U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590 

Petition for Exemption Under 14 CFR § 11.81 to Allow Commercial Use of Unmanned Aircraft Systems 

Petitioner: 

Justin Duke Lieberknecht

4756 Lake pl.

Las Vegas, NV 89147

Tel.: 619-249-6200

Email: justinduke@nyu.edu

To Whom It May Concern, 

This application is substantially based on the FAA's findings in Exemption No. 11351 granted to bizUAS 

Corp on April 17, 2015, and in reliance on the analysis provided therein. 

1. Sections from which exemptions are sought: Application is hereby made for exemption from: 

a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 333 

b. 14 CFR Part 21, subpart H 

c. 14 CFR Part 61.113(a) and (b) 

d. 14 CFT Part 91: 

i. 91.103(b)(2) 

ii. 91.105 

iii. 91.109 

iv. 91.119 

v. 91.121 

vi. 91.151 

vii. 91.405 

viii. 91.407 

ix. 91.409 

x. 91.417 

2. Relief sought: 

a. Wiregrass Aerial Photography wishes to operate small Unmanned Aircraft Systems (sUAS) for 

commercial purposes to include (but not be limited to) videography, cinematography, photogrammetry, 

industrial inspections and analyses. This relief is sought because commercial use of sUAS is currently 

prohibited by law unless performed under an exemption. 

b. This exemption will cover use of the following airframes, all of which will weigh less than 55 

pounds including payload and energy sources: 

i. DJI Inspire 1
ii. DJI Phantom 2 

iii. DJI Phantom 3 

iv. Other models to be added by future amendment to this exemption. 

3. Public benefit: 

a. Use of sUAS technology to obtain imagery, information and data currently obtained by use of 

manned flight or manual methods: 

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., power line 

inspections) and due to other dangerous activities that can be avoided (e.g., scaffolding/rigging 

failures during stack or bridge inspections). 

ii. Reduces the cost of obtaining such information, which benefits consumers and the 

economy. 

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from 

manned aircraft. 

4. Safety not adversely affected: 

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 

45, Subpart C. 

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. All 

repair and maintenance work will be conducted or approved by qualified personnel such as those 

authorized by DronePlus (or equivalent), and will require a test flight after such work. Records of all 

maintenance and repair work will be kept in a maintenance log for each aircraft. 

c. All flight operations will be conducted by at least two individuals (PIC and observer) who will 

maintain verbal communication capability with each other at all times during the flight, and who will 

remain stationary on the ground during the flight operations: 

i. A Pilot In Command (PIC) who possess the following credentials: 

1. At least 200 cycles and 25 hours of flight experience in a UAS rotorcraft (or 

UAS fixed-wing in the case of fixed-wing flight operations under this exemption). Such 

cycles and hours may be gained during flights under this exemption if a safe distance is 

maintained from persons in accordance with 14 CFR 91.119. 

2. At least 5 hours of flight experience and 3 takeoffs and landings in make and 

model being flown in the prior 90 days. Such cycles and hours may be gained during 

flights under this exemption if a safe distance is maintained from persons in accordance 

with 14 CFR 91.119. 

ii. A Visual Observer. 

iii. A Sensor Operator as necessary. 

d. All flight operations will be conducted in accordance with valid Certificates of Authorization. 

e. All flight operations will comply with the following: 

i. The manufacturers' Aircraft Flight Manuals and Operation Guidelines 

ii. Written flight operations policies including lost communication and other emergency 

and safety procedures as guided in the relevant UAS flight manual. 

iii. Conducted in VMC conditions during daylight hours. 

iv. PIC and VO will maintain VLOS at all times. 

v. Pre-flight inspections (including ground control station, if any) and safety risk 

assessments will be conducted prior to each flight. 

vi. Flight altitudes will remain below 400 feet above ground level. 
vii. Flight ground speeds will not exceed 50 knots. 

viii. Not intrude into Class B, C or D airspace, or published approach, SID or STAR, or take 

place within restricted space of an airport as updated by DJI in their app. 

ix. Not be made near persons as required in 14 CFR 91.119 and not over persons on the 

ground without their prior permission. 

x. Each flight will be logged in both the PIC's logbook and the aircraft logbook. 

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes, 

whichever occurs first. 

xii. Any incidents will be reported to NTSB within 24 hours of occurrence. 

xiii. Justin Duke Lieberknecht or his client will maintain liability insurance of at least 

$1,000,000 issued by an insurance underwriter. 

xiv. Any applicable local FSDO requirements. 

xv. All other applicable regulations concerned with the operation of aircraft. 

f. Aircraft will use 2.4 GHz for control of the aircraft, and 5.8 GHz for sending data with welldefined and tested lost link procedures. Please advise us of any additional information or 

changes that may be required.

Please advise of any additional information or changes that may be requested.

Sincerely,

Justin Duke Lieberknecht

07/09/2015