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March 6, 2016

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and CFR Part 

11 of small Unmanned Air Aircraft Systems (UAS), Precision Aerial Imagery, LLC is requesting to be exempted 

from the Federal Aviation Regulations (FARs) contained herein in order to operate a UAS commercially in airspace 

regulated by the Federal Aviation Administration. These operations will be conducted within the guidelines and 

regulations established by the Federal Aviation Administration (FAA) and any terms of relief established and 

granted by the FAA’s approval of this request within the National Airspace System (NAS). 

Torrey Hogan (Partner of Precision Aerial Imagery, LLC) specializes in aerial photography and 

videography for real estate and private events. Precision Aerial Imagery, LLC will utilize FAA certified private pilot 

Jesse James Skeets (Private Pilot Certificate #3845108) for all aspects of aerial operation to include but not limited 

to (conducting briefings pertaining to UAS operations, aircraft maintenance including logs, flight logs, contacting 

authorities or airport facilities in order to ensure compliance with operations of the UAS). All UAS operations of 

Precision Aerial Imagery, LLC will be in accordance with all current governing UAS regulations as established by 

the FAA, as well as all provisions contained in the FAA’s Small UAS NPRM (FAA’s proposed Part 107).

The approval of this request would permit the operation of lightweight (less than 55 lbs. total take-off gross 

weight) UAS under supervised and controlled conditions for commercial use by a Certified Pilot. This would fulfill 

and add a level of safety to the Secretary of Transportation’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.
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The name and address of the applicant is:

Precision Aerial Imagery, LLC

Torrey Hogan (Partner)

Jesse Skeets (UAS Operator)

 4080 Forestview Ave

Concord, CA 94521

Phone: (760) 608-2773

Email: PreciseAerial@gmail.com

Precision Aerial Imagery, LLC respectfully requests to be granted exemptions to the following specific 

sections of the Title 14 Code of Federal Regulations allowing operations of lightweight UAS for commercial 

purposes:

14 CFR Part 21 14 CFR Part 45 14 CFR Part 61 14 CFR Part 91

Subpart H 45.23(b) 61.113(a),(b) 91.7(a)

91.9(b) (2)

91.103(b)

91.109

91.119

9.121

91.151(a)

91.203(a),(b)

91.405(a)

91.407(a) (1) 

91.409(a) (2)

91.417(a), (b)

The requested relief and exemptions would permit Precision Aerial Imagery, LLC to operate a UAS in a 

commercial service business in the NAS. These commercial services would consist of, but not limited to, operating

a registered DJI Phantom 3 Pro quad-copter to conduct aerial videography and photography of real estate, 

construction sites, inspections, special events, aerial survey, inventory assessments, and for marketing and/or 

advertising, Search and Rescue Operations when requested or approved by local authorities. These services are not 

limited to the above and may expand as the capabilities of UAS are realized. 

The UAS operates at speeds of less than 32 knots and has the capability to hover and move in a vertical and 

horizontal plane simultaneously. This operating speed is well below the proposed 87 knot limit. The UAS will be 

operated within the line-of-sight of the pilot within the protected flight area. The DJI Phantom Pro operates at a 

RC frequency of 2.4 GHz for both control and video play back and complies with FCC regulations. The UAS takes 
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high quality still and video digital images that will be used to provide data and photographic images for commercial 

customers. Additional examples of aerial photography may include constructions sites, roof inspections and aerial 

video/photography of sporting or special events or weddings. The use of the UAS for aerial inspections reduces the 

need to utilize conventional manned aircraft, manned lifting devices or manual climbing and provides very high

quality imagery at a fraction of the cost and increased safety. These types of UAS operations will benefit the public 

by reducing exhaust emissions, noise pollution, reducing setup and labor times in various occupational settings, 

increasing safety and other operational efficiencies. Precision Aerial Imagery, LLC will operate each UAS with a 

practice of safety. This means that our operator will operate the UAS in compliance with FAA regulations and any

stipulated exemptions with the utmost concern for safety. This type of policy will create a safe operational 

environment that will not create undo hazards to the other users of the National Airspace System (NAS) or the 

public in general.

