Todd Massey

Owner Operator

Aerial Impressions, LLC

414-899-8512

aerialimpressionsMKE@gamil.com

Dear Madam or Sir

Aerial Impressions is petitioning the Federal Aviation Administration (FAA) for 

an exemption to Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 CFR Part 11 The exemption would allow operation of the DJI Phantom 

2 and DJI S1000 unmanned aircraft systems (UAS) for the purpose of supporting the 

agriculture industry, aerial photography/video and land surveying. this document will 

outline requested relief from regulations pertaining to this exemption.

Aerial Impression agrees to operate within the boundaries set forth by this 

exemption. Along with with rules and regulations that the FAA has in place Aerial 

Impressions plans to use additional safety precautions were they see fit to ensure safe 

sUAS operations. Implementation of lightweight small unmanned systems is an tool that 

can greatly improve the safety standards of or National Airspace (NAS). sUAS can fly 

operations that would traditionally would require manned aircraft which carry pilots, 

gallons of flammable fuel. Please Allow Aerial Impressions to offer sUAS operations to 

its local market to promote the safe efficient and responsible use of sUAS. 

Thank you for your time,

Todd Massey

Owner Operator

Aerial Impressions, LLC

414-899-8512

aerialimpressionsMKE@gamil.com

Table of Contents

Glossary of Abbreviations....................................................................4 

List of Attachments...............................................................................3

Introduction and Interest of Petitioner...................................................3 

Unmanned Aerial Systems.....................................................................3 

Equipment List..................................................................4 

Unmanned Aircraft Pilot in Command (PIC).........................................7 
Operations of sUAS ...............................................................................8

Requested Exemptions from Regulations .............................................12

Public Interest.........................................................................................15

Conclusion..............................................................................................16 

Glossary of Abbreviations

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Aviation 

Administration

FAR Federal Aviation Regulation

MAAP Mid Atlantic Aviation 

Partnership

NAS National Airspace System

PIC Pilot in Command

sUAS Small Unmanned Aircraft 

Systems

VFR Visual Flight Rules

VMC Visual Meteorological 

Conditions

VO Visual Observer

VLS Visual Line of Sight 

LIST OF ATTACHMENTS

Futaba 14sg operational manual

A2 Flight Control operational manual

DJI S1000+ operational Manual

DJI Phantom 2 operational manual

Naza M flight control operational manual 

Section 1: Introduction and Interest of Petitioner
Aerial Impressions is a small business located in southeastern Wisconsin that 

intends to use two current DJI model UAV platforms,to gather images for the use 

of Real estate Precision Framing, Georeference Mapping and Golf courses. Aerial 

Impressions is committed to offering safe and responsible sUAS flight operations.

It shall be the intent of every sUAS operator to make a responsible effort to 

not invade a person's reasonable expectation of privacy when operating the UAS 

while performing safe flight operations. When operating the sUAS, Aerial 

Impressions operators will abide by all FAA Regulations for flight and receive the 

proper authorization for flight.

Section 2: Unmanned Aerial Systems

General Information Pertaining to All Proposed UAS

Aerial Impressions will operate less than fifty-five pound sUAS, for the ability to conduct 

aerial imagery and videography, with payloads capable of supporting these missions.

Prior to each flight the PIC shall inspect the sUAS to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the sUAS, the 

aircraft will be prohibited from operating until the necessary maintenance has been 

performed and the sUAS is found to be in a condition for safe flight. Ground Control 

Station will be included in preflight inspections as well. Maintenance and Alterations 

must be properly documented in aircraft records. All discrepancies noted shall be 

documented as described in the Aerial Impressions Operators Manual pg.2 

(Organization) 

Any maintenance or alterations made to the sUAS shall be documented in a logbook as 

well as undergo test flight before it can return to service. Any repairs or alterations must 

meet the manufacturer's guidelines with particular attention to flight critical components 

that may not be addressed in the manufacturer’s manuals. Only personnel who are 

authorized shall perform such operations.

