1 Todd Massey Owner Operator Aerial Impressions, LLC

414

- 899

- 8512 aerialimpressionsMKE@gamil.com

Dear Madam or Sir,

Aerial Impressions is petitioning the Federal Aviation Administration (FAA) for an exemption to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 CFR Part 11 The exemption would allow operation of the DJI Phantom 2 and DJI S1000

unm anned aircraft systems (UAS) for the purpose of supporting the agriculture industry, aerial photography/video and land surveying. this document will outline requested relief from regulations pertaining to this exemption.

Aerial Impression agrees to operat e within the boundaries set forth by this exemption. Along with rules and regulations that the FAA has in place Aerial Impressions plans to use additional safety precautions were they see fit to ensure safe sUAS operations. Implementation of lightweight small

- unmanned systems is a tool that can greatly improve the safety standards of or National Airspace System (NAS). sUAS can fly operations that would traditionally would require manned aircraft, which carry pilots, gallons of flammable fuel. Please All ow Aerial Impressions to offer sUAS operations to its local market to promote the safe efficient and responsible use of sUAS.

Thank you for your time,

Todd Massey Owner Operator Aerial Impressions, LLC

414

- 899

- 8512 aerialimpressionsMKE@gamil.com2 

## Table of Contents

Glossary of Abbreviations..................................... ...............................2

List of Attachments...............................................................................3

Introduction and Interest of Petitioner...................................................3

Unmanned Aerial Systems.....................................................................3

Equipment List..................................................................4

Unmanned Aircraft Pilot in Command (PIC).........................................6

Operations of sUAS ............................................................................... 6

Requested Exemptions from Regulations .............................................10

Public Intere st........................................................... ..............................13

Conclusion................................................................ ..............................13



## Glossary of Abbreviations

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

MAAP Mid Atlantic Aviation Partnership

NAS National Airspace System

PIC Pilot in Command

sUAS Small Unmanned Aircraft Systems

VFR Visual Flight Rules

VMC Visual Meteorological Conditions

VO Visual Observer

VLS Visual Line of Sight3 

## LIST OF ATTACHMENTS

Futaba 14sg operational manual

A2 Flight Control operational manual

DJI S1000+ operational Manual

DJI Phantom 2 operational manual

Naza M flight control operational manual



## Section 1: Introduction and Interest of Petitioner

Aerial Impressions is a small business lo cated in southeastern Wisconsin that intends to use two current DJI model UAV platfor ms, to gather images for indust ries such as of Real estate, Precision Framing, Geo

- Reference Mapping and Golf courses Photography . Aerial Impressions is committed to offering safe and responsi ble sUAS flight operations. It shall be the intent of every sUAS operator to make a responsible effort to not invade a person's reasonable expectation of privacy when operating the UAS while performing safe flight operations. When operating the sUAS, Aeria l Impressions operators will abide by all FAA Regulations for flight and receive the proper authorization for flight.



## Section 2: Unmanned Aerial Systems
General Information Pertaining to All Proposed UAS

Aerial Impressions will operate less than fifty

- fiv e pound sUAS, for the ability to conduct aerial imagery and videography, with payloads capable of supporting these missions.

Prior to each flight the PIC shall inspect the sUAS to ensure it is in a condition for safe flight. If the inspection reveals a con dition that affects the safe operation of the sUAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. Ground Control Station will be included in pr eflight inspections as well. Maintenance and Alterations must be properly documented in aircraft records. All discrepancies noted shall be documented as described in the Aerial Impressions Operators Manual pg.2 (Organization)

Any maintenance or alterati ons made to the sUAS shall be documented in a logbook as well as undergo test flight before it can return to service. Any repairs or alterations must meet the manufacturer's guidelines with particular attention to flight critical components that may not be4 addressed in the manufacturer’s manuals. Only personnel who are authorized shall perform such operations.

