Advanced	Aerial	Imaging,	LP

Charles	Lockwood

3210	Dunbar	Lane

Tallahassee,	Fl	32311

advancedaerialimaging@gmail.com	

September	3,	2015	

US	Department	Of	Transportation	

Federal	Aviation	Administration	

800	Independence	Ave	SW	

Washington	DC	20591	

Dear	Sir	or	Madam:	

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	

reform	act)	and	CFR	Part	11,	Advanced	Aerial	Imaging,	LP,	owner	and	operator	of	Small	

Unmanned	Aircraft	Systems	(UASs),	request	to	be	exempted	from	the	Federal	Aviation	

Regulations	(FAR)	listed	below	so	that	Advanced	Aerial	Imaging,	LP	may	operate	UASs	

commercially	in	airspace	regulated	by	the	FAA.,	as	long	as	such	operations	are	conducted	

within	and	under	the	conditions	outlined	herein	or	as	maybe	established	by	the	FAA	as	

required	by	Section	333.	

Advanced	Aerial	Imaging,	LP	is	co-	owned	by	Charles	Lockwood	and	Robert	Hall.	All	

operations	will	be	performed	with	the	public’s	safety	and	right	to	privacy	safeguarded	at	all	

times.	

As	described	below,	the	requested	exception	would	permit	the	operation	of	light	

weight	(less	than	55	lbs.	total	takeoff	weight)	UASs	under	controlled	conditions	for	

commercial	use	by	a	certified	private	pilot	thereby	enhancing	safety	and	fulfilling	the	

Secretary	of	Transportation’s	(the	FAA	Administrator’s)	responsibility	to”	establish	

requirements	for	safe	operation	of	such	aircraft	systems	in	national	airspace	systems.”	

Section	333(c),	of	the	Reform	Act.	

The	rotorcraft,	which	Advanced	Aerial	Imaging	operates,	weigh	less	than	55	pounds	

including	payload.	(The	DJI	Phantom	2	Quad-copter	and	DJI	Inspire	1	Quad-copter –	see	

Appendix)	Both	UAS	operate	at	a	speed	less	than	50	knots	and	have	the	capability	to	hover	

and	move	in	the	vertical	and	horizontal	plane	simultaneously.	Both	have	an	auto	return	to	

launch	point	when	battery	power	is	under	25%.	The	UAS	will	operate	within	the	line	of	sight	

with	in	a	protected	flight	area	as	described	below	and	at	200	feet	AGL	or	less	with	an	

observer	located	close	at	hand	as	to	make	voice	communication	possible.	These	operations	

will	not	create	a	hazard	to	users	of	the	nation	airspace,	public	nor	the	environment.	
Advanced	Aerial	Imaging,	LP	respectfully	requests	the	grant	of	an	exception	to	the	

following	specific	sections	of	the	Title	14	Code	of	Federal	regulations	allowing	it	to	operate	

lightweight	UASs	for	commercial	use,	

14	CFR	21,	subpart	H,	14	CFR	45.23	(b)	14	CFR	91.7	(a),	91.9	(b)	(2)	91.103	(b),	

91.109,	91.119,	91.121,91.151,(a),	91.203(a)	&(b),91.405(a),91.407(a)(1),	

91.409(a)&(b).	

Advanced	Aerial	Imaging,	LP	submits	this	application	in	accordance	with	the	Reform	

Act	,112	P.L.	95	331-334,	seeking	relief	from	any	currently	applicable	FAR’S	operating	to	

prevent	Advanced	Aerial	Imaging,	LP	future	commercial	use	of	small	UASs	to	operate	in	the	

national	airspace	system	as	described	below.	The	reform	Act	section	332	provides	for	such	

integration	of	civil	unmanned	aircraft	into	our	national	airspace	system	as	it	is	in	the	public’s	

interest	to	do	so.	The	UASs	operated	by	Advanced	Aerial	Imaging,	LPs	meet	the	definition	of

“small	unmanned	aircraft”	as	defined	in	Section	331	and	therefore	the	integration	of	these	

UASs	are	expressly	contemplated	by	the	Reform	Act.	Advanced	Aerial	Imaging,	LP	would	like	

to	operate	its	light	weight	UASs	prior	to	the	time	period	by	which	the	Reform	Act	requires	

the	FAA	to	promulgate	rules	governing	such	aircraft.	

The	Reform	Act	directs	the	Secretary	of	Transportation	to	consider	whether	certain	

unmanned	aircraft	systems	may	operate	safely	in	national	airspace	before	completion	of	

the	rule	making	required	under	Section	332	of	the	reform	Act.	In	making	this	determination,	

the	Secretary	of	Transportation	is	required	to	determine	which	UASs	do	create	a	hazard	to	

users	of	the	national	airspace	system	or	the	public	or	pose	a	threat	to	national	security	in	

light	of	the	following:	

The	UASs	size,	speed,	weight	and	operational	capability	

Operation	of	the	UASs	in	close	proximity	to	airports	and	populated	areas	

Operation	of	the	UASs	within	visual	line	of	sight	of	the	operator	

Reform	Act	333(a).	If	the	secretary	determines	that	such	vehicles	“mayoperate	

safely	in	National	Airspace	System,	the	secretary	shall	establish	requirements	for	the	safe	

operation	in	national	airspace.	

