Justin K. Sellers, President, CEO 

Sellers Imaging, LLC 

303 Foxchase Circle 

North Augusta, SC 29860 

18August2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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, Sellers Imaging, LLC ("The Applicant"), developer and operator of Small Unmanned Aircraft Systems ("SUASs") 

equipped to conduct Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, 

Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar 

arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf 

Courses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, 

Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and 

tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious 

gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and 

development, traffic monitoring, and sporting events, 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)1imited, 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: 

Sellers Imaging, LLC 

ATIN: Justin K. Sellers 

Ph: (843)655-8944 

Email: Justin@Sellerslmaging.com 

Address: 303 Foxchase Circle North Augusta, SC 29860 

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860 ---CONFIDENTIAL AND PROPRIETARY 
Regulations from which the exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 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 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) & (b) 

14 C.F.R. 91.405 (a) 

14 C.F.R. 91.407 (a) (1) 

14 C.F.R. 91.409 (a) (2) 

14 C.F.R. 91.417 (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." Jd. §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 requirements 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 U.S.C. §44711 (a); 49 U.S.C. §44704; 14 C.F.R. §91.203 (a) (1). 

Sellers Imaging, LLC'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 55 knots and have the capability to hover and move in 

1 Applicant interprets this provision to place the duty on the administrator to not only process applications for exemptions under 

§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. 

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860--- CONFIDENTIAL AND PROPRIETARY 
the vertical and horizontal plane simultaneously. They will operate only in line of sight and will operate only within 

the sterile area described in the confidential Sellers Imaging, LLC Unmanned Aircraft Systems Operations Manual, 

attached as Appendix 2 (hereinafter "The Manual")2

• 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 equivilant 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 Precision Agriculture, 2D and 3D Mapping, Photography, 

Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, 

bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds, 

absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction 

Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, 

Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, 

Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, 

Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events, 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 

Sellers Imaging, LLC is in the business of consulting on, building, and maintaining mission specific sUAS for 

Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual InspectionPrimarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind 

generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, 

Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law 

Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and 

tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, 

Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research 

and development, traffic monitoring, and sporting events. Sellers Imaging, LLCs' clients look to us for safe 

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

looking to operate sUAS for Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data 

Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical 

structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. 

Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public ServicePrimarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, 

hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patient 

tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, 

volumetric Analysis, Research and development, traffic monitoring, and sporting events. 

2 Applicant submits this manual as a Confidential document under 14CFR 11.35 (b) as the entire manual contains proprietary 

information that the applicant has not and will not share with others. The manual contains operating conditions and procedures 

that are not available to the public and are protected from release under the Freedom of Information Act 5 U.S.C. 552 et. Seq. 

3 Reform Act Section 333(b). 

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860--- CONFIDENTIAL AND PROPRIETARY 

---------------------------------------------------------------------------------------- ---- ---
Operations performed by Sellers Imaging, LLC include: 

Precision Agriculture 

2D and 3D Mapping 

Photography 

Cinematography 

Aerial Data Collection 

Visual Inspection- Primarily: 

Towers 

Poles 

Pipelines 

power lines 

cables 

bridges 

chimneys 

vertical structures 

solar arrays 

wind generators 

power stations and substations 

coal ash ponds 

absorbers 

buildings 

Real Estate 

Golf Courses 

Orthographic Photography 

Special Events 

Construction Progress 

Public Service- Primarily: 

Search & Rescue 

Law Enforcement 

Fire 

Security 

Disaster Management & Relief 

Wildfires 

Floods 

Hurricanes 

news broadcasting 

tornados 

Banner towing 

Announcements 

animal tracking 

Alzheimer patient tracking 

Radiation detection 

Noxious gas detection 

Forestry & logging 

Insurance Assessments 

Surveys 

Mining 

volumetric Analysis 

Research and development 

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860--- CONFIDENTIAL AND PROPRIETARY 
traffic monitoring 

sporting events 

As part of this Sellers Imaging, LLC 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 Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data 

Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical 

structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real 

Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search 

& Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news 

broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation 

detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, 

Research and development, traffic monitoring, and sporting events. Sellers Imaging, LLCs' clients look to us for safe 

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

to operate sUAS for Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, 

Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar 

arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf 

Courses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, 

Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and 

tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious 

gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and 

development, traffic monitoring, and sporting events operations conducted with conventional aircraft. 

These limitations and conditions to which Sellers Imaging, LLC agrees to be bound when conducting commercial 

operations under an FAA issued exemption include: 

1. The sUAS will weigh less than 551bs. 

2. Flights will be operated within line of sight, unless an addendum is released or other appropriate FAA guidelines 

supercede. 

3. Maximum total flight time for each operational flight will be 60 minutes. Flights will be terminated at 25% 

battery power reserve; should that occur prior to the 60 minute time limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL (Above Ground Level) or, not more than 200 

feet above an elevated platform from which the 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 Sellers Imaging, LLC. Knowledgable 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. 

