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June 1, 2015

John Holden

AGL Imaging LLC

13037 Bathgate Way 

Bristow, VA 20136

Cell 757-537-3325

Email: jholdenatp@gmail.com

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave SE 

Washington, DC 2059 

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 

Attachments: 

1) DJI Inspire User Manual v1.2 - Link HERE (File too large to upload)

2) DJI Inspire Maintenance Manual v1.0

3) DJI Inspire Safety Guidelines v1.0

4) DJI Phantom 3 Professional User Manual v1.2 - Link HERE (File to large to upload)

5) Yuneec Q500+ User Manual

References: 

1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the matter of the 

petition of DOUGLAS TRUDEAU 

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the matter of the 

petition of ADVANCED AVIATION SOLUTIONS LLC 

3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in the matter of the 

petition of FLYING CAM INC 

Dear Sir or Madam, 

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 

333 of the FAA Modernization and Reform Act of 2012, AGL Imaging LLC, referred to 

hereafter as the petitioner, request exemption from the following sections of Title 14, Code of 

Federal Regulations:

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1); 

91.409(a)(2); 91.417(a) & (b); 

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated 

by the Federal Aviation Administration (FAA) for the purposes of aerial photography, 

cinematography, videography, mapping, crop surveying, inspections and other flight operations 

that could be performed safely and more cost effectively with the use of small UAS at low 

altitude within the U.S. national airspace system as compared to a manned aircraft. Operations 

will be performed only at the request of and with the authorization and permission of clients or 

their authorized agents in order to facilitate commerce and raise awareness of the beneficial uses
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of small unmanned air systems. So long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333. The 

conditions identified and proposed by the petitioner are drawn from references 1-3. 

The FARs 

The petitioner seeks exemption from the above mentioned FARs for the following reasons; 

61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, who 

hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under this exemption 

would be required to comply with any conditions as set forth and in a similar fashion to the 

previously granted exemptions. 

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted 

closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to 

essential persons, or objects that would not be possible without additional relief. The petitioner 

requests modification, waiver or exemption and clarification concerning the terms “congested 

areas” and “densely populated”. The petitioner requests waiver for this condition to allow 

reasonable and responsible operations in areas of subdivisions and neighborhoods if required. 

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the 

UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for 

altitude information. 

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) 

prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, 

including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief has 

been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The 

UAS provides battery power remaining in percent to the PIC. The UA batteries provide 

approximately 25 minutes of powered flight. Information provided in the operating documents 

discusses procedures regarding remaining battery power management. Those documents contain 

a condition in which the PIC will initiate a landing procedure when battery remaining reaches a 

specified level. Given the limitations on proposed operations and the location of those proposed 

operations, the FAA found that a reduced minimum power reserve for flight in daytime VFR 

conditions was reasonable. 

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 

(DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a 

condition for safe flight in accordance with the operating documents. The FAA found that 

adherence to the petitioner’s operating documents and the conditions and limitations specified, 

describing the requirements for maintenance, inspection, and record keeping, were sufficient to 

ensure that safety would not be adversely affected. 
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The UAS 

The petitioner plans on utilizing separate, but similar airframes. The DJI Inspire 1, DJI Phantom 

3 Professional, and the Yuneec Q500+. These airframes are a "pro-sumer" grade small rotorcraft 

in the quadcopter configuration powered by electric motors each. Individual Specifications for 

the different airframes are located in the table below. 

These airframes utilize an internal inertial measuring unit (IMU) with integrated barometric 

sensor augmented with global positioning system (GPS) to maintain its geospatial orientation 

and position. It is controlled primarily through an FCC certified radio control (RC) unit. Real 

time video and telemetry information is transmitted back to a ground control station allowing the 

operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from 

PIC, camera imagery, and control camera angle.

Failsafe modes of operation for either loss of signal (RC or GPS) or battery level. Altitude is 

limited and pre-programmed to not exceed 400ft AGL. Battery life limits flight times to 

approximately 20-25 minutes for each airframe. The onboard flight controller will warn the pilot 

via telemetry and external lighting cues before reaching a low battery state. An automatic 

termination of flight and landing will be initiated when the battery reaches a predetermined low 

state. It is anticipated that flights will usually last less than 10 minutes. More information is 

available in product manuals which are Attachments 1 through 4. 

