July 8, 2015

Christina Martinez

Precision Approach Aerial Photography LLC

15909 Elmwood Way

Apple Valley, MN 55124

Dear Mrs. Martinez:

This letter is to inform you that we are unable to process your request for an exemption from 

Title 14, Code of Federal Regulations (14 CFR). It explains why we can not process your 

request and what you should do in the next 30 days.

Why We Can Not Process Your Request

We entered your April 22, 2015 exemption request on behalf of Precision Approach Aerial 

Photography into the public docket (No. FAA-2015-1126), but we are unable to process your 

request any further. The information you sent does not comply with the requirements of

§ 11.81 (copy enclosed). For us to consider the request any further, you must send us all of 

the following:.

 The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole.

 The reasons why the exemption would not adversely affect safety or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which you 

seek an exemption.

 Any additional information, views, or arguments available to support your request.

What You Should Do

If you want us to process your request any further, you must send the information described 

earlier to reach us within 30 days. Please note that § 11.63(d) requires you to send your 

petition for exemption at least 120 days before the proposed effective date of the exemption.
2

If We Do Not Hear From You

If we do not hear from you within 30 days, we will close the docket without notifying you 

further. If you have any questions or require additional time, you may call (202) 267-9677.

Sincerely,

/s/

Brenda Robeson

Program Analyst, Airmen and 

 Airspace Rules Division

Enclosure
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Precision Approach Aerial Photography LLC - Exemption/Rulemaking

This Other document was issued by the Federal Aviation Administration (FAA)

For related information, Open Docket Folder 

Content

This is an exemption request pursuant to Section 333 of the FAA Reform Act of 2012 for Precision

Approach Aerial Photography LLC. Precision Approach Aerial Photography LLC requests to perform

aerial photography through the use of its small unmanned aircraft commercially in airspace regulated by

the FAA. The owner and pilot is a Certified Flight Instructor with a Bachelor of Science in Aeronautics.

Having firsthand knowledge of the National Airspace System gives Precision Approach Aerial

Photography an advantage in safely operating small UAS within our airspace.

Description of Petitioner

Christina Martinez is the owner of Precision Approach Aerial Photography LLC. Christina is a Certified

Flight Instructor and has vast experience operating in the National Airspace System. She has experience

flying RC Planes, blimps in indoor college hockey arenas, and small quad copters for pleasure.

Contact information:

Christina Martinez

15909 Elmwood Way

Apple Valley, MN 55124

paaerialphotography@gmail.com

952-412-3656

Exemptions

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 CFR 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 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)

Description of UAS and Equivalent Level of Safety

The primary UAS system that will be used is the DJI Phantom 3. The UAS will be safely operated in the

NAS by maintaining line of sight visual contact, flown only during daylight, and less than 400ft above the

ground. Flights will be operated at a lateral distance of no less than 100 feet from any persons or

property not associated with the operation. Additional safety features on the DJI Phantom 3 include

return to home functionality when GPS is available and failsafe technology that return the aircraft to the

takeoff point if batteries run low. 

The specifications for the UAS are as follows:

Weight: 1280 g

Diagonal Size: 590 mm 

Max Ascent Speed: 5 m/s

Max Descent Speed: 5 m/s

Max Speed: 16 m/s

Additionally, the max flight time for the UAS will be limited to maintain a reserve of 25% battery power.

At all times, the UAS will be operated in accordance with the safety and operational requirements of the

manual.

Comment Now!

ID: FAA-2015-1126-0001

Document Information

Date Posted:

Apr 22, 2015

Show More Details 

Submitter Information

Submitter Name:

Christina Martinez

Mailing Address:

15909 Elmwood Way

City:

Apple Valley

Country:

United States

State or Province:

MN

ZIP/Postal Code:

55124

Comments

0

Docket Information

This document is contained in

FAA-2015-1126

Related Dockets:

None

Related RINs:

None

Related Documents:

None

This count refers to the total

comment/submissions received on

this document, as of 11:59 PM

yesterday. Note: Agencies review all

submissions, however some

agencies may choose to redact, or

withhold, certain submissions (or

portions thereof) such as those

containing private or proprietary

information, inappropriate language,

or duplicate/near duplicate

examples of a mass-mail campaign.

This can result in discrepancies

Comments Received *

*
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UAS Operations

Preflight would include checking the operation of the UAS to include the battery in both the transmitter

and the UAS, the condition of the body of the UAS and its propellers. Updates to the firmware will be

done as they become available and maintenance will be performed pursuant to the manufacturers

recommendations. The area in which the drone will be flown will be checked for powerlines, antennas,

and other obstructions. The weather conditions will be monitored throughout the flight. Wind conditions

will be reviewed and the UAS will only be flown in daylight. As the pilot, Christina would ensure that she

is safe to operate the drone as she would if she were flying in the aircraft herself. 

The pilot will abide by the following currency and proficiency requirements:

The pilot will posses at least a private pilot certificate

The pilot will have a minimum of 25 hours total time as a UAS rotorcraft pilot

The pilot will have a minimum of 5 hours in the make and model utilized 

Conclusion

Precision Approach Aerial Photography, a small woman-owned business, would like to safely operate a

UAS aerial photography business. Having a Section 333 Exemption and entering into the NAS legally

would give the business a competitive advantage. The safe and compliant operations would discourage

illegal operations and improve the industry.

Thank you for your consideration.

Sincerely,

Christina Martinez

Owner/Pilot 

Precision Approach Aerial Photography LLC

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