Aerial Engineering Services, LLC

214 East John Hand Rd

Cedartown, GA 30125

770-749-1808

aeservicesllc@charter.net

July 6, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Submitted Via www.regulations.gov

Re: Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 CFR § 61.3; 14 CFR § 61.113(a) & (b); 14 CFR § 61.133; 14 CFR 

§ 91.7(a); 14 CFR § 91.9(b); 14 CFR § 91.119(c); 14 CFR § 91.121; 14 CFR § 91.151(a); 14 CFR 

§ Part 21; Subpart H; 14 CFR § 91.203; 14 CFR § 91.405(a); 14 CFR § 91.407(a)(1); 14 CFR § 

91.409(a)(1) & (a)(2); 14 CFR § 91.417(a) & (b)

Dear Sir or Madam:

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 2012 (the Reform Act) and 14 CFR Part 11, Aerial Engineering Services, LLC

hereby requests a grant of exemption from the Federal Aviation Regulations (FARs) noted

herein. Aerial Engineering Services, LLC is seeking a grant of exemption to operate small 

Unmanned Aircraft Systems (sUAS) within the National Airspace System (NAS) for commercial 

operations.

As directed by Congress through the enactment of Section 333(a) - (c) of the Reform Act, the 

Secretary of Transportation shall determine whether certain unmanned aircraft systems (UAS)

may operate safely in the NAS before completion of the plan and rule-making required by 

Section 332. This petition will show that, due to their size, weight, speed, and operational 

capability, the sUAS operated by Aerial Engineering Services, LLC will not create a hazard to 

users of the NAS, the public, or national security.

In addition to considering size, weight, speed,....--- it is important to note that per Section 

333(b) of the Reform Act, "ASSESSMENT OF UNMANNED AIRCRAFT SYSTEMS. - In making the 

determination under subsection (a), the Secretary shall determine, at a minimum-- (2) whether 

a certificate of waiver, certificate of authorization, or airworthiness certification under section 

44704 of title 49 U.S.C., United States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1)." Aerial Engineering Services, LLC respectfully submits 
Aerial Engineering Services, LLC 

Petition for Exemption

that the phrase "at a minimum" used by Congress in Section 333(b) carries the same meaning 

as the phrase "at least", which by definition means "lowest in consideration, position, or

importance". Therefore, Section 44704 of title 49 U.S.C. was intended to be a starting point, for 

the Secretary, when considering requested exemptions from regulations prior to the 

establishment of a sUAS Rule. Being such, the Secretary has the implied authority to also 

consider granting relief from other Title 49 sections as necessary, including Section 44711 - 

Prohibitions and Exemption, to accomplish the Congressional goal of safely accelerating the 

integration of civil UAS into the NAS. 

New technologies have both risks and benefits. Aerial Engineering Services, LLC fully 

understands the risks, the importance of safety, and the need to have skilled & experienced 

PICs operating its sUAS. Therefore, the PIC of flight operations for Aerial Engineering Services, 

LLC will be required to document at least 20 hours of comprehensive sUAS flight training, as 

specified in the attached petition, prior to piloting Civil sUAS missions. 

The sUAS employed by Aerial Engineering Services, LLC in its operations are manufactured by 

one of the most reputable manufacturers in the industry, 3D Robotics, and are of the highest 

quality, safest, and most professional grade sUAS available. In addition to the investment in 

quality equipment, Aerial Engineering Services, LLC has also invested its time, energy, and 

resources to ensure the safest sUAS operating environment possible. 

Aerial Engineering Services, LLC will employ sUAS to capture high resolution data for use in the 

Agriculture, Engineering, Construction, Real Estate, and Building Inspection industries. Granting 

this petition will help fulfill the goal of Congress to safely accelerate the introduction of sUAS 

into the NAS.

The information and documentation included within the attached petition has been provided to

support Aerial Engineering Services, LLC's requested grant of exemption.

I look forward to your favorable response.

