August 14, 2015

Exemption No. 12461

Regulatory Docket No. FAA–2015–1826

Mr. Jerry Speasl

ImageKeeper LLC

President and CEO

P. O. Box 27740

Las Vegas, NV 89126

Dear Mr. Speasl:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated May 18, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of ImageKeeper LLC (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial data 

collection.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the 3D Robotics IRIS+, DJI Phantom 2, and the DJI 

Inspire 1.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 
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operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, ImageKeeper LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, ImageKeeper LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the 3D Robotics

IRIS+, DJI Phantom 2, and DJI Inspire 1 when weighing less than 55 pounds 

including payload. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. 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; 

electronic messaging or texting is not permitted during flight operations. The PIC 

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 duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 
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the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

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

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

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

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

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

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must 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 must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must 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 UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
n 

HmageKeeR~f 

U. S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Subject: ImageKeeper's Request for Exemptions Pursuant to FMRA Section 333 

and Part 11, FARs to Use Small Unmanned Aircraft Systems in the property 

and casualty insurance industry 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA modernization and Reform Act of 2012 

("FMRA") and 14 C.F.R. Part 11, lmageKeeper LLC hereby petitions for exemptions 

from the listed Federal Aviation Regulations ("FARs") and any other rules necessary 

to allow operation of small unmanned aircraft systems ("UAS") under the conditions 

set forth in this petition. FMRA Section 333 grants the FAA authority to allow the 

operation of certain UAS within the national airspace. ImageKeeper respectfully 

requests authorization to conduct small UAS operations (aerial data collection) 

related to its property insurance, risk and reporting business area, inducting (but 

not limited to) roof inspections, automatic hail imaging damage assessment, 

analysis, certified report system, underwriting report, risk assessment, risk controls, 

accident reconstruction and small UAS pilot training and development. As explained 

below, ImageKeeper's FAA certified commercial pilot will conduct operations under 

the requested exemptions, under strict operating requirements and conditions to 

ensure safety. 

ImageKeeper 1 provides multiple image data acquisition systems, and survey 

systems for insurance emergency claims processing, involving catastrophic events 

such as hurricane, tornado, and earthquake and flood events. This work involves 

aerial image data collection, processing and dissemination for insurance claims 

damage reporting which includes businesses, schools, homes that suffer damages to 

roofs. Collections also include foundations, buildings, farms, roads, bridges and 

infrastructure etc. 

ImageKeeper2 has developed a range of mobile digital image system tools for the 

flood insurance marketplace including FEMA compliant technology. This technology 

' 

1 ImageKeeper has (2) FAA Certified Pilots, Commercial and Private Pilots, current FAA Medicals with over 50 years of 

combined pilot aeronautical, knowledge and experience on staff, in charge of all flight operations. Commercial Pilot is a 

graduate of Embry Riddle Aeronautical University with Degrees in Aeronautical Science, Aeronautical Studies and has been 

involved with many government UAS Programs since the early 90's, awards received from Association for UVS For High 

Altitude and Very Long Endurance Aircraft (Classified Program) 2 ImageKeeper's founders invented Direct Digital Airborne Camera Systems (Patents 5,999,211/5,604,534) for the U. S 

Government and 25 other patents relating to GPS, imaging technology, airborne surveillance. Google acquired the airborne 

camera company. 

1 
and economic benefits or ImageKeepers's products also includes all taxpayers that 

fund FEMA. ImageKeeper is committed to keeping up with the ever-changing safety 

and secure technology needs of our customers, by offering the first mobile 

application to report flood insurance claims and commit payment on the spot. 

Image Keeper leads the industry in this mobile technology. The use of UAS will allow 

ImageKeeper to stay competitive and to further advance innovative technologies 

that benefits its insurance clients, customers, government and courts. By providing 

certifiable data, our clients are saving time and money. They can prevent fraud and 

litigation. 

Types of Operation 

Request to Use UAS for Inspection of Private Property 

ImageKeeper requests an exemption to use small UAS to inspect, collect geo 

referenced aerial data and assess the nature and extent of damage to policyholders' 

private property. ImageKeeper would conduct these UAS operations only with the 

express written consent of the property owner. ImageKeeper is specifically 

interested in studying how UAS can be used to obtain ultra precise and detailed 

images of a geo referenced, certified policyholder's roofing systems and any other 

portion of the property that would normally require utilizing remote access to 

acquire such information. In addition to the roofing we are developing an advanced 

hail damage reporting system along with floodwater precision elevation technology 

before and after an event. By using this technology, this experience will allow 

ImageKeeper to continue to innovate technology more efficiently and rapidly adjust 

claims, enhance the experience of the customers and further Image Keeper's overall 

goals of improving safety for personnel, equipment, and customers. This exemption 

will also provide ImageKeeper pilots with real-world training and experience on 

UAS and will generate valuable data about the operational and safety of UAS that 

could also be beneficial to the FAA. 

