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26 October 2015 

Larry R. Field DBA Arizona Aerial Imaging Solutions (AAIS) 

64400 E. Squash Blossom Ln

Tucson, AZ 85739 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE

Washington DC 20590 

Re: Petition for Exemption Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 

91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 

91.151(a); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a)(1) 

and (2); 14 CFR 91.417(a) and (b) 

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

CFR Part 11, Arizona Aerial Imaging Solutions (Petitioner) (AAIS) hereby applies for an exemption from 

the listed Federal Aviation Regulations (FAR) to allow commercial operation of a designated unmanned 

aerial system (UAS), provided such operations are conducted within the conditions outlined herein or as 

may be established by the FAA as required by Section 333. 

AAIS seeks the requested exemptions to permit it to offer aerial data collection services in the fields of 

remote sensing, aerial imaging, aerial mapping and scientific survey.

As described in the following pages, the requested exemption would permit the operation of a designated 

UAS as set forth in this document under controlled conditions in the National Airspace System (NAS) 

that would be operated safely. Approval of this exemption would provide services that would reduce the 

risk associated with manned solutions, in both flight and other methods of completion of the proposed 

services. 

The name and address of the Petitioner is as follows:

Larry R. Field

Arizona Aerial Imaging Solutions (AAIS)

44000 E. Squash Blossom Ln

Tucson, AZ 85739

Ph: (505)-577-0588

Pilot Cert #3157427

E-mail: larryfield35@msn.com
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Unmanned Aerial System Description 

Arizona Aerial Imaging Solutions (AAIS) will employ both the 3DR Robotics Iris+ Clone and the 3DR 

Aero-M Clone for data collection operations. These systems are clones of Iris+ and Aero-M manufactured 

by 3DR Robotics, have been extensively tested and have a proven safe flight history. Both systems

includes an air frame, a Pixhawk flight controller, and a Minim OSD (onscreen telemetry display). A 

variety of small cameras, radio telemetry receivers, and other sensors can be attached to these platforms to 

accomplish the desired objectives. Both aircraft are flown by the pilot-in-command (PIC) using a radio 

control system. These platforms have a sophisticated flight control system (Pixhawks) that enables the 

PIC to locate the unmanned aircraft (UA) on a moving map as a part of a ground control system in 

addition to being continually in visual line-of-sight and has safety systems to warn and manage low 

battery-voltage situations. These aircraft can be flown manually by the PIC or fly a pre-planned route 

using the ground control system. Both of these aircraft will be flown under a comprehensive set of 

operational standard procedures focused on the safe operation of the platform to minimize risk. Each 

aircraft has a LED lighting system to communicate key elements of operational status at all times, in 

addition to the on-screen display showing flight parameters relevant to the safe operation of the UA.

The Iris+ Clone and the Aero-M Clone have a maximum take-off weight of 3.8 and 6.8 pounds, 

respectively. The UA flight speed will not exceed 30 knots, and it will not be flown in controlled airspace 

or at an altitude that exceeds 400 feet AGL. All flights will be flown in such a way that they can be safely 

terminated with a reserve battery power of 30% maximum charge.

These UAs does not carry any flammable propellant or fuel. 

Command, control, and telemetry communications for both UAs occur on the 2.4 GHz frequency band. 

The communications link is frequency hopping, spread spectrum which greatly reduces the potential for 

interference. The specific radio frequency devices used by these UAs have been tested and found to 

comply with the limits for a Class B digital device, pursuant to Part 15 of the Federal Communications 

Commission. The programming of the respective Pixhawk controllers in each UA is such that, if a lost 

communication link occurs the UA will return to its starting point and automatically land/or circle with no 

user interaction necessary.

Granting an Exemption Would Serve the Public Interest 

In the absence of a UAS, many of the proposed activities would have to be carried out by a helicopter, 

fixed wing aircraft, a bucket truck, or a lineman climbing a tower. All of these conventional methods 

involve a risk to human lives and property that is clearly higher than risks to human lives and property 

posed by the utilization of UAS. 

UAS utilization in accordance with the typical terms of an exemption grant does not require the 

interaction of Air Traffic Control (ATC). Where such use replaces manned aircraft, a net reduction in 

ATC burden is realized. 
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The Iris+ and Aero-M clones are battery powered and therefore creates no noxious emissions hazardous 

to the environment. Further, as a battery powered vehicle the noise levels are substantially lower than any 

internal combustion engine driven aircraft. 

Survey, mapping, and aerial data collection techniques utilizing UAS technology is substantially more 

cost effective than the conventional methods to accomplish these tasks. Cost savings by UAS utilization 

have the potential to find their way to ratepayers thereby reducing energy costs to the consumer. 

