National Association of Expert Advisors

3011 Internet Blvd Ste 116

Frisco, TX 75034

December 14, 2015

U.S. Department of Transportation

Federal Aviation Administration

Docket Operations, M-30

1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor

Washington DC 20590

Re: Petition of NAEA Inc. for an Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 to Operate Unmanned Aircraft Systems for 

Aerial Cinematography, Photography and Data Collection

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform

Act”) And 14 C.F.R. Part 11, National Association of Expert Advisors, Inc. (“Applicant”), hereby 

applies for an exemption from the Federal Aviation Regulations identified below to allow for the 

commercial operation of the UASs described below for aerial cinematography, photography and 

data collection.

Applicant requests that the FAA review this petition pursuant to its “summary grant” process as 

the FAA has already granted exemptions similar in all material respects to this petition. See FAA 

Grant of Exemption Nos. 11062, 11109, 11112 and 11213. The reasons stated by the FAA in 

granting the exemptions listed above also apply to this petition, and the grant of this petition is in 

the public interest. 

I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED 

Applicant requests exemption from the following regulations: 

• 14 C.F.R. Part 21, Subpart H; 

• 14 C.F.R. Part 27; 

• 14 C.F.R. § 45.23 (b); 

• 14 C.F.R. § 45.27 (a); 

• 14 C.F.R. § 61.113; 

• 14 C.F.R. § 91.7 (a); 
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• 14 C.F.R. § 91.9 (b) (2); 

• 14 C.F.R. § 91.9 (c); 

• 14 C.F.R. § 91.103; 

• 14 C.F.R. § 91.109 (a); 

• 14 C.F.R. § 91.119; 

• 14 C.F.R. § 91.121; 

• 14 C.F.R. § 91.151 (a) & (b) 

• 14 C.F.R. § 91.203 (a) & (b); 

• 14 C.F.R. § 91.405 (a); 

• 14 C.F.R. § 91.407 (a) (l); 

• 14 C.F.R. § 91.409 (a) (2); 

• 14 C.F.R. § 91.417 (a) & (b). 

II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS 

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. 

Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft 

systems into the national airspace system.” Pursuant to Section 333 of the Reform Act, the FAA 

Administrator is to permit operation of an unmanned aircraft system (“UAS”) where it does not 

create a hazard to users of the national airspace system (“NAS”) or the public or pose a threat to 

national security based on the following considerations: 

• The size, weight, speed and operational capability; 

• Operation in proximity to airports and populated areas; and 

• Operation within visual line of sight of the operator. 

The Federal Aviation Act grants the FAA Administrator authority to grant exemptions from the 

agency’s safety regulations and minimum standards when the Administrator decides an 

exemption is in the public interest. See 49 U.S.C. §§ 106(f), 44701-44716, et seq. 

III. CONTACT INFORMATION FOR APPLICANT

Applicant’s address is listed below.

National Association of Expert Advisors, Applicant

3011 Internet Blvd. Ste. 116, Frisco, TX 75034

Co-founders: Jay Kinder & Michael Reese

(972) 668-5090

marketing@naea.com

IV. DESCRIPTION OF PROPOSED OPERATIONS

NAEA, Inc. is a real estate association. Applicant is requesting exemptions from applicable 
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Federal Aviation Regulations (FARs) pursuant to Section 333 of the Reform Act for aerial 

cinematography, photography and data collection. UASs offer the real estate industry an 

innovative and safer option for filming. This new tool for marketing and promotional purposes 

will allow for creative and exciting aerial shots, and is the latest in a myriad of new technologies 

being used by the industry to further enhance the consumer experience. 

This type of aerial imagery and data collection will be performed by rotorcraft aircraft. Use of a 

UAS will greatly reduce safety risks because the UAS will not carry flammable fuel or a pilot, 

and operations can be performed at considerable savings and allow for better imagery.

The UASs operated by Applicant weigh less than 55 pounds, including all payload. They operate 

at speeds less than 87 knots, can hover, and can simultaneously move in multiple directions. In no 

case will the UAS be operated at airspeeds greater than the maximum operating airspeed 

recommended by the aircraft manufacturer. 

A. Aircraft to be Operated

Applicant intends to operate the UASs identified below (together, the “Aircraft”). This petition 

incorporates the material contained in the Manufacturer’s Manuals (together, the “Manuals”).1

Each UAS is more fully described in its User Manual. (See Footnote 1.)

1. Freefly Alta

Applicant will operate the Freefly Alta. The FAA has already approved use of the 

Alta in FAA Exemption No. 12428 (Docket No. FAA-2015-1945).