Authority for Exemptions 

Precision Aerial Imagery, LLC submits this application to request exemptions as set forth by the 

Congressional Mandate in Section 333 of the Reform Act for the Commercial Use of UAS. The purpose of the 

Reform Act is to help safely introduce UAS into the National Airspace System (NAS). In making this 

consideration, the Secretary of Transportation is required to determine which types of UAS do not create a hazard 

to users of the NAS or the public, or pose a threat to national security in light of the following considerations:

- The UAS size, weight, speed and operational capability.

- Operation of the UAS in close proximity to airports and populated areas.

 - Operation of the UAS within visual line-of-sight of the operator.

Reform Act 333 (a). If the Secretary of Transportation determines that such vehicles “may operate safely in the 

National Airspace System, the Secretary shall establish requirements for the safe operation of such aircraft in the 

National Airspace System.”

Given the clear direction of Section 333 of the Reform Act and the authority contained in the Federal 

Aviation Act, as amended, the diminutive nature of the UAS that are utilized by Precision Aerial Imagery, LLC, 

combined with the safety protocols outlined below, will allow for a greater than equivalent level of safety which 

Congress had envisioned. Approval of the requested exemptions presents no national security issues and addresses 

all known safety concerns, thus offering the equivalent or greater level of safety suggested by the mandate. In 

addition, further significant benefits to the general public would be: enhanced safety, reduced emissions and noise 

versus the use of traditional aircraft, as well as, reducing the cost of aerial photography, all of which meet the intent 

of Reform Act 333. 
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Operation Procedures

The following protocols are to be used as standard operating practice of UAS for commercial purposes by 

Precision Aerial Imagery LLC:

1. The DJI Phantom 3 Pro quad-copter is registered with the FAA. Any UAS to be used by Precision 

Aerial Imagery LLC will comply with any registration requirements of the FAA.

2. Flights will be operated in the visual line-of-sight (VLOS) by the pilot in command.

3. Flights will only occur in daylight hours (official sunrise to official sunset, local time)

4. The UAS weight will be less than 55 lbs. at takeoff and during flight and landing.

5. Flights will be terminated with 25% of battery life remaining.

6. Flights will be operated at an altitude at or below maximum allowed altitude for that flight, primarily 

500 feet AGL within Class G airspace, unless required ATC permissions are obtained for operation 

within Class B, C, D, or E airspace. 

7. Maximum airspeed will be 100 mph (87 knots) 

8. Pilot, camera operators, and observers will be trained in accordance with the applicable portion of the 

UAS manual, as well as the Standard Operating Procedures.

9. Minimum UAS crew will be one licensed pilot with a current FAA medical. A camera operator and/or 

observer may be added as required to further reduce the possibility of task saturation by the pilot.

10. Pilot, observer, and camera operator will maintain real-time communication capability throughout 

flight operations.

11. The UAS Pilot will conduct a full-site survey to determine the Area of Responsibility (AOR). This 

AOR is the actual area for UAS operations for a particular day. Each survey will include the 

assessment of potential hazards to include, but not limited to: airspace classifications, temporary 

flight restrictions, closest airport proximity, natural and manmade obstacles, and unnecessary/nonparticipating persons which may pose a risk to operations or safety. If deemed necessary, the crew will 

employ additional personnel as safety observers.

12. A thorough briefing will be conducted, prior to the first flight of the day in an AOR, utilizing the 

briefing guide in the SOPs. Flights will be restricted to ceilings at or above 1000 ft. AGL and/or 

visibility of 3 statute miles or greater from center of AOR.

13. Operator will notify any persons who need to be within 100 feet of UAS flight operations.

14. Written and/or verbal permission from the relevant property owners will be obtained prior to flight.

15. All required permissions and permits would be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other governmental agencies.

16. If the UAS loses communications or loses its GPS signal, the UAS will have the capability to return to 

a pre-determined location within the AOR and land autonomously.

17. The UAS will have the ability to abort a flight in case of unpredicted obstacles or emergencies. 

18. A preflight inspection will be conducted prior to any operations and the UAS will be maintained in safe 

condition for flight operations. Precision Aerial Imagery LLC will retain a Maintenance log book to 

record all maintenance and modifications to the UAS. 