OPERATIONAL LIMITATIONS TO ACHIEVE AN EQUIVALENT LEVEL OF 

SAFETY 

AAIS proposes the following operational limitations to achieve an equivalent or higher level of safety 

than under the current regulatory structure, particularly in comparison to the use of manned aircraft. 

1. All operations will be carried out with strict adherence to the operating procedures outlined in the

Pilot s Operating Handbooks (POH) contained in the manufacturer’s user manual (Attachment A)

The POH includes the following: 

a. General description, specifications, and warnings 

b. Limitations 

c. Emergency Procedures 

d. Normal Procedures 

e. Performance 

f. Weight and Balance/Equipment List 

g. Air Vehicle and Systems Description 

h. Handling, Service, and Maintenance 

i. Supplements 

2. The UAs will weigh less than 3.8 and 6.8lbs, respectively, for the two UAs. 

3. The UAs, will operate at a true airspeed maximum (VNE) of 15 m/s (approximately 30 knots) 

which is within manufacturer specifications. 

4. Minimum crew for each operation will consist of the UA Designated Pilot in Command (PIC)

and at least one Visual Observer (VO). The PIC and VO will be able to communicate verbally at

all times during the flight and will not exchange roles during the flight. Electronic messaging or

texting is not permitted during flight operations. The PIC will ensure that the VO can perform the

required duties of the VO. 
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5. The PIC will hold either an airline transport, commercial, private, recreational, or sport pilot

certificate. In addition the PIC must hold a valid U.S. driver s license issued by a state, the 

District of Columbia, Puerto Rico, a territory, a possession, or the Federal Government. 

6. Flights will be operated within visual line of sight (VLOS) of the PIC and VO at all times. AAIS

understands that definition of VLOS is human vision unaided by any device other than corrective 

lenses. 

7. The primary responsibility of the VO will be to enhance the safety of flight operations by verbally 

communicating potentially unsafe observations to the PIC. Such conditions may include, but are 

not limited to, conflicting aircraft, hazardous terrain, features, or weather, UA approaching VLOS 

limits or altitude limits, assisting the PIC in monitoring battery voltage, and advising the PIC if 

non-participating personnel move within a potential danger zone. VO s will be familiar with the 

UAS normal and emergency procedures and aircraft limitations in sufficient detail as to provide 

the PIC with recommended corrective actions.

8. Maximum flight time for each operational flight will be approximately 30 minutes. The actual 

flight time will depend on a variety of variables including wind conditions, sensor payload, 

mission requirements, and the choice of battery capacity. All flights will be conducted under a 

strict battery management regime that alerts the operator to end flight at a pre-determined battery 

capacity. If the PIC exceeds this limit, the UA will autonomously return to the departure point 

and land/circle upon reaching the first critical battery level (first alert) and will land immediately 

upon reading the second critical battery level (second alert). 

9. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL). 

10. All operating documents will be accessible to the PIC at the ground control station during UAS 

operations. Operating documents will include the current POH and a copy of the FAAs 

Exemption, if granted. If a discrepancy exists between the various operating documents, the FAA 

s Exemption, the Exemption will take precedence. The POH will be updated as necessary. Such 

updates will be tracked. 

11. A safety briefing will be performed prior to each day’s flights consisting of all the day’s flight 

operations. All parties involved in the flight operations will participate in the safety briefing. 

12. The PIC will conduct a pre-flight inspection for the UAS. The pre-flight inspection will account 

for all systems to insure that the UAS is in a condition for a safe flight. As a minimum, the preflight inspection will follow the checklist procedures in the POH. If the pre-flight inspection 

reveals a condition that may affect the safe operation of the UAS, the aircraft will not be operated 

until necessary maintenance has been completed. 

13. In the event of an emergency or other unpredicted obstacle to the completion of a flight, the PIC 

will abort the flight in the safest manner possible. 

14. AAIS will not permit a PIC to operate the UAS unless the PIC demonstrates the ability to safely 

operate the UAS safely and competently within the framework of the measures outlined herein 

and the POH. This will include normal and emergency procedures and maintaining appropriate 

distances from persons, vessels, vehicles and structures. PIC qualification flight hours will be 

logged in a manner consistent with 14 CFR ß61.51(b). 

15. The PIC and VO will have been trained in operation of UAS and receive current information

regarding operation of the UA. 
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16. PIC and VO training and evaluation flights will only be conducted during dedicated training

sessions. During such sessions, the PIC will operate the UA a manner consistent with 14 CFR

ß91.119 by maintaining the prescribed distance from non-participants. 

17. All aircraft utilized as a part of this request will be registered and subsequently assigned a serial 

number in accordance with 14 CFR part 47 and display identification markings in accordance 

with 14 CFR part 45, subpart C. N-number markings will be as large as practicable. 

