February 13, 2015 

U.S. Department of Transportation 

Federal Aviation Aministration 

800 Independence Avenue, SW

Washington, DC 20591

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 C.F.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); 91.409 (a) (2); 91.417 (a) & (b). 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 

14 C.F.R. Part 11, Motter Aero Vision (“the applicant”), developer and operator of Small Unmanned 

Aircraft Systems (“sUASs”) equipped to conduct infrastructure and construction inspection and assist 

business operations, hereby applies for an exemption from the listed Federal Aviation Regulations 

(“FARs”) 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 

333. 

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 in the infrastructure and business operations industry presently 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 applicant is: 

Matthew Motter 

504 Emily Lane 

Piedmont SC, 29673

mmotter90@gmail.com
(360)672-1547

Regulations from which the exemption is requested: 

14 CFR Part 21 

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 of UASs do not create a hazard to 

users of the 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 of the UAS within visual line of sight of the 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.” Id. §333(c) (emphasis added).1

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 §40101 of the Act, 

which 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) of this 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). 

Motter Aero Vision’s sUASs (Appendix 1) are rotorcraft, weighing 55 or fewer lbs. including payload. 

They operate under normal conditions at a speed of no more than 25 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 the sterile area. Such operations insure that the sUAS does “not 

create a hazard to users of the national airspace system or the public.”3

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 of UASs 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 for infrastructure, construction, and business operations, the 

granting of the requested exemptions is in the public interest. Accordingly, the applicant respectfully 

requests that the FAA grant the requested exemption without delay. 

Background Information 

Motter Aero Vision is in the business of consulting on building and maintaining mission specific sUAS 

for infrastructure, construction, and public safety. Motter Aero Vision’s clients look to us for safe 

 

1 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. 
operations of sUAS. We have developed specific safe UAV operational procedures. Increasingly, we have 

clients looking to operate sUAS for infrastructure and maintenance inspections, construction 

documentation, public safety, and business operations. 

Operations performed by Motter Aero Vision: 

Utility and General Infrastructure Documentation

Construction Site Documentation

Land Development

Public Safety

Agriculture Inspection

Geospatial Mapping

Real Estate Marketing 

As part of this Motter Aero Vision is requesting FAA Exemption for sUAS operations for safety, 

inspection and video capture usage. 

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 within 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 infrastructure, 

construction, and business operations conducted with conventional aircraft. 

These limitations and conditions to which Motter Aero Vision 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 30 minutes. Flights will be terminated 

at 25% battery power reserve should that occur prior to the 30 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 flight is planned. 

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

6. The sUAS pilot will be a specially trained staff member of Motter Aero Vision knowledgeable of 

the airspace within which the operation will take place and how that airspace fits into the NAS. 

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

Pilot, who possess the necessary PIC qualifications, is also present on site, that person can also be 

designated as PIC. 

8. The sUAS will only operate within defined boundaries as outlined in Section 8.4 of the Manual. 
9. A briefing will be conducted in regard to the planned sUAS operations prior to each mission. 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 file a FAA Form 7711-1, or its equivalent, as modified in light of the requested 

exemption, with the appropriate Flight Standards District Office (FSDO). 

11. The operator will obtain the consent of all persons involved in the mission 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, as required by Section 

8.4 of the Manual. With the advanced permission of the relevant FSDO, operations at closer range 

can be approved. 

12. The operator will submit a written Plan of Activities to the FSDO three days before the proposed 

mission as required in Section 8.1 of the Manual. Items will include: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS mission conducted under this 

petition of exemption; 

c. Make, model, and serial or N-number of UAS to be used; 

d. Name and certificate number of UAS PICs involved in the mission; 

e. A statement that the operator has obtained permission from property owners and/or 

local officials to conduct the mission; 

f. The list of those who gave permission made available to the inspector upon request; 

g. Signature of exemption-holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, town, 

county, and/or state over which the mission will be conducted and the altitudes essential 

to accomplish the operation. 

13. Pilot and observer will have been trained in operation of UAS generally and received up-to-date 

information on the particular UAS to be operated as required in Sections 7.4 and 7.5 of the 

Manual. 

14. Observer and pilot will at all times be able to communicate by voice. 

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

16. 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. 

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

to a pre-determined location within the Security Perimeter and land. 

18. The sUAS will have the capability to abort a flight in case of unpredicted 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 and observer, pursuant to the Manual’s policies, 

and under and in compliance with local public safety requirements, to provide security for the area of 

operation as is now done with conventional infrastructure and construction inspections and business 

operations. The FAA will have advance notice of all operations. These safety enhancements, which 

already apply to civil aircraft operated in connection with infrastructure and construction inspections 

and business operations, 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. 

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 a cabin, cockpit or pilot station on which the word “Experimental” can be 

placed. Given the size of the sUAV, 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 sUAV marked on its fuselage as 

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

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

regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

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 UAS 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 specially trained staff 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 as set forth in the Manual. 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 by specially trained staff 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 checklists 

prior to each flight, as set forth in Sections 9.1 and 9.6, 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. 

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: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

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. An equivalent level of safety will be provided as set forth in Sections 8 and 9 

of the Manual. 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 and the exemption requests authority to operate at altitudes up to 400 

AGL, or not more than 200 above an elevated platform from which operation 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 a 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 permission of the property 

owner or local officials. Because of the advance notice to the property owner and participants in the 

mission, all affected individuals will be aware of the planned flight operations as set forth in Section 6.2, 

8.1, and 8.2 of the Manual. Compared to flight operations with aircraft or rotorcraft weighing 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 in the infrastructure and construction inspections and business operations industry. In addition, 

the low-altitude operations of the sUAS will ensure separation between these small UAS operations and 

the operations of conventional aircraft that must comply with Section 91.119. 
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 checklist, 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 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 20 

minutes or 25% of battery power whichever 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, and 10808. 

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. 

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, and 

10700. 

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 sections and Part 43 apply only to aircraft with an airworthiness certificate, 

these sections will not apply to the applicant. Maintenance will be accomplished by the operator 

pursuant to the flight manual and operating handbook as referenced in the Manual (See Sections 8.6 

and 9). 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.F.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.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.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) in motion picture and television operations. 

Approval of exemptions allowing commercial operations of sUASs in the infrastructure and construction

inspections and business operations will enhance safety by reducing risk. Conventional infrastructure 

and construction inspections and business operations, using jet or piston power aircraft, operate at 

extremely low altitudes just feet from the infrastructure being inspected 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 work 

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 worksite 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, weighing 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. 

Privacy 

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

and knowledge. Infrastructure and construction inspections and business operations will be performed 

for people who have also consented for work to be performed or otherwise have agreed to be in the 

area where UAS flight will take place. 

Conclusion 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – 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 in the infrastructure and construction 

inspections and business operations industry pursuant to the Manual appended hereto. 

Sincerely, 

Matthew Motter

Owner/ Operator 

Motter Aero Vision

504 Emily Lane 

Piedmont SC, 29673

(360) 672-1547

Appendix 1

1.1- DJI Phantom 2 Vision +

See Attached Flight Manuals: 

DJI Phantom 2 Vision+ User Manual 1.8 

Naza-M v2 Quick Start Manual v1.26

1.2 – DJI Phantom 3
See Attached Flight Manuals:

DJI Phantom 3 Professional User Manual 1.2

1.3 – DJI Inspire 1

See Attached Flight Manual:

DJI Inspire 1 User Manual 1.4