July 14, 2015

Exemption No. 12037

Regulatory Docket No. FAA–2015–1431

Mr. Michael Finnegan 

Owner/Operator

Photo Elevations LLC

2508 Eagle Lane, NE.

Bemidji, MN 56601

Dear Mr. Finnegan:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 17, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Photo Elevations LLC (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

photography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S1000+.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 
2

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Photo Elevations LLC is granted an exemption 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), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

Conditions and Limitations

In this grant of exemption, Photo Elevations LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3, 

DJI Inspire 1, and DJI Spreading Wings S1000+ when weighing less than 55 pounds 

including payload. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

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

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

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

This requires the PIC to be able to 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 must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and 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 must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 
4

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

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

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

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

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

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must 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.
5

14. The operator may 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 this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

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

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

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

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate 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 with 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 the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may 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 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

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

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning 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 least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
6

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

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

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, 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 must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall 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.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
7

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
April 17, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Attention: Flight Standards Service Director

Dear Mr. Duncan,

We at Photo Elevations LLC sincerely thank you for your time and consideration for the 

following review.

Re: Expedited Exemption Petition of Section 333 of the FAA Reform Act of 2012 to 

Operate Small Unmanned Aircraft Systems (sUAS) For Commercial Purposes 

Under the New “Blanketed” (COA) Below 200 feet Above Ground Level (AGL) 

policy for following Pursuant:

Photo Elevations LLC

Michael Finnegan, Owner/Operator

2508 Eagle Lane NE

Bemidji, MN 56601

218-368-1375

photoelevations@yahoo.com

I, Michael Finnegan, sole owner/operator of Photo Elevations LLC, prepared the 

following document. The use of the terms, “I” “My” “We” “Our” or “The Company” 

from here forth within this document refer to Photo Elevations LLC.

Photo Elevations LLC respectfully requests exemption from the following Federal 

Aviation Administration (FAA) regulations:

14 CFR Part 21, Subpart H, 14 CFR Part 27, 14 CFR sections 45.23(b), 61.101(e)(4) and 

(5), 61.113(a), 61.23(a) and (c), 61.315(a), 91.103, 91.105, 91.109, 91.119, 91.121, 

91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b), 

91.7(a).

About Photo Elevations LLC and UAS Commercial Applications

Based in Bemidji, MN, Photo Elevations LLC is a small, yet, rapidly growing company 

that is dedicated towards addressing a wide variety of photographic applications both on 

and off the ground. Our Aerial Division foresees an abundance of opportunity and 

discovery. Our initial requests for service have come with a strong demand from the Real 

Estate and Land Development markets. However, as the technology quickly proves its 

value, we will be heavily focused on agricultural monitoring of growth, development and 

deficiencies, as well as, commercial advertising, public safety services, such as, search 
and rescue emergencies, lake-ice safety monitoring and first responder for hazardous 

condition assessments like material spills and fires, both controlled and wild. We also 

project a wide variety of Environmental Safety and Conservation applications in the near 

future. This could include botanical and wildlife studies and safety assessments, as well 

as, forest canopy monitoring and expedited detection of invasive species like the Pine 

Bark Beetle, Emerald Ash Borer or the Forest Tent Caterpillar into Minnesota territories.

About Michael Finnegan, Owner/Operator, Photo Elevations LLC

I, Michael Finnegan, a long time advocate and hobbyist of many varied UAS’s, graduated 

from Brooks Institute of Photography, Santa Barbara, CA in 1996 with a BA in 

Illustration and Advertising Photography along with a Minor in Audio/Visual 

Photography and Videography. My pertinent collegiate resume also includes 

Meteorology courses at Montana State University. My decades experience and 

professionalism in difficult situation photography for commercial purposes is very vast. 

During my career, I have always placed public, crew and overall operational safety on the 

highest plateau. As an Ambassador of an amazingly new technology, Photo Elevations 

LLC will always strive to be an exemplary representative of proper UAS’s integration 

into National Air Space (NAS) for commercial applications. Our safety protocols and 

paramount professionalism will never be compromised.

Pilot In Command (PIC) Training Requirements

Photo Elevations LLC strongly believes the safe integration of UAS’s into National Air 

Space (NAS) is of the utmost importance and is wanting/willing to adhere to any 

additional regulations imposed by the FAA in order to maintain the NAS safety and 

security.

In order to maintain and advance those necessary safety and security protocols of an 

emerging industry, Any/All Photo Elevations LLC PIC’s must possess and complete the 

following FAA and Operator requirements before any consideration for commercial 

flight takes place:

1. All PIC’s must complete appropriate Pilot School training and pass the 

Aeronautics Knowledge Test conducted by the Federal Aviation Administration.

