Remote Imagery Solutions LLC

9304 Wyndham Hill Lane

Spotsylvania, VA 22551

Kris@RemoteImagerySolutions.com

(mobile) 202-679-6671

September 25, 2015

U.S. Department Of Transportation

Federal Aviation Administration 

800 Independence Ave SW 

Washington DC 20591 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012(the reform act) and CFR Part 11, Remote Imagery Solutions LLC, owner 

and operator of Small Unmanned Aircraft Systems (UASs), requests to be 

exempted from the Federal Aviation Regulations (FAR) listed below so that 

Remote Imagery Solutions LLC may operate UASs commercially in airspace 

regulated by the FAA., as 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. 

Remote Imagery Solutions LLC (an aerial photography and videography 

company) is owned by Kristoffer John Buquet, a Virginia resident, with a Virginia

Drivers license. Mr. Buquet is currently studying for his sport pilots license (SPL) 

and will be the PIC upon obtaining his SPL. All operations will be performed with 

the public’s safety and right to privacy safeguarded at all times.

As described below, the requested exception would permit the operation 

of light weight (less than 55 lbs. total takeoff weight) UASs under controlled 

conditions for commercial use by a certified private pilot thereby enhancing 

safety and fulfilling the Secretary of Transportation’s (the FAA Administrator’s) 

responsibility to” establish requirements for safe operation of such aircraft 

systems in national airspace systems.” Section 333(c), of the Reform Act. 

Remote Imagery Solutions LLC UAS (The 3DR SOLO quadcopter) is a

rotorcraft weighing less than 55 pounds including payload. It operates at a speed 

less than 50 knots and has the capability to hover and move in the vertical and 

horizontal plane simultaneously. It has an auto return to launch point when 

battery power is under 25%. The UAS will operate within the line of sight within a 
protected flight area as described below and at 200 feet AGL or less with an 

observer located close at hand as to make voice communication possible. These 

operations will not create a hazard to users of the nation airspace, public nor the 

environment. 

Remote Imagery Solutions LLC respectfully requests the grant of an 

exception to the following specific sections of the Title 14 Code of Federal 

regulations allowing it to operate lightweight UASs for commercial use, 

14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 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)&(b). 

Remote Imagery Solutions LLC submits this application in accordance 

with the Reform Act , 112 P.L. 95 331-334, seeking relief from any currently 

applicable FAR’S operating to prevent Remote Imagery Solutions LLC future 

commercial use of small UASs to operate in the national airspace system as 

described below. The reform Act section 332 provides for such integration of civil 

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

to do so. Remote Imagery Solutions LLC UAS meets the definition of “small 

unmanned aircraft” as defined in Section 331 and therefor the integration of this 

UAS is expressly contemplated by the Reform Act. Remote Imagery Solutions 

LLC would like to operate its lightweight UAS prior to the time period by which 

the Reform Act requires the FAA to promulgate rules governing such aircraft. 

The Reform Act directs the Secretary of Transportation to consider 

whether certain unmanned aircraft systems may operate safely in national 

airspace before completion of the rule making required under Section 332 of the 

reform Act. In making this determination, the Secretary of Transportation is 

required to determine which UASs do create a hazard to users of the national 

airspace system or the public or pose a threat to national security in light of the 

following: 

The UASs size, speed, weight and operational capability

Operation of the UASs in close proximity to airports and populated areas 

Operation of the UASs within visual line of sight of the operator.

Reform Act 333(a). If the secretary determines that such vehicles “may operate 

safely in National Airspace System, the secretary shall establish requirements for 

the safe operation in national airspace. 

Remote Imagery Solutions LLC rotorcraft weighs less than 55 lbs. and it

operates at speeds less than 50 knots and has the capability to operate in the 

vertical and horizontal plane simultaneously. The UAS will operate only within the 

line of sight of the operator within a protected flight area and at 200 feet AGL or 

less. These will not present a hazard to the national airspace nor the public. 
The very small nature of these UASs combined with the safe guards 

presented below, will allow for the safe operation greater than that envisioned by 

Congress for the FAA to establish and by exemption allow commercial 

operations of UASs to commence immediately. Also due to the size of UASs and 

the areas and altitudes they will operate approval of this exception presents no 

national security issues and absolutely minimal safety concerns which have been 

mitigated through our rigorous risk management process. Given the clear 

direction given in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the strong equivalent level of enhanced 

safety, reduced emissions utilizing UASs verses traditional aircraft as well as the 

economic impact of greatly reducing the cost of aerial photography thereby 

benefiting the greater public’s interest. Accordingly, the applicant requests that 

the FAA grant the requested exemption without delay. 

