Peyton J. Wilson Esq.

Registered Agent – Aerora Incorporated

3305 Lexington Road

Louisville, Kentucky 40206

(p) 502.365.2772 

(e) peytonjameswilson@gmail.com

June 18, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of FAA Reform Act and Title 14, Code of Federal Regulations 

(14CFR): §§ 61.113 (a) and (b); 91.119; 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 

91.417(a) & (b). 

Dear Sir or Madam:

Pursuant to 14 CFR pare 11 and Section 333 of the FAA Modernization and Reform Act of 2012 (“the 

FMRA”), Aerora Inc. (referred to herein as “Applicant”), developer, operator, servicer, authorized dealer, 

and solicitor of small Unmanned Aircraft Systems (“sUAS”) equipped to conduct aerial cinematography 

operations on behalf of businesses operating in markets including insurance, real estate, legal, 

agriculture, infrastructure, motion picture, technology, government, and private security, hereby applies 

for an exemption from the enumerated Federal Aviation Regulations in order to allow commercial 

operation of its sUAS, so long as such operations are conducted within and under the conditions 

stipulated herein or as may be established by the FAA as required by Section 333. 

Aerora Incorporated seeks the exemption to retain permitted operations of sUAS exist under controlled 

conditions in airspace which; (1) provide safety enhancements to the already safe businesses presently 

using the conventional aircraft, and; (2) thereby limits, controls, and predetermines access to the sUAS. 

Applicant’s Information:

Aerora Incorporated

Attn: Peyton J. Wilson

2341 Carnegie Avenue, Suite 403

Cleveland, OH 44115

502.299.1816

aerora.inc@gmail.com

Table of Regulations in the Petition

14 CFR § 61.113(a), (b); 14 CFR § 91.119; 14 CFR § 91.121; 14 CFR § 91.151(a); 14 CFR § 91.405(a); 14 

CFR § 91.407(a)(1); 14 CFR § 91.409(a)(2); 14 CFR § 91.417(a), (b).
The petition for exemption is expressly submitted to fulfil the legislative intent of Section 333 (a) 

through (c) of the FMRA. The FMRA directs the Secretary of Transportation to consider the issue of UAS 

operations with respect to the National Airspace System (NAS) prior to the maturation of the pending 

rulemaking required under Section 332 of the FMRA. In resolving this issue, the Secretary must 

determine the type of sUAS which do not create a hazard to users of the NAS or public or pose a threat 

to national security. Such hazardous sUAS’s are determined based on the size, weight, speed, 

operational capability, proximity with respect to airports, and the operation of the sUAS within the 

visual line of sight (VLOS) of the operator(s) or spotter(s) partied to the sUAS operations. 

Upon determining such vehicles operate safely, the Secretary establishes requirements for the safe 

operation of such aircraft in the NAS. FRCA §333(a), (c). However, the Federal Aviation Act grants an 

express authority to the FAA to issue exemptions. The federal statutory authority on its face included 

the exempting of civil aircraft (defined under § 40101 of the act), which in turn includes sUAS, as per the 

requirement of all civil aircraft to retain an airworthiness certificate.

An exemption may be granted under subsection (a) or (b) of the aforementioned section, or any section 

44701-44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C.A. § 

44701 (West 2015). See also U.S.C.A § 44711(a) (West 2015); 49 U.S.C.A. § 44704 (West 2015) 

and; 14 CFR § 91.203(a)(1) (West 2015). 

Aerora Inc. seeks to use rotorcrafts which do not exceed 55 pounds (including payload). The 

rotorcraft operates at an air speed not in excess of 55 knots. The rotorcraft will be operated 

within the VLOS of the operator and/or spotter at all times while remaining in a secure area 

which ensures that the sUAS does not create a hazard to users of the NAS or the public at large. 