Aerial Impressions will follow all manufacturer’s sUAS aircraft/component, 

maintenance, overhaul, replacement, inspection and life limit requirements, Aerial 

Impressions shall carry out their maintenance, inspections and record keeping 

requirements, in accordance with the operator’s manual. Maintenance, inspection, and 

alterations must be noted in the aircraft log book, including total flight hours, description 

of work

Each sUAS operated under the proposed exemption shall comply with all manufacturer 

System and Safety Bulletins.

Aerial Impressions technicians will receive and document training referenced in the 

manufacturer’s operations manual.

Before conducting operations, the radio frequency spectrum used for operation and 

control of the sUAS shall comply with the Federal Communications Commission (FCC) 

or other appropriate government oversight agency requirements.
Equipment List 

DJI Phantom 2

Aerial Impressions seeks an exemption to operate DJI Phantom 2 sUAS, for 

compensation or hire. The DJI Phantom 2 is comprised of a quadrotor unmanned aircraft 

and a handheld ground control station. The Phantom II has a maximum gross weight of 

approximately 2.8 pounds, diameter (rotor span) 23.75 inches, width of 12.5 inches, and 

height of 8.1 inches. The Phantom II is equipped with four rotors driven by four lithium 

polymer battery powered electric motors.

Design and operational characteristics are provided in DJI Phantom 2 Operating Manual 

(Page 35). Flight crews shall conduct pre-flight inspections as documented in DJI

Phantom 2 Operating Manual (Page 24)

ATTACHMENTS

DJI Zemuse H3 -3d Gimbal

DJI ISOD mini

DJI 2.4ghz. Data link

14sg Futaba radio transmitter 

Gopro Hero 3+

DJI Naza M Flight controller

Phantom Specifications

Please refer to (Sec. 8.1) in the provided Phantom Operating Manual.

Nazi M Flight Control Specifications

Please refer to (Page 23) in the provided Nazi Flight Control Manual

Futaba 14sg specifications

Please refer to (Page 11) of the Futaba 14sg Control Manual

DJI S1000+

Aerial Impressions seeks an exemption to operate a DJI-S1000 sUAS for compensation 

or hire. The DJI-S1000+ is comprised of a multi-rotor unmanned aircraft and two 

handheld ground control stations. The DJI-S1000 has a maximum gross weight of 

approximately 24 pounds, diagonal wheelbase of 41.4 inches, and height of 

approximately 18 inches. The DJI- S1000 is equipped with eight rotors driven by eight 

lithium polymer battery powered electric motors.

Design and operational characteristics are provided in DJI S1000+ Operating Manual 

(Page 22).

Flight crews shall conduct pre-flight inspections as documented in DJI S1000+ Operating 

Manual (Page 4).

ATTACHMENTS 

DJI A2 Flight Control

DJI Zemuse Gimbal for either Panasonic GH4 or Canon Mark III

DJI ISOD

DJI Light Bridge
2 Futaba 14sg Radio Transmitter

S1000 Specifications

Please refer to (Page 22) of the S1000+ Operating Manual

A2 Flight control specifications

Please refer to (Page 49) of the A2 Flight Control Manual

Futaba 14sg specifications

Please refer to (Page 11) of the Futaba 14sg Control Manual

Align M690L

Aerial Impressions seeks an exemption to operate a Align M690L sUAS for 

compensation or hire. The Align M690L is comprised of a multi-rotor unmanned aircraft 

and two handheld ground control stations. The Align M690L has a maximum takeoff 

weight of 7,200g, wheelbase of 875mm, and height of approximately 446 mm. The Align 

M690 is equipped with six rotors driven by six lithium polymer battery powered electric 

motors.

Design and operational characteristics are provided in Align M690L Operating Manual 

(Page 59).

Flight crews shall conduct pre-flight inspections as documented in Align M690L

Operating Manual (Page 42).

