Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Aerial Services of Central Florida, LLC

James Partin, Owner

4209 Isle Vista Avenue

Belle Isle, FL 32812

407-592-6232

aerialservicesofcfl@gmail.com

July 1, 2015

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 of the Federal Aviation

Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21 subpart H; 14 C.F.R. 

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:

This petition is being submitted on our own behalf without legal council or consulting 

services.

Aerial Services of Central Florida (“ASoCFL”) writing pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 and the procedures contained within 14 

C.F.R.Part 11, to request that ASoCFL, an owner and operator of small unmanned 

aircraft, be exempted from the FederalAviation Regulations (“FARs”) listed above so 

that ASoCFL may legally operate small light weight unmanned aircraft systems

(“UAS”) commercially in airspace regulated by the FederalAviation Administration 

(“FAA”). ASoCFL humbly and respectfully requests exemption of the above noted 

Federal Aviation Regulations so that it (ASoCFL) can legally offer the following 

services:

1. Aerial photography and/or video for public and/or private use including 

real estate, architecture, construction, land surveying, land mapping, land 

acquisition, crop surveying, engineering and other related professional

activities.

2. Aerial video and/or photography for public and/or private use including 

television, public events, cinematography and newsgathering.

3. Aerial inspection/photography of residential/commercial structures under

contract with the owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure 

including but not limited to electrical power lines, wind turbines, and cell 

towers.
Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

5. Aerial video/photography or providing live video feed to assist with search

and rescue operations in cases of an emergency or natural disaster only

when the local authorities or government has requested it by contract or

donation.

6. The ability to offer training to persons individually or belonging to both

private and or public organizations that have interests in the use and

application of UAS for the purpose of the safe operation of UAS to

enhance the safety of the National Airspace System (NAS) as well as

for the protection of the persons and property.

As described in more detail below, the requested exemption would authorize the 

operation of small lightweight UAS under controlled conditions in airspace that is 1) 

limited 2) predetermined 3) controlled as to access and 4) would provide safety 

enhancements to the safe operational protocols that will be followed by ASoCFL. 

Approval of this exemption would thereby enhance safety (by reducing emissions, 

noise, and the potential large scale accidents single engine planes and helicopters 

could and would cause) 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 Petitioner:

Aerial Services of Central Florida, LLC

Attention: James Partin, Owner

4209 Isle Vista Ave., 

Belle Isle, FL 32812

Phone: 407-603-1235

Email: aerialservicesofcfl@gmail.com

Regulations from which the exemption is requested:

14 CFR 45.23 (b)

14 CFR Part 21 subpart H

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)
Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

Introduction

ASoCFL is based in Orlando, Florida. As the owner of ASoCFL I possess more 

than 10 years of extensive RC experience and flight hours as a pilot of hobby grade 

helicopters, quad copters, and hexi-copters, for recreational purposes. ASoCFL will 

employ the use of a professional level UAS known as the DJI Inspire 1, a hobby 

grade UAS known as the DJI Phantom 2, and the prosumer level DJI Phantom 3

with intent to offer commercial services upon approval from the FAA. ASoCFL 

requests permission to offer the following services: 1. Aerial photography and/or

video for public and/or private use including real estate, architecture,

construction, land surveying, land mapping, land acquisition, crop surveying, 

engineering and other related professional activities. 2. Aerial video and/or

photography for public and/or private use including television, public events, 

cinematography and newsgathering. 3. Aerial inspection/photography of

residential/commercial structures under contract with the owners or local

government authority. 4. Aerial inspection/photography of residential/commercial 

utility infrastructure including but not limited to electrical power lines, wind turbines, 

and cell towers. 5. Aerial video/photography or providing live video feed to assist

with search and rescue operations in cases of an emergency or natural disaster

only when the local authorities or government has requested it by contract or

donation. 6. The ability to offer training to persons individually or belonging to

both private and or public organizations that have interests in the use and

application of UAS for the purpose of the safe operation of UAS to enhance the

safety of the National Airspace System (NAS) as well as for the protection of the

persons and property. ASoCFL intends to offer services to industries such as real

estate professionals, home builders, land brokers, land developers, construction 

companies, communication tower inspection, news, television, motion picture 

companies, farmers, and other industries as will be revealed by the natural passing 

of time and the rapidly maturing UAS technologies following exemption and 

approval by the FAA.