FMRA § 333(b) (West 2015). Aerora Inc. intention is secure environment operations and due to 

the size of the aircraft provides the “zone of safety” which manifests the intentions expressed 

by Congress when enacting FMRA. Id. In addition, with respect to the size and intended use of 

the sUAS on behalf of the applicant, Aerora Inc. within secure environments, approval of the 

application presents no issue of national security. Here, given the express direction of Section 

333 of the FRMA, and under the authority of the FAA as amended, the secure flight operations 

of the proposed aerial photography/filming operations, it stands to reason that public benefit 

vis-à-vis enhanced safety, positive environmental impacts (reduced use of larger manned 

aircraft), and positive economic impacts support granting of the requested exemption in the 

interest of the public. As a result of the aforementioned, the FAA should by exemption allow 

Aerora Inc.’s commercial operations of sUAS to commence immediately. Therefore, Aerora Inc., 

respectfully requests the FAA grant the requested exemption with haste. 

Specific Relief Requested by Aerora Inc.;

1. Private Pilot Operations under 14 CFR § 61.113(a) and (b)

14 CFR section 61.113(a) and (b) provide limits upon private pilot non-commercial operations. 14 CFR § 

61.113(a), (b) (West 2015). Distinguishable from a conventional manned aircraft, which carries a pilot

and passengers, the sUAS is operated remotely. Here, the sUAS will not carry any persons (pilot or 

passenger), and the proposed operations can thereby achieve the requisite equivalent level of safety of 
current flight operations. That is to say, the operations of the sUAS will be controlled and restricted as 

all flights will be planned and coordinated prior to commencing operations. Thus, the level of control 

and restriction exceed the requirements by a commercial pilot operating a conventional aircraft. In 

addition, the level of restriction aforementioned will so diminish the risk associated with commercial 

operations contemplated when part 61 was drafted that allowing the operation as requested clearly 

exceeds the levels of safety achieved by 14 CFR § 61.113(a) and (b). 

2. Minimum Safe Altitudes under 14 CFR § 91.119

14 CFR section 91.119 proscribes safe altitudes for civil aircraft operations. 14 CFR § 91.119 (West 2015). 

Section 91.119 permits helicopter operations in lower altitudes on the condition that the helicopter 

operator complies with the FAA’s relative route and altitude instructions. Here, the request is for sUAS 

rotorcraft operations below 400 feet above ground level or for filming operations no more than 200 feet 

above any platform which filming is planned, as an exemption may be necessary for such operations. As 

set forth herein, Aerora Inc., applicant, will not operate sUAS in excess of 400 feet at any time. As 

previously mentioned, and equivalent level of safety as intended by congress will be achieved due to the 

size, weight, and speed of the sUAS in addition to the locations where the sUAS will be operated. No 

flight will occur without the consent of the property owner(s) and local official(s). Thus, with the consent 

of the property owner and notice to the participants to the aerial photography all affected individuals 

will be aware of the planned sUAS operations. Moreover, the lack of flammable fuel, the nominal size of 

the sUAS, are significantly less than any associated risk with the operation of manned aircrafts at or 

below 400 feet above ground level.

3. Altimeter Settings under 14 CFR § 91.121 

The sUAS in operation does not have a barometric altimeter, but instead functions with Global 

Positioning Satellite altitude data readouts an exemption to 14 CFR section 91.121 may be necessary. In 

pertinent part, “... to the elevation of departure airport or an appropriate altimeter setting available 

before the departure”, requires each operator to maintain cruising altitude by virtue of an altimeter that 

is fixed. 14 CFR § 91.121 (West 2015). Here, the level of safety will most likely exceed the level of safety 

by confirming the altitude of the launch site shown on the GPS readouts prior to any flight operations. 

