Adam	White

Above	Ground	Aerial	Photography	&	Video

182	Carver	Falls	Rd.

Fayetteville,	NC	28311

November	30th 2015

U.	S.	Department	of	Transportation	

Docket	Management	System	

1200	New	Jersey	Ave.,	

SE	Washington,	DC	20590	

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	and	14	C.F.R.	

Part	11,	I,		Adam	White,	 a	media	specialist,	preparing	this	exemption	request	myself,	would	

like	to	apply	for	an exemption	from	the	following	Code	of	Federal	Regulations	(C.F.R)	to	be	

allowed	commercial	operation	of	lightweight	Unmanned	Aircraft	Systems	(SUAS)

Exemption Request Pursuant to Section 333 of the FAA Reform 

Act and Part 11 of the Federal Aviation Regulations from: 14 

C.F.R. 21 Subpart H; 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. 

§91.103(b)(2); 14 C.F.R. §91.109; 14 C.F.R. §91.119(c); 14 C.F.R. 

§91.121; 14 C.F.R. §91.151(a); 14 C.F.R. §91.203 (a) and (b); 14 

C.F.R. §91.405 (a); 14 C.F.R. §91.407 (a) (1) 14 C.F.R. §91.409 

(a)(1) and (2); 14 C.F.R. §91.417(a) and (b)

Commercial operation of a sUAS, as described herein, which are 

equipped with camera(s) and sensors, would operate in the following 

manner:

1. Aerial photography and/or video for public and/or private use 

including real estate, architecture, land surveying, engineering, 

and other related professional activities. 

2. Aerial video and/or photography for public and/or private use 

including closed-set motion picture and television filming, public 

events, cinematography, and news gathering. 

3. Aerial data collection applications which include mapping, 

topographical surveying, 3D modeling, and precision agriculture. 
4. Aerial inspection/photography of residential/commercial 

structures. 

5. Aerial inspection/photography of residential/commercial utility 

infrastructure including but not limited to electrical power lines, 

wind turbines, and cell towers. 

6. Aerial video/photography or providing live video feed to assist 

with search and rescue operations in cases of an emergency or 

natural disaster only when the local authorities or government has 

requested it by contract or donation. 

7. The ability to offer training to persons individually or belonging 

to both private and/or public organizations that have interests in 

the use and application of a sUAS for the purpose of the safe 

operation of a sUAS to enhance the safety of the National 

Airspace System (NAS) as well as for the protection of the 

persons and property. 

The requested exemption would permit the operation of a sUAS under controlled 

conditions in the NAS that would be a) limited b) controlled c) predetermined, and d) will 

provide safety enhancements to the already safe operations in the industry presently using 

conventional aircraft. Approval of this exemption would thereby enhance safety and 

fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to 

“....establish requirements for the safe operation of such aircraft systems in the national 

airspace system.”

Above Ground Aerial Photography & Video proposes to operate the DJi Inspire 1 & 

DJi Phantom 3 Professional 

1. DJI Inspire 1 – Quadcopter: Dimensions: 17.24 in. x 17.75 in. x 11.85 in. 

(height) Weight: 6.4 lbs.Maximum Speed: 42 kts Frequency Spectrum: 2.4GHz 

(control), 5.8GHz (video feed) FCC Compliant 

2. DJi Phantom 3 Professional: Dimensions 15in x 15in Weight: 5lbs Max Speed: 

24kts Frequency Spectrum: 2.4GHz (control), 5.8GHz (video feed) FCC 

Compliant
Regulations from which the exemptions are requested:

• 14 C.F.R. Part 21 Subpart H• 14 C.F.R. Part 36 Subpart A, F & O 

• 14 C.F.R. §45.23 (b)• 14 C.F.R. §61.113 (a) & (b)• 14 C.F.R. §91.7 

(a)• 14 C.F.R. §91.9 (b) (2)• 14 C.F.R. §91.103(b)(2)• 14 C.F.R. 

§91.109

• 14 C.F.R. §91.119 (c)• 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. §91.405 (a)

• 14 C.F.R. §91.407 (a) (1)• 14 C.F.R. §91.409 (a) (2)• 14 C.F.R. 

§91.417 (a) & (b)

AIRCRAFT & EQUIVALENT LEVEL OF SAFETY

The applicant seeks to have this exemption cover the sUASs used to carry 

out the commercial operations described herein which are subject to the 

limitations proposed in this petition. Above	Ground	Aerial	Photography	&	

Video and agrees to the following limitations and conditions for commercial 

sUAS operations conducted under a granted FAA exemption:

1. The sUASs will weigh less than 55 lbs. 

2. The sUASs will have a maximum operating speed of no more 

than 55kts. 

