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FROM:			 Aerial	Revelation LLC. 14	July,	2015

Attn:	Mr.	Craig	Cook

1223	Bonneview	Drive

Evansville,	IN	47715

816-372-4298

Craig.Cook@AerialRevelation.com

TO:	 Federal	Aviation	Administration

US	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.	S.E

Washington,	DC	.	20590

SUBJECT: Aerial	Revelation	Petition	for	Exemption	under Section	333	of	the	FAA	Reform	Act

REFERENCES: Exemption	Request	Section	333	of	the	FAA	Reform	Act, Pursuant	to	section	333	of	the	

FAA	Modernization	and	Reform	act	of	2012	(The	Reform	Act),	and	14	C.F.R.	Part	11,

BUNGEE	LLC,	Exemption	No.	11993,	Regulatory	Docket	No.	FAA–2015–1511

§ Used	as	an	example	to	create	this	exemption	request

Aerial	Revelation LLC	,	herby	seeks	and	applies	for	an	exemption	to	the	Federal	Aviation	Regulations	

(FARs)	to	allow	Aerial	Revelation LLC	to	operate	Small	Unmanned	Aircraft	Systems	(UAS)	commercially	in	

airspace	regulated	by	the	Federal	Aviation	Administration	(FAA)	under	the	conditions	and	limitations	set	

forth	in	this	petition.	

The	requested	exemption	would	permit	Aerial	Revelation	LLC	to	operate	a	small	unmanned	aircraft	

system	(UAS)	for	the	purpose	of	providing	an	aerial	photography	and	survey	service	to	municipalities,	

utilities	&	private	consumers.	The	areas	of	use	will	include	both	photo	and	video	in	the	utilities	industry,	

communications	industry,	real	estate	industry,	surveying	industry,	construction	industry,	agricultural	

industry	and	other	industries	as	needed.

The	UAS	will	be	operated	in	airspace	that	is	1)	limited	2)	predetermined	3)	would	provide	added	safety	

enhancements	to	the	already	safe	operations	in	the	industry	presently	using	conventional	aircraft	

system.

Exemption	request	to	Section	333	of	the	FAA	Reform	Act	Plan	11	specific	to	UAS	operations:

• 14	CFR	21	subpart	H;	

• 14	CFR	45.23(b);	

• 14	CFR	61.113(a)	&	(b);	

• 14	CFR	91.103;

• 14	CFR	91.105;	

• 14	CFR	91.109:	

• 14	CFR	91.119(c);

• 14	CFR	91.121;	

• 14	CFR	91.151(a);	

• 14	CFR	91.203	(a)	and	(b);

• 14	CFR	91.405(a);	

• 14	CFR	91.407(a)(1);	

• 14	CFR	91.401(a)(1)	&	(2);	

• 14	CFR	91.417(a)	7	(b).
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Dear	Sir	or	Madam:

Aerial	Revelation	LLC	is	a	newly	formed	limited	liability	company	with	the	purpose	of	commercial	

operation	of	an	Unmanned	Aircraft	System	(UAS),	more	commonly	known	as	a	drone.		Aerial	Revelation	

uses	a	DJI	Inspire1,	as	described	herein and	at	the	manufacturer’s	website.		

(http://www.dji.com/product/inspire-1), The	DJI	Inspire	is equipped	with	camera(s)	and sensors,	and	

would commonly	be	used	for	the	following	purposes:

• Acquire	aerial	photography	and/or	video	for	public	and/or	private	use	including	real	estate,	

architecture,	land	surveying,	engineering	and	other	related	professional	activities.

• Acquire	aerial video	and/or	photography	of	for	public	and/or	private	use	including	

television,	public	events,	cinematography	and	news	gatherings.

• Aerial	inspection/photography	of	residential/commercial	structures	under	contract	with	the	

owners or	local	government	authority.

• Perform	aerial	inspection/photography	of	residential/commercial	utility	infrastructure	

included	but	not limited	to	electrical	power	lines,	wind	turbines	and	cell	towers.

