January 27, 2016 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Re: Petition for Exemption under Section 333 of the FM Modernization and Reform 

Act and other certain FARs to operate Unmanned Aircraft Systems (UAS) 

Dear Sir or Madam; 

Pursuant to Section 333 of the FAA Modernization and Reform Act ("FMRA") and 14 

C.F.R. Part 11, Leading Edge Imagery, Inc. hereby petitions the Federal Aviation 

Administration for exemption from the following regulations in order to safely and 

legally operate UAS's for aerial data collection, aerial videography and photography: 

• 14 C.F.R. Part 21 

• 14 C.F.R 61.23 (a) and (c) 

• 14 C.F.R.61.113 (a) and (b) 

• 14 C.F.R. 91.7 (a) 

• 14 C.F.R. 91.9 (b)(2) 

• 14 C.F.R. 91.119(c) 

• 14 C.F.R. 91.121 

• 14 C.F.R. 91.151(a) 

• 14 C.F.R. 91.203 (a) & (b) 

• 14 C.F.R. 91.405 (a) 

• 14 C.F.R. 91.407 (a)(1) 

• 14 C.F.R. 91.409 (a)(1) &(2) 

• 14 C.F.R. 91.417 (a) & (b) 
I. Proposed UAS's 

Leading Edge Imagery, Inc. requests an exemption to operate the DJI Inspire 1 and 

DJI Phantom 3 models. These UAS's are well below 55 pounds, including payload 

and will be operated below 400 feet. They are electrically powered by lithium ion 

batteries, carry no combustible fuel or crew and will always be transported via 

proper storage to and from all flight zones. 

As evidenced by recent Exemption numbers, the FAA recently approved similar use 

of the DJI Phantom 3 and DJI Inspire 1. These particular UAS's have been proven 

reliable and safe flying machines managed by gyroscopically-stabilized flight, 

ground detection, GPS aided navigation, a built in compass, blinking LED navigation 

lights, a manual and automatic failsafe "Return to Home" feature, and propeller 

guards to protect the UAS and environment. DJI also has built in a "No Fly Zone" 

feature for major cities and airspace such as active airports. As a result the UAS will 

not start up if in these areas and will stop before entering such airspace. These 

models are widely utilized for similar operations and when flown responsibly and 

with proper aviation knowledge, they ensure safe operations and limited, easy 

maintenance. 

II. Proposed Operations and Applications 

The granting of exemption for commercial operations would allow the petitioner to 

operate the proposed UAS's for aerial data collection, videography and photography. 

As a new company, owned and operated by an ATP MEII, SEll pilot we would like to 

offer our services to the public and businesses that require aerial photographs and 

for video including but not limited to: real-estates, production companies, ground 

based photographers, not for profit organizations, media stations, local 

municipalities. 

In addition it is our goal to offer land surveying and mapping, forest monitoring and 

management, wetland monitoring and management, topography charting, 

environmental assessments, visual monitoring of equipment and developing areas, 

thermal mapping and, aid in search and rescue operations. 

The petitioner believes that the use ofUAS's is more economical, safer and 

environmentally friendly for the proposed operations. As a company that is 

operated by a licensed pilot, it is our intent to have licensed pilots at the control of 

the UAS's for commercial use while utilizing a visual observer (V.O.) for all flights. 

Having an extensive aviation background will aid in good decision-making and 

utilization of basic aviation practices such as but not limited to: 

• Preflight checklists 

• Post flight checklists 
• Preflight planning 

• Aircraft inspection and maintenance 

• VFR weather minimums observances 

• TFR and No Fly Zone awareness 

• Airspace awareness 

• Right of way rules 

• Pilot IMSAFE checklists 

• Flying "neighborly". 

III. Request for Exemption, Section 333 of the FAA Reform Act: 

Specific section( s) of 14 CFR, which the petitioner seeks relief as well as any 

additional regulations that may apply to operations ofUAS's and the FAA, seems fit 

to grant. 

14 C.F.R Part 21: Airworthiness Certificates 

Due to the size and limited operating area associated with the UAS's to be utilized, 

an exemption from Part 21 meets the requirements of an equivalent level of safety 

under Part 11 and Section 333 of the Reform Act. It has been determined by other 

exemption numbers that similar UAS's do not require an airworthiness certificate. 

14 C.F.R. 61.23 (a) and (c): Medical Certificates 

Due to the nature of commercial operations ofUAS's it is viewed to be acceptable to 

hold a pilot certificate and second or third class medical certificate. Considering the 

operation will not be carrying passengers, keeping a current license and third class 

medical certificate should complete the requirement. 

