Aerial Anthropology LLC

REQUEST FOR EXEMPTION

Aerial Anthropology LLC

Thomas Davis, Owner

4702 Grace Rd. 

North Olmsted, OH 44070

ENTITY ID: 2390423

TABLE OF CONTENTS:

1. Request for Exemption – purpose and operations of Aerial Anthropology

2. Exemption Details

3. Appendix A – Inspire1 Safety and Flight Details

4. Appendix B – Inspire1 Specifications

5. Appendix C – Phantom1 Safety and Flight Details

6. Appendix D – Phantom1 Specifications

7. Appendix E – Aerial Anthropology General Safety Standards

8. Appendix F – Aerial Anthropology LLC – Certificate of Approval – State of Ohio

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 

14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 

14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) 

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 

11, Aerial Anthropology LLC, operator of Small Unmanned aircraft Systems (“UAS”), applies for an exemption 

from the listed Federal Aviation Regulations to allow commercial operation of its UAS, so long as such operations 

are conducted within and under the conditions outlined herein or as my be established by the FAA as required by 

Section 333. 

Aerial Anthropology will use UAS to capture aerial videography and photography. Aerial Anthropology will not 

poses any risk to national security interests in any way and will be dedicated to promoting the safe operation and 

flight of UAS within the National Airspace. Aerial Anthropology LLC intends to use aerial videography and 

photography to produce high quality media that can serve as a tool to aid in the study of human culture and provide 

historical reference for future generations. In addition, Aerial Anthropology will use aerial videography and 

photography to provide high quality media used in marketing efforts for several industries including, but not limited 

to businesses, municipalities, cities, states, parks, non-profit organizations, and academia. 

The Commercial operation of UAS equipped with photography equipment, as described herein, would operate in the 

following manner: 

1. Aerial videography for public and/or private use including but not limited to marketing, insurance, agriculture, 

architecture, historical reference, video services, real estate, golf courses, land surveying, events, and other related 

professional activities.

2. Aerial photography for public and/or private use including but not limited to marketing, insurance, agriculture, 

architecture, historical reference, video services, real estate, golf courses, land surveying, events, and other related 

professional activities. 

3. Aerial photography for public and/or private use including but not limited to television, public events, and other 

cinematography projects.

4. Aerial videography for public and/or private use including but not limited to television, public events, and other 

cinematography projects.

5. Aerial inspection/photography of residential/commercial structures under contract with the owners or local 

government authority. 
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6. Provide safety training and education to hobbyists, photographers, and organizations that will be operating UAS. 

Our intention is to spread awareness and ensure safety and best practices by placing education at the forefront of this 

industry. 

7. Provide consulting on the best practices around the purchase, use, flight, safety, and maintenance of UAS

As described in the pages below, the requested exemption would permit the operation of UAS under controlled 

conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety 

enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s)

responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace 

system.” 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 

The UAS are multi-rotor craft weighing no more than 55lbs. including payload. Under normal conditions they 

operate at speeds of no more than 50kts and have the ability hover and move along a vertical and horizontal plane 

simultaneously. They will operate in line of sight (VLOS) and will operate within the rules of the NAS and in only 

areas deemed safe for flight.

Based on the equipment that will be used and the safety procedure in place our proposed operations will completely 

adhere to the Reform Act’s safety requirements. The approval of this application presents no national security 

issues. Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in 

environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested 

exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested exemption 

with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because operations will further 

enhance the safety of the persons and/or property using conventional aircraft. 

These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations 

under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) include: 

1. The UAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum flight time for each operational flight will be less than 30 minutes. Flights will be terminated at 25% 

battery power reserve or 30 minutes of flight time whichever occurs first. 

4. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 

200 feet above an elevated platform from which filming is planned. 

5. Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may also involve 

a Camera Operator in certain situations, but will not be required in addition to the PIC and the VO. 
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6. The UAS pilot will be a designated Pilot in Command (PIC). If the PIC feels another operator to be qualified with 

the necessary skills to be PIC & possess a valid state driver’s license, that person may be designated PIC provided 

they have a minimum of 40 hours of flight time with the UAS. 