In support of this petition ASoCFL provides hyperlink’s to User Manuals for the DJI 

Inspire 1, DJI Phantom 2, and DJI Phantom 3.

Aerial Services of Central Florida’s Proposed Operations Do Not Create 

Significant Risks or Hazards

The exemption request would authorize operation of the below-illustrated ultra

lightweight UAS(s) in tightly controlled and limited airspace. All instances for hire 

would take place at predetermined areas away from general public, airports, 

heliports, vehicular traffic, and within property boundaries of the hirer with their 
Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

expressed verbal and or written consent. In addition to following the FAA’s 

Conditions and Limitations, ASoCFL has adopted safety protocols and controls to 

avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe by 

following a self-imposed process detailed later herein.

The proposed commercial use of UAS(s) as compared to commercial use of 

manned single engine planes, helicopters, and not to mention manned climbing for

tower inspections offers a significantly safer alternative to the health and welfare of 

the public. In a Presidential Memorandum published February 15, 2015; President 

Obama said in part, “As compared to manned aircraft, UAS may provide lower-cost 

operation and augment existing capabilities while reducing risks to human life. 

Estimates suggest the positive economic impact to U.S. industry of the integration 

of UAS into the NAS could be substantial and likely will grow for the foreseeable 

future.”

The UAS’s:

Each of the UAS outlined below includes a GPS mode that allows the UAS to hover

in place if communication is lost and will subsequently return back to its launched

position or “Home” position. In addition; when the UAS reaches 25% of usable battery 

power, the PIC will return the UAS to it’s Home position, if necessary the on board 

computer will return the UAS automatically.

UAS-1: Inspire 1 by DJI

The professional level UAS-1 known as the Inspire-1 by DJI is equipped with a 4K 

camera which is capable of shooting up to 4K video and capture up to 12 megapixel 

photos weighing less than seven pounds. If needed please see the attached 

Inspire 1 manual for additional specs.
Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Model T600

Weight (Battery Included) 2935 g

Hovering Accuracy (GPS Mode) Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (ATTI mode, no wind)

Max Flight Altitude 4500 m

Max Wind Speed Resistance 10 m/s

Max Flight Time Approximately 18 minutes

Motor Model DJI 3510

Propeller Model DJI 1345

Indoor Hovering Enabled by default

Operating Temperature Range -10° to 40° C

Diagonal Distance 559 to 581 mm

Dimensions 438x451x301 mm

Supported DJI Smart Battery

UAS-2: Phantom 2 by DJI

The hobby grade UAS-2 known as the Phantom 2 by DJI is capable of shooting up 

to 4K video and capture up to 12 megapixel photos utilizing a GoPro 3 HERO 

camera all weighing less than three pounds. If needed please see the attached 

Phantom 2 manual for additional specs.
Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Weight (Battery & Propellers) 1000g

Hover Accuracy (Ready To Fly) Vertical: 0.8m;

Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle 35°

Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s

Max Flight Speed 15m/s(Not Recommended)

Diagonal Length 350mm

Flight Time 25mins

Take-Off Weight ≤1300g

Operating Temperature -10°C ~ 50°C

Supported Battery DJI Smart Battery

UAS-3: Phantom 3 by DJI

The prosumer grade UAS-3 known as the Phantom 3 by DJI is equipped with a 4K 

camera which is capable of shooting up to 4K video and capture up to 12 megapixel 

photos weighing less than three pounds. If needed please see the attached 

Phantom 3 manual for additional specs.

Weight (Battery & Propellers) 1280g

Hover Accuracy (Ready To Fly) Vertical: 0.1m;

Horizontal: 1.5m

Max Ascent / Descent Speed Ascent: 5m/s; Descent: 3m/s

Max Flight Speed 16m/s(ATTI mode, no wind)

Diagonal Length 590mm (including propellers)

Flight Time 23mins

Take-Off Weight ≤1300g

Operating Temperature 0°C ~ 40°C

Supported Battery DJI Smart Battery
Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Self-Imposed Safety Protocols and Controls

Aerial Services of Central Florida will fully and voluntarily adhere to the safety 

guidelines set forth by FAA Policy N 8900.227 Section 14 "Operational 

Requirements for UAS” with the appropriate exemptions for flying a small UAS.

