June 25, 2015

Exemption No. 11911

Regulatory Docket No. FAA–2015–1341

Mr. Radley Angelo

CEO

Spark Aerial, Inc.

311 4th Avenue, Unit 309

San Diego, CA 92101

Dear Mr. Angelo:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted April 29, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Spark Aerial, Inc. (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

photography, cinematography, videography, mapping, crop surveying, inspections, and other 

flight operations.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.
2

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 Vision+, DJI Inspire 1, and DJI 

S1000.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that the relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1

. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

delegated to me by the Administrator, Spark Aerial, Inc. is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Spark Aerial, Inc. is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision+, DJI Inspire 1, and DJI S1000 when weighing less than 55 pounds including 

payload. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.
4

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 
5

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA 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

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 
7

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Spark Aerial Inc.

311 4th Avenue, Unit 309

San Diego, CA, 92101

(650)­823­5345

admin@sparkaerial.com

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA­2014­0481 in the matter of the

petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the matter of the

petition of ADVANCED AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA­2014­0355 in the matter of the

petition of FLYING CAM INC

Attachments: 1) Phantom 2 Vision+ User Manual V1.6 2014­11­12

2) Phantom 2 Vision Plus (Quick Start Guide) 2014­11­18

3) Phantom pilot training guide V1.1 2014­04­07

4) Inspire 1 User Manual

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under

section 333 of the FAA Modernization and Reform Act of 2012, Spark Aerial Inc.​, referred to

hereafter as the petitioner, request exemption from the following sections of Title 14, Code of

Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1);

91.409(a)(2); 91.417(a) & (b);

In order to operate small unmanned aircraft systems (UAS) commercially in airspace

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial

photography, cinematography, videography, mapping, crop surveying, inspections and other

flight operations that could be performed safely and more cost effectively with the use of small

UAS at low altitude within the U.S. national airspace system as compared to a manned

aircraft. Operations will be performed only at the request of and with the authorization and

permission of clients or their authorized agents in order to facilitate commerce and raise

awareness of the beneficial uses of small unmanned air systems. So long as such operations

are conducted within and under the conditions outlined herein or as may be established by
the FAA as required by Section 333. The conditions identified and proposed by the petitioner

are drawn from references 1­3.

About the Petitioner

Spark Aerial Inc.​is the brainchild of three engineering graduates from The University of

California, San Diego. With a heavy background in software engineering and design as well

as model aeronautics, the emerging world of sUAS represents a clear and exciting future for

all of our founding members.

The FARs

The petitioner seeks exemption from the above mentioned FARs for the following reasons;

61.113(a) & (b); ​The petitioner requests relief in order to facilitate the utilization of pilots, who

hold a SPORT 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 the

previously granted exemptions.

91.119(c) ​As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted

closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to

essential persons, or objects that would not be possible without additional relief. The

petitioner requests modification, waiver or exemption and clarification concerning the terms

“congested areas” and “densely populated”. The petitioner requests waiver for this condition

to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if

required. 91.121 ​As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable

since the UAS does not have an altimeter and instead utilizes electronic GPS with a

barometric sensor for altitude information.

91.151(a) ​As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC)

prior relief has been granted for manned aircraft to operate at less than the prescribed

minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS­specific

relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR

conditions. The UAS provides battery power remaining in percent to the PIC. The UA

batteries provide approximately 25 minutes of powered flight. Information provided in the

operating documents discusses procedures regarding remaining battery power management.

Those documents contain a condition in which the PIC will initiate a landing procedure when

battery remaining reaches a specified level. Given the limitations on proposed operations and

the location of those proposed operations, The FAA found that a reduced minimum power

reserve for flight in daytime VFR conditions was reasonable.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b)​As discussed in Exemption

11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is
in a condition for safe flight in accordance with the operating documents. The FAA found that

adherence to the petitioner’s operating documents and the conditions and limitations

specified, describing the requirements for maintenance, inspection, and recordkeeping, were

sufficient to ensure that safety would not be adversely affected.

The Unmanned Systems

The DJI Phantom 2 vision plus​is a highly successful consumer grade small rotorcraft in the

quadcopter configuration with an advertised weight of less than 44 Ounces (1242g) designed

primarily to carry aloft a high definition camera. It has an advertised maximum speed of less

than 30 knots (15m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It

is powered by four electric motors with a distance between motors of less than 14 inches

(350mm) It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor

augmented with global positioning system (GPS) to maintain its geospatial orientation and

position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time

video and telemetry information is transmitted back to a ground control station allowing the

operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance

from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for

either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and

maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to

approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry and

external lighting cues before reaching a low battery state. An automatic termination of flight

and landing will be initiated when the battery reaches a predetermined low state. It is

anticipated that flights will usually last less than 10 minutes. More information is available in

attachment 1 or http://www.dji.com/product/phantom­2­vision­plus

The DJI Inspire 1 ​is a similar system to the Phantom 2 Vision plus, with all of the same safety

features and camera capabilities augmented with a more robust flight plane and a higher

definitiion camera. Despite these additions, the system falls well below the FAA’s prescribed