4. Fuel Requirements for Flight in Visual Flight Rules Conditions under 14 CFR § 91.151 (a) 

Aerora Inc. seeks an exemption for under 14 CFR section 91.151 (a). Aircrafts are required to retain a 30 

minute fuel reserve as per 14 CFR section 91.151. 14 CFR § 91.151 (a) (West 2015). However, the 

batteries powering Aerora Inc.’s sUAS(s) provide approximately 45 minutes of flight time. Therefore in 

order to meet the requirements set forth under section 91.151(a) the sUAS flights would be limited to 

roughly 15 minutes. Aerora Inc. respectfully asserts an exemption from 14 CFR section 91.151 (a) is 

reasonable as an exemption falls within the scope of previously approved exemption petitions. See FAA 

Exemptions 10673, 268F, 5745, 10808, and 11633. Limiting sUAS flights to approximately 15 minutes 

would greatly reduce the utility for the aerial cinematography for which the exemption is sought. Thus, 

applicant asserts an equivalent level of safety can be achieved by limiting flights to 30 minutes or 20 

percent of battery power. This restriction provide adequate time to return the sUAS to a planned 

landing zone within the sUAS secure operating area. Thus, as per the aforementioned previously 

approved exemptions the applicant seeks similar exempt status from 14 CFR section 91.151 (a).

5. Maintenance Inspections under 14 CFR § 91.405(a); § 91.409(a)(2); § 91.417(a) and (b) 
The enumerated sections and part 43 apply to aircraft with airworthiness certificates, and therefore 

these sections will not apply to the applicant. Moreover, the performance of any requisite maintenance 

will be conducted and logged to ensure that the sUAS remains in working order prior to any flight 

operations. The maintenance logs will be available to the FAA upon request. 

Terms and Conditions to which Aerora Incorporated agrees to be bound during any and all commercial 

operations of Small Unmanned Aerial Systems

1. All aircraft operated in accordance with this exemption will be identified by serial number, 

identification number (N-Number) markings in accordance with 14 CFR part 45, and registered 

in accordance with 14 CFR part 47. The sUAS will not at any time exceed a weight of 55 pounds 

or a speed of 55 knots. The sUAS will be programed to return to a predetermined landing 

location in the event that manual control is lost. No sUAS operation will exceed thirty minutes of 

flight time or fifteen percent of total battery power remaining, whichever occurs first. 

2. No sUAS operations will be conducted at night as required by 14 CFR section 1.1 and all 

operations will be conducted under weather conditions which are conducive to the visual line of 

sight requirements of safe flight operations. 

3. The operations authorized by this grant of exemption are limited to the following aircraft: DJI 

phantom series, DJI Inspire 1, and DJI s1000. Aerora Inc. will provide serial numbers and 

registration or proof of non-registration (brand new aircraft) of all sUAS upon request by the 

FAA. 

4. All flight manuals and general operating manuals will be maintained by Aerora Inc. and will be 

made available to the FAA upon request. Aerora Inc. will follow the procedures as outlined in 

the flight manuals and general operating manuals and will track any revisions to either of the 

aforementioned documents and present any update or revision if a subsequent petition for 

extension or amendment occurs. Moreover, if any discrepancy exists between the exemption 

and procedures outlined in the flight manuals and/or general operating manuals, the conditions 

herein retain superiority and thereby must be followed. 

5. The crew for each commercial operation will consist of a pilot, spotter or visual observer, and 

camera operator. The spotter satisfies the visual line of sight requirement at all times so long as 

s/he is within the proximate verbal communication vicinity of the pilot. 

6. During all flights all persons not essential for flight operations will be considered non-partied to 

the flight operations. Thus, the pilot will operate the sUAS the requisite distance from these 

non-parties to the flight operations in accordance with 14 CFR section 91.119. 

7. Before conducting commercial sUAS flight operations the crew will complete tests conducted by 

Aerora Incorporated which will be documented as there are currently no established test 

standards for sUAS flight operations. The tests conducted by Aerora Incorporated will coincide 

with the qualification processes detailed in the general operating manuals for the respective 

sUAS(s). The record completion of these processes will be documented and made available to 

the Administration upon request. 
8. The flight and general operating manuals will be available to the pilot at all times during flight 

operations in accordance with 14 CFR section 91.9 and 14 CFR section 91.203. These documents 

will be made available to the Administrator or any law enforcement official upon request. 