In addition to improving ImageKeepers' customer experience and claim 

effectiveness, granting this petition would improve safety for claims professionals 

and reduce the further human risk by eliminating visual on site inspections involved 

with real time storm surge, flash flood and major flooding. Some of ImageKeeper's 

clients were involved in the recent Sandy hurricane and processed around 30,000 

claims. Using ImageKeeper's imaging technology with a UAS and supporting mobile 

claims processing system, that process can be improved, enhanced significantly and 

customers will benefit with accuracy, streamlined process, and chain of custody 

documentation. The government will benefit by eliminating fraudulent claims, 

increase-processing speed, and lower the labor involved in establishing the claim 

paperwork. ImageKeeper will be able to eliminate the need for roof & water 

intrusion inspections in wet, after storm slippery conditions, where risk is 

everywhere to inspectors. The risk of water and downed electrical lines pose risks 

of all types to inspectors/adjustors. However, by comparison, the risk posed by the 

type of UAS roof and floodwater inspections proposed in this petition are minimal. 

This is due to the characteristics of the small UAS that lmageKeeper will use, 

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including the extremely small size and lightweight low operating altitudes. 

Experienced FAA pilots understand the airspace, operations, and safety of flight 

rules. 

ImageKeeper's pilots have never experienced any FAA violations/warnings and 

have been accident free. The level of pilot training received at Embry Riddle 

Aeronautical University is the absolute best in the world. Even with the pilot 

credentials and aeronautical skills, Imagekeeper will use required comprehensive 

UAS flight and ground training in all aspects of UAS. This includes flight planning, 

preflight, maintenance, inspections, geo fencing, flight, recovery, emergency power 

management, flight reviews and keeping up with any FAA new rules governing use 

of UAS. Over the long term, granting this petition will undoubtedly save lives, and 

prevents serious injuries. 

With the appropriate process enhancements, inspection with UAS will not only is 

safer than sending an inspector, but will be faster and will result in enhanced 

customer experience. It is important to point out the significant public interest 

associated with ImageKeeper proposed UAS integration. As with flood we have 

learned how slow the process is to get insurance to pay the flood victim who has lost 

every thing in a flood. By developing a mobile flood claims application tied to a 

cloud system, we are able to write the flood victim approval for funds on the spot 

while at the flooded property scene. Given ImageKeeper's role in flood claims 

payment quickly and efficiently, those 30,000 victims of Sandy who waited a month 

or more for funds could have received funds within days, which allows quicker 

repairs and less productive time lost for paperwork. When considered with the 

contrast and scale of catastrophic events such as hurricanes, tornadoes or 

earthquakes, these efficiencies will translate into quicker recoveries and save 

money, time and lives. 

Image Keeper's UAS operational model poses no risk to the national airspace 

system. In the supporting material for this petition, ImageKeeper will provide an 

operating model that will require UAS inspections take place within a very confined 

(GPS box including altitude of 100 feet or less), tight footprint around and above an 

individual structure. The vast majority of UAS work will take place 20 foot above an 

individual structure. The majority of UAS work will take place at 15 feet above the 

roof surface. This will allow for roof inspection and flood at the same time, due to 

ImageKeeper's multispectral technology. Since ImageKeeper will be operating so 

close to the actual earth surface, the UAS will pose no greater risk to the national 

airspace than the structure themselves. The only concern will be the lost connection 

or run-a-way UAS. ImageKeeper will use geo-fence (GPS box including altitude of 

100 feet or less) and lost-link (return to preprogrammed recovery point) 

technology. 

ImageKeeper is requesting permission to integrate UAS technology into its mobile 

claims processing workflow, which includes cloud integration, mapping, reporting, 

analysis, and overall management. 

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Mobile Flood Insurance Claims Processing 

ImageKeeper requests an exemption to use the UAS to conduct private property 

inspections in connection with claims arising out of ImageKeeper's Flood Claims 

System. ImageKeeper has developed an advanced mobile claims system in the flood 

and roof insurance area and is finalizing deployment of the system for flood and roof 

insurance. ImageKeeper is working with the largest flood claims insurer in the 

United States. This mobile claims system already saves time, protects against fraud 

and creates data that meets chain of custody requirements. ImageKeeper believes 

that by adding mobile UAS aerial data directly on site to the mobile claims 

application, a comprehensive claim can be completed faster, safer, more efficiently. 

Geospatial data provides certifiable complete damage reporting capability. By using 

this system, the claims can be processed, the damage repaired and people can go on 

with their business. Agents, adjustors and investigators will have complete records 

which will be correct, accurate, and searchable and geo located. 