ATTACHMENTS 

AMP-S Flight Control

Align G3 Gimbal for either Panasonic GH4 or Canon Mark III or Samsung NX1

Align OSD

Align FPV 5.8ghz video transmitter

2 Futaba 14sg Radio Transmitter

Align M690L Specifications

Please refer to (Page 59) of the Align M690L+ Operating Manual

APSM Flight control specifications

Please refer to (Page 59) of the Align M690L Control Manual

Futaba 14sg specifications

Please refer to (Page 11) of the Futaba 14sg Control Manual

X8-M

Aerial Impressions seeks an exemption to operate a X8-M sUAS for compensation or 

hire. The X8-M is comprised of a multi-rotor unmanned aircraft and one handheld ground 

control station. The X8-M has payload capacity of 200 g, wheelbase of 20.1 inches, and 

height of approximately 12 inches. The X8 -M is equipped with eight rotors driven by

eight lithium polymer battery powered electric motors.

Flight crews shall conduct pre-flight inspections as documented in X8-M Operating 

Manual (Page 25).

ATTACHMENTS 

3DR robotics Pixhawk flight control

Spektrum DX7s radio control
Canon S100 with custom 3DR EAI software and fixed mount

Spektrum DX7s radio control

X8-M Specifications

 Pixhawk autopilot system

 Motors: SunnySky V2216-12 800 kV II (The images above show conical nuts; X8-M ships with hex 

nuts.)

 Propellers: APC 11X4.7 SFP (4), APC 11X4.7 SF (4)

 Flight battery: 4S 10000 mAh 10C lithium polymer

 Aircraft weight (with battery): 7.7 lbs (3.5 kg)

 Aircraft dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 30 cm)

 Case dimensions: 60.7 in x 14.5 in x 15.5 in (154 cm x 37 cm x 39 cm)

 Payload capacity: .4 lbs (200 g)

 Radio range: .6 miles* (1 km)

 Flight time: 14 min*

 Maximum operational wind speed: 25 mph (11 m/s)

 Area coverage: 25 acres* (0.1 km2)

 Ground sampling distance: .7 inches per pixel (2 cm per pixel)*

 Orthomosaic accuracy: 3-16 ft (1-5 m)

Pixhawk Flight control specifications

Please refer to (Page 12) of the Pixhawk Flight Control Manual

Spektrum DX7 specifications

Please refer to (Page 103) of the Spektrum Control Manual

Section 3: Unmanned Aircraft Pilot in Command (PIC)

Aerial Impressions Flight Crew, including PIC and Visual Observers (VO), will be 

qualified as directed by Aerial Impressions Operation Manual pg.3 (operators)

All flight crew members, including PIC and VO, will have an understanding of, and 

comply with, Title 14 Code of Federal Regulations, and/or Agency directives and 

regulations, applicable to the airspace where the sUAS will operate. Specifically all flight 

crew members will receive training on the rules and responsibilities described in 14 CFR 

Part 91 Sections 91.111, 91.113 and 91.115 regarding cloud clearance, flight visibility

and the pilot controller glossary, including standard ATC phraseology and 

communication.

The PIC must possess at least a current private pilot certificate and third class medical

certificate. The PIC must also meet the flight review requirements specified in 14 CFR 

Section 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate.

Prior to operations conducted for the purpose of aerial imagery and videography (or

similar operations), the PIC must have accumulated and logged, in a manner consistent 

with 14 CFR Section 61.51(b), a minimum of 25 hours of total time as a sUAS pilot and 

at least ten hours logged as a sUAS pilot with similar sUAS type (fixed wing or rotary). 

Prior documented flight experience that was obtained in compliance with applicable 
regulations may satisfy this requirement. Training, proficiency, and experience building 

flights are requested to be conducted under this grant of exemption to accomplish the 

required flight cycles and flight time. During training, proficiency, and experience 

building flights, all persons not essential for flight operations will be considered nonparticipants and the PIC will operate the sUAS with appropriate distance from nonparticipants in accordance with 14 CFR Section 91.119. operations), the PIC must have 

accumulated and logged in a manner consistent with 14 CFR Section 61.51(b), a 

minimum of five hours as a sUAS PIC operating the make and model of the sUAS to be 

utilized for operations under this requested exemption, and three take-offs and landings in 

the preceding 90 days. Training, proficiency, experience- building, and take-off and 

landing currency flights are requested to be conducted under this grant of exemption to 

accomplish the required flight time and 90 day currency. During training, proficiency, 

experience building, and take-off and landing currency flights all personnel not essential 

for flight operations are considered non participants, and the PIC must operate the sUAS 

with appropriate distance from nonparticipants in accordance with 14 CFR Section 

91.119.

