IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

IMAGERHEE, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151(a)

91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)

Submitted on 07/28/2015

By:

Mary Anne Baker

ImageRhee LLC

354 Ivy Ridge Circle

Sylva, North Carolina 28779

(828) 226-4492
PETITION FOR RELIEF OF REQUIREMENTN OF TITLE 14 OF THE CODE

OF FEDERAL REGULATIONS, SPECIFICALLY AS AUTHORIZED UNDER

THE F.A.A. MODERNIZATION AND REFORM ACT OF 2012, SECTION 333;

SPECIAL RULES FOR CERTAIN UNMANNED AIRCRAFT SYSTEMS.

Mary Anne Baker as ImageRhee LLC

ImageRhee, LLC seeks exemptions from Title 14 of the Code of Federal Regulations: 61.113 (a) and (b); 

91.7 (a); 91.119; 91.121; 91.151.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and 

(b), in order to operate a DJI Phantom 2 Quadcopter and a 3DR - Solo Drone UAS. This exemption will 

allow ImageRhee LLC to operate an unmanned aerial vehicle commercially for the purposes of 

conducting aerial video and still photography in the Tourism, Real Estate, and Hospitality markets of 

North Carolina, Georgia, and Tennessee. These still images and videos will provide both commercial and 

community awareness and understanding of aerial imaging systems.

ImageRhee, LLC is a Tourism, Real Estate, and Hospitality photography company producing high quality 

results for clients who want to display images and video for tourism promotion, real estate promotion, 

and hospitality promotion in the Western North Carolina, Northeast Georgia, and East Tennessee

markets. 

ImageRhee, LLC will be using a DJI Phantom 2 Quadcopter and a 3DR - Solo Drone quad copter to 

commercially capture video stills and film while working on private and public properties for the 

purpose of aerial location services. ImageRhee, LLC will employ both an experienced pilot and utilize a 

visual observer to maintain a visual line-of-sight between the quad copter and the pilot UAV operator.

THE DJI PHANTOM 2 QUADCOPTER 

The DJI Phantom 2 Quadcopter is an electric powered quad copter weighing less than three pounds and 

is operated via a handheld remote that features “Return to Home” and “Follow Me” commands. The 

Return to Home feature can be triggered manually and the UAV unit works off of a 2.4 GHz downlink for 

remote control. The video function works on 5.8 GHz frequency video. The default altitude setting for 

the DJI Phantom 2 Quadcopter is 400 feet AGL. The camera system is a Hero 3 and is operated from the 

handheld remote control. Both units are powered by a single battery giving the DJI Phantom 2 

Quadcopter approximately 25 minutes of flight time.

3DR - SOLO DRONE QUADCOPTER

The 3DR – Solo Drone Quadcopter is an electric powered quad copter weighing less than three pounds

and is operated via a handheld remote that features “Return to Home” and “Follow Me” commands. 

The Return to Home feature can be triggered manually and the UAV unit works off of a 2.4 GHz 

downlink for remote control. The video function works on 5.8 GHz frequency video. The default altitude 

setting for the 3DR – Solo Drone Quadcopter is 400 feet AGL. The camera system is a Hero 4 and is 

operated from the handheld remote control. Both units are powered by a single battery giving the 3DR –

Solo Drone Quadcopter approximately 25 minutes of flight time.
BASIS FOR PETITION

ImageRhee, LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. SS 11.61) and 

the F.A.A. Modernization and Reformed Act of 2012, Section 333, Special Rules for Certain Unmanned 

Aircraft Systems, hereby petitions the Administrator to operate the DJI Phantom 2 Quadcopter and the 

3DR - Solo Drone Quadcopter within the National Airspace System, and for an exemption from the 

requirements of 14 CFR SS 61.113 (a) and (b), 91.7 (a), 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a) 

(1), 91.409 (a) (1) and (2), 91.417 (a) and (b).

NAME AND ADDRESS OF THE PETITIONER

Mary Anne Baker

354 Ivy Ridge Circle

Sylva, NC 28779

828-226-4492

IMAGERHEE, LLC Requests Relief from the Following Sections of 14 C.F.R.

• Sections 61.113, entitled Private pilot privileges and limitations: Pilot in Command, Subsections (a) and 

(b).

• Section 91.7, entitled Civil airworthiness subsection (a).

• Section 91.119 entitled Minimum Safe Altitudes, General.

• Section 91.121, entitled Altimeter Settings.

• Section 91.151 entitled Fuel requirements for flight in VFR conditions.

• Section 91.405, entitled Maintenance required.

• Section 91.407 (a) (1), entitled Operation after maintenance, preventative maintenance, rebuilding, or 

alteration.

• Section 91.409 entitled Inspections.

• Section 91 the .417 entitled Maintenance Records.