7. A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of all the 

days’ production activities. 

8. The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the requested exemption, with 

the appropriate local Flight Standards District Office (FSDO) no more than 72 hours but no less than 48 hours from 

planned operation.

9. The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that 

only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 

feet based upon an equivalent level of safety determination, as required under the FOM. With the advanced 

permission of the FSDO, operations at closer range may be approved. 

10. The PIC and VO will have been trained in operation of UAS and will maintain current knowledge of UAS. 

11. The PIC and VO will be able to clearly communicate by voice, radio, and/or text at all times. 

12. Written and/or verbal permission and permits will be obtained, when necessary, from territorial, state, county or 

city jurisdictions, including law enforcement, fire or other appropriate governmental agencies. 

13. If the UAS loses communications or loses GPS signal, the UAS will have the capability to return to a predetermined location within a designated location and land autonomously. 

14. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated 

with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 

U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria 

demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating 

with an airworthiness certificate without the restrictions and conditions proposed. 

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no 

explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike 

other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator 

and under the requirements and in compliance with local public safety requirements. The FAA will have advance 

notice of all operations. These safety enhancements provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, 

Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security 

posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted 

or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display 

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 

than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no 

entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the 

UAS, two-inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance 

with §45.29 (f). 

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) 

where the pilot, observer and others working with the UAS will see the identification of the UAS as “Experimental.” 

14 C.F.R. § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.113 

(a), no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying 
Aerial Anthropology LLC

passengers or property for compensation or hire. Our UAS do not carry any pilots or passengers nor property 

therefore I am seeking an exemption to 14 CFR 61.113(a). Although helpful, a pilot’s license will not ensure remote 

control piloting skills. The risks attendant to the operation of UAS is far less than the risk levels inherent in the 

commercial activities outlined in 14 CFR 61. I feel the operation and limitations set forth in the FOM will equate to 

the safe operation of the UAS. 

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be 

no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard 

will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety check lists 

prior to each flight an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (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. The UAS, given its size and configuration has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an 

item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the UAS will have immediate access to it. 

14 C.F.R. § 91.103: Preflight Action. 

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As 

FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC 

will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and 

aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight Instruction. 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used 

for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, by 

their design do not have fully functional dual controls. Flight control is accomplished through the use of a control 

box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight 

training without fully functional dual controls for a number of aircraft and for flight instruction in experimental 

aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the 

aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum Safe Altitudes. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be 

operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route 

or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform 

from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS 

will never operate at higher than 400 AGL with the exception that in circumstances where the UAS is used to survey 

or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be operated more than 100' above 

the highest point on the structure. It will however be operated in a restricted area with security perimeter, where 

buildings and people will not be exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location 

where it is operated. No flight will be taken without the permission of the property owner or local officials. Because 

of the advance notice to the property owner and participants in the filming activity, all affected individuals will be 

aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more 

than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations 

is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the 

low-altitude operations of the UAS will ensure separation between these small- UAS operations and the operations 

of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings. 
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This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter 

that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” 

As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data 

monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR 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 – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to 

fly after that for at least 45 minutes.” 

The battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve 

requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the 

limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined 

area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating 

the small UAS, in a tightly controlled area where only people and property owners or official representatives who 

have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks 

that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting 

UAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted. Applicant 

believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery 

power— whichever happens first. This restriction would be more than adequate to return the UAS to its planned 

landing zone from anywhere in its limited operating area. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: 

(1) An appropriate and current airworthiness certificate. . . . 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this 

section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew. 

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no 

ability or place to carry certification and registration documents or to display them on the UAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the 

pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the 

aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant 

to the flight manual and operating handbook. An equivalent level of safety will be achieved because these small 

UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods 

of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet 

AGL. 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 the person most familiar with 

the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. 

An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance 

with the UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual (AOM). As provided in the 

FOM, the operator will ensure that the UAS is in working order prior to initiating flight and perform required 

maintenance needed.