August 19, 2015

Exemption No. 12528

Regulatory Docket No. FAA−2015−1126

Ms. Christina Martinez 

Owner

Precision Approach Aerial Photography LLC

15909 Elmwood Way 

Apple Valley, MN 55124

Dear Ms. Martinez:

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 letters posted to the public docket on April 22, 2015, and July 22, 2015, you petitioned the 

Federal Aviation Administration (FAA) on behalf of Precision Approach Aerial Photography 

LLC (hereinafter petitioner or operator) for an exemption. The petitioner requested to operate 

an unmanned aircraft system (UAS) to conduct aerial photography and video for real estate, 

land surveying, architecture, public events, inspection of commercial property including cell 

towers and commercial construction, and flight training1.

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.

 

1 The petitioner also requested authority to conduct UAS training. At this time, the FAA is unable to authorize 

UAS operations for training until a further assessment is completed. When the FAA completes its review, we 

will proceed accordingly and no further action will be required by the petitioner. However, the petitioner is 

permitted to train its own pilot in commands and visual observers in accordance with condition no. 14 and the 

other conditions and limitations in this exemption.
2

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 3.

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 

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 collection2. 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, 

 

2 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

delegated to me by the Administrator, Precision Approach Aerial Photography 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.

Conditions and Limitations

In this grant of exemption, Precision Approach Aerial Photography 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

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.
4

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, 

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.
5

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.

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 
6

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.

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.
7

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.

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 August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
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Precision Approach Aerial Photography LLC - Exemption/Rulemaking

This Other document was issued by the Federal Aviation Administration (FAA)

For related information, Open Docket Folder 

Content

This is an exemption request pursuant to Section 333 of the FAA Reform Act of 2012 for Precision

Approach Aerial Photography LLC. Precision Approach Aerial Photography LLC requests to perform

aerial photography through the use of its small unmanned aircraft commercially in airspace regulated by

the FAA. The owner and pilot is a Certified Flight Instructor with a Bachelor of Science in Aeronautics.

Having firsthand knowledge of the National Airspace System gives Precision Approach Aerial

Photography an advantage in safely operating small UAS within our airspace.

Description of Petitioner

Christina Martinez is the owner of Precision Approach Aerial Photography LLC. Christina is a Certified

Flight Instructor and has vast experience operating in the National Airspace System. She has experience

flying RC Planes, blimps in indoor college hockey arenas, and small quad copters for pleasure.

Contact information:

Christina Martinez

15909 Elmwood Way

Apple Valley, MN 55124

paaerialphotography@gmail.com

952-412-3656

Exemptions

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

Description of UAS and Equivalent Level of Safety

The primary UAS system that will be used is the DJI Phantom 3. The UAS will be safely operated in the

NAS by maintaining line of sight visual contact, flown only during daylight, and less than 400ft above the

ground. Flights will be operated at a lateral distance of no less than 100 feet from any persons or

property not associated with the operation. Additional safety features on the DJI Phantom 3 include

return to home functionality when GPS is available and failsafe technology that return the aircraft to the

takeoff point if batteries run low. 

The specifications for the UAS are as follows:

Weight: 1280 g

Diagonal Size: 590 mm 

Max Ascent Speed: 5 m/s

Max Descent Speed: 5 m/s

Max Speed: 16 m/s

Additionally, the max flight time for the UAS will be limited to maintain a reserve of 25% battery power.

At all times, the UAS will be operated in accordance with the safety and operational requirements of the

manual.

Comment Now!

ID: FAA-2015-1126-0001

Document Information

Date Posted:

Apr 22, 2015

Show More Details 

Submitter Information

Submitter Name:

Christina Martinez

Mailing Address:

15909 Elmwood Way

City:

Apple Valley

Country:

United States

State or Province:

MN

ZIP/Postal Code:

55124

Comments

0

Docket Information

This document is contained in

FAA-2015-1126

Related Dockets:

None

Related RINs:

None

Related Documents:

None

This count refers to the total

comment/submissions received on

this document, as of 11:59 PM

yesterday. Note: Agencies review all

submissions, however some

agencies may choose to redact, or

withhold, certain submissions (or

portions thereof) such as those

containing private or proprietary

information, inappropriate language,

or duplicate/near duplicate

examples of a mass-mail campaign.