Aerial Impressions will follow all manufacturer’s sUAS aircraft/component, maintenance, overhaul, replacement, inspection and life limit requirements , Aerial Impressions shall carry out their maintenance, inspections and record keeping requirements, in accordance with the operator’s manual. Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight hours, des cription of work

Each sUAS operated under the proposed exemption shall comply with all manufacturer System and Safety Bulletins.

Aerial Impressions technicians will receive and document training referenced in the manufacturer’s operations manual.

Before conducting operations, the radio frequency spectrum used for operation and control of the sUAS shall comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.



## Equipment List

DJI Phantom 2

Aerial Impressions seeks an exemption to operate DJI Phantom 2 sUAS, for compensation or hire. The DJI Phantom 2 is comprised of a quad

- rotor unmanned aircraft and a handheld ground control station. The Phantom II has a maximum gross weight of approximatel y 2.8 pounds, diameter (rotor span) 23.75 inches, width of 12.5 inches, and height of 8.1 inches. The Phantom II is equipped with four rotors driven by four lithium polymer battery powered electric motors.

Design and operational characteristics are provide d in DJI Phantom 2 Operating Manual (Page 35). Flight crews shall conduct pre

- flight inspections as documented in DJI Phantom 2 Operating Manual (Page 24)

ATTACHMENTS

DJI Zemuse H3

- 3d Gimbal

DJI ISOD mini DJI 2.4ghz. Data link 14sg Futaba radio transmitte r Gopro Hero 3+ DJI Naza M Flight controller5 Phantom Specifications Please refer to (Sec. 8.1) in the provided Phantom Operating Manual.

Nazi M Flight Control Specifications Please refer to (Page 23) in the provided Nazi Flight Control Manu al

Futaba 14sg specifications Please refer to (Page 11) of the Futaba 14sg Control Manual



### DJI S1000+

Aerial Impressions seeks an exemption to operate a DJI

- S1000 sUAS for compensation or hire.

The DJI

- S1000+ is comprised of a multi

- rotor unmanne d aircraft and two handheld ground

control stations. The DJI

- S1000 has a maximum gross weight of approximately 24 pounds, diagonal wheelbase of 41.4 inches, and height of approximately 18 inches. The DJI

- S1000 is equipped with eight rotors driven by eight lithium polymer battery powered electric motors.

Design and operational characteristics are provided in DJI S1000+ Operating Manual (Page 22).

Flight crews shall conduct pre

- flight inspections as documented in DJI S1000+ Operating Manual (Page 4).

ATTACHMENTS DJI A2 Flight Control

DJI Zemuse Gimbal for either Panasonic GH4 or Canon Mark III

DJI ISOD DJI Light Bridge 2 Futaba 14sg Radio Transmitter

S1000 Specifications Please refer to (Page 22) of the S1000+ Operating Manual

A2 Flight c ontrol specifications Please refer to (Page 49) of the A2 Flight Control Manual

Futaba 14sg specifications Please refer to (Page 11) of the Futaba 14sg Control Manual



## Section 3: Unmanned Aircraft Pilot in Command (PIC)

Aerial Impressions Flight Crew, including PIC and Visual Observers (VO), will be qualified as directed by Aerial Impressions Operation Manual pg.3 (operators)

All flight crewmembers, including PIC and VO, will have an understanding of, and comply with,

Title 14 C ode of Federal Regulations, and/or Agency directives and regulations, applicable to the6 airspace where the sUAS will operate. Specifically all flight crew members will receive training on the rules and responsibilities described in 14 CFR Part 91 Sections 91.111, 91.113 and 91.115 regarding cloud clearance, flight visibility and the pilot controller glossary, including standard ATC phraseology and communication.

The PIC must possess at least a current private pilot certificate and third class medical certif icate. The PIC must also meet the flight review requirements specified in 14 CFR Section 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate.