Kindest Regards,

James Matthew Denton

Owner/Partner

Aerial Engineering Services, LLC

Enclosure: Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations

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Petition for Exemption

Petition for Exemption Under Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations

For the sake of convenience, this Petition is organized as follows:

Section Page_ 

1. Description of Petitioner ..................................................................................... 3

2. Proposed Uses ..................................................................................................... 3

3. Description and Characteristics of sUAS .............................................................. 4

4. Public Interest and Benefits ................................................................................. 6

5. Aerial Engineering Services, LLC's sUAS Operations Manual .............................. 6

6. Requested Exemptions from Regulations ............................................................ 11

7. Supporting Documentation .................................................................................. 15

8. Summary for Publication ...................................................................................... 15

1. Description of Petitioner

The name and address of the Petitioner is:

Aerial Engineering Services, LLC

Attn: Matthew Denton

214 East John Hand Rd

Cedartown, GA 30125

770-749-1808

aeservicesllc@charter.net

Aerial Engineering Services, LLC will employ sUAS to capture high resolution data for use in the 

Agriculture, Engineering, Construction, Real Estate, and Building Inspection industries. The 

owner/manager of Aerial Engineering Services, LLC possesses a Bachelors of Science Degree in 

Civil Engineering, has three years and countless hours of experience safely operating sUAS for 

recreational enjoyment, and is a member of the Academy of Model Aeronautics.

2. Proposed Uses

Aerial Engineering Services, LLC will employ the 3D Robotics Solo Quadcopter and X8-M 

Octocopter for Aerial Surveying, 2D and 3D Mapping, Agricultural Crop Management, Real 

Estate Marketing, and Building Inspection operations. The sUAS will be flown at relatively low 

altitudes, well below 400' AGL, and at moderate speeds well within the capabilities of the sUAS, 

for the purpose of collecting high resolution visual-spectrum still and video imagery necessary 

to generate detailed 3D Digital Terrain & Surface Models, 2D and 3D Photographs, Rectified 

Ortho Photos & Mosaic Images, Topography Maps, Real Estate Marketing Videos, and Building 

Inspection Data.

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3. Description and Operational Characteristics of sUAS

Aerial Engineering Services, LLC will employ the 3D Robotics Solo Quadcopter and X8-M 

Octocopter in its operations. Below are descriptions and operational characteristics of both 

sUAS. 

a. 3D Robotics Solo Quadcopter

The 3d Robotics Solo Quadcopter will be used to capture high resolution still and video 

imagery associated with creating real estate marketing videos and preparing building 

inspection data. 

3D Robotics Solo Specifications

Weight (Including Battery and Camera) Less Than 5.0 lb

Maximum Ascent Speed 16.1 ft/s (5.0 m/s)

Maximum Descent Speed 8.0 ft/s (2.5 m/s)

Maximum Speed 48 knots (55 mi/h) (24 m/s)

Typical Flight Time Approximately 20 minutes

Dimensions 18.0 in x 18.0 in x 10.0 in

Remote Control Operating Frequency 2.4 GHz Both CE and FCC Compliant

Remote Control Transmitting Distance 1.2 mi (2 km)

Remote Control Battery 2600 mAh LiPo 

Solo Battery 5200 mAh LiPo 

The 3D Robotics Solo utilizes GPS data to determine its horizontal position and altitude.

The sUAS has a Return to Home (RTH) feature that can be manually activated in the 

event of a detected abnormality or emergency or automatically in the event of a lost

Communications Signal or if the remaining battery reaches a minimum level. 

Additionally, if for some reason the aircraft battery cannot support the RTH feature, the 

aircraft can safely land at its current location. The RTH feature, when activated, 

commands the UAS to an altitude of 98' and returns to its home point. Via a Graphical In 

Flight Control System the GPS signal strength, remote control signal strength, altitude, 

vertical & horizontal speed, the distance of the aircraft from the remote control, 

remaining life of the remote control and aircraft batteries, and remaining flight time, 

can be monitored by the Pilot in Command (PIC) at any time during a flight.

b. 3D Robotics X8-M Octocopter

The 3D Robotics X8-M Octocopter will be utilized to capture high resolution visualspectrum still imagery necessary to generate 3D Digital Terrain & Surface Models, 2D 

and 3D Photographs, Rectified Ortho Photos & Mosaic Images, and Survey Maps. 

