Capital Aerial, LLC

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June 3, 2015

Donald Olszowy

69 Glenwood Rd

Troy, NY 12180

518-894-7600

skyhimedia@yahoo.com

Petition of Capital Aerial, LLC

For Exemption Pursuant to Section 333

Of the FAA Modernization and Reform Act of 2012

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

Capital Aerial, LLC (CA), hereby applies for an exemption from Federal Aviation Regulations (FARs) 

identified below, to allow commercial operations of small unmanned aerial systems (i.e., sUAS). unmanned 

aerial systems (i.e., sUAS).

This exemption is in accordance with protocols outlined in this petition for exemption, and any

other requirements established by the FAA pursuant to Section 333 of the Reform Act.

This exemption would permit commercial operation by CA, which uses a DJI Phantom 2 sUAS

to conduct:

 Aerial surveying

 Event Photography/Videography

 Agriculture purposes

 Real Estate Photography

 Aerial Filmmaking and Photography

 Construction Site Inspections and Monitoring, and

 News Gathering and First Responders.

CA’s operation under the exemption will be subject to strict operating requirements and conditions 

to ensure 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.

CA's sUAS will be operated under controlled VFR conditions at low altitudes. They will operate

the sUAS’s with pilots who have comprehensive UAV / UAS / Drone flight training for competency and 

new FAA 333 and Part 107 commercial compliance requirements. 

Finally, when required, the FAA ATC will approve the airspace in which the sUAS will operate 

in advance.

Capital Aerial, LLC respectfully submits this request for an exemption because it operates sUAS's. 

The FAA can have confidence that the operations will be conducted at an equivalent level of safety or 

greater. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 
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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.”

For your convenience, CA has organized this Exemption request as follows:

I. Petitioner's Description

II. Relevant Statutory Authority

III. Qualifications for Approval Under Section 333 of the Reform Act

IV. Description of Proposed Operations

V. Regulations From Which Exemption is Requested

VI. Public Interest

VII. Privacy

VIII. Federal Registry Summary

IX. Conclusion

I. Petitioner's Description:

Capital Aerial, LLC, headquartered in Troy, NY, is a company that provides sUAS support to news 

and event videography, real estate and construction site photography, film and movie production, precision 

agricultural purposes, education, and demonstration flights in a compliant and safe environment. CA plans 

on providing a wide range of services as the sUAS market expands. CA's goal is to operate in an accidentfree environment by:

• Demonstrating a commitment by management and all employees to operate in a compliant

 manner.

• Identifying hazard and risk while eliminating or controlling all these risks.

• Using steps to intervene and report when unsafe work practices appear to exist.

• Training all employees involved in flight operations to operate at the highest standard level.

The contact information for Petitioner is as follows:

Capital Aerial, LLC

69 Glenwood Rd

Troy, NY 12180

Owner:

Donald Olszowy

Office: (518)-894-7600

Email: skyhimedia@yahoo.com

II. Relevant Statutory Authority:

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through

(c) of the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil

unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, 

the FAA Administrator is to consider whether certain unmanned aircraft systems may operate safely in the 
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National Airspace ("NAS") before completion of the formal UAS rulemaking, based on the following 

considerations:

• The UAS's size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within the visual line of sight of the operator.

If the Secretary determines that such vehicles "may operate safely in the National Airspace system, 

the Secretary shall establish requirements for the safe operation of such aircraft in the National

Airspace System".

Additionally, the FAA Administrator has general authority to grant exemptions from its safety

regulations and minimum standards, and has done so on numerous occasions, when the Administrator 

decides a requested exemption is in the public interest. A party requesting an exemption must explain the 

reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect 

safety (or how it would provide a level of safety at least equal to the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under 40101 of the 

Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service:

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any of sections.

III. Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for expedited approval under

Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied. The 

proposed operations would permit CA the use of small UAS under controlled conditions in airspace that is: 

(1) predetermined; (2) controlled as to access; and that (3) provides an increased level of safety beyond that 

existing when fixed or rotor wing aircraft are used to accomplish the same purpose.

