Private and Confidential

4-Verticals Aerial Imagery L.L.C., West Bloomfield, MI - Section 333 Exemption Petition

February 2nd, 2016

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave,

SE Washington, DC 20590 

I, Chris Payton, the owner of 4-Vericals Aerial Imagery LLC, prepared this document. The use of 

the terms “I”, “My”, “We”, “Our” from here forth within this document refer to 4-Vericals Aerial 

Imagery LLC.

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(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)(2); 91.417(a)&(b)

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

and 14 C.F.R. Part 11, 4-Verticals Aerial Imagery L.L.C., operator of Small Unmanned Aircraft 

Systems (“sUASs”) equipped to conduct aerial photography and videography, hereby applies for 

an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its sUASs, so long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333.1

Following exemption and approval by the FAA, 4-Verticals Aerial Imagery L.L.C., will primarily 

use its professionally built DJI Inspire 1 (To be Purchased ASAP) and DJI Phantom 3

(Currently Own) UAS equipped with cameras for the following applications: 

 Event Photography/Videography

 Agriculture purposes

 Real Estate Photography

 Aerial filmmaking and photography

 Construction site/Real property inspections 

 Private property mapping and surveys

- Marketing/advertising

- Land development

- Insurance claims

- Golf course planning

- Construction

- Vineyard and winery

- Land appraisal
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 Educational and research operations

4-Verticals Aerial Imagery L.L.C.’s, exemption request would permit the operation of ultralightweight, unmanned (i.e. piloted by remote control) UAS’s for the development of community 

and government use videos, permissible within property boundaries for individual homeowners 

and within tightly controlled, limited airspaces predetermined in areas away from the general 

public, airports, heliports and vehicular traffic. Currently, similar lightweight, remote controlled 

UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in 

place to prevent catastrophe. Furthermore, it is my intent to assist future FAA safety protocols 

and regulations exclusive to lightweight UAS's for specific video and photography usage by 

sharing information with the FAA as, 4-Verticals Aerial Imagery L.L.C., records flight data and 

other pertinent information gained through permitted flight operations. 

In addition, granting 4-Verticals Aerial Imagery L.L.C.’s exemption request, will comply with 

the Secretary of Transportation’s (FAA Administrator’s) instructions to not only integrate UAS's 

into the national airspace system, but to “...establish requirements for the safe operation of such 

aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act 

specific to the use of UAS's for real estate/Realtor purposes, educational videos, Search and 

Rescue, land/trusts inspections, agricultural field monitoring, film/video productions, mapping 

purposes, and structure inspections, to aid state and local agencies.

Further, 4-Verticals Aerial Imagery L.L.C., will conduct its operations in compliance with the 

protocols described herein or as otherwise established by the FAA. For the reasons stated 

below, 4-Verticals Aerial Imagery L.L.C., respectfully requests the grant of an exemption 

allowing operations of ultra-lightweight, remote controlled UAS’s to aid academic community 

awareness, to benefit/stimulate attraction to the metro Detroit and to enhance personal and 

public video feeds. A grant that will ultimately allow UAS’s to play a more positive role in our 

local community by increasing employment opportunities, heightening security measures and 

decreasing government expenditures by reducing the need for heavier manned aircraft, 

containing costly, combustible fuel- a potential public hazard in and of itself. 
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I. Contact Information:

Chris Payton

4-Verticals Aerial Imagery L.L.C.

West Bloomfield, MI, 48324

Phone: 248-496-5744

Email: cpayton@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations from Which 

4-Verticals Aerial Imagery L.L.C. Requests Exemption are: 

14 CFR 21; 14 C.F.R. 45.23(b); 

14 CFR 61.113 (a) & (b); 

14 C.F.R. 91, et seq.; 

14 CFR 407 (a) (1); 

14 CFR 409 (a) (2); and, 

14 CFR 417 (a) & (b). 

III. The Extent of Relief 4-Verticals Aerial Imagery L.L.C. Seeks and the 

Reason it Seeks Such Relief: 