18. AAIS will conduct routine inspections of the UA to ensure that they are in a condition for safe 

operation. As a minimum, inspections will be conducted as per the POH and as per manufacturer

recommendations. Additional inspections will be completed as deemed necessary. AAIS will

comply with all safety bulletins issued by the manufacturer. 

19. AAIS will conduct maintenance on the UA as necessary. Maintenance procedures will follow

manufacturer s recommendations regarding replacement, overhaul, and life limited components. 

20. After maintenance or alterations that affect the operational or flight characteristics of the UA, a

test flight will be conducted to determine that the UA is properly functioning prior to resuming

commercial operations. Flight tests will be conducted by a PIC and a VO and will remain at least

500 feet from other non-participants. Further, the flight test will be conducted in a manner so as

not to pose an undue hazard to persons and property. 

21. AAIS will also obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic 

Organization (ATO) prior to conducting operations within the NAS. 

22. No UA flights will be conducted at night and all flights will occur under Visual Meteorological 

Conditions (VMC). The UA will not be operated less than 2,000 feet horizontally from a cloud or 

when the visibility is less than 3 statute miles from the PIC. 

23. The PIC will ensure that the UA remains clear of and gives right-of-way to all manned aviation 

operations. 

24. The PIC will not operate the UA from a moving device or vehicle. 

25. The UA will not be operated within 5 nautical miles of an airport reference point (ARP) unless a

letter of agreement with that airport’s management is obtained or it is otherwise permitted by a

COA issued to AAIS . 

26. The UA will be operated in a manner that maintains at least a 500 foot clearance from all nonparticipating persons, vessels, vehicles and structures except in the case of the following

conditions:

a. Barriers are present to protect non-participating persons in the event of an accident. AAIS

will ensure that non-participating persons utilize these protective barriers. If a nonparticipating person leaves a barrier and is within 500 feet of the UA, flight operations

will be terminated in a manner that ensures the safety of non-participating persons. 

b. The owner or controller of any vessels, vehicles, or structures has to grant permission to

operate closer than 500 feet to those obstacles and the PIC has to complete a safety

assessment of the proposed operation in order to determine that the operation can be

completed safely. 

27. Flight operations will only be conducted over property where the permission is granted by the

property owner or otherwise authorized representative. 

28. The UASs automatically determine its failsafe return-to-home position upon liftoff. If the UAS 

loses communications with the remote controller, it will return to a liftoff location and land or 

circle autonomously.
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29. AAIS will report any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA to the FAA's UAS

Integration Office (AFS−80) within 24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB). 

SPECIFIC EXEMPTIONS REQUESTED 

In pursuit of this petition the following exemptions are requested:

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR ß91.203 (a) (1). 

Given the size and limited operating area associated with the aircraft to be utilized by AAIS, 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.ß44701 (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 UAS. In all cases, an analysis of these criteria demonstrates that the 

UAS 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 UAS to be operated hereunder 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. These safety enhancements provide a greater degree of safety to the public and 

property owners than conventional 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 UAS, due to its size, speed of 

operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to 

carry a substantial external load. 

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 required by ß21.5 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. 

The UAS, given its size and configuration has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such 

an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at 

the ground control point where the PIC will have immediate access to it. 
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This regulation requires each pilot in command to take certain actions before flight to insure the safety of 

flight. These actions include the following: 

a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, 

and any known traffic delays of which the pilot in command has been advised by ATC; 

b) For any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information: 

1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing

takeoff and landing distance data is required, the takeoff and landing distance data 

contained therein; and 

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. 

As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. The PIC will take all actions as stated in the POH under Normal Procedures including but not 

limited to reviewing weather, flight battery requirements, and aircraft performance data before initiation 

of flight. 

Section 91.103 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. 

UAS and remotely piloted aircraft, 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 

signals. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be 

carried in the UA and by the small size, weight, and generally slow speed of the UA. Thus, an exception 

is requested.

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 request is for a UAS that is helicopter like and the exemption requests authority to operate at 

altitudes up to 400 AGL an exemption may be needed to allow such operations. As set forth herein, the 

UA will never operate at higher than 400 AGL It will only be operated in a controlled environment, 

where structures, vessels, vehicles, and non-participating people will not be exposed to operations. 

The equivalent level of safety will be achieved given the small size, low weight, and slow speed of the 

UAS as well as the controlled environment where it is operated. No flight will be initiated without the 

permission of the property owner or authorized representative. Unlike conventional aircraft, the UA

requires no flammable fuel, a safety enhancement at low altitude. Further, since the UA will be operated 
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at 400 AGL or less, it will maintain separation from manned aircraft that are required to comply with 

Section 91.119. 