All operations must utilize a VO. The VO may be used to satisfy the Visual Line of Sight 

(VLOS) requirement as long as the PIC always maintains VLOS capability. The VO and 

PIC must be able to communicate verbally at all times. This condition and limitation is 

consistent with all FAA approved Exemptions

Section 4: Operations of sUAS

At all times the sUAS must remain close enough to the operator for the operator to be 

capable of seeing the aircraft with vision unaided by any device other than corrective 

lenses.

Small unmanned aircraft may not operate over any persons not directly involved in the 

operation.

Daylight-only operations (official sunrise to official sunset, local time).

Must yield right-of-way to other aircraft, manned or unmanned.

First-person view camera cannot satisfy “see-and-avoid” requirement but can be used 

as long as requirement is satisfied in other ways.

Maximum airspeed of 30 mph 

Maximum altitude of 400 feet above ground level.

Minimum weather visibility of 3 miles from control station.

No operations are allowed in Class A (18,000 feet & above) airspace.

Operations in Class B, C, D and E airspace are allowed with the required ATC 

permission.
Operations in Class G airspace are allowed without ATC permission

No person may act as an operator or VO for more than one unmanned aircraft 

operation at one time.

No careless or reckless operations.

Requires preflight inspection by the operator. 

The sUAS shall remain clear and yield the right of way to all other manned aviation 

operations and activities at all times.

The sUAS shall be operated at an altitude of no more than 400 feet above ground level 

(AGL). All altitudes reported to ATC will be in feet.

The multi-rotor sUAS shall not be flown at a ground speed exceeding 30 mph.

sUAS Operations will be conducted under visual meteorological conditions (VMC). The 

sUAS will not be operated less than 500 feet below or less than 2000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC.

If the sUAS loses communications or loses its GPS signal, it must return to a 

predetermined location within the planned operating area and land or be recovered. 

The sUAS PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with operating documents.

The sUAS PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising speed to the 

intended landing point and land the sUAS with 25% battery power remaining.

The sUAS operated in accordance with this proposed exemption shall be identified by 

serial numbers, registered in accordance with 14 CFR part 47, and have identification 

(Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as 

large as practicable.

The sUAS documents required under 14 CFR 91.9 and 91.203 shall be available to the 

PIC at the Ground Control Station of the sUAS anytime the aircraft is operating. Those 

documents shall be available to the Administrator or any law enforcement official upon 

request.

Any sUAS incidents, accidents or flight operations that transgress the lateral or vertical 

boundaries of the operational area as defined by the applicable COA shall be reported to 

the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents shall be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov.

Unless otherwise specified in this petition, the sUAS PIC, and the sUAS operations shall 

comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61 

and 91.
Intended Area of Operations

The sUAS shall not be operated over congested or densely populated areas. These 

areas include but are not limited to the yellow areas depicted on World Aeronautical 

Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts

(TAC). Each work site will also be evaluated based on local conditions.

Operations of sUAS may be conducted at distances less than 500 feet from participating 

persons, vessels, vehicles or structures that perform an essential function in connection 

with these special purpose operations. Operations closer than 500 feet from the PIC, 

VO, operator trainees and essential persons are permitted when operationally 

necessary; but never so close to present an undue hazard. This is consistent with 

Exemption No. 11138.

Operations of sUAS may be conducted at distances less than 500 feet from unoccupied 

vessels, vehicles or structures owned by the land owner/controller when the land 

owner/controller grants such permission, and the PIC makes a safety assessment of the

risk from operations and determines that it does not present an undue hazard to persons 

or property. This is consistent with Exemption No. 11138.