4-Verticals Aerial Imagery L.L.C., submit this application in accordance with the Reform Act, 

112 P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent 

4-Verticals Aerial Imagery L.L.C., contemplated commercial flight operations within the 

national airspace system. The Reform Act in Section 332 provides for such integration of civil 

unmanned aircraft systems into our national airspace system as it is in the public’s interest to do 

so. 4-Verticals Aerial Imagery L.L.C.’s, ultra- lightweight UAS meets the definition of “small 

unmanned aircraft” as defined in Section 331 and therefore the integration of its ultra-lightweight 

UAS is expressly contemplated by the Reform Act. 4-Verticals Aerial Imagery would seeks to 

operate ultra-lightweight UAS prior to the time period by which the Reform Act requires the FAA 

to promulgate rules governing such craft. Thereby, providing direct experience and valuable 

information for formal regulation that can be administered uniformly to all related UAS aerial 

video and photography. The Reform Act guides the Secretary in determining the types of UAS's 

that may operate safely in our national airspace system. Considerations include: The weight, 

size, speed and overall capabilities of the UAS's; Whether the UAS will be operated near 

airports or heavily populated areas; and, whether the UAS will be operated by line of sight. 112 

P.L. 95 § 333 (a). 
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Each of these items reflects in favor of an exemption for4-Verticals Aerial Imagery L.L.C.. Its

UAS’s utilize eight (8) or less rotating propellers for balance, control and stability. The UAS’s are 

equipped with the following via video and data telemetry:

1) Altimeter 

2) Attitude indicator 

3) Ground Speed indicator 

4) Magnetic compass 

5) Heading indicator 

6) Vertical speed indicator 

7) Course deviation indicator 

8) Radio magnetic indicator 

9) GPS location 

10) Battery consumption and Battery Left with approximate time. 

11) Loiter and circle mode. 

12) Auto safety or RTL (Return To Launch) 

13) Auto landing technology. 

Each UAS weighing less than thirty five (35) pounds (far below the maximum 55 pound limit); 

Including camera(s) with or without a gimbal (a camera stabilizer). 4-Verticals Aerial Imagery 

L.L.C., considers safety as foremost with each flight. Its small unmanned aircraft is designed to 

hover in place, circle in a specific place or loiter via GPS and can be operated in winds up to 

30.4 knots (35mph) wind. For safety, stability and fear of financial loss, 4-Verticals Aerial 

Imagery L.L.C. will not fly in winds exceeding 21.7 knots (25 mph). Built in safety systems 

include a GPS mode that allows the UAS to hover/circle in place or land when radio controls are 

released. 

With three (3) modes to choose from, the PIC (Pilot in Command) will fly with the modes safest 

to complete its necessary aerial videography/photography. The PIC also has the ability to 

choose the safest, most reliable, and stable mode to prevent accident and hazard. When pilot 

communication from the radio control is lost, our UAS are designed to slowly descend to the

point of takeoff and or to land at point of launch after ascending to a pre-set altitude to ensure 

the UAS will clear any obstacles that may be between the takeoff point and the current position 

of the UAS. This failsafe altitude will not be set more than 200ft and is determined before each 

flight. 

4-Verticals Aerial Imagery L.L.C., will not operate its UAS within 5 NM of airports/heliports, 

hospitals, police missions, and will not operate near areas that are densely populated. The PIC 

will constantly be on alert for any manned aircraft (police/medical helicopters, etc.) and will be

prepared to land/abort immediately to the nearest and safest ground point should a manned 

aircraft approach the flight location. 4-Verticals Aerial Imagery L.L.C. UAS’s are capable of 

vertical and horizontal operations, and are flown only within line of sight with the remote control 

pilot. 4-Verticals Aerial Imagery L.L.C. UAS's are also flown with a second operator who aids 
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in watching for any obstacles (visual observer), including manned aircraft, within the flight zone 

of the UAS. Utilizing battery power rather than combustible fuels, flights generally last between 

(10) ten to fifteen (15) minutes, with an altitude under one hundred fifty (150) feet. Smart Mode 

includes, position hold, self-leveling, altitude command, GPS, return home feature, and safety 

control to return home or land in the event of communication interruption between RC 

transmitter and UAS.

