U.S. Department of Transportation, Docket Operations

West building ground floor, Room w12-140 1200 New Jersey Avenue, SE, Washington, DC 20590 

Attn: To whom it may concern

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14

C.F.R. Part 11, Northwest Aerial, operator of a Small Unmanned Aerial System (“sUAS”) is equipped to 

conduct aerial photography and videography, is applying for exemption from the listed (“FARS”) Federal 

Aviation Regulations. To allow commercial operations of it’s (“sUAS”), as long as such operations are 

conducted within the guidelines outlined by the FAA. The exemption would allow the operation of Small 

Unmanned Aerial System (“sUAS”) by a Pilot In Command (“PIC”) accompanied with a Visual Observer (“VO”) 

in airspace that is predetermined and limited in a safe and controlled manner. The exemption, if granted would 

allow Northwest Aerial to conduct commercial operations of (“sUAS”) that meets or exceeds all of the safety 

requirements congress has set forth in Section 333.

Northwest Aerial is a photography service which provides photography and videography services to real estate 

companies, construction companies, event planners and privet parties: In the scope of imaging services, There 

is a need to provide services with the use of (“sUAS”) for safety and compliance issues that can only be 

achieved with (“sUAS”).

-Aerial photography/videography for the purpose of enhancing real estate listings.

-Aerial photography/videography for public and privet events e.g. festivals, parades, weddings, sporting 

events.

-Aerial photography/videography for construction site inspections and monitoring 

-Aerial photography/videography for filmmaking 

-Aerial photography/videography for inspection of structures, towers, roof tops

-Aerial photography/videography for the purpose of land use planning and design

-Aerial photography/videography for agricultural inspections and land use planning

Northwest Aerial (“The Petitioner”) request exemption from the following (“FARS”) Federal Aviation 

Regulations.

FAR SUBJECT JUSTIFACATION

14 CFR § 45.23 (b) Requirement to display registration 

number on vehicle 

Insufficient space on vehicle

14 CFR Part 21

Aircraft certification requirements 

and procedures

Designed for manned aircraft not off the 

shelf (“sUAS”) small unmanned aerial 

systems

14 CFR § 61.3 Requirement for pilot certification Part 61 requirements designed for 

manned aircraft, not sUAS; petition 

describes training for (“PIC”) pilot in 

command of sUAS

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft not 

(“sUAS”)
14 CFR § 91.9 (b) (2) Requirement for manual to be 

available in the cockpit

No cockpit available aircraft is 

unmanned nobody aboard to read 

manual.

FAR SUBJECT JUSTIFICATION

14 CFR § 91.103 (b) Requirement for crew members to 

be onboard

Unmanned vehicle.

14 CFR § 91.109 Requirement for dual controls 

during flight instructions 

Nobody aboard to operate controls.

14 CFR § 91.119 Minimum altitudes for safe flight Safety requires operation below these 

altitudes.

14 CFR § 91.121 Altimeter settings Nobody onboard to read altimeter. 

14 CFR § 91.151 (a) Fuel requirements Vehicle operates on battery power not 

fuel.

14 CFR § 91.203 (a) & 

(b)

Requirements for registration and 

airworthiness certificates to be 

onboard

Unmanned vehicle nobody onboard to 

read certificates.

14 CFR § 91.205 (b) Aboard cockpit instruments Unmanned vehicle nobody aboard to 

read instruments 

14 CFR § 91.215 ATC transponder and altitude 

reporting equipment

Unmanned vehicle is to small to carry 

transponder equipment and also 

operates below civilian and commercial 

air traffic safe operating altitudes in the 

NAS.

14 CFR § 91.401-91.407 Maintenance, Preventive 

Maintenance, Alterations and

operations after.

There is not a standardized maintenance 

schedule for off the shelf (“sUAS”) 

Northwest Aerial will perform preflight 

visual inspections and ensure 

connectivity to the NAZA GPS flight 

system. Northwest Aerial will also keep 

a log book of flights, times, maintenance 

and any modification’s that can be 

viewed upon request. 
(“sUAS”) Are much smaller and safer to operate than conventional helicopters or fixed wing aircraft over 

populated areas, crowds, and in close proximity to buildings or events. Northwest aerial is petitioning 

for exemption to operate it’s DJI Phantom 2 in a commercial capacity and operate safely in NAS. 

Northwest Aerial DJI Phantom 2 is equipped with safety features that enable the user to set altitude 

limits and limits the radius to which the DJI Phantom 2 can fly from the PIC. It is also equipped with a DJI 

iOSD (“On Screen Display”) that relays the battery power level of the sUAS and the altitude of the sUAS 

to the (“PIC”) to a 7” monitor attached to the handheld transmitter . The DJI Phantom 2 is equipped with 

a safety system so if the battery level of the sUAS falls to 25% the DJI Phantom will return to home and 

home is a predetermined GPS waypoint that is set before take off. The return to home feature will also 

be activated automatically if the transmitter (main controller) loses contact with the onboard receiver of 

the sUAS. The DJI Phantom 2 is also fitted with a H3-3D 3 axis gimbal and a GoPro Hero 3+ camera that 

will be used to capture video and photographs. Northwest Aerial will only operate it’s sUAS within VLOS 

of the PIC and VO and will operate at sites with sufficient distance from Heli pads and airports. If the 

sUAS is operated within 5 miles of an airport or heli pad the operators of the airport will be notified and 

the PIC will give the right away to any full size aircraft to ensure the safety of the users of the NAS 

system and public. Flight times will be a maximum of 20 minutes per flight and all flights will be 

