St Louis Aerial Photography 

Bob Krull 

10812 Arnett Drive 

St Louis, MO 63123 

Telephone: 314-892-1233 

Email: stlouisaerialphotography@gmail.com 

April 20, 2015 

U. S. Department of Transportation 

Docket Management System 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE 

Washington DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir or Madam: 

We respectfully request exemption under Section 333 ofthe FAA Reform ACT and Part 11 of the Federal 

Aviation Regulations. 

Petitioner: 

St Louis Aerial Photography 

Bob Krull 

10812 Arnett Drive 

St Louis, MO 63123 

Telephone: 314-892-1233 

Email: stlouisaerialphotography@gmail.com 

STLAP is a small business. STLAP intends to incorporate the use of sUASs for a variety of projects which 

may include but not be limited to project and construction management, inspections and monitoring; 

environmental review projects; aerial surveying; agricultural projects; educational and research projects; 

remote sensing projects, wildlife and forestry monitoring projects; aerial filmmaking, photography and 

real estate purposes; search and rescue, etc. 

Specific Section(s} seeking exemption: 

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 

U. S. Department of Transportation 

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April 20, 2015 

Page Two 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) and (b) 

14 C.F.R. 91.215 

14 C.F.R. 91.104 through 91.417 

Extend of relief requested: 

To permit commercial operation of Small Unmanned Aircraft Systems (sUASs) for operations conducted 

within and under the conditions outlined herein or as may be established by the FAA as required by 

Section 333. 

Said exemption would permit the operation of sUASs under controlled conditions in limited, 

predetermined and controlled airspace. Upon granting of this proposed exemption request, STLAP 

would conduct commercial operations of sUASs meeting or exceeding all operational and safety 

requirements per Section 333. 

Public Benefit: 

1. Project and construction management, inspections and monitoring. The use of sUASs on construction 

sites may improve the safety of workers, local residents and general public by assessing potential 

dangerous situations. Falls and injuries may be reduced or eliminated through a more thorough review 

of the construction sites. In some cases, sUASs may reduce the reliance of helicopters or small aircraft to 

monitor said sites. This may improve safety as well as reduce environmental impact by reducing energy 

usage; 

2. Environmental Review projects. The use of sUASs during the process of reviewing projects as required 

by 24 C.F.R. 50.4, 58.5 and 58.6 would provide a more in-depth Environmental Review of the project site 

as well as surrounding areas. Reliance of helicopters or small aircraft may be eliminated; 

3. Aerial surveying. The use of sUASs in connection with aerial surveying of smaller areas may eliminate 

the use of helicopters or aircraft. This could provide a more cost effective, safer and more energy 

efficient product; 
4. Agricultural projects. Wildlife and Forestry projects. The use of sUASs could assist with surveying 

agricultural projects as well as wildlife and forestry projects by providing information when problems 

occur, vermin infestation, fire hazards, etc.; 

5. Remote Sensing projects. The use of sUASs could provide views and information for remote and 

inaccessible areas. This could promote worker safety as well as reduce the reliance on helicopters and 

aircraft; 

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Docket Management System 

April 20, 2015 

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6. Educational and Research projects. The use of sUASs could provide information for said projects in a 

more cost effective and efficient manner than other available options; 

7. Aerial filmmaking, photography and real estate purposes. The use of sUASs may provide a point of 

view previously unavailable through other means. They would be more cost effective, efficient and more 

safely than helicopters and aircraft; and 

8. Search and rescue. The use of sUASs may provide assistance to local law organizations during search 

and rescue missions. SUASs may reach areas unattainable or viewable with helicopters and aircraft. 

SUASs may be implemented quicker as time is of the essence during search and rescue operations. 

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. 

