UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _____________________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

AERIAL PERSPECTIVE LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b)

CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 3, 

DJI INSPIRE 1, DJI S1000+, SKYWALKER X8 FLYING WING

AND 3D ROBOTICS SOLO

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on August 7, 2015

Jakee Stoltz, Co-Founder

Aerial Perspective LLC

Tel:(701) 290-5459

Email: jakee.stoltz@gmail.com
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TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS .......................................................................................... 3

SUMMARY.................................................................................................................................. 4

INTRODUCTION AND INTERESTS OF PETITIONER .......................................................... 4

AIRCRAFT MODELS IN THIS PETITION ............................................................................... 4

BASIS FOR PETITION ............................................................................................................... 5

A. NAME AND ADDRESS OF PETITIONER.............................................................. 7

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH AERIAL 

PERSPECTIVE LLC SEEKS EXEMPTION............................................................. 8

C. THE EXTENT OF RELIEF AERIAL PERSPECTIVE LLC SEEKS AND THE 

REASON AERIAL PERSPECTIVE LLC SEEKS THE RELIEF ............................ 11

D. THE REASONS WHY GRANTING AERIAL PERSPECTIVE LLC’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST .............................................................. 13

E. THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY............................................................................. 15

F. SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......... 23

G. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVILABLE 

TO SUPPORT AERIAL PERSPECTIVE LLC’S REQUEST................................... 23

CONCLUSION............................................................................................................................. 24

ATTACHMENTS......................................................................................................................... 26
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing
4

SUMMARY

Aerial Perspective LLC seeks exemption from the requirements of 14 C.F.R. §§ 

61.113(a), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b), to operate Unmanned Aircraft Systems pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Aerial Perspective 

LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting 

photography, videography, infrastructure inspections, and mapping within the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Aerial Perspective LLC is a business dedicated to providing professional UAS flight 

services and UAS consulting. Aerial Perspective LLC created and maintains a Flight Operations 

Manual which is attached to this request as Attachment A.

Aerial Perspective LLC is staffed with experienced, aviation professional with a 

combined 9+ years of experience in both manned and unmanned aviation. Company co-founder, 

Jakee Stoltz, is a Commercial Pilot and Flight Instructor with over 1000 hours in single engine 

airplanes. He has OEM training and certification on the Trimble UX5, Aerovironment Qube and 

Raven, and Draganflyer X4-ES UAS’s and has accumulated over 150 flights and over 70 hours 

on those platforms including time on various DJI and 3D Robotics platforms. Mr. Stoltz has 

previously held jobs at the University of North Dakota Aerospace and the Northern Plains UAS 

Test Site.

The other two members of Aerial Perspective LLC are also Commercial Pilots and Flight 

Instructors and also have a wealth of experience flying manned and unmanned aircraft. Andrew 

Regenhard coordinates unmanned aircraft projects at the University of North Dakota. Trevor 

Woods is the airspace manager at the Northern Plains UAS Test Site and has extensive 

experience flying UAS and acquiring COA’s. We are dedicated to providing safe, efficient 

operations of unmanned aircraft systems in the NAS.

AIRCRAFT MODELS INCLUDED IN THIS PETITION

1. DJI Phantom 3

2. DJI Inspire 1

3. DJI S1000+

4. Skywalker X8 Flying Wing
5

5. 3D Robotics Solo UAS

Aerial Perspective LLC seeks an exemption to operate DJI, Skywalker, and 3D Robotics 

systems for compensation or hire within the NAS. 

The DJI Phantom 3, DJI Inspire 1, DJI S1000+, and 3D Robotics Solo UAS’s are all 

similar in speed, weight, size, and operational capability. All four of these UAS are vertical 

takeoff and landing (VTOL), battery powered, electric motor aircraft. All have similar fail safes 

that prevent loss of control and fly away scenarios. The table below highlights some key 

specifications of each UAS.

Max Speed Max Weight Size Mission Time

DJI Phantom 3 36 mph 2.8 lbs 23 in x 23 in 23 minutes

DJI Inspire 1 49 mph 6.5 lbs 22 in x 23 in 18 minutes

DJI S1000+ 26 mph 24.2 lbs 41 in x 16 in 15 minutes

3D Robotics Solo 55 mph 3.3 lbs 18 in x 18 in 25 minutes

The Skywalker X8 Flying Wing is a fixed wing UAS that also fits within the speed, 

weight, size, and operational capability for exemption. The Skywalker X8 has an 83 in.

wingspan, a maximum takeoff weight of 7.7 pounds, and a top speed of 50 knots. The Skywalker 

X8 is outfitted with a 3D Robotics Pixhawk autopilot which provides the autonomous flight 

features that are similar to the 3D Robotics Solo. 