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Due to the degree of accuracy, stability, and control required during a flight to capture 

highly detailed and precision photographic imagery necessary to generate 3D Digital 

Terrain & Surface Models, 2D and 3D Photographs, Rectified Ortho Photos & Mosaic 

Images, and Survey Maps, Aerial Engineering Services, LLC will conduct autonomous 

flights using the X8-M. Autonomous flights will be programmed into the aircraft's 

onboard autopilot flight controller prior to arriving at each site. Adjustments, however, 

may be made on the ground prior to each flight to correct for wind direction and other 

unanticipated site related variables discovered at the time of each flight to insure the 

safest, most efficient, and most productive flight possible. 

Below are the standard specifications of the 3D Robotics X8-M Octocopter.

3D Robotics X8-M Specifications

Max. Weight (Including Battery and Camera) Less Than 10 lb

Autopilot 3DR Pixhawk V2.4.5

GPS 3DR u-blox GPS w/ Compass

Hovering Accuracy (GPS Mode) Horizontal: 9.8 ft (3 m)

Maximum Ascent Speed Undetermined by Manufacturer

Maximum Descent Speed Undetermined by Manufacturer

Maximum Speed 35 knots (40 mi/h) (18 m/s)

Maximum Wind Speed Resistance 21.7 knots (25 mi/h) (11 m/s)

Typical Flight Time Approximately 14 minutes

Aircraft Dimensions 13.7 in x 20.1 in x 11.8 in

Remote Control Operating Frequency 2.4 GHz, FCC Compliant

Remote Control Transmitting Distance 0.6 mi (1 km)

Number of Remote Control Frequencies 7

Remote Control Battery 8 - AA Batteries

X8-M Battery 10000 mAh 10C LiPo 4S

The 3D Robotics X8-M utilizes a fully redundant propulsion system that provides 

increased reliability. The X8-M depends upon GPS to determine its horizontal position, 

and a barometer in the onboard autopilot to determine its vertical position. The 3D 

Robotics X8-M Aircraft has a Return to Launch (RTL) feature that can be manually 

activated in the event of an in flight abnormality or emergency or automatically in the 

event of a lost Communications Signal or if the remaining battery life reaches a preprogrammed minimum level. Also, the RTL feature can be automatically activated if a 

pre-defined vertical and horizontal geofence is breached. Additionally, if for some 

reason the aircraft battery cannot support the RTL feature, the aircraft can safely land at 

its current location. Via a graphical interface on the remote control and the Ground 

Control Station the PIC can monitor the number of GPS satellites acquired and the GPS 

signal strength, remote control signal strength, altitude, horizontal speed, the distance 

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of the aircraft from the remote control, remaining life of the remote control and aircraft 

batteries, and total flight time, at all times during a flight.

4. Public Interest and Benefits

By employing sUAS for Aerial Engineering Services, LLC's operations, the potential risk of serious 

accidents and injuries associated with manned rotary and fixed wing aircraft weighing 

thousands of pounds, will be greatly reduced and/or eliminated. In addition to weight, the type 

of manned aircraft typically used to capture the high resolution photography and video 

described herein are capable of carrying 100 or more gallons of fuel which creates the potential 

risk of spillage and fire in the event of an incident or accident, emit emissions harmful to the 

environment, and require an onboard pilot and additional crew members to operate the 

photographic and video equipment. Due to the fact that the sUAS employed by Aerial 

Engineering Services, LLC's weigh less than 10 pounds fully loaded, carry no fuel, emit no 

harmful emissions, the pilot and crew are remotely located from the aircraft, and the sUAS are 

operated over controlled access sites/properties, a significant public benefit is achieved.

Additionally, by employing sUAS at altitudes well below and at speeds far less than manned 

aircraft, Aerial Engineering Services, LLC will provide the Agriculture, Architecture, Civil 

Engineering, Construction, Real Estate, and Building Inspection Industries; with data and 

imagery that possess a superior level of detail and precision that is impossible to acquire with 

manned flights or satellite imagery.