1. No flight will be made with a UA Gross weight exceeding 20 pounds.

2. Flights will be operated at an altitude of no more than 400 feet Above Ground

Level (AGL) and not more than 200 feet above an elevated platform from which

filming is planned.

3. Operations will be restricted to flights over private property with the permission of 

the written and/or oral permission of the property owner.

4. The owner/operator will file FAA Form 7711-1, or its equivalent, as modified in

light of the requested exemption, with the appropriate local Flight Standards

District Office (FSDO) no more than 72 hours but no less than 48 hours from

planned operation.

5. The PIC and VO will have been trained in operation of UAS and receive up-todate information for the particular UAS to be operated.

6. A briefing will be conducted in regard to the planned UAS operations prior to 

each day's production activities. It will be mandatory that all personnel who will be 

performing duties within the boundaries of the safety perimeter be present for this 

briefing.

7. The owner/operator will obtain verbal and or written consent of all persons

involved with the planned operation and ensure that only consenting persons will

be allowed within 100 feet of the flight operation, and the radius may be reduced

to 30 feet based upon an equivalent level of safety determination. With the

advanced permission of the FSDO, operations at closer range may be approved.

8. Maximum flight time for each operational flight will be 25 minutes. Flights will

be terminated at 25% battery power reserve.

9. The UAS will not be operated within 5 NM of an airport or heliport.

10. Operations will be restricted to daytime only and weather conditions equivalent 

to VFR.

11. Minimum crew for each operation will consist of the UAS Pilot and at least one

Visual Observer (VO), and may include a third, but separate, Camera Operator

(CO).
Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

12. The PIC will brief the property owner about the operation and risk before the 

first flight at each new location.

13. No operation will take place without both a fully charged battery and a PreFlight Inspection by the PIC to establish the UAS is in condition for safe flight.

14. The PIC and VO will be able to communicate by voice, or radio at all times.

15. If the UAS loses communications with the remote controller or loses GPS

signal, the UAS will have the capability to return to a pre-determined location

within a designated location and land autonomously.

16. The UAS will have the capability to abort a flight in case of

emergencies with an automated “Return Home and Land” function.

17. The UAS will have the capability to abort a flight in case of unpredicted

obstacles, weather, or emergencies such as low battery.

The protocols as outlined above, are the minimum guidelines ASoCFL will obey.

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 petitioner, 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 (49 U.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 airworthiness certificate without 

the restrictions and conditions proposed. The UAS to be operated hereunder is less 

than 20 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive 

materials or flammable liquid fuels, and operates exclusively within a secured and 

designated area. Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by both the operator and under the requirements 

and in compliance with local public safety requirements. These safety 

enhancements 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, 
Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

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 the cabin, cockpit or pilot station on which the word “Experimental” can 

be placed. Given the size of the UAS, two-inch lettering will be impossible. The 

word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). 

US Department of Transportation February 20, 2015 The equivalent level of safety 

will be provided by having the UAS marked on its fuselage as required by §45.29 (f) 

where the pilot, observer and others working with the UAS will see the identification 

of the UAS as “Experimental.”

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in 

Command. Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private 

pilot certificate may act as a pilot in command of an aircraft that is carrying 

passengers or property for compensation or hire. The proposed UAS operations 

may achieve an equivalent level of safety as achieved by current Regulations 

because the petitioner’s UAS(s) do not carry any pilots or passengers or property. 

The risk associated with the operation of a UAS is far less than the risk levels 

inherent in the commercial activities outlined in 14 CFR 61.