This can result in discrepancies

Comments Received *

*
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UAS Operations

Preflight would include checking the operation of the UAS to include the battery in both the transmitter

and the UAS, the condition of the body of the UAS and its propellers. Updates to the firmware will be

done as they become available and maintenance will be performed pursuant to the manufacturers

recommendations. The area in which the drone will be flown will be checked for powerlines, antennas,

and other obstructions. The weather conditions will be monitored throughout the flight. Wind conditions

will be reviewed and the UAS will only be flown in daylight. As the pilot, Christina would ensure that she

is safe to operate the drone as she would if she were flying in the aircraft herself. 

The pilot will abide by the following currency and proficiency requirements:

The pilot will posses at least a private pilot certificate

The pilot will have a minimum of 25 hours total time as a UAS rotorcraft pilot

The pilot will have a minimum of 5 hours in the make and model utilized 

Conclusion

Precision Approach Aerial Photography, a small woman-owned business, would like to safely operate a

UAS aerial photography business. Having a Section 333 Exemption and entering into the NAS legally

would give the business a competitive advantage. The safe and compliant operations would discourage

illegal operations and improve the industry.

Thank you for your consideration.

Sincerely,

Christina Martinez

Owner/Pilot 

Precision Approach Aerial Photography LLC

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We the People Federal Register Reginfo Congress.gov USA.gov E-Gov Opengov
U.S.$Department$of$Transportation

Docket$Operations

1200$New$Jersey$Ave,$SE

Washington,$DC$20590

Request$for$Section$333$Exemption,$Revision$Provided$14$July$2015

This$is$an$exemption$request$pursuant$to$Section$333$of$the$FAA$Reform$Act$of$2012

for$Precision$Approach$Aerial$Photography$LLC.$$Precision$Approach$Aerial$

Photography$LLC$requests$to$perform$aerial$photography$through$the$use$of$its$

small$unmanned$aircraft$commercially$in$airspace regulated$by$the$FAA.$$The$owner

and$pilot is$a$Certified$Flight$Instructor$with$a$Bachelor$of$Science$in$Aeronautics.$$$

Having$firsthand$knowledge$of$the$National$Airspace$System$gives$Precision$

Approach$Aerial$Photography$an$advantage$in$safely$operating$small$UAS within$our$

airspace.

Description+of+Petitioner

Christina$Martinez$is$the$owner$of$Precision$Approach$Aerial$Photography$LLC.$$

Christina$is$a$Certified$Flight$Instructor$and$has$vast$experience$operating$in$the$

National$Airspace$System.$$She$has$experience$flying$RC$planes,$blimps$in$indoor$

college hockey$arenas,$and$small$quad$copters$for$pleasure.

Contact$information:

Christina$Martinez

15909$Elmwood$Way

Apple$Valley,$MN$55124

paaerialphotography@gmail.com

952Z412Z3656

Commercial+Operations:

Exemption$is$requested$for$commercial operations$for$ aerial$photography$and/or$

video$for$commercial$use$including$real$estate,$land$surveying,$architecture,$and$

other$related$activities.$$Aerial$photography$and/or$video$for$commercial$use$

including$public$events.$$Aerial$photography$and/or$video$for$inspection$of$

commercial$property$including$cell$towers$and$commercial$construction.$$And,$the$

ability$to$offer$flight$training$to$others.

Exemptions

Regulations$from$which$the$exemption$is$requested:

14$CFR$Part$21

14$C.F.R.$45.23(b)

14$CFR$61.113$(a)$&$(b)

14$C.F.R.$91.7$(a)

14$CFR$91.9$(b)$(2)

14$C.F.R.$91.109
14$C.F.$R.$91.119 (c)

14$C.F.R.$91.121

14$CFR$91.151$(a)

14$CFR$91.203$(a)$&$(b)

14$CFR$91.405$(a)

14$CFR$91.407$(a)$(1)

14$CFR$91.409$(a)$(2)

14$CFR$91.417$(a)$&$(b)