terminated at 25% battery life if that happens before the 20 minute flight time is up. Northwest Aerial 

will program it’s sUAS to fly at no more than 400 feet AGL and no more than 200 feet above any 

elevated platform from which any filming is planned. Northwest Aerial will also not fly directly above 

large crowds at outdoor events but rather capture photos and video from the outer edge of events or 

from predetermined safe zones within the event that will be blocked off to prevent foot traffic from 

walking under the airspace of the sUAS. The minimum crew to fly the sUAS will consist of a PIC (pilot in 

command) and a VO (visual observer) the sUAS operated by Northwest Aerial weighs no more than 5 

pounds including payload (i.e. camera, gimbal) and will travel no faster than 30 mph can hover, and can 

simultaneously move vertically and horizontally. Given the size of Northwest Aerials sUAS and the 

restricted environment in which we will be operating Northwest Aerial will adhere to the Reform Act’s 

safety requirements. The sUAS is smaller, lighter and more maneuverable than full sized helicopters and 

fixed wing aircraft that run on fuel and carry passengers, it operates at lower altitudes and carries no 

passengers and thereby reduce the risk of serious bodily injury, death and property damage and thereby 

enhance safety. Low level photography/videography that is done with a sUAS is far more cost effective 

than chartering a full sized helicopter or fixed wing aircraft and can be completed with no impact on the 

environment from the use of combustible fuels and far less danger to the safety of the users of the NAS 

and the public below. Safety and compliance issues in the construction industry can now be viewed in 

real time with the DJI Phantom 2 and viewed with the FPV (first person view) monitor. The DJI Phantom 

operated by Northwest Aerial can also benefit the local agriculture industry by monitoring cropland and 

inspecting problem areas it can also be a key tool in land use planning for maximum harvest potential. 

Previous methods would have been to drive through cropland with atv’s, trucks or machinery to get to 

problem areas resulting in further damage to the crop. With the use of a sUAS we can help farmers see 

problem areas and give them a perspective they could never achieve from ground based imagery

resulting in more effective treatment of noxious weeds, crop disease, water usage and other agricultural 

related issues.

This is the DJI Phantom 2 L.E.D. light indicators upon power up it will flash a sequence of lights to let you 

know the status of the sUAS and weather your in GPS flight mode which locks on to several satellites 

and allows you to set a return to home waypoint. In the event of signal loss or low voltage it 

automatically goes into RTH mode.

 
In return to home mode you can set the altitude to which the sUAS will ascend or descend to before it 

flys to the home waypoint and lands. This is helpful because every area of operation may have different 

obstacles that the sUAS may have to fly over before it returns to the home waypoint. But if the sUAS 

encounters an obstacle that it cannot clear in RTH mode you have the option to manually turn it off and 

manually control and fly the sUAS back to a safe landing area. 

This is the picture of the screen when you connect the DJI Phantom 2 to your home PC where you can 

set all the altitude limits and return to home features and also download new firmware.
Here is an example of a screen shot where you can monitor your batteries and their status.

Once the DJI Phantom is plugged into your PC all of your control calibrations can be checked and the 

UAS can be programed to meet all limitations as far as altitude and return to home features when low 

voltage or loss of signal occurs. 
 Pilot in command qualifications

Northwest Aerial pilot in command Nathan Hueser has extensive history with remote control airplanes, 

cars, boats and multirotor. I started around the age of 6 when I received my first 2 channel nitro 

powered remote control airplane built by my father. My father and grandfather were both licensed 

privet pilots and also licensed sailplane pilots I’ve spent many weekends as a child walking the flight line 

of Felts Field and Mead and Deer Park airports in the Spokane Wa. Area. I have flown in several types of 

aircraft including Cessna, Aeronca Champ, Stearman Biplane and a couple different types of sailplane. As 

an adult I still fly R/C aircraft that are much larger and more complicated than the first 2 channel .049 

powered one that I started with I’m currently flying a 4 channel Super Decathlon equipped with rudder, 

elevator, ailerons and throttle I’ve also flown a 6 channel airplane equipped with retractable landing 

gear and flaps. Having flown several types of R/C aircraft over the years in club atmosphere and also 

teaching others to fly them, and as a former member of the AMA (Academy of Model Aeronautics) I 

know the importance of safe operation of model airplanes around the public and also understand how 

important it is to maintain the safety of the NAS. If Northwest Aerial exemption is granted we will 

adhere to the regulations set by congress and the FAA to the fullest extent and conduct business in the 

safest most professional manner to ensure the safety of the general public and the users of the NAS. 

Northwest Aerial will also use a VO (visual Observer) to help ensure the safety of the public and the NAS 

this person will maintain a visual look out for any potential hazards like overhead power lines, 

structures, people, Trees, full size aircraft or anything that may pose an issue or safety concern for the 

pilot or public on the ground or users of the NAS. Northwest Aerial will always maintain VLOS and never 

fly behind buildings, trees, walls, clouds or anything that will block the view of the sUAS from the PIC or 

the VO. Northwest Aerial believes it can provide a very safe very cost effective service to the public 

without endangering the public or the property in the operational area as a further precaution we will 

also maintain liability insurance from www.insuremydrone.net or www.aig.com or 

www.transportrisk.com or www.drone-insurance.com whichever can be determined to give the best 

coverage suited for the scope of business Northwest Aerial will be conducting.

Yours Truly,

Nathan Hueser Owner Northwest Aerial

11905 S. Funseth Dr. 

Spokane Wa. 99223

1-509-362-7056

bignate509@gmail.com