CA uses sUASs that are multi-rotor, weighing less than 25 pounds including payload. They

operate, under normal conditions, at speeds not to exceed 40 mph and have the capability to fly, hover, and 

move in the vertical and horizontal plane. CA’s sUAS’s will operate in line of sight, during daylight hours, 

and will only operate within a sterile area. CA will operate at or below 200 feet AGL and will file a 

NOTAM for each flight operated in controlled airspace. All required permissions and permits would be 

obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies prior to operating a sUAS. Given the small size of the sUAS’s involved 

and the restricted sterile environment within which they will operate, CA’s exemption falls within the zone 

of safety and demonstrates an equivalent level of safety, in which Congress desired the FAA to permit 

commercial UAS operations by exemption pending completion of formal rulemaking. Also, due to the size 

of the sUAS’s and the confined area in which the sUAS’s will operate, approval of the application presents 

no hazard in the NAS. Considering the clear direction in Section 333 of the Reform Act, the authority 

contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed 
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operations, and the significant public benefit, the grant of the requested exemptions is also in the public 

interest.

IV. Depiction of Proposed Operations

To assist the FAA in its safety assessment of CA's proposed sUAS operations, below is a summary 

of operational limitations and conditions that will ensure an equivalent or higher level of safety to operations 

conducted under current regulatory guidelines:

1. The sUAS will weigh less than 25 pounds.

2. Flights will be operated within line of sight of the PIC and observer.

3. Maximum total flight time for each operational flight will be limited to the amount of time

 the sUAS can be flown and still maintain a reserve battery power of no less than 25%.

4. Flights will be operated at an altitude of no more than 200 feet AGL.

5. Flights will be operated at a lateral distance of least 100 feet from any inhabited structures,

 buildings, vehicles, vessels, people not associated with the operation or who have not

 signed a waiver in advance of the operation.

6. Minimum crew for each operation will consist of the sUAS Pilot in Command and a Visual

 Observer.

7. The sUAS Pilot in Command will hold at least a sport pilot or recreational pilot certificate and a

valid U.S. driver’s license.

8. CA will designate a Pilot in Command (PIC) for each mission.

9. The sUAS will operate only within a confined "Sterile Area".

10. Prior to the operations at a particular location, a site inspection will have been conducted.

 On the day of the mission the management person with operational control and the PIC

 will concur on dispatching of the mission.

11. A briefing will be conducted in regard to the planned sUAS operations prior to each day's

 missions. It will be mandatory that all personnel who will be performing duties within the

 boundaries of the sterile area be present for this briefing.

12. CA crew will use the checklist and callouts required in the Operations Manual.

13. All sUAS’s will be maintained in accordance with inspection program specified in the

 manufacturer’s guidelines.

14. In the event of an accident involving an CA sUAS, they will cease operations and report

 the accident to the NTSB and AFS-80.

15. Pilot in Command and Visual Observer will at all times be able to communicate by voice.

16. Pilot in Command, Visual Observer, Camera Operator, and Operational Personnel will

 have been trained and tested in accordance to FAA, NTSB, and AFS-80 best practices.

17. All required permissions and permits would be obtained from territorial, state, county or

 city jurisdictions, including local law enforcement, fire or other appropriate governmental

 agencies.

18. CA management will submit a written “Plan of Activities” to the local Flight Standards

 District Office (FSDO) having jurisdiction over the area of proposed filming three days in

 advance of operations during film or movie productions.

19. If the sUAS loses communications signal, the sUAS will have the capability to return to a

 pre-determined location within the Sterile Area and land.

20. Contingency plans will be in place to safely terminate flight if there is a loss of

 communication between the pilot and the observer.
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21. The sUAS PIC has the capability to abort a flight in case of unpredicted obstacles or

 emergencies.

22. CA, by following FAA, NTSB, and AFS-80 best practices, will assure no individuals’

 privacy is violated.

23. Procedures have been established in CA’s Operations Manual to contact ATC prior to

 operating in airspace other than G.

V. Regulations From Which Exemption is Requested

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”,

provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. 

Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safely 

in the national airspace system before completion of the (comprehensive) plan and rulemaking required by 

section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), 

Congress made it clear that Section 333 provides a mechanism for “expedited operation authorization” if 

several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS 

operations. The Petitioner Requests Relief From the Following:

A. 14 CFR § 91.103: Preflight Action

CA requests an exemption from the preflight actions requirements of 14 CFR 91.103 that prescribes 

the preflight actions under which aircraft may operate: Each pilot in command shall, before beginning a 

flight, become familiar with all available information concerning that flight.

a. Flight under IFR or a flight not in the vicinity of an airport, weather reports

 and forecasts, fuel requirements, alternatives available if the planned flight

 cannot be completed, and any known traffic delays of which the pilot in

 command has been advised by ATC;

b. For any flight, runway lengths at airports of intended use, and the following

 takeoff and landing distance information:

i. For civil aircraft for which an approved Airplane or Rotorcraft Flight

 Manual containing takeoff and landing distance data is required, the

 takeoff and landing distance data contained therein; and

ii. For civil aircraft other than those specified in paragraph (b)(1) of this

 section, other reliable information appropriate to the aircraft,

 relating to aircraft performance under expected values of airport

 elevation and runway slope, aircraft gross weight, and wind and

 temperature.

CA will not operate sUAS’s under IFR conditions or when the ceilings are below 1000 feet and the 

visibility is below 3 statute miles. CA’s sUAS’s do not have a published approved Airplane or Rotorcraft 

Flight Manual containing takeoff and landing distance data.
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Equivalent Level of Safety

In adherence to FAA, NTSB, and AFS-80 best practices, the PIC along with the person having

operational control must follow regulations to assure that the weather will be adequate to complete the 

mission in VFR condition.

B. 14 CFR 91.113: Right-of-Way Rules

CA requests an exemption from 14 CFR 91.113 Right-of-way rules, requiring vigilance by each

person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another 

aircraft the right-of-way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of 

it unless well clear.

Capital Aerial, LLC operates small pilotless UAS’s and cannot comply with these rules as they

have been written.

Equivalent Level of Safety

CA operates sUAS’s at or below an altitude of 200 feet AGL, well below the normal operating altitude 

of other aircraft. CA management requires that the Pilot in Command with experience oversee each mission 

and has knowledge of the see-and-avoid rules. A Visual Observer will assist the PIC in looking for aircraft 

entering the operations area. It’s the responsibility of the PIC to cease operations and land the UAS 

immediately whenever an aircraft comes into the vicinity creating a potential threat. Operations will not 

recommence until the threat is clear.

C. 14 CFR. § 91.119: Minimum Safe Altitudes

CA requests an exemption from the minimum safe altitude requirements of 14 CFR 91.119 that

prescribes the minimum safe altitudes under which aircraft may operate:

• Over any congested area of a city, town, or settlement, or over any open air assembly of

 persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of

 2,000 feet of the aircraft.

• Over other than congested areas at an altitude of 500 feet above the surface, except over

 open water or sparsely populated areas. In those cases, the aircraft may not be operated

 closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when it

can be operated "without hazard to persons or property on the surface," provided that "each person operating 

the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

To provide the intended operations, the sUAS is normally operated below 500 feet AGL.

Additionally, due to the nature of the proposed operations, the sUAS will maintain a lateral distance of at 

least 100 feet from inhabited structures, buildings, vehicles, and vessels, and from people not associated 

with the operation.
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Equivalent Level of Safety

Compared to normal aircraft, CA’s multi-rotor aircraft weigh a maximum of 25 pounds, and given 

the lack of flammable fuel, any risk associated with these operations is far less than those that presently 

exist with conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and 

speed of the UAS, as well as the location where it is operated. As set forth in the FAA, NTSB, and AFS-80 

best practices, the sUAS will be operated in a sterile area, where buildings and people will not be exposed 

to operations without their pre-obtained consent. Because of the advance notice to the property owners and 

participants, all affected individuals will be well aware of the planned flight operations prior to 

commencement of operations.

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with aircraft that are

subject to the minimum safe altitude regulations. Finally, the successful safety record of the Phantom 2 

sUAS’s demonstrates that the sUAS can be safely used at these lower altitudes and closer operating 

environments.