4-Verticals Aerial Imagery L.L.C., utilizes a fresh fully charged battery with each flight as a 

safety precaution; full flight time limit for each battery is eight (8) to thirty (30) minutes as tested. 

The PIC will not operate the UAS at or below manufacturer recommend minimum charge levels 

for operation; preferring to remain well within a safe operating range to insure adequate 

communication between radio control and UAS to eliminate potential for crash, loss of control,

or hazard. Reserve batteries are on hand with each exercise to insure replacement for sufficient 

safe level of operation. I do not believe in taking risk that may cause a crash that could create 

hazard to the public/property/manned aircraft, and have no desire to lose an investment. I have 

clocked numerous practice flights in remote areas as a hobbyist simulating flights for future 

commercial use to gain familiarization with the characteristics of this specific UAS's performance 

under different temperature and weather conditions. I also practice computerized simulated 

flights to maintain adequate skills and response reflex time. All for the sake of safety. 

4-Verticals Aerial Imagery L.L.C. is extremely cautious when operating its UAS/ultralightweight unmanned aircraft and will not “create a hazard to users of the national airspace 

system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of its UAS it falls 

well within Congress’s contemplated safety zone when it promulgated the Reform Act and the 

corresponding directive to integrate UAS's into the national airspace system. 4-Verticals Aerial 

Imagery L.L.C.’s UAS, used in hobby flight, has a demonstrable safety record and does not 

pose any threat to the general public or national security. 

IV. How 4-Verticals Aerial Imagery L.L.C.’s Request Will Benefit the Public as A Whole: 

Aerial videography for geographical awareness, education, mapping, land management, 

structure inspections, and for real estate marketing has been around for a long time through 

manned fixed wing aircraft and helicopters. For small budget companies, average homeowners 

and property owners the expense of such aerial videography is cost prohibitive. Only large 

companies and high end Realtors or luxury homeowners can afford to absorb such expense; 

depriving non-luxury owners and lower budget companies, such as myself a certified Realtor,

from a valuable marketing tool. Manned aircraft pose a threat to the public through potential 

catastrophic crashing which could result in the loss of property or in worst case scenario, life. 

4-Verticals Aerial Imagery L.L.C.’s, UAS poses no such threat since size and lack of 

combustible fuel alleviates any potential threat to the public. Congress has already proclaimed 

that it is in the public’s interest to integrate commercially flown UAS's into the national airspace 

system, hence the passing of the Reform Act. Granting 4-Verticals Aerial Imagery L.L.C.’s, 

exemption request furthers the public interest through academic/visual awareness of the 

geographical benefits in and around the metro Detroit area. My ultra-lightweight UAS is battery 
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powered and creates no emissions that can harm the environment. The consequence of my 

ultra light-weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; which 

are heavy, contain combustible fuel, and can cause catastrophic devastation to the public. The 

public’s interest is furthered by minimizing ecological and crash threats by permitting aerial 

video/photo capture through battery operated ultra-lightweight UAS's. Permitting 4-Verticals 

Aerial Imagery L.L.C., to immediately fly within national air space furthers economic growth. 

Granting this exemption request substantially furthers the economic impact for the metro Detroit 

area serving as a stimulus to the community. 

V. Reasons Why 4-Verticals Aerial Imagery L.L.C.’s Exemption Will Not Adversely Affect 

Safety or How the Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

4-Verticals Aerial Imagery L.L.C.’s, exemption will not adversely affect safety. Quite the 

contrary, for the reasons stated permitting 4-Verticals Aerial Imagery L.L.C. to log more flight 

time in FAA controlled airspace. Communication with the FAA, will allow me to contribute to the 

innovation and implementation of new, and as of yet, undiscovered safety protocols for 

