Paul E. Ott, 

d/b/aFlintridge Aerial Services 

2455 S Leonine Rd 

Wichita, KS 67217 

peott@prodigy.net 

August 19, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Request for Exemption Per PL 112-95 §333 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) 

Dear Sir or Madam: 

With that preface, pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 ("FMRA") and 14 C.F.R. Part 11, Flintridge Aerial Services, developer and operator 

of Unmanned Aerial Vehicles ("UAVS'') equipped to conduct aerial 

photography/Inspection/included but not limited to the following Commercial 

Operations: 

• Real Estate listings 

• Yacht brokerage/listings 

• Private events: weddings, parties, etc ... 

• Commercials/promotions for businesses, communities, golf courses, marinas, etc. 

• Agriculture: imaging for crop health and/or production estimates 

• Private land owners: pictures/video of their property 

• As needed/requested to support law enforcement and/or first responders 

Petitioner hereby applies for an exemption from the listed Federal Aviation Regulations 

("FARs") to allow commercial operation of its UAVs, 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. 

Please consider this a request for an exemption of the above applicable sections of title 

14 CFR for Flintridge Aerial Services for the purpose of conducting commercial aerial 

survey and photography operations with its Unmanned Aircraft System (UAS) within 

controlled access airspace employing a comprehensive safety, training, and planning 

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program. The employment of UAS platforms for these missions should provide the FAA 

with good cause to find that these operations enhance safety by eliminating the need 

to use conventional aircraft in the sometimes unique environments where an UAS 

would be particularly adept, but a conventional aircraft may pose a hazard to its crew 

and those on the ground. 

Flintridge Aerial Services requests exemption from the following applicable regulations, 

pursuant to the Administrator's authority to grant exemptions contained in 49 U.S.C. § 

106(f), 40113, and 44701: 

14 CFR 61.23(a) and (c), 

14 CFR 61.10(e)(4) and (5), 

14 CFR 61.113(a) 

14 CFR 61.315(a) 

14 CFR 91.7(a) 

14 CFR 91.119(c), 

14 CFR 91.121, 

14 CFR 91.151(a)(l), 

14 CFR 91.405(a), 

14 CFR 91.407(a)(1), 

14 CFR 91.409(a)(1) and (2), 

14 CFR 91.417(a) and (b) 

to the extent necessary to allow Flintridge Aerial Services to operate a UAS to perform 

aerial data collection. 

OPERATION OVERVIEW 

Our operations utilize UAS in a manner that provides services not offered by manned 

aircraft or enhances the level of safety at which the tasks can be completed in manned 

aircraft 

Examples of the proposed aerial photography operations include both real estate and 

insurance damage assessment. Both operations restrict the use of the UAS to a small 

area typically encompassing a limited number of residential and commercial properties 

at a time. The areas in which the flight takes place can readily be protected with 

secured access by the staff of Flintridge Aerial Services. The structures on these 

properties provided sufficient protection from the UAS and can be completed with 

much less risk than what would be assumed in a manned operation at low altitudes 

with flammable fuel. 

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Our intended film production operation would typically include both photography and 

videography for commercial purposes including real estate development and private 

events as well as promotional video and commercial production for businesses. These 

events are restricted to only the invited participants and are closed to the general 

public, providing the opportunity to operate only in an area where informed, 

consenting participants and personnel are present. By adhering to the restrictions and 

exemptions previously granted to other operators by the FAA, Flintridge Aerial Services 

will be able to provide a level of safety equal to or greater than the manned aircraft 

that would typically provide these services. 

Our survey operation will include the orthomosaic mapping of both agriculture and 

construction sites utilizing our UAS rot'orcraft flying pre-programmed grids that can be 

interrupted and returned to a safe landing zone by our FAA certified pilots at any time. 

Currently these operations are executed by general aviation aircraft carrying hundreds 

of pounds of fuel and equipment flying at low altitudes and speeds. Our operation 

would greatly increase the level of safety, replacing large aircraft with an UAS under 55 

pounds including payload and restricted to speeds no greater than 87 knots (100 miles 

per hour) at altitudes no more than 400 feet above ground level (AGL). These sites are 

areas that can readily be secured by Flintridge Aerial Services personnel and would not 

provide any additional risk to the general public. 