D. 14 C.F.R. § 91.121: Altimeter Settings

CA seeks an exemption from 14 CFR 91.121, which requires a person operating an aircraft to

maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure. An exemption is required because the sUAS does not have a 

barometric altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in the FAA,

NTSB, and AFS-80 best practices. CA will confirm the altitude of the launch site shown on the GPS altitude 

indicator before flight. Moreover, the PIC will use the GPS altitude indicator to constantly monitor the 

sUAS's height, thus ensuring operation at safe altitudes.

E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

CA requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR

conditions. Section 91.151 states:

 a. No person may begin 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 cruising speed –

i. During the day, to fly after that for at least 25 minutes; or

ii. At night, to fly after that for at least 45 minutes.

The batteries powering CA’s Phantom 2 provide approximately 25-30 minutes of powered flight. 

To meet the 30 minutes reserve requirement in 14 CFR 91.151. Given the limitations on the sUAS's 

proposed flight area and the location of its proposed operations within a predetermined area, a safety margin 

based on a reserve amount of battery life is needed. CA will not be conducting any sUAS flights at night.

Equivalent Level of Safety
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An equivalent level of safety will be achieved because the operations will be conducted on-site without 

significant transit time by the sUAS. All flights will be planned to terminate with no less than 25% reserve 

battery power still available. This restriction would be more than adequate to return the sUAS safely to its 

planned landing zone from anywhere in its confined area of operation even in the event of an unexpected 

occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel does not include the type of 

risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS, and the 

proximity of the flight operation to the landing zone. Moreover, operation will be limited to controlled areas 

where only people and property owners, or official representatives who have signed waivers will be 

allowed.

F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections

CA also seeks an exemption from the maintenance inspection requirements contained in 14

CFR 91.405(a), 91.407(a) (1), 91.409(a) (2), 91.417(a) and (b). These regulations specify maintenance and 

inspection standards in reference to 14 CFR Part 43. 14 CFR 91.405(a) (stating that each owner or operator 

of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption 

to these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness 

certificate, which the sUAS will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be

performed in accordance with FAA, NTSB, and AFS-80 best practices. The operator will ensure that the 

sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. 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.

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight operations

will only take place in restricted areas for limited periods of time during daylight hours, creates less risk 

than that associated with conventional rotorcraft or fixed wing aircraft performing the same operation.

VI. PUBLIC INTEREST

Granting Capital Aerial, LLC an exemption furthers the public interest in and around the states of 

New York, Vermont, Massachusetts and Connecticut. National policy set by Congress favors early 

integration of sUAS into the national airspace in controlled, safe working environments such as those 

propose in this petition. CA would like to help facilitate safe integration of sUAS’s into mainstream USA 

in the following areas:

Aerial Surveying; As with construction imaging, aerial imaging flights will be used to capture aerial 

photos for the purpose of creating image maps. The image maps will be used to compute volume, create 

3D models, DSM’s, DTM’s, profile and contour lines.

Movies and Event Photography; Whether the shot requires unique views and expansive panning or 

altitude with unique views, the sUAS is designed to hold up under demanding conditions. Because of 
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the autopilot feature with pre-designed mission management and R/C control interrupt, the pilot and 

camera operator can easily create the ultimate shot with HD video or HD still photos. When working 

close in on a closed set the hazards to the actors are substantially reduced due to the size of the sUAS.

Precision Agriculture; This technology, which uses a variety of spectral data, has potential for several

agricultural uses, including: early-generation crop breeding line evaluations, quick and wide-scale 

scouting of croplands for crop conditions and weed densities, grassland conditions and production 

evaluation, detection of noxious weeds and detection of blue green algae blooms in ponds and 

reservoirs. In addition, the technology allows the monitoring of water use and will allow the land owner 

to directly control the quantity of water use.

News Gatherings; Similar to movies and event photography, each news assignment may require a

completely different shot or view of a scene. With budgets for traditional helicopter use being greatly 

reduced, the sUAS is the perfect solution to allow for easy news gathering for a fraction of the cost. The 

sUAS can and will be operated in a sterile area away from the public, while the traditional helicopter 

must hover over persons and property increasing the danger to individuals.