5. Aerial Engineering Services, LLC's sUAS Operations Manual

Aerial Engineering Services, LLC shall review and update this sUAS Operations Manual at least

annually, or more frequently if necessary, to insure that the information contained herein is 

current, relevant to sUAS operations, and to insure that it accurately reflects updated FAA 

requirements for Civil sUAS operations.

a. Safety

Safety is the main priority of Aerial Engineering Solutions, LLC. To achieve the safest 

possible environment regarding Civil sUAS operations, Aerial Engineering Services, LLC's 

sUAS Operations Manual and the sUAS Operations, Maintenance, and Safety Manuals

shall be followed.

Monthly safety meetings shall be conducted and documented to insure strict adherence 

to Aerial Engineering Services, LLC's sUAS Operations Manual.

A Visual Observer (VO) shall be utilized during every flight (training and mission flights). 

The VO shall maintain direct Visual Line of Sight (VLOS) at all times during a flight. The 

VO shall remain in verbal contact at all times during a flight. The VO shall only perform 

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see and avoid duties for the purpose of identifying ground based and aerial obstacles 

and potential hazards including but not limited to other UAS and Manned Aircraft.

The PIC and VO shall monitor weather conditions prior to and during every flight. If 

adverse weather conditions are predicted or observed, including but not limited to 

winds greater that the capabilities of the aircraft, rain, low or ominous clouds, lightning, 

and thunder, the flight shall be aborted.

Phone calls, electronic messaging, and texting shall not be permitted at any time during 

flight operations.

To insure the safest possible environment during a flight, all nonparticipating personnel, 

shall remain at least 500 feet from the sUAS unless a protective shelter has been 

established prior to the flight.

sUAS shall not be operated within 500 of vessels, vehicles, or structures unless written 

permission has been granted by the owner and such operations do not create a 

potential safety hazard.

All flights shall be conducted during daytime hours only, under Visual Meteorological 

Conditions (VMC).

sUAS shall not be operated over crowds or congested areas.

All sUAS related incidents and/or accidents shall be immediately documented and 

reported to the FAA's sUAS Integration Office within 24 hours. Accidents shall be 

reported to the National Transportation Safety Board (NTSB).

b. Training

Training sessions shall be conducted as needed, but no less than bi-annually, for the 

purpose of flight training, proficiency, experience building, and to review safety issues. 

Prior to being designated as a PIC for an official mission flight, the PIC must document at 

least 20 hours piloting the sUAS employed by Aerial Engineering Services, LLC that 

involves at a minimum take offs and landings, hovering, evasive & emergency 

maneuvers, mock mission flights, and ground control operations so to become fully 

aware of the capabilities of the sUAS.

Prior to acting as a VO for an official mission flight, the VO must document at least 10 

hours training to become fully aware of the responsibilities of seeing and avoiding for 

the purpose of identifying ground based and aerial obstacles and potential hazards 

including but not limited to other UAS and Manned Aircraft.

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c. Flight Planning

Prior to each flight, the PIC and VO will visually survey the site/property being flown to 

identify site/property boundaries and ground based obstacles and potential hazards 

that may affect the aircraft during flight. They will also determine the safest location 

from which to launch the aircraft as well as the best vantage point from which to 

maintain a VLOS of the aircraft at all times during the flight. The location of a shelter for 

non-participating personnel, if needed, shall also be determined at this time.

Operations shall be conducted over public, private, or limited access property only, Prior 

to each flight, Aerial Engineering Services, LLC shall obtain written permission from the 

site/property owner authorizing the sUAS operations over the site/property and to 

capture high resolution photographs and video of the site/property and any structures

thereon. Aerial Engineering Services, LLC shall strictly adhere to all privacy laws of the 

State and/or local jurisdiction in which sUAS operations are conducted.

Prior to each flight, a PIC shall be designated. That designation shall not be transferred 

for the duration of the flight.

Prior to each flight, the PIC, VO, and other necessary participants will review and discuss 

the details and parameters of the flight to insure that all participants have a firm 

understanding of the flight objectives.

