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National Aerials LLC

Bradley Young, Manager

11 First Street

Colorado Springs, Colorado 80906

nationalaerials@gmail.com

To: Federal Aviation Administration (FAA) 

Contents Include: 

• Exemption Request (1-3)

• Certificate of Good Standing for National Aerials, LLC (4)

• DJI Phantom 3 Professional Users Manual (5-11)

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This document constitutes an exemption Request under Section 333 of the FAA Modernization and 

Reform Act of 2012 for Aviation Unmanned to perform Aerial Photography for National Aerials LLC. 

National Aerials is requesting exemption for the commercial use of small UASs under section 333. We 

plan to operate any and all UASs with the proper training and certification required by the FAA.

National Aerials will provide services to the community and to consumers interested in aerial data capture 

using the DJI Phantom 3 Professional, DJI Inspire and similar UASs manufactured in the United States 

that comply with all FAA regulations (hereafter referred to as UASs). The intended use for these UASs is 

to provide video marketing material for real estate and other business in need of aerial photography and 

videography. Additionally, there are many agricultural and other use cases that require imaging and 

surface mapping to increase their overall business awareness and effectiveness. We would like to be 

able to provide companies with these services. There are many angles, views, and perspectives that are 

unsafe to film without the use of UASs that we would like to be able to bring to the public, while making 

sure to comply with all FAA regulations. Many of the operations would be similar in nature to the 

exemption granted to Ralph Apel, Exemption No. 11410.

The services would include the use of small UASs for: 

• Real Estate Photography / Videography

• Aerial Photography / Videography and Filmmaking

• Event Photography / Videography

• Aerial Surveying / Data Collection

• Construction Site Inspection / Monitoring

Request: An exemption from 91.7(a), 91.119, 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(2) 

and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR) as was granted to Ralph Apel in 

Exemption No. 11410
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Petition: We request an 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) 

The Extent of Relief We Seek

1. Extent of Relief that we seek regarding Section 61.113 (a) and (b) Private Pilot Privileges and 

Limitations Relief from Section 61.113 (a) and (b) is requested to allow a Pilot in Command holding a 

current airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also 

hold a current FAA airman medical certificate or a valid U.S. driver’s license. The PIC must also meet the 

flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her 

pilot certificate. All flights will be accompanied by a Visual Observer who, along with the pilot, will maintain 

Visual Line of Sight with the UAS at all times. None of our UASs will be able to carry passengers. 

2. Extent of Relief that we seek in regards to Section 91.7(a) Civil Aircraft Airworthiness Relief from 

Section 91.7(a) is requested to allow the PIC to determine airworthiness of the operating UAS. As part of 

this determination the following will be adhered to: a. Prior to the UAS’s flight the PIC will inspect the UAS 

to ensure it is in a condition that will be conducive for a safe flight. The ground control station will be 

included in the above inspection. b. The PIC will follow the UAS’s aircraft/component, maintenance, 

overhaul, replacement, inspection and life limit requirements. c. The PIC will comply with all 

manufacturer's Safety Bulletins. 

3. Extent of Relief that we seek in regards to Section 91.119 Minimum Safe Altitudes General relief from 

91.119 is requested to allow the PIC to operate the UAS at altitudes not to exceed 400’ AGL over private 

property at a distance at or greater than 5NM from the nearest airport as depicted on current Aeronautical 

Charts. We also wish for the PIC to be granted exemption to operate at an altitude not greater than 50’

AGL (below tree level) between 1NM and 5NM from the nearest airport as depicted on current 

Aeronautical Charts. 

4. Extent of Relief that we seek in regards to Section 91.121 Altimeter Settings Relief from 91.121 is 

requested because the UAS has an electronic GPS with a barometric sensor. In order to maintain an 

equal level of safety that 91.121 requires, the PIC of the UAS will use the radio signal to abort the flight in 

the events that the UA loses communications with the GPS signal. 

