Flyral Imaging 

6845 Corsica Drive 

Memphis, TN 38120 

January 8, 2016 

Dept. of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM 

Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations- Amended August 7, 2015 

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, Flyrallmaging (Fiyral lmaging), a Tennessee based business 

operating small Unmanned Aircraft Systems (sUAS) equipped to conduct aerial 

photography and survey for various industries, hereby seeks an exemption from Federal 

Aviation Regulations (FARs) detailed below to allow operation of our sUAS commercially in 

airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are 

conducted with and under the conditions outlined herein or as may be established by the FAA 

as required by Section 333. The requested exemption is similar to previous FAA issued grants 

of exemption including but not limited to Exemption Nos. 11062, 11109, 11112, 11213 and 

11295. 

The requested exemption would allow Flyral Imaging to pursue commercial business by 

being permitted to provide services to consumers, companies, local law enforcement and 

first responders as well as government agencies interested in training, research, and aerial 

data capture using sUAS in the following areas: 

- Agricultural Surveying and Application; 

- Aerial Photography and Videography for real estate, insurance, construction, mining and 

utilities companies; 

- Disaster relief and emergency management efforts; 

- Product and Service Demonstrations; 

- Operator Training; 

- Research and Development. 

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The petitioner request relief from the following regulations: 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61 .113(a), 61.315(a), 91.7(a), 91.109, 

91.119(c), 91.121 , 91.151 (a)(1 ), 91 .215, 91.405(a), 91.407(a)(1 ), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow Flyrallmaging to operate a UAS to 

perform research, training and aerial data collection. 

Petitioner's sUAS platforms 

We are petitioning for exemption to enable Flyral Imaging to operate a series of widely operated 

and well established sUAS platforms manufactured by DJI that have been previously approved 

by exemption. These include: 

DJI Phantom 2 

DJ I Phantom 2 Vision + 

DJI Phantom 3 

DJI Inspire 1 

Exemption 11398 

Exemption 11398 

Exemption 12342 

Exemption 12331 

These sUAS all weigh less than 55 lbs, have a built-in capability to limit the height flown above the 

ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, 

C and D airspace including a no fly zone feature. Each system also has the failsafe function of the 

autopilot system, which means when the communication between the Main Controller and the 

transmitter is lost, the system will automatically trigger Return to Home and will land safely. 

This submission does not include the Operating Manuals for each model requested above, as 

they have been reviewed by the Administrator in granting previous exemptions. Copies of all 

Operating Manuals for the individual models listed can be submitted on request. 

General Operating Standards 

The Flyral Imaging sUAS will be operated in the field with both a PIC (Pilot in Command) and a 

VO (Visual Observer) in accordance with FAA Policy and with the following Restrictions: 

a) No flight will be made with a UAS Gross weight exceeding 55 pounds, including payload; 

b) All operations must occur in FAA Class G airspace at no more than 400ft AGL, at 

an airspeed of no more than 87 knots (100 miles per hour) and be operated within 

the visual line of sight (VLOS) of the PIC at all times; 

c) All operations must utilize a visual observer (VO). The VO and PIC must be 

able to communicate by voice at all times during a flight operation; 

d) Operations will be restricted to flights over private property with the permission of 

the property owner(s); 

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e) The PIC will hold either 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, the District of Columbia, Puerto Rico, a territory, 

a possession, or the Federal government. The PIC will also meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his 

or her pilot certificate. 

f) All required permits will be obtained from state and local government prior to operation; 

g) The 901 Drone sUAS will not be operated over densely populated locations; 

h) The 901Drone sUAS will not be operated at air shows; 

i) 

j) 

k) 

I) 

The 901 Drone sUAS will not be operated over any open-air assembly of people; 

The 901 Drone sUAS will not be operated over heavily trafficked roads; 

The 901 Drone sUAS will not be operated within 5 NM of an airport or heliport; 

Operations will be restricted to day only and weather conditions equivalent to VFR; 

m) The PIC will brief the VO and property owner about the operation and risk before the 

first flight at each new location; 

n) No flight may be made without a Preflight Inspection by the PIC before each operation 

to ascertain that the sUAS is in a condition safe for flight (see Appendix A). 

We submit that the combination of the sUAV's light weight, flight performance and ability, 

fully qualified flight crew and under all of the Restrictions (a) through (n) listed above, the 

FAA can have full confidence that the operation will have an equivalent or greater level of 

safety than manned aircraft performing the same mission. 

All sUAS operated in accordance with this exemption will be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 

Exemption Requests and Equivalent Level of Safety 

Flyrallmaging requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the sUAV System: 

14 CFR 61.23 Medical Certificates 

The regulation provides that a person requires a first or second class medical to act as Pilot in 

Command of an aircraft for compensation or hire. Our proposed operations require that the PIC 

must hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a 

state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal 

government. Since the aircraft cannot carry passengers or property, we feel we meet the intent 

of 61 .23 even though the intent of this application is to conduct a business. 