55lbs weight threshold. More information is available in attachment (4), or here:

http://www.dji.com/product/inspire­1/spec

Finally, the DJI S1000 ​aircraft system is a larger aircraft capable of lifting slightly heavier

payloads, never to exceed 17 lbs total take off weight. Despite this larger system, it retains all

the same safety features of the Inspire 1 and the Phantom Vision 2 +. It utilizes an internal

inertial measuring unit (IMU) with integrated barometric sensor augmented with global

positioning system (GPS) to maintain its geospatial orientation and position. It is controlled

primarily through an FCC certified radio control (RC) unit. Real time video and telemetry

information is transmitted back to a ground control station allowing the operator and/or PIC to

monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera

imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or

GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can

be preprogrammed by the PIC. Battery life limits flight times to approximately 15 minutes. The
onboard flight controller will warn the pilot via telemetry and external lighting cues before

reaching a low battery state. An automatic termination of flight and landing will be initiated

when the battery reaches a predetermined low state. It is anticipated that flights will usually

last less than 7 minutes. More information is available here:

http://www.dji.com/product/spreading­wings­s1000/spec

Mitigating Risk

The petitioner has reviewed FAA exemptions reference’s 1­3 Conditions and Limitations

section and believes that the procedures specified therein are reasonable and will be utilized

in order to manage and mitigate risk and ensure public safety. A preflight checklist will be

developed and employed to ensure that the UA airworthiness will be verified before launch.

Airworthiness will be maintained by performance of routine inspections before each flight,

maintaining flight and maintenance logs to record time on failure­prone components. The

petitioner request that in a manner similar to reference 3, we be allowed to operate within 5

miles of an airport provided that;

“The UA may not operate in Class B, C, or D airspace without written approval from the FAA.

The UA may not operate within 5 nautical miles of the geographic center of a nontowered

airport as denoted on a current FAA­published aeronautical chart unless a letter of agreement

with that airport’s management is obtained, and the operation is conducted in accordance with

a NOTAM as required by the operator’s COA. The letter of agreement with the airport

management must be made available to the Administrator upon request.”

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is

requesting a mechanism to facilitate such activities without requesting a new and separate

exemption(s) should the need arise. Operations within class B airspace are not requested due

to the lack of mode C transponder.

The Public Interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the

environmental impact as compared to similar operations conducted with manned aircraft of

greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in order

to facilitate commerce will lead to economic growth. Operations for this petition will enable

service for property owners or their designees seeking an enhanced perspective for

characteristics, amenities, and benefits of their desired photographic subjects that cannot be

displayed through ground level videography/photography. Aerial photography is a valuable

marketing tool that can lead to increased commerce and enhance personal photography.

Crop surveying applications could lead to decreased use of pesticides and fertilizer and

conservation of water as well as increased crop yields and decreased costs. Aerial surveying

and inspections can increase work site efficiency, improve volumetric estimations and reduce

risks. The petitioner will provide clients with photographic data for these purposes on a ‘for
hire’ basis acting as an independent contractor. A visual observer will be utilized. Liability

insurance has already been obtained commensurate with the granting of this request for

exemption. Flight data including UA flight time, Control Unit operation time, incident, accident,

and details concerning any deviations from normal operations will be available to FAA for use

in collecting data regarding the use of UAS as part of this application. This data may be

submitted to FAA via traditional means, e.g. COA Monthly Reports, or other means as

required.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial photography,

cinematography, videography, mapping, crop surveying, inspections and other flight

operations”. The reason for such a general and broad based request is that the petitioner

wishes to utilize a business strategy of horizontal integration and maximize economies of

scope in order to capitalize on opportunities as they may arise in the future without the long

turnaround time associated with additional exemption requests. The petitioner's business

model is based on the idea of offering ad hoc small UAS services to individuals or companies

who wish to employ these services as a safe, effective, and legal option to enhance their

business or hobby. The petitioner’s own market research shows incredible demand for these

services currently exists in the real estate market and other markets are just beginning to

emerge. Although videography and photography are included in the request, the primary

objective will be aerial survey of construction combined with industry leading software to

create precise estimations. The petitioner has identified universities and other agencies that

could benefit from the operation requested in this application. A quick internet search will

show that many are currently operating similar UAS in exactly this fashion without, it is

assumed, FAA authorization. The primary purpose of seeking this exemption is to obtain the

capability to offer those services while remaining in compliance. The individuals that make up

Spark Aerial Inc. ​are aviation enthusiasts, and have been pursuing Remote Control Aviation

for much of their lives. Our CEO, Radley Angelo, began flying R/C aircraft at the age of nine

years old and has been an active member of the Academy of Model Aeronautics (AMA) ever

since. The economic, research and development and creative applications for these devices

is nearly limitless, and our pursuit of an FAA exemption represents our first formal step to

making this dream a reality.

Respectfully Submitted,

Spark Aerial Inc.