Extent of relief that ImageRhee, LLC seeks regarding section 61.113 (a) and (b) Private pilot privileges 

and limitations: Pilot in Command, Subsections (a) and (b) prescribed the following, in part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that 

is carrying passengers or property for compensation or hire; nor may that person, for compensation or

hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if –

(1) The flight is only incidental to that business or employment and

(2) The aircraft does not carry passengers or property for compensation or hire.
Relief from section 61.113 (a) and (b) is requested to allow a PIC holding a current private pilot’s 

certificate to operate the DJI Phantom 2 Quadcopter aor the 3DR - Solo Drone Quadcopter. The flight 

would be complemented by a visual observer who will, along with the pilot, maintain visual line of sight 

with the DJI Phantom 2 Quadcopter or the 3DR - Solo Drone Quadcopter at all times. All operations will 

be conducted as per ImageRhee LLC’s business related operations. The DJI Phantom 2 Quadcopter and 

the 3DR - Solo Drone Quadcopter are not able to carry passengers.

Extent of relief that ImageRhee, LLC seeks in regards to section 91.7(a), Civil Airworthiness; Relief from 

section 91.7(a), is requested to allow ImageRhee LLC to determine the air-worthiness of the DJI 

Phantom 2 Quadcopter and the 3DR - Solo Drone Quadcopter.

Extent of relief that ImageRhee, LLC seeks in regards to section 91.119, Minimum Safe Altitudes; 

General. Relief from 91.119 is requested to allow operations of the DJI Phantom 2 Quadcopter or the 

3DR - Solo Drone Quadcopter at altitudes not to exceed 400 feet AGL, over private property or at a 

distance at or greater than five nautical miles from the nearest airport as depicted on current 

aeronautical charts.

ImageRhee, LLC also wishes to be granted exemptions to operate at an altitude not more than 50 feet 

AGL or below tree level between one and five nautical miles from the nearest airport as depicted on 

current aeronautical charts.

Extent of relief that ImageRhee, LLC seeks from 91.121, (a), Altimeter Settings. 

Extent of relief from 91.121 is requested because the DJI Phantom 2 Quadcopter and the 3DR - Solo 

Drone Quadcopter utilize an Electronic GPS with a barometric sensor.

Extent of relief that ImageRhee, LLC seeks in regard to section 91.151(a), Fuel Requirements for Flight in 

VFR Conditions.

Relief from 91.151(b), is requested to the extent that ImageRhee LLC to operate the DJI Phantom 2 

Quadcopter or the 3DR - Solo Drone Quadcopter up to a point that there is enough power to fly at 

normal cruising speed to the landing point and land the vehicle with 25% battery power remaining. 

Note: a low battery alarm on the operating consoles for the DJI Phantom 2 Quadcopter and the 3DR -

Solo Drone Quadcopter are equipped with a shaker mechanism to warn the pilot of a low battery

condition.

Extent of relief that ImageRhee, LLC seeks in regards to sections 91.405(a), 91.407(a)(1), 91 .409 

point(a)(1) and (a)(2), 91.4179 1.417 (a) and (b). These are all associated with an airworthiness 

certificate. There are currently no airworthiness certificates for small UAVs.

BENEFITS GAINED VIA RELIEF FOR ImageRhee LLC from the above stated Federal Regulations:

A. Use of the small UAV will allow for quicker and timelier aerial video and aerial photography of 

properties as contracted for.

B. Use of the small UAV will allow for more cost effective aerial video and aerial photography as the cost 

to operate a small UAV is fractional compared to the cost of operating a full size aircraft for aerial 

photography.
C. Use of the small UAV will lessen the use of full size aircraft for some aerial photography missions and 

therefore give a somewhat greater safety ratio for the use of aerial photography.

REASONS WHY SAFETY WILL NOT BE AFFECTED BY GRANTING THESE REQUESTED EXEMPTIONS:

• Standard operating procedures prior to launch will include a preflight checklist of the vehicle and a 

visual inspection of area to be surveyed at ground level will be performed.

• Flight operations will be conducted by a two man crew consisting of the PIC and the Visual Observer. 

All operations will be conducted with a clear line of sight between the UAV and the team.

• ImageRhee, LLC will only operate the UAV over private or public property with the permission of the 

property owner or the governing body and will maintain a safe distance from any structures, people or 

vehicles.

This petition is being made pursuant to the FAA Modernization and Reform Act of 2012, Section 333, 

which directs the Secretary of Transportation to determine if any UAS may safely operate in the National 

Airspace. ImageRhee, LLC will operate all aircraft granted for use by the exemption as directed by the

operating manual provided with the DJI Phantom 2 Quadcopter and the 3DR - Solo Drone Quadcopter 

by the manufacturers.

IN CONCLUSION

As set forth previously ImageRhee, LLC seeks an exemption pursuant to 14 CFR: 11.61 and Section 333 of 

the FAA Modernization and Reform Act of 2012, which will permit safe operation of DJI Phantom 2 

Quadcopter and the 3DR - Solo Drone Quadcopter UAS commercially within the tourism, real estate and 

hospitality markets. The Administrator will be assisting small business and local tourism organizations by 

granting this petition.

In accordance with the FAA Modernization and Reform Act of 2012, ImageRhee LLC respectfully

requests that the FAA Administrator grants this petition for exemption from TITLE 14 OF THE CODE OF 

FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a);

91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)

Respectfully submitted by ImageRhee, LLC.