Operation Manuals with details for each UAS will be included with this request. All DJI, 

Skywalkere, and 3D Robotics systems operated by Aerial Perspective LLC will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R. Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

Markings.

BASIS FOR PETITION

Petitioner, Aerial Perspective LLC, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), 

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator to commercially operate the DJI, Skywalker, and 3D Robotics UAS’s in the 
6

National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R. §§ 

61.113(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, Aerial Perspective LLC’s operation of the DJI, Skywalker,

and 3D Robotics UAS’s meets the conditions of FMRA Section 333 and therefore, will not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Aerial Perspective LLC requests relief from Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements 

for maintenance that only apply to aircraft with an airworthiness certificate.

Aerial Perspective LLC submits that the requested relief is proper since an equivalent 

level of safety will be ensured. Aerial Perspective LLC will use experience personnel or 

technicians to perform maintenance, alternations, or preventative maintenance on the UAS’s 

using the methods, techniques, and practices prescribed in the operating documents (i.e., manual 

names). Furthermore, Aerial Perspective LLC will document and maintain all maintenance 

records for the UAS’s.

Relief from certain requirements of Sections 61.113(a), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by Aerial Perspective LLC to the extent 

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as 

well as an airman medical certificate, and who has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the UAS’s in a manner 

consistent with this exemption, including normal procedures, abnormal procedures, emergency 

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

Aerial Perspective LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the UAS’s do not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H. As such, Aerial Perspective LLC will ensure that the UAS’s are in 

an airworthy condition, prior to every flight, by determining that the UAS’s are in compliance 

with the operating documents (i.e., manual names), and that the aircrafts are in a condition for 

safe flight.
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Aerial Perspective LLC seeks relief from Section 91.119(c), entitled Minimum safe 

altitudes: General, because the proposed UAS’s must fly lower than 500’ above the surface to 

accomplish certain operations such as photography and infrastructure inspections. As such, 

Aerial Perspective LLC will ensure that operations that occur less than 500’ above the surface 

will remain at least 500’ away from all nonparticipating persons, vehicles, vessels, and structures 

unless a barrier exists to shield nonparticipating persons or Aerial Perspective LLC has the 

owner’s permission to operate near the vehicle, vessel, or structure.

Aerial Perspective LLC also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the UAS’s will not have a typical barometric altimeter 

onboard. However, altitude information of the UAS’s will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, which 

downlinks from the UA to the GCS for active monitoring of the flight path. This altitude 

information, combined with Aerial Perspective LLC’s operation of the UAS’s within visual line 

of sight, at or below 500’ AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Aerial Perspective LLC seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Aerial Perspective 

LLC submits that safety will not be affected by operation of the UAS’s during daylight hours in 

visual meteorological conditions (VMC) under visual flight rules (VFR), for a total duration not 

greater than that recommended by the manufacturer. 

In accordance with 14 C.F.R. § 11.81, Aerial Perspective LLC provides the following 

information in support of its petition for exemption:

A. Name and Address of the Petitioner.

The name and address of the Petitioner is:

Aerial Perspective LLC

111 N 3rd Street Unit 1003

Grand Forks, ND 58203

A point of contact for Aerial Perspective LLC is:

Jakee Stoltz

Tel: (701) 290-5459

Email: jakee.stoltz@gmail.com
8

B. The Specific Sections of 14 C.F.R. From Which Aerial Perspective LLC

Seeks Exemption.

1. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section 

61.113(a).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsection (a) prescribes the following, in relevant part:

(a) No person who holds a private pilot certificate may act as pilot in command of 

an aircraft that is carrying passengers or property for compensation or hire; nor 

may that person, for compensation or hire, act as pilot in command of an aircraft.

2. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section 

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a) prescribes the 

following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section 

91.119(c).

Section 91.119, entitled Minimum safe altitudes: General, subsection (c) prescribes 

the following, in relevant part:

(c) Except when necessary for takeoff or landing, no person may operate an 

aircraft over other than congested areas below 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.

4. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section 

91.121.

Section 91.121, entitled Altimeter settings, subsection (a) prescribes the following, in 

relevant part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating—

(1) Below 18,000 feet MSL, to –

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft;
9

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) 

of this section, the current reported altimeter setting of an appropriate 

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of 

the departure airport or an appropriate altimeter setting available before 

departure.

5. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section 

91.151(b).

Section 91.7, entitled Fuel requirements for flight in VFR conditions, subsection (b) 

prescribes the following:

(b) No person may begin a flight in a rotorcraft 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, to fly 

after that for at least 20 minutes.

6. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section 

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a) prescribes the 

following:

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[.]

7. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section 

91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventative maintenance, 

rebuilding, or alteration, subsection (a)(1) prescribes the following:

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

preventative maintenance, rebuilding, or alteration unless –

(1) It has been approved for return to service by a person authorized under § 43.7 

of this chapter [.]

8. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section 

91.409(a)(1) and 91.409(a)(2).
10

Section 91.409, entitled Inspections, subsection (a) prescribes the following:

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

aircraft unless, within the preceding 12 calendar 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.

9. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section 

91.417(a) and 91.417(b).

Section 91.417, entitled Maintenance records, subsection (a) and (b) prescribes the 

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include –

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature and certificate number of the person approving the 

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the 

aircraft which are required to be overhauled on a specified time 

basis.

(iv) The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained.
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(v) The current status of applicable airworthiness directives (AD) 

and safety directives including, for each, the method of 

compliance, the AD or safety directive number and revision date. 

If the AD or safety directive involves recurring action, the time and 

date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for 

each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods 

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be 

retained until the work is repeated or superseded by other work or for 1 

year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be 

retained and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 

43.11 of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service.

C. The Extent Of Relief Aerial Perspective LLC Seeks And The Reason Aerial 

Perspective LLC Seeks The Relief.

1. Extent of Relief Aerial Perspective LLC Seeks And The Reason Aerial 

Perspective LLC Seeks Relief From Section 61.113(a).

Relief from Section 61.113(a) entitled Private pilot privileges and limitations: Pilot 

in command, is requested to the extent necessary to allow a PIC holding a private 

pilot or higher level certificate, as well as a current and valid airman medical 

certificate, and who has met certain training and currency requirements, to conduct 

the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) 

state that a private pilot may, for compensation or hire, act as a PIC 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.

As set forth more entirely below, Aerial Perspective LLC submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate a UAS 

unless that PIC has demonstrated, through OEM training and currency requirements,

that the PIC is able to safely operate the aircraft in a manner consistent with the 

operations specifications as described in this exemption including normal procedures, 
12

abnormal procedures, and emergency procedures to include evasive maneuvering and 

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

Further, Aerial Perspective LLC submits that all flights of the UAS conducted by the 

PIC pursuant to the grant of this Petition (1) will be incidental to Aerial Perspective 

LLC’s business; and (2) will not carry passengers or property for compensation or 

hire.

2. Extent of Relief Aerial Perspective LLC Seeks And The Reason Aerial 

Perspective LLC Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a), entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Aerial Perspective LLC to determine that the operations UAS 

is in an airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the applicable operations and maintenance manuals, and that the UA 

is in condition for safe flight. Copies of the manuals, which contain proprietary 

information, are attached hereto, and are to be held in a separate file pursuant to 14 

C.F.R. Section 11.35(b).

Aerial Perspective LLC seeks the requested relief because the proposed sUAS do not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Therefore, Aerial Perspective LLC will ensure that the sUAS is in an airworthy 

condition based upon its compliance with the operating documents prior to every 

flight, and as stated in the conditions and limitations below. 

3. Extent of Relief Aerial Perspective LLC Seeks And The Reason Aerial 

Perspective LLC Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the proposed UAS, which utilize barometer and GPS equipment, 

to ensure that a ground level pressure setting will be established prior to each flight, 

and in order to report altitude to the PIC. 

Aerial Perspective LLC seeks the requested relief because the proposed UAS do not 

utilize a typical barometric altimeter that may be set as contemplated by Section 

91.121. As more fully set forth below, an equivalent level of safety will be 

maintained since the sUAS are equipped with a barometer and GPS equipment, which 

will ensure that a ground level pressure setting will be established prior to each flight, 

and provides the PIC with altitude information of the UA, above ground level (AGL), 

on the heads-up display of the GCS. 