• Perform	aerial video/photography	or	providing	live	video	feed	to	assist	with	rescue	

operations	in	cases	of	an	emergency	or	natural	disaster	only	when	the	local	authorities	or	

government	has	requested	it	by contract	and/or	donation.

As	described	fully	below,	the	requested	exemptions	would	permit the	operation	of	a	UAS	under	

controlled	conditions	in	the	National	Airspace	System	(NAS) that	would	be	a)	limited,	b) controlled,	c)	

predetermined,	and	d)	will	provide	safety	enhancements	such	as	limited	exposure	to flight	crew,	

climbing	crews,	weight	of	vehicles,	speeds	of	usage,	non-use of	volatile	fuels,	etc.

Approval	of	this	exemption	would	thereby	enhance	safety	and	fulfill	the	Secretary	of Transportation’s	

(the	FAA	administrators)	responsibilities	to	“....establish	requirements	for	the	safe operation	of	such	

aircraft	systems	in	the	national	airspace	system.

AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY

The	primary	vehicle	to	be	used	will	be	the DJI	Inspire1.	No	vehicle	operated	by	Aerial	Revelation LLC	will	

be	modified	from	the manufacturers	design	unless	specifically	directed	by	the	same	manufacturer.

As	described	by	EXHIBIT	1	through	EXHIBIT	8 below,	Aerial	Revelation	does	hereby	request	an	

exemption	under	Section	333	of	the	FAA	Reform	Act	Plan	11	specific	to	UAS	operations.		Aerial	

Revelation	operations	will	surpass the	safety	requirements	set	forth	upon persons	and/or	property	using	

conventional	aircraft.	The applicant	agrees	to	adhere	to	the	limitations	and	conditions as	described	in	

the	EXHIBITS	below when	conducting	commercial operations	under	the	FAA	issued	exemption	as	set	

forth	in	the	flight	operations	manual.		
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EXHIBITS

The	information	below	illustrates	how	this	petition	for	exemption	from	14 CFR	§	11.81	is	organized:

FAA	REFERENCES:	 The	FAA	provided	public	guidance	on	the	information	that	the	petition	for	exemption	

to	14 CFR	§	11.81	should	contain:				http://aes.faa.gov/Petition/home.html

EXHIBIT	#1 – Applicant	name	and	mailing address; You	may	include	other	contact	information	such	as	a	

fax	number,	telephone	number,	or	email	address

EXHIBIT	#2 - The	specific	section	or	sections	of	14	CFR	from	which	you	seek	an	exemption	

EXHIBIT	#3 - The	extent	of	relief	you	seek	and	the	reason	you	seek	the	relief	

EXHIBIT	#4 – How	your	request	would	benefit	the	public	as	a	whole;

EXHIBIT	#5 – Reasons	why	the	exemption	would	not	adversely	affect	safety,	or	how	the	exemption	

would	provide	a	level	of	safety	at	least	equal	to	the	existing	rule;

EXHIBIT	#6 – A	summary	the	FAA	can	publish	in	the	Federal	Register	stating:

• The	rule	from	which	you	seek	the	exemption

• A	brief	description	of	the	exemption	you	seek

EXHIBIT	#7 – Presents	additional	information,	views,	and	arguments	available	to	support	Aerial	

Revelation’s	exemption	request.

EXHIBIT	#8 - If	you	want	to	exercise	the	privileges	of	your	exemption	outside	the	United	States,	you	

must	state	the	reason
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Exhibit #1

Your	name	and	mailing	address.		You	may	include	other	contact	information	such	as	a	fax	number,	

telephone	number,	or	email	address;

Craig	Cook

1223	Bonneview	Drive,	

Evansville,	Indiana	47715

816-372-4298

Craig.Cook@AerialRevelation.com
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Exhibit #2

The	specific	section	or	sections	of	14	CFR	from	which	you	seek	an	exemption

• 14	CFR	part	21,	Certification	procedures	for	products and	parts,	and

• Subpart	H—Airworthiness	Certificate

• Any	associated	noise	certification	and	testing	requirements	of	part	36.