3. Flights will be operated within line of sight of the Pilot in 

Command (PIC) and/or Visual Observer (VO). 

4. Maximum flight time for a multi-rotor sUAS operational flight 

will be 30 minutes. Flights will be terminated at 25% battery 

power reserve or 25 minutes of flight time whichever occurs first. 

5. Maximum flight time for a fixed wing sUAS operational flight 

will be 40 minutes. Flights will be terminated at 25% battery 

power reserve or 30 minutes of flight time whichever occurs first. 
6. Flights will be operated at an altitude of no more than 400 feet 

Above Ground Level (AGL). In cases where the sUAS is used to 

survey, inspect, or photograph a structure that exceeds 400 feet 

AGL, the sUAS will not be operated more than 200 feet above 

the highest point of that structure. 

7. Minimum crew for each operation will consist of the sUAS Pilot, 

the Visual Observer (VO) and may include but not limited to a 

Camera Operator. 

8. The sUAS pilot will be a designated Pilot in Command (PIC) and 

hold either an airline transport, commercial, private, recreational, 

or sport pilot certificate. The PIC will also hold a current FAA 

airman medical certificate or a valid U.S. driver’s license issued

by a state, District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal government of the United States. The 

PIC will also meet the flight review requirements specified in 14 

C.F.R. §61.56 in an aircraft in which the PIC is rated on his or 

her pilot certificate. 

9. A briefing will be performed regarding the planned sUAS 

operations prior to each day’s flight operations, which will 

outline the individual flight activities and safety measures. 

10. All flights will occur under Visual Meteorological Conditions 

(VMC) only. 

11. The flights will occur no closer than a 5 mile radius of the 

geographic center/Airport Reference Point (ARP) of a tower 

controlled or uncontrolled airport. 

12. If operations will be within a 5 mile radius of the geographic 

center/Airport Reference Point (ARP) of a tower controlled or 

uncontrolled airport the respective airports will be contacted 

advising them of the estimated flight time, flight duration, 

elevation of flight and other pertinent information. 
13. The operator will file FAA Form 7711-1, or its equivalent, as 

modified in light of the requested exemption, with the appropriate 

local Flight Standards District Office (FSDO) no more than 72 

hours but no less than 48 hours from planned operation. 

14. The operator will obtain verbal/written consent of all persons 

involved with the planned operation and ensure that only 

consenting persons will be allowed within 100 feet of the flight 

operation, and the radius may be reduced to 30 feet based upon 

an equivalent level of safety determination. With the advanced 

permission of the FSDO, operations at closer range may be 

approved.

15. The PIC and VO will have been trained in operation of sUAS and 

receive up-to-date information for the particular sUAS to be 

operated. 

16. The PIC and VO will be able to communicate by voice or radio at 

all times. 

17. Written and/or verbal permission and necessary permits will be 

obtained from territorial, state, county, or city jurisdictions, 

including law enforcement, fire, or other appropriate 

governmental agencies. 

18. If the sUAS loses communications with the remote controller or 

experiences GPS signal degradation, the sUAS will have the 

capability to return to a pre-determined location. 

19. When applicable, GPS Geo-Fencing technology will be used to 

place limits on the aircraft’s maximum vertical and horizontal 

displacement from the ground control point. 

20. The sUAS will have the capability to abort a flight in case of 

unpredicted obstacles, weather, or emergencies. 
21. The sUAS 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. 

22. A Motion Picture and Television Operations Manual (MPTOM) 

will be used to help govern all closed-set motion picture and 

television filming operations. 

PUBLIC INTEREST Above Ground Media ensures that with the approval of the 

exemptions requested in this petition are in the public’s interest. Our sUAS create

reduced environmental impact, lower cost, and increased safety.

14 C.F.R. Part 21, Subpart H: Certification Procedures -

Airworthiness Certificates

Subpart H, entitled Airworthiness Certificates, establishes the 

procedural requirements for the issuance of airworthiness certificates as 

required by FAR §91.203 (a) (1). Given the size and limited operating 

area associated with the aircraft to be utilized by the applicant, an 

exemption from Part 21, Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform 

Act. The Federal Aviation Act 49 U.S.C.§44701 (f) and Section 333 of 

the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular sUAS. In all cases, an analysis of 

these criteria demonstrates that the sUAS operated without an 

airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions 

proposed.
The sUAS to be operated is less than 55 lbs. fully loaded, carries 

neither a pilot nor passenger, carries no explosive materials or 

flammable liquid fuels, and operates exclusively within a secured and 

designated area. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the operator in 

compliance with local public safety requirements. These enhancements 

provide a greater degree of safety to the public and property owners 

than conventional civil aircraft operations conducted with airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, there is 

no credible threat to national security posed by the sUAS, due to its 

size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and its inability to carry a 

substantial external load. There have been exemptions granted by the 

FAA to petitioners seeking identical relief; See Grant of Exemption No. 

