February 6, 2016

Unique Perspectives Aerial Photography, LLC

10413 SW Tranquil Way

Wilsonville, OR 97070

(503) 360-8437

uniqueperspectivesllc@outlook.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Subject: Exemption Request to Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14

C.F.R. Part 11, Unique Perspectives Aerial Photography, LLC, is seeking exemption 

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (The 

Reform Act), and 14 CFR Part 11. Unique Perspectives Aerial Photography, LLC is

requesting to be allowed commercial operation of designated Unmanned Aircraft 

Systems (UAS), provided operations are conducted within the conditions outlined 

under current Section 333 of the FAA Modernization and Reform Act of 2012 and 

any subsequent revisions therein. 

Equipment

 DJI Phantom 3 Professional 

 DJI Inspire 1 

 DJI Spreading Wings S900

Types of Operations

The requested exemption would permit the operation of small, unmanned multirotor

aircraft under controlled safe conditions, to provide the following professional services, 

but are not limited to:

 Aerial Survey

 Aerial Photo/video

 Promotional advertising material

 Inspections of real estate properties

 Public entity support operations

 Communications and public infrastructure inspection/monitoring

 Pipeline inspection and patrolling 

 Construction site inspection and monitoring

 Real Estate: Residential & Commercial
 Special Events 

 Engineering inspections

Operations will be safely conducted within federal guidelines, by a FAA Licensed Pilot 

with the assistance of an Observer. Operations would be conducted after carefully 

reviewing, inspecting, and examining the area of aerial operation to ensure the safety of 

persons and property.

Requested Exemption Relief

Exemption request pursuant to Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from:

 14 CFR 21

 14 CFR 45.23 (b)

 14 CFR 61.113 (a) & (b)

 14 CFR 91.7 (a)

 14 CFR 91.9 (b) (2)

 14 CFR 91.103 (b)(1), (b)(2)

 14 CFR 91.109

 14 CFR 91.119

 14 CFR 91.121

 14 CFR 91.151 (a)

 14 CFR 91.203 (a) & (b)

 14 CFR 91.405 (a)

 14 CFR 407 (a)(1)

 14 CFR 409 (a)(2)

 14 CFR 417 (a) & (b)

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 91.7 (a)

14 CFR 91.203 Given the size, weight, speed, and limited operating area associated with 

the UAS aircraft to be utilized, exemption from 14 CFR Part 21 Subpart H

(Airworthiness Certificates) and 91.203 (a) and (b) (Certifications required), subject to 

certain conditions and limitations, is warranted and meets the requirements for an

equivalent level of safety under14 CFR Part 11 and Section 333 of the Reform Act.

The Federal Aviation Act U.S.C. 44701 (f) and 333 of the Reform Act both authorize the 

FAA to Exempt aircraft from the requirement for an airworthiness certificate, upon

consideration of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular UAS. In all cases, an analysis of these criteria

demonstrated that the UAS operated without an airworthiness certificate, in the restricted

environment and under conditions proposed, will be at least as safe, or safer, than a

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate

without the restrictions and conditions proposed. Unique Perspectives Aerial 

Photography, LLC requests an exemption from 14 CFR 91.7 (a) Civil Aircraft 

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

Unique Perspectives Aerial Photography, LLC requests an exemption from 45.23 

Marking of the aircraft because the UAS does not have areas large enough on which to 

mark certain words or phrases. Additionally two -inch lettering is difficult to place on 

such a small aircraft with dimensions smaller than the minimal lettering requirement.

Even though the UAS will have no airworthiness certificate, an exemption may be

needed. The word “Experimental” could be placed on the UAS to comply with 45.29 (f) 

in a size suitable for the available space. The UAS is equipped with LED lights to aid in 

visibility.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command

Under 61.113 (a) and (b) private pilots are limited to non-commercial operations,

however Unique Perspectives Aerial Photography, LLC can achieve an equivalent level 

of safety as achieved by current regulations because the UAS does not carry any pilots or 

passengers. Until new legislation is passed, all Pilots In Command (PIC) will have a 

Sport or Private Pilot’s License, and maintain a FAA current medical certificate.

