PEACHTREE 

AERIAL PHOTOGRAPHY 

607 Blackburn Lane 

Peachtree City, Georgia 30269 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., Washington, DC 20590 

Greetings, 

Enclosed is my Petition for Exemption 14 CFR § 11.81. Please let me know ifl can assist in 

anyway throughout this process. 

Sincerely yours, 

Matt 

/'~~"----~" Miller 

Owner, Peachtree Aerial Photography 

(612) 251-6510 

matt@pt-aerial.com 
Peachtree Aerial Photography 

c/o Matthew James Miller 

607 Blackburn LN 

Peachtree City, GA 30269 

(612) 251-6510 

matt@pt-aerial. com 

Summary 

I, Matthew James Miller, sole owner and sole Pilot In Command of 

Peachtree Aerial Photography LLC, seek the following exemptions from 

14 CFR § 11.81: 

• 14 CFR part 21, Subpart H (Airworthiness Certificates) 

• § 91.203 (a) and (b) (Certifications required) 

• § 45.23 (Marking of the aircraft) 

• §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) 

(Maintenance inspections) 

• § 61. 113 (Private Pilot Privileges and Limitations: Pilot in command) 

Petition for Exemption 14 CFR § 11.81 

Matthew James Miller, sole owner and sole Pilot In Command of Peachtree 

Aerial Photography, LLC (PETITIONER) plans to operate a UAS, the 

PHANTOM 3 Advanced, which is comprised of an unmanned aircraft (UA 

or PHANTOM) and a transportable ground station. 

The PHANTOM is referred to as a quad-copter with a maximum gross 

weight of about 2. 82 pounds. It is equipped with four rotors that are driven 

by electric motors powered by batteries. The UA has a maximum airspeed 

of 30 k17ots. Petitioner plans to operate the UA over various areas near 

Peachtree City, Georgia to enhance academic community awareness and 

augment real estate listing videos. 
PETITIONER is making the following representations of operational 

enhancements which he proposes to abide by to ensure this exemption will 

provide a level of safety at least equal to existing rules: 

• He wi/1 only operate in reasonably safe environments that are strictly 

controlled, are away from power lines, elevated lights, airports and 

actively populated areas; and 

• He wi/1 conduct extensive preflight inspections and protocols, during 

which safety carries primary importance. 

The PETITIONER states that given the size, weight, speed, and limited 

operating area associated with the aircraft to be utilized by him, an 

exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and 

§ 91.203 (a) and (b) (Certifications required), subject to certain conditions 

and limitations, is warranted and meets the requirements for an 

equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 

112-95 (Section 333). 

PETITIONER requests an exemption from § 45.23 Marking of the aircraft 

because his UA will not have a cabin, cockpit or pilot station on which to 

mark certain words or phrases. Further, he states that two-inch lettering is 

difficult to place on such a small aircraft with dimensions smaller than the 

minima/lettering requirement. 

The PETITIONER states that an exemption from§§ 91.405(a), 91.407(a) 

(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections may be 

required and should be granted since they only apply to aircraft with an 

airworthiness certificate. However, the petitioner states as a safety 

precaution he will perform a preflight inspection of his UAS before each 

flight as outlined in his operating documents. 

The PETITIONER asserts that under§ 61.113 (a) and (b) private pilots are 

limited to non commercial operations, however he can achieve an 

equivalent level of safety as achieved by current regulations because his 

UAS does not carry any pilots or passengers. Further, he states that, while 

helpful, a pilot license will not ensure remote control piloting skills. 

He further indicates that the risks of operating a UAS are far less than the 

risk levels inherent in the commercial activities outlined in 14 CFR part 61, 
et seq., thus he requests an exemption from§ 61.113 Private Pilot 

Privileges and Limitations: Pilot in command. 

Regarding UAS operational training, the PETITIONER states he has flown 

over 200 hours of practice flights in remote areas as a hobbyist simulating 

flights for future commercial use to gain familiarization with the 

characteristics of his UAS' performance under different temperature and 

weather conditions. He further states that he practices computerized 

simulated flights to maintain adequate skills and response reflex time. 

In a supplemental request to the FAA, the petitioner requests consideration 

of a 120 day temporary airman certificate in accordance with § 63. 13, to 

allow him time to obtain a private pilot certificate or to allow the FAA time to 

establish minimum UAS airman certification standards. 

I hereby verify that all information on this exemption request is true and 

correct. 

Matthew Jam s Miller, sole owner and sole Pilot In 

Command, Peachtree Aerial Photography LLC 

' I t1 jl ojJ.O/S 

Date