ImageKeeper requests an exemption to use UAS to conduct property inspections 

in connection with claims in the flood, flood areas, and after storm in rising water 

situations. Many properties are in rural outlying areas, and farms in unpopulated 

areas. Use of the UAS in this area would provide ImageKeeper valuable data without 

risk to property or persons. ImageKeeper's small operational footprint, UAS, (under 

5.5 lbs.) low operational altitude of 100 feet or less, geo-fenced, lost-link equipped, 

FAA Certified Pilots, will pose no threat to the national airspace or neighboring 

persons or property. 

Use of UAS in this this setting would further the goal of improving overall safety. 

Under current protocols, each such inspection would be conducted by FAA pilots 

who understand aeronautics, national airspace, TFRs, Restricted airspace, Class A, B, 

C, D, E and G airspace requirements, UAS, safety, security, operational security. 

ImageKeeper employees have been involved in every aspect of mission planning, 

safety, operations and flight activities. 

ImageKeeper will fly 25 practice insurance roof claims inspection in a real and 

simulation situation before moving to a real scenarios in a remote area with 

structure measurement documenting each flight and logging each flight. 

ImageKeeper will be using the UAS to measure, inspect, and capture aerial image 

data, geospatial data, testing signal strength, and recording all data in a secure 

cloud. 

Request to Use UAS for R & D, Training and Certification at ImageKeeper Test 

Site located in Sherman, TX 

ImageKeeper also requests as exemption to use UAS to perform Research and 

Development, training, sensor testing, pilot certification at it own facilities on 

property owned or leased by ImageKeeper. The testing facility will not be open to 

the public and access will be restricted to ImageKeeper employees. The test site will 

contain uninhabited structures, which will enable ImageKeeper to test various 

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sensor types and measurement technologies. The test site is located in a sparsely 

populated area of north Texas. The land is flat, with no obstruction and no airports 

within 25 miles, or homes within two miles. The footprint of the test area is one to 

ten acres. The land is tillable but fallow, with fencing around the entire complex. 

There is no special use airspace above the area test site. 

Pilot Requirements 

ImageKeeper will establish an internal program that will focus on skills, 

knowledge and expertise required to operate small UAS of which ImageKeeper 

intends to operate, 5.5 lbs. or less. ImageKeeper will utilize its own FAA Commercial 

Licensed pilot to develop and implement a practical training program with 

operation of small lightweight UAS. ImageKeeper also intends to work with Embry 

Riddle Aeronautical University who has developed advanced program degrees in 

UAS. By staying involved with this respected world-class aeronautical university, 

ImageKeeper will stay informed of every new educational tool available for UAS. A 

general pilot certification program for UAS must be as stringent as a private pilot 

license, which will apply the same duty of care and operational safety when 

operating a UAS. Not only is a knowledge test important, but should be required, as 

well as a flight evaluation completed by an FAA examiner. 

ImageKeeper has two FAA Rated Pilots, Commercial and Private, with current 

FAA Medical Examinations and over combined 50 years of pilot and aeronautical 

knowledge and experience on staff, which will oversee all flight operations. 

ImageKeeper's commercial pilot is a graduate of Embry Riddle Aeronautical 

University with Degrees in Aeronautical Science, Aeronautical Studies and has been 

involved with many government UAS programs since the early 90's, with awards 

received from the Association of UVS for High Altitude and Very Long Endurance 

Aircraft (Classified Program). ImageKeeper's founders invented Direct Digital 

Airborne Camera Systems, US Patents 5,999,211, 5,604,534 for the U.S Government 

and 25 other patents relating to GPS, digital cameras, imaging technology and 

airborne surveillance. Google acquired the airborne camera company and 

technology established by the Image Keeper founders. 

Image Keeper will develop a complete training course designed by our staff FAA 

Commercial Certified pilot who has an extensive security background as well as 

considerable experience with fixed wing aircraft and technology development. 

ImageKeeper will require each potential UAS company pilot to successfully 

complete a training that combines private pilot ground school that is relevant to 

small UAS. He/she will be required to log 15 hours of total time as a UAS pilot and 5 

hours as a UAS pilot operating the particular make and model of UAS to be utilized 

for operations under this exemption. In addition, the UAS pilot will be required to 

certify that he or she has no medical defects that would make him or her unable to 

pilot a small UAS in a safe manner, including requirement to wear correct lenses if 

required. In addition, in order to meet all ImageKeeper requirements, the candidate 

will be required to have a clear criminal background check and drug test. All pilot 

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certification training will take place under the direct supervision and control of a 

person holding an FAA Commercial or private pilot certificate. 

Public Interest Benefits 

Approval of Image Keepers' request to use UAS to inspect insurance policyholders' 

private property in time of need is in the public interest. Granting this petition 

advances Congress' goal of integrating civil UAS into the national airspace safely and 

expeditiously. Allowing ImageKeeper to conduct the aerial data inspections 

proposed herein is a necessary step toward realizing the consumer benefits of using 

UAS in the insurance industry for flood, hail damage, hurricane and tornado. In 

addition, ImageKeeper is a proven hi- technology leader and developer of new and 

novel technology. Its past proven management team has over 25 patents which 

have created many digital camera companies that have provided thousands of jobs 

in the United States. They continue to develop technology useful to many 

businesses and the law enforcement communities, which provide safety and 

security for the United States. 

