AERIALIMAGERYLLC

2645 New Haven Blvd

Navarre, FL 32566

slfoster72@hotmail.com

(850) 572-5805

July 9,2015

US Department OfTransportation

Federal Aviation Administration

800 Independence Ave SW

Washington DC20591

Dear Sir or Madam:

Pursuant to Section 333 of the FAAModernization and Reform Act of

2012(the reform act) and CFRPart 11, AERIALIMAGERYLLC,owner and operator

of Small Unmanned Aircraft Systems (UASs), request to be exempted from the

Federal Aviation Regulations (FAR) listed below so that AERIALIMAGERYLLCmay

operate UASs commercially in airspace regulated by the FAA., as long as such

operations are conducted within and under the conditions outlined herein or as

maybe established by the FAAas required by Section 333.

AERIALIMAGERYLLCis owned by Scott Foster. Scott Foster is in possession

of a valid Florida driver's license. Scott Foster possesses a valid commercial pilot's

license (certificate number 285689879), has been a rated aviator since 1997, and

will be the PIC.All training of additional pilots will be conducted by Scott Foster. All

operations will be performed with the public's safety and right to privacy

safeguarded at all times.

As described below, the requested exception would permit the operation of

lightweight (less than 55 lbs. total takeoff weight) UASsunder controlled conditions

for commercial use by a certified private pilot thereby enhancing safety and fulfilling

the Secretary of Transportation's (the FAAAdministrator's) responsibility to

"establish requirements for safe operation of such aircraft systems in national

airspace systems." Section 333(c), ofthe Reform Act.

AERIALIMAGERY'sUASs are rotorcraft weighing less than 55 pounds

including payload (The Inspire 1 Quad Copter). They operate at a speed less than 50

knots and have the capability to hover and move in the vertical and horizontal plane

simultaneously. They have an auto return to launch point when battery power is

under 25%. The UASwill operate within the line of sight within a protected flight

area as described below and at 200 feet AGLor less with an observer located close at

hand as to make voice communication possible.

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These operations will not create a hazard to users of the nation airspace, public nor

the environment.

AERIALIMAGERYLLCrespectfully requests the grant of an exception to the

following specific sections of the Title 14 Code of Federal regulations allowing it to

operate lightweight UASsfor commercial use,

14 CFR21, subpart H, 14 CFR45.23 (b) 14 CFR91.7 (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)&(b).

AERIALIMAGERYLLCsubmits this application in accordance with the

Reform Act ,112 P.L. 95 331h 334, seeking relief from any currently applicable

FAR'S operating to prevent AERIALIMAGERYLLCfuture commercial use of small

UASsto operate in the national airspace system as described below. The reform Act

section 332 provides for such integration of civil unmanned aircraft into our

national airspace system as it is in the public's interest to do so. AERIALIMAGERY

LLC'sUASsmeet the definition of "small unmanned aircraft" as defined in Section

331 and therefor the integration of these UASs are expressly contemplated by the

Reform Act. AERIALIMAGERYLLCwould like to operate its light weight UASsprior

to the time period by which the Reform Act requires the FAAto promulgate rules

governing such aircraft.

The Reform Act directs the Secretary of Transportation to consider whether

certain unmanned aircraft systems may operate safely in national airspace before

completion of the rule making required under Section 332 of the reform Act. In

making this determination, the Secretary of Transportation is required to determine

which UASs do create a hazard to users of the national airspace system or the public

or pose a threat to national security in light of the following:

The UASssize, speed, weight and operational capability

Operation of the UASsin close proximity to airports and populated areas

Operation of the UASswithin visual line of sight of the operator

Reform Act 333(a). If the secretary determines that such vehicles "may

operate safely in National Airspace System, the secretary shall establish

requirements for the safe operation in national airspace.

AERIALIMAGERY'sUASs are rotorcraft weighing less than 55 lbs. and they

operate at speeds less than 50 knots and have the capability to operate in the

vertical and horizontal plane simultaneously. The UASswill operate only within the

line of sight of the operator within a protected flight area and at 200 feet AGLor

less. These will not present a hazard to the national airspace nor the public.
The very small nature of these UASs combined with the safe guards

presented below, will allow for the safe operation greater than that envisioned by

Congress for the FAAto establish and by exemption allow commercial operations of

UASsto commence immediately. Also due to the size of UASs and the areas and

altitudes they will operate approval of this exception presents no national security

issues and absolutely minimal safety concerns which have been mitigated through

our rigorous risk management process. Given the clear direction given in Section

333 of the Reform Act, the authority contained in the Federal Aviation Act, as

amended, the strong equivalent level of enhanced safety, reduced emissions

utilizing UASsverses traditional aircraft as well as the economic impact of greatly

reducing the cost of aerial photography thereby benefiting the greater public's

interest. Accordingly, the applicant requests that the FAAgrant the requested

exemption without delay.

The following will be considered as the binding limitation on operations of

AERIALIMAGERYLLC:

1. Flights will only occur in the daytime hours or in well lit, large stadiums (football).

2. Flights will be operated in the line of sight of the operator (PIC) and

Observer(VSO).

3. Flights will be terminated at any time weather and wind deteriorate to "unsafe for

flight" by manufacturer's recommendations.