• 14	CFR	21	subpart	H;	

• 14	CFR	45.23(b);	

• 14	CFR	61.113(a)	&	(b);	

• 14	CFR	91.103;

• 14	CFR	91.105;	

• 14	CFR	91.109:	

• 14	CFR	91.119(c);

• 14	CFR	91.121;	

• 14	CFR	91.151(a);	

• 14	CFR	91.203	(a)	and	(b);

• 14	CFR	91.405(a);	

• 14	CFR	91.407(a)(1);	

• 14	CFR	91.401(a)(1)	&	(2);	

• 14	CFR	91.417(a)	7	(b).
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Exhibit #3

The	extent	of	relief	you	seek	and	the	reason	you	seek	the	relief;

• The	petitioner	requested	relief	from	14	CFR	part	21,	Certification	procedures	for	products	

and	parts,	Subpart	H—Airworthiness	Certificates.			

• Aerial	Revelation	seeks	exemption	based	on	the	enhanced	safety	achieved	using	an	

unmanned	aircraft	(UA)	with	the specifications	described	herein.		Safety	is	increased	by	UAS	

operations	through	carrying	no	passengers	or	crew,	rather	than	a	manned	aircraft	of	

significantly	greater	proportions	carrying	crew	in	addition	to	flammable	fuel.		

Based	on these	benefits, Aerial	Revelation	(the	applicant)	requests	concurrence	from	the	

FAA	that	Aerial	Revelation	UAS	operations	are in	the	public’s	best interest.
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Exhibit #4

How	your	request	would	benefit	the	public	as	a	whole;

• Reduced	Resource	Consumption – Drones	are	far	more	efficient	than	helicopters	and	small	

airplanes.		The	DJI	Inspire1 is	battery	operated	and	is	very	efficient.

• Environmentally	Friendly - Electric	drones	do	not	pollute	the	air	like	gasoline	helicopters	or	

small	aircraft.		They	will	not	leak	flammable	fuel	either.

• Safe – The	DJI	Inspire	drone	Aerial	Revelation	plans	to	use	will:	

o Will	weigh	less	than	55	pounds	and	is	much	smaller	than	manned	aircraft	(which	

would	cause	far	less	property	damage	and	prevent	loss	of	human	life	in	the	event	of	

mechanical,	electrical,	or	operator	failure	(as	compared	to	helicopters	or	small	

aircraft).		

o Will	be	more	safe	than	manned	aircraft	because	it	will	not	carry	any	passengers	or	

crew

o Will	not	carry	flammable	fuel	that	could	damage	property	or	the	environment.

o Will	promote	the	safety	of	damage	surveyors	because	it	will	prevent	the	need	for	

people	to travel	into	dangerous	or	unsafe	areas	to	survey	damage.

• Public	Service – Aerial	Revelation	photography	and	videography	will	serve	the	public	by	

capturing	images	(and	telemetry)	that	can	be	used	for	land	surveys,	home	inspections,	

infrastructure	inspections	(like	transportation),	industrial	inspections,	3D	mapping	of	

structures,	and	survey	of	areas	not	easily	reachable	or	hazardous	to	humans	(example	–

survey	of	storm	damages	where	water,	gas,	&	electric	may	be	dangerous).		

• Aid	to	Law	Enforcement - Aerial	Revelation	services	(in	conjunction	with	law	enforcement)	

can	be	used	to	cover	vast	swaths	of	area	quickly	when	search	and	rescue	operations	are	

underway.