Further, ImageKeeper desires to work with, report, share findings, discuss, or 

brief on technology, that might happen to be in development in any process or 

avenues the FAA would like to collaborate in order to insure safety, security, and 

interest in the United States. 

In addition to improving UAS operational safety, granting this petition would 

improve safety for our customers, clients, and professionals with whom we work, as 

well as reduce the risk and damage to customer properties by eliminating the need 

to put humans on roofs and in dangerous flooding conditions. In addition, these 

UAS surveys will prove faster, cheaper, fraud resistant and more accurate 

technology. ImageKeeper makes the data un-modifiable. ImageKeeper also 

believes that these benefits will integrate into other areas of advanced electronic 

insurance processes, such as automatic mobile claims processing, underwriting 

processing and quality assurance, thereby saving money for the consumers. 

System Operation Parameters, Operations, Inspection and Maintenance 

Manual 

The proposed operating limitation describes how ImageKeepers' UAS operations 

will be safely conducted to minimize risk to the national airspace or to person and 

property on the ground. 

1. The operations will be conducted using only one of these at a time, a 3DR 

IRIS+, DJI Phantom 2 or DJI Inspire 1, .which are small UAS, weighing 

approximately 4.4 to 6.4 pounds with payload.3 

2. Flights will be operated at all times within visual line of sight (VLOS) of a 

pilot (PIC) under FAA issued medical requirement certificate, corrective 

3 The operationaljuser, safety manuals for each, 3DR IRIS+, DJI Phantom 2, DJI Inspire 1 are included as part of this 

document as an attachment. 

6 
lenses if required by FAA medical and logging all time, location and duration 

of flights, and having a U. S. driver's license. The VO and PIC will be able to 

communicate verbally at all times. The PIC will be designated before each 

flight and will not transfer designation for the duration of the flight. The PIC 

is required to ensure the VO can perform the duties required of the VO. The 

VO and PIC will not use electronic messaging or texting during flight 

operations. 

3. The UAS will be operated at an altitude of no more than 400 feet above 

ground level (AGL). Altitude must be reported in feet AGL. 

4. The UAS will not be flown at ground speeds exceeding 87 knots using either 

ground speed or calibrated airspeed to determine compliance with 87 know 

speed restrictions. In no case will the UAS be operated at airspeeds greater 

than the maximum UAS operating airspeed recommended by the aircraft 

manufacturer. 

5. The lmageKeeper UAS will not carry any persons, pilots, crew, animals, 

flammable liquid fuels, chemicals, explosive materials or defensive weapons. 

6. All ImageKeeper UAS flights will terminate at 30% battery reserve. 

7. All ImageKeeper flights will be operated at an altitude of no more than 400 

feetAGL. 

8. All ImageKeeper flights will be operated in only VFR conditions and official 

daylight conditions reported by nearest airport ATIS. UAS operations will not 

be permitted during night as defined in 14 CFRl.l. 

9. Prior to any ImageKeeper UAS removed from active status for maintenance 

or alteration that affects the UAS operation or flight characteristics, such as 

component replacement, etc., will undergo a functional test flight in 

accordance with ImageKeepers Maintenance process manual prior to 

returning to active flight status complete with notes/approval signatures. 

10. Prior to each flight, the ImageKeeper pilot must inspect the UAS to ensure 

that it is in a safe flight condition with a checklist. If any item on the checklist 

is deficient, then the UAS is prohibited from operating until the required 

maintenance has been performed and found safe for flight. The flight 

manager is required to properly document in the aircraft records the type, 

parts, date, the person who made the changes, and a signature approval of 

the pilot noting corrections and flight safety approval. 

11. Each manual contains the preflight information for each model. Preflight 

inspection includes the requirements that the inspection must account for 

including any discrepancies (squawks found). They shall be listed and noted. 

Preflight must account for all potential discrepancies, inoperable 

components, items, or equipment. If the inspection reveals a condition that 

effects the safe operation of the UAS, the aircraft is prohibited from operating 

until the required maintenance has been performed and UAS is found to be in 

a condition for safe flight. 

12. The operator must follow the UAS manufacturer's inspection and record 

keeping requirements in accordance with the manual. Maintenance, 

inspection and alterations must be noted in the aircraft records, including 

total flight hours, description of work accomplished and the signature of the 

authorized person returning the UAS into service. The operator will be 

7 
responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

13. The operator must follow the UAS manufacture's hull/components 

maintenance overall replacement, inspection and life limit requirements. 

14. All ImageKeeper UAS operated under the exemption must comply with all 

manufacturer safety and operational materials, bulletins, documents, and 

safety of flight notification. 