5. Extent of Relief that we seek in regards to Section 91.151(b) Fuel Requirements for Flight in VFR 

Conditions Relief from 91.151(b) is requested to the extent that allows the PIC to operate the UAS up to a 

point (considering wind and forecast weather conditions) that there is enough power to fly at normal 

cruising speed to the intended landing point and land the UA with sufficient reserve battery. 

6. Extent of Relief that we seek in regards to Sections 91.405(a), 91.407(a)(1), 91.409(a)(1), and (a)(2), 

91.417(a) and (b) These are all associated with an Airworthiness certificate Relief from 91.405(a), 

91.407(a)(1) and (a)(2), and 91.417(a) and (b) is requested to the extent that allows the PIC to operate 

the UAS as necessary. These sections are all related to airworthiness certificates of aircraft. There is not 

currently an airworthiness certificate for small UAS’s. We will comply in full with any conditions and 

limitations that the Administrator may impose in order to receive an approved Grant of Exemption.
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Aircraft and Equivalent Level of Safety:

Safety procedures set forth by National Aerials LLC will include: 

● The UASs will weigh less than 55 pounds 

● Airport owners and/or local air traffic control facilities will be contacted and notified if operations 

take place within the designated distance from that airport, pursuant to any conditions of COAs 

issued for commercial UAS flight activities 

● A briefing will be conducted for planned UAS operations prior to each flight 

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

jurisdictions, including local law enforcement, fire, or other managing governmental agencies, if 

applicable 

● If the UAS loses communications or loses its GPS signal, the UAS will and does have the 

capability to return to a pre-determined location within the Security Perimeter and land safely 

● The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies

Public Interest: 

Aerial photography and videography has been around for a long time through manned fixed wing aircraft 

and helicopters, but for small business owners, its expense has been cost-prohibitive. Granting this 

exemption would allow National Aerials to provide this service at a much lower cost. Our UASs will pose 

little risk to the public given their small size and lack of combustible fuel when compared to manned 

aircraft. The operation of our UAS will minimize ecological damage and promote economic growth by 

providing a more affordable and safer alternative to traditional aerial photography and videography 

means. 

Conclusion: 

As set forth herein, National Aerials seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 

of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of UASs for 

commercial purposes. In accordance with the FAA Modernization and Reform Act of 2012, National 

Aerials 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)

If you have any questions or need any additional information, please contact the undersigned at 

nationalaerials@gmail.com

Thank you for your consideration.

National Aerials, LLC

Bradley Young, Manager
I, Wayne W. Williams, as the Secretary of State of the State of Colorado, hereby certify that, according to

the records of this office, 

National Aerials, LLC 

is a Limited Liability Company formed or registered on 09/03/2015 under the law of Colorado, has

complied with all applicable requirements of this office, and is in good standing with this office. This

entity has been assigned entity identification number 20151578185.

This certificate reflects facts established or disclosed by documents delivered to this office on paper

through 09/02/2015 that have been posted, and by documents delivered to this office electronically

through 09/03/2015 @ 17:07:38.

I have affixed hereto the Great Seal of the State of Colorado and duly generated, executed, authenticated,

issued, delivered and communicated this official certificate at Denver, Colorado on 09/03/2015 @

17:07:38 pursuant to and in accordance with applicable law. This certificate is assigned Confirmation

Number 9297128.

OFFICE OF THE SECRETARY OF STATE 

OF THE STATE OF COLORADO

CERTIFICATE

_____________________________________ 

*********************************************End of Certificate******************************************** 

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as an option, the issuance and validity of a certificate obtained electronically may be established by visiting the Certificate Confirmation Page of 

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necessary to the valid and effective issuance of a certificate. For more information, visit our Web site, http://www.sos.state.co.us/ click Business 

Center and select “Frequently Asked Questions.” 

CERT_GS_D Revised 08/20/2008

Secretary of State of the State of Colorado