Realtors, as well as, land and structure owners for development in cooperation with the FAA. In 

addition, 4-Verticals Aerial Imagery L.L.C., submits the following representations of 

enhancements to current aerial videography and photography: The UAS’s weigh less than 

seven (7) pounds complete with an integrated ultra-light weight camera.; The PIC only operates

the UAS below the 400 foot AGL ceiling set by the FAA Modernization and Reform Act of 2012; 

The UAS’s only operate for 3-30 minutes per flight; The PIC will land the UAS prior to

manufacturer recommended minimum level of battery power; The PIC will operate using a

remote control never losing line of sight; and have live video feed for a secondary pilot to 

monitor video recording; The PIC receives a live telemetry feed from the UAS during all flights 

which include remaining battery voltage, distance, altitude, and any anomalies that may occur 

during flight.

4-Verticals Aerial Imagery L.L.C. UAS’s Command and Control utilizes spread spectrum 

2.4Ghz-2.485Ghz frequencies in accordance with CFR 47, Part 15 for model aircraft use.

4-Verticals Aerial Imagery L.L.C. UAS’s camera system utilizes 5.725Ghz-5.875Ghz 

frequencies in accordance with CFR 47, Part 15.

4-Verticals Aerial Imagery L.L.C. UAS’s have a GPS controlled flight controller- a flight safety 

feature whereby it hovers or circles and then lands at the GPS takeoff point if communication 

with the remote control pilot is lost; The PIC will actively record and analyze flight data through 

the DJI Inspire 1 and DJI phantom 3 flight controller app to constantly update and enhance 

safety protocols; The PIC will only operate in reasonably safe environments that are strictly 

controlled, are away from power lines, elevated lights, airports, and actively populated areas; 

The PIC will conduct extensive preflight inspections and protocol, during which safety carries 

primary importance; The PIC will always obtain all necessary permissions prior to operation; 

and, have procedures in place to abort flights in the event of safety breaches or potential 

danger. 4-Verticals Aerial Imagery L.L.C.’s, safety protocols provide a level of safety equal to 

or exceeding existing rules. It is important to note that absent the integration of commercial UAS 

into our national airspace system, helicopters are the primary means of aerial video and 
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photography for community awareness, real estate, structured inspections, land management,

and mapping. While the safety record of such helicopters is remarkably astounding, there has 

been local incidents involving loss of life, as well as extensive property damage; it is far safer to 

operate a battery powered ultra-lightweight UAS. First, the potential loss of life is diminished 

because UAS's carry no people on board and the PIC only operates the UAS in specific areas 

away from mass populations. Second, there is no fuel on board a UAS and thus the potential for 

fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of the

UAS allow the PIC to remotely pilot away from and avoid hazards quickly and safely. Lastly, 

given its small size and weight, even when close enough to capture amazing images, the UAS 

need not be so close to the objects they are focused on. Through technology and use of post 

editing software, 4-Verticals Aerial Imagery L.L.C. can do post shoot pan and zooms to fit the 

wants/needs of customers. Accordingly, 4-Verticals Aerial Imagery L.L.C.’s UAS has been 

experimentally operated for familiarization/competency and will continue to operate at and 

above current safety levels. 

VI. A Summary the FAA May Publish in the Federal Register: 

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14 C.F.R. 21, 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary airworthiness certificates in relation to FAR §91.203(a)(1). The size, weight, and 

enclosed operational area of 4-Verticals Aerial Imagery L.L.C.’s, UAS permits exemption from 

Part 21 because its UAS meets (and exceeds) an equivalent level of safety pursuant to Section 

333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the 

Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness 

certificate requirement in consideration of the weight, size, speed, maneuverability and proximity 

to areas such as airports and dense populations. 4-Verticals Aerial Imagery L.L.C.’s, current 

and projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) 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 C.F.R. § 91.9 (b)(2) requires an aircraft flight manual in the aircraft. As there are no on board 

pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a safety/flight manual delineating 

areas of where safety can be defined. The FAA has previously issued exemptions to this 

regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 

10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor or controlled GPS “geofencing” 
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14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level 

of safety will be achieved by maintaining any such required certifications and registrations by 4-

Verticals Aerial Imagery L.L.C..

