May 21, 2015

Exemption No. 11650

Regulatory Docket No. FAA–2015–0672

Mr. Peter A. Monette

Trinity Aeroimaging LLC

P .O. Box 1175

Aztec, NM 87410

Dear Mr. Monette:

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 March 11, 2015, you petitioned the Federal Aviation Administration (FAA) on 

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

petitioner requested to operate an unmanned aircraft system (UAS) to conduct videography of 

real estate, area service providers, business enterprises, including construction and utilities.

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 DJI Phantom and a DJI Vision 2+.

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 

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 
2

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, Trinity Aeroimaging 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.

Conditions and Limitations

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

 

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.
3

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 DJI Phantom and 

DJI Vision 2+ 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, 

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 
4

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.

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 
5

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.

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.
6

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.

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.
7

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.

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
\ 

) 

PETITION FOR EXEMPTION 

March 11, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room Wl2-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

CONTACT INFORMATION: Peter A. Monette 

Trinity Aeroimaging LLC 

P .0. Box 1175 

Aztec, NM 87 410 

505-330-6511 

Email pzzoom@gmail.com 

-. ~ .. 

RE: Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation 

Regulations: 14 CFR 61.56(a)(1) and (2); 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); 91.417(a) & (b) 

Dear Sir or Madam, 

In accordance with the guidelines for submitting a Petition for Exemption under Section 333 of 

the FAA Modernization and Reform Act of2012, I, Peter A. Monette, DBA Trinity 

Aeroimaging LLC, a Native American owned company, hereafter referred as "Petitioner", 

respectfully submit my exemption request. 

The Petitioner requests exemptions in order to legally operate two Unmanned Aircraft Systems, 

(UAS) a DJI Phantom UAS with GoPro Hero 3 camera, and a DJI Vision 2+, with integral 

camera system in the National Airspace System, for the purpose of commerce relating to 

Videography of real estate, area service providers, business enterprises, including construction 

and utilities while providing and enhancing the beneficial uses ofUAS operations. 

The Petitioner conveys the use of the DJI Phantom is more economical and safer than using 

manned aircraft for similar purposes. In addition, this growing aspect of aviation is a benefit to 

commerce as a whole by allowing individuals and businesses to participate in this unique facet 

of aviation technology in an affordable manner. 
PETITION FOR EXEMPTION 

The Petitioner, Peter A. Monette, submitting this exemption request, is a FAA certificated 

Airline Transport Pilot, Commercial Pilot, Single and Multi Engine Instrument Airplane. In 

addition, the petitioner has graduated with honors from an accredited college, obtaining a 

degree in Aviation Technology. The Petitioner has operated a DJI Phantom for the past 15 

months as a hobby, acquiring 40 plus flight hours. 

,l The petitioner is submitting the following: 

1. Exemption requests by Part and Sub Part of the FAA Regulations. 

2. Relief request from Airport Proximity and Limitations. 

a. Aerial Maps 

3. Public Interest 

4. Operations Manual 

The petitioner shall reference prior exemptions: 1. January 6, 2015 to Douglas Trudeau, 

Exemption No. 11138, Regulatory Docket No. FAA-2014-0481. 2. Clayco Inc, Exemption 

No. 11109 

1. EXEMPTION REQUEST BY PART AND SUBPART OF THE FAA 

REGULATIONS. 

14 CFR 61.56(a)(l) and (2)(c)(l) and (2) 

FLIGHT REVIEW: (a) Consists of 1 hour flight training and 1 hour of ground training. 

(1) Review of current general operating and flight rules of this chapter. 

(2) Review of those maneuvers and procedures that are necessary for the 

pilot to demonstrate the safe exercise of the privileges of the pilot 

certificate. 