2. DJI Spreading Wings S1000+

Applicant will operate the DJI Spreading Wings S1000+. The FAA has already 

approved use of the Spreading Wings S1000+ in FAA Exemption No. 13551 (Docket 

No. FAA-2015-2803).

3. DJI Inspire 1

Applicant will operate the DJI Inspire 1. The FAA has already approved use of the 

Inspire 1 in FAA Exemption No. 12411 (Docket No. FAA-2015-2186).

4. DJI Phantom 3

Applicant will operate the DJI Phantom 3. The FAA has already approved use of the 

Phantom 3 in FAA Exemption No. 11696 (Docket No. FAA-2015-0746). 

5. DJI Phantom 2

Applicant will operate the DJI Phantom 2. The FAA has already approved use of the 

Phantom 2 in FAA Exemption No. 13551 (Docket No. FAA-2015-2803). 

1

The Freefly Alta Manuals are publically available at http://freeflysystems.com/software-manuals

The DJI Spreading Wings S1000+ Manuals are publically available at http://www.dji.com/product/spreading-wingss1000-plus/download

The DJI Inspire 1 Manuals are publically available at http://www.dji.com/product/inspire-1/download

The DJI Phantom 3 Manuals are publically available at http://www.dji.com/product/phantom-3/download

The DJI Phantom 2 Manuals are publically available at http://www.dji.com/product/phantom-2/download
4

B. Applicant’s Proposed Operations Demonstrate an Equivalent Level of Safety

1. General Description of Proposed Flight Operations

Applicant proposes to operate within the limitations and performance specifications 

listed in this application and in the Manuals. These limitations provide for at least and 

equivalent, or higher, level of safety for operations under the current regulatory 

structure because the proposed operations are safer than conventional operations 

using helicopters or fixed wing aircraft which carry an operator and flammable fuel. 

The proposed flight operations are similar in all material respects to operations 

already approved by the FAA and are therefore subject to the FAA’s “summary 

grant” process.

The proposed operations do not crate any hazard to users of the NAS or pose a threat 

to national security. The Aircraft are battery operated with a maximum flight time of 

less than 25 minutes. The Aircraft weigh less than 55 pounds. The Aircraft will be 

operated at or below 400 feet AGL within the Visual Line of Sight (VLOS) of the 

Pilot in Command (PIC). The UAS operations will be over private or controlled 

access property with the permission of the owner/controller or authorized agent. 

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or 

accident. The proposed UASs carry no fuel, and therefore the risk of fire following 

an incident or accident due to fuel spillage is eliminated. Compared to manned 

aircraft, the UASs being operated by the Applicant reduces the risk to participating 

persons in close proximity to the Aircraft due to the limited size, weight, operating 

conditions, and design safety features. 

The Applicant’s Aircraft have the capability to operate safely after experiencing 

certain in-flight failures, as specified in the Manuals. The Aircraft are also able to 

respond to a lost-link event with a pre-conditioned, predictable, automated flight 

maneuver.

2. Specific Limitations on Proposed Flight Operations

Given the small size involved, the restricted environment within which they will 

operate, the procedures listed below, and pilot certification requirements, Applicant’s 

proposed operations would “not create a hazard to users of the NAS or the public or 

pose a threat to national security.” Reform Act Section 333 (b)(1).

1. The Aircraft weigh less than 55 pounds.

2. Each Aircraft will be identified by serial number, registered with the FAA, and 

have identification (N-Number) markings as large as practicable.

3. Flights will be operated within VLOS of the PIC.

4. Prior to each flight, a zero altitude initiation point will be established and 

confirmed for accuracy by PIC.
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5. The PIC will ensure that before each flight, there is enough available power for 

the UAS to conduct the intended operation and to operate after that for at least 

five minutes or with the reserve power recommended by the manufacturer if 

greater.

6. The Aircraft will be operated during daylight and in VFR conditions.

7. Flights will not exceed 400 feet AGL.

8. Flights will be operated at a lateral distance of at least 500 feet from any persons 

or property not associated with the operation who have not given prior 

permission.

9. Flights will be limited to a groundspeed of 87 knots (100 mph).

10. Minimum crew for each flight will consist of a PIC and a Visual Observer (VO).

11. The PIC will hold either an airline transport, commercial, private, recreational or 

sport pilot certificate. The PIC will also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state or the Federal 

Government. The PIC will also meet the flight review requirements specified in 

14 C.F.R. § 61.56.

12. Prior to the flight, a Mission Plan will be created setting forth the limitations for 

the flight as well as contact information for the PIC.