Prior to each flight, the PIC shall determine and document the altitude of the launch site

and calculate the maximum flight altitude allowable to remaining within 400 feet AGL 

during the flight.

Prior to each flight, the PIC shall ensure that the UAS has been programmed to 

automatically RTH or RTL if the remaining battery life reaches a minimum level of 25%.

Prior to each flight, the PIC shall ensure that the UAS has been programmed with a 

vertical and horizontal geofence (vertical maximum 400' AGL; horizontal maximum 0.5 

miles from the PIC) that if breached will automatically activate the aircraft's RTH or RTL 

feature.

d. Preflight Inspections

Prior to each flight, the PIC shall inspect the sUAS being flown to ensure it is safe for 

flight. In the event, any condition, including but not limited to, inoperable components, 

items, or equipment, are discovered that would affect the safe operation of the sUAS, 

the flight shall be aborted until the necessary corrective maintenance has be performed 

and a follow up inspection has been completed. An inspection of the Ground Control 

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Station shall be included in the preflight inspection. Additional inspections shall be 

conducted as prescribed by the Manufacturer.

The sUAS and Remote Control Batteries shall be inspected for defects and to insure they 

have a charge sufficient to complete the mission flight with at least 25% battery life 

remaining.

The PIC shall verify that an adequate GPS signal is obtained per the Manufacturer's User

Manual prior to launching the UAS.

The PIC shall ensure that the remote control antenna and range extender is properly 

configured so to achieve the best possible communication link between the remote 

control, Ground Control Station, and the UAS. The Remote Control, Ground Control 

Station, and sUAS connection shall be tested to ensure proper functionality.

e. Flight Procedures

A copy of the Aerial Engineering Services LLC's sUAS Operations Manual and the sUAS

Manufacturer's User, Safety, and Maintenance Manuals shall be maintained with the 

Ground Control Station at all times during a flight. 

sUAS shall be operated at an altitude of no more than 400 feet AGL.

sUAS shall not exceed speeds recommended by the manufacturer. 

sUAS shall not be operated within 5 nautical miles of an airport unless a written 

agreement is obtained from the airport's manager. In the event a flight is conducted 

within 5 miles of an airport, a Notice to Airman (NOTAM) must be issued.

sUAS shall be operated within visual line of site (VLOS) of the PIC and VO at all times. 

The PIC and VO must be able to communicate verbally at all times.

sUAS shall not be operated when visibility is less than 3 miles from the PIC.

sUAS shall not be operated less than 500 feet below or within 2000 feet horizontally 

from a cloud.

The PIC shall stay clear of and always yield the right-of-way to other sUAS and manned 

aircraft.

The PIC shall manually activate the UAS's RTH or RTL feature in the event of any 

detected abnormality or emergency.

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During a flight, the PIC shall monitor at a minimum the UAS's altitude, horizontal speed, 

distance of the aircraft from the remote control, and remaining battery life; and the 

remaining life of the remote control.

During all programmed autonomous flights, the PIC shall maintain Visual Line of Site of 

the sUAS and monitor the sUAS controls. The PIC shall assume full manual control of the 

aircraft in the event of any detected abnormality or emergency and activate the RTH or 

RTL feature.

f. Maintenance

Routine and preventive maintenance, overhaul, and replacement shall be performed on 

each sUAS as specified in the Manufacturer's Maintenance Manual. The Maintenance 

Manual for each sUAS shall be maintained with the Ground Control Station at all times 

during a flight.

Corrective maintenance for any condition, including but not limited to, inoperable 

components, items, or equipment, that are discovered during a pre-flight inspection 

shall be completed according to the Manufacturer's recommendation.

sUAS that have undergone any maintenance or alterations that affect critical flight 

components shall undergo a functional test flight prior to being placed back into service.

g. Record Keeping

An aircraft maintenance record shall be kept up to date for each sUAS operated by 

Aerial Engineering Services, LLC.

Routine and preventive maintenance shall be recorded in the aircraft record for each 

sUAS operated by Aerial Engineering Services, LLC.