4. Extent of Relief Aerial Perspective LLC Seeks And The Reason Aerial 

Perspective LLC Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b), entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered 
13

UA, during daylight hours in visual meteorological conditions under visual flight 

rules (VFR), to continue for a total duration not greater than that recommended by the 

manufacturer for safe operation. 

Aerial Perspective LLC seeks the requested relief, because without an exemption 

from Section 91.151(b), the flight time duration of the battery powered UA will 

severely constrain the practicality of many of the operations Aerial Perspective LLC 

proposed to conduct pursuant to this Petition.

5. Extent of Relief Aerial Perspective LLC Seeks And The Reason Aerial 

Perspective LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, Aerial Perspective LLC 

requests relief from these Sections because the sUAS do not require an airworthiness 

certificate. As set forth more fully below, the selected sUAS meet the conditions of 

Section 333 of the FMRA for operation with an airworthiness certificate. 

Accordingly, Aerial Perspective LLC will perform maintenance, alterations, or 

preventative maintenance on the UAS as prescribed by the manufacturers’ 

maintenance documentation where applicable, or by returning the aircraft to the 

manufacturer when operator maintenance is not recommended. Furthermore, Aerial 

Perspective LLC will maintain maintenance logbooks for each sUAS to document 

and maintain all maintenance records for the aircraft used. 

D. Reasons Why Granting Aerial Perspective LLC’s Request Would Be In 

The Public Interest. 

Granting the present Petition will further the public interest by allowing Aerial 

Perspective LLC to safely, efficiently, and economically perform aerial photography, 

videography, infrastructure inspections, and mapping over areas of the United States.

Additionally, use of the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying 

Wing, and 3D Robotics Solo UAS’s will decrease congestion of the NAS, reduce pollution, 

and provide significant benefits to the economy. Notably, the benefits of Aerial Perspective 

LLC’s proposed operation of sUAS’s will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D 

Robotics Solo UAS’s are battery powered and serve as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By 

reducing the amount of manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use of a DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker 

X8 Flying Wing, or 3D Robotics Solo UAS would reduce the amount of manned aircraft 
14

in the NAS, reduce noise and air pollution, as well as increase the safety of life and 

property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics 

Solo UAS’s do not require an airport to takeoff or land. Likewise, a reduction of manned 

aircraft conducting aerial video and photography missions would result in fewer aircraft 

that must be handled by air traffic control during the ground, takeoff, departure, cruise, 

arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3, 

DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, And 3D Robotics Solo 

UAS’s.

Conducting aerial acquisitions with the DJI Phantom 3, DJI Inspire 1, DJI S1000+, 

Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s, instead of manned aircraft, 

will greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial photography, videography, inspection, and mapping 

flight operations. By using battery power and electric motors, the DJI Phantom 3, DJI 

Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s

produce no air pollution, and is the most viable environmentally conscious alternative to 

the cabin class, six cylinder internal combustion engine aircraft that are typically utilized 

for aerial video and photography, while burning approximately 10-20 gallons per hour of 

leaded aviation fuel. The DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 

Flying Wing, and 3D Robotics Solo UAS’s, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UA’s are propelled by battery 

powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying 

Wing, and 3D Robotics Solo UAS’s to perform aerial acquisitions, the substantial risk to 

life and property in the air and on the ground, which is usually associated with traditional 

manned aircraft flight operations, will be substantially reduced or completely eliminated. 

Aside from the lack of flight crew members located onboard the aircraft, the DJI 

Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics 

Solo UA’s (all weighing less than 10 pounds at their maximum gross weights and with no 

fuel on board) has less physical potential for collateral damage to life and property on the 

ground, and in the air, compared to the manned aircraft that typically conduct similar 

operations (weighing 3000-6000 pounds and carrying 50-100 gallons of fuel). 

3. Performing Aerial Image Acquisitions With The DJI Phantom 3, DJI Inspire 1, 

DJI S1000+, Skywalker X8 Flying Wing, And 3D Robotics Solo UAS’s Will 

Benefit The Economy.
15

In addition to being safe and efficient, the DJI Phantom 3, DJI Inspire 1, DJI S1000+, 

Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s are also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, 

operation of the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing,

and 3D Robotics Solo UAS’s will allow United States based companies, like Aerial 

Perspective LLC, to remain competitive and contribute to growth of the U.S. economy. 