4. The UASswill weigh less than 55 lbs.

5. Flights will be operated at 200 feet AGLor less.

6. Crew will be at a minimum of operator (PIC) and an observer and/or camera

operator (VSO).

7. Operator and crew will remain in contact during the flight operation.

8. The UASs operator will perform a check of the flight area and make certain of the

safety of all persons in the area.

9. When prudent, consent will be obtained from all persons with in the video

capabilities of the units to further reduce the chance of violating anyone's privacy.

10. All required FAAclearances, will be obtained and distances from airports

strictly observed.

11. All UASswill have the capability to return automatically to the operator in a

safe manner with the auto return function checked and working.

12. Flights will only operate in VFR conditions.

13. UASs have a function on the control to tell operator the distance away from the

operator and its battery power remaining.

14. Flight team will communicate by voice and the use of twoh way radio if the

area is too big to hear voice from all team members.

15. UASswill be used to photograph and record video for real estate ventures,

private outings and functions, sporting events from a safe distance, local government

bridge and pier inspection and shark surveillance.

16. When operating over or near water the UASswill be equipped with flotation

devices so that recovery can be made as to prevent lithium battery exposure to the

water table.
14 CFRpart 21 Subpart H: Airworthiness Certificate 14 CFR91.7(a), 91.203(a)(1)

Subpart H, entitled Airworthiness Certificates, sets forth requirements for

procurement of necessary certificates in relation to FAR91.203(a)(1). The size,

weight and defined area of operations for AERIALIMAGERYLLCUASsflights

permits exception from Part 21 because they meet an equivalent level of safety

pursuant to Section 333 of the Reform Act. The FAAis authorized to exempt

aircraft from the airworthiness certificate requirement under both the Act (49

USC4470(f) and Section 333 of the Reform Act. Both pieces oflegislation permit

the FAAto exempt UASsfrom airworthiness certificates in consideration of

weight, size, speed, maneuverability and proximity to areas such as airports and

dense populations. AERIALIMAGERYLLCmeets or exceeds each of these

elements.

As of March 23, 2015 the FAAhas stated that it will automatically grant a "blanket"

CGAfor flights at or under 200 AGLto any UASsoperator with a section 333

exemption.

14 CFR91.203(a&b) provides for carrying of civil aircraft certifications and

registrations. These are inapplicable for the same reasons stated above. The

equivalent level of safety will be achieved by maintaining such certifications and

registrations at AERIALIMAGERYLLCoperations center.

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness

certificate. As no such certificate will be applicable in the form contemplated by

FAR's, this regulation is inapplicable.

14 CFR91.9(b) (2) CivilAircraft Flight Manual in Aircraft

14 CFR91.9(b)(2) requires an aircraft flight manual in the aircraft. As there are

no pilots or passengers, and given the size of the UASsthis regulation is

inapplicable. An equivalent level of safety will be achieved by maintaining such

certifications and registrations at AERIALIMAGERYLLCoperations center.

The FAAhas previously issued exemptions to this regulation in Exemptions No's

8607,8737,8738,9299,9299A,9565,9565B,10167,l0167 A,l0602,l0700 and 32827.

14 CFR91.119 Minimum safe altitudes, prescribes safe altitudes for operation of

civil aircraft. It allows helicopters to be operated at lower altitudes in certain

conditions. AERIALIMAGERYLLCwill only operate its UASs at or below 200 feet

AGL.They will be operated in a wellh defined area that has been carefully

reviewed for hazards and minimizes the presence of any persons not essential for

these operations. Compared to flight operations of conventional and traditional

aircraft or rotorcraft weighing far more than 50 lbs., operating below 500 AGLwith

flammable
fuel UASsoperations present a far smaller risk to the public.

Approval of these 333 Exemptions allowing commercial operations of small

UASsin the service of aerial photography will greatly enhance safety by reducing

the overall risk associated with traditional aircraft. Traditional aerial photography

requires large aircraft with flammable fuel to fly in close proximity of populated

areas and people in general. With the use of small UASs of 55 lbs. or less, battery

operated and fling below 200 feet AGL,the risk of injury to people on the ground or

the crew has been reduced or eliminated.

The granting of the use of these small UASsby AERIALIMAGERYLLCwill

give realtors a comprehensive tool for sales and property jland developers an

efficient and cost effective means to monitor and evaluate progress, from overhead,

spanning large areas. AERIALIMAGERYLLCwill be a video recording source for

families. Families will have the ability to have their special occasions recorded from

a 3 dimensional perspective. Additionally, AERIALIMAGERYLLCwill provide the

local government a safe and cost effective means for the of conducting bridge and

pier inspections and conduct shark surveillance.

Granting AERIALIMAGERYLLCthe above exemption will facilitate the

development and growth of a local small business, providing an undetermined

amount of local jobs. Through safe operations and consideration of privacy, AERIAL

IMAGERYLLCwill provide a positive image and guidance in the implementation

and use of UASsinto the future.

AERIALIMAGERYLLCrespectfully requests the FAAgrant its exception

without delay. The FAAhas the authority to issue the exemption sought by AERIAL

IMAGERYLLCpursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended

(the ACT).

Sincere~ _

sco~ /

AERIALIMAGERYLLC

2645 New Haven Blvd

Navarre, FL 32566

slfoster72@hotmail.com

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