11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

14 C.F.R. Part 36, Subparts A, F and O: Noise Standards - Aircraft 

Type and Airworthiness Certification

Pursuant to 14 C.F.R. Part 36, Subparts A, F and O, establish certain 

noise standards for certification of various aircraft types. Because the 

Subject sUAS would not have an airworthiness certificate, and given its 

small size and negligible noise impact, the petitioner requests an 

exemption from 14 C.F.R. Part 36.

14 C.F.R. § 45.23 (b): Display of Marks; General.

Pursuant to 14 C.F.R. 45.23(b); When marks include only the Roman 

capital letter “N” and the registration number is displayed on limited, 

restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that 

aircraft near each entrance to the cabin, cockpit, or pilot station, in 

letters not less than 2 inches nor more than 6 inches high, the words 

“limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” 

as applicable.
While the sUAS will have no airworthiness certificate, an exemption 

may be needed as the sUAS will have no entrance to the cabin, cockpit 

or pilot station on which the word “Experimental” can be placed. Given 

the size of the sUAS, two-inch lettering will be impractical. The word 

“Experimental” will be placed on the fuselage in compliance with 

§45.29 (f). The equivalent level of safety will be provided by having 

the sUAS marked on its fuselage as required by §45.29(f) where the 

pilot, observer, and others working with thesUAS will see the 

identification of the sUAS as “Experimental.” In a previous Grant of 

Exemption, the FAA determined that exemption from these 

requirements was warranted provided that the aircraft “have 

identification (N-Number) markings in accordance with 14 C.F.R Part 

45, Subpart C if the markings are as large as practicable.” See FAA 

Docket No. FAA-2014-0352. All sUASs flown by American Drone 

Pros will bear N-number markings that are as large as practicable in 

accordance with 14 C.F.R. Part 45, Subpart C.

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and 

Limitations - Pilot in Command.

Pursuant to 14 C.F.R. 61.113 (a) & (b); No person who holds a private 

pilot certificate may act as a pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire. Because the 

applicant’s sUAS does not carry any pilots, passengers, or property, 

American Drone Pros may achieve an equivalent level of safety as 

achieved under current regulations. The risks attendant to the operation 

of a sUAS is far less than the risk levels inherent in the commercial 

activities outlined in 14 C.F.R. 61. The PIC of the sUAS will have 

either an airline transport, commercial, private, recreational, or sport 

pilot certificate. The PIC will also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state, District of 

Columbia, Puerto Rico, a territory, a possession, or the Federal 

government of the United States. 
In meeting those limitations as listed in previous FAA exemption 

approvals, the PIC of American Drone Pros sUASs will exceed current 

safety levels in relation to 14 C.F.R. 61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.

Pursuant to 14 C.F.R. 91.7(a); No person may operate a civil aircraft 

unless it is in airworthy condition. As there will be no airworthiness 

certificate issued for the sUAS, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the maintenance requirements detailed 

in the sUAS User and/or Operations Manual combined with safety 

check lists prior to each flight, an equivalent level of safety will be 

provided. See Grant of Exemption No. 11671 to Dronair Solutions 

(FAA–2015–0648 page 18) for previous FAA granted exemption.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual, Marking, 

and Placard Requirements.

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered 

civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual 

is not required by §21.5 of this chapter, unless there is available in the 

aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination 

thereof. Given the size and configuration of the sUAS used by 

American Drone Pros, there is no capacity to carry such a flight manual 

on the aircraft. An equivalent level of safety will be achieved by 

keeping the sUAS Operation Manual at the ground control point where 

the pilot in command will have immediate access. See Memorandum 

from Mark Bury, FAA Assistant Chief Counsel for International Law, 

Legislation and Regulation, to John Duncan, FAA Flight Standards 

Service (Aug. 8, 2014); see also Docket No. FAA-2014-0352 at 16-18.
14 C.F.R. § 91.103(b)(2): General Operating and Flight Rules -

Preflight Action.