Specifically, with the rising cost of aviation fuel and the Environmental Protection 

Agency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and 

operated companies must adopt new and alternative technology in order to maintain 

competitive. Operating the battery powered DJI Phantom 3, DJI Inspire 1, DJI S1000+, 

Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s is one such technology that 

not only allows companies greater operational flexibility compared to manned aircraft, 

but provides such flexibility without the high operational cost of a traditional manned 

aircraft.

By operating the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying 

Wing, and 3D Robotics Solo UAS’s, companies such as Aerial Perspective LLC can 

remain competitive and profitable, and therefore, provide greater job stability to 

employees and contractors, which will ultimately contribute to growth of the U.S. 

economy. Improved financial performance of U.S. companies, through commercial use of 

the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D 

Robotics Solo UAS’s provides a stable workforce that increases consumer spending, 

improves tax revenues, and allows companies to invest in research and development in 

order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted 

for decades, Aerial Perspective LLC’s proposed operations of the DJI Phantom 3, DJI 

Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s will 

not implicate any privacy issues. Specifically, the DJI Phantom 3, DJI Inspire 1, DJI 

S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s will be operated only 

in compliance with limitations set forth in the Granting of this Petition and operating 

documents (i.e. Aerial Perspective LLC Flight Operations Manual) which guides 

operations around persons and property, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. Section 91.119.

E. Reasons Why Granting Aerial Perspective LLC’s Request Would Not 

Adversely Affect Safety. 

1. Reasons Why The DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 

Flying Wing, And 3D Robotics Solo UAS’s Meet The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FRMA) Section 333.
16

In consideration of the size, weight, speed, and limited operating area associated with 

the unmanned aircraft and their operation, Aerial Perspective LLC’s operations of the DJI 

Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics 

Solo UAS’s meet the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security. 

Specifically, FMRA Section 333 states the following, in part:

(a) In General. – Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required 

by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems. – In making the determination 

under subsection (a), the Secretary shall determine, at a minimum—

(1) Which types of unmanned aircraft systems, if any, as a result of 

their size, weight, speed, operational capability, proximity to 

airports and populated areas, and operation within visual line of 

sight do not create a hazard to users of the national airspace system 

or the public or pose a threat to national security; and

(2) Whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United 

States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1).

(c) Requirements for Safe Operation. – If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Aerial Perspective LLC submits that the included UAS’s 

can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) 

the characteristics of these UAS; (b) the pilot certification requirement; and (c) the 

specific operating limitations.

A. DJI Phantom 3, DJI Inspire 1, DJI S1000

i. Safety Features

Although a degredation or loss of control link, and/or degradation or loss of 

the source of navigation is unlikely, it is a situation that is well planned for 

and therefore, a benign event.
17

In the event of a loss of link, the aircraft will follow a user-selected procedure. 

The aircraft will proceed to the “home” position, which is set by the PIC prior 

to flight and can be changed in flight if necessary, at a set altitude. If link is 

not regained, the aircraft will initiate a decent and land at the designated 

“home” position.

If the GPS solution is lost during flight, the PIC will still have full control of 

the aircraft and can maneuver it back to “home” for a safe landing. As the PIC 

always flies the UAS in visual line of sight, it is immediately apparent if this 

situation occurs. 

DJI Intelligent Flight Batteries have many built in safeguards to prevent 

battery failures in flight. These include battery level displays, electronic 

monitors to monitor things like temperature and amperage, and battery history 

information. These features in addition to electrical safeguards on the aircraft 

like Low Battery Return To Home ensure an aircraft will never lose electrical 

power in flight. 

A complete description of the operation and specifications of DJI Phantom 3, 

DJI Inspire 1, and DJI S1000+ is provided in the Operator Manuals included 

with this petition.

B. 3D Robotics Solo and Skywalker X8 Flying Wing

i. Safety Features

The 3D Robotics Solo and Skywalker X8 Flying Wing UA also have many 

safety features to mitigate events like loss of link and loss of navigational 

capability. 

Although a degredation or loss of control link, and/or degradation or loss of 

the source of navigation is unlikely, it is a situation that is well planned for 

and therefore, a benign event.