13. Prior to each flight, the PIC will conduct a preflight inspection and determine the 

UAS is in a condition for safe flight. 

14. The flight operations will yield the right of way to other manned aircraft 

operations.

15. The Aircraft will only operate over private or controlled access property with the 

permission of the owner/controller or authorized representative.

16. The Aircraft will not operate within 5 nautical miles of an airport unless a letter 

of agreement is obtained.

17. All required permissions and permits will be obtained from territory, state, 

county or city jurisdictions prior to flight. 

18. If the Aircraft loses communications, it will have the capability to return to a 

predetermined location within the operational area and land. The UAS will utilize 

a geofence where practicable in case of emergencies.

19. If the Aircraft loses its GPS signal it will have the capability of being flown 

manually to a predetermined location within the operational area and land.

20. The flight will be aborted in case of unpredicted obstacles or emergencies.
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21. UAS operations will be conducted within the parameters of the Manuals.

3. Flight Recovery, Lost Communications, and Lost GPS Procedures

The flight recovery, lost communications, and lost GPS procedures are more fully 

documented in the Manuals. 

V. SPECIFIC FAR EXEMPTIONS REQUESTED

Applicant seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, 

and 91 for purposes of conducting the requested operations. Listed below are (1) the specific FAR 

sections for which exemption is sought, and (2) the operating procedures and safeguards that 

Applicant has established which will ensure a level of safety better than or equal to the rules from 

which exemption is sought. See 14 C.F.R. § 11.81 (e). 

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 

91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the 

Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met with this petition, and 

therefore no exemption is needed. See Grant of Exemption No. 11062, Docket No. FAA 2014-

0352 at 13-14, 22. If the FAA determines that there are some characteristics of the Aircraft that 

fail to meet the requirements of the Reform Act, an exemption is requested. 

Equivalent Level of Safety: The Aircraft are safe when taking into account their size, weight, 

speed, and operational capability. They weigh less than 55 pounds and will be flown at speeds 

less than 87 knots (100 miles per hour), and in VLOS of the operator. The Aircraft do not carry 

pilots, passengers, explosive materials, or flammable liquid fuels. The Aircraft will be operated 

within the parameters of the Manuals. 

The proposed operations will be at least as safe as, or safer than, conventional rotorcraft or fixed 

wing aircraft operating with an airworthiness certificate without the restrictions and conditions 

proposed here. 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent the UASs would otherwise require certification under Part 27, 

Applicant seeks an exemption from Part 27’s airworthiness standards for the same reasons 

identified in the request for exemption from 14 C.F.R. Part 21, Subpart H. 

C. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification 

Requirements 

14 C.F.R. § 45.23(b), Markings of the Aircraft states: 
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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. 

14 C.F.R. § 45.27(a) states: 

Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23. 

14 C.F.R. § 91.9(c) states: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter. 

In a previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft “have identification (N-Number) markings in accordance 

with 14 CFR part 45, Subpart C if the markings are “as large as practicable.” See Exemption No. 

11062, Docket No. FAA 2014-0352, at p. 14. 

Equivalent Level of Safety: Applicant will mark all UASs with their N-Number in a prominent 

spot on the fuselage with markings that are as large as practicable. 

D. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations 

Applicant seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying 

aircraft for compensation or hire and would also require a second class medical certificate. The 

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in 

which the PIC will be operating, as well as requiring certifications if the pilot is carrying 

passengers or cargo for hire. 

While the UAS will be operated as part of a commercial operation, they carry neither passengers 

nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA determined 

that the unique characteristics of UAS operation outside of controlled airspace did not warrant the 

additional cost and restrictions attendant with requiring the PIC to have a commercial pilot 

certificate and a class II medical certificate. The FAA has also determined that the required 

knowledge for a commercial pilot covers the same fundamental principles as a private pilot. 

The FAA has recently granted exemptions allowing operations by people who hold an airline 

transport, commercial, private, recreational, or sport pilot certificate with a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by a state or the Federal Government. 

The PIC must also meet the flight review requirements specified in 14 CFR § 61.56. See FAA 

Exemption No. 11374. 

Applicant will ensure the PIC will meet the requirements listed in the above paragraph. Applicant 

will also ensure the PIC will have completed the manufacturers’ training guidelines outlined in 

the Manuals. 
8

The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the 

overriding safety factor for the limited operations proposed by the petitioner to be the airmanship 

skills acquired through UAS-specific flight cycles, flight time, and specific make and model 

experience, culminating in verification through testing.” See Exemption No. 11062, Docket No. 