Proposed operations using sUASs provide increased safety enhancement especially when compared 

with helicopters and aircraft for the following reasons: 

1. The sUASs will weigh less than ten (10) pounds; 

2. Flights will be operated within the visual line of sight of the pilot; 

3. Maximum total flight time for each operational flight will be thirty (30) minutes. Flight times may be 

less than thirty (30) minutes as the UAS will continuously monitor battery reserve and return to the 

ground station with at least 20% battery power reserved; 

4. Flights will be operated at an altitude of 200 feet AGL. Flights will never exceed 400 feet AGL; 

5. Minimum crew for each operation will consist of the sUAS pilot and a Visual Observer; 

6. A briefing will be conducted daily by all personnel working with said sUAS; 

7. All onsite personnel and client employees will be required to execute a waiver. Verbal/written 

consent will be required of all persons within 100 feet of flight operation; 

8. Written and/or oral permission from relative property owners will be obtained prior to operating the 

sUAS; 
I \ 

9. All permits, permissions, etc. will be obtained from local government offices as required; 

10. The sUAS operated will weigh less than 55 pounds including payload (camera, lens, gimbal, etc.); and 

11. The sUAS will operate at speeds less than 50 knots, hover and simultaneously move vertically and 

horizontally; 

12. The sUAS will have the capability to return and land at the pre-determined location with the Security 

Perimeter should the sUAS lose communication or GPS signal during any operations; 

13. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies; 

14. Operations will not be conducted over densely populated areas or heavily traffic highways; and 

U. S. Department of Transportation 

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April 20, 2015 

Page Four 

15. Operations will not be conducted within five (5) NM of an airport or heliport. 

STLAP will abide by all regulations including the following: 

1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. Airworthiness Certificates; 

2. 14 C.F.R. 45.23 Display of marks; general and 45.29 Size of marks; 

3. 14 C.F.R. 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial 

pilot privileges and limitations; 

4. 14 C.F.R. 91.7 Civil aircraft airworthiness; 

5. 14 C.F.R. 91.9 Civil aircraft flight manual, marking and placard requirements; 

6. 14 C.F.R. 91.109 Flight instruction; Simulated instrument flight and certain flight tests; 

7. 14 C.F.R. 91.119 Minimum safe altitudes: general; 

8. 14 C.F.R. 91.121 Altimeter settings; 

9. 14 C.F.R. 91.151 Fuel requirements for flight in VFR conditions; 

10. 14 C.F.R. 91.203 Civil aircraft: Certifications required; 

11. 14 C.F.R. 91.205 Powered civil aircraft with standard category U.S. airworthiness certificates: 

Instrument and equipment requirements; 

12. 14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use; 

13. 14 C.F.R. 91.401 Applicability; 

14. 14 C.F.R. 91.403 General; 
l ' 

15. 14 C.F.R. 91.405 Maintenance required; 

16. 14 C.F.R. 91.407 Operation after maintenance, preventive maintenance, rebuilding or alteration; 

17. 14 C.F.R. 91.4091nspections; 

18. 14 C.F.R. 91.411 Altimeter system and altitude reporting equipment tests and inspections; 

19. 14 C.F.R. 91.413 ATC transponder tests and inspections; 

20. 14 C.F.R. 91.415 Changes to aircraft inspection programs; and 

21. 14 C.F.R. 91.417 Maintenance records. 

Equipment and Specifications. 

3DR SOLO KIT~ 3DR solo, 3DR Solo Gimbal, 3DR Solo Controller, 3DR Solo Propeller Set- Black, 3DR Solo 

Battery Charger, 3DR Solo Controller Charger 

Specifications: 

Up to 26 minutes of flight time (20 with camera and Solo Gimbal), 

HD video streaming to mobile 

Top speed: 55 mph 

Max Altitude: 400ft, per FM rules 

Weight: 1600 g; 1760 g with Solo Gimbal and GoPro 

Wifi range: up to a half a mile, depending on environment 

Controller with color screen and live flight data 

Pixhawk 2 flight controller software 

Customizable color LEOs for orientation 

Solo Battery: 14.8 V LiPo (5200mAh) 

Rechargeable controller batter: 2600 mAh/7.2 Vdc; lasts 4 hours (extendable battery available} 

10x4.5 self tightening props 

880 kV motors 

Plug and play with 3-axis Solo Gimbal from 3DR 

Please feel free to contact our office should you have any additional questions or comments. Thank you 

for your cooperation with this matter. 

Sincerely, 
Bob Krull 

St Louis Aerial Photography