In the event of a loss of link, the aircraft will follow a user-selected procedure. 

The aircraft will proceed to the “home” position, which is set by the PIC prior 

to flight and can be changed in flight if necessary, at a set altitude. If link is 

not regained, the aircraft will initiate a decent and land at the designated 

“home” position.

If the GPS solution is lost during flight, the PIC will still have full control of 

the aircraft and can maneuver it back to “home” for a safe landing. As the PIC 

always flies the UAS in visual line of sight, it is immediately apparent if this 

situation occurs. 

The 3D Robotics Solo Controller has many built in alerts and safety features 

as well. Five features; pause, regain manual control, return home, land, and 
18

motor shutoff are available in case of emergency. The motor shutoff feature is 

a two-step procedure to prevent inadvertent motor shutoff.

A complete description of the operation and specifications of the 3D Robotics 

Solo and Skywalker X8 Flying Wing are provided in the Operator Manuals, 

included with this petition.

2. Flight Operations Of The DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker 

X8 Flying Wing, And 3D Robotics Solo UAS’s Are Limited To The Line Of Sight 

Of A Certificated Pilot In Command With A Visual Observer.

Aerial Perspective LLC will only utilize pilots who meet the following criteria:

x Possess and meet currency requirements for at least a sport pilot certificate

x Possess a valid third class or better FAA airman medical certificate

x Successfully complete OEM training on the UA being flown and demonstrate 

proficiency on that UA

Aerial Perspective LLC will only utilize visual observers who are trained on the 

appropriate FAA rules and regulations required to perform their duties. The Aerial 

Perspective LLC Flight Operations Manual describes how visual observers will be 

trained. Training records, flight time totals, and applicable flight currency records will 

be maintained by the Aerial Perspective LLC Chief Pilot. 

3. Flights Of The DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying 

Wing, And 3D Robotics Solo UAS’s Will Be Conducted Pursuant To Specific 

Operating Limitations.

In seeking this exemption, Aerial Perspective LLC proposes to commercially operate 

the specified sUAS for the special purpose of conducting photography, videography, 

infrastructure inspections, and mapping in the United States, pursuant to the 

following specific operating limitations:

1) Operations authorized by the grant of this exemption will be limited to the 

following aircraft described in the operating documents, which are vertical 

takeoff and landing, unmanned aircraft weighing less than 55 pounds 

maximum gross weight: DJI Phantom 3, DJI Inspire 1, DJI S1000+,

Skywalker X8 Flying Wing, and 3D Robotics Solo. Proposed operation 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. 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.
19

5) The UA must be operated within visual line of sight of the PIC at all times.

6) All operations must utilize a visual observer. 

7) Operating documents, to include an exemption if granted and UAS operating 

manuals, will be accessible during UAS operations and made available to the 

Administrator upon request.

8) Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics must undergo a functional test flight prior to 

conducting further operations under this request. Functional test flights will be 

conducted with a PIC and VO and will remain at least 500 feet from other 

people. 

9) Aerial Perspective LLC will be responsible for maintaining and inspecting the 

UAS to ensure that is in a condition for safe operation. 

10) Prior to each flight, the PIC will conduct a pre-flight inspection to determine 

the UAS is in a condition for safe flight.

11) Aerial Perspective LLC will follow UAS manufacturer’s maintenance, 

overhaul, replacement, inspection, and life limit requirements for the aircraft 

and aircraft components.

12) Each UAS operated under this request will comply with all manufacturer 

safety bulletins.

13) All PIC will hold at a minimum a sport pilot certificate. All PIC will also hold 

a current FAA airman medical certificate. All PIC will meet the flight review 

requirements specified in 14 C.F.R. Section 61.56 in an aircraft in which the 

PIC is rated on his or her pilot certificate.

14) Aerial Perspective LLC will not permit any PIC to operate UAS’s unless the 

PIC demonstrates the ability to safely operate the UAS in a manner consistent 

with how the UAS will be operated under this request. 

15) Operations will be conducted in day light hours under VMC conditions.

16) Aerial Perspective LLC will not operate UA’s within 5 nautical miles of an 

airport reference point, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to Aerial 

Perspective LLC.

17) UAS’s will 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 a UAS loses communications or loses its GPS signal, the UA will be able to 

return to a pre-determined location.