• Entertainment – Aerial	Revelation	will	capture	aerial	photography	&	footage	to	be	used	in	

demonstration	videos,	cinematography,	marketing,	advertising,
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Exhibit #5

Reasons	why	the	exemption	would	not	adversely	affect	safety,	or	how	the	exemption	would	provide	a	

level	of	safety	at	least	equal	to	the	existing	rule

Aerial	Revelation	will	not	adversely	affect	safety	due	to	the	following	safeguards	that	will	be	in	place:

• Aerial	Revelation	will	use	the	DJI	Inspire1 Drone,	which	is	an	unmanned	aircraft	that	weighs	less	

than	55	lbs.	(25	kg).	

o Product	information	can	be	found	at	the	manufacturer’s	website	located	at:	

http://www.dji.com/product/inspire-1

• Aerial	Revelation	operator	Craig	Cook	will	maintain	visual	line-of-sight	(VLOS)	only;	the	unmanned	

aircraft	will	remain	within	VLOS	of	the	operator	and/or	visual	observer.

• Minimum	crew	for	each	operation	will	consist	of	the	UAS	pilot in	control	(PIC),	the	visual	observer	

(VO)	and	may	include	(but	not	limited	to)	a	camera	operator.

• At	all	times	the	small	unmanned	aircraft	will	remain	close	enough	to	the	operator	(Craig	Cook)	for	

the	operator	to	be	capable	of	seeing	the	aircraft	with	vision	unaided	by	any	device	other	than	

corrective	lenses.

• Maximum	flight	time	for	each	operational	flight	will	be	30	minutes.	Flights	will	be	terminated	at	25%	

battery	power	reserve	or	30	minutes	of	flight	time	whichever	occurs	first.

• Aerial	Revelation	will	not	operate	any	small	unmanned	aircraft	over	any	persons	not	directly	

involved	in	the	operation.

• Aerial	Revelation	will	only	execute	Daylight-only	operations	(official	sunrise	to	official	sunset,	local	

time).

• Aerial	Revelation	operator	and	drone	will	always	yield	right-of-way	to	other	aircraft,	manned	or	

unmanned.

• Aerial	Revelation	will use	an	additional	person	as	a visual	observer	(VO)	during	flight	operations.		

Safety	and	adherence	to	the	FAA	observation	&	control	guidelines	will	dictate	whether	an	additional	

VO	is	needed.

• First-person	view	camera	will	not	be	used	to	satisfy	the	“see-and-avoid”	requirement.		The	“seeand-avoid”	requirement	will	be	accomplished by	an	operator	pre-site	survey,	pre-flight	operations	

briefings,	and	visual	line	of	site	observance	during	flight	operations.

• All	flights	will	occur	under	visual	flight	rules	meteorological	conditions	(VFR	only).

• The	PIC	(Pilot	in	Charge)	and	VO (Visual	Observer) will	be	able to	communicate	by	voice	and/or	radio

at	all	times.		No	texting	shall	be	allowed	during	operations.

• 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.

• Aerial	Revelation	shall	not	exceed	the	maximum	airspeed	of	100	mph	(87	knots).

• Aerial	Revelation	shall	not	exceed	the	maximum	altitude	of	400	feet	above ground	level	(AGL).

• Aerial	Revelation	shall	not	exceed	the	minimum	weather	visibility	of	3	miles	from	control	station.

• Aerial	Revelation	shall	not	operate	in	Class	A	(18,000	feet	&	above)	airspace.

• Aerial	Revelation	shall	not	operate	in	Class	B,	C,	D	and	E	airspace.

• Aerial	Revelation	shall	not	operate	in	in	Class	G	airspace.

• Aerial	Revelation	shall	not	allow	any	person	to	act	as	an	operator	or	VO	for	more	than	one	

unmanned	aircraft	operation	at	one	time.