Description+of+UAS and+Equivalent+Level+of+Safety

The$primary$UAS$system$that$will$be$used$is$the$DJI$Phantom$3.$$The$UAS$will$be$

safely$operated$in$the$NAS$by$maintaining$line$of$sight$visual$contact,$flown$only$

during$daylight,$and$less$than$400ft$above$the$ground.$$Flights$will$be$operated$at$a$

lateral$distance$of$no$less$than$100 feet$from$any$persons$or$property$not$associated$

with$the$operation.$$All$flights$will$be$preplanned$and$owner$approval$will$be$

obtained$for$flights$over$personal$property.$$Additional$safety$features$on$the$DJI$

Phantom$3$include$return$to$home functionality$when$GPS$is$available$and$failsafe$

technology$that$return$the$aircraft$to$the$takeoff$point$if$batteries$run$low.$$

The$specifications$for$the$UAS$are$as$follows:

Weight:$1280$g

Diagonal$Size:$590$mm

Max$Ascent$Speed:$5$m/s

Max$Descent$Speed:$5$m/s

Max$Speed:$16$m/s

Additionally,$the$max$flight$time$for$the$UAS$will$be$limited$to$maintain$a$reserve$of$

25%$battery$power.$$At$all$times,$the$UAS$will$be$operated$in$accordance$with$the$

safety$and$operational$requirements$of$the$manual.

UAS+Operations

Preflight$would$include$checking$the$operation$of$the$UAS$to$include$the$battery$in$

both$the$transmitter$and$the$UAS,$the$condition$of$the$body of$the$UAS$and$it’s$

propellers.$$Updates$to$the$firmware$will$be done$as$they$become$available and$

maintenance$will$be$performed$pursuant$to$the$manufacturer’s$recommendations.$$

The$area$in$which$the$drone$will$be$flown$will$be$checked$for$powerlines,$antennas,$

and$other$obstructions.$$The$weather$conditions$will$be$monitored$throughout$the$

flight.$$Wind$conditions$will$be$reviewed and$the$UAS$will$only$be$flown$in$daylight

during$visual$flight$rules$meteorological$conditions.$

Regulations+from+which+an+exemption+is+requested:

14+CFR+Part+21 subpart+H

An$exemption$is$requested$from$applying$for$an$airworthiness$certificate.$$Given$the$

size$and$limited$operating$area$of$the$aircraft$to$be$used,$an$exemption$meets$the$

requirements$of$an$equivalent$level$of$safety.$$The$UAS$will$be$operating$in$an$area$
and under$conditions$that$would$be$at$least$as$safe$as$a$conventional$aircraft$

operating$with$an$airworthiness$certificate.

14+C.F.R.+45.23(b) – Display+of+Marks

An$exemption$is$requested$from$displaying$the$aircraft$“N”$number on$the$aircraft$

and$from$displaying$the$words$“limited”,$“restricted”,$“lightZsport”,$“experimental”,$

or$“provisional”$as$applicable.$$There$is$no$entrance$into$a$UAS$and$the$aircraft$is$not$

large$enough$to$display$letters$2$inches$tall.$$The$equivalent$level$of$safety$will$be$

provided$by$marking$“Experimental”$on$the$UAS$casing$where$the$pilot$or$other$

observers will$see$the$identification.$

14+CFR+61.113+(a)+&+(b) – Private+Pilot

An$exemption$is$requested$from$holding$a$private$pilot$certificate$and$the

requirements$for$compensation$or$hire.$$An$equivalent$level$of$safety$is$met$because$

UAS$do$not$carry$passengers,$property$or$pilots.$$The$risk$is$far$less$than$that$of$

commercial$activities$of$a$private$or$commercial$pilot.

14+C.F.R.+91.7+(a) – Civil+Aircraft+Airworthiness

An$exemption$is$requested$due$to$the$fact$that$an$airworthiness$certificate$will$not$

be$issued.$$

14+CFR+91.9+(b)+(2) – Civil+Aircraft+Flight+Manual,+Marking+and+Placard+

Requirements

An$exemption$is$requested$from$carrying$a$current$and$approved$Flight$Manual,$

markings$and$placards.$$The$UAS$is$not$large$enough$to$carry$any$of$these$items.$$An$

equivalent$level$of$safety$will$be$maintained$by$keeping$the$flight$manual$at$the$

launch$site$where$the$pilot$will$have$access$to$it.$$

14+C.F.R.+91.109 – Flight+Instruction

An$exemption$is$requested$from$operating$a$civil$aircraft$for$flight$instruction$unless$