15. All Image Keeper flights shall be conducted over private or controlled access 

property with permission for each flight from the landowner or authorized 

represented. Permission for the owner or authorized represented will be 

obtained for each flight to be conducted. A record shall be made of each of 

the approvals with time, date, and name. All of this will become part of the 

overall mission data capture located in ImageKeeper's electronic system. 

16. Each ImageKeeper flight will be operated by a PIC holder of a commercial, 

private, recreational, or sport pilot certificate, with current FAA medical 

certificate, a valid U. S. driver's license issued by a state. The PIC will also 

meet flight review requirements specified in 14 CFR 61.56 in an aircraft in 

which the PIC is rated on his or her pilot certificate. 

17. Flight operations will be conducted at least 500 feet from any non-person 

who is nonparticipating. The operator will ensure the nonparticipating 

person remains under protection. If nonparticipating leave protection and 

within 500 feet then all flight operations will cease immediately. The UAS will 

not be operated near a vessel or structures where the owner of such vessel 

or structures have not granted permission. 

18. By using GPS technology, ImageKeeper establishes boundaries made up of 

GPS coordinates (GPS operations box area with ceiling of 400 feet AGL) in 

which the UAS will operate. 

19. ImageKeeper will have a 25-foot clearance around the UAS departure point 

and the recovery area, which will be located at same point of departure. This 

will be the landing and take off point for the UAS. There will be no overhead 

obstructions within 400 feet of the vertical departure point. The UAS pilot 

will be the sole designation for lmageKeeper in locating the departure and 

recovery location. 

20. The ImageKeeper UAS will be preprogrammed to return to the departure 

point for any false takeoff, emergency or aborted flight.· No obstruction, 

including animals, birds, or power lines shall be in the takeoff path of the UAS 

prior to takeoff. If the UAS loses communication or loses its GPS signal, the 

UAS will return to a predetermined location within the private or controlled 

access property. 

21. All Image Keeper aircraft will have an N number marking identification by 

serial number and registered in accordance with 14 CFR Part 47,49 C. 

22. ImageKeeper will comply with all Federal Communication Commission 

requirements for control and operation of UAS. 

23. The UAS will meet the VFR flight minimums including cloud clearance and 

visibility requirements. UAS may not be operated less than 500 feet below or 

less than 2,000 feet horizontally from a cloud or when visibility is less than 3 

statute miles from the PIC. The PIC is prohibited from beginning a flight 

8 
unless considering wind and forecast weather conditions there is enough 

available power for the UAS to conduct the intended operation and operate 

after that for at least five minutes or with reserve power recommended by 

the manufacturer. 

24. Before conducting operations, a qualified UAS pilot will demonstrate and log 

per 14 CFR 61.51 (b) ability to operate the UAS in a manner consistent with 

how the UAS will be operated under the exemptions, including evasive and 

maneuvers, emergency and maintaining appropriate distances from people, 

vessels, vehicles, and structures. PIC qualification flight hours and currency 

will be logged consistent with 14 CFR 61.51 (b). 

25. ImageKeeper flight operations will only occur in Class G airspace. The UAS 

may operate within 5 nautical miles of geographic center of an airport as 

found on current FAA published aeronautical charts unless an agreement 

with the airport management and COA is obtained and operated in 

accordance to NOTAM. Any agreement must be made available to the 

Administrator or any law enforcement official upon request. 

26. ImageKeeper (operator) will comply with the operating, inspection, 

maintenance and record keeping procedures set forth in the UAS manual. 

27. The UAS must remain clear and yield the right of way to all other manned 

operations and activities. 

28. The PIC will abort the flight in the event of unpredicted obstacles or 

emergencies. 

29. The UAS may not be operated by pilot from any moving device or vehicle, 

such as a car, trucks, cranes, hi-lift etc. 

30. All documentation required under 14 CFR § 91.9, 203 will be accessible to 

the pilot at the ground station, during flight operations and to the FAA 

administrator and or law enforcement. It is operator responsibility to track 

revisions and present them to the Administrator oflaw enforcement. 

31. Any accident must be reported to the NTSB. In the event a Certificate of 

Authorization (COA) is required, any incident, accident, or flight operation 

that transgresses beyond the boundaries of the operating area as defined by 

the COA must be reported to the FAA' AUS Integration Office within 24 hours. 

Operation and Training Manuals 

ImageKeeper will follow the operating procedures set forth in the manual 

attached to this document in support of this petition. The manual will be 

maintained and will be made available to the FAA if requested. ImageKeeper will 

communicate with the FAA on any issue relating to operation and training manuals. 

The manuals and training will be under configuration control. 

Inspection and Maintenance 

ImageKeeper will manage its UAS fleet according to procedures called out in the 

inspection and maintenance sections of the UAS manuals, which will be submitted 

as part of this petition. The manuals will be maintained at Image Keeper and will be 

made available to the FAA as required or requested. 