19) The PIC will abort a flight in the event of unpredicted obstacles or 

emergencies.

20) The PIC will not begin a flight unless 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.
20

21) All operations will be conducted in accordance with an Air Traffic 

Organization-issued COA.

22) All aircraft will be identified by serial number, registered in accordance with 

14 CFR part 47, and have identification markings in accordance with 14 CFR 

part 45, Subpart C. Markings will be as large as practicable.

23) Documents used by Aerial Perspective LLC to ensure the safe operation and 

flight of the UAs and any documents required under 14 CFR Sections 91.9 

and 91.203 will be available to the PIC at the Ground Control Station of the 

UAS any time the aircraft is operating.

24) UA’s will remain clear and give way to all manned aviation operations and 

activities at all times.

25) UAS will not be operated from any moving device or vehicle.

26) All Flight Operations will 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.

b. The owner/controller of any vessel, vehicle, or structure has granted 

permission for operating closer to those objects and the PIC has 

determined the operation is safe.

27) All operations will be conducted over private or controlled-access property 

with permission from the property owner/controller or authorized 

representative.

28) Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

will be reported to the FAA’s UAS Integration Office within 24 hours. 

Accidents will be reported to the National Transportation Safety Board per 

instructions on the NTSB website.

4. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

Would Not Adversely Affect Safety.

Aerial Perspective LLC submits that an equivalent level of safety established by 

Section 61.113(a) will be maintained because no PIC will be allowed to operate the 

UAS unless that PIC has demonstrated, through the proper UAS training and 

currency requirements, that the PIC is able to safely operate the UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and 

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

Considering Aerial Perspective LLC’s proposed area of operations and the operating 

limitations set forth above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No 11062); 

and the airmanship skills necessary to safely operate the UAS, Aerial Perspective 

LLC submits that the additional manned airmanship experience of a commercially 
21

certificated pilot would not correlate to the airmanship skills necessary for Aerial 

Perspective LLC’s specific proposed flight operations.

Additionally, the FAA has previously granted relief from Section 61.113(a) specific 

to UAS, in circumstance similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11112, 11136, 11138).

As in Exemption No. 11109, Aerial Perspective LLC will not allow any PIC to 

operate the UAS unless that PIC has demonstrated through the UAS training and 

currency requirements that the PIC is able to safely operate the UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and 

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

5. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would 

Not Adversely Affect Safety.

The level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, Aerial Perspective LLC will ensure that the UAS is in an airworthy 

condition and safe for flight based upon the UAS’s compliance with its operating 

documents and as stated in the conditions and limitations herin.

Additionally, the FAA has previously granted relief from Section 91.7(a), specific to 

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138).

6. Reasons Why An Exemption From The Requirements Of Section 91.119(c) 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.119(c) will be maintained 

given the size, weight, and speed of the UAS as well as the location where it is 

operated. No flight will be taken without the required local and ATC coordination. 

Due to the advance notice to the property owner and participants in the aerial activity, 

all affected individuals will be aware of the planned sUAS flight operations. 

Additionally, the FAA has previously granted relief from Section 91.119(c), specific 

to UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11112, 11136, 11138).

7. Reasons Why An Exemption From The Requirements Of Section 91.121 Would 

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because all the UAS Aerial Perspective LLC proposes to operate are equipped with a 
22

digitally encoded barometric altimeter and GPS triangulation equipment, with a zero 

altitude initiation point being established prior to each flight. As such, the PIC on the 

UAS is provided the altitude of the UA above ground level (AGL) via a heads-up 

display of the ground control station (GCS). 

Additionally, the FAA has previously granted relief from Section 91.121, specific to 

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138).

8. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.151(b) will be maintained 

because the operator will always have detailed information on the charge and state of 

the battery, and preset battery failsafe’s will prevent any loss of flight control due to 

power loss. 

The ground control station (GCS) for each UAS provides a battery indicator on the 

heads-up display, which indicates the UA’s current remaining battery power measure 

in volts, and thus provides the PIC with constant awareness of the real-time battery 

voltage during a flight. 

Additionally, the FAA has previously granted relief from Section 91.151(b), specific 

to UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11136, 11138). These previous exemptions granted by 

the FAA concerning Section 91.151 establish that safety is not adversely affected 

when the technical characteristics and operating limitations of the UAS are 

considered.