2. All PIC’s must be vetted by the Transportation Safety Administration (TSA).

3. All PIC’s must complete and log a minimum of 100 hours of advanced flight 

simulation time using our Real Flight Professional RF 7.5 flight simulation 

training programs.

4. All PIC’s must complete and log a minimum of 40 hours actual hands on flight 

training at our privately owned, expansive and rural located training facility.

5. All PIC’s must possess advanced safety training and knowledge, as well as, 

advanced training in Pre & Post flight planning, maintenance, checklists, etc.. 

6. All PIC’s must pass Photo Elevations LLC strictly monitored final flight tests.

The Photo Elevations LLC Operator and PIC’s would also strictly respect any/all further 

requirements and regulations set by the FAA including but not limited to the following:
1. The UAS must weigh less than 55 pounds, including payload.

2. Operations for closed-set motion picture and television filming are not permitted.

3. The UAS would never exceed a speed of 87 knots (100 miles per hour).

4. All flights are strictly limited to the current COA height of less than 200 feet

above ground level (AGL). Any higher altitudes would require a new COA 

approval from the FAA.

5. The UAS must be operated within the unaided visual line of sight (VLOS) of the 

PIC at all times.

6. The Operator is responsible for maintaining and inspecting the UAS to ensure that 

it is in a condition for safe flying.

7. Pre and Post Flight safety inspections and documentation.

8. No flight operations will be held at night and conducted under visual 

meteorological conditions (VMC).

9. The UA will not operate within 5 nautical miles (NM) of any airport with an 

operational tower; or 3 NM from an airport with a published instrument flight 

procedure; or 2 NM from an airport without a published instrument flight 

procedure or operational tower; or 2 NM from a heliport with a published 

instrument flight procedure.

10. Any UAS’s operated by Photo Elevations LLC would be properly identified by

serial number, registered in accordance with 14 CFR 47, and have (N-Number) 

markings as large as practicable.

11. The UA must remain clear and give way to all manned aviation operations and 

activities at all times.

12. The UAS may not be operated by the PIC from any moving device or vehicle.

Proposed UAS’s For Exemption and Their Physical Descriptions

Depending on our photographic, environmental safety and/or atmospheric conditional 

needs, we have three UAS’s prepared for business operations. At this time we formally 

request exemption for the DJI Phantom 3, DJI Inspire 1 and DJI Spreading Wings 

S1000+; all of which have had precedent rotorcraft UAS Section 333 exemption approval 

by the FAA. As performance and safety technologies quickly advance, we too should 

advance with them. Therefore we respectfully request the approval to update our DJI 

series systems software and hardware when need be as long as they fit within the FAA’s 

UA size and weight parameters and follow all further imposed regulations.

These are the latest models in their class from DJI, a worldwide leader in technologically 

advanced small rotorcraft, radio controlled (RC) aircraft. Each of the proposed models 

are equipped with highly advanced control and navigational features and fit within the 

prior safety requirements set forth by the FAA.

Included with this petition for exemption are the proposed model flight safety guidelines, 

battery safety guidelines and maintenance manuals for the DJI Inspire 1, Phantom Series 

and Spreading Wing S1000+ series. Due to the large size data files of the pilot training 
manual and user manuals (exceeding the 10MB file maximum allowed for online 

submissions) and prior precedent exemption grants by the FAA for each proposed UAS, 

full user manuals (containing all specifications) are not included with this petition. They

are available upon request or at the following website links:

DJI Inspire 1:

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf 

DJI Spreading Wings S1000+

http://download.djiinnovations.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf

DJI Phantom Series: (Phantom 3 manual not yet available online)

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_

Manual_v1.8_en.pdf

DJI Pilot Training Manual:

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_Pilot_

Training_Guide_v1.1_en.pdf

UAS Radio Frequencies

All devices used will comply with the FCC usage and emissions regulations and 

guidelines. The radio frequencies used will also comply with the allotted FCC 

frequencies for data transmission and vehicle control in unlicensed frequency bands. 

(More on radio frequencies provided on the specification/user manuals included with this 

petition.)

About our Location

Bemidji is located in North-Central Minnesota. With a population of nearly 15,000, 

Bemidji is a central hub of an expansive rural territory made up of agriculture farmlands 

and dynamic forests both privately and publicly owned. Lakes, bogs and grasslands are 

also abundant. A majority of our aerial operations would take place in extremely remote, 

rural locations.