(c) No person may act as pilot in command of an aircraft unless, since the 

beginning of the 24th calender month before the month in which that 

pilot acts as pilot in command, that person has-

(1) Accomplished a flight review given in an aircraft for which that pilot 

is rated by an authorized instructor; and 

(2) A logbook endorsement from an authorized instructor who gave the 

review certifying that the person has satisfactorily completed the 

review. 
) 

PETITION FOR EXEMPTION 

The petitioner, a certificated Airline Transport Pilot, is aware through previous training, 

curriculum and aeronautical training the necessity of Federal Aviation Regulations pertinent for 

safe operations in the National Airspace System. With reference given to Exemption 11138, the 

petitioner believes he is in compliance with the "two reasons" set forth regarding Pilot in 

Command of the UAS. First, the petitioner meets the statutory requirement by holding an 

airman certificate, as prescribed in 49 USC 44 711. Second, as a certificated airman, the 

petitioner meets the requirements established by the Department of Homeland Security for 

security screening. It is the position of the petitioner that a flight review, as outlined above, 

does not pertain to the use of a UAS, and is not applicable in this instance. 

14 CFR 91.7(a) 

Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in an 

airworthy condition 

Based on the exemption No. 11138, the petitioner requests an exemption from 14 CFR 91.7(a). 

The FAA has determined this make and model does not require an airworthiness certificate. 

\ The petitioner, pilot in command, will ensure airworthiness through the combined use and 

) application of the company Operations Manual, Flight Log/Preflight and Maintenance Form. 

14 CFR 91.119(c) 

Minimum Safe Altitudes:( 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. 

Based on the exemption No. 11138 and 11109, the petitioner requests an exemption from 14 

CFR 91.119( c). The petitioner request consistent relief as granted in those exemptions. The 

petitioner will adhere to policy and practices outlined in the Flight Operations Manual. 

14 CFR 91.121 

Altimeter Settings: 

Based on the exemption granted, No. 11138, the petitioner requests an exemption from 14 CFR 

91.121. The petitioner, UAS, does not incorporate a barometric altimeter, but instead, GPS 

derived altitude capabilities. The petitioner will limit flights to a maximum altitude of 250 feet 

above ground level (AGL ), with any altitude reports to ATC in AGL. 
) 

PETITION FOR EXEMPTION 

14 CFR 91.151(a)(l) 

Fuel requirements for flight in VFR conditions:( a) No person may begin 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. 

The petitioner, requests relief consistent with exemption No. 11138. The petitioner will be 

utilizing the same make and model ofUAS. 

14 CFR 91.405(a) 

Maintenance required: Each owner or operator of an aircraft- (a) 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. 

The petitioner, pilot in command, shall inspect the aircraft prior to every flight. Reference 

given to the Flight Log/Preflight and Maintenance Form in the Operations Manual. The 

petitioner requests an exemption similar to Exemption No. 11138. 

14 CFR 91.407(a)(l) 

Operation after maintenance, preventive maintenance, rebuilding, or alteration. 

(a) No person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration 

unless-

( 1 )It has been approved for returned to service by a person 

authorized under 43.7 of this chapter 

The petitioner, pilot in command, who has final authority and responsibility for the operation 

and safety of the UAS flight, shall insure through the use of protocols and procedures listed in 

the Maintenance Form, Operations Manual, proper maintenance and subsequent approval for 

return to service. The petitioner requests an exemption, reference Exemption No. 1113 8. 
~\ 

) 

PETITION FOR EXEMPTION 

14 CFR 91.409(a)(l) and (2) 

Inspections: (a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calender months, it has had-

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

No inspection performed under paragraph (b) of this section may be substituted 

for any inspection required by this paragraph unless it is performed by a person 

authorized to perform annual inspections and is entered as an "annual" inspection 

in the required maintenance records. 

The petitioner, in accordance with the Operations Manual will ensure that the UAS is in a 

condition for safe flight. The petitioner requests exemption from 14 CFR 91.409 

(a)(l) and (2). Reference given to Exemption No.lll38. 