19. All flights will be electronically recorded and made available to the FAA upon request. 

20. The UAS will be marked with contact information and registration number.

21. All flights will follow all FAA proposed rules, including: no careless or reckless operation, PIC will 

not conduct flights if experiencing any physical or mental impairments.

22. Any accident that results in injury to property or persons will be reported within 10 days.

 
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Operator Certification and Responsibilities

Precision Aerial Imagery’s UAS Operator will be FAA certified Private Pilot Jesse Skeets. Jesse Skeets has 

been operating radio controlled aircraft for over 10 years and is currently a recreational private pilot. He has vast 

knowledge regarding aircraft maintenance, flight operations, and the development and implementation of Standard 

Operating Procedures (SOP) as well as checklists. Jesse Skeets will ensure each UAS system have a current SOP

and checklist to aid in all operational aspects to ensure a high level of safety. As previously stated, briefings will be 

conducted for anyone involved in the UAS flight in order to increase public safety and awareness. Any additional 

operators utilized will meet all requirements set forth by the FAA and the Standard Operating Procedures outlined 

within.

Description of Specific Regulations

4 CFR Part 21 Subpart H: Airworthiness Certificates 14 CFR 91.7(a), 91.203(a) (1)

Subpart H, entitled, “Airworthiness Certificates”, sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR 91.230(a) (1). The size, weight, and defined area of operations for 

Precision Aerial Imagery, LLC UAS flights permits exemption of Part 21 Subpart H, because Precision Aerial 

Imagery, LLC meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is 

authorized to exempt aircraft from the airworthiness certificate requirement under both 49 USC Section 44701 (f) 

and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS from the 

airworthiness certificate requirement in consideration of weight, size, speed, maneuverability and proximity to 

areas such as airports and dense populations. 

 As previously noted in #18 of Operation Procedures: A preflight inspection will be conducted prior to 

any operations, and the UAS will be inspected and maintained for safe operations. Precision Aerial 

Imagery, LLC will retain a maintenance log book to record all maintenance and modifications to the 

UAS. This meets or exceeds any airworthiness concerns under the Reform Act, and therefore, an 

exemption to these regulations should be granted.

14 C.F.R 91.203(a), (b) provides for carrying of civil aircraft certifications and registrations. They are 

inapplicable for the same reasons stated above. 

 The equivalent level of safety will be achieved by the aforementioned periodic maintenance and 

inspections and applicable manuals and log books to be kept in the possession of Precision Aerial 

Imagery, LLC. 

14 C.F.R 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. 

 As no such certificate will be applicable in the form contemplated by the FARs, this regulation is 

inapplicable. 

 
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14 CFR 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 the aircraft inspected as 

prescribed in Subpart E of this section and shall, between required inspections, except as prescribed 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.”

 These regulations only apply to aircraft with an airworthiness certificate. They will not apply to the 

UAS utilized by Precision Aerial Imagery, LLC, should its requested exemption be granted. 

 As an equivalent level of safety, all of Precision Aerial Imagery, LLC’s UAS operators will be required 

to conduct a preflight, through-flight, and post-flight inspection of the UAS to ensure its flight 

worthiness. Each UAS is flown in compliance with the applicable manufacturer’s manual to include all 

software update cycles as well as flight checklists. In the event of a malfunction, the UAS can land 

immediately either automatically or through manual control.

14 CFR 45.23 Marking of the Aircraft

Applicable Code of Federal Regulations require aircraft to be marked according to certain specifications. 

The UAS operated by Precision Aerial Imagery LLC are unmanned and do not have a cabin, cockpit, or pilot 

station on which to mark certain words or phrases. 

 Due to the size, two-inch lettering is impractical to place on such small aircraft. There will, however, 

be contact and registration information affixed to the aircraft’s exterior to allow identification of the 

aircraft.

14 CFR 61.113 (a), (b) Private Privileges and Limitations: Pilot in Command

Unlike civil aircraft, the UAS does not carry living things on board; rather, it is controlled remotely via a 

safe and restricted location. 