Repair or corrective maintenance shall be recorded in the aircraft record for each sUAS

operated by Aerial Engineering Services, LLC.

A record shall be created and maintained for each flight that shall include at a minimum 

the PIC's and VO's names, the flight location, time of day, atmospheric conditions at the 

time of the flight, the sUAS flown, the duration of the flight, and purpose of the flight.

The original agreement granting access to the site/property must be made a part of 

each flight record.

Training records shall be maintained for each PIC and VO that includes at a minimum, 

name, date, time of day, total training time, location of training, and training type.

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6. Requested Exemptions from Regulations

14 CFR § 61.3; Requirements for certificates, ratings and authorizations: 14 CFR § 61.113(a) & 

(b); Private Pilot Privileges and Limitations: 14 CFR § 61.133; Commercial pilot privileges and 

limitations

Aerial Engineering Services, LLC seeks an exemption from 14 CFR § 61.3 which states "No 

person may serve as a required pilot flight crewmember of a civil aircraft of the United States, 

unless that person: (1) Has in the person's physical possession or readily accessible in the 

aircraft when exercising the privileges of that pilot certificate or authorization— (i) A pilot 

certificate issued under this part and in accordance with §61.19;", and

14 CFR § 61.113(a) & (b) which states "(a) Except as provided in paragraphs (b) through (h) of 

this section, no person who holds a private pilot certificate may act as pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire; nor may that person, 

for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for 

compensation or hire, act as pilot in command of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) The 

aircraft does not carry passengers or property for compensation or hire.", and

14 CFR § 61.133 which states "(a) Privileges—(1) General. A person who holds a commercial 

pilot certificate may act as pilot in command of an aircraft— (i) Carrying persons or property for 

compensation or hire, provided the person is qualified in accordance with this part and with the 

applicable parts of this chapter that apply to the operation; and (ii) For compensation or hire, 

provided the person is qualified in accordance with this part and with the applicable parts of 

this chapter that apply to the operation."

Prior to the grant of exemption issued to Jeffery J. Walsh (11229), FAA required that a PIC of a 

commercially operated sUAS must at least hold a Private Pilot Certificate. Following the grant of 

exemption issued to Jeffery J. Walsh, FAA's stance changed thus permitting a PIC to hold a 

range of licenses from a Commercial Pilot Certificate down to a Sport Pilot Certificate. 

Most recently, per the release of a Small UAS Notice of Proposed Rulemaking, FAA proposes to 

replace the pilot airman certificate requirement with an Aeronautical Knowledge Test, create a 

sUAS certificate, and establish a TSA security screening process for sUAS Operators, followed by 

recurrent Aeronautical Knowledge Tests every 24 months, all of which Aerial Engineering 

Services, LLC feels is reasonable and necessary.

As of the date of this petition, a number of petitioners have requested complete relief from the 

requirement to hold an pilot airman certificate, however, FAA has held firm to the position that 

Section 333 did not grant the authority to exempt that requirement (e.g. Singer's Creations 

(11191)). Additionally, FAA has also required a pilot certificate for sUAS operations because 

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pilots holding an FAA issued pilot certificate are subject to the security screenings by the 

Department of Homeland Security that certificated airmen undergo.

Section 333(b) of the Reform Act states, "ASSESSMENT OF UNMANNED AIRCRAFT SYSTEMS. - In 

making the determination under subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within visual 

line of sight do not create a hazard to users of the national airspace system or the public or 

pose a threat to national security; and (2) whether a certificate of waiver, certificate of 

authorization, or airworthiness certification under section 44704 of title 49, United States Code, 

is required for the operation of unmanned aircraft systems identified under paragraph (1)." 

Based upon the wording of Section 333(b) of the Reform Act, Aerial Engineering Services, LLC 

respectfully disagrees with FAA's opinion/position that the Secretary only has the authority to 

grant relief from Section 44704 of Title 49 U.S.C. when considering requested exemptions from 

regulations; and instead submits that the phrase "at a minimum" used by Congress in the 

Section 333(b) carries the same meaning as the phrase "at least", which by definition means 

"lowest in consideration, position, or importance". Therefore, Section 44704 of Title 49 U.S.C.

was simply intended to be a minimum starting point, for the Secretary, when considering 

requested exemptions from regulations, prior to the establishment of a sUAS Rule. Being such, 

the Secretary also has the implied authority to grant relief from other Title 49 sections as 

necessary, including Section 44711 - Prohibitions and Exemption, to accomplish the 

Congressional goal of safely accelerating the integration of civil UAS into the NAS.