14 CFR 91.417(a) and (b) 

Maintenance Records: (a) Except for work performed in accordance with 91.411 and 91.413, 

each registered owner or operator shall keep the following records (l)(i) 

(ii)(iii) (2)(i)(ii)(iii)(iv)(v)( vi) 

for the periods specified in paragraph (b) of this section: ( 1 )(2)(3) 

The petitioner, through the use of diligent record keeping as outlined in the Operations 

Manual and Maintenance Form will adhere to 14 CFR 91.417(a) and (b) in accordance and 

relation to the operation of a UAS. The petitioner request an exemption based on variables 

associated with the operation of a UAS in the NAS, similar to Exemption No. 11138. 

2. RELIEF REQUEST FROM AIRPORT PROXIMITY AND LIMITATIONS 

The Petitioner, a certificated pilot, understands the concerns associated with the operation 

ofUAS aircraft in the vicinity of airports. The Petitioner believes relief can be granted when 

facts relating to a particular airports geographic location are considered. The Petitioner, through 

the use of the Trinity Aerolmaging Operations Manual and criteria established by the 

Administrator, will operate the UAS with safety and common sense directives. 

The Petitioner requests relief relating to two airports: Farmington Regional Airport, (FMN) 

and Aztec Municipal Airport (Nl9). The Petitioner foresees 35 %of commerce within 5 miles 

ofthese airports. 
PETITION FOR EXEMPTION 

Both airports are situated on bluffs, with an airport elevation higher than much of the 

surrounding rural area and properties. This being the case, the Petitioner is confident that 

operations conducted in many situations can be below actual airport elevation. 

It is the intent of the Petitioner to offer services covering larger parcels, while avoiding 

congested areas altogether. 

The Petitioner requests relief from the 5 Nautical Mile limitation concerning the proximity to 

the 2 airports based on the following restrictions: 

1. Altitude of 50 feet AGL of the particular airport runway elevation within 1 to 5 

Nautical Miles of the airport. 

The Pilot in Command, shall combine the actual elevation of the airport (FMN) 

5503, (N19) 5877, plus 50 feet to determine the ceiling of operations. If safe UAS 

operations require a flight level of 15 0 feet, then the operator may operate at an A GL of 

5403 feet (FMN) and 5777 (N19) Therefore, the operation can be conducted at those 

operational areas and those elevations, or less. The elevation at the place of operations 

shall be measured using GPS equipment. 

2. No flight on the extended center lines, or 5 degrees to either side of any active or 

runway in use, out to 1 Nautical mile from the airport reference point. 

3. Communicate with airport. Date, time, location and heading from airport ofUAS 

operation. 

4. Communicate with traffic if necessary, or required, using air band transceiver. 

5. Obtain a Certificate of Authorization (COA) 

6. Issue NOTAM for activities to be conducted. 

7. Keep nonessential persons at safe distances from the operation. 

8. Use the on-board programmable altitude restriction system to prevent inadvertent 

altitude deviation. 

9. Post notification of operation signs at appropriate locations. 

The Petitioner has provided aerial maps to depict locations and elevations in the area. Given 

the location of these airports and the rural nature of the area, unless an exemption is granted, 

much commercial opportunity would be lost. Due to the unique characteristics and topography 

of the area, the Petitioner is confident UAS operations could coexist in this environment. The 

Petitioner would ensure that safety and communication would be paramount in this operation. 
PETITION FOR EXEMPTION 

3. PUBLIC INTEREST 

The public interest is safety. The Petitioner through the use of the exemption process 

contained in Section 333, requests safe and legal entry into the NAS. The public will 

benefit wholeheartedly knowing the national airspace is operated in an organized 

manner with open dialog. Through this process, illegal operations will be minimized and 

legal commerce will thrive. The full benefits of this new facet of Aviation is yet to be 

realized. 

Peter A. Monette 

Trinity Aeroimaging LLC. 

P.O. Box 1175 

Aztec, NM 87410