These operations are similar in all material respects to those of Astraeus Aerial whom 

the FAA granted exemption number 11062 under the regulatory docket no. FAA-2014-

0352. This is similar in all material respects to relief previously requested in grant of 

Exemptions Nos. 11109 to Clayco, Inc. (Docket No. FAA-2014-0507), 11112 to VDOS 

Global, LLC (Docket No. FAA-2014-0382), and 11213 to Aeryon Labs, Inc. (Docket No. 

FAA-2014-0642). 

All of Flintridge Aerial Services operations will be performed by FAA licensed pilots with 

trained Visual Observers and, where necessary, Site Security Coordinators, in controlled 

and secured environments only after a safety assessment has been completed and risk 

mitigation practices reviewed. In order to perform the aerial data collection with a UAS 

we propose and agree to be bound to the following: 

1 UAV's used in the operation will be limited to the DJI Phantom 3, DJI Phantom 

2, and DJI Inspire 1, which will all weigh less than 55 pounds including payload. The 

aircraft are equipped with failsafe protocols that return the aircraft to a predetermined 

point and land if any abnormalities are present. The petitioner's UAS has the capability 

to operate safely after experiencing certain in-flight contingencies or failures and uses a 

failsafe mode to return to home and land when connection is lost. The UAS is also able 

to respond to a loss of the global positioning system (GPS) or a lost-link event with precoordinated automated flight maneuvers. These safety features provide an equivalent 

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level of safety compared to a manned aircraft holding a restricted airworthiness 

certificate performing a similar operation. Because of the UAS' specifications and flight 

characteristics, it poses no threat to national security. 

No pilot or passengers will be carried aboard. Proposed operations of any other aircraft 

will require a new petition to amend the exemption. 

a) User manuals, safety guidelines and maintenance manuals for these UAV's are 

available on-line at www.dji.com for download and review. In the public interest of 

conservation of natural resources, we have not printed and included the manuals with 

this petition. 

2 There will be no closed-set motion picture and television filming conducted. 

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

Either ground speed or calibrated air speed will be used to determine this limitation. 

At no time will the UA be operated at a speed exceeding the maximum airspeed 

recommended by the aircraft manufacturer. 

4 At no time will the UA be operated at an altitude exceeding 400 feet above 

ground level (AGL). Altitude will be reported in feet AGL. 

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

This means that the PIC must 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 will utilize a visual observer (VO). The UA will be operated within the 

visual line of sight (VLOS) of the PIC and the 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 will be able to communicate verbally at all times; electronic messaging or 

texting will not be permitted during flight operations. The PIC will be designated 

before the flight and cannot transfer his or her designation for the duration of the 

flight. The PIC will ensure that the VO can perform the duties required of the VO. 

7 The UAS will be operated within the limitations and according to the guidelines in 

the User Manuals, Safety Guidelines and Maintenance Manuals published by the 

manufacturer of the UAS. Any additional operating documents will be available to the 

FAA at any time upon request of the Administrator. 

8 After maintenance or alterations that affect the UAS operation or flight 

characteristics, a functional test will be performed prior to conducting further 

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operations. Functional flight tests will only be conducted by a PIC with aVO and will 

remain at least 500 feet from other people. The functional test will be conducted in 

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

9 The operator will be responsible for maintaining and inspecting the UAS to ensure 

that is in a condition for safe operation. 

10 Prior to each flight, the PIC will conduct a pre-flight inspection and determine that the 

UAS is in a condition for safe flight. The pre-flight inspection will 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 will follow the UAS manufacturer's maintenance, overhaul, 

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

components. 

12 Each UAS operated under the proposed exemption will comply with all manufacturer 

safety bulletins. 

13 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, 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 will 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 the proposed exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from persons, vesssels, vehicles and structures. 

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

14 CFR 61.51(b). Training flights will be conducted for the purpose of training PIC's and 

VOs to safely conduct operations permitted under the proposed exemption. This training 

will be for the purpose of building proficiency and experience to insure the safe operation 

of the UAS. Training will only be conducted during dedicated training sessions. During 

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

operations will be condsidered nonparticipants, and the PIC will operate the UA with 

appropriate distance from nonparticipants in accordance with 14 CFR 91.119. 