The following will be considered as the binding limitation on operations of 

Remote Imagery Solutions LLC, 

Flights will only occur in the daylight hours, 

Flights will be operated in the line of sight of the operator (PIC) and 

Observer,(VSO) 

Flights will be terminated at any time weather and wind deteriorate to “unsafe for 

flight” by manufacturers recommendations, 

The UAS will weigh less that 55 lbs., 

Flights will be operated at 200 feet AGL or less. 

Crew will be at a minimum of operator(PIC) and an observer and/or camera 

operator(VSO), 

Operator and crew will remain in contact during the flight operation, 

The UASs operator will perform a check of the flight area and make certain of the 

safety of all persons in the area, 

Consent will be obtained from all persons within the video capabilities of the units 

to further reduce the chance of violating anyone’s privacy. 

All required FAA clearances, will be obtained and distances from airports strictly 

observed. 

All UASs will have the capability to return automatically to the operator in a safe 

manner with the auto return function checked and working. 

Flights will only operate in VFR conditions. 

UASs have a function on the control to tell operator the distance away from the 

operator and its battery power remaining. 

Flight team will communicate by voice and the use of two-way radio if the area is 

too big to hear voice from all team members. 

UASs will be used to video for commercial consulting and sales.

When operating over or near water the UASs will be equipped with flotation 

devices so that recovery can be made as to prevent lithium battery exposure to 

the water table. 
14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 

91.203(a)(1) 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary certificates in relation to FAR 91.203(a)(1). The size, 

weight and defined area of operations for Remote Imagery Solutions LLC UAS

flights permits exception from Part 21 because it 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 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation 

permit the FAA to exempt UASs from airworthiness certificates in consideration 

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

and dense populations. Remote Imagery Solutions LLC

meets or exceeds each of these elements.

As of March 23, 2015 the FAA has stated that it will automatically grant a 

“blanket” COA for flights at or under 200 AGL to any UASs operator with a 

section 333 exemption. 

14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and 

registrations. These are inapplicable for the same reasons stated above. The 

equivalent level of safety will be achieved by maintaining such certifications and 

registrations at Remote Imagery Solutions LLC operations center. 

14CFR91.7 (a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by 

FAR’s this regulation is inapplicable. 14 CFR 91.9(b)(2) Civil Aircraft Flight 

Manual in Aircraft 

14 CFR 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 UASs this regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining such 

certifications and registrations at Remote Imagery Solutions LLC operations 

center. The FAA has previously issued exemptions to this regulation in 

Exemptions No’s 

8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700 and 

32827. 

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of 

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

conditions. Remote Imagery Solutions LLC will only operate its UAS at or below 

200AGL. They will be operated on a will defined AOR that has been carefully 

reviewed for hazards and minimizes the presence of any persons not essential 

for these operations. Flights will only be over private property that the owner has 

consented and all persons within this video area also give consent for this 

filming. Compared to flight operations of conventional and traditional aircraft or 

rotorcraft weighing far more than 50 lbs., operating below 500 AGL with 

flammable fuel UASs operations present a far smaller risk to the public. 
Approval of these 333 Exemptions allowing commercial operations of small 

UASs in the service of aerial photography will greatly enhance safety by reducing 

the overall risk associated with traditional aircraft. Traditional aerial photography 

requires large aircraft with flammable fuel to fly in close proximity of populated 

areas and people in general. With the use of small UASs of 55 lbs. or less, 

battery operated and fling below 200 feet AGL the risk of injury of people on the 

ground or the crew has been reduced or almost erased. 

Granting Remote Imagery Solutions LLC the above exemption will allow for the 

expansion of UAS systems into the future for the safe conduct of free enterprise 

and the enjoyment of the masses. 

Remote Imagery Solutions LLC respectfully requests the FAA grant its exception 

without delay. The FAA has the authority to issue the exemption sought by West 

Edge Collective, LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as 

amended (the ACT). 

Sincerely,

Kristoffer John Buquet

CEO & Manager

Remote Imagery Solutions LLC

9304 Wyndham Hill Lane

Spotsylvania VA 22551

Kris@RemoteImagerySolutions.com

(mobile) 202-679-6671