July 14

, 2015

Exemption No. 12037 Regulatory Docket No. FAA

– 20 15

– 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 1 7, 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 ai rcraft system (UAS) to conduct aerial photography

.
See Appendix A for the petition submitted to the FAA des cribing 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, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria2

provided in Section 333 of P ublic 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

, C ertification 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 collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 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 Lab s , 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 fue l, 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 pre sent; 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), 9 1.121, 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 (part iculate 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 immediat e 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 operat ing 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 observe r (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 ver bally at all times ;

e lectronic 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 pe rform 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 do cuments. 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 pr ocedures 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 gr anted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’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 un dergone 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 tes t 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 f or 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 accou nt 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 perf ormed 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 med ical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircr aft 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 purp oses of training the operator’s PICs and VOs (traini ng, 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 traini ng, 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 symbo l 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 le tter 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 visibilit y is less than 3 statute miles from the PIC.

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

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredic ted 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 cond ucted in accordance with an ATO

- issued COA. The exemption holder may a pply 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 C FR 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 mus t 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
per sons, 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 unde r 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 control led

- access property with permission from the property owner/controller or authorized re presentative. 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 are a as defined by the applicable COA must be reported to the FA A'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 Dis trict Office (FSDO) with jurisdiction over the a rea 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 nu mber of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e 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 numb er 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 in spector 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 ac complish 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 thi s 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

EnclosuresApril 17, 2015

United States Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE Washington, DC 20590

Attention: Flight Standards Service Director

Dear Mr. Duncan,

We at Photo Elevations LLC sincerel y 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**  **Sm all**  **Unmanned Aircraft**  **Systems (sUAS)**  **For Commercial**  **Purposes Under**  **the New**  **“Blanketed” (COA)**  **Below 200**  **feet Above**  **Groun d**  **Level (AGL)**  **policy for following Pursuant:**

Photo Elevations LL C Michael Finnegan, Owner/Operator 2508 Eagle Lane NE Bemidji, MN 56601 218

- 368

- 1375 photoelevations@y ahoo.com

I, Michael Finnegan, sole ow ner/operator of Photo Elevations LLC, prepared the following document. T he 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**  **fro m**  **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, rapidl y growing company that is dedicated towards addr essing a wide variety o f photographic applications both on and off the ground. O ur Aerial Division foresees an abundance of opportunity a nd discovery . Our initial requests for service have come with a strong demand from the Real Estate and Land Developme nt markets. H owever, as the technology q uickly p roves its value, we will be heavily focused on agricultural monitoring of growth, development and deficiencies, as well as, commercial advertising, public safet y services, such as, searchand rescue emergenc ies, lake

- ice safet y monitoring and first responder for hazardous

condition assessments like material spills and fires, both controlled and wild. W e also project a wide variet y of Environmental Safet y and Conservation applications in the near future. T hi s could include botanical and wildlife studies and safet y assessments, as well
as, forest canop y 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 hobby ist of many varied UAS’s, graduated from Brooks Institute of Photograph y, Santa Barbara, CA in 1996 with a BA in Illustration and Advertising Photograph y along with a Minor in Audio/Visual Photograph y and Videograph y. M y pertinent collegiate resume also includes Meteorology

c ourses at Montana State University. M y decades experience and professionalism in difficult situation photography for comm ercial purposes is very v ast. During m y career, I have alway s placed public, crew and overall operational safety on the highest plateau. A s an Ambassador of an amazingl y new technology

, Photo Elevations LLC will alway s strive to be an exemplary r epresent ative of proper UAS’s integration into National Air Space (NAS) for commercial applications. O ur safet y protocols and paramount professionalism will never be compromised.



### Pilot In Command (PIC) Training Requirements

Photo Elevations LLC strongl y believ es the safe integration of UAS’s into National Air Space (NAS) is of the utmost importance and is wanting/willing to adhere to an y additional regulations imposed by t he FAA in order to maintain the NAS safet y and securit y.

In order to maintain and advance those necessary s afet y and securit y protocols of an emerging industry

, An y/ All Photo Elevations LLC PI C’s must possess and complete the following FAA and Operator requirements before an y consideration for commercial flight takes place:

1. All PI C’s must com plete appropriate Pilot School training and pass the Aeronautics Knowledge Test conducted b y the Federal Aviation Administration. 2. All PI C’s must be vetted by the Transportation Safety Administration (TSA). 3. All PI C’s must complete and log a minimum of 10 0 hours of advanced flight simulation time using our Real Flight Professional RF 7.5 flight simulation training programs. 4. All PI C’s must complete and log a minimum of 40 hours actual hands on flight training at our privatel y owned, expansive and rural loca ted training facility

. 5. All PI C’s must possess advanced safet y training and knowledge, as well as, advanced training in Pre & Post flight planning, maintenance, checklists, etc.. 6. All PI C’s must pass Photo Elevations LLC strictl y monitored final flight test s.

The Photo Elevations LLC Operator and PI C’s would also strictly r espect 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 pay load.

2. Operations for c losed

- 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 l imited to the current COA height of less than **200 feet**  above ground level (AGL). An y higher al titudes 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 PI C at all times. 6. The Operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition f

or 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 an y airport with an ope rational 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 U A S’s operated by

P hoto Elevations LLC would be properl y 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 t o all manned aviation operations and

a ctivities at all times. 12. The UAS may

not be operated b y the PIC from any moving device or vehicle.



