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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 

unmanned 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 operate 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 Allow 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.com
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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 Interest.........................................................................................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 Sight 
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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 located in southeastern Wisconsin that intends to 

use two current DJI model UAV platforms, to gather images for industries such as of Real estate, 

Precision Framing, Geo-Reference Mapping and Golf courses Photography. Aerial Impressions 

is committed to offering safe and responsible 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, Aerial 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-five 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 condition 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 preflight 

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 alterations 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 be
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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, description 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 approximately 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 provided 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 transmitter 

Gopro Hero 3+

DJI Naza M Flight controller
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 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 Manual

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 unmanned 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 control 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 Code of Federal Regulations, and/or Agency directives and regulations, applicable to the 
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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 certificate. 

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 similar 

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). Prior 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 operate 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 capability. 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 official sunset, local time).
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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 operator. 

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 with 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 power 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) 
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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 Administrator 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 Integration 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.ntsb.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 Charts (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 with 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 No. 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 nonparticipating 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/controller or 

authorized representative. Permission from the land owner/controller or authorized 

representative will be obtained for each flight to be conducted.
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Airport Proximity

The sUAS will not operate within 5 nautical miles of an airport reference point 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 the 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 use 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 always 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 Authorization

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.

Weather
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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. 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 conditions 

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 a 
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limitations 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 conditions 

specified in this petition.

14 C.F.R. Part 91.7(a) Civil Aircraft 

Airworthiness

Aerial Impressions recommends that 

in consideration of the 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. Relief 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 a 
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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 operations. 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 

necessary.

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.
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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 jeopardize 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 safety 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