.. 

October 26, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 3 3 3 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 C.P.R. 45.23(b);14 CFR Part 21;14 CFR 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); 1.409 (a) 

(2);91.417 (a) & (b). 

PETITION FOR SUMMARY EXEMPTION 

Summary Grant exemptions include 11822, 12339 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the Reform Act) 

and 14 C.P.R. Part 11, G2 Aerial, Inc. operator of Small Unmanned Aircraft Systems ("sUASs") 

equipped to offer commercial UAS operations for closed set/scripted filming and aerial data collection in 

the following applications: 

• Filmmaking, Cinematography, and Videography 

• Precision Agriculture 

• Wildlife and Forestry Monitoring 

• Aerial Surveying 

• Inspection, Patrolling, and Monitoring 

• Security and Surveillance 

G2 Aerial, Inc. hereby applies for an exemption from the listed Federal Aviation Regulations 

("F ARs") 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 3 3 3. 

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) 

predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe 

operations using conventional aircraft. Approval of this exemption would thereby enhance safety and 

fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to " ... establish 

requirements for the safe operation of such aircraft systems in the national airspace system." Section 

333(c) of the Reform Act. 

The name and address of the petitioner is: 

G2 Aerial, Inc. 

Attn: Gary Kaplan 

3529 Cay Drive 

Carlsbad, Ca. 92010 

Ph: 858-353-5322 

Email: Sales@G2Aerial.com 

Page 1 of9 
Regulations from which the exemption is requested: 

14 CFRPart21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.F.R. 91.103 

14 C.F.R. 91.109 

14 C.F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 

333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider 

whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) 

before completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types ofUASs do not create a hazard to users 

ofthe NAS or the public or pose a threat to national security in light of the following: 

• The UAS's size, weight, speed, and operational capability 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation ofthe UAS within visual line of sight ofthe operator. 

Reform Act§ 333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely 

in the national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system." /d§333(c) 

Applicant interprets this provision to place the duty on the Administrator to not only process 

applications for exemptions under section 333, but for the Administrator to craft conditions for the safe 

operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the 

statutory requirements for approval. 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40 l 01 of 

the Act that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness 

certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) ofthis section or any sections 44702-44716 of this title if the Administrator 

finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC 

§44704; 14 CFR §91.203 (a) (1). 

G2 Aerial, Inc. sUASs are rotorcraft, weighting 55 or fewer lbs. including payload. They operate, 

under normal conditions at a speed of no more than 87 knots and have the capability to hover, and move 

in the vertical and horizontal plane simultaneously. They will operate only in line of sight and will 

operate only within a sterile area described in the Motion Picture and Television Operations Manual 

(MPTOM) that will be submitted confidentially. Such operations will ensure that the sUAS will "not 

create a hazard to users of the national airspace system or the public." 

Page 2 of9 
G2 Aerial, Inc. intends to operate the following sUASs: 

Manufacturer 

DJI 

Align 

Align 

DZY'NE Technologies, Inc. 

Model 

SlOOO 

690L Hexacopter 

800 Trekker 

Atlas-8 

Max Gross Weight 

21 pounds 

11.5 pounds 

26 pounds 

54 pounds. 

The sUAS that will be operated by G2 Aerial, Inc. will be registered in accordance with 49 U.S.C. 

44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R Part 45, Identification and Registration Marking. 

Reform Act Section 333 (b). 

Given the small size of the sUASs involved and the restricted sterile environment within which 

they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in 

which Congress envisioned that the FAA must, by exemption, allow commercial operations ofUASs to 

commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant 

sUASs will operate, approval of the application presents no national security issue. Given the clear 

direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding the proposed operations, and the significant 

public benefit, including enhanced safety, reduction in environmental impacts, including reduced 

emissions associated with allowing UASs, the grant of the requested exemptions is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without 

delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least an 

equivalent or even higher level of safety to operations under the current regulatory structure because the 

proposed operations represent a safety enhancement to the already safe operations conducted with 

conventional aircraft. 

These limitations and conditions to which G2 Aerial, Inc. agrees to be bound when conducting 

commercial operations under an FAA issued exemption include: 

1. The sUAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 45 minutes. Flights will be terminated at 

25% battery power reserve should that occur prior to the 45 minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above 

an elevated platform from which filming is planned. 

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer, and/or the 

Camera Operator. 

6. sUAS pilot will be an FAA licensed airman with at least a sport pilot certificate and a valid US 

Driver's License. 