FAA 2014-0352, at p. 18. The proposed operations can achieve an equivalent level of safety by 

requiring the knowledge and experience in the UAS operations described above. 

Equivalent Level of Safety: The restrictions Applicant has placed on its UAS operations meet or 

exceed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA-2014-0352 

and those listed in the FAA’s “summary grant” process. 

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Applicant seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in 

airworthy condition to be operated. The FAA has stated that no exemption is required to the 

extent that the requirements of Part 21 are waived or found inapplicable. Accordingly Applicant 

requests that the requirements for Section 91.7 be treated in accordance with FAR Part 21 Subpart 

H. See Grant of Exemption No. 11062, p. 19. 

F. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 14 C.F.R. §§ 

91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 

Pursuant to 14 C.F.R. § 91.9(b)(2): 

(b) No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is 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. 

Pursuant to 14 C.F.R. § 91.203(a) and (b): 

(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. 

Applicant does not request an exemption from this section but instead notifies the FAA that, in 

accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight 

manual, registration certificate and other documentation will be kept at the control station with 

the PIC during flight. The Chief Counsel’s Office has held that for all UAS operations, this 

alternate method constitutes full compliance with the regulations. See also Grant of Exemption 

No. 11062, pp. 19-20, and Grant of Exemption No. 8607. 
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G. 14 C.F.R. § 91.103: Preflight Action 

Applicant seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar 

with specific information before each flight, including information contained in the FAAapproved Flight Manual on board the aircraft. The aircraft will not have a Flight Manual on 

board. The PIC will take all actions including reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation of flight. Under these 

circumstances, the FAA has stated that no exemption is required. See Grant of Exemption No. 

11062, p. 20. An exemption is requested to the extent that an FAA-approved Flight Manual is 

required. 

Equivalent Level of Safety: An equivalent level of safety will be provided by following the 

Manuals. The PIC will take all required preflight actions - including performing all required 

checklists and reviewing weather, flight requirements, battery charge, landing and takeoff 

distance, aircraft performance data, and contingency landing areas - before initiation of flight. 

The applicable Manuals will be kept at the ground station with the operator at all times. 

H. 14 C.F.R. § 91.109(a): Flight Instruction 

Applicant seeks an exemption from 14 C.F.R. § 91.109(a), which 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.” UASs and remotely piloted aircraft, by 

their design, do not have functional dual controls. Instead, flight control is accomplished through 

the use of the Ground Control Station (GCS) that communicates with the aircraft via radio 

communications. 

Equivalent Level of Safety: When flight instruction is performed, no pilots will be on board the 

aircraft and the GCS will be a safe distance from the aircraft and the public, causing no safety 

hazard. Given the size and speed of the UAS, an equivalent level of safe training can still be 

achieved without dual controls because no pilot or passengers are aboard the aircraft, and all 

persons will be a safe distance away in the event that the aircraft experiences any difficulties 

during flight instruction. In addition, Applicant will conduct flight training at a remote facility 

away from population centers. These training flights will comply with the provisions in the 

Manuals. Accordingly, Applicant’s proposed method of operation provides superior levels of 

safety. 

I. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas 

Applicant requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet 

to any person, vessel, vehicle, or structure. This petition provides for Applicant’s operations at 

least 500 feet from persons and structures not involved in the operations. The FAA has already 

determined that relief from Section 91.119(c) is warranted for UAS operations in uncongested 

areas with similar flight restrictions as those imposed by Applicant. See Grant of Exemption No. 

11062, p. 20-21. 

Equivalent Level of Safety: Compared to flight operations with rotorcraft or fixed wing aircraft 

weighing far more than the maximum weights proposed herein, and given the lack of flammable 

fuel, any risk associated with these operations is far less than those that presently exist with 
10

conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and 

speed of the UAS, as well as the locations where it is operated. In order to avoid any risk to 

aircraft, flight operations will be restricted to 400 feet AGL or below. Other aircraft are already 

prohibited from operating closer than 500 feet from structures where Applicant proses to operate. 

This is airspace where other aircraft do not normally operate. As set forth in the Manuals and 

herein, the UAS will be operated in the remote sites, away from persons or structures not 

involved in the operation. All persons who are not involved with Applicant’s operations will be 

required to be at least 500 feet from flight operations. This will pose no risk to the public because 

other aircraft are not operating in these areas. 