9. Reasons Why An Exemption From The Requirements Of Section 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a) (2), And 91.417(a) & (b) Would Not Adversely 

Affect Safety.

In seeking this exemption, Aerial Perspective LLC submits that an equivalent level of 

safety with regard to the regulatory maintenance and alteration requirements 

established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), And 

91.417(a) & (b) will be met because Aerial Perspective LLC and the manufacturers of 

each aircraft, will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the manufacturer’s maintenance manual. Furthermore, Aerial 

Perspective LLC will document and maintain all maintenance records for each of the 

individual aircraft.
23

Since each UAS will be inspected as prescribed by the manufacturer’s maintenance 

manual, Aerial Perspective LLC will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of each 

aircraft’s Operator’s Manual, which contain descriptions and procedures for all 

maintenance of the system, are included with this request. 

Additionally, the FAA has previously granted relief from Section 91.151(b), specific 

to UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11136, 11138). These previous exemptions granted by the FAA concerning Section 

91.151 establish that safety is not adversely affected when the technical 

characteristics and operating limitations of the UAS are considered.

F. Summary That Can Be Published In The Federal Register.

The Rules From Which Aerial Perspective LLC Seeks Exemption:

Aerial Perspective LLC seeks exemption from the requirements of 14 C.F.R. Sections 

61.113(a), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b.

A Brief Description Of The Nature Of The Exemption Aerial Perspective LLC 

Seeks:

This exemption will permit Aerial Perspective LLC to commercially operate 

Unmanned Aircraft Systems for the purpose of conducting photography, videography, 

infrastructure inspections, and mapping within the United States.

G. Any Additional Information, Views, Or Arguments Available To Support 

Aerial Perspective LLC’s Request.

This Petition is made pursuant to the FAA modernization and Reform Act of 2012 (FMRA) 

Section 333, which directs the Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, Aerial Perspective LLC’s request for exemption may be 

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth 

above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security, and 

further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Aerial Perspective will operate the specified UAS safely in the 

NAS without creating a hazard to users of the NAS, or the public, or otherwise pose a threat 

to national security.
24

CONCLUSION

As set forth herein, Aerial Perspective LLC seeks an exemption pursuant to 14 C.F.R. 

Section 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), 

which will permit safe operation of the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker 

X8 Flying Wing, and 3D Robotics Solo UAS’s commercially, without an airworthiness 

certificate, for the limited purpose of conducting photography, videography, infrastructure 

inspection, and mapping within the stated operational guidelines. By granting this Petition, the 

FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and 

Reform Act of 2012, while also advancing the interests of the public, by allowing Aerial 

Perspective LLC to safely, efficiently, and economically operate these UAS commercially within 

the NAS.
25

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Aerial Perspective LLC respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements of 14 

C.F.R. Sections 61.113(a), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Aerial Perspective LLC to operate the 

specified UAS for the purpose of conducting photography, videography, infrastructure 

inspections, and mapping within the United States.

Dated: August 7, 2015

Respectfully submitted, 

AERIAL PERSPECTIVE LLC

___________________________________

JAKEE STOLTZ

111 N 3rd Street Unit 1003

Grand Forks, ND 58203

Tel: (701) 290-5459

Attachment A: Aerial Perspective LLC Flight Operations Manual

Attachment B: DJI Phantom 3

Attachment C: DJI Inspire

Attachment D: DJI S1000+

Attachment E: Skywalker X8 Flying Wing

Attachment F: 3D Robotics Solo
26

ATTACHMENT A

Aerial Perspective LLC Flight Operations Manual

This document is withheld as proprietary and confidential and is subject to non-disclosure under 

Freedom of Information Act, 5 U.S.C. Section 522 et seq.
27

ATTACHMENT B

DJI Phantom 3

See Attached Manual:

Phantom_3_Professional_User_Manual_v1.2
28

ATTACHMENT C

DJI Inspire 1

See Attached Manuals:

Inspire_1_User_Manual_v1.2_en

Inspire_1_Maintenance_ManualV1.0_en
29

ATTACHMENT D

DJI S1000+

See Attached Manual:

S1000_Plus_User_Manual_v1.2
30

ATTACHMENT E

Skywalker X8 Flying Wing

See Attached Manual:

3DR Pixhawk Manual 
31

ATTACHMENT F

3D Robotics Solo

See Attached Manuals:

3D Robotics Solo User Manual