November 15, 2015

Docket Operations, M-30 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590-0001

Exemption Request Section 333 of the FAA Reform Act 

To whomever it may concern, 

This petition is being submitted on our own behalf without legal counsel or consulting services. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 

C.F.R. Part 11, Advanced Aerial Imagery, a Northern California based company operating a Small 

Unmanned Aircraft System (sUAS) equipped to conduct aerial photography and survey for various 

industries, hereby applies for an exemption from the Federal Aviation Regulations listed below to allow 

operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) 

so long as such operations are conducted with and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333. The requested exemption would permit Advanced 

Aerial Imagery to pursue its commercial interests in providing services to consumers interested in aerial 

data capture and photography using a small advanced sUAS in the following areas: 

• Agricultural Surveying 

• Construction Surveying 

• Mining Surveying 

• Forestry Surveying 

• Commercial Surveying 

• Gas and Oil Inspections 

• Real Estate Photography 

• sUAS Operator Training 
• Product Demonstrations 

• Research and Development 

Advanced Aerial Imagery states that all sUAS flights that will occur over private or controlled 

access property will do so with the property owner's prior consent and knowledge and that only people 

who have consented or otherwise have agreed to be in the area where photography and videography 

will take place will be captured. Additionally, Advanced Aerial Imagery pilots will hold a minimum of a 

sport pilot license and if observers are not qualified pilots, they will be trained by Advanced Aerial 

Imagery pilots to understand the proper roles of an observer, communication procedures, proper visual 

scan techniques, operations at non-towered airports, and appropriate sections of the Aeronautical 

Information Manual. 

Regulations from which the exemption is requested: 

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b) (2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203 (a) & (b) 

14 C.F.R. 91.205 (b) 

14 C.F.R. 91.215 

14 C.F.R. (91.401 - 91.417) 

The small Unmanned Aircraft System we are petitioning for exemption to enable Advanced Aerial 

Imagery to operate is a Tarot T-810 multi-rotor (hexacopter) which utilizes a Naza-M V2 flight controller. 

The sUAS is equipped with a three-axis gimbal and various cameras. This sUAS weighs less than 15 lbs., 

have a built-in capability to limit the height it flies above the ground, to limit the radius of the distance it 

flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. 

Each system also has the fail-safe function of the autopilot system, which means when the 

communication between the Main Controller and the transmitter is lost, the system will automatically 

trigger Return-to-Home and will land safely. 
The above specifications meet standards listed below, some derived in accordance with the Model 

Aircraft Operating Standards: 

• The petitioner will only operate the sUAS in line of sight of a pilot and/or observer and will operate at 

sites that are a sufficient distance from populated areas. Such operations will ensure that the sUAS will 

not create a hazard to users of the national airspace system or the public.

• When flying sUAV within 5 miles of an airport, airport operators will be notified and the operator will 

give the right of way to avoid flying in the proximity of full-scale aircraft. 

• Maximum flight time for each operational flight will be 30 minutes. 

• Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. 

• The sUAS will be programmed so that it will not be operated at an altitude of more than 200 feet AGL, 

and not more than 200 feet above an elevated platform from which filming is planned. 

• Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer. 

• The sUAS PIC's (Pilot in Command) will be an FAA licensed airman holding a minimum of a FAA Sport 

Pilot Certificate and second Class FAA Medical Certificate. 

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, 

lens, and gimbal). 

• The sUAS will operate at speeds of no more than 30 mph. 

• Given the small size of the sUAS and the restricted sterile environment within which they will operate, 

our sUAS operations adhere to the Reform Act's safety requirements. 

Additionally, the fact that Advanced Aerial Imagery pilots will hold FAA Pilot certificates demonstrates 

that they have a high regard to safe operations with an understanding of FARs, pre-flight inspections,

maintenance and repair, operations within airspace, as well as being trained to high safety standards. 

We respectfully request exemption under Section 333 to enable Advanced Aerial Imagery to operate 

safe, low-risk commercial sUAV operations for the activities stated. Advanced Aerial Imagery will respect 

the space and privacy of citizens and property whilst keeping our skies safe at all times. 