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860 ---CONFIDENTIAL AND PROPRIETARY 
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 numbers of UAS PICs involved in the mission; 

e. A Statement that the operator has obtained permission from property owners or property owners' 

representatives 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. Al l 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 predetermined 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 (49U.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 

airwrothiness certificate without the restrictions and conditions proposed. 

The sUAS to be operated hereunder is less than 551bs. 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 operations as is now done with conventional Precision Agriculture, 

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860 ---CONFIDENTIAL AND PROPRIETARY 
2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, 

poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power 

stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic 

Photography, Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, 

Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. 

Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas 

detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and 

development, traffic monitoring, and sporting events. The FAA will have advanced notice of all of these operations. 

These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 

2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, 

poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power 

stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic 

Photography, Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, 

Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. 

Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas 

detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and 

development, traffic monitoring, and sporting events, 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 

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860 --- CONFIDENTIAL AND PROPRIETARY 
aircraft that carries the pilot and passengers, the sUAS is remotely 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 pilots 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, 

9565,95658, 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 functional dual controls. 

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860--- CONFIDENTIAL AND PROPRIETARY 
sUASs and remotely piloted aircraft, by their deisgn 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 Exemtpion Nos. 5778K & 9862A. The equivalent level of safety is 

provided by the fact that neither the 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 400AGL, or not more than 200 feet 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 w ill 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, representatives 

of the property owner or local officials. Because of the advanced notice to the property owners 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 operat ions with aircraft or rotorcraft weighing far more than the maximum 

SSibs. 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 Precision Agriculture, 2D 

and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, 

pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations 

and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, 

Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, Fire, Security, 

Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, 

Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & 

logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic 

monitoring, and sporting events. The FAA will have advanced notice of all of these operations. These safety 

enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D and 3D 

Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, 

power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and 

substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special 

Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster 

Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, 

Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & 

logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic 

monitoring, and sporting events industries. 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 

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860--- CONFIDENTIAL AND PROPRIETARY 
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 30-37 minutes of powered flight. To meet the 30-

minute reserve requirement in 14 C.F.R. §91.151, sUA$ 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 C.F.R. §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 sUA$ 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, 10808. 

14 C.F.R. §91.202 (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 require by paragraph (a) 

of this section or a special flight authorization issues under §91. 715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers and crew. 

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860--- CONFIDENTIAL AND PROPRIETARY 
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 ©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 references 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 400ft 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. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113 (a) & (b), 14 C.F.R. 91.7 (a), 14 C.F.R. 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 C.F.R. 91.151(a), 14 C.F.R. 91.203(a) & (b), 14 C.F.R. 

91.405 (a), 14 C.F.R. 91.407 (a) (1), 14 C.F.R. 91.409 (a) (2), 14 C.F.R. 91.417 (a) & (b). to operate commercially a small 

unmanned vehicle (551bs or less) in motion picture and television operations. 

Approval of exemptions allowing commercial operations of sUASs in the Precision Agriculture, 2D and 3D Mapping, 

Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, 

cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash 

ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction 

Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, 

Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, animal tracking, 

Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, 

Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events. The FAA will 

have advanced notice of all of these operations. These safety enhancements, which already apply to civil aircraft 

operated in connection with Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data 

Collection, Visual Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical 

structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real 

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860--- CONFIDENTIAL AND PROPRIETARY 
Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search 

& Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news 

broadcasting, and tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation 

detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, 

Research and development, traffic monitoring, and sporting events, using jet or piston powered 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 4,0001bs, 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 SSibs. 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 SSibs., conducted in the strict conditions outlines 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. 

Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual InspectionPrimarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind 

generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, 

Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law 

Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and 

tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious 

gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and 

development, traffic monitoring, and sporting events. The FAA will have advanced notice of all of these operations. 

These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D 

and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, 

pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and 

substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special 

Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster 

Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, 

animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance 

Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events 

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 applican'ts UAS 

in the Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual 

Inspection- Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, 

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860 ---CONFIDENTIAL AND PROPRIETARY 
wind generators, power stations and substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, 

Orthographic Photography, Special Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law 

Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and 

tornados. Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious 

gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and 

development, traffic monitoring, and sporting events. The FAA will have advanced notice of all of these operations. 

These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D 

and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection- Primarily towers, poles, 

pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and 

substations, coal ash ponds, absorbers, and buildings. Real Estate, Golf Courses, Orthographic Photography, Special 

Events, Construction Progress, Public Service- Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster 

Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados. Banner towing, Announcements, 

animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance 

Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events 

industries pursuant to the Manual appended hereto. 

Sellers Imaging, LLC 

Sellers Imaging, LLC 303 Foxchase Circle North Augusta, SC 29860 ---CONFIDENTIAL AND PROPRIETARY