UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 20591 

In the matter of the petition of 

AERIAL ADVANTAGES, LLC, for an 

exemption from§§ 61.23(a) and (c), 

6l.IOI(e)(4) and (5), 61.1 13(a), 61.3 15(a), 

91.7(a), 91.1 J9(c), 91.121 , 91.151(a)(l), 

91.405(a), 91.407(a)(1), 91.409(a)(l) and (2), 

and 91.417(a) and (b) of Title 14, Code of 

Federal Regulations. 

Exemption No. 14744A 

Regulatory Docket No. FAA-2015-3928 

DENIAL OF EXEMPTION 

Aeria

By letter posted to the public docket on May 24, 2016, Mr. Brent Forman, on behalf of 

Administration 

l Advantages LLC, 6 Ross Street, Nashua, NH 03060, petitioned the Federal Aviation 

(FAA) for an exemption from§§ 61.23(a) and (c), 61.10l(e)(4) and (5), 

61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121 , 91.151(a)(l), 91.405(a), 91.407(a)(l), 

91.409(a)(l) and (2), and 91.417(a) and (b) ofTitle 14, Code of Federal Regulations. The 

operate 

petitioner 

UAS 

requested to renew Exemption No. 14744, which expires February 28, 2018, to 

to conduct aerial data collection and closed-set motion picture filming. 1 

The petitioner supports its request with the following information: 

The original petition for exemption describing the proposed operation and the regulations 

http:

from which the petitioner seeks exemption is posted to the docket. To view the petition, visit 

//www.regulations.gov, enter the regulatory docket number found on the first page of this 

next 

document into the search box and click "Search," then click on the "Open Docket Folder" link 

to a result associated with the docket number. 

The FAA's analysis is as follows: 

The FAA has finalized the first operational rules for routine commercial use of small 

unmanned aircraft systems (part l 07). The new rule is now in effect and offers safety 

regulations for unmanned aircraft drones weighing less than 55 pounds. The FAA has 

reviewed your request and determined that your requested operation may be conducted 

entirely under part 107, Operation and Certification of Small Unmanned Aircraft Systems, 

1 The petitioner also requested the authorization to operate additional aircraft. Please 

reference Docket No. F AA-20 15-3928-0007 for the amendment that permits this request. 
2 

without exemption or need for waiver under the provisions of 14 C.F.R. § 107.200. 

Section 333 of Public Law 11 2-95, Special Rules for Certain Unmanned Aircraft Systems 

(UAS), provided the FAA authority to authorize certain UAS operations. This incremental 

step provided a pathway for safe and legal civil operations in the National Airspace System 

(NAS) and was considered a bridge mechanism until the implementation of part 107. Now 

that part l 07 is in effect, the vast majority .of operations authorized under previously issued 

exemptions under Section 333, including the operations proposed in this petition for 

exemption, can be conducted under part l 07. These operations no longer necessitate an 

exemption. 

The FAA's decision: 

In consideration of the foregoing, I find that a grant of exemption is not 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, the petition of Aerial Advantages LLC is hereby 

denied. The petitioner may begin operations in accordance with 14 CFR, part 107: Opera/ion 

and Certification of Small Unmanned Aircraft Systems immediately. 

Issued in Washington, DC on FEB 2 3 2017 

rf'LJ 

John S. Duncan 

Director, Flight Standards Service