• Aerial	Revelation	shall	not	allow	any	careless	or	reckless	operations.
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• Aerial	Revelation	shall	require	preflight	inspection	by	the	operator	prior	to	every	flight	operation	to	

assure	the	UAS	is	in	a	condition	that	is	safe	for	flight.		Should	the	pre-flight	inspection	discover	any	

potential	discrepancies	(e.g.	inoperable	components,	items,	or	equipment),		the	aircraft	shall	be	

prohibited	from	operating	until	the	necessary	maintenance	has	been	performed	and	the	UAS	is	

found	to	be	in	a	condition	for	safe	flight.

o If	maintenance	or	alterations	that	affect	the	UAS	operation	or	flight	characteristics	have	been	

conducted	(e.g.	replacement	of	a	flight	critical	component),	the	drone	shall	undergo	a	

functional	test	flight	prior	to	conducting	any	operations.		The	functional	test	flights	shall	only	

be	conducted	by	the	operator	with	a	VO	and	shall	remain	at	least	500	feet	from	other	people.	

The	functional	test	flight	shall	be	conducted	in	such	a	manner	so	as	to	not	pose	an	undue	

hazard	to	persons	and	property.

o The	operator	shall	follow	the	UAS	manufacturer’s	maintenance; overhaul,	replacement,	

inspection,	and	life	limit	requirements	for	the	aircraft	and	aircraft	components.

• Aerial	Revelation	shall	not	allow	any	operator	or	person	to	operate	a	small	unmanned	aircraft	if	he	

or	she	knows	or	has	reason	to	know	of	any	physical	or	mental	condition	that	would	interfere	with	

the	safe	operation	of	a	small	UAS.

• Pre-programmed	aerial	GPS	safety	points	in	the	drone	software	return	the	drone	to	a	known	safe	

location	in	the	event	of	loss	of	communications.

• Aerial	Revelation	drones	will	be	pre-programmed	to	fly	on	known	safe	routes	whenever	possible	

while	the	operator	is	observing	with	full	override	remote	control.

• Drones	are	pre-programmed	to	land	in	a	known	safe	location	on	the	ground	in	the	event	of	any	kind	

of	failure	(damage,	low	battery,	interference,	etc.)

• PIC	and	VO	shall	command	the UAS	to	automatically	return	home	and	land	in	event	that	either	

member	is	incapacitated.

• No	Fly	Zones - Where	‘No	Fly	Zones’	are	designated,	Aerial	Revelation	will	NOT	operate	in	those

environments:

o 5	Nautical	Miles	(NM)	from	an	airport	having	an	operational	control	tower;	or

o 3	NM	from	an	airport	with	a	published	instrument	flight	procedure,	but	not	an	operational	

tower;	or

o 2	NM	from	an	airport	without	a	published	instrument	flight	procedure	or	an	operational	

tower;	or

o 2	NM	from	a	heliport	with	a	published	instrument	flight	procedure.

• Aerial	Revelation	will	use	DJI	Inspire1	drone	software	and	hardware.		The	DJI	Inspire	drone	is	

industry	proven	and	thoroughly	validated	to	perform	in	accordance	with	the	highest safety	

standards.		A	few	of	the	software	safety	features	are	listed	below:

o DJI	software	enforces	programmed	‘No	Fly	Zones’	around	all	known	existing	airports

o DJI	software	enforces	flight	altitude	restrictions	outside	of	airport	‘No	Fly	Zones’	to	a	15	

degree	incline	radiating	out	from	each	airport.

o DJI	continually	updates	software	to	add	additional	‘No	Fly	Zones’	around	national	borders	and	

restricted	facilities.		

o Details	can	be	found	here:		http://flysafe.dji.com/no-fly
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Exhibit #6

A	summary	the	FAA	can	publish	in	the	Federal	Register	stating:

• The	rule	from	which	you	seek	the	exemption

• A	brief	description	of	the	exemption	you	seek

• Aerial	Revelation	requests	Exemption	to	Section	333	of	the	FAA	Reform	Act	Plan 11	specific	to	

UAS	operations:			(NOTE:		See	Exhibit	7	below	for	descriptions)

• 14	CFR	21	subpart	H;	

• 14	CFR	45.23(b);	

• 14	CFR	61.113(a)	&	(b);	

• 14	CFR	91.103;

• 14	CFR	91.105;	

• 14	CFR	91.109:	

• 14	CFR	91.119(c);

• 14	CFR	91.121;	

• 14	CFR	91.151(a);	

• 14	CFR	91.203	(a)	and	(b);

• 14	CFR	91.405(a);	

• 14	CFR	91.407(a)(1);	

• 14	CFR	91.401(a)(1)	&	(2);	

• 14	CFR	91.417(a)	7	(b).

