Gerald W. Lempicki

3D UAV Aerial Services

452 Williamsburg Road

Ashfield, MA 01330

September 29, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Dear Mr. Duncan:

This letter constitutes a petition for exemptions in accordance with Section 333 of the 

FAA Modernization and Reform Act of 2012. I, Gerald W. Lempicki, doing business as 

3D UAV Aerial Services, intend to use small unmanned aircraft systems (SUAS) for the 

purposes of aerial photography, video capture, closed-set filming, surveying, 

inspections, data collection, SUAS/UAV operational training, and demonstration of 

SUAS/UAV capabilities.

I seek relief from the following:

 14 CFR Section 61.23 (a) and (c): Medical certificate requirement

o I request exemption so as to not require the operator to hold a medical 

certificate.

 14 CFR Section 61.101 (e)(4) and (5): Recreational pilot limitations

o I request exemption so as to allow a recreational pilot certificate holder to 

operate the UAS for compensation or hire, and in furtherance of a 

business.

 14 CFR Section 61.113(a): Private pilot limitations

o I request exemption so as to allow a private pilot certificate holder to 

operate the UAS for compensation or hire, and in furtherance of a 

business.

 14 CFR Section 61.315(a): Sport pilot limitations

o I request exemption so as to allow a sport pilot certificate holder to operate 

the UAS for compensation or hire, and in furtherance of a business.

 14 CFR Section 91.7(a): Civil aircraft airworthiness

o I request exemption so as to allow the operator to determine airworthiness 

based on a preflight inspection incorporating manufacturer’s 

recommendations.
 14 CFR Section 91.119(c): Minimum safe altitudes

o I request exemption so as to allow operation of the UAS from the surface 

up to 400’ AGL.

 14 CFR Section 91.121: Altimeter settings

o I request exemption so as to allow operation with existing UAS flight 

controller technology, be it GPS derived or pressure sensor derived 

altitude.

 14 CFR Section 91.151(a)(1): Fuel requirements

o I request exemption so as to allow UAS operation by maintaining a 

reasonable reserve power supply in order to complete the mission in the 

event of unforeseen winds/occurrences.

 14 CFR Section 91.405(a): Maintenance required

o I request exemption so as to allow operation of the UAS given preflight 

and post flight inspections based on manufacturer recommendations and 

operator experience.

 14 CFR Section 91.407(a): Operation after maintenance, etc.

o I request exemption so as to allow operation of the UAS based on 

following manufacturer’s recommended maintenance procedures.

 14 CFR Section 91.409(a)(1)(2): Inspections

o I request exception from annual inspection and airworthiness certificate 

requirements so as to allow operation of the UAS based on preflight 

inspections and proper maintenance according to the manufacturer.

 14 CFR Section 91.417(a)(b): Maintenance records

o I request exemption from 14 CFR Section 91.417(a) and (b) as written. I 

will maintain operational and inspection logs to satisfy my safety and 

operating requirements.

3D UAV Aerial Services intends to use the following SUAS, to be selected based on the 

mission profile required by the client:

 3DR Solo

 DJI Inspire 1

 DJI Phantom 3 Pro

 DJI F550

 DJI S900

 DJI S1000

 Birdseyeview Aerobotics Firefly6

 Action Drone AD-1

All of the above are electric powered and meet the weight requirements of a small 

unmanned aircraft system. For convenience, the manuals and specifications are 

hyperlinked above.
As shown by numerous previously granted SUAS exemptions, commercial operations of 

SUASs will enhance safety by reducing exposure to risk. Conventional aircraft are 

much larger than SUASs, and are inherently more dangerous due to the volume of fuel 

on board. SUASs generate less noise and have less environmental impact.

A high level of safety will be maintained by following the SUAS manufacturer’s 

recommended operating procedures, my Operations Manual, and Motion Picture 

Television Operations Manual (when applicable). These documents are currently being 

drafted and reviewed, and will adhere to previously established industry protocols. In 

addition, the operator will adhere to all terms, conditions, and limitations of the 

exemptions granted.

As I wish to provide inspection and data collection services, the result of this action 

would contribute to the overall integrity of our infrastructure and reliability of our utilities.

In summary, 3D UAV Aerial Services seeks exemption from the following rules: 14 CFR 

Section 61.23 (a) and (c), 14 CFR Section 61.101 (e)(4) and (5), 14 CFR Section 

61.113(a), 14 CFR Section 61.315(a), 14 CFR Section 91.7(a), 14 CFR Section 

91.119(c), 14 CFR Section 91.121, 14 CFR Section 91.151(a)(1), 14 CFR Section 

91.405(a), 14 CFR Section 91.407(a), 14 CFR Section 91.409(a)(1) and (2), and 14 

CFR Section 91.417(a) and (b).

I do not believe the request for exemption of the above rules would set a precedent; 

upon review of the FAA’s Authorizations Granted via Section 333 Exemptions it is clear that there 

have been many previously approved exemptions for similar purposes.

If you require any additional information, please contact me here.

Sincerely,

Gerald W. Lempicki

3D UAV Aerial Services