Prior to operations conducted for the purpose of aerial imagery and videography (or simila r operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR Section 61.51(b), a minimum of 25 hours of total time as a sUAS pilot and at least ten hours logged as a sUAS pilot with similar sUAS type (fixed wing or rotary). P rior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience building flights are requested to be conducted under this grant of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience building flights, all persons not essential for flight operations will be considered non

- participants and the PIC will operate the sUAS with appropriate distance from non

- participants in accordance with 14 CFR Section 91.119. operations), the PIC must have accumulated and logged in a manner consistent with 14 CFR Section 61.51(b), a minimum of five hours as a sUAS PIC operating the make and model of the

sUAS to be utilized for operations under this requested exemption, and three take

- offs and landings in the preceding 90 days. Training, proficiency, experience

- building, and take

- off and landing currency flights are requested to be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience building, and take

- off and landing currency flights all personnel not essential for flight operations are considered non participants, and the PIC must opera te the sUAS with appropriate distance from nonparticipants in accordance with 14 CFR Section 91.119.

All operations must utilize a VO. The VO may be used to satisfy the Visual Line of Sight (VLOS) requirement as long as the PIC always maintains VLOS capabi lity. The VO and PIC must be able to communicate verbally at all times. This condition and limitation is consistent with all FAA approved Exemptions



## Section 4: Operations of sUAS

At all times the sUAS must remain close enough to the operator for the operator to be capable of seeing the aircraft with vision unaided by any device other than corrective lenses.

Small unmanned aircraft may not operate over any persons not directly involved in the operation.

Daylight

- only operations (official sunrise to o fficial sunset, local time).7 Must yield right

- of

- way to other aircraft, manned or unmanned.

First

- person view camera cannot satisfy “see

- and

- avoid” requirement but can be used as long as requirement is satisfied in other ways.

Maximum airspeed of 30 mph

Maximum altitude of 400 feet above ground level.

Minimum weather visibility of 3 miles from control station.

No operations are allowed in Class A (18,000 feet & above) airspace.

Operations in Class B, C, D and E airspace are allowed with the required ATC permission.

Operations in Class G airspace are allowed without ATC permission

No person may act as an operator or VO for more than one unmanned aircraft operation at one
time.

No careless or reckless operations.

Requires preflight inspection by the operat or.

The sUAS shall remain clear and yield the right of way to all other manned aviation operations
and activities at all times.

The sUAS shall be operated at an altitude of no more than 400 feet above ground level (AGL). All altitudes reported to ATC will be in feet.

The multi

- rotor sUAS shall not be flown at a ground speed exceeding 30 mph.

sUAS Operations will be conducted under visual meteorological conditions (VMC). The sUAS will not be operated less than 500 feet below or less than 2000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

If the sUAS loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered.

The sUAS PIC must abort the flight in the event of unpredicted obstacles or emergencies in
accordance w ith operating documents.

The sUAS PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the sUAS with 25% battery p ower remaining.

The sUAS operated in accordance with this proposed exemption shall be identified by serial numbers, registered in accordance with 14 CFR part 47, and have identification (Number)8 markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

The sUAS documents required under 14 CFR 91.9 and 91.203 shall be available to the PIC at the Ground Control Station of the sUAS anytime the aircraft is operating. Those documents shall be
available to the Admin istrator or any law enforcement official upon request.

Any sUAS incidents, accidents or flight operations that transgress the lateral or vertical boundaries of the operational area as defined by the applicable COA shall be reported to the FAA’s UAS Integ ration Office (AFS

- 80) within 24 hours. Accidents shall be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:

www.nts b.gov

.

Unless otherwise specified in this petition, the sUAS PIC, and the sUAS operations shall comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61 and 91.



## Intended Area of Operations

The sUAS shall not be operated over congested or densely populated areas. These areas include but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Char ts (TAC). Each work site will also be
evaluated based on local conditions.