J. 14 C.F.R. § 91.121: Altimeter Settings 

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport. The Aircraft proposed here use both barometric pressure 

sensors and GPS to determine altitude but do not have the ability to set in a current altimeter 

setting. An exemption is required to the extent that the Aircraft do not have a barometric altimeter 

setting. The altitude of the UAS is monitored by the PIC on the ground control station and by the 

visual observer. 

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety can be 

achieved if the aircraft will be operated at or below 400 feet AGL and within visual line-of-sight 

in addition to GPS based altitude information relayed in real time to the operator. See Grant of

Exemption No. 11062, p. 20-21. The Aircraft will be operated at or below 400 feet AGL and 

otherwise comply with the limitations in the Grant of Exemption No. 11062. 

K. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Applicant requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in 

VFR conditions. Section 91.151 states: 

(a) 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. 

Here, the technological limitations on the UAS battery power means that no meaningful flight 

operations can be conducted while maintaining a 30 minute reserve. The aircraft are battery 

powered with a maximum flight time of less than 25 minutes. The PIC will ensure that before 

each flight, there is enough available power for the UAS to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety is provided if 

the UAS flight is conducted under daytime VFR flight conditions using VLOS, and terminated 

with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21-
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22. The FAA’s “summary grant” process provides that the PIC is prohibited from beginning a 

flight unless there is enough available power to conduct the intended operation and to operate 

after that for at least five minutes or with the reserve power recommended by the manufacturer if 

greater. See FAA Exemption No. 11374 (FAA Docket No. 2015-0091 at p. 5). The limitations 

here provide that the PIC will ensure that before each flight, there is enough available power for 

the UAS to conduct the intended operation and to operate after that for at least five minutes or 

with the reserve power recommended by the manufacturer if greater. 

L. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections 

Applicant seeks an exemption from the maintenance inspection requirements contained in 14 

C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 

91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ... have discrepancies 

repaired as prescribed in part 43 of this chapter”). An exemption from these regulations is needed 

because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which 

the UAS proposed here will not have. 

Equivalent Level of Safety: An equivalent level of safety will be achieved because maintenance 

and inspections will be performed in accordance with the Manuals. This includes maintenance, 

overhaul, replacement, and preflight inspection requirements. See Exemption No. 11062 (FAA 

Docket No. 2014-0352, at p. 14-15) and Exemption No. 11374 (FAA Docket No. 2015-0091, at 

p. 4). Applicant will follow the Aircraft manufacturer’s maintenance requirements. Flights will 

not be conducted unless a flight operations checklist is performed that includes all of the aircraft’s 

components. 

VI. PUBLIC INTEREST 

Granting Applicant’s petition for exemption furthers the public interest. National policy set by 

Congress favors early integration of UAS into the NAS in controlled, safe working environments 

such as proposed in this petition. By granting this petition, the FAA will fulfill Congress’s intent 

of allowing UAS to operate safely in the NAS before completion of the rulemaking required 

under Section 332 of the Reform Act. 

Moreover, use of UAS will promote the efficient use of resources and decrease safety-related 

incidents involving traditional aircraft. The public has an interest in promoting the use of UAS 

and in reducing the hazards and emissions associated with alternate use of helicopters and small 

airplanes to conduct similar operations. 

VII. PRIVACY 

All flights will occur over private or controlled access property with the owner’s consent and will 

be conducted in accordance with any federal, state or local laws regarding privacy. 
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VIII. SUMMARY FOR FEDERAL REGISTER 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules to allow for UAS operations for aerial

cinematography, photography, and data collection: 14 C.F.R Part 21, Subpart H; 14 C.F.R Part 

27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 91.7(a); 14 C.F.R § 

91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109(a); 14 C.F.R § 91.119(c); 

14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203(a) & (b); 14 C.F.R § 

91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417(a) & (b). 

The exemption will promote the public interest while enhancing safety by reducing risk to the 

operator, the general public, and property owners from the substantial hazards associated with 

performing equivalent operations using conventional aircraft and rotorcraft. 

IX. CONCLUSION 

Applicant has satisfied the requirements of Section 333 of the Reform Act to permit operation of 

the Aircraft proposed here. This petition warrants review by the FAA under the “summary grant” 

process for immediate approval as this petition would not set a precedent, and any delay in acting 

on this petition would be detrimental to the Applicant. 

If you have any questions or require any additional information, please do not hesitate to contact 

the undersigned.

Respectfully submitted,

Jay Kinder

CEO, NAEA Inc.