Pursuant to 14 C.F.R. 91.103(b)(2); For civil aircraft other than those 

specified in paragraph (b)(1) of this section, other reliable information 

appropriate to the aircraft, relating to aircraft performance under 

expected values of airport elevation and runway slope, aircraft gross 

weight, and wind and temperature. An equivalent level of safety will be 

provided by a preflight checklist and other safety measures detailed in 

the sUAS Operation Manual. The PIC will take actions including 

reviewing weather, flight battery requirements, landing and takeoff 

distances, aircraft performance data, and setting the pre-determined 

safe landing area in case of loss of GPS communication before 

initiation of flight. See Grant of Exemption No. 11671 to Dronair 

Solutions (FAA–2015–0648 page 18)

14 C.F.R. §91.109: Flight instruction; Simulated Instrument Flight 

and Certain Flight Tests.

Section 91.109 provides that no person may operate a civil aircraft 

(except a manned free balloon) that is being used for flight instruction 

unless that aircraft has fully functioning dual controls. Remotely 

piloted aircraft and sUAS, by their design, do not have fully functional 

dual controls. Flight control is accomplished through the use of a 

control box that communicates with the aircraft via radio. The FAA has 

approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in 

experimental aircraft. Due to the size and speed of the sUAS and the 

fact that neither a pilot nor passengers will be carried in the aircraft, 

and all persons will be a safe distance away in the event that the UAS 

experiences any difficulties during flight instruction, an equivalent 

level of safety is provided. The FAA has granted exemption for the 

same operation, See Grant of Exemption No. 11671 to Dronair 

Solutions (FAA–2015–0648 page 19)
14 C.F.R. §91.119: General Operating and Flight Rules - Minimum 

Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. 

Section 91.119 (d) allows helicopters to be operated at less than the 

minimums prescribed, provided the person operating the helicopter 

complies with any route or altitudes prescribed for helicopters by the 

FAA. As this exemption is for sUAS operation at altitudes up to 400 

feet AGL, an exemption may be needed. In cases where the sUAS is 

used to survey, inspect, or photograph a structure that exceeds 400 feet 

AGL, the sUAS will not be operated more than 200 feet above the 

highest point of that structure. An exemption was granted by the FAA 

for like operations - See Grant of Exemption No. 11138 to Douglas 

Trudeau (FAA-2014-0481 page 19)

An equivalent level of safety will be achieved given the size, weight, 

and speed of the sUAS as well as the location where it is operated. No 

flight will be taken without the permission of the property owner or 

local officials. Compared to flight operations with aircraft or rotorcraft 

operating below 500 feet AGL, weighing far more than the proposed 55 

pound maximum, and carrying flammable fuel, the sUASs employed 

by American Drone Pros provide a much safer alternative. In addition, 

the low-altitude operations of the sUAS will ensure safe separation 

from those of conventional aircraft that must comply with Section 

91.119.

14 C.F.R. §91.121: General Operating and Flight Rules - Altimeter 

settings.

Section 91.121 requires each person operating an aircraft to maintain 

cruising altitude by reference to an altimeter that is set “...to the 

elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As the sUAS may not have a barometric 

altimeter, but instead a GPS altitude read out, an exemption may be 

needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the safety check list and live flight data monitoring, 
confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. See e.g., Grant of Exemption No. 11062 to 

Astraeus Aerial (FAA-2014-0352 at 21).

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR 

Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in 

an airplane 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 – (1) During 

the day, to fly after that for at least 30 minutes; or (2) At night, to fly 

after that for at least 45 minutes.” For similarly FAA granted 

exemption, see Grant of Exemption to Alan Purwin (Exemption No. 

11161). The battery powering the sUAS provides approximately 30 

minutes of powered flight. Because the 30 minute reserve requirement 

in 14 C.F.R. §91.151 cannot be met by the sUAS, an exemption is 

needed. With a limited flight time of 25 minutes or 25% battery power 

and line of sight operation in a limited area, an equivalent level of 

safety is achieved. This time/power restriction is more than adequate to 

safely return the sUAS to its planned landing zone from anywhere in its 

limited operating area.

14 C.F.R. §91.203 (a) and (b): Civil Aircraft: Certifications 

Required

The regulation provides in pertinent part: (a) Except as provided in § 

91.715, no person may operate a civil aircraft unless it has within it the 

following: (1) An appropriate and current airworthiness certificate...(b) 

No person may operate a civil aircraft unless the airworthiness 

certificate required by paragraph (a) of this section or a special flight 

authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. The sUAS fully 

loaded weighs no more than 55 lbs. and is operated without an onboard 
pilot. As such, it is impractical to carry certification and registration 

documents or to display them on the sUAS. An equivalent level of 

safety will be achieved by keeping these documents at the ground 

control point where the pilot in command will have immediate access. 