Construction and First Responders; Low level oblique photos and video from several angles are far 

more effective than ground based imagery for displaying the characteristics of large, complex properties 

with several buildings and large trees. The applicants in the past have chartered 2-seat full-sized 

helicopters for this purpose, which has proven more costly than many potential clients have been able 

to afford. The benefits of reduced cost and improved quality of presentation from the UA will be 

valuable to and benefit many buyers and sellers of real property. Additionally, we request that we be 

allowed to use our system to benefit first responders nearby who might require assistance, including fire 

fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application.

Real Estate; The sUAS can be used in all areas of real estate, including commercial, residential and 

industrial properties. Using a sUAS, real estate professionals can create promotional videos, photos and 

unique shots that normal camera aspects cannot capture. CA’s easy-to-use video and photo platforms 

enable properties to stand out, providing dazzling views that are typically shown via expensive computer

animation or costly helicopter rentals. Imagine shooting a view from a high-rise condo in stunning high 

definition that shows your potential customer the actual view from the residence. The remote platform 

is great for new planning, zoning and large developments. Simple and easy-to-use video and photos 

allow for multiple height pictures and elevation views.

VII. Privacy

Capital Aerial, LLC is deeply committed to protecting public privacy. CA knows that many

individuals have concerns about privacy from the operations of sUAS’s. CA has created a privacy notice 

that informs residents, commercial property owners, churches, schools, and governmental organizations of 

our intent to conduct commercial drone operations in proximity to their property.

VIII. Federal Registry Summary

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed:
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Capital Aerial, LLC, seeks an 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) 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 (Page 3)

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)

Approval of this exemption request allows CA to conduct commercial operations with small and

lightweight unmanned aerial systems. CA’s singular vision is to enhance safety of sUAS operations in the 

NAS while reducing risk to the general public and property owners.

The Phantom 2 sUAS, weighing less than 30 pounds and powered by batteries, eliminates virtually

all of that risk given the reduced mass and absence of combustible fuel carried on board. The sUAS is 

transported to the designated mission area and set up there. The sUAS will carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of this small UAS will provide an equivalent level of safety supporting the grant of

the exemptions requested herein, including exempting the applicant from the requirements of several

regulations and allowing commercial operations. These lightweight sUAS’s operate at slow speeds, close 

to the ground, and in a sterile environment. As a result, they are far safer than conventional aerial survey 

and inspection operations conducted with fixed wing aircraft or helicopters.

If additional information is required, or if you have any questions regarding this Petition for

Exemption, please contact the undersigned.

IX. Conclusion

The petitioner is requesting this exemption for the purposes of aerial surveying, precision

agriculture, real estate photography, aerial filmmaking and photography, construction site inspections and 

monitoring, news gatherings and other flight operations. The reason for such a general and broad based 

request is that the petitioner wishes to utilize a business strategy of horizontal integration and maximize 

economies of scope in order to capitalize on opportunities as they may arise in the future without the long 

turnaround time associated with additional exemptions. The petitioner's business model is based on the idea 

of offering ad hoc small UAS services to individuals or companies who wish to employ these services as a 

safe, effective, and legal option to enhance their business or hobby. The petitioner’s own market research 

shows pent up demand for these services currently exists in the real estate market, construction, moviemaking, and other markets are just beginning to emerge. The petitioner has identified Universities and other 
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agencies that could benefit from the operation requested in this application. A quick internet search will 

show that many are currently operating similar UAS in exactly this fashion without, it is assumed, FAA 

authorization. The petitioner has refrained from engaging in commercial use of the UAS. The primary 

purpose of seeking this exemption is to obtain the capability to offer those services while remaining in

compliance. The petitioner has 20 years of experience in marketing/communications, 8 years of radio 

control hobby, 5 years of photography and extensive knowledge relative to the industries and conditions 

that petitioner intends to service.

Best Regards,

Donald Olszowy

Capital Aerial, LLC

Office: (518) 894-7600

Supporting Documents:

Summary Guide

Operations Checklist