Aerial Engineering Services, LLC will achieve an equivalent level of safety by:

1. Requiring the PIC to complete Sport Pilot ground instruction and pass the FAA Sport 

Pilot written examination to substantiate that essential aeronautical knowledge has 

been acquired. 

2. Requiring the PIC to document at least 20 hours of comprehensive training with the 

sUAS employed by Aerial Engineering Services, LLC as specified in the Aerial Engineering 

Services, LLC sUAS Operations Manual to ensure operating proficiency with the sUAS 

employed by Aerial Engineering Services, LLC. 

3. Requiring the PIC to strictly adhere to all sections of the Aerial Engineering Services, LLC 

sUAS Operations Manual, the Manufacturer's Operating Manuals, and FAA sUAS 

operating requirements. 

4. Requiring the PIC to undergo a Transportation Security Administration screening process 

as soon as such screenings become available for sUAS Operators. 

5. Requiring the PIC to poses a third class airman medical certificate.

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Granting this requested exemption will facilitate the mandate of the Reform Act to safely 

accelerate the introduction of sUAS into the NAS.

14 CFR § 91.7(a); Civil Aircraft Airworthiness

Aerial Engineering Services, LLC seeks an exemption from 14 CFR § 91.7(a) which states "No 

person may operate a civil aircraft unless it is in an airworthy condition." 

Currently FAA does not have a regulatory standard for determining whether or not a UAS is 

airworthy. Aerial Engineering Services, LLC will achieve an equivalent level of safety by 

complying with the Manufacturers User Manual and Aerial Engineering Services, LLC's sUAS 

Operations Manual to insure each UAS is airworthy. 

14 CFR § 91.9(b); Civil Aircraft Flight Manual, Marking, and Placard Requirements

Aerial Engineering Services, LLC seeks an exemption from 14 CFR § 91.9(b) which states "(b) No 

person may operate a U.S.-registered civil aircraft—(1) For which an Airplane or Rotorcraft 

Flight Manual is required by §21.5 of this chapter unless there is available in the aircraft a 

current, approved Airplane or Rotorcraft Flight Manual or the manual provided for in 

§121.141(b); and (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 

of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or any combination thereof."

Due to the small size of the sUAS operated by Aerial Engineering Services, LLC, there is no 

possible way to store the manual materials, markings, and placards onboard the aircraft. Aerial 

Engineering Services, LLC will achieve An equivalent level of safety by keeping the User, 

Maintenance, and Operations Manuals available at the Ground Control Station during each 

flight.

14 CFR § 91.119(c); Minimum Safe Altitudes

Aerial Engineering Services, LLC seeks an exemption from 14 CFR § 91.119(c) which states

"Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes: (c) Over other than congested areas. An altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those cases, the aircraft may 

not be operated closer than 500 feet to any person, vessel, vehicle, or structure."

Due to the fact that the 3D Robotics Solo and X8-M will be operating up to a maximum altitude 

of 400 AGL, Aerial Engineering Services, LLC cannot comply with this requirement. An 

equivalent level of safety, however, will be achieved by only conducting flights over 

sites/property in which written permission has been granted by the owner and precautions are 

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taken to either shelter on site or keep nonparticipating personnel at least 500 feet from the 

sUAS while in flight, as specified by Aerial Engineering Services, LLC's Operations Manual.

14 CFR § 91.121; Altimeter Settings

Aerial Engineering Services, LLC seeks an exemption from 14 CFR § 91.121 which states, in 

pertinent part, "Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating—(1) Below 18,000 feet MSL, to—(i) The current reported altimeter setting of a 

station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station 

within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter 

setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a 

radio, the elevation of the departure airport or an appropriate altimeter setting available 

before departure;"

Aerial Engineering Services, LLC will achieve an equivalent level of safety by following its sUAS

Operations Manual which states that prior to each flight, the PIC shall determine and document 

the altitude of the launch site and calculate the maximum flight altitude allowable to remaining 

within 400 feet AGL during the flight.

