U.S. Department of Transportation, DocketOperations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, S.E.

Washington, DC 20590

Application/Petition for

Section 333 Exemption

June 18, 2015

Petitioner:

Valley Aerial Imaging, LLC

Joshua S. Belile, CEO A&P# 3343863

1001 E. Fern Ave Apt B212

McAllen, TX 78501

Cell: 337-244-2732

Email: joshbelile@gmail.com

Greetings,

I am submitting this petition for exemption pursuant to Section 333; FAA Modernization 

and Reform Act of 2012, Public Law 112-95 FEB. 14, 2012, Section 333.

I request this exemption in order to operate my UAV/UAS, DJI Phantom 3 Professional 

Quadcopter Aircraft, and my Yuneec Q500+ Professional Quadcopter Aircraft in order to 

provide services for profit to include aerial photography, aerial cinematography, aerial filming 

and photography for real estate, construction firms, agricultural modeling, crop monitoring 

operations, aerial mapping, special events to included but not limited to weddings, private or 

public parties/events, business advertising, promotional events, geological surveying, and 

environmental studies. 

The ability to provide these services to other local businesses and individuals in my 

community will benefit them by opening up opportunities they otherwise did not have before. 

Traditional methods of aerial photography/videography are simply not viable options for the 

average consumer as they are costly and involve greater risks to everyone involved; i.e. the use 

of larger aircraft carrying humans and flammable fuel. By utilizing the UAV/UAS the same 

results can be achieved with much safer conditions.

Prior to each flight/operation of the UAV/UAS, I will conduct a Pre-Flight Safety 

Inspection. Any and all repairs will be performed only by the manufacturer's authorized repair 

facilities/ providers. Flights will not take place over densely populated areas or private property 

without the owners' permission. The UAV/UAS will only be operated within visual line of sight 

and will not be flown near airports or above 400 feet.

I have been involved in American aviation for greater than thirteen years. Beginning in 

2002 when I enlisted into the U.S. Marine Corps as a UH-1N and AH-1W (Huey/Cobra) 

Sheetmetal and Hydraulics mechanic (MOS 6154) serving both on American soil and overseas 

for two combat deployments in Iraq. My current full time position is fulfilling maintenance 

services as an A&P mechanic for the U.S. Customs and Border Protection here in McAllen, TX 

at the Office of Air and Marine. My daily duties require that I put aviation safety in the 

forefront of my mind at all times. I fly with the pilots to perform main rotor blade tracking and 

balancing, and I am also a flight mechanic in times where in-air diagnostics are a mandatory 

step in determining an issue and solving the problem. These experiences in the past thirteen 

years have provided me the unique perspective of both Pilot and Mechanic, and I have safety for 

the American people and American airspace as my most paramount of concerns. I place these 

same ideals of safety and professionalism into the body of my employees and my company,

Valley Aerial Imaging.
The specific sections of 14 C.F.R from which I am seeking exemption are as follows:

14 C.F.R. Part 21; CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS

14 C.F.R. 45.23(b); Display of marks; general.

14 C.F.R. 61.101(e)(4), & (5); Recreational pilot privileges and limitations.

14 C.F.R. 61.113(a) & (b); Private pilot privileges and limitations: Pilot in command.

14 C.F.R. 61.133 (a); Commercial pilot privileges and limitations.

14 C.F.R. 61.23(a) & (c); Medical certificates: Requirement and duration.

14 C.F.R 91.7(a); Civil aircraft airworthiness.

14 C.F.R. 91.9(b)(2); Civil aircraft flight manual, marking, and placard requirements.

14 C.F.R. 91.109(a); Flight instruction; Simulated instrument flight and certain flight tests.

14 C.F.R. 91.103; Preflight action.14 C.F.R. 91.119; Minimum safe altitudes: General.

14 C.F.R. 91.121; Altimeter settings.

14 C.F.R. 91.151(a); Fuel requirements for flight in VFR conditions.

14 C.F.R. 91.203(a) & (b); Civil aircraft: Certifications required.

14 C.F.R. 91.405(a); Maintenance required.

14 C.F.R. 91.407(a)(1); Operation after maintenance, preventive maintenance, rebuilding, or 

alteration.

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

14 C.F.R. 91.417(a) & (b). Maintenance records.

Specifications of the DJI Phantom 3 (“P3”)

Gross weight: P3=1280g

Diagonal Size (including propellers): P3=590mm

Maximum Ascent Speed: P3=5m/sec

Maximum Descent Speed: P3=3m/sec

Vertical Hover Accuracy: P3=+/-10cm

Horizontal Hover Accuracy: P3=+/-1m

Maximum Speed: P3=16m/sec

Specification of the Yuneec Q500+ "Typhoon"

Q500 Height: 210mm (8.3 in)

Length (without rotor blades): 420mm (16.5 in) 

Width (without rotor blades): 420mm (16.5 in) 

Diameter (without rotor blades): 565mm (22.2 in) 

Propeller/Rotor Blade Diameter: 330mm (13.0 in) 

Weight (without battery and payload): 1130g (40.0 oz) 

Takeoff Weight (with battery and CGO2-GB): 1700g (60.0 oz) 

Battery: 5400mAh 3S 11.1V LiPo 

Flight Time: 20-25 minutes

Thank you very much for your time and consideration of this important request. Please advise 

us if any additional information is required.

Respectfully,

Joshua S. Belile A&P# 3343863

CEO, Owner

Valley Aerial Imaging