Flight operations will be conducted at least 500 feet from all nonparticipating persons 

unless barriers or structures are present that sufficiently protect nonparticipating persons 

from the sUAS and/or debris in the event of an accident. HAZON shall ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the sUAS, 

flight operations will cease immediately. This is consistent with Exemption No. 11138.

All operations of sUAS shall be conducted with the permission from the land 

owner/controller or authorized representative. Permission from the land owner/controller 

or authorized representative will be obtained for each flight to be conducted.

Airport Proximity

The sUAS will not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement with 

that airport’s management is obtained, and the operation is conducted in accordance 

with a NOTAM as required by the operator’s COA. The letter of agreement with the 

airport management will be made available to the Administrator upon request. This is 

consistent with Exemption No 11159.

Visual Line of Site

The sUAS must be operated within VLOS of the PIC and VO at all times. This requires 

the PIC to be able to use human vision to see the sUAS unaided by any device other 

than corrective lenses, as specified on the PIC’s FAA issued medical certificate.

All sUAS operations must utilize a VO. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC 

must be able to communicate verbally at all times. The PIC and VO must be designated 

before the flight and cannot transfer his or her designation for the duration of the 

flight. The PIC must ensure that the VO can perform the functions. 
The sUAS will not be operated by the PIC from any moving device or 

vehicle. Operations will not be conducted during night as defined in 14 CFR 1.1. 

PreFlight Safety (14 CFR § 91.7(b))

Aerial Impressions will conduct preflight safety risk assessments to determine that the 

sUAS is in a condition for safe flight (14 CFR Section 91.7(b)) and that the planned 

operation can be completed safely. Specific procedures are addressed in Aerial 

Impressions Operators manual pg.6

Flight Standards District Offices (FSDOs)

Aerial Impressions operations do not require a notification to Flight Standards District 

Offices (FSDOs). They will not be engaging in the type of sUAS that would warrant 

contact.

Certificate of Waiver or Authorization

Aerial Impressions shall obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this requested 

grant of exemption. Additionally, Aerial Impressions will request a Notice to Airmen 

(NOTAM) not more than 72 hours, but not less than 48 hours prior to the operation.

Weather

sUAS Operations will be conducted under visual meteorological conditions (VMC). The 

sUAS will not be operated less than 500 feet below or less than 2000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC. In additions 

fellow sUAS manufacturer's guidelines for weather operation limitations and standards. 

Section 5: Requested Exemptions from 

Regulations

Considered 

Regulation

Title Recommended Action

14 C.F.R Part 

21.185

Airworthiness 

Certificate

Aerial Impressions recommends that in consideration 

of the size, weight, speed and limited operating area 

associated with these aircraft and their operation, the 

Secretary of Transportation determines that these 

aircraft meet the conditions of Section 333. Relief is 

not necessary. 

14 C.F.R. Part 

45.23(b)

Display of marks Aerial Impressions sUAV shall be identified by serial 

number, registered in accordance with 14 CFR part 

47, and have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart 

C. Markings will be as large as practicable. 
Relief is not necessary.

14 C.F.R. Part 

61.113(a)

Private pilot 

privileges and 

limitations

The FAA has found in previous grants of exemption 

that a PIC with a private pilot certificate operating a 

sUAS would not adversely affect operations in the 

NAS or present a hazard to persons or property on 

the ground. Request relief with limitations and 

conditions specified in this petition.

14 C.F.R. Part 

61.133(b) 

Commercial pilot 

privileges and 

limitations

The FAA has found in previous grants of exemption 

that a PIC with a private pilot certificate operating a 

sUAS would not adversely affect operations in the 

NAS or present a hazard to persons or property on 

the ground. Request relief with limitations and 

conditions specified in this petition.

14 C.F.R. Part 

91.7(a)

Civil Aircraft 

Airworthiness

Aerial Impressions recommends that in consideration 

of the size, weight, speed and limited operating area 

associated with this aircraft and its operation, the 

Secretary of

Transportation determines that these aircraft meet the 

conditions of Section 333. Relief is not necessary.