Public Safety, Privacy and Environmental Impact

Photo Elevations LLC is very excited to have our foot in on the ground floor of such an 

extraordinary and electrifying new industry. As mentioned before, flight safety is of the 

highest importance and we vow to maintain all regulations and guidelines to the highest 

standards. These standards would also adhere towards all privacy rights and 

environmental impact issues.

This new sUAS technology virtually releases both the environmental and economic 

restraints on a level never fathomed before in the aerial photography industry. 

Traditional methods of piloted aircraft for our proposed purposes are extremely 
expensive, produces high levels of toxic emissions into the atmosphere, carry large 

payloads of flammable fuel and greatly increase the risk of human endangerment. For 

those reasons, Photo Elevations LLC believes its proposed services are in the best Public 

Interest.

Our small, lightweight, micro UAS’s run on rechargeable LiPo batteries and produce zero 

toxic emissions during flight. They’re highly controllable with advanced safety features 

for stabilization, GPS navigations, electronic speed controllers, autopilot safety modes 

and real-time data transmissions and recording. Overall, the proposed UAS’s greatly 

increase public safety and benefits as compared to conventional methods of aerial 

photography. 

Pre and Post Flight Checklist/Inspections

To include, but not be limited to the following:

1. Inspect all parts and system components for proper working condition. 

 Including, but not limited to:

a. Actuators/Servos

b. All Motors

c. Wiring and Connectors

d. Propellers, cleaned, inspected for damage, mounted correctly

e. Electronic Speed Controllers 

f. Batteries Levels and Condition of all power supplies.

g. Remote Control Functions and Settings

h. Ground Station equipment and connections

 

2. Conduct preflight safety discussions and assessments regarding areas of 

concern and taking steps to minimize all safety risks prior to flight.

3. Proper clearance of NAS, if need be, and proper permission for land use.

4. Spectator, Crew and Public Safety management.

5. Must have on hand all necessary flight documents, handbooks, 

exemptions, etc.

6. All preflight inspections and operational testing recommended in the UAS 

user and operational manuals.

Conditions

Photo Elevations LLC will only conduct operational flights under ideal visual 

meteorological conditions (VMC). No flights will take place in obstructed view 

locations or during unpredictable weather conditions. No flights will be conducted less 

than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is 

less than 3 statute miles from the PIC. No flight operations will be conducted at night. 

All flights will be aborted in the event of unpredicted obstacles or emergencies.
Licensing and Supporters of Photo Elevations LLC

Photo Elevations LLC has obtained proper State and Local licensing, extensive liability 

insurance coverage, and proper Federal and State Tax Identification Numbers, as well as, 

approval support from local Law Enforcement, Bemidji Fire Dept., City Council 

Members, Local Business Owners and the Chamber of Commerce. Acceptance of this 

emerging technology is growing fast through the use of the tremendous visual benefits. 

Seeing is believing and Photo Elevations LLC wants to help show our Community a new 

vision and the amazing reimbursements that flow with.

Petition Summery

Petition Pursuant:

Photo Elevations LLC

Michael Finnegan, Owner/Operator

2508 Eagle Lane NE

Bemidji, MN 56601

218-368-1375

photoelevations@yahoo.com

Re: Expedited Exemption Petition of Section 333 of the FAA Reform Act of 2012 

Photo Elevations LLC respectfully requests exemption from the following Federal 

Aviation Administration (FAA) regulations:

14 CFR Part 21, Subpart H, 14 CFR Part 27, 14 CFR sections 45.23(b), 61.101(e)(4) and 

(5), 61.113(a), 61.23(a) and (c), 61.315(a), 91.103, 91.105, 91.109, 91.119, 91.121, 

91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b), 

91.7(a).

Proposed UAS’s: DJI Phantom 3, DJI Inspire 1, DJI Spreading Wings S1000+

Proposed Uses:

Real Estate and Land Development

Agricultural

Commercial Photography

Public Safety Services

Aerial Surveying 

Botanical and Wildlife Studies/Assessments 

Invasive Species Detection

Conclusion

Photo Elevations LLC would like to thank you again for your time and consideration. 

The FAA has granted prior exemptions in circumstances similar in all material respects to 

those presented in this petition. We strongly believe our services will greatly benefit the 

surrounding community and serve in the public’s overall best interest as a whole. For the 

preceding reasons listed throughout this petition, Photo Elevations LLC formally asks for 

these exemptions. Thank you.

Sincerely,

Michael Finnegan