03/25/2015 

Aerial Impact Southeast, Inc. 

414 Yellow River Walk 

Lawrenceville, Ga 30043 

(407)782-8578 

Dave Cullens 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Dear Sir or Madam: 

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

Act), 

 Aerial Impact Southeast (applicant), planned operator of Small Unmanned Aircraft 

Systems (sUAS) equipped to conduct aerial photography and survey for various 

industries hereby applies for exemptions to several Federal Aviation Regulations 

(FARs) to allow commercial operation of their sUAS, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by 

the FAA. We ask that the Secretary of Transportation consider whether the applicants' 

systems may operate safely in the national airspace system (NAS) before finalization of 

the sUAS rulemaking required under Section 332 of the Reform Act. In making this 

determination, we ask the Secretary to consider the following: 

• The UAS’s size, weight, speed, limited flight durations and operational capability 

• Operation of the UAS below 200' agl 

• Operation of the UAS within visual line of sight of the operator at all times. 

• PIC is a FAA Certified Commercial Pilot (#215502328) with current 2nd class medical 

• Operations will be limited to the areas being filmed as outlined in Flight Ops manual 

Regulations from which the exemption is requested: 

14 C.F.R. 61.113(a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.215 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a)(1) & (2) 

14 CFR 417 (a) & (b) 
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Relief not necessary (reference Exemption No. 11195) 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

Relief not necessary (reference Exemption No. 11195) 

14 C.F.R. §91.7(a) & (b): Civil aircraft airworthiness. 

Petitioner's Preflight Checklists will satisfy the airworthiness requirement. Pre-flight 

checks will be performed prior to each flight. The PIC will determine if the aircraft is 

suitable for safe flight. See attached flight operation manual. 

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

the FAA has previously determined in Grant of Exemption 11062, that relief from these 

sections is not necessary. Relevant materials may be kept in a location accessible to 

the PIC in compliance with the regulations.

14 C.F.R. §91.109: Flight instruction: 

Relief not necessary (reference Exemption No. 11195) 

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 sUAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 200 AGL, an exemption may 

be needed to allow such operations. As set forth herein, the UAS will never operate at 

higher than 200 AGL. It will be operated in a restricted area, where buildings and people 

will not be exposed to operations without their pre-obtained consent. See petitioner's 

flight operations manual(s) for proposed operational boundaries. 

14 C.F.R. §91.121 Altimeter Settings 

Applicant requests exemption to allow a GPS referenced altitude be used in lieu of a 

pressure based altimeter. Considering the low altitudes the proposed operations will be 

taking place, the GPS altitude information will be at least as accurate as the mechanical 

pressure altimeters used in full scale aircraft. Altitude information AGL (from takeoff 

point) will be displayed to the pilot & observer at all times during the flight with On 

Screen Display telemetry information overlaid on a live video feed from the aircraft. 

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

Due to the very close operational distances and limited flight times that the proposed 

operations will take place, landing with 30 minutes reserve fuel is not a reasonable 

requirement. Applicant submits that flight times will be limited to 20 minutes or when 

battery capacity reaches 20%, whichever comes first. Aircraft will never be flown more 

than 1 minute away from the takeoff/ landing site. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

Relief not necessary (reference Exemption No. 11195) 

14 C.F.R. §91.215 ATC transponder & altitude reporting equipment & use

As applicant's aircraft will not be transponder equipped, we submit that the associated 

COA will satisfy this requirement and afford a level of safety at least equivalent to what 

is afforded by the FAR. 

Summary of proposed operations 

• The sUAS will weigh less than 30 lbs. 

• Maximum speed will be no more than 50 kts. 

• Flights will be operated within line of sight of Pilot and Observer. 

• Flights will only be conducted under Day Visual Meteorological Conditions. 

• Maximum total flight time for each operational flight will be 20 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 20 minute limit. 

• Flights will be operated at an altitude of no more than 200 feet AGL. 

• Minimum crew for each operation will consist of the sUAS Pilot and Visual Observer. 

• sUAS Pilot will be an FAA licensed airman with a Commercial Pilot certificate and 2nd 

class medical. 

• sUAS Pilot will be Pilot in Command (PIC). 

• The UAS will only be operated within the confines of the property being 

filmed/photographed. 

• A briefing will be conducted in regard to the planned sUAS operations prior to each 

flight. 

• Pilot and observer have been trained in operation of UAS generally and receive up-todate information on the particular UAS to be operated 

• Observer and Pilot will at all times be able to communicate by voice. 

• Written and/or oral permission from the relevant property holders will be obtained. 

• If the sUAS loses communications or loses its GPS signal, the UAS has capability to 

return to a pre-determined location and land. 

• The PIC will have the ability to abort a flight at any time. 

 
The applicants' sUAS are multirotor craft, weighting 30 or fewer lbs. including payload. 

They operate, under normal conditions at a speed of no more than 50 knots and are 

able to hover, and move in the vertical and horizontal plane simultaneously by remote 

control. They will operate only within line of sight and will operate only within the 

confines as described in the operators' procedural manual. Given the small size of the 

sUASs involved and the restricted areas within which they will operate, the applicant 

feels that its' operations will afford an equivalent or higher level of safety which the 

FAR's afford manned aircraft operations performing similar operations. Due to the size 

of the sUAS's applicant plans on using and the areas in which they will operate, 

applicants' operations will present no national security issue. As a Commercial Pilot, 

with 3000+ total flight hours, performing Aerial Photography using full scale Cessna 

aircraft for 16+ years and over 2500 hours, applicant feels strongly that its' operations 

will not be in conflict with manned aircraft operations as most of the proposed work will 

take place at altitudes below 100' agl, with no operations above 200' agl. This operation 

would in fact be an add-on service to the manned aircraft operation to get shots that 

would not be possible with manned aircraft, without compromising safety. In addition to 

the strong level of safety surrounding the proposed operations, there are also 

significant public benefits, including enhanced safety and reduction in environmental 

impacts, including reduced emissions and noise when compared to manned aircraft 

operations. Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption. 

Sincerely, 

e-sign David W. Cullens 

David W. Cullens, President/Owner 

Aerial Impact Southeast, Incorporated 

Attachments: 

• Aerial Impact Flight Operations manual