that$aircraft$has$dual$controls.$$The$UAS$is$remotely$piloted$and$control$is$

established$through$the$transmitter.$$Because$there$is$no$one$aboard$the$aircraft$and$

the$instructor$is$able$to$handle$the$controls$at$the$same$time$as$the$pilot,$an$

equivalent$level$of$safety$is$achieved.$$

14+C.F.+R.+91.119 – Minimum+Safe+Altitude

An$exemption$is$requested$from$operating$over$sparsely$populated$areas$closer$

than$500$feet.$$An$exemption$is$requested$to$operate$up$to$400ft$AGL.$$Given$the$size$

weight,$and$controllability$of$the$UAS,$an$equivalent$level$of$safety$will$be$met.$$No$

flight$will$operate$over$property$without$the$permission$of$the$owner.$$All$UAS$

activities$will$be$preplanned.$

14+C.F.R.+91.121 – Altimeter+Setting

An$exemption$is$requested$from$operating$by$reference$to$an$altimeter$set$to$the$

departure$elevation.$$An$equivalent$level$of$safety$is$met$by$using$an$Above$Ground$

Level$measurement$that$is$displayed$on$the$aircraft$transmitter$held$by$the$pilot.$$
14+CFR+91.151+(a) – Fuel+Requirements+for+VFR+Conditions

An$exemption$from$the$requirement$to$operate$an$aircraft$with$30$minutes$of$fuel$

reserve$is$requested.$$The$battery power$of the$UAS$is$approximately$25$minutes$in$

length.$$An$equivalent$level$of$safety$is$met$by$the$transmitter$display.$$A$digital$

readout$of$the$batter$percentage$is$available.$$Additionally$the$aircraft$LED$lights$

flash$red$and$an$audible$alarm is$sounded$when the$aircraft$is$low$battery.$$If$the$

aircraft$is$not$landed,$the$return$to$home$safety$feature$is$engaged.$$The$max$flight$

time$for$the$UAS$will$be$limited$to$maintain$a$reserve$of$25%$battery$power.$$

14+CFR+91.203+(a)+&+(b) – Civil+Aircraft:+Certifications

An$exemption$is$requested$from$carrying$an$airworthiness$certificate$that$is$

displayed$and$legible.$$The$UAS$is$not$large$enough$to$carry$additional$items.$$An$

equivalent$level$of$safety$will$be$met$by$storing$any$registration$documents$at$the$

aircraft$launch$point with$the$pilot.$$Additional,$the$UAS$will$be$marked$

“Experimental”.

14+CFR+91.405+(a),+91.407+(a)+(1),+91.409+(a)+(2),+91.417+(a)+&+(b) –

Maintenance+Inspections

An$exemption$is$requested$from$having$the$UAS$inspected$as$prescribed$in$Subpart$

E.$$These$inspections$only$apply$to$aircraft$carrying$an$airworthiness$certificate.$$

Maintenance$will$be$done$according$to$the$UAS$manual,$manufacturer$

recommendations and$firmware$upgrades$will$be$performed$as$they$are$made$

available.$$In$order$to$ensure$an$equivalent$level$of$safety,$the$pilot$will$inspect$the$

aircraft$before$each$flight.

Public+Interest

Precision$Approach$Aerial$Photography$will$be$using$UAS$in$applications$that$either$

required$fullZsize$aircraft,$or$were$unable$to$be$completed$in$the$past.$$Reducing$the$

risks$of$flying$full$sized$aircraft$at$low$altitude$and$providing$safe$operations$is$in$

the$public’s$interest.$$By$granting$an$Exemption,$Precision$Approach$Aerial$

Photography$will$provide$safe$and$compliant$operations$while$safely$promoting$the$

UAS$business$model.$$

Conclusion

Precision$Approach$Aerial$Photography,$a$small$womanZowned$business, would$like$

to$safely$operate$a$UAS$aerial$photography$business.$$Having$a$Section$333$

Exemption$and$entering$into$the$NAS$legally$would$give$the business$a$competitive$

advantage.$$The$safe and$compliant$operations$would$discourage$illegal$and$unsafe$

operations$and$improve$the$industry.

Thank$you$for$your$consideration.

Sincerely,

Christina$Martinez
Owner/Pilot

Precision$Approach$Aerial$Photography$LLC