9 
Image Keeper's AUS Vehicles 

ImageKeeper proposes to utilize the following models types of UAS to conduct 

operations, a DJI Phantom 2, 3DR IRIS+ and DJI Inspire 1. 3DR IRIS+ has a weight of 

2.8 pounds and a range of 300 meters. Its maximum flight time is averaging at 22 

minutes. The DJI Phantom 2 has a weight of 2.56 pounds and a range of 300 meters. 

Its maximum flight time is averaging about 25 minutes. DJI Inspire 1 has a weight of 

5.4 pounds without gimbal using standard cameras and an average flight time of 18 

minutes. 

Image Keeper will maintain a GPS coordinate box perimeter /boundary (GPS geefence) including a maximum ceiling of 400 feet AGL. GPS lateral box boundaries will 

be maintained at all times and clearances with structures and humans will be 

surveyed prior to any flight. Flight launch and recovery location will be cleared of 

any non-participants at all times during operation. The property owner prior to any 

operation will consent/approve all property surveys. At all times the automatic 

recovery to the recovery site will be engaged and programmed according the 

operational manual on each UAS. All operation will be conducted in official daylight 

hours and under the VFR rules and visibility conditions by an ImageKeeper certified 

UAS pilot. Each ImageKeeper UAS will have the proper markings identifying the 

serial number and identification (N-number), which will also be integrated into 

ImageKeeper data, capture system. All UAS operations will comply with the 

manufacturer's operational, training, and safety notices. ImageKeeper will maintain 

a log showing date, time, mission, mission parameters, altitude, and geographic 

position of the AUS at every point of the mission. This data is unalterable, stored in 

an off site location, and will be made available to the FAA for any reason necessary. 

This is part of the Image Keeper technology. Image Keeper's system allows tracking, 

organized aerial image data, image location, image capture times and the ability to 

look at large data image files, as all data is globally searchable. It would be possible 

to utilize this data system as a UAS black box data recovery system. We would be 

happy to share this information with the FAA if interested. ImageKeeper records 

offsite the exact UAS location, direction, time and date. 

FAA has Authority Under FMRA Section 333 to Grant the Requested 

Exemptions. 

By granting this request for exemption will allow promotion of Congress' goal in 

enacting Section 3333 of the FMRA. Sec. 333 directs the Sec. of Transportation to 

consider whether certain UAS may operate safely in the national airspace before 

completion of the rulemaking required under Section 332 of the FMRA. The 

Secretary is required to determine the kind of UAS operations that do not create a 

hazard to users of the national airspace or the public or pose a threat to national 

security in light of the UAS' size, weight, speed, operational capability and areas of 

operation and whether the operations will occur within the visual line of sight of the 

10 
operator.4 Section 333 reflects Congressional intent that FAA will grant exemptions 

to allow small UAS operations under conditions that ensure safety, like those 

proposed in this lmgeKeeper petition. 

In addition, the Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority by the terms includes exempting civil aircraft 

(as defined under 40101 of the Act which in includes UAS) from the requirements 

that all such aircraft must have a current airworthiness certificate and granting 

exemptions from the pilot certification requirements. The Administrator may grant 

an exemption from a requirement of a regulation under§ 44701 (a.) or (b.) or in§ 

44702-44716 of the Act, if the Administrator finds the exemption is in the public 

interest. s 

Application Information 

Name and address of the applicant 

ImageKeeper LLC 

Jerry Speasl 

President and CEO 

P. 0. Box 27740 

Las Vegas, NV 89126 

jspeasl@imagekeeper.com 

702-308-7985 

List of Regulation from which ImageKeeper requests Exemption 

14 C.F.R. § §61.113 (a.) and (b.), 61.133 (a) 

14 C.F.R. § 91.7 (a.) 

14 C.F.R. § 91.119 (b.) and (c.) 14 C.F.R. § 91.121 

14 C.F.R. § 91.151 (a) 

14 C.F.R. § 91.405 (a) 

14 C.F.R. § 91.407 (a), (1) 

14 C.F.R. § §91.409 (a), (1), (2) 

14 C.F.R. § §91.417 (a), (b) 

Federal Register Summary 

Petitioner: ImageKeeper LLC 

Affected regulations: 14 C.F.R. § §61.113 (a) and (b), 14 C.F.R 61.133 (a), and 14 

C.F.R. § 91.7 (a); 14 C.F.R. § 91.119 (b) and (c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151 

(a); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a), (1); 14 C.F.R. § §91.409 (a), (1), (2); 

14 C.F.R. § §91.417 (a), (b) 

4 FAA Modernization and Reform Act of 2012, Pub.L.No. 112-95, 126 Stat.75-76 (codified as Note to 49 U.S. C § 

40101). 

s 49 U.S.C. § 44701(f) also 49 U.S.C. § 44711 (a.), 49 U.S.C. § 44704; 14 C.F.R. § 91.203 (a,) (1.) 

