# 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 No t Process Your Request We entered your April 22, 2015 exemption request on behalf o f 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 no t 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 reques t.

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 th e proposed effective date of the exemption.

# 2

If We Do No t 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/ B renda Robeson Program Analyst, Airmen and Airspace Rules Division

EnclosureRegulations.gov - Other Document

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## Precision Approach Aerial Photography LLC - Exemption/Rulemaking

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# 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

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### 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 between this count and those displayed when conducting searches on the Public Submission document type. For specific information about an agency’s public submission policy, refer to its website or the Federal Register document.

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