### Proposed UAS’s For Exemption and Their Physical Descriptions
Depending on our photographic, environmental safety a nd/or atmospheric conditional needs, we h ave three UAS’s prepared for business operations. A t this time we formall y request exemption for the DJ I Phantom 3, DJI In spire 1 and DJ I Spreading Wings S1000+; all of which have had precedent rotorcraft UAS Section 333 exemption approval by t he FAA. A s performance and safet y technologies quickl y advance, we too should advance with them. T herefore we respectfully r equest the approval to update our DJ I series sy stems software and hardware when need be as long as they f it within the FAA’s UA size and weig ht parameters and follow all further imposed regulations.

These are the latest models in their class from DJI, a worldwide leader in technologicall y advanced small rotorcraft, radio controlled (RC) aircraft. E ach of the proposed models

are equipped with highly a dvanced control and navigational features and fit within the prior safet y requirements set forth b y the FAA.

In cluded with this petition for exemption are the proposed model flight safety g uidelines, battery s afet y guidelines and maintenance manu als for the DJ I Inspire 1, Phantom Series and Spreading Wing S1000+ series. D ue to the large size data files of the pilot trainingmanual and user manuals (exceeding the 10MB file maximum allowed for online

submissions) and prior precedent exemption grant s by t he FAA for each proposed UAS, full user manuals (containing all specifications) are not included with this petition. T hey are available upon request or at the following website links:
**DJI Inspire 1:** http://download.dji

innovations.com/downloads/in spire_1/en/Inspire_1_User_Manual_v1.0_en.pdf
**DJI Spreading Wings S1000+** http://download.dji

innovations.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf

**DJI Phantom Series:** (Phantom 3 manual not y et available online) http://download.dji

i nnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_ Manual_v1.8_en.pdf
**DJI Pilot Training Manual:** http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_Pilot_ Training_Guide_v1.1_en.pdf

**UAS R adio Frequencies**  All devices used will comply w ith the FCC usage and emissions regulations and guidelines. T he radio frequencies used will also comply w ith the allotted FCC frequencies for data transmission and vehicle control in unlicensed frequency b and s. (More on radio frequencies provided on the specification/user manuals included with this petition.)



### About our Location
Bemidji is located in North

- Central Minnesota. W ith a population of nearl y 15,000, Bemidji is a central hub of an expansive rural territory m ade up of agriculture farmlands and dy namic forests both privately a nd publicl y owned. L akes, bogs and grasslands are also abundant. A majority o f our aerial operations would take place in extremely remote, rural locations.



### Public Safety, Pri **vacy and Environmental Impact**

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

a nd electrify ing new industry

. A s mentioned before, flight safet y 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 r ig hts and environmental impact issues.

This new sUAS technology v irtually r eleases both the environmental and economic restraints on a level never fathomed before in the aerial photography i ndustry

. Traditional methods of piloted aircraft for our proposed purposes are extremel yexpensive, produces high levels of toxic emissions into the atmosphere, carr y large

pay loads of flammable fuel and greatl y increase the risk of human endangerment. F or those reasons, Photo Elevations LLC b elieves 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 durin g flight. T hey ’re highl y controllable with advanced safet y features for stabilization, GPS navigations, electronic speed controllers, autopilot safet y modes and real

- time data transmissions and recording. O verall, the proposed UAS’s greatl y increase publ ic safet y and benefits as compared to conventional methods of aerial photograph y.


### Pre and Post Flight Checklist/Inspections

To include, but not be limited to the following:

1. Inspect all parts and sy stem components for proper working condition. In cluding, 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 a nd Settings h. Ground Station equipment and connections

2. Conduct preflight safet y 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 permis sion for land use. 4. Spectator, Crew and Public Safet y 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.



### Condition **s**

Photo Elevations LLC w ill only c onduct operational flights under ideal visual meteorological conditions (VMC). N o flights will take place in obstructed view locations or during unpredictable weather conditions. N o 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 PI C. N o flight operations will be conducted at night. All flights will be aborted in the event of unpredicted obstacles or emergenc ies.

### Licensing and Supporters of Photo Elevations LLC

Photo Elevations LLC has obtained proper State and Lo cal licensing, extensive liabilit y insurance coverage, and proper Federal and State Tax Id entification Numbers, as well as, approval support from local Law Enforcement, Bemidji Fire Dept., City C ouncil Members, Local Business Owners and the Chamber of Commerce. A cceptance of this emerging technology

i s 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 LL C Michael Finnegan, Owner/Operator 2508 Eagle Lane NE Bemidji, MN 56601 218

- 368

- 1375 photoelevations@y ahoo.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 Survey ing Botanical and Wildlife Studies/Assessments Invasive Species Detection


### Conclusion

Photo Elevations LLC would like to thank yo u 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. W e strongl y believe our services will greatly b enefit the surrounding community

a nd serve in the public’s overall best interest as a whole. For the preceding reasons listed throughout this petition, Photo Elevations LLC formally a sks for
t hese exemptions. Thank y ou.
Sincerel y, Michael Finnegan