Aerial PIC llc

Jeff Webbe, Owner & Operator

17941 W. Jojoba Rd., Goodyear, AZ 85338

jjwebbe@gmail.com

August 13, 2015

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Docket ID FAA-2015-1763-0001

Exemption Request Section 333 of the FAA FMRA and Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam:

In a letter dated July 30, 2015, from Brittany Newton, Program Analyst, Airmen and Airspace Rules Division of the 

FAA, I was informed that my request for exemption from Section 333 /Part 11 of the FARs (Docket ID FAA-2015-

1763-0001) could not be processed without further information. This submission is an addendum to my original 

petition for exemption in order to provide, in addition to documents previously filed in the public docket, the 

following requested information:

1) Reasons why granting this request for exemption would be in the public interest and would not 

adversely affect public safety

2) Additional information available to support this request

3) A summary of the request that can be published in the Federal Register

REASONS WHY GRANTING THIS REQUEST FOR EXEMPTION WOULD BE IN THE PUBLIC INTEREST AND WOULD NOT 

ADVERSELY AFFECT PUBLIC SAFETY:

Batteries power the UAS described in this petition; and they are smaller, lighter and more maneuverable than 

larger aircraft running on combustible fuel. The UAS operates at lower altitudes with no people on board and 

will thereby reduce current risk levels associated with traditional aircraft, enhance safety and greatly diminish 

the likelihood of death or serious bodily injury. The environmental impact (including air and noise pollution) 

caused by the UAS is also less than traditional aircraft, based on its smaller size, more limited flight times and 

alternative power source. Also, with a small payload and typical flight time of only 20 minutes, as well as the 

restricted secure environments in which the UAS would be operated, there is little or no risk to national security. 

The photography and video available from UAS could previously only be obtained using fully manned aircraft, 

which was cost-prohibitive for many applications. The lower cost and improved photographic quality from the 

UAS will be a benefit to many small businesses that would otherwise be unable to afford high quality aerial 

imagery. Additionally, we plan to make our UAS available to first responders in our community who might 

require assistance, including fire fighters, police, sheriff, et al., while remaining subject to all limitations cited in 

this application. Flight safety will be maintained at a level that is equivalent to traditional flight operations, by 
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Exemption Request Section 333 Aerial PIC llc

Docket ID FAA-2015-1763-0001 Jeff Webbe, Owner & Operator

17941 W. Jojoba Rd., Goodyear, AZ 85338

jjwebbe@gmail.com 

an FAA licensed pilot in a manner consistent with safe operation, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and structures.

ADDITIONAL INFORMATION, VIEWS OR ARGUMENTS TO SUPPORT THIS REQUEST:

Congress’s national policy favors early integration of UAS into the national airspace in controlled, safe working 

environments such as those proposed in this petition. Those goals are furthered when businesses such as Aerial 

PIC llc are granted exemption, thereby helping to facilitate and promote the safe integration of UAS into the 

NAS, while providing education and awareness of UAS operations and capabilities. By providing lawfully 

operated UAS photography and videography in our geographical region, Aerial PIC llc offers a safer 

alternative to the public at large, in comparison with those who are currently operating UAS illegally in national 

airspace.

SUMMARY:

The petitioner, Jeff Webbe, owner and operator of Aerial PIC llc, requests relief from Section 333 of the FAA 

Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, to operate the DJI Inspire 1 Unmanned Aircraft 

System (“Inspire 1”) and the DJI Phantom 3 Unmanned Aircraft System (“Phantom 3”). The extent of the relief 

specifically applies to the following Federal Aviation Regulations: 14 C.F.R. Part 21; 14 C.F.R. Part 36 Noise 

Standards; 14 C.F.R. 45.23(b) Markings and Registration Number; 14 C.F.R. 61.113(a) & (b) Private Pilot Privileges 

and Limitations; 14 C.F.R. 61.133(a) Commercial Pilot Privileges and Limitations; 14 C.F.R. 91.7(a) & (b) Civil 

Aircraft Worthiness; 14 C.F.R. 91.9(b)(2) Civil Aircraft Flight Manual Marking and Placard Requirements; 14 C.F.R. 

91.119 Minimum Safe Altitudes; 14 C.F.R. 91.121 Altimeter Settings; 14 C.F.R. 91.151(a) & (b) Fuel Requirements in 

VFR conditions; 14 C.F.R. 91.203(a) & (b) Airworthiness Certificate; C.F.R. 91.207 Emergency locator transmitters; 

14 C.F.R. 91.405(a) Maintenance Inspections; 14 C.F.R. 91.407(a)(1) Maintenance Inspections; 14 C.F.R. 

91.409(a)(2) Maintenance Inspections; and 14 C.F.R. 91.417(a) Maintenance Inspections. The requested 

exemptions would allow the petitioner to use the Inspire 1 and Phantom 3 Unmanned Aerial Systems for 

commercial purposes such as obtaining aerial images, photos and video footage for use in marketing, real 

estate, agriculture, insurance, surveying, aerial photography and videography, construction, events, police 

and governmental support, and search and rescue operations. 

Sincerely,

Jeff Webbe

Owner & Operator, Aerial PIC llc