This regulation requires each person operating an aircraft below 18,000 feet MSL to maintain cruising 

altitude by reference to an altimeter that is set to a particular barometric pressure (altimeter setting) or the 

elevation of the departure airport. 

Manned aircraft have an altimeter that displays altitude in MSL. The intent of this regulation is to ensure 

that all aircraft in an area are displaying the same altitude when they at the same true altitude MSL. In this 

way aircraft can maintain vertical separation in cruise flight as per ß91.159 for VFR flights and as per 

ß91.179 for IFR flights. Further it ensures that aircraft assigned a particular altitude by ATC or as per

published altitude requirements such as traffic pattern altitudes will have the ability to accurately 

determine that altitude. 

Conversely, the UA’s Pixhawk Controller automatically sets its zero altitude based on the departure site. 

Thus, all altitude readings displayed on the Ground Control Station are in AGL from the departure site. In 

order comply with the limitations specified herein to maintain an altitude below 400 feet AGL, it is 

appropriate for the altimeter to display in AGL instead of MSL thereby maintaining separation from 

manned aircraft and achieving an equivalent level of safety. 

Section 91.151 specifies fuel reserve minimums for airplanes and helicopters. Specifically, 91.51 (b) 

states that 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. 

Since the UA is battery powered and lacks a combustion engine, there is no conventional fuel 

consumption. Further, the flight times for the UAs are considerably shorter (maximum of 30 minutes) 

than combustion engine powered manned aircraft. An equivalent level of safety will be achieved by 

landing the aircraft when the battery power, as monitored at the ground control station, reaches 30% of 

the capacity of a fully charged battery. A further safety feature is that the UAs Controller will 

automatically return to its departure point with no PIC interaction required if the battery voltage falls 

below 20% of the capacity of a fully charged battery. 

The regulation provides in pertinent part: 

a. Except as provided in ß91.715, no person may operate a civil aircraft unless it has within it the 

following: 

1) An appropriate and current airworthiness certificate. . 

2) . An effective U.S. registration certificate issued to its owner or, for operation within the 

United States, the second duplicate copy (pink) of the Aircraft Registration Application as 

provided for in ß47.31(b), or a registration certificate issued under the laws of a foreign 

country. 
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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 ß91.715 is displayed at the cabin 

or cockpit entrance so that it is legible to passengers or crew. 

As previously discussed, an exemption is sought regarding the requirement to acquire an airworthiness 

certificate. Further, these UASs fully loaded weigh <6.8 pounds and are operated without an onboard 

pilot. As such, there is no ability or place to carry a registration certificate or to display it on the UAS. An 

equivalent level of safety will be achieved by keeping the registration certificate at the ground control 

point where the PIC will have immediate access to it. 

These regulations cover maintenance, preventative maintenance, and aircraft alterations. In summary for 

VFR aircraft, and not including all exceptions, it requires the following: 

1. Annual inspections or 100-hour inspections (for commercial operations) with approval for 

return to service by a person authorized by ß43.7. 

2. A test flight by an appropriately rated pilot after repairs or alterations that may have 

appreciably changed the aircraft s flight characteristics have been made 

3. Logging of all maintenance performed according to particular standards 

These sections, collectively part of Subpart E, and Part 43 only apply to aircraft with an airworthiness 

certificate. As previously discussed, an exemption is sought regarding the requirement to acquire an 

airworthiness certificate. However, an equivalent level of safety will be achieved by implementing the 

concepts of these sections as follows: 

1. Inspections will be performed at intervals recommended by the POH and the manufacturer. 

2. A test flight will be performed after any maintenance or alteration is performed that may affect

the UAs flight characteristics. The test flight will be performed prior to return to commercial

service by an appropriately rated and experienced PIC. 

3. All maintenance will be logged. 

CLOSING 

Arizona Aerial Imaging Solutions (AAIS) appreciates the opportunity to submit this petition for 

exemption to the Federal Aviation Administration. I have endeavored to provide the appropriate 

information required based on guidance from the FAA s website. If there are any questions or I can 

provide further information, please contact me. 

Larry R. Field

Owner, Arizona Aerial Imaging Solutions

Instrument Rated Private Pilot
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Appendix A 

Owner Manuals

Containing Pilot Operating Handbook

for

3DR’s Iris+ Quadcopter and Aero-M Drone

These Links are for POHs and Manuals that are directly applicable to the cloned versions 

of the Iris+ and Aero-M referenced in this document. 

Aero-M POH & Manual: https://3drobotics.com/wp-content/uploads/2014/10/AeroMOperation-Manual-v1.pdf

3DR Iris+ POH and Mapping Manual: https://3drobotics.com/wpcontent/uploads/2015/04/Mapping-Package-Instructions-v1.pdf