitate commerce could lead to economic growth.

Operations for this petition will enable service for property owners or their designees seeking

an enhanced perspective for characteristics, amenities, and benefits of their desired

photographic subjects that cannot be displayed through ground level photography or

videography. The petitioner will provide clients with photographic data for these purposes on a

‘for hire’ basis acting as an independent contractor; a visual observer will be utilized. Liability

insurance will be obtained commensurate with the granting of this request for exemption. Data

may be submitted to FAA by traditional means, e.g. COA Monthly Reports, or other means as

required or requested.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial photography,

cinematography, videography, mapping, crop surveying, inspections and other flight

operations”. The petitioner's business model is of the idea of offering ad hoc small UAS’s

services to individuals or business entities who wish to employ these services as a safe,

effective, and legal option to enhance their business or hobby.

Currently, many other UAS operators are conducting business in exactly as described above

without FAA authorization. The petitioner has refrained from engaging in commercial use of the

UAS’s. The primary purpose of seeking this exemption is to obtain the capability to offer those

services while remaining in compliance. 

Respectfully submitted,

F5 Graphics, Inc.

Jozie M. Felicella

Donald J. Felicella