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Advanced Aerial Imagery, LLC

1110 E. Hidden Ranch Cir.

Palmer, AK 99645

October 8, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington DC 20590

Reference: Exemption Request Pursuant to Section 333 of PL 112-95 and Part 11 of the Federal 

Aviation Regulations from: 14 CFR §§ 21 subpart H; 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).

Dear Sir or Madam:

Advanced Aerial Imagery, LLC seeks exemption from the requirements listed above to operate a small

Unmanned Aircraft System (sUAS) pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA). This exemption will permit Advanced Aerial Imagery, LLC to operate an Unmanned 

Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography over 

certain areas of the United States.

I. NAME AND ADDRESS OF THE PETITIONER

The name and address of the Petitioner and point of contact is:

Chad Nuttall

Advanced Aerial Imagery, LLC

1110 E. Hidden Ranch Cir.

Palmer, AK 99645

II. REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED

Advanced Aerial Imagery, LLC requests exemption from the following applicable regulations, 

pursuant to the Administrator’s authority to grant exemptions contained in 49 U.S.C. 

§106(f), 40113, and 44701: 

 14 CFR 61.23 (a) and (c)

 14 CFR 61.101 (e)(4) and (5)

 14 CFR 61.113 (a)

 14 CFR 61.315 (a)

 14 CFR 91.7 (a)

 14 CFR 91.119 (c)

 14 CFR 91.121

 14 CFR 91.405 (a)
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 14 CFR 91.407 (a)(1)

 14 CFR 91.409 (a)(1) and (2)

 91.417 (a) and (b)

III. PROPOSED UAS

Advanced Aerial Imagery, LLC seeks the above exemptions to operate DJI Phantom 3

Professional sUAS’s for compensation or hire within the NAS. The DJI Phantom 3 

Professional is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground 

Control Station (GCS) utilizing electronic tablet or smartphone systems. The DJI Phantom 3 

Professional has a maximum gross weight of 2.82 pounds, a length of 23.2 inches (square 

size in all dimensions), height of 10 inches, and a maximum speed of approximately 31 

knots. The DJI Phantom 3 Professional is equipped with four main rotors; driven by Lithium 

Polymer battery powered electric motors. The most current operator’s manual can be found 

at http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_

en_0915.pdf. 

The Phantom 3 Professional’s that will be operated by Advanced Aerial Imagery, LLC will be 

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R 

Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification 

and Registration Marking. All operators possess at a minimum, a Private Pilots Certificate 

and a current Airman’s Third Class Medical Certificate. 

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, Advanced Aerial Imagery, LLC operation of DJI 

Phantom 3 Professional meets the conditions of FMRA Section 333 and therefore, will not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Advanced Aerial Imagery, LLC requests relief from Sections 91.405(a), 91.407(a) 

(1), 91.409(a) (1) & (a) (2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. Advanced Aerial 

Imagery, LLC submits that the requested relief is proper since an equivalent level of safety 

will be ensured. Advanced Aerial Images, LLC will use experienced personnel or technicians 

to perform maintenance, alterations, or preventive maintenance on the sUAS’s using the 

methods, techniques, and practices prescribed in the operating documents.

Advanced Aerial Images, LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 3 Professional does not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Advanced Aerial Images, 

LLC will ensure that the DJI Phantom 3 Professional is in condition for safe operation, prior 

to every flight, by determining that the sUAS is in compliance with the operating documents 

and that the aircraft is in a condition for safe flight.

Advanced Aerial Images, LLC also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as DJI Phantom 3 Professional will not have a typical 

barometric altimeter onboard. However, altitude information of the DJI Phantom 3 
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Professional will be provided to the PIC via GPS equipment and radio communications 

telemetry data link, which downlinks from the sUAS to the GCS for active monitoring of the 

flight path. This altitude information, combined with Advanced Aerial Imagery, LLC 

operation of the DJI Phantom 3 Professional within visual line of sight, at or below 400 feet 

AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, Advanced Aerial 

Images, LLC seeks an exemption from the requirements of Section 91.151(b) entitled Fuel 

requirements for flight in VFR conditions. Advanced Aerial Images, LLC submits that safety 

will not be affected by operation of DJI Phantom 3 Professional during daylight hours in 

visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery 

power to fly for a total duration of approximately 18 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 4 minutes.

FCC compliance information can be found in the operator’s manual at http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_

en_0915.pdf. All camera and sensor equipment on board the Phantom 3 Professional 

complies with current FCC requirements. 

IV. UAS PILOT IN COMMAND

Advanced Aerial Imagery, LLC petitions for relief from certain requirements of Section 

61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, to the 

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, as well as an airman medical certificate, and who has demonstrated, that the PIC 

is able to safely operate the DJI Phantom 3 Professional in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

V. PROPOSED OPERATION(S) OF THE UAS

Advanced Aerial Images, LLC proposes the following guidelines and limitations to ensure 

safety in the NAS:

1. The DJI Phantom 3 Professional will be operated at less than 40 knots groundspeed. 

2. Flights will be operated within unaided visual line of sight of an operator and observer. 

3. Flights will never be operated directly over a person, and will remain at least 100 feet

from all persons. 

4. All flights will be conducted in daylight, Visual Flight Rules (VFR) conditions. 

5. Flights will be operated at an altitude of no more than 400 feet AGL. 

6. Maximum total flight time for each operational flight will be 30 minutes. 

7. Flights will be terminated at 20% battery power reserve should that occur prior to 30 

minutes. 

8. Minimum crew for each operation will consist of the sUAS Operator, the Visual Observer 

and may include a security coordinator. 

9. The sUAS operator will be an Advanced Aerial Imagery, LLC trained operator and will 

maintain at least an FAA third class medical certificate. The observer will be an

Advanced Aerial Imagery, LLC trained observer.
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10. A briefing will be conducted in regard to the planned sUAS operation prior to each flight. 

All Advanced Aerial Imagery, LLC personnel who will be participating in that flight shall 

be present for the preflight briefing. 

11. When necessary, and at least 72 hours prior to flight, the operator will file FAA Form 

7711-1, or its equivalent, with the appropriate Flight Standards District Office. 

12. Observer and Operator will at all times be able to communicate by voice with each 

other. 

13. When necessary, permission from relevant property owners will be obtained. 

14. If the sUAS suffers a ‘lost link’, the DJI Phantom 3 Professional will perform the 

predetermined flight maneuver to land as soon as practical as outlined in the preflight 

briefing. 

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

emergencies. 

16. All accidents and incidents shall be recorded in the aircraft log and reported in 

accordance with FAA directives.

Sincerely,

Chad Nuttall

Managing Member