14 CFR 61.101, 14 CFR 61.113, and 14 CFR 61.315 Pilot privileges and Limitations 

The regulation provides that no person that holds a Recreational Pilot, Sport Pilot, or Private 

Pilot certificate may act as Pilot in Command of an aircraft for compensation or hire. Our 

proposed operations require that the PIC must hold at least airline transport, commercial, 

private, recreational, or sport pilot certificate. Since the aircraft cannot carry passengers or 

property, we feel we meet the intent of 61 .113 Subparagraph (b) even though the intent of this 

application is to conduct a business. 

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14 CFR 91.7 Civil Aircraft Airworthiness 

This Section prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

14 CFR 91 .109 Flight Instruction; Simulated instrument flight and certain flighttests 

The regulation states that "No person may operate a civil aircraft that is being used for flight 

Instruction unless that aircraft has fully functioning dual controls." Training will be conducted by 

Flyrallmaging PIC instructors. We have the ability to provide dual controls utilizing two 

transmitters with a wireless and or wired link between the transmitters. One transmitter is 

designated the master transmitter and the other transmitter is designated as a slave. The Flyral 

lmaging PIC instructor, utilizing the master transmitter, will be at all times be able assume 

control of the sUAS. 

14 CFR 91.119 Minimum safe altitudes: General 

The regulation states that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of thesUAS 

would be photography or survey of persons, vessels, vehicles or structures it would be 

necessary to operate closer than 500 feet to the items listed. Operations will only be flown over 

property where permission has been obtained and careful pre-planning has been performed. 

The sUAS will be operated at a low altitude allowing, if a power unit fails, an emergency landing 

without undue hazard to persons or property on the surface. Therefore we maintain that due to 

the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared 

to manned aircraft, which should·be considered in granting the exemption. 

14 CFR 91 .121 Altimeter settings 

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and 

will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An 

Above Ground Level altimeter measurement above the takeoff point is transmitted via radio 

from the sUAS on-board computer to the display screen held by the PIC, providing a constantly 

updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions 

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy 

reserve as a safety buffer for delays to landing. The sUAS are battery operated and the 

maximum duration of flight from a single battery charge is 12-45 (depending on which sUAS) 

minutes with a 20% reserve. Since the aircraft will never fly more than 1/2 NM from the point of 

intended landing, a full battery charge at launch will ensure that we meet the reserve energy 

requirement of this paragraph. We request an exemption to the word "fuel" and ask for an 

equivalent interpretation with the word "energy". We also request exemption from the 30 min 

reserve and ask that our reserve will be to fly the mission to the point of intended landing and 

have at least a 20% battery reserve after that. 

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14 C.F.R. 91 .215 ATC transponder and altitude reporting equipment and use: 

This regulation states all aircraft operating within 30 nautical miles of class A, B and C airspace 

must be equipped with automatic pressure altitude reporting equipment having a Mode C 

capability that automatically replies to Mode C interrogations. Due to the small size and lifting 

capabilities of our sUAS we cannot carry a traditional transponder. All of our operations will be 

under 250' if we are operating within the 30mi reach of a mode C vail. 

14 CFR Subpart E (91.401- 91 .417)- Maintenance, Preventive Maintenance, Alterations 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. It is our intention that the Flyrallmaging PIC perform 

maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return 

to service." 

The PIC will ensure that the sUAS is in an airworthy condition prior to every flight and in 

addition, conduct detailed inspections after every two hours of flight. Maintenance performed by 

the PIC is limited to repairing small cracks, replacing a propeller, checking electrical 

connections and updating software and firmware for the on-board computer. All other 

maintenance will be performed by the manufacturer or their designated repair facility. The PIC 

will document work performed in accordance with 91.417. We feel that due to the size, 

construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 

How this request is to the betterment of our community 

Our UAS are powered by batteries, smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel, it operates at lower altitudes with no people on board and will 

thereby reduce current risk levels associated with traditional aircraft, enhance safety and 

diminish the likelihood of death or serious bodily injury. Also with a small payload and typical 

flight time of only 20 minutes, there is little or no risk to national security. 

Low level photos and video are far more effective than ground or high altitude manned aircraft 

imagery for displaying detailed characteristics of ground based objects. The applicant in the 

past has chartered full-sized helicopters for this purpose, which has proven more costly than 

many potential clients have been able to afford. The benefits of reduced cost and improved 

quality of presentation from the UAS will be incredibly valuable to future clients. 

Additionally, we will make our sUAS available to first responders in our community who might 

require assistance, including fire fighters, police, sheriff, et al., while remaining subject to all 

limitations cited in this application. 

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The name and contact information of the petitioner are: 

Flyrallmaging 

Attn: Aaron Jaffe 

Phone: 901 .834.9566 

Email: Aaron@flyral.co 

We are prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. Please contact us at any time if you require additional information 

or clarification. We look forward to working with your office. 

Sincerely, 

Aaron Jaffe, Owner 

Flyral Imaging 

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