From: Advanced Aerial Systems LLC

To: United States Department of Transportation,

Docket Management System 1200 New Jersey Ave., 

SE West Building Ground Floor Room W12-140 

Washington, DC 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

July 27, 2015

Brian Martini

Advanced Aerial Systems LLC

9 Alfred Circle

Bedford, MA 01730

brian@AdvancedAerialSystems.com

339-223-9713

Dear Sir or Madam:

Federal Aviation Administration:

I, Brian Martini, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the 

procedures contained within 14 C.F.R. 11, to request that my company, Advanced Aerial 

Systems LLC, an owner and operator of small unmanned aircraft, be exempted from the 

Federal Aviation Regulations (“FARs”) listed below so that Advanced Aerial Systems LLC, may 

operate a small light weight unmanned aircraft system (“UAS”) commercially in airspace 

regulated by the Federal Aviation Administration (“FAA”) in accordance with FAA UAS 

Regulations & Policies.

I would like to formally submit for an exemption from the following Section 333 regulations: 14 

C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 

14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 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 DJI’s following UAS: Phantom 2, Phantom 3, Inspire 1, and S800 Evo along 

the guidelines of the accompanying DJI Phantom 2, DJI Inspire 1, DJI Phantom 3, and DJI S800 

Evo Operator’s manuals. These UAS will be equipped with detachable cameras and will be 

transported in proper storage. This proposed exemption would allow me operation of unmanned 

aircraft systems (UAS) for the purpose of aerial videography/ photography as a service to the 

public/ business interests. As found in exemption No. 11138 (Trudeau), the FAA recently 

approved similar use of a Phantom 2 UAS.

These devices were selected because they have proven reliable flying capabilities managed by 

gyro stabilized flight, ground detection (phantom 3 and inspire 1) ,GPS aided navigation, a 

compass, blinking LEDs, failsafe mode for returning home and prop guards. 
Specific section or sections of 14 CFR which I seek relief and the reason I seek relief:

14 C.F.R. Part 21: Airworthiness Certificates

Given the size and limited operating area associated with the aircrafts to be utilized by 

Advanced Aerial Systems LLC, an exemption from Part 21 meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the reform Act. In all cases, an 

analysis of these criteria demonstrates that the UA operated without an airworthiness certificate, 

in the restricted environment and under the conditions proposed will be at least as safe, or safer, 

than conventional aircraft operating with an airworthiness certificate without restrictions and 

conditions proposed.

14 C.F.R. 45.23: Display of marks: general

The UAs will not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to 

mark certain words or phrases. Further, the two inch lettering is difficult to place on such a small 

aircraft with dimensions smaller than the minimal lettering requirement.

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

The FAA has previously declared that additional manned airship experience of a 

commercially certified pilot would not correlate to the airmanship skills necessary for similarly 

proposed operations in previously issued exemptions to this regulation through Exemption Nos. 

11062 and 11138.

14 C.F.R 91.7: Civil aircraft airworthiness

Currently, since there is no certificate applicable to the UAs in question, this regulation is 

inapplicable.

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements

Requires an aircraft flight manual in the aircraft, however there are no pilots or 

passengers on board this aircraft and given its size, this regulation is inapplicable. An equivalent 

level of safety will be achieved by maintaining a safety/flight manual with the operator.

14 C.F.R. 91.119(c): Minimum safe altitudes

Advanced Aerial Systems LLC will ensure that our UAS do not operate any higher than 

400 feet above ground level. Advanced Aerial Systems LLC will not fly over congested areas. 

Advanced Aerial Systems LLC will plan operations before hand, for proper flight safety, and 

proper height analysis as to avoid collisions. Advanced Aerial Systems LLC UAS are equipped 

with software that can restrict the hight of our aircraft above the ground, and we have set the 

altitude limit to 400’ AGL.
14 C.F.R. 91.121: Altimeter settings

The UAS utilize electronic GPS with a barometric sensor. An equivalent level of safety 

will be achieved by using this.

14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions

The UAS that Advanced Aerial Systems LLC will fly are powered by electricity, using 

lithium polymer batteries that currently have a flight limit of no more than 20 minutes. Therefore, 

due to the limitations of the batteries, it is currently impossible to comply with part 91.151.

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required

Currently, there are no procedures for providing airworthiness certificates for the 

mentioned UAS. Advanced Aerial Systems LLC however will always fly safely while having the 

manuals of the DJI Phantom 2, DJI Inspire 1, DJI Phantom 3, and the DJI S800 Evo.

14 C.F.R. 91.405(a): Maintenance Required,

14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive 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

Maintenance inspections may be required and should be granted since they only apply to 

aircraft with an airworthiness certificate. However an Advanced Aerial Systems LLC employees, 

will perform preflight inspections of the UAS before each flight as outlined in the operating 

documents. Advanced Aerial Systems LLC, will also follow manufacturer recommendations from 

said operating documents.

Public Interest

Aerial photography and videography as an available service to the public allows for a 

cheaper method of capturing imagery than its alternative. Its alternative being aircraft and 

helicopters. They are expensive, create lots of noise, and are much more threatening due to 

size and combustible fuel.

Advanced Aerial Systems LLC, would gladly offer our services upon request and with 

proper coordination to any official search and rescue or emergency services organization to 

benefit the public.

Also as mentioned in the Trudeau exemption, exemption No.11138:

““Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, are 

operated by an onboard pilot and may carry other onboard crew members, as well as 100 

gallons or more of fuel. The petitioner’s [sUAS] weighs less than 15 lbs. The pilot and crew will 

be remotely located from the aircraft. The limited weight reduces the potential for harm to 

persons or damage to property in the event of an incident or accident. The risk of an onboard 

pilot and crew during an incident or accident is eliminated with the use of a [sUAS] for the 

proposed operation.”
Summary

Advanced Aerial Systems LLC is seeking exemption from the following rules:

14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)

(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 

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)

With the exemptions of the mentioned rules Advanced Aerial Systems LLC will be seeking to 

make our drone photography/videography services available to the public. Alternatively the 

public had seeked the use of helicopters and aircraft to achieve what we can offer in a safer, 

more cost efficient manner. By not using combustible fuel, flying at safe heights and strictly 

following the usage recommendations from DJI.

These include 

Flying the following UAS in a safe manner

! ! DJI S800 Evo

! ! DJI Inspire 1

! ! DJI Phantom 3

! ! DJI Phantom 2

• Flying below 400 feet AGL

• Proper visual inspection of the UAS before flights

• Keeping mentioned UAS in visual sight at all times when in operation

• Using an observer to assist if needed

• Remain well Clear of and do not interfere with manned aircraft operations and avoid other 

aircraft and obstacles at all costs

• Not intentionally fly over unprotected persons or moving vehicles

• Not flying in adverse whether conditions 

• Check and follow all local laws and ordinances before flying over private property

Respectfully, 

Brian Martini

Advanced Aerial Systems LLC

9 Alfred Circle 

Bedford MA, 01730

brian@AdvancedAerialSystems.com

339-223-9713