11 
Description: Petitioner seeks an exemption from the requirements of 14 C.F.R. § 

§61.113 (a) and (b), 61.133 (a); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.119 (b) and (c); 

14 C.F.R. § 91.121; 14 C.F.R. § 91.151 (a); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 

(a), (1); 14 C.F.R. § §91.409 (a), (1), (2); and 14 C.F.R. § §91.417 (a), (b) to use UAS 

small unmanned aircraft systems in order to conduct small UAS operations related 

to its insurance business, including but not limited to hail roof damage, roof 

inspections, underwriting process enhancements, risk assessment, risk and accident 

reconstruction, catastrophic response for flood, tornado, hurricane, earthquake and 

UAS pilot training, development, maintenance. 

Exemptions Sought by ImageKeeper the Petitioner 

ImageKeeper requests exemptions from the following regulations to the extent 

necessary to enable the requested UAS operations for the reasons detailed below. 

14 C.F.R. § §61.113 (a) & (b): Private pilot privileges and limitations; 

14 C.F.R. § 61.133 (a): Commercial pilot privileges and limitations 

Section 61.113 (a) and (b) limit private pilots to non-commercial operations. 

Section 61.133 (a) requires an individual with a commercial pilot's license to be 

pilot in command of an aircraft for compensation or hire. The FAA has already 

determined that it is appropriate to exempt small UAS pilots from the commercial 

pilot's license requirements in section 61.133 (a). In situations analogous of those 

presented by this petition. See Exemptions #11109, 11110, 11136, and 11138. 

However, to date, FAA has required such operators to have a private pilot's license. 

ImageKeeper respectfully submits that, given the characteristics of the 3DR IRIS+, 

DJI Phantom 2 and DJI Inspire 1, the operating GPS box and ImageKeeper's level of 

past and current aeronautical education, licenses, aviation sensor development, and 

FAA certified commercial pilot, are applicable specifically to small UAS operators 

like (ImageKeeper). Given the aeronautical skills, historical knowledge of 

developing complex airborne sensors, and fielded UAS in support of wartime 

national interest, indicates ImageKeeper is competent in performing UAS services 

important to the United States. FAA certified pilots on staff, in a business that can be 

grown by creating technology made in America by Americans is important to 

meeting Congress' requirements. 

The 3DR IRIS+, DJI Phantom 2 and DJI Inspire 1 are exceedingly small and very 

lightweight. They are both advertised as lightweight UAS and are already widely 

flown by recreational and real estate companies. They operate both autonomously 

and manually. They have pre programmable GPS fencing features. They have lost 

link and lost GPS capabilities. In the event of loss of communications link or GPS the 

aircraft automatically returns to preprogrammed recovery location. They also have 

emergency flight termination system where the pilot hits a kill switch and it will 

then land. The UAS will not carry a pilot, passenger, animals, flammable, explosive, 

drugs, weapons or defensive systems, such as jammers, or microwave sensors, radar 

12 
systems, or stealth technology. The operating area is controlled and restricted, and 

all flights are planned and coordinated in advance as set forth in the manual. Image 

Keeper submits that the proposed operation can be achieved an equivalent level of 

safety by requiring the pilot of this very small lightweight, low altitude, low speed 

limited range UAS to be trained in a UAS specific certification program approved by 

FAA and administered by a Commercial FAA certified pilot. 

14 C.F.R. § 91.7 a: Civil aircraft airworthiness 

Section 91.7 (a) requires that no person may operate a civil aircraft unless it is in 

airworthy condition. Given the characteristics of the UAS and stringent operating 

restrictions and conditions proposed in this petition, and equivalent level of safety 

will be achieved by compliance with the operations manual. Imagekeeper therefore 

requests FAA to grant an exemption from section 91.7 (a) and finds that the 

operator may ensure that the UAS are in an airworthy condition by complying with 

the manual and the proposed operating restrictions and conditions. FAA has 

granted similar exemptions in Exemptions# 11136 and 11138. 

14 C. F. R. § 91.119 band c: Minimum safe altitudes 

Section 14 C. F. R. § 91.119 (b) and (c) established certain minimum altitude for 

operation of civil aircraft. Section 91.119 provides, in pertinent part, that "except 

for when necessary for takeoff and landing, no person may operate an aircraft below 

the following altitudes: (b). Over congested area. Over any congested area of a city, 

town, or settlement, or over any open-air assembly of persons, an altitude of 1,000 

feet above the heights obstacle and within a horizontal radius of 2,000 feet of the 

aircraft. 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. 

ImageKeeper requests relief from this section since the UAS flights will operate at 

altitude of no higher than 100 feet AGL. Given the small size, lightweight, low 

speeds and limited range of the UAS, and the fact that they carry no persons or 

explosives or flammable materials, and the UAS flights may be safely operated at 

much lower altitudes than conventional aircraft. ImageKeeper will restrict all of its 

operations to an altitude of 100 feet or less and will utilize GPS geo fencing 

technology to prevent deviation. Relief from this rule is warranted because the 

operations will be conducted with the safeguards and under the operating 

conditions outlined herein and in the safety and operations manual. The FAA has 

issued an exemption from Section 91.119 (c) in Exemptions# 11136 and 11138. 

