(May 15, 2015)

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(the “Reform Act”) and 14 C.F.R. Part 11, Visual Aerial Pros, seeks an 

exemption from Federal Aviation Regulations (“FARs”) detailed below for 

(1) DJI Inspire 1, and (1) DJI Phantom3 quadcopters manufactured by DJI 

Innovations.

The requested exemption would support an application for a commercial 

Certificate of Authorization to use the system to support aerial photography 

and videography. The DJI Inspire 1 (6.5lb) and DJI Phantom3 (3lb) consist 

of a battery operated aircraft, a tablet-based ground control station and/ a 

RC Controller, and associated communications equipment. Both aircrafts 

carry an onboard geo-referenced gimbaled camera that allows it to obtain 

photography and videography.

The Unmanned Aircraft System will be operated in the field with a PIC in 

accordance with FAA Policy N 8900.227 Section 14 "Operational 

Requirements for UAS".

Visual Aerial Pros respectfully requests the grant of exemption allowing to

operate lightweight, remote controlled UAS's lawfully and safely.

Visual Aerial Pros also respectfully requests Exemption Request Section 

333 from (but not limited to) the Specific Sections of Title 14 of the Code of

Federal Regulations and part ll of the Federal Aviation. Regulations listed 

below.
14 C.F.R.45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 

(b) (2); 91.103(b); 91.109; 91.119; 91.121~ 91.151(a); 91.203(a) & (b); 

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b)

The extent of relief Visual Aerial Pros seeks and the reason why:

Visual Aerial Pros is seeking relief from any applicable FARs operating to 

prevent Visual Aerial Pros from conducting aerial shots of real estate and 

other possible legal flight operations. The weight of the UAS meets the 

definition of ''small unmanned aircraft” found in section 331 "The Reform 

Act”. Visual Aerial Pros seeks to operate legally as a small business that 

cater mostly to real estate agents. Realtors are not allowed to use UAS's or 

hire unless they or the person they hire, is allowed by the FAA to fly a UAS. 

Visual Aerial Pros would satisfy the need for safe and affordable aerial 

shots.

At less than 7 pounds, Visual Aerial Pros uses UAS that is considerably 

less than 55 pounds including the camera that is attached. The UAS will be 

used at speeds under 35 mph because of the nature of the business and 

the limited physical capabilities of the UAS. It is designed to hover and take 

pictures. The UAS will be in accordance with flying well below 400ft.

The UAS in which Visual Aerial Pros would be using only utilizes battery 

power for its operations. There are no combustible fuels used in the UAS 

that Visual Aerial Pros uses. The maximum flight time for our particular 

UAS is 20 minutes battery life. It will fly no more than 15 minutes maximum 

at one time at one location. The amount of time the UAS will be in the air, 

less than 400ft, is very minimal.

A Safety system in place for Visual Aerial Pros UAS includes a GPS mode 

that allows the UAS to return home if communication is lost. Further, the 

GPS onboard allows the UAS to return back to its launched position if the 

battery life of the UAS is low.
THE GROUND STATION PART OF THE SYSTEM:

A Pilot in Command (PIC) in operational control of a flight operation from 

beginning to end and who controls the UAS while in the air. Additionally, 

the line of site of the UAS will not leave the sight of the PIC.

A 2.4GHz radio transmitter/controller operated by the PIC to control the 

U.AS while in flight;

A radio receiver receiving live video,and flight data from the on-board 

camera and computer. It projects it all in one screen to the Pilot in 

Command

The UAS, weighing less than 7lbs fully loaded, is powered by batteries and 

operates with no people on board which lowers the likelihood of death or 

serious bodily injury. With a small payload consisting of harmless 

electronics such as a camera and GPS, the UASs only purpose is to be 

used as a tool to take pictures and videos.

Low level aerial photos and video from several angles are far more 

effective than ground based photos. Low level aerial video and pictures 

show the layout of properties with the advantage of seeing more in one 

photo or short video.

Current applicants have used helicopters and small planes for this purpose 

but the cost of fuel, time, and emissions of such aircraft is not efficient 

enough for most customers to afford.

The benefits of reduced cost and improved efficiency of the UAS allows 

future customers to afford this service with a faster turnaround time at a 

lesser cost.

Additionally, I respectfully request that VISUAL AERIAL PROS be allowed 

to use the UAS to benefit possible first responders our local area for 

actions that could benefit the public. Such as, fires and search and rescue.
Visual Aerial Pros will not operate a UAS near airports and generally does 

not fly over crowds. Situational awareness is most important. The areas 

where Visual Aerial Pros conducts aerial photography is predetermined 

which allows for a controlled environment to operate safely.

With allowing Visual Aerial Pros to conduct business with a light weight 

UAS, it could very well help the economy and benefit people in first 

response situations. Further, Visual Aerial Pros UAS is considerably lighter 

than the alternative which is a helicopter or small plane. Currently, Visual 

Aerial Pros has 2 UAS which only operates off 20 minutes of battery power. 

Therefore, the UAS used by Visual Aerial Pros would only have a flight time 

of 5 - 15 minutes at one time. The likelihood of injury or even death with 

such a small unmanned aircraft, compared to an aircraft flown by a person 

loaded with combustible fuel, is considerably low

SUMMARY:

Visual Aerial Pros is more than willing to follow the safety guidelines of the 

FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS'1 

with the appropriate exemptions for flying a small UAS.

A-No flight will be made with a UA Gross weight exceeding 55lbs

B- All operations must occur in FAA Class G airspace at no more than 400 

ft. AGL, at an airspeed of not more than 25 knots and no further than 3/4 

NM from the Pilot In Charge

 

C- Operations will be restricted to flights over private property with the 

permission of the property owner

D- All required permits will be obtained from state and local government 

prior to operation

E- The UAS will not be operated over densely populated areas

F- The UAS will not be operated at air shows

G- The UAS will not be operated over any open-air assembly of people

H-The UAS will not be operated over heavily trafficked roads
I-The UAS will not be operated within 5 NM of an airport or heliport

J- Operations will be restricted to day only and weather conditions 

equivalent to VFR

K- The PIC will notify property owner about the operation and risk before 

the first flight at each new location;

L- No flight may be made without a Pre-Flight Inspection by the PIC before 

each operation to ascertain that the UAS is in a condition safe for flight (see 

Appendix A).

My operations above are the bare minimum safety guidelines Visual Aerial 

Pros will follow. Visual Aerial Pros is also more than willing to follow any 

additional safety requirements if not listed above.

Visual Aerial Pros believes flying its UAS as a small business within the 

safety parameters of the FAA, can help people and promote the economy.

The name and contact information of the applicant is:

Visual Aerial Pros

Attn; Adrey Arrojo

Phone: 305-431-3777

Email: VISUALAERIALPROS@GMAIL.COM

Visual Aerial Pros respectfully requests that the FAA grant its exemption 

request without delay. I very much look forward working together with you 

guys. Thank you for your time.

Respectfully,

Adrey Arrojo

Visual Aerial Pros

305-431-3777