9. Prior to conducting commercial aerial cinematography operations, the operator will log a 

minimum of 25 hours of total time as a UAS rotorcraft pilot in accordance with 14 CFR section 

61.51(b). Additionally, the operator will accumulate and log consistent with 14 CFR section 

61.51(b) at least 5 hours of the make and model to be used for operations under the exemption 

with a minimum of six take offs and landings. 

10. During all training operations all persons not essential for flight operations are to be considered 

non-participants and the operator will be required to operate the sUAS in accordance with the 

distance requirements under 14 CFR section 91.119.

11. Record of the successful completion of the qualification process detailed in the general 

operating manual and administered by Aerora Inc. will be made available for each member of 

the crew upon the request of the Administrator. As this is a requirement promulgated by Aerora 

Inc. the test is to be administered and implemented by a qualified person designated at the 

discretion of Aerora Inc. 

12. Prior to commercial sUAS cinematography flight operations a demonstration will be 

administered by an operator approved and otherwise qualified and thereby documented. This 

documentation of the demonstration will be made available to the Administrator upon request. 

As no established tests or standards which support the jurisdictional FAA Flight Standards 

District Office evaluation with respect sUAS flight operations for the previously enumerated 

sUAS(s) Aerora Inc. will conduct these tests in accordance with the general operating manual. 

13. Any and all documents required under 14 CFR sections 91.9, and 91.203 will be available to the 

operator at any time during the operations of the aircraft. Moreover, these documents will be 

made available to the Administrator or and law enforcement official upon request. 

14. Under the event that the sUAS undergoes any maintenance, repair, or alteration which effects 

the flight operations, for example the replacement of a propeller, the entire sUAS will undergo a 

functional flight test. The flight test will be conducted in accordance with the general operating 

manual. The operator who conducts the results of the flight test in the sUAS aircraft records. 

15. Current maintenance procedures, inspection requirements, and lift limits for the entirety of the 

sUAS(s) enumerated herein will be periodically updated and retained on file with Aerora Inc. 

and made available to the Administrator upon request. 

16. Any technician who is to perform maintenance and/or inspection on the sUAS will meet all 

qualification criterions developed by Aerora Inc. with respect to the guidelines set forth in the 

general operating manual. Additionally, each sUAS operated under this exemption will comply 

with the manufacturer’s promulgated safety guidelines as the general operating manual 

provides processes by which to document and record the sUAS maintenance.

17. Prior to each flight, the operator will inspect the sUAS to ensure it is safe for flight condition. The 

operator must approve of the aircraft in order for flight operations to ensue. If the operator 

finds upon the pre-flight inspection the sUAS ability to fly safely is compromised the aircraft is 
prohibited from operations until necessary maintenance has been performed and the sUAS is 

otherwise approved for safe flight operations. 

18. The sUAS will be operated in the visual line of sight of the operator, or the spotter under the 

instance that virtual reality eyewear is used by the operator so long as the spotter is within the 

proximate communication distance of the operator, at all times. 

19. All flights will be operated at an altitude of no more than 400 feet above ground level. All 

altitudes reported and recorded will be in feet above ground level.

20. The operator will ensure no person(s) in open areas are allowed within 500 feet of the aircraft 

except under the circumstances that those persons by either express or implicit consent to be a 

party to the cinematography and are deemed necessary for the aerial cinematographic flight 

operations. However, if barriers exist between the sUAS operations and the non-parties to the 

flight operations which will sufficiently protect the non-parties to the flight operations from any 

debris in the event of a misfortunate event then the sUAS may operate closer than 500 feet to 

persons afforded such protection. If a situation occurs to which the persons leave such 

protection of a barrier affording protection and are thereby within 500 feet, then the operator 

must either cease flight operations, or move to a safe distance of 500 feet away from said 

person immediately. 

