RE: Petition for Exemption: 14 CFR § 11.81, Section 333 

Operator Information: 

Company: 

National Airviews, Inc. 

11412 Williamsport Pike 

Greencastle, PA 17225 

Phone 717-597-4994 

Email: airviews@comcast.net 

Operator/Pilot: (owns above company) 

David A Friedrich 

132 Helens Drive 

Greencastle, PA 17225 

Phone 301-730-3514 

Email: dave@nationalairviews.net 

FAA Certificate # 3251450 

Reason for Request 

Section 333 prohibits the use of a UAS for commercial purposes over private property. I 

am a multi-engine commercial pilot with over 10,000 hours of flight time and have 

owned and operated an aerial photography business for over 19 years. I have a current 

third class medical and BFR. Due to the ever increasing demand for our services 

utilizing low altitude UASs, I am petitioning for an exemption to provide a commercial 

service to private land owners/real estate companies who request low altitude aerial 

imagery and video of said properties for marketing and advertising. I would like to be 

able to accept payment for these services as we do now with our conventional, piloted, 

fixed wing aerial services thus making this a commercial use of a UAS. 

Public Benefit 

This request benefits the public as a whole by satisfying the ever-growing demand and 

providing an additional service we can offer to supplement our existing photographic 

services that cannot operate at these low altitudes. This will provide an ever increasing 

opportunity for real estate companies to enhance their services to their clients by taking 

advantage of the unique, low-altitude technology that now exists in the form of UAS’s 

and ensures them a safe, legal operation with an FAA certified and very experienced PIC. 
Safety 

Being an FAA licensed pilot, I will employ the same vigilance and safety with a UAS as I 

now do with our fixed wing aircraft. All FAA regulations will be followed as applicable 

to UAS operation including pre-flight checks, see and avoid, aircraft separation distances, 

cloud clearance requirements, airspace communication requirements, etc. Maximum 

operational altitude will be limited to 400 feet AGL, with a maximum speed limited to 29 

kts (ground speed). Flight will only occur in daylight VFR conditions (no IFR or SVFR 

flight). Per requirements, the UAS will be kept within a visual line of sight (VLOS) at all 

times and will always employ a visual observer (VO) for obstacle clearance. Flight time 

will be limited to battery life with a reserve that will allow a safe return to the flight’s 

origin. 

Proposed Operation: 

Operations will be limited to privately owned residential and commercial properties. 

Low altitude aerial imagery and video will be captured throughout several orbits of said 

property at varying altitudes (maximum of 400 AGL). During the orbital process, overall 

characteristics of said property will be captured along with any required highlights that 

may help market said property. Estimated flight time over said property will typically be 

less than 10 minutes but not greater than the battery life with a reserve allowing a safe 

return to the flight origin. Prior to the flight, a walk-around of each property will occur to 

ensure there are no unknown obstacles. In addition, each flight will begin with a vertical 

accent to determine the height of the highest obstacle within the flight path of the 

property. Once determined, the minimal operational altitude will be based off of this 

height with a margin of safety applied. All FAA provided documentation will be present 

during each flight to satisfy any general public safety concerns or law enforcement 

inquiries. 
Specific UAS for Operations 

We plan to utilize the 3DR Solo UAS which can be found here: 

https://3dr.com/solo-drone/ 

Solo is a quad-rotor aerial vehicle powered by the 3DR Pixhawk 2 autopilot system and 

APM Copter flight control software. Solo communicates with the controller and Solo app 

over the 3DR Link secure Wi-Fi connection. 

Autopilot: 3DR Pixhawk 2 

Flight code: ArduPilot Copter 

Control: 3DR Solo Controller 

Wireless communication: 3DR Link 1.0 

Frequency: 2.4 GHz 

Height: 10 in. (25 cm) 

Motor-to-motor dimension: 18 in. (26 cm) 

Propulsion: 880 KV motors, two clockwise rotating motors and 

two counterclockwise rotating motors 

Propeller: 10 in. x 4.5 in. (25 cm x 11.4 cm) 

Weight with battery: 3.3 lbs. (1.5 kg) 

Controller battery life: 3 hours 

Extended controller battery life: 6 hours 

Controller battery: Li-ion 2600 mAh 7.2 Vdc (5200 mAh for extended 

battery) 

Power: Electric (rechargeable lithium polymer battery) 

Battery: Lithium polymer, 5200 mAh, 14.8 Vdc 

Battery weight: 1 lb. (.5 kg) 

Estimated flight time: 25 minutes 

Maximum altitude: 328 ft. (100 m) 

Range: .5 miles (.8 km) 

Payload capacity: 1.1 lbs. (500 g) 

Cruise speed: 5.7 mph (2.5 m/s) 

Maximum speed: 55 mph (25.5 m/s) 

Maximum climb rate: 11 mph (5.0 m/s) 

Maximum descent rate: 5.5 mph (2.5 m/s) 

Headwind limitation: 25 mph (11 m/s) 

Crosswind limitation: 25 mph (11 m/s) 

Camera: Streaming video compatible with GoPro® HERO 3, 

3+ or 4 Full compatibility with GoPro® HERO 4 

Solo app compatibility: iOS 8.0 or later / Android 4.3 or later 

Operating temperature: 32° F - 113° F (0° C - 45° C) 

Operating relative humidity: 0-85% RH 
Geographic Area of Use 

We will conduct flights only within the continental United States and more specifically, 

within our local market (the mid-Atlantic region) of the United States. 

Summary 

I, David Friedrich, am seeking an exemption of the FAA Section 333 rules that currently 

do not allow the use of a UAS for commercial purposes. I am petitioning for an 

exemption so that we can provide commercial service for our existing and future 

customers who may wish to utilize our services for low altitude aerial imagery and 

videography which cannot be provided with our conventional fixed wing aircraft. Being 

an FAA licensed pilot with over 10,000 hours, I fully understand the importance of 

following all FAA regulations and procedures and will do so with the same diligence 

when utilizing the UAS. With this said I feel I would be an ideal candidate for this 

exemption and appreciate your consideration for exemption. 

Sincerely, 

David Friedrich 

National Airviews, Inc.