12/8/2015

Nicholas T. LaRiviere Sr

Firefly Aerial Solutions LLC 

40 Grayson St 

Biddeford, ME. 04005 

207-504-7773

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 

of the Federal Aviation Regulations from: 14 CFR 21 subpart H 

14 CFR 45.23(b) 

14 CFR 61.113(a) and (b) 

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) and (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a)(1) and (2) 

14 CFR 91.417(a) and (b) 

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

“Reform Act”) and 14 CFR Part 11, Nicholas T. LaRiviere owner of Firefly Aerial 

Solutions LLC , hereby applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of designated UAS, 

provided such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. 

Commercial operation of an UAS, as described herein, which are equipped with 

camera(s) and sensors, would provide professional services in the following 

areas: 
1. Aerial photography and/or video for public and/or private use including 

real estate, Architecture, Weddings, land surveying, engineering and 

other related professional activities. 

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

television, public Events, cinematography and newsgathering, Weddings. 

3. Aerial inspection/photography of residential/commercial structures 

under contract with the owners or local government authority. 

4. Aerial inspection/photography of residential/commercial utility 

infrastructure including but not limited to electrical power lines, wind 

turbines and cell towers. 

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

search and rescue operations in cases of an emergency or natural disaster 

only when the local authorities or government has requested it by 

contract or donation. 

6. Training to persons individually or belonging to both private and/or public 

organizations to increase awareness and improve safety for current and 

future UAS operations within the NAS. 

As described fully below, the requested exemption would permit the operation 

of designated UAS as set forth in this document under controlled conditions in 

the NAS that would be 

1. Limited

2. Controlled

3. Predetermined

4. Safe

Approval of this exemption would increase public awareness of UAS operations 

and enhance safety to aid in fulfilling 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.” 
Nicholas T. LaRiviere owner of Firefly Aerial Solutions LLC, plans to operate a 

UAS, the DJI PHANTOM 3 Professional which is comprised of an unmanned 

aircraft (UA or Phantom 3) and a transportable ground station. The Phantom 3 

Professional is referred to as a quad-copter with a maximum gross weight of 

about 3 pounds. It is equipped with four rotors that are driven by electric 

motors powered by batteries. The UA has a maximum airspeed of 16 m/s. 

Nicholas T. LaRiviere owner of Firefly Aerial Solutions LLC, also plans to operate 

a UAS, the DJI Inspire 1 which is comprised of an unmanned aircraft (UA or 

Inspire 1) and a transportable ground station. The DJI Inspire 1 is referred to as a 

quad-copter with a maximum gross weight of about 6.5 pounds. It is equipped 

with four rotors that are driven by electric motors powered by batteries. The UA 

has a maximum airspeed of 22 m/s. 

Also, given the small size of the UAS’s involved and the restricted controlled 

environment within which they will operate, the applicant fits 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 controlled areas in which 

the relevant UASs will operate, approval of the application presents no national 

security issue. Given the following, the grant of the requested exemptions is 

clearly in the public interest: 

Nicholas T. LaRiviere owner of Firefly Aerial Solutions LLC, 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 

an exceptional level of safety to operations. These limitations and conditions to 

which Nicholas T. LaRiviere owner of Firefly Aerial Solutions LLC, agrees to be 

bound when conducting commercial operations under an FAA issued exemption 

including: 
1. The UAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of operator. 

3. Maximum total flight time for each operational flight will be 30 minutes. 

4. Flights will be terminated at 20% battery power reserve. 

5. Flights will be operated at an altitude of no more than 400 feet AGL 

6. UAS operator will be trained and certified in the proper safety and operations 

of the UAS. 

7. The UAS will only operate within a controlled area as defined in the 

Procedures. 

8. The operator will post advisor notice around the controlled area. 

9. The operator will have been trained in operation of UAS generally and 

received up-to-date information on the particular UAS to be operated as 

required. 

10. If the UAS 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. 

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

obstacles or emergencies. 

Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption and are prepared to modify or amend any part of this 

request to satisfy the need for an equivalent level of safety. We look forward to 

working with your office. Please contact us at any time if 

additional information or clarifications are needed. 

Sincerely, 

Nicholas T. LaRiviere 

Firefly Aerial Solutions LLC