21. The approval of Flight Standards District Office or aviation-safety inspector will be deemed 

unnecessary with respect to reductions to the distances set forth in the general operating 

manual consistent with the manned aircraft procedures promulgated in Federal Aviation 

Administration Order 8900.1, V3, C8, S1. However, the sUAS will always yield to the right of way 

to all other manned flight operations and aerial activities for example but not limited to 

parasailing, parachuting, and etcetera. 

22. The sUAS will not operate in a Class B, C, or D airspace without written approval from the FAA 

nor will the sUAS operate within five nautical miles of the epicenter of a non-towered airport 

unless otherwise a letter of agreement exists with the airport’s management. If such a letter 

manifests, it will be made available to the Administrator upon request. 

23. As per the general operating manual the sUAS will only operate within the secured area(s) which 

are established by pre-flight security perimeter(s) conducted and logged before each flight by 

the crew. A pre-flight briefing will establish the secure area, and security perimeter. Each 

member of the crew is required to attend this pre-flight briefing. The logs of the briefings and 

security perimeters will be made available to the Administrator upon request. 

24. Any accident will be reported to the National Transportation Safety Board per the instructions 

contained at www.ntsb.gov. In the event of an accident and after the report to the NTSB is 

submitted further flight operations for the sUAS and crew who were partied to the accident will 

be suspended until AFS-80 authorization to resume operations is provided. 

25. Applicant agrees that failure to comply with any of the conditions and limits of this grant of 

exemption are grounds for immediate rescission of this exemption. 

26. Unless otherwise specified in the grant of this exemption, applicant agrees to comply with all 

applicable parts of 14 CFR. 
Under 14 CFR part 11, the subsequent summary is provided for publication in the Federal Register:

Aerora Incorporated seeks an exemption from the following rules Title 14, Code of Federal 

Regulations (14CFR): §§ 61.113 (a) and (b); 91.119; 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 

91.409(a)(2); and 91.417(a) & (b), and seeks permission to operate sUAS commercially in 

cinematographic flight operations. 

The approval of exemptions which allow commercial flight operations of sUAS(s) invariably enhance 

safety by reducing risks. Traditional aircraft can weigh in excess of 10,000 pounds, use jet engines 

for propulsion, and at times operate in close proximity to people and fixed ground structures. Risks 

that are present in the traditional operations of manned aircraft include those associated with large 

amounts of highly flammable fuel and other flammable liquids. Dissimilarly, the sUAS weighing less 

than 55 pounds and operating on battery power eliminates the risks associated with manned 

aircraft as the lack of combustible fuel is ever present in sUAS flight operations. Moreover, sUAS(s) 

do not carry passengers or a crew and therefore do not expose people at large to the risks 

associated with manned aircraft. All flight operations will exist over controlled access properties 

with the prior consent of the property owner. All cinematographic flight operations will be 

conducted with the consent of the parties to the flight operations and all flight operations will be in 

compliance with local and state laws.

The operation of sUAS in accordance with the conditions set forth hereinto provide an equivalent 

safety level which supports the grants of the exemptions petitioned for herein. The sUAS(s) Aerora 

Inc. seeks to use are small, lightweight aircraft, which operate in secure environments, close to the 

ground, at relatively slow speeds. All of which as a result suggests that Aerora Inc.’s operation of 

sUAS(s) are safer to society than traditional operations conducted with helicopters or other aircraft. 

The criteria set forth in Section 333 of the Reform Act have been satisfied by the applicant’s request. 

The enumerated conditional flight operations aforementioned do not create a hazard to users of the 

national airspace system and do not pose any national security threats or concerns. Thus, the 

foregoing meets the criteria necessary for granting the requested exemptions thereby allowing 

Aerora Inc.’s commercial operations of sUAS pursuant to the general operating manual and the 

aircraft flight manuals attached hereinto. 

Respectfully Submitted with Kind Regards,

______________________________________

Peyton J. Wilson

Aerora Inc.

2341 Carnegie Avenue, Suite 403

Cleveland, OH 44115

502.299.1816

aerora.inc@gmail.com