14 C. F. R. Altimeter Settings§ 91.121: Altimeter settings 

Section 91.121 requires each person operating an aircraft to maintain crmsmg 

altitude by reference to an altimeter that is set to the elevation of the departure 

airport or an appropriate altimeter setting available before departure. An 

13 
exemption may be needed because the UAS does not have a barometric altimeter, 

but instead have a GPS altitude read out. An equivalent level of safety will be 

achieved by the operator, pursuant to the manual, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight. The FAA issued an 

exemption to this regulation for UAS operations in Exemptions# 11136 and 11138. 

14 C.F.R. 91.151 a Fuel requirements for VRF conditions 

Section 91.151 a prohibits an individual from beginning 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, 2. During the day, and after that for at least 30 minutes. 

An exemption is needed because the UAS have a maximum flight time of less than 30 

minutes and this cannot meet the 30-minute reserve requirements. Given the 

characteristics of the UAS including their small size, low weight and speed, limited 

range, ability to land very quickly, operations within visual line of sight, restricted 

operating area, and the fact that they do not carry persons or any explosive or 

flammable materials, grant of the exemption is justified. An equivalent level of 

safety can be achieved by terminating flights at 25% battery power reserve, which 

will occur before the 25-minute flight duration. The FAA issued an exemption to 

this regulation for UAS operation in Exemption# 11062,10673, 111136 and 11138. 

14 C.F.R. § 91.405 a: Maintenance required 

14 C.F.R. § 91.407 a, 1: Operation after maintenance, preventive maintenance, 

rebuilding or alteration 

14 C.F.R. §§ 91.409 a, 1 and 2; Inspections 

14 C.F.R. §§ 91.417 (a) and (b); Maintenance records 

These regulations require that an aircraft operator owner (i) shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required 

inspection, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter .... And (ii) shall inspect or maintain 

the aircraft in compliance with part 43. Because these sections and part 43 apply 

only to aircraft with an airworthiness certificate, these sections will not appy to the 

petitioner. Maintenance will be accomplished by the operator pursuant to the 

manufacturer's manual. An equivalent level of safety will be achieved because the 

UAS are very small in size and weight, will carry a small payload and operate only in 

very restricted areas (defined by the GPS fence) and 100 feet of altitudes for short 

periods of time. If mechanical issues arise, the UAS can land immediately and will be 

operating from no higher than 100 feet AGL. As provided in the manual, the 

operator will ensure that the UAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the operator is most familiar with the UAS and best suited to maintain the 

UAS in an airworthy condition and provide an equivalent level of safety. The FAS 

issued an exemption to these regulations in Exemption# 11062, 11136 and 11138. 

14 
Such other relief as the FAA deems appropriate to enable the requested 

operation 

ImageKeeper also requests exemption from such other FARs as the FAA deems 

appropriate to enable the requested operations. If, during the effective dates of the 

exemption issued per this petition, thee FAA issues interim or final rules for small 

UAS, ImageKeeper requests that it be relieved of the requirements of any conditions 

and limitation of the exemptions and allowed to comply with any less restrictive 

applicable regulations that may have become effective. 

Privacy 

The petition raises no privacy issues because all flights will occur over private or 

controlled access property with the property owner's prior knowledge and consent. 

In addition, Image Keeper's privacy polices would apply to all UAS operations. 

National Security 

No national security issues are presented by grant of this exemption. ImageKeeper's 

management, experience with UAS, small UAS footprint, lightweight, lost link, geo 

fencing, and carrying no defensive, offensive, guns, flammable, chemicals, or 

explosives or any dangerous materials and ope\ated by professionals, assures this. 

Conclusion 

For the reasons stated above, ImageKeeper proposed use of UAS satisfies the 

criteria in the FMRA Section 333 regarding size, weight, speed, operating 

capabilities, operating areas, operation within visual line of sight, and national 

security. 

Petitioner's proposed safety measures and operating parameters provide more than 

adequate justification for the grant of the requested exemptions allowing operation 

of UAS. Image Keeper therefore respectfully asks the FAA to grant the requested 

exemptions. Please do not hesitate to contact ImageKeeper, (petitioner) with any 

questions about this filing. 

o./.. . j . ~ I 5'-1 f!~/5' Jerry 

President 

Speasl 

and 

~ 

CEO 

ImageKeeper LCC 

P.O Box 27740 

Las Vegas, NV 89126 

jspeasl@imagekeeper.com 

702-308-7985 

Attachments: Maintenance, Operations/User Manuals 

• 3DR IRIS+ 

• DJI Phantom 2 

• DJI Inspire 1 

15