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

Aerial Engineering Services, LLC seeks an exemption from 14 CFR § 91.151(a) which states, " (a) 

No person may begin a flight in an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing 

and, assuming normal cruising speed— (1) During the day, to fly after that for at least 30 

minutes;"

The maximum flight time as allowed by battery power is 20 minutes for the 3D Robotics Solo

and 15 minutes for the 3D Robotics X8-M thus making it impossible to comply with this 

regulation. Aerial Engineering Services, LLC will achieve an equivalent level of safety by

following its sUAS Operations Manual which requires the PIC to monitor the remaining battery 

life of the UAS and by programming the UAS to automatically RTH or RTL if the remaining 

battery life reaches 25%.

14 CFR § Part 21; Certification Procedures for Products and Parts: Subpart H; Airworthiness 

Certificates: 14 CFR § 91.203; Civil Aircraft, Certifications Required

Aerial Engineering Services, LLC seeks an exemption from 14 CFR § Part 21 Subpart H which 

prescribes procedural requirements for the issuance of airworthiness certificates, and 14 CFR §

91.203 which requires that no person may operate a civil aircraft unless it has within it an 

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Aerial Engineering Services, LLC

Petition for Exemption

appropriate and current airworthiness certificate, however, while FAA does not currently have 

a regulatory standard for determining whether or not a UAS is airworthy, Section 333 of the 

Reform Act has granted the Secretary the authority to determine which types of UAS, based 

upon size, weight, speed, operational capability, ... do not create a hazard to users of the NAS, 

the public, or national security.

Due to the size, weight, speed, and operational capabilities of the 3D Robotics Solo and X8-M

operated by Aerial Engineering Services, LLC as compared to manned aircraft normally 

operated for the same purpose of obtaining high resolution aerial data, an even greater level of 

safety is achieved.

14 CFR §§ 91.405(a); Maintenance Required: 91.407(a)(1); Operation After Maintenance, 

Preventive Maintenance, Rebuilding, or Alteration: 91.409(a)(1) & (a)(2); Inspections: and 

91.417(a) & (b); Maintenance Records;

Aerial Engineering Services, LLC seeks an exemption from 14 CFR §§ 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b); which collectively, these regulations specify certain 

procedural requirements for the maintenance, repair, and inspection of manned aircraft that 

are issued airworthiness certificates.

Aerial Engineering Services, LLC will achieve an equivalent level of safety by following its aUAS

Operations Manual and the Manufacturers User and Maintenance Manuals in regards to the 

maintenance, repairs and inspections, and record keeping for the sUAS being operated.

7. Supporting Documentation

Submitted with this petition, as separate documents, are the Manufacturers User and 

Maintenance Manuals for the 3D Robotics Solo and X8-M sUAS.

8. Summary for Publication

Aerial Engineering Services, LLC

214 East John Hand Rd

Cedartown, GA 30125

770-749-1808

aeservicesllc@charter.net

Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 CFR § 61.3; 14 CFR § 61.113(a) & (b); 14 CFR § 61.133; 14 CFR § 

91.7(a); 14 CFR § 91.9(b); 14 CFR § 91.119(c); 14 CFR § 91.121; 14 CFR § 91.151(a); 14 CFR § 

Part 21; Subpart H; 14 CFR § 91.203; 14 CFR § 91.405(a); 14 CFR § 91.407(a)(1); 14 CFR § 

91.409(a)(1) & (a)(2); 14 CFR § 91.417(a) & (b)

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Aerial Engineering Services, LLC

Petition for Exemption

Aerial Engineering Services, LLC will utilize the 3D Robotics Solo Quadcopter and X8-M 

Octocopter for Aerial Surveying, 3D Mapping, Agricultural Crop Management, Real Estate 

Marketing, and Building Inspections.

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