U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Avenue,	S.E.

West	Building	Ground	Floor,	Room	W12-140	Washington,	DC	20590

October	19,	2015

Petitioner:

Aerial	Analytics,	LLC

401	Queensway	Drive

Lexington,	KY	40502

Phone:	859-229-5414

Email:	wstuarthartley@gmail.com

Dear	Sir	or	Madam:

Aerial	Analytics,	LLC seeks	exemption	from	section	333	of	the	FAA	Modernization	

and	Reform	Act	of	2012	and	14	C.F.R.	part	11.81.	This	is	to	allow	commercial	

operation	of	small,	unmanned	aircraft	drones	for	purposes	of	public	interest	

including	but	not	limited	to:	inspections,	engineering,	photo	telemetry,	

photogrammetry,	and	photography.	All	operations	shall	be conducted	within	and	

under	the	conditions	and	limitations	outlined	previously	by	the FAA	as	required	by	

Section	333	and	conducted	in	compliance	with	the	applicable	owners	manuals.

Application	for	the	exemption	of	the	following	sections	is	made:

1. 14	CFR	Part	21,	part	H

2. 14	CFR	Part	61.113(a)	and	(b)

3. 14	CFT	Part	91:

a. 91.103(b)(2)

b. 91.105

c. 91.109

d. 91.119

e. 91.121

f. 91.151

g. 91.405

h. 91.407

i. 91.409

j. 91.417

Operation	small	UAS,	as	described	herein,	which	are	equipped	with	cameras	and	

sensors,	would	operate	in	the	following	manner:
1. Aerial	photography	and/or video	for	public	and/or	private	use	including	

engineering,	construction,	real	estate,	land	surveying,	and	other	related	

professional	activities.

2. Aerial	inspection and	data	collection,	including	photography	and/or	

video,	of	residential/commercial	civil	infrastructure.	This	includes,	but	is	

not	limited	to	bridges,	roadways,	dams,	levees,	utilities,	transmission	

systems,	telecommunication	facilities,	wind	turbines,	process	piping,	and	

energy	infrastructure.

3. Aerial	inspection,	including	but	photography	and/or	video,	of	

residential/commercial	structures	under	contract	with	the	owners	or	

local	government	authority.

4. Aerial	photography	and/or	video	for	public	and/or	private	use	including	

television,	public	events,	newsgathering	and	cinematography.

5. Aerial	inspection	and	data	collection,	including	photography	and/or	

video,	of	agricultural	facilities	including	but	not	limited	to	crops,	

livestock,	and	materials	management.

6. Aerial	video/photography	or	providing	live	video	feed	to	assist	with	

search	and	rescue	operations	in	the	event	of	an	emergency	or	natural	

disaster,	or	when	requested	by	local	authorities	or	government.

The	requested	exemption	would	permit	the	operation	of	small	UAS	under	controlled	

conditions	in	the	NAS	that	would	be	a)	limited	b)	controlled	c)	predetermined	and	

d)	safe.	Approval	of	this	exemption	would	increase	public	awareness	of	UAS	

operations	and	enhance	safety	to	high	hazard	workers	to	aid	in	fulfilling	the	

Secretary	of	Transportation’s	(the	FAA	Administrator’s)	requirements	to	

“...establish	requirements	for	the	safe	operation	of	such	aircraft	systems	in	the	

national	airspace	system”	(NAS).

The	name,	phone,	email	and	address	of	the	applicant:

Name:	William	Stuart	Hartley

Phone: (859)	229-5414

Email:	wstuarthartley@gmail.com

Address:	401	Queensway	Dr,	Lexington,	KY	40502

USA	Regulations	from	which	the	exemption	is	requested:	14	CFR	Part	21	subpart	H	

14	CFR	45.23	(b)	14	CFR	61.113(a)	14	CFR	91.7	(a)	14	CFR	91.9	(b)	(2)	14	CFR	

91.103	14	CFR	91.109	14	CFR	91.119(c)	14	CFR	91.121	14	CFR	91.151	(a)	14	CFR	

91.203	(a)	&	(b)	14	CFR	91.405	(a)	14	CFR	91.407	(a)	(1)	14	CFR	91.409	(a)	(2)	14	