14 C.F.R. Part

91.9(b)(2) &(c)

Civil Aircraft Flight 

Manual, Marking, 

and Placard 

Requirements

The FAA has previously determined that relief from 

these sections is not necessary. Relevant materials 

may be kept in a location accessible to the PIC in 

compliance with the regulations. Relief is not 

necessary.

14 C.F.R. Part 

91.103

Preflight Action Aerial Impressions will perform. Relief is not 

necessary.

14 C.F.R. Part 

91.109(a)

Flight 

Instruction

Aerial Impressions will conduct all flight training through 

procedures specified in Training Instruction during 

dedicated training sessions. Based on previous 

decisions made by the FAA for sUAS petitions regarding 

this regulation, relief is not necessary.

14 C.F.R. Part 

91.119(c)

Minimum Safe 

Altitude

Aircraft will be operated below 400 AGL, but not over 

congested areas. Request relief with limitations and 

conditions specified in this petition.

14 C.F.R. Part 

121

Altimeter 

Settings

The proposed aircraft have a barometric altimeter and 

GPS derived altitude capabilities. Aerial Impressions 

recommends that the altimeter be set to zero feet AGL 

rather than local barometric pressure or field altitude 

before flight. Considering the limited altitude of the 

proposed operations. Request relief with limitations 

and conditions specified in this petition.

14 C.F.R. Part Fuel Prior relief has been granted for manned and unmanned 
91.151(a) Requirements 

in VFR

aircraft to operate at less than prescribed 

minimums. Request relief with limitations and 

conditions specified in this petition.

14 C.F.R. Part 

91.203(a) and 

(b)

Certifications 

Required

Original intent of these regulations was to display an 

aircraft’s airworthiness, certification and registration 

documents so they would be easily available to 

inspectors and passengers. Based on the FAA 

Memorandum subject, “Interpretation regarding whether 

certain required documents may be kept at an unmanned 

aircraft’s control station,” dated August 8, 2014, relief is 

not necessary.

14 C.F.R. Part 

91.405(a)

Maintenance 

Required

Request relief with limitations and conditions 

specified in this petition.

14 C.F.R. Part

91.407(a)(1)

Operation after 

Maintenance

Request relief with limitations and conditions 

specified in this petition.

14 C.F.R. Part

91.409(a)(1) 

and (2)

Inspections Request relief with limitations and conditions 

specified in this petition.

14 C.F.R. Part 

91.417(a) and 

(b)

Maintenance 

Records

Request relief with limitations and conditions 

specified in this petition.

Protection of Rights and Privacy

UAS Pilot in Command, Gimbal Operators and Spotter or any other person involved 

in flight mission is to observer and privacy rights or expectations of the public. Any 

person involved in any unlawful flights that may jeopardize someone's privacy right or 

expectations will be held accountable for their actions. 

Public Interest

Aerial Impressions is a small local business supporting and promoting the 

safe and responsible implementation of sUAS into our national airspace 

(NAS). Aerial Impressions will offer local market an accredited sUAS option to 

aid in aerial imagery gathering. Aerial Impressions use small unmanned units 

that have the capacity to perform work that would require a full scale fixed 

winged aircraft and pilot, reducing risk to people and property. 

Conclusion 

In conclusion if granted relief for :14 CFR § 61.113(a) & (b) 14 CFR § 91.7(a) 14 CFR § 

91.119(c) 14 CFR § 91.151(a) 14 CFR § 91.405(a). Aerial Impression believes they can 

perform safe, efficient and responsible flight operations. Promoting legal flight 

operations solutions to ensure greater public safety and discouraging unlaw use. While 

lessen risk to pilots, property and civilians due to the implementation of lightweight small 

unmanned systems. 
Sincerely,

Todd Massey

Owner Operator

Aerial Impressions, LLC

414-899-8512

aerialimpressionsMKE@gamil.com