Sandra & Timothy Ammann

Echo Aerial Imaging LLC

13575 S. Greybull St. 

Nampa, ID 83651

U. S. Department of Transportation Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulation from: 14 CFR Part 21, Subpart H; 14 CFR 61.113(a) and (b); 91.103; 91.105; 91.107; 

91.109; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a); 91.409(a)(1) and (2); 91.417(a) and (b).

To whom it may concern:

This document constitutes an exemption Request under Section 333 of the FAA Modernization and 

Reform Act of 2012, and 14 C.F.R. Part 11. Echo Aerial Imaging, LLC, an operator of Small Unmanned 

Aircraft Systems (sUAS) is seeking exemption in order to legally conduct business and comply with all 

Federal regulations and standards put forth by the FAA while operating our sUAS. We will be providing 

services to including but not limited the following industries: commercial and private real estate, 

architecture, marketing, short range inspection, surveying and mapping, agricultural, sporting events, 

special events.

Echo Aerial Imaging, LLC's requested exemption would permit the operation of sUAS under controlled 

and secure conditions that is: (a) limited, (b) predetermined, (c) subject to controlled access, and (d) 

provide greater safety in connection with aircraft operations. 

As established by the exemptions already granted by the FAA, approval of Echo Aerial Imaging, LLC's 

exemption would enhance safety and fulfill the Secretary of Transportation’s responsibilities to 

“...establish requirements for the safe operation of such aircraft systems in the national airspace 

system.” Section 333(c) of the Reform Act.

Echo Aerial Imaging, LLC will be using the DJI Phantom 3, and DJI Inspire 1. 

 Both weigh less than 55 pounds, including the payload (i.e. camera, lens, and stabilizing gimbal)

 Both operate at no more than 50 knots 

 Both can hover, and can simultaneously move vertically and horizontally. 

Aircraft and Equivalent level of Safety

The operating limitations proposed by Echo Aerial Imaging, LLC are as follows:

 All flights will be operated within line of sight of pilot and/or observer

 Flights will be operated at an altitude of no more than 400 feet

 Before each flight sUAS will be calibrated, blades will be inspected, batteries will be charged, 

and a short test flight will be performed
 Flights will be terminated when the battery reaches 25%. This will allow enough reserve time to 

land safely

 Flights will be operated at an altitude of no more than 400 feet

 Minimum crew for each operation will consist of the sUAS pilot, the Visual Observer, and the 

Camera Operator (only when the Inspire 1 is flown)

 A briefing will be conducted, and all operators will be in attendance prior to flight. 

 The operator will obtain consent of all persons involved and ensure that only consenting 

persons will be allowed within 50 feet of the flight operation. 

 Observer and pilot will be able to communicate by voice and/or text at all times. 

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

 All appropriate permissions and permits will be obtained from territorial, state, county, or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

 If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return to 

a predetermined location within the Security Perimeter and land. 

 The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

As established by the sUAS exemptions already granted by the FAA, allowing commercial operations of 

sUASs in agriculture, real estate, inspection, surveying, mapping, and special events will enhance safety 

by reducing risk. Current methods use small aircraft, flying at low altitudes weighing in around 4,000 

pounds and carry fuel (either Avgas, or Jet A). SUAs weigh fewer than 55 pounds and are powered by 

batteries. This eliminates virtually all of that risk given the small size and lack of combustible fuel. 

The name and address of the applicant are:

Echo Aerial Imaging LLC

Sandra & Timothy Ammann

13575 S. Greybull St. Nampa, ID 83651

Phone: 208-319-4247

email: echoaerialimaing@gmail.com

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:

Regulations from which exemption is requested: 

 14 CFR Part 21, Subpart H

 14 CFR 61.113(a) and (b) 

 14 CFR 91.103

 14 CFR 91.105

 14 CFR 91.107

 14 CFR 91.109

 14 CFR 91.119 

 14 CFR 91.121 

 14 CFR 91.151(a)

 14 CFR 91.405(a) 
 14 CFR 407(a)(1) 

 14 CFR 409(a)(2)

 14 CFR 417(a) and (b)

If you have any questions or need any additional information, please contact us at 208-319-4247 or 

echoaerialimaging@gmail.com

Thank you for your consideration

Sandra & Timothy Ammann

Echo Aerial Imaging LLC