15 No UAS operations will be conducted during night, as defined in 14 CFR 1.1. All 

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operations will be conducted under visual meteorlogical conditions (VMC). 

16 No UA operations will be conducted 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 witin 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 Flintridge Aerial 

Services. If such a letter is obtained, it will be made available to the FAA Administrator or 

any law enforcement official upon request. 

17 The UA will 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 stature miles from the PIC. 

18 If the UAS loses communications or loses its GPS signal, the UAS will have capability 

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

19 The PIC will abort the flight in case of unpredicted obstacles or emergencies. 

20 The PIC will not begin 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 lease five minutes or with the reserve power 

recommended by the manufacturer if greater. 

21. All operations will be conducted in accordance with an Air Traffice Organization 

Certificated of Waiver or Authorization. 

22. All aircraft operated by Flintridge Aerial Services will be identified by serial number 

and registered in accordance with 14 CFR part 47, and have identification (N-Number) 

markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as 

practicable. 

23. All documents used by Flintridge Aerial Services to ensure the safe operation and 

flight of the UAS and and documents required under 14 CFR 91.9 and 91.203 will be 

available to the PIC at the Ground Control Station of the UAS any time the aircraft is 

operating. These documents will be avialable to the FAA Administrator or any law 

enforcement official upon request. 

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

activities at all times. 

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

26. All flight operations will be conducted at least 500 feet from all nonparticipating 

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persons, vessels, vechicle 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 will ensure that 

nonparticipating persons remain under such protection. If the situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations will cease immediately in a manner ensuring the safety of the 

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. 

Flintridge Aerial Services will establish and maintain a security perimeter for the 

purpose of protecting structures and people not associated with the operation. In 

establishing the security perimeter, Flintridge Aerial Services will receive the permission 

of the owner of the property upon which the ground crew will stage and above which 

the aircraft will operate, and at no time will the UAS be operated directly over a person. 

Should the flight take place over public lands, Flintridge Aerial Services will obtain the 

permission of the governing body of jurisdiction. Obtaining permission to operate will 

serve as notification to the property owner or governing body that operations will be 

taking place. The UAS will be continuously operated at an altitude which will allow a 

safe descent and recovery should a mechanical issue arise. 

The PIC, VO, operator trainees or essential persons will be considered "crew" and not 

subject to the above restrictions. 

27. All operations will 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. 

BENEFIT TO THE PUBLIC INTEREST 

Flintridge Aerial Services will be using battery powered UAS for operations that would 

normally be used by full size aircraft. The battery operated UAS does not release 

greenhouse gas emissions and have lower noise levels reducing the risk to the public 

and an overall benefit to the public interest. In addition these aircraft can replace work 

that is dangerous and difficult at the same time providing an equivalent or greater level 

of safety than alternative manned aircraft. By providing services that would normally 

be provided by manned aircraft, Flintridge Aerial Services will not only reduce emissions 

but may eliminate the need for an aircraft carrying flammable aircraft fuel to fly over 

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the populated areas which would benefit the public interest. 

Manned aircraft conducting aerial photography operations can weigh thousands of 

pounds or more and are operated by an onboard pilot and may carry other onboard 

crewmembers, as well as carry large quantities of fuel. The petitioner's unmanned 

aircraft (UA) weighs less than 8 pounds, including payload. The pilot and crew will be 

remotely located from the aircraft. The limited weight and construction reduces the 

potential for harm to the pubic or damage to property in the event of an incident or 

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

or accident. The UA carries no fuel, and therefore the risk of fire following an incident 

or accident due to fuel spillage is eliminated which would benefit the public not only by 

the elimination of a crew but also the public on the ground at the site of the incident or 

accident. The risk to an onboard pilot and crew during an incident or accident is 

eliminated with the use of a UAS for the proposed operation and will benefit the public. 

In conclusion, by granting Flintridge Aerial Services an exemption it would benefit the 

pubic as a whole and be in the best interest of the public. 

PRIVACY 

All applicable laws and regulations regarding privacy will be adhered to. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security) provide more than adequate 

justification to grant Flintridge Aerial Services requested exemption, allowing for 

Flintridge Aerial Services' UAS commercial operations for the purpose of photography, 

film and survey pursuant to the operating terms, conditions and limitations as detailed 

in this appliation. 

Owner- Flintridge Aerial Services 

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