The FAA has granted exemption for same, See Grant of Exemption No. 

11671 to Dronair Solutions (FAA–2015–0648 page 18)

14 C.F.R. §91.405 (a); §91.407 (a) (1); §91.409 (a) (2); §91.417(a) & 

(b): Maintenance required.

Sections 91.405(a), 407(a)(1), 409(a)(2), 417(a)(b) require that an 

aircraft operator or owner “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...,” and 

others shall inspect or maintain the aircraft in compliance with Part 43. 

American Drone Pro proposes that the maintenance of the sUAS will 

be accomplished by the owner/operator according to the operation 

manual. As provided in the attached manuals, the operator will ensure 

that the sUAS is in working order prior to initiating flight, perform 

required maintenance, and keep a log of any maintenance that is 

performed. Moreover, the operator is the person most familiar with the 

aircraft and is best suited to maintain the aircraft in an airworthy 

condition thereby ensuring an equivalent level of safety. See e.g., Grant 

of Exemption No. 11671 to Dronair Solutions (FAA–2015–0648 page 

15)
SUMMARY OF SECTION 333 EXEMPTION REQUEST

Above Ground Photography & Video, hereby provides, pursuant to 14 C.F.R. Part 11 

Subpart A §11.81, a summary of our exemption petition to allow commercial operation 

of sUAS for aerial video and photography, precision aerial mapping, 3D modelling, 

surveying, cataloguing, and inspection services. Our pursuit for exemption is intent on 

benefiting both public and governmental sectors some of which include:

• Agriculture 

• Land Planning & Development 

• Local Infrastructure 

• Solar Power 

• Power Generation and Distribution 

• Architecture and Engineering 

• Environmental 

• Search & Rescue American Drone Pros is poised to provide service in support of these 

and future applications with the utmost attention to quality and safety. Therefore, 

we respectfully request exemption from the following regulations: 

14 C.F.R. Part 21 Subpart H14 C.F.R. Part 36 Subpart A, F & O 14 C.F.R. §45.23 

(b)14 C.F.R. §61.113 (a) & (b)14 C.F.R. §91.7 (a)14 C.F.R. §91.9 (b) (2)14 C.F.R. 

§91.103(b)(2)14 C.F.R. §91.10914 C.F.R. §91.119 (c)14 C.F.R. §91.12114 C.F.R. 

§91.151 (a)14 C.F.R. §91.203 (a)14 C.F.R. §91.405 (a)14 C.F.R. §91.407 (a)14 C.F.R. 

§91.409 (a)14 C.F.R. §91.417 (a)

CertificationProceduresforProductsandParts-AirworthinessCertificates. Noise 

Standards: Aircraft Type and Airworthiness Certification.Display of Marks; 

General.Private Pilot Privileges and Limitations: Pilot In Command.

Civil Aircraft Airworthiness.Civil Aircraft Flight Manual, Marking, and Placard 

Requirements. General Operating and Flight Rules - Preflight Action.Flight 

Instruction; Simulated Instrument Flight and Certain Flight Tests. General 

Operating and Flight Rules - Minimum Safe Altitudes.General Operating and 

Flight Rules - Altimeter settings.Fuel Requirements for Flight in VFR 

Conditions.Civil Aircraft: Certifications Required.Maintenance 

Required.Operation After Maintenance, Rebuilding, or 

Alteration.Inspections.Maintenance Records
I	have	included in	this	report:

1) A	Supplemental	Response	for	Petition	

2)		Manuals:	The DJI	manuals	are	too	large	for	upload	to	regulations.gov.	

Therefore,	please	follow	the	link	below	to	the	assembly	and	operating	

manual	for	the	sUAS.

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3

_Professional_User_Manual_v1.0_en.pdf

2) Personal	protocols	and	controls	- Safety/Flight	concerns

4)	Summary	of	Section	333	Exemption	Request

I	would	like to	thank	you	for	giving	me	this	opportunity	to	apply	for	a	333	

Exemption.	With	your	approval,	I	will	have	the	ability	to	be	commercially	able	to	

provide	a	positive	service	in	many	exciting	industries.	

Sincerely	yours,

Adam	White

Above	Ground	Aerial	Photography	&	Video

182	Carver	Falls	Rd.

Fayetteville,	NC	28311