Sincerely, 

Nathan Edgar

Co-Owner

Advanced Aerial Imagery

236 Windrose Ct.

Chico, CA 95973

530-518-5604
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OFSAFETY 

Advanced Aerial Imagery requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the sUAV System: 

14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA 

continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an 

experimental certificate be issued for the Tarot T-810 sUAS with Naza-M V2 controller under either or 

both of the following provisions: 

21.191 Experimental certificates. 

Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, 

new aircraft installations, new aircraft operating techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations, including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys, 

sales demonstrations, and crew training, we would expect that an experimental certificate 

would permit our commercial purpose as well. The aircraft will not carry persons or property, 

will not carry fuel, and will only fly under strict operational requirements. Combined with the 

UAS's light weight, being constructed primarily of carbon fiber, and/or plastic, we propose that 

the UAS will be at least as safe, if not safer, than a conventionally certificated aircraft performing 

the same mission. If an experimental airworthiness certificate is not appropriate for this 

application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement 

for an airworthiness certificate in general, citing the equivalent level of safety outlined in the 

previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's registration number in 

letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters 

at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. This UAV does not have an 

entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number 

assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" on one of the arms of the UAV (the biggest spot on the aircraft to place such 

markings), where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will 

be able to see the designation. Additionally, we feel that the permanent placard discussed in the 

previous paragraph will provide the aircraft's registration information at the ground station. Finally, we 

will display at the ground station a high contrast flag or banner that contains the words "Unmanned 
Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within a visual 

line of sight of the ground station, the banner should be visible to anyone that observes the aircraft and 

chooses to investigate its point of origin. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and61.133 Commercial pilot 

privileges and limitations. 

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command 

of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in 

command of an aircraft in connection with any business or employment if: (1) The flight is only 

incidental to that business or employment; and (2) The aircraft does not carry passengers or property 

for compensation or hire. Our proposed operations require that the PIC must hold at least a Sport Pilot 

Certificate issued by the FAA and since the aircraft cannot carry passengers or property, we feel we 

meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a 

business. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved flight manual 

is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to this 

requirement since the aircraft is not only too small to carry documentation; the documentation would 

not be available to the crew during flight operations. To obtain an equivalent level of safety and meet 

the intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the 

crew at the ground station anytime the aircraft is in, or preparing for, flight. 

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests 

The regulation states that "No person may operate a civil aircraft that is being used for flight instruction 

unless that aircraft has fully functioning dual controls." The sUAS ground-based control station consists 

of a small hand-held radio transmitter and while it does not offer a second set of "controls", both the 

student and instructor can, and will, operate the single set of controls simultaneously. With both 

student and instructor having "hands-on" the controls during flight, we feel that this technique meets 

the intent 91.109 and provides an equivalent level of safety. 

14 CFR 91.119 Minimum safe altitudes: General. 

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 

feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be 

photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer 

than 500 feet to the items listed. Operations will only be flown over property or persons where 

permission has been obtained and careful pre-planning has been performed. The aircraft will be 
operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. Therefore we maintain that due to the small size of the UAS, the 

hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be 

considered in granting the exemption. 

14 CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting 

available within 100 NM of the aircraft. The sUAS will always fly below 600 feet AGL and will not need to 

maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the sUAS on-board 

computer to the display screen held by the PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless 

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 

minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for 

delays to landing. The sUAS are battery operated and the maximum duration of flight from a single 

battery charge is 12-20 minutes with a 20% reserve. Since the aircraft will never fly further than the 

visual line of sight (less than one mile) from the point of intended landing, a full battery charge at launch 

will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption 

to the word "fuel" and ask for an equivalent interpretation with the word "energy". We also request 

exemption from the 30 min reserve and ask that our reserve will be to fly the mission to the point of 

intended landing and have at least a 20% battery reserve after that. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) 

provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew." Our sUAS is too small to carry documentation, does not have an 

entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and 

meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA 

will be located with the crew at the ground control station and available for inspection upon request. In 

order to identify the aircraft, we propose that the information found on airworthiness and registration 

certificates be permanently affixed to the aircraft via placard containing the following information plus 

the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 

14 CFR Subpart E (91.401- 91.417) - Maintenance, Preventive Maintenance, Alterations. 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require 

that the aircraft be "approved for return to service by a person authorized under 43.7" after 

maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the 

aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the 
aircraft is in an airworthy condition prior to every flight and in addition, conduct detailed inspections 

after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, 

replacing a propeller, checking electrical connections and updating software and firmware for the onboard computer. All other maintenance will be performed by the manufacturer or their designated 

repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to 

the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.