• Brief	description	of	the	exemption	Aerial	Revelation	seeks:		

o Aerial	Revelation	seeks	to	operate	an	unmanned	aircraft	system	(UAS)	to	perform	aerial	

data	collection,	capture	aerial	photography,	videography,	and	provide	survey	services	in	

the	utilities,	communications,	real	estate,	construction,	agricultural,	and	other	various	

industries	as	needed.		UAS	operations	will	provide	quality	data	at	lower	cost	and	higher	

safety	than	traditional	manned	aircraft	system	alternatives.
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Exhibit #7

Exhibit	#7 presents	additional	information,	views,	and	arguments	available	to	support	Aerial	

Revelation’s	exemption	request.

FAA	REFERENCE MATERIAL:		

https://www.faa.gov/uas/legislative_programs/section_333/how_to_file_a_petition/media/section3

33_public_guidance.pdf

“In	seeking	authorization,	petitioners	will	require	exemptions	from	regulations	with	which	they	cannot	

fully	comply.	The	table	below	provides	guidance	regarding	regulations	from	which	a	petitioner	may	

require	exemption.	However,	some	proposed	operations	may	require	exemption	from	regulations	not	

listed	here,	while	others	may	not	require	exemption	from	all	regulations	listed	here.”

AERIAL	REVELATION	EXEMPTION	ARGUMENTS:

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

The Unmanned	Aerial	System	(UAS) will	operate at 55lbs	or	less	(Gross Weight),	carry neither	a	pilot	nor	

passenger,	carry no	explosive	materials	or	flammable	liquid	fuels,	and	operate within	a	secured	and	predetermined	designated	area,	at	altitudes	NOT to	exceed	400	feet	Above	Ground	Level	(AGL) and	NOT

exceed	speeds	in	excess of	100	MPH.
Page	|	12

14	C.F.R.	Sec	91.105	Flight	crew	members	at	station

Exemption	requires	the	Pilot	In	Charge	(PIC) may	not	leave	his	station	nor	shall	Visual	Observer	(VO)

leave	his	station.	In	event	that PIC	or	VO	become	incapacitated,	UAS	is	to	automatically	return	to	

designated	landing	area.

14	CFR	Sec	91.109	Flight	Instruction	(Dual	Controls)

14	CFR	Sec	91.109	requires	that	no	person	shall	operate	a	civil	aircraft	for	flight	instruction	unless	the	

aircraft	has	fully	functioning	dual	controls.		UA and	Remote	controlled	aircraft	by	design	do	not	have	

dual	controls; to	do	so	on	a	radio	controlled	aircraft	would	lower	the	ability	to	safely	operate	the	UAS.	

This	section	cannot	reasonably	apply

14	C.F.R.	Sec	45.23(b).	Marking	of	the	Aircraft

Although	exemption	from	said	section	cannot	benefit	nor	exceed current	stipulations,	physical	

limitations	of	UAV	are	reality,	such	as	cabins,	letter	size,	etc. The	UAV	will	operate	under	the	control	of	

the	PIC	with	registration	lettering	sized	to	fit	fuselage	in	compliance	of	said	section	45.23(b)	under	

conditions	and	or	limitations	deemed	mandatory	by	FAA. My	colleges and	I shall	be	held responsible	for	

compliancy,	for the Public’s	safety and	for	the	safety	of the	shared	air	space while	performing	

operations. We	shall	be	responsible to	identify	the	vehicle	and	enforce	the	accountability	of	this	

growing	industry.