CFR	91.417	(a)	&	(b)

Given	the	small	size	of	the	small	UAS	and	the	controlled	environment	provided	the	

proposed	operations	will	adhere	to	the	Reform	Act’s	safety	requirements.	The	

approval	of	this	application	presents	no	national	security	issues.	Regarding	the	level	

of	safety	surrounding	the	proposed	operations	and	the	public	benefit,	reduction	in	

environmental	impacts,	including	but	not	limited	to	reduced	emissions	and	noise,	

the	grant	of	the	requested	exemption	is	in	the	public	interest.	Accordingly	the	
applicant	requests	that	the	FAA	grant	the	requested	exemption	with	minimum	

delay.

Safety	Guidelines	and	Regulations:

1. Aircraft	will	comply	with	maintenance	and	inspection	requirements	of	the	

manufacturer.	All	repair	and	maintenance	work	will	be	conducted	or	

approved	by	qualified	personnel,	and	will	require	a	test	flight	after	such	

work.	Records	of	all	maintenance	and	repair	work	will	be	kept	in	a	

maintenance	log	for	each	aircraft.

2. All	flight	operations	will	be	conducted	by	at	least	two	individuals	(Pilot	and

observer)	who	will	maintain	verbal	communication	capability	with	each	

other	at all	times	during	the	flight,	and	who	will	remain	stationary	on	the	

ground	during the	flight	operations:

3. All	flight	operations	will	be	conducted	in	accordance	with	valid	Certificates	of

Authorization.

4. All	flight	operations	will	comply	with	the	following:

a. The	manufacturers’	user	manuals.

b. Pre-flight	inspections	(including	ground	control	station,	if	any)	and	

safety	risk assessments	will	be	conducted	prior	to	each	flight.

c. Flight	altitudes	will	remain	below	200	feet	above	ground	level

d. Flight	speeds	will	not	exceed	35	knots

e. Not	intrude	into	Class	B,	C	or	D	airspace,	or	published	approach,	SID	

or	STAR, or	take	place	within	5	nautical	miles	of	an	airport.

f. Not	be	made	near	persons	as	required	in	14	CFR	91.119	and	not	over	

persons on the	ground	without	their	prior	permission.

5. Each	flight	will	be	logged	in	both	the	pilot’s	logbook	and	the	aircraft	logbook

6. Not	exceed	75%	of	the	battery	or	fuel	capacity	of	the	aircraft,	or	30	minutes,

whichever	occurs	first.

7. Any	incidents	will	be	reported	within	24	hours	of	occurrence.

8. All	other	applicable	regulations	concerned	with	the	operation	of	aircraft.	

9. Aircraft	will	use	FCC	compliant	2.4	GHz	for	command	&	control	of	the	aircraft

with	well-defined	and	tested	lost	link	procedures.

10. The	small	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	

obstacles,	weather,	or	emergencies.

Relief	Sought:	

1)	Aerial	Analytics,	LLC desires to	operate	small	Unmanned	Aircraft	(sUAS)	for	

commercial	purposes	as	identified	above. Relief	from	section	333	is	sought	because	

law	currently	prohibits	the	commercial	use	of	sUAS	unless	an	exemption	is	granted.	

2)	This	exemption	is	sought	for	use	of	the	following	aircraft,	both	of	which	will	

weigh	less	than	55	pounds	including	cameras	and	energy	sources.	

a)	DJI	Phantom	3	

b)	Future	models	to	be	added	by	amendments	to	this	exemption
DJI	Phantom	3	Specifications:	http://www.dji.com/product/phantom-3/spec

Thank	you	for	your	time	and	attention	to	this	matter.	Please	do	not	hesitate	to	reach	

out	to	me	with	any	questions	or	concerns.	I	thank	you	for	reviewing	my	application	

for	a	Section	333	exemption	and	eagerly	await	your	response.

Best	Regards,

W.	Stuart	Hartley