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, who 

possess the necessary PIC qualifications, is also present (i.e. the Visual Observer), that person can also be 

designated as the PIC. 

8. The UAS will only operate within a confined "Sterile Area" ofthe flight operations area. 

Page 3 of9 
9. A briefing will be conducted in regard to the planned sUAS operations prior to each day's activities. It 

will be mandatory that all personnel who will be performing duties within the boundaries of the safety 

perimeter be present for this briefing. 

10. The operator will obtain the consent of all persons involved and ensure that only consenting persons 

will be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based 

upon an equivalent level of safety determination. 

11. Pilot and observer will have been trained in operation ofUAS generally and received up-to-date 

information on the particular UAS to be operated. 

12. Observer and pilot will at all times are able to communicate by voice and/or text. 

13. Written and/or oral permission from the relevant property holders will be obtained. 

14. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

15. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a 

pre-determined location within the Security Perimeter and land. 

16. The sUAS will have the capability to abort a flight in case ofunpredicted obstacles or emergencies. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited 

operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 

Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the 

Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and populated 

areas of the particular UAS.In all cases, an analysis of these criteria demonstrates that the UAS operated 

without an airworthiness certificate, in the restricted environment and under the conditions proposed will 

be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. The sUAS to be operated 

hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive 

materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the 

Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by both the operator, pursuant to the Manual's requirements, and under the requirements and in 

compliance with local public safety requirements, to provide security for the area of operation as is now 

done with conventional filming. The FAA will have advance notice of all operations. These safety 

enhancements, which already apply to civil aircraft operated in connection with motion picture and 

television production, provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart 

H. Lastly, application of these same criteria demonstrates that there is no credible threat to national 

security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and inability to carry a substantial external load. The FAA has issued 

the following exemption to this regulations Exemptions Nos. 11251. 

Page 4 of9 
14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in 

letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," 

"experimental," or "provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the 

UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be 

placed. Given the size of the sUAS, two-inch lettering will be impossible. The word "Experimental" will 

be placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the sUAS will see the 

identification of the UAS as "Experimental." The FAA has issued the following exemptions to this 

regulation to Exemptions, but not limited to, Nos. 10700, 8738, 10167 and 10167A, 11256, 11251. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of 

current operations by requiring the PIC operating the aircraft to have a private pilot's license rather than a 

commercial pilot's license to operate this small UAS. Unlike a conventional aircraft that carries the pilot 

and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance. The level of safety 

provided by the requirements included in the Manual exceeds that provided by a single individual holding 

a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation 

of the sUAS are so diminished from the level of risk associated with commercial operations contemplated 

by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PIC 

exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b). 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be 

granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the 

aircraft and the requirements contained in the Manual for maintenance and use of safety check lists prior 

to each flight, as set forth in Sections J, Land Q, an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. 

Page 5 of9 
The sUAS, given its size and configuration has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to 

carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the 

following exemptions to this regulation, but not limited to: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A,9565,9565B, 10167, 10167A, 10602,32827,10700, 11251,and11256. 

14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an 

exemption will be needed. The PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight instruction: 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. 

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with the aircraft via 

radio communications. The FAA has approved exemptions for flight training without fully functional 

dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption 

Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor 

passengers will be carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption 

is for a sUAS that is a helicopter or multirotor and the exemption requests authority to operate at altitudes 

up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an 

exemption may be needed to allow such operations. As set forth herein, except for the limited conditions 

stated in the Manual, the UAS will never operate at higher than 400 AGL. It will however be operated in 

a restricted area with security perimeter, where buildings and people will not be exposed to operations 

without their pre-obtained consent. The equivalent level of safety will be achieved given the size, weight, 

and speed of the UAS as well as the location where it is operated. No flight will be taken without the 

required permission of the property owner or local officials. Because of the advance notice to the property 

owner and participants in the aerial activity, all affected individuals will be aware of the planned flight 

operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the 

maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with conventional aircraft operating at or below 500 

AGL other industries. In addition, the low-altitude operations of the sUAS will ensure separation between 

these small-VAS operations and the operations of conventional aircraft that must comply with Section 

91.119. 

Page 6 of9 
14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter 

setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS 

altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown 

on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the 

first point of intended landing, and, assuming normal cruising speed - ( 1) During the day, to fly after that 

for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." 