 Precision Aerial Imagery, LLC requests relief in order to facilitate the utilization of pilots, who hold a 

PRIVATE PILOT (or greater) certificate. Any pilots operating under this exemption would be required 

to comply with any conditions as set forth and in a similar fashion to previously granted exemptions.
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14 CFR 91.9(b) (2) Civil Aircraft Flight Manual in the Aircraft

14 CFR 91.9(b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, 

and given the size of the UAS, this regulation is inapplicable. 

 An equivalent level of safety will be achieved by maintaining an Operator’s Manual at the operations 

center. The FAA has previously issued exemptions to this regulation.

14 CFR 91.103(b) Preflight actions

Each Pilot in Command shall, before beginning a flight, become familiar with all available information 

concerning that flight. This information must include: (b) For any flight, runway lengths at airports of intended 

use, and the following takeoff and landing distance information: 

 This subparagraph is not applicable due to our off-airfield operation.

14 CFR 91.109 Flight instruction: Simulated instrument flight and certain flight tests

14 CFR 91.109 and all subparagraphs address the operation of a civil manned aircraft in conjunction with 

the training and flight tests. 

 The UAS to be utilized by Precision Aerial Imagery, LLC are not designed in this category.

14 CFR 91.121 Altimeter Settings

14 CFR 91.121 regarding altimeter settings is inapplicable.

 Precision Aerial Imagery, LLC’s UAS utilize GPS systems and internal gyroscopes to provide spatial 

stability and reference datum.
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14 CFR 91.151 Fuel Requirements for Flight in VFR Conditions

14 C.F.R 91.151 (a) states “No person may begin 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 battery powering the UAS provides approximately 23 minutes of powered flight, which is less than 

the reserve requirement alone by FARs for day or night VFR flight. Given the limitations on the UAS 

flight envelope, proposed AOR size, battery life and its ability to land immediately, it is reasonable to 

allow an exception to this regulation.

 An equivalent level of safety can be achieved by limiting flights to 25% of battery power. This 

restriction would be more than adequate to return the UAS to its planned landing zone in the AOR.

14 CFR 91.119 Minimum Safe Altitudes

14 CFR 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be 

operated at lower altitudes in certain conditions. 

 Precision Aerial Imagery, LLC will normally operate the UAS at or below 500’ AGL. In situations 

involving obstacles, i.e. buildings, towers, natural obstructions, the UAS will be operated at 

altitudes that maintain a level of safety above those objects that are not directly associated with the 

service being performed. Precision Aerial Imagery, LLC will operate a UAS only in a defined 

AOR that has been carefully reviewed for hazards and minimizes the presence of any person not 

essential for operations. 

 The equivalent or higher level of safety will be achieved given the size, weight, speed, and fuel 

characteristics of the UAS, as well as, the location and size of its operating area. 

Summary

Precision Aerial Imagery, LLC is seeking exemption from the following rules: 14 CFR 21 

Subpart H, 14 CFR 45.23 (b), 14 CFR 61.113 (a),(b), 14 CFR 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).

Approval of the above exemptions allowing commercial operations of small UAS in the service of aerial 

photography will greatly enhance safety by reducing the overall risk associated with traditional aircraft. Traditional 

aerial photography requires large aircraft weighing thousands of pounds and carrying hundreds of pounds of fuel 

presenting a significant risk to life and property. The use of a small UAS weighing less than 55 lbs., powered by 

batteries and operating at altitudes at or below 500’ AGL will greatly minimize the risks associated with traditional 

aerial photography. Precision Aerial Imagery’s UAS Operator Jesse Skeets has the qualifications, knowledge, and 

skills necessary to meet and exceed the provisions being proposed in the FAA’s Small UAS NPRM, and the intent 
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of the Reform Act of 2012. Precision Aerial Imagery LLC respectfully requests that the FAA grants these 

exemptions without delay. 

Very Respectfully,

Precision Aerial Imagery, LLC

Torrey Hogan (Partner)

Jesse Skeets (UAS Operator)

4080 Forestview Ave 

Concord, CA 94521

(760) 608-2773

PreciseAerial@gmail.com