B. 14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation require 

aircraft to be marked according to certain specifications. My UAS can be marked with the 

appropriate “N” number once this “N” number has been given.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 

61.113 (a) & (b), private pilots are limited to non-commercial operations. 4-Verticals Aerial 

Imagery L.L.C., The sUAS Pilot in Command must possess at least a sport pilot certificate and 

a driver's license. The PIC must also meet the flight review requirements specified in 14 CFR § 

61.56 in which the PIC is rated on his/her pilot certificate.

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for 

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

conditions. My UAS will never operate at an altitude greater than 400 feet AGL. 4-Verticals 

Aerial Imagery L.L.C., will however operate its UAS in safe areas away from public and traffic, 

providing a level of safety at least equivalent to or safer than those in relation to minimum safe 

altitudes. Given the size, weight, maneuverability and speed of the UAS, an equivalent or higher 

level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.1,2,

Manual. The above-cited Regulations require, amongst other things, aircraft owners and 

operators to “have [the] 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. . . .”These Regulations only 

apply to aircraft with an airworthiness certificate. They will not, therefore, apply to 4-Verticals 

Aerial Imagery L.L.C. 's, UAS. However, as a safety precaution The PIC will inspect the UAS 

before and after each flight. 

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: 

Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled 

Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness 

certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of 

my UAS permits exemption from Part 21 because my, 4-Verticals Aerial Imagery L.L.C.’s, 

UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is 

authorized to exempt aircraft from the airworthiness certificate requirement under both the Act 

(49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the 

FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the 

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

populations. 4-Verticals Aerial Imagery L.L.C.’s UAS meets or exceeds each of the elements. 

14 C.F.R. 91.7(a) 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 
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inapplicable. 14 C.F.R. § 91.9 (b)(2) requires an aircraft flight manual in the aircraft. As there are 

no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a manual. The FAA has previously 

issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, maintenance program that involves regular software updates and curative 

measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

In summary, 4-Verticals Aerial Imagery L.L.C. seeks an exemption from the following 

Regulations:

14 C.F.R. 21, subpart H; 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); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 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) (2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. 

§§ 91.417 (a) & (b) to commercially operate my, 4-Verticals Aerial Imagery L.L.C. 's, small 

unmanned vehicle/lightweight unmanned aircraft vehicle for purposes mentioned earlier. 
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F. Additional FAA Required Operating Conditions and Limitations

When not covered elsewhere in this Operations Manual, the following conditions and 

limitations apply:

1. The UA must weigh less than 55 pounds (25kg), including energy source(s) 

and equipment

2. The UA may not be flown at a speed exceeding a ground speed of 85 knots.

3. Flights must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operator's manual. All 

altitudes reported to ATC must be in feet AGL.

4. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other 

than corrective lenses, as specified on the PIC's state driver’s license.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the 

VLOS requirement, as long as the PIC always maintains VLOS capability. The VO 

and PIC must be able to communicate verbally at all times.

6. If a discrepancy exists between these limitations and any procedure outlined elsewhere 

in this operations manual, the conditions and limitations herein take precedence and 

must be followed.

7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, 

the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground 

Control Station, if utilized, must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight in accordance with the operator's manual. The PIC who conducts 

the functional test flight must make an entry in the UAS aircraft records of the flight.

9. The operator must follow the manufacturer's UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance
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requirements must be established and identified in the operator's manual. At a minimum, 

the following must be included in the operator's manual:

a. Actuators / Servos

b. Transmission (single rotor)

c. Powerplant (motors)

d. Propellers

e. Electronic speed controller 

f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used)

j. Any other components as determined by the operator

10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a 

current state driver’s license. The PIC must also meet the flight review requirements 

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his/her pilot 

certificate.

11. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14

CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a UAS 

rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single 

blade or multirotor). Prior documented flight experience that was obtained in compliance 

with applicable regulations may satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under this grant of exemption to 

accomplish the required flight cycles and flight time. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are considered 

non-participants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

12. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14

CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS 

to be utilized for operations under the exemption and three take-offs and three landings in the 

preceding 90 days. Training, proficiency, experience-building, and take-off and landing 
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currency flights can be conducted under this grant of exemption to accomplish the required 

flight time and 90 day currency. During training, proficiency, experience-building, and take-off 

and landing currency flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAS with appropriate distance from non-participants 

in accordance with 14 CFR § 91.119.

13. Prior to any flight operations authorized by this grant of exemption, the PIC and visual 

observer (VO) must have successfully completed a qualification process, as outlined in

the operator’s manual. As this is a requirement stipulated by the operator, the test must be 

developed and implemented by a qualified person designated at the sole discretion of the 

operator. A record of completion of this qualification process must be documented and made 

available to the Administrator upon request.

14. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), a flight demonstration, administered by an operator-approved and -qualified pilot 

must be successfully completed and documented. This documentation must be available for 

review upon request by the Administrator. Because the knowledge and airmanship test 

qualifications have been developed by the operator, and there are no established practical 

test standards that support a jurisdictional FAA FSDO evaluation and approval of company 

designated examiners, the petitioner will conduct these tests in accordance with the operator’s 

manual.

15. The UAS may not be operated directly over any person, except authorized and consenting 

production personnel, below an altitude that is hazardous to persons or property on the surface 

in the event of a UAS failure or emergency.

16. Regarding distance from non-participating persons, the operator must ensure that no 

persons are allowed within 500 feet of the area except those consenting to be involved and 

necessary for the filming production. This provision may be reduced to no less than 200 feet 

if it would not adversely affect safety and the Administrator has approved it. For example, an 

equivalent level of safety may be determined by an aviation safety inspector’s evaluation of 

the filming production area to note terrain features, obstructions, buildings, safety barriers, 

etc. Such barriers may protect non-participating persons (observers, the public, news media, 

etc.) from debris in the event of an accident. This is also consistent with the same FAA Order 

8900.1, V3, C8, S1. 18. If the UAS loses communications or loses its GPS signal, the UA 
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must return to a pre-determined location within the security perimeter and land or be 

recovered in accordance with the operator’s manual.

17. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance 

with the operator’s manual.

18. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual.

19. Each UAS operation must be completed within 30 minutes flight time or with 25%

battery power remaining, whichever occurs first.

20. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this grant of

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation.

21. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

22. The operator must develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the UAS. These procedures must be 

added to the operator’s manual.

23. Each UAS operated under this exemption must comply with all manufacturer Safety

Bulletins.

24. The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual.

25. The preflight inspection section in the operator’s manual must be amended to include the 

following requirement: The preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in the relevant preflight 

inspection sections of the operator’s manual.

26. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.
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27. At least three days before scheduled filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction 

over the area of proposed filming. The 3-day notification may be waived with the 

concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights

b. Name and phone number of the person responsible for the UAS filming 

production under this grant of exemption

c. Name and phone number of the person responsible for the on-scene operation 

of the UAS.

d. Make, model and serial or N-number of the UAS to be used

e. Name and certificate number of the UAS PIC's involved in the filming 

production event 

f. A statement that the operator has obtained permission from property 

owners and/or local officials to conduct the filming production event; the 

list of those who gave permission must be made available to the 

inspector upon request.

g. Signature of exemption-holder or representative

h. A description of the flight activity, including maps or diagrams of any area, 

city, town, county, and/or state over which filming will be conducted and the 

altitudes essential to accomplish the operation

28. The documents required under 14 CFR § 91.9 and § 91.203 must be available to the PIC 

at the ground control station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request.

29. The UAS must remain clear and yield the right of way to all other manned operations 

and activities at all times (including, but not limited to, ultralight vehicles, parachute 

activities, parasailing activities, hang gliders, etc.).

30. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

31. The UAS cannot be operated by the PIC from any moving device or vehicle.

32. The UAS may 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.
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33. The UAS may not operate in Class B, C, or D airspace without written approval from the 

FAA. The UAS may not operate within 5 miles of the geographic center of a non-towered 

airport as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of agreement 

with the airport management must be made available to the Administrator upon request.

34. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the Federal Aviation Administration’s (FAA) UAS Integration Office (AFS-80) within 24 

hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations may 

not be conducted until the incident, accident, or transgression is reviewed by AFS-80 and 

authorization to resume operations is provided.

Currently, the aforementioned aerial videography/photography relies primarily on the use of 

larger aircraft running on combustible fuel. Posing potential risk to the public. Granting 4-

Verticals Aerial Imagery L.L.C.’s, request for exemption will reduce current risk levels and 

thereby enhance safety. My UAS craft do not contain potentially explosive fuel, is smaller, 

lighter and more maneuverable than conventional video and photographic aircraft with much 

less flight time. Further, our PIC operate at lower altitudes and in controlled airspace eliminating 

potential public risk flying to and from established airfields. 4-Verticals Aerial Imagery L.L.C., 

has been informally analyzing and recording flight information and will compile safety protocols 

and the implementation of a flight operations manual for usage that exceeds currently accepted 

means and methods for safe flight. Formal collection of information shared with the FAA will 

enhance the FAA's internal efforts to establish protocols for complying with the FAA 

Modernization and Reform Act of 2012. There are no personnel on board my, 4-Verticals 

Aerial Imagery L.L.C.’s, UAS and therefore the likelihood of death or serious bodily injury is 

significantly diminished. My, 4-Verticals Aerial Imagery L.L.C.’s, operation of my UAS, 

weighing less than forty (40) pounds and traveling at lower speeds within limited areas low to 

the ground will provide an equivalent level of safety as that achieved under current FARs. 

Accordingly, 4-Verticals Aerial Imagery L.L.C., respectfully requests that the FAA grant the

exemption requested. Furthermore, I am willing to cooperate in sharing information to benefit 

the FAA, safety of manned aircraft, and the general public at large. 
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Respectfully submitted, 

Chris Payton

4-Verticals Aerial Imagery L.L.C.

7456 Arrowood Drive

West Bloomfield, MI

48324
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Appendix A

List of Aircraft

No. Make and Model Description Serial No. Registration

No.

1 DJI Inspire 1 Electric powered, 4 rotor, small 

unmanned multirotor helicopter

Not yet 

Purchased

N/A

2 DJI Phantom 3 Electric powered, 4 rotor small 

unmanned multirotor helicopter

P76DCF3

0016757

Pending

1. DJI INSPIRE ONE

The operation of the DJI INSPIRE ONE system is as follows.

1. Build Materials

I. Plastic

II. Aluminum 

2. Motor Configuration

I. The DJI Inspire 1- flight is a 4 motor quadcopter setup. ,

3. Payload 

I. The DJI INSPIRE ONE flies it’s own light-weight integrated camera. 

II. Maximum All-up weight- 6lbs

4. Maintaining the DJI INSPIRE ONE

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 

5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as 

necessary. 

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. 

and/or chips. Replace if propeller is questionable. 
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4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check for updates to flight controller firmware. If available, install and 

perform a minimum of 15 test flights before conducting commercial work.

Appendix B 

2. DJI Phantom 3 

The operation of the DJI Phantom 3 system is as follows.

1. Build Materials

I. Plastic

II. Aluminum 

2. Motor Configuration

I. The Phantom 3 flight in a 4 motor quadcopter setup. ,

3. Payload

I. The Phantom 3 it’s own integrated camera. 

II. Maximum All-up Weight- 4lbs

4. Maintaining the Phantom 3

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 

5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as 

necessary. 

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. 

and/or chips. Replace if propeller is questionable. 

4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

5. Check for updates to flight controller firmware. If available, install and 

perform a minimum of 15 test flights before conducting commercial work.
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Appendix C

Personal Protocols/Controls/Flight Manual 

Protocols and Controls 

4 – Verticals Aerial Imagery, West Bloomfield, Mi.

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. As such, safety protocols and controls must be 

implemented through pre-flight preparation and during flight. Pre-Flight Protocol: 

Check batteries with voltage meter to insure fully charged and ready for use. 