14	C.F.R.	Sec	61.113(a)	and	(b):	Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command

By	current	regulations	because	the	applicant’s	UAS	does	not	carry	passengers,	or	property.	The	use	of

UAS	is	far	less	dangerous	(weight,	speed,	fuel)	than	the	inherent usage	of	commercial	activities	outlined	

in	14	CFR.16.	The	pilot	in	command	shall	have	a	current	state	driver’s	license which	will	equal	if	not	

exceed	safety	regulations	outlined	in	14	CFR 16.113.(a)	&	(b).

14	C.F.R.	Sec.	91.103:	Preflight	Action:

Exemption	is	requested	due	to	fact	that FAA	rotor	flight	manuals	are not	available	for	UAV.	The	PIC	will	

take	all	actions	as	stated	in	Flight	Operations	Manual	(FOM),	under	normal	procedures	included	but	not	

limited	to	review	of	weather,	examination	of	batteries	for	flight	time	analysis,	landing	and	takeoff	

distances	as	well	as	flight	and	aircraft	performance	in	flight.

14	C.F.R.	Sec	91.119;	Minimum	Safe	Altitudes

Mandates	safe	altitude	for	operation	of	civil	aircraft	and	allows	helicopters	to	operate	less	then	

minimums	prescribed,	providing	the	person	operating	helicopter	complies	with	any	route	with	and	or	

altitudes	prescribed	for	helicopter	by	the	FAA.		Being	that	UAV	is	of	helicopter	standards	and	operations,	

a	request	for	exemption	to	operate	at	altitude’s	not	to	exceed	400	feet	AGL	or	not	more	than	400	feet	

above	any	elevated	platform	from	which	take	off	is	necessary.	In	the	event	of	such	particular	flight	plan,	

property	owners,	filming	crews	and	other	personnel	impacted	would	all	be	briefed	as	to	safety	and	

conduct	procedures	during	flight.		Air	Traffic	Control	(ATC)	having	jurisdiction	in	such	area	would	be	

briefed	as	well.
Page	|	13

14	C.F.R.	Sec	91.121	Altimeter	Settings

The	requirement	of	PIC	is	to	use	altimeter	as	means	to	navigate	aircraft	to	cruise	altitudes	to	and	from	

corresponding	airports	as	predetermined	in	flight	plan,	unless	ordered	otherwise.	 As	the	UAS	has	no	

barometric	altimeter,	but	instead	uses	GPS	altitude	read	out,	an	exemption	is	needed.		Per	a	pre-flight	

check	list	and	live	flight	data	monitoring,	the	altitude	of	launch	site will	be	predetermined	and	therefore	

calculated	into	the	UAS- GPS	indicator	before	flight.

14	C.F.R.	Sec	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Co	

Fuel	requirements	for	flight; The	maximum	flight	time	under	ideal	conditions	is	30	minutes	with	the

current	manufacturers	battery	pack.	The	proposed	rule	under	this	exemption	would	require	the	UAS	to	

return	to	its	point	of	launch	if	its	battery	reaches	less	than	25%.		This provides	a	higher	standard	of	

safety	when	applied	to	a	UAS.

14	C.F.R.	Sec	91.405(a);	407(a)(1);	409(a)(2);	417(a)	&	(b):	Maintenance	Inspections

Referring	to	maintenance,	preventive	maintenance,	and	alterations	to	the	UAS.	 The	operator	will	

provide	minor	maintenance	and	inspection	to	the	UAS,	documented	as	outlined	in	the	operational	and	

safety	guidelines.	Given	the	size	and	simplicity	of	the	UAS	combined	with	the	operational	and	safety	

guidelines	outlined	in	this	petition, the	operator	shall maintain	or	exceed	the	required	level	of	safety.		

Manufacturer	‘best	practices’	guidelines	shall	be	followed	for	maintenance	&	upkeep,	and	all	

maintenance	performed	shall	require	structured	testing	prior	to	any	flight	operations.
Page	|	14

Exhibit #8

Exercising	privileges	of	exemption	outside	the	United States

Aerial	Revelation	does	not	wish	to	provide	services	or	request	an	exemption	outside	of	the	United	

States.