14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

An exemption to the part will be needed since there is nowhere to place a copy of a flight 

manual on board the UAS.

14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action

Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

is in good condition prior to flight. Inspections will be in accordance with the operation 

manual for each specific UAS. The preflight inspection will account for all potential 

discrepancies, i.e., inoperable components, damaged items, or faulty equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

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

UAS is found to be in a condition for safe flight. 

14C.F.R. 91.109: Flight Instruction 

Section 91.103 provides that no persons may operate a civil aircraft (except a manned 

free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. 

By design, UAS are remotely piloted air craft and do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The FAA has previously 

approved exemptions for aircraft without fully functional dual controls. The equivalent 

level of safety is provided by the fact that neither a pilot nor passengers will be carried in 
the aircraft, the ability to control the UAS via radio signals from the controller, and by the 

size and speed of the aircraft. 

14 CFR 91.119: Minimum Safe Altitudes

Due to the limitation that operations be conducted at or below 400 feet Above Ground 

Level (AGL), an exemption will be necessary to meet 91.119. The typical UAS flight 

will be operated and limited as follows:

 Due to battery life, flights of the UAS are limited to 10-15 minutes 

 All flights will remain under 400 feet AGL. The software provided from DJI has 

limits which will be set at 398 feet.

 Auto return and landing will be set according to the manufacturer’s recommended 

minimum level of battery power.

 All flights of the UAS will be within visual line of sight (VLOS).

 All necessary permissions will be obtained prior to operation.

 Procedures are built into the aircraft to abort flights in the event of safety breaches or 

potential danger.

14 CFR 91.121: Altimeter Setting

The UAS is not equipped with an altimeter setting device. GPS will be used on board the

UAS to determine altitude by reference to the ground (AGL).

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

An exemption from 91.151 will be necessary as the normal flight time will only be 10- 15 

minutes. The UAS is fueled by battery power and a long duration flight is not possible.

Also since all flights will be conducted in Visual Line of Sight (VLOS), this requirement 

is not applicable.

14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration

The UAS fully loaded weighs no more than 55 pounds and is operated without an 

onboard pilot. Therefore, there is no ability or place to carry certification and registration 

documents or to display them on the UAS. An equivalent level of safety will be achieved 

by keeping these documents at the ground flight control station where the pilot flying the 

UAS will have immediate access to them, to the extent they are applicable to the UAS.

14 CFR 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance Inspections

These regulations require the owner/operator to have the aircraft inspected as

prescribed in subpart E of this part. An equivalent level of safety will be maintained

because of the small size and limitations of this UAS. Maintenance will be accomplished

by the operator pursuant to the owner’s manual. The operator will ensure that the UAS is 

in proper working order prior to each flight, perform necessary maintenance, and keep a 

log of maintenance. The operator is the person most familiar with the UASs operation 
and is best suited to maintain in an airworthy condition to provide equivalent level of 

safety.

Summary

In summary, Unique Perspectives Aerial Photography, LLC respectfully requests

exemption from regulations specified above under Section 333 to enable us to operate 

efficient, low-risk commercial UAS operations, for the activities stated above. Unique 

Perspectives Aerial Photography, LLC along with each PIC will respect at all times the 

space and privacy of citizens and property, while keeping the general public safe. 

Granting this request would be in the public interest by allowing our company to provide 

low cost aerial photography, video, and data collection to businesses and individuals 

(public) who would otherwise be unable to afford such service. Other benefits to the 

public from this service are; a reduction in aircraft noise, reduction in pollution, and with 

no fuel on board, the risk of fire due to a crash is all but eliminated. The most important

benefit to the public is that the use of a UAS over conventional aircraft will reduce the 

amount of people and property exposed to hazards during traditional aerial photography. 

The use of a UAS will provide a level of safety at least equal to existing rules and will

only be operated in a safe environment that is strictly controlled. Operations will only be

conducted after a careful review of the area and weather conditions. Safety for all parties 

involved is priority number one.

Sincerely,

Greg Glaze

Unique Perspectives Aerial Photography, LLC