Operations of sUAS may be conducted at distances less than 500 feet from participating persons, vessels, vehicles or structures that perform an essential function in connection w ith these special purpose operations. Operations closer than 500 feet from the PIC, VO, operator trainees and essential persons are permitted when operationally necessary; but never so close to present an undue hazard. This is consistent with Exemption N o. 11138.

Operations of sUAS may be conducted at distances less than 500 feet from unoccupied vessels, vehicles or structures owned by the land owner/controller when the land owner/controller grants such permission, and the PIC makes a safety assessment of the risk from operations and determines that it does not present an undue hazard to persons or property. This is consistent with Exemption No. 11138.

Flight operations will be conducted at least 500 feet from all nonparticipating persons unless barriers or structures are present that sufficiently protect nonparticipating persons from the sUAS and/or debris in the event of an accident. HAZON shall ensure that nonparticipating persons remain under such protection. If a situation arises where nonp articipating persons leave such protection and are within 500 feet of the sUAS, flight operations will cease immediately. This is consistent with Exemption No. 11138.

All operations of sUAS shall be conducted with the permission from the land owner/con troller or authorized representative. Permission from the land owner/controller or authorized representative will be obtained for each flight to be conducted

.9 

## Airport Proximity

The sUAS will not operate within 5 nautical miles of an airport reference poi nt 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 t he airport management will be made available to the Administrator upon request. This is consistent with Exemption No 11159.



## Visual Line of Site

The sUAS must be operated within VLOS of the PIC and VO at all times. This requires the PIC
to be able to us e human vision to see the sUAS unaided by any device other than corrective lenses, as specified on the PIC’s FAA issued medical certificate.

All sUAS operations must utilize a VO. The VO may be used to satisfy the VLOS requirement as long as the PIC alw ays maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. The PIC and VO must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the functions.

The sUAS will not be operated by the PIC from any moving device or vehicle. Operations will not be conducted during night as defined in 14 CFR 1.1.



## PreFlight Safety (14 CFR § 91.7(b)) Aerial Impressions will conduct preflight safety risk assessments to determine that the sUAS is in a condition for safe flight (14 CFR Section 91.7(b)) and that the planned operation can be completed safely. Specific procedures are addressed in Aerial Impressions Operators manual pg.6



## Flight Standards District Offices (FSDOs)

Aerial Impressions operations do not require a notification to Flight Standards District Offices (FSDOs). They will not be engaging in the type of sUAS that would warrant contact.



## Certificate of Waiver or Au thorization

Aerial Impressions shall obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this requested grant of exemption. Additionally, Aerial Impressions will request a Notice to Airmen (NOTAM) not more than 72 hours, but not less than 48 hours prior to the operation

. 

## Weather10 sUAS Operations will be conducted under visual meteorological conditions (VMC). The sUAS will not be operated less than 500 feet below or less tha n 2000 feet horizontally from a cloud or when visibility is less than 3 statute miles fr om the PIC. All PIC must also abide by all sUAS manufacturer's guidelines for weather operation limitations and standards.



## Section 5: Requested Exemptions from Regulations

Considered Regulation Title Recommended Action

14 C.F.R Part 21.185 Airworthiness
Certificate Aerial Impressions recommends that in consideration of the size, weight, speed and limited operating
area associated with these aircraft and their operation, the Secretary of Transportation determines that
these aircraft meet the conditions of
Section 333. Relief is not

necessary

.

14 C.F.R. Part 45.23(b) Display of marks Aerial Impressions sUAV shall be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. Relief is not necessary.

14 C.F.R. Part 61.113(a) Private pilot privileges
and limitations The FAA has found in previous grants of exemption that a PIC with a private pilot certificate operating a sUAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. Request relief with
limitations and c onditions specified in this petition.

14 C.F.R. Part 61.133(b) Commercial pilot privileges and The FAA has found in previous grants of exemption that a PIC with a11 limitations private pilot certificate operating a sUAS would not adversely affect operation s in the NAS or present a hazard to persons or property on the ground. Request relief with
limitations and conditions specified in this petition.