14 C.F.R. 61.113 (a) and (b): Private Pilot Privileges 

The petitioner feels it's pertinent to hold a pilots license to operate UAS's for 

compensation or hire. However the commercial operations for this company would 

not require the need of a commercial pilot certificate due to the scope of flight 

operations. Holding a current pilot certificate and medical would be sufficient for 

P.I.C. of our UAS's. 

14 C.F.R. 91.7 (a): Civil Aircraft Airworthiness: 

The UAS's for proposed use currently to not require or have an airworthiness 

certificate. It will be up to the P.I.C. to determine its airworthiness before each flight 

by referring to the operation/company manual and performing a visual inspection. 

The proposed UAS's also have a ('Safe to Fly" message when fully operational. 

14 C.F.R. 91.9 (b)(2): Civil Aircraft Flight Manual. Marking. and Placards 

Considering the UAS's proposed and the obvious absence of space for a flight 

manual or placards this regulation is inapplicable. The petitioner will have an 

accessible flight manual for each operation at the point where the P.I.C is located. 
14 C.F.R. 91.119(c): Minimum Safe Altitudes 

The proposed UAS's will not be flown over 400 feet AGL. It is the petitioner's intent 

to limit proximity to people and congested areas. In all cases local authorities and 

property owners will be notified of the flight plan and associated altitudes. Using a 

dedicated V.O. and keeping the UAS's in line of sight will lessen any possible 

interference or safety issues. 

14 C.F.R. 91.121: Altimeter Settings 

The proposed UAS's utilize the latest GPS/GLONASS technologies as well as a 

barometric sensor with live data output. The petitioner will be able to have 

immediate altitude data on the tablet device connected to the transmitter. 

14 C.F.R. 91.151(a): Fuel Requirements for fligh,t in VFR Conditions 

The proposed UAS's are battery operated and have a battery life of less than 23 

minutes. While the petitioner cannot comply with the regulation, the UAS's have a 

countdown feature clearly showing remaining flight time/battery life. They also are 

equipped with a "Return to Home" and landing mode that will activate when the 

aircraft senses that it has only enough battery life to make it to the Home point. The 

P.I.C. will be conscious of surroundings and battery life in order to execute a safe 

and unobstructed landing before loss of power. 

14 C.F.R. 91.203 (a) & (b): Civil Aircraft Certification Required 

There are currently no airworthiness certificates for the proposed UAS's. The P.I.C. 

will carry any pertinent documentation with her /him to be contained at a home 

point where the pilot is based and flying the aircraft. 

14 C.F.R. 91.405 (a): Maintenance Required 

The petitioner will carry out pre and post flight inspections on all UAS's. Each UAS's 

manufacturer recommendations and operating documents will be reviewed and 

taken into account. Any actual maintenance or inspections will be documented and 

kept in a separate maintenance log. 

14 C.F.R. 91.407 (a)(1): Operation after Maintenance 

Any maintenance or manufacturer replacement parts installed by the P.I.C. will be 

notated in the maintenance log. If the UAS is sent back to the manufacturer for 

maintenance, upon return, the invoice and date of "return to service" will be notated 

in the maintenance log by the P.I.C. 

14 C.F.R. 91.409 (a)(1) &(2): Inspections 

There is currently no guidance for UAS's annual inspection. The petitioner will 

accomplish an annual check of components and parts of each UAS and the P.I.C. will 

make a log entry. And firmware or service updates from the manufacturer will be 

also complied with and entered into the maintenance log by the P.I.C. 
14 C.F.R. 91.417 (a) & (b): Maintenance Records 

The petitioner will keep a record of all repairs and modifications completed by the 

operator or manufacturer. Date, time, maintenance performed and name will all be 

recorded. 

IV. Applicant Information 

Wendy E. Reynolds 

Chief Pilot/Owner 

Leading Edge Imagery, Inc. 

612 North Sea Mecox Rd. 

Southampton, NY 11968 

Mailing Address: 

Leading Edge Imagery, Inc. 

Attn: Wendy E. Reynolds 

P.O. Box 343 

Watermill, NY 11976 

Wendy@LeadingEdgeUAV.com 

V.Summary 

Leading Edge Imagery, Inc. is seeking exemption from the aforementioned F ARs. 

With the exemptions of the mentioned rules, Leading Edge Imagery, Inc. will be able 

to operate safely and efficiently in accordance with pertinent FARs and local 

restrictions. UAS's offer an affordable and environmentally friendly option to many 

businesses and private individuals looking for aerial data. 

Being that the operation is operated by an ATP licensed pilot, with commercial 

operation experience, the petitioner hopes for timely consideration and an 

expedient response. 

Please do not hesitate to contact us with any further questions about our proposed 

operations. Thank you for your consideration. 

Sincerely, 

\0r_~~· 

Wendy~. ~y~olds Leading Edge Imagery, Inc. 

Wendy@LeadingEdgeUAV.com 

631.334.3510 mobile