UAS Airframe Specifications

DJI Inspire 1 DJI Phantom 3 Yuneec Q500+

Weight (Pounds) 6.47 2.82 3.75

Dimensions (inches) 17.25x17.75x11.85 23.23 (Diagonal) 16.5x16.5x9.5

Max Speed (Knots) 43 30 47

Temp Range (°C) -10° to 40° 0° to 40° -5° to 80°

Risk Mitigation

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and Limitations section 

and believes that the procedures specified therein are reasonable and will be utilized in order to 

manage and mitigate risk and ensure public safety. A preflight checklist has been developed and 

employed to ensure that the UA airworthiness will be verified before launch. Airworthiness will 

be maintained by performance of routine inspections before each flight, maintaining flight and 

maintenance logs to record time on failure-prone components. 

The petitioner requests that in a manner similar to reference 3, he be allowed to operate within 5 

miles of an airport provided that; 

“The UA may not operate in Class B, C, or D airspace without written approval from the FAA. 

The UA may not operate within 5 nautical miles of the geographic center of a non-towered 
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airport as denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request.” 

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is 

requesting a mechanism to facilitate such activities without requesting a new and separate 

exemption(s) should the need arise. Operations within Class B airspace are not requested due to 

the lack of Mode C transponder. 

Public Interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental 

impact as compared to similar operations conducted with manned aircraft of greater proportions, 

carrying a crew and flammable fuel. Additionally, use of the UAS in order to facilitate 

commerce could lead to economic growth. Operations for this petition will enable service for 

property owners or their designees seeking an enhanced perspective for characteristics, 

amenities, and benefits of their desired photographic subjects that cannot be displayed through 

ground level videography/photography. Aerial photography is a valuable marketing tool that can 

lead to increased commerce and enhance personal photography. Crop surveying applications 

could lead to decreased use of pesticides and fertilizer and conservation of water as well as 

increased crop yields and decreased costs. Aerial surveying and inspections can increase work 

site efficiency, improve volumetric estimations and reduce risks. The petitioner will provide 

clients with photographic data for these purposes on a ‘for hire’ basis acting as an independent 

contractor. A visual observer will be utilized. Liability insurance will be obtained commensurate 

with the granting of this request for exemption. Flight data including UA flight time, Control 

Unit operation time, incident, accident, and details concerning any deviations from normal 

operations will be available to FAA for use in collecting data regarding the use of UAS as part of 

this application. This data may be submitted to FAA via traditional means, e.g. COA Monthly 

Reports, or other means as required. 

Conclusion 

The petitioner is requesting this exemption for the purposes of “aerial photography, 

cinematography, videography, mapping, crop surveying, inspections and other flight operations”. 

The reason for such a general and broad based request is that the petitioner wishes to utilize a 

business strategy of horizontal integration and maximize economies of scope in order to 

capitalize on opportunities as they may arise in the future without the long turnaround time 

associated with additional exemptions. The petitioner's business model is based on the idea of 

offering ad hoc small UAS services to individuals or companies who wish to employ these 

services as a safe, effective, and legal option to enhance their business or hobby. The 

petitioner’s own market research shows pent up demand for these services currently exists in the 

real estate market and other markets are just beginning to emerge. The petitioner has identified 

Universities and other Agencies that could benefit from the operation requested in this 

application. 
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A quick internet search will show that many are currently operating similar UAS in exactly this 

fashion without, it is assumed, FAA authorization. The petitioner has refrained from engaging in 

commercial use of the UAS. The primary purpose of seeking this exemption is to obtain the 

capability to offer those services while remaining in compliance. 

Adding to the level of safety and experience in these operations, the petitioner has 10 years of 

experience in the radio control model aircraft hobby, 19 years experience in general and 

commercial aviation and holds the following FAA Licenses and Ratings:

Airline Transport Pilot Certificate (AMEL)

Commercial Pilot License (ASEL)

Private Pilot License (Rotorcraft-Helicopter)

Instrument - Airplane

Certified Flight Instructor - Single and Multi Engine Land, Instrument Airplane

Thank you in advance for your time and consideration.

Kind Regards,

John Holden

AGL Imaging LLC