14 C.F.R. Part 91.7(a) Civil Aircraft
Airworthiness Aerial Impressions recommends that
in consideration of t he size, weight, speed and limited operating area
associated with this aircraft and its operation, the Secretary of Transportation determines that these
aircraft meet the conditions of
Section 333. Relief is not

necessary

.

14 C.F.R. Part 91.9(b)(2) &(c) Civil Aircraft Flight Manual, Marking, and Placard Requirements The FAA has previously determined
that relief from these sections is not necessary. Relevant materials may be kept in a location accessible to the PIC in compliance with the regulations. Rel ief is not

necessary

.

14 C.F.R. Part 91.103 Preflight Action Aerial Impressions will perform

. Relief is not necessary

.

14 C.F.R. Part 91.109(a) Flight Instruction Aerial Impressions will conduct all flight training through procedures specified in Training Instruction during dedicated training sessions. Based on previous decisions made by the FAA for sUAS petitions regarding this regulation, relief is not necessary.

14 C.F.R. Part 91.119(c) Minimum Safe
Altitude Aircraft will be operated below 400 AGL, but not over congested areas. Request relief with limitations and conditions specified in this petition.

Altimeter Settings The proposed aircraft have a12 barometric altimeter and GPS derived altitude capabilities. Aerial Impressions recommends that the
altimeter be set to zero feet AGL rather than local barometric pressure or field altitude before flight. Considering the limited altitude of the proposed o perations. Request
relief with limitations and conditions specified in this petition.

14 C.F.R. Part 91.151(a) Fuel Requirements in
VFR Prior relief has been granted for
manned and unmanned aircraft to operate at less than prescribed
minimums. Request relief with
limitations and conditions specified in this petition.

14 C.F.R. Part 91.203(a) and (b) Certifications Required Original intent of these regulations was to display an aircraft’s airworthiness, certification and registration documents so they would be easily available to inspectors and passengers. Based on the FAA Memorandum subject, “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station,” dated August 8, 2014, relief is not

necessar y

.
14 C.F.R. Part 91.405(a) Maintenance Required Request relief with limitations and conditions specified in this petition.

14 C.F.R. Part 91.407(a)(1) Operation after
Maintenance Request relief with limitations and conditions specified in this petition.

14 C.F.R. Part 91.409(a)(1) and (2) Inspections Request relief with limitations and conditions specified in this petition.

14 C.F.R. Part 91.417(a) and (b) Maintenance Records Request relief with limitations and conditions specified in this petition.13 

## Protection of Rights and Privacy

UAS Pilot in Command, Gimbal Operators and Spotter or any other person involved in flight mission is to observer and privacy rights or expectations of the public. Any person involved in any unlawful flights that may jeopa rdize someone's privacy right or expectations will be held

accountable for their actions.



## Public Interest

Aerial Impressions is a small local business supporting and promoting the safe and responsible implementation of sUAS into our national airspace (NAS). Aerial Impressions will offer local market an accredited sUAS option to aid in aerial imagery gathering . Aerial Impressions use small unmanned units that have the capacity to perform work that would require a full scale fixed winged aircraft and pilot, reducing risk to people and property.



## Conclusion

In conclusion if granted relief for :14 CFR § 61. 113(a) & (b) 14 CFR § 91.7(a) 14 CFR § 91.119(c) 14 CFR § 91.151(a) 14 CFR § 91.405(a). Aerial Impression believes they can perform safe, efficient and responsible flight operations. Promoting legal flight operations solutions to ensure greater public sa fety and discouraging unlawful use. While lessen risk to pilots, property and civilians due to the implementation of lightweight small unmanned systems

.

Sincerely,

Todd Massey Owner Operator Aerial Impressions, LLC

414

- 899

- 8512 aerialimpressionsMKE@ gamil.com