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 for maintenance and use of safety checklists prior to each flight, 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 UAS, 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 PIC flying the UAS will have 

immediate access to it.
Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

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. The PIC will take all actions as outlined above; including but not 

limited to a thorough pre-flight inspection of the UAV, 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 functioning dual controls. UAS and remotely 

piloted aircraft, by their design 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. The equivalent level of safety is provided by the 

fact that neither a 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 UAS that is a helicopter and the exemption requests 

authority to operate at altitudes up to 400 AGL, or not more than 200 above an 

elevated platform from which filming is planned, an exemption may be needed to 

allow such operations. As set forth herein, the UAS will never operate at higher than 

400 AGL with the exception that in circumstances where the UAS is used to survey 

or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be 

operated more than 200 feet above the highest point on the structure. It will 

however be operated in a restricted area with security perimeter, where buildings 

and people will not be exposed to operations without their previous 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 or local officials. Because of the advance notice to 

the property owner and participants in the filming activity, all affected individuals will 

be aware of the planned flight operations. Compared to flight operations with aircraft 

or rotorcraft weighting far more than the maximum 55lbs. 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 addition, the low- altitude operations of the UAS will ensure separation between 

these UAS operations and the operations of conventional aircraft that must comply 

with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings. 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 
Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

available before departure.” As the UAS may not have a barometric altimeter, but 

instead a GPS altitude read out, an U.S. exemption may be needed. An equivalent 

level of safety will be achieved by the operator, pursuant to the safety check list and 

live flight data monitoring, 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 petitioner believes that an 

exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. 

Operating the UAS in a tightly controlled area where only people and property 

owners or official representatives who have signed waivers will be allowed does not 

produce the type of risks that Section 91.151(a) was intended to alleviate given the 

size and speed of the small UAS. The petitioner believes that an equivalent level of 

safety can be achieved by limiting flights to 25 minutes or 25% of battery power —

whichever happens first. This restriction would be more than adequate to return the 

UAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. §91.203 (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 required by paragraph (a) of this 

section; or a special flight authorization issued under §91.715 is displayed at the 

cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully 

loaded weighs well under the proposed 20-lb. limit and is operated without an 

onboard pilot. As such, there is no ability or place to carry certification and 

registration documents within or on the UAS to display them as contemplated. An 

equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the PIC flying the UAS will have immediate access to 

them, to the extent they are applicable to the UAS.

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 (c) 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 petitioner. Routine maintenance will be accomplished 

by the owner/operator pursuant to the flight manual and operating handbook. An 

equivalent level of safety will be achieved because the UAS is very limited in size 

and will carry a small payload and operate only in restricted areas for a limited 

period of time. If mechanical issues arise the UAS can land immediately and will be 
Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

Aerial Services of Central Florida, Orlando, FL – Section 333 Exemption Petition

operating from no higher than 400 feet AGL. The PIC 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 PIC 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. An equivalent level of safety will be achieved 

because maintenance and inspections will be performed in accordance with the 

UAS Manufacturer's User Manual. As outlined above, the PIC will ensure that the 

UAS is in working order by completing the pre-flight inspection of the UAS prior to 

initiating flight and will perform required maintenance needed.

Summary:

ASoCFL will not operate UAS(s) near airports, the locations where ASoCFL will 

conduct it’s services will be both limited and predetermined, which will allow for a 

controlled environment to operate safely while greatly reducing risk. By allowing 

ASoCFL to conduct business with a UAS, it will help the Central Florida economy 

and benefit many other industries including private citizens to market their homes;

that have not been able to afford to do so prior to UAS technologies. Furthermore, 

ASoCFL’s UAS’s are considerably lighter than the alternative which could be a 

helicopter or small plane carrying explosive flammable fuels. ASoCFL employs the 

use of UAS’s, which will operate up to 25 minutes powered by a battery. Therefore, 

the UAS’s used by ASoCFL will typically have a flight time of 10-15 minutes at one 

time, as most photos and video are easily obtained in this flight time window. The 

likelihood of injury or even death with a small UAS compared to a large manned 

aircraft is greatly reduced.

Granting Aerial Services of Central Florida’s request for exemption comports with 

the Secretary of Transportation’s (FAA Administrator’s) responsibilities and 

authority to not only integrate UAS's into the national airspace system, but to 

“...establish requirements for the safe operation of such aircraft systems [UAS's] in 

the national airspace system” under Section 333(c) of the Reform Act specific to the 

use of UAS's as proposed herein. Further, ASoCFL will conduct operations in full 

compliance with the protocols described herein or as otherwise established by the 

FAA.

Please contact me should any additional information be required to satisfy an 

approval.

Sincerely,

James D. Partin

1 Appendix-A – DJI Inspire 1 User Manual

2 Appendix-B – DJI Phantom 2 User Manual

3 Appendix-C – DJI Phantom 3 User Manual