Inspect batteries for damage or leakage that may affect proper operation. 

Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or 

unmanageable/uncontrolled flight. 

Check all GPS and Telemetry connections prior to flight. 

Check weather forecasts for wind advisory or other conditions that my impact flight. 

Consult Sky Vector aeronautical Charts (Skyvector.com) for airport vicinity and flight paths of 

possible air traffic.

Contact respective airport to advise of estimated flight time, estimated flight duration, estimated 

elevation of flight, and any other pertinent information. 

Inspect flight area for 

Vicinity of public safety helipads/heliports

Vicinity of medical helipads/heliports 

Vicinity of light poles vicinity or utility wires 

Vicinity of trees flocks of birds that may cause interference and potential flight impact 

Vicinity of any elevated obstructions that may pose potential flight hazard 

Vicinity of roadways with moderate to heavy traffic that can be distracted public 

Gatherings that may attract viewers optional point of control for best visual site of UAS 

while in flight 

Emergency landing areas 

Takeoff and landing 

Inspect area for best and safest point of takeoff and landing 

If in a subdivision or area that is within 150 feet of a residential street, post warning 

Sign(s)/stand(s) "Attention Aerial Photography In Progress  Remain Back 150 Feet” 
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Flight Protocol: takeoff and land from same location (have alternate landing areas in case of 

emergencies) remain alert to birds, sound or aircraft, curious public, and approaching vehicles 

do not allow anyone to engage in conversation or distract the remote control pilot restrict flight to 

minimal elevation sufficient to acquire desired results remained prepared for emergency landing 

at all times pay attention to flight time – warning meter for low voltage. 

Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and shut 

down propulsion immediately following landing – priority of disconnecting batteries 

Post flight: 

1. a) Disconnect battery to prevent accidental activation of propulsion system 

2. b) Secure UAS in a safe location 

c) Remove all warning signs from public access areas Emergency or Suspected Hazard: 

Immediate land UAS at safest and closet ground location in the event 

Manned aircraft is heard or seen in vicinity of flight 

There is a public gathering within established safety boundary wanting to observe flight 

Pilot is being distracted from focusing on flight and safety 

Sudden change in weather (wind bursts) 

Sudden increase in vehicular traffic in vicinity of flight 

Birds enter into proximity of flight 

Any sudden unsafe event that can cause collision, distraction or interruption of control 

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. 

Maintaining a record of safe flight for FAA request and for determining future UAS safety 

protocols is imperative. 

Date:____________________ 

Location:___________________________________________________ 

Pre-flight Inspection: 

o Yes o No 

Comment: _________________________________________________ 
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Elements 

Proximity to airport: _________________ (see attached map pinpointing approximate location 

of flight) 

Airport notified: No Yes 

Date:_______________ Time: ______________ 

Phone Number: _______________________ 

Contact Name:___________________________________ 

Nearest major intersection: 

______________________________________________________________ 

Proximity to medium traffic road: 

_________________________________________________________ 

Proximity to heavily traveled roadway road: 

_________________________________________________ 

Proximity to congested population: 

________________________________________________________ 

Approx. Takeoff Time: GMT: 

Weather Good Fair Poor Comment: 

Visibility Good Fair Poor Comment: 

Wind Speed ___mph ___Gusts/MPH ___avg/MPH Comment: 

Approx. Landing Time: GMT: Estimated Elevation Ground level: 

Safety Concerns: 

Additional Comments: 

Sea level: 
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Appendix 'D'

Aircraft Manuals

This Appendix includes UAS manufacturer's user manuals, maintenance instructions, and 

illustrated parts catalogs. These manuals can be found on dji.com and will be submitted with 

request. Information regarding design, aircraft performance, fail-safe features, operating 

limitations, normal and emergency procedures, and maintenance and inspection procedures 

is contained within the manuals as well as supplemental information documents.

For more information or questions about this manual please contact:

Chris Payton

4-Verticals Aerial Imagery L.L.C.

7456 Arrowood Dr.

West Bloomfield, MI

48324