The battery powering the sUAS provides approximately 30-50 minutes of powered flight. To 

meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to 

approximately 20 minutes in length. Given the limitations on the UAS's proposed flight area and the 

location of its proposed operations within a predetermined area, a longer time frame for flight in daylight 

or night VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only 

people and property owners or official representatives who have signed waivers will be allowed, with less 

than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the small UAS. Additionally, limiting sUAS flights to 20 minutes 

would greatly reduce the utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 45 

minutes or 25% of battery power which ever happens first. This restriction would be more than adequate 

to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar 

exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808, and 

11251. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it 

the following: 

( 1) An appropriate and current airworthiness certificate .... 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the 

cabin or cockpit entrance so that it is legible to passengers or crew. 

Page 7 of9 
The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As 

such, there is no ability or place to carry certification and registration documents or to display them on the 

sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the sUAS will have immediate access to them, to the extent they are 

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative 

sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 

10700, 11251, and 11256. 

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

These regulations require that an aircraft operator or owner "shall have that 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 ... ," and 

others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. The operator pursuant to the flight manual and operating 

handbook will accomplish maintenance. An equivalent level of safety will be achieved because these 

small UASs are very limited in size and will carry a small payload and operate only in restricted areas for 

limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating 

from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance 

performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain 

the aircraft in an airworthy condition to provide the equivalent level of safety. 

Pursuant to 14 C.P.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14 C.P.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.P.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) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) 

(2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less). 

Approval of exemptions allowing commercial operations of sUASs, will enhance safety by 

reducing risk. Conventional operations, using jet or piston power aircraft, operate at extremely low 

altitudes just feet from the subjects being filmed and in extreme proximity to people and structures and 

present the risks associated with vehicles that weigh in the neighborhood of 4,000lbs, carrying large 

amounts of jet A or other fuel. Such aircraft must fly to and from the operational location. In contrast, a 

sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the 

reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the operation site and 

not flown. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights. 

The operation of small UASs, weighting less than 55 lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 and allowing 

commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a 

sterile environment and, as a result, are far safer than conventional operations conducted with turbine 

helicopters operating in close proximity to the ground and people. 

Page 8 of9 
Privacy 

All flights will occur over private or controlled access property with the property owner's prior 

consent and knowledge. Filming will be of people who have also consented to being filmed or otherwise 

have agreed to be in the area where filming will take place. The grant of this exemption request will 

provide improved safety in both day and night operations. Satisfaction of the criteria provided in Section 

333 of the Reform Act of2012 -size, weight, speed, operating capabilities, proximity to airports and 

populated areas and operation within visual line of sight and national security - provide more than 

adequate justification for the grant of the requested exemptions allowing commercial operation of 

applicant's UAS. It is of note that certain public safety operations may involve advanced monitoring 

technology such as Infrared Red, Night Vision, etc. These specific operations will be governed pursuant 

to all applicable Local, State, and Federal laws regarding search and seizure including court approval of 

said operations via search warrant. 

Conclusion 

As set forth herein, G2 Aerial, Inc. seeks an exemption pursuant to 14 C.F .R 11.61 and Section 

333 of the FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation of the 

DJI S 1000, Align 690L Hexacopter, Align 800 Trekker, and DZYNE Technologies, Inc. Atlas-8 

commercially, without an airworthiness certificate, for the limited purpose of conducting the 

aforementioned on-demand commercial sUAS operations that include: 

• Filmmaking, Cinematography, and Videography 

• Precision Agriculture 

• Wildlife and Forestry Monitoring 

• Aerial Surveying 

• Inspection, Patrolling, and Monitoring 

• Security and Surveillance 

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of 

the FAA Modernization and Reform Act of 2012, while also advancing the interests ofthe public, by 

allowing G2 Aerial, Inc. to safely, efficiently, and economically operate sUASs commercially within the 

NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and 

Reform Act of2012, section 333, G2 Aerial, Inc. respectfully requests that the Administrator grant this 

Petition for an exemption from the requirements of 14 C.F.R Sections 45.23(b); Part 21; 61.113(a) & (b), 

91.7(a); 91.9(b); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a); 91.405(a), 91.407(a)(l); 

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

Respectfully Submitted, 

Gary 

w~0 Kaplan 

G2 Aerial, Inc. 

3529 Cay Drive 

Carlsbad, Ca. 92010 

Ph: 858-353-5322 

Email: Sales@G2Aerial.com 

Page 9 of9