The	rotorcraft	Advanced	Aerial	Imaging,	LP	operate	weigh	less	than	55	lbs.	and	they	

operate	at	speeds	less	than	50	knots	and	have	the	capability	to	operate	in	the	vertical	and	

horizontal	plane	simultaneously.	The	UASs	will	operate	only	within	the	line	of	sight	of	the	

operator	within	a	protected	flight	area	and	at	200	feet	AGL	or	less.	These	will	not	present	a	

hazard	to	the	national	airspace	nor	the	public.

The	small	nature	of	these	UASs	combined	with	the	safe	guards	presented	below,	will	

allow	for	the	safe	operation	greater	than	that	envisioned	by	Congress	for	the	FAA	to	

establish	and	by	exemption	allow	commercial	operations	of	UASs	to	commence	

immediately.	Also	due	to	the	size	of	UASs	and	the	areas	and	altitudes	they	will	operate	

approval	of	this	exception	presents	no	national	security	issues	and	absolutely	minimal	

safety	concerns	which	have	been	mitigated	through	our	rigorous	risk	management	
process.	Given	the	clear	direction	given	in	Section	333	of	the	Reform	Act,	the	authority	

contained	in	the	Federal	Aviation	Act,	as	amended,	the	strong	equivalent	level	of	enhanced	

safety,	reduced	emissions	utilizing	UASs	verses	traditional	aircraft	as	well	as	the	economic	

impact	of	greatly	reducing	the	cost	of	aerial	photography	thereby	benefiting	the	greater	

public’s	interest.	Accordingly,	the	applicant	requests	that	the	FAA	grant	the	requested	

exemption	without	delay.	

The	following	will	be	considered	as	the	binding	limitation	on	operations	of	Advanced	Aerial	

Imaging,	LP,	

1.	Flights	will	only	occur	in	the	day-time	hours,	

2.	Flights	will	be	operated	in	the	line	of	sight	of	the	operator	(PIC)	and	Observer	

(VSO)	

3.	Flights	will	be	terminated	at	any	time	weather	and	wind	deteriorate	to	“unsafe	for	

flight”	by	manufacturers	recommendations,	

4.	The	UASs	will	weigh	less	than	55	lbs.,	

5.	Flights	will	be	operated	at	200	feet	AGL	or	less.	

6.	Crew	will	be	at	a	minimum	of	operator (PIC)	and	an	observer	and/or	camera	

operator (VSO),	

7.	Operator	and	crew	will	remain	in	contact	during	the	flight	operation,	

8.	The	UASs	operator	will	perform	a	check	of	the	flight	area	and	make	certain	of	the	

safety	of	all	persons	in	the	area,	

9.	Consent	will	be	obtained	from	all	persons	with	in	the	video	capabilities	of	the	

units	to	further	reduce	the	chance	of	violating	anyone’s	privacy.	

10.	All	required	FAA	clearances,	will	be	obtained	and	distances	from	airports	strictly	

observed.	

11.	All	UASs	will	have	the	capability	to	return	automatically	to	the	operator	in	a	safe	

manner	with	the	auto	return	function	checked	and	working.	

12.	When	operated	in	conjunction	with	fishing	vessels	in	the	gulf,	a	chase	boat	will	

be	assigned	to	operate	the	UASs	at	a	safe	distance	from	the	main	fishing	boat.	

13.	Flights	will	only	operate	in	VFR	conditions.	

14.	UASs	have	a	function	on	the	control	to	tell	operator	the	distance	away	from	the	

operator	and	its	battery	power	remaining.	

15.	Flight	team	will	communicate	by	voice	and	the	use	of	two-way	radio	if	the	area	is	

too	big	to	hear	voice	from	all	team	members.	

16.	UASs	will	be	used	to	video	record	private	outings	and	functions,	boating,	jet	

skiing,	kayaking,	fishing	trips and	other	outdoor	activities	from	a	safe	distance.	

17.	When	operating	over	or	near	water	the	UASs	will	be	equipped	with	flotation	

devices	so	that	recovery	can	be	made	as	to	prevent	lithium	battery	exposure	to	the	

water	table.	
14	CFR	part	21	Subpart	H:	Airworthiness	Certificate	14	CFR	91.7(a),	91.203(a)(1)	

Subpart	H,	entitled	Airworthiness	Certificates,	sets	forth	requirements	for	procurement	of	

necessary	certificates	in	relation	to	FAR	91.203(a)(1).	The	size,	weight	and	defined	area	of	

operations	for	Advanced	Aerial	Imaging,	LP	UASs	flights	permits	exception	from	Part	21	

because	they	meet	an	equivalent	level	of	safety	pursuant	to	Section	333	of	the	Reform	Act.	

The	FAA	is	authorized	to	exempt	aircraft	from	the	airworthiness	certificate	requirement	

under	both	the	Act	(49	USC	4470(f)	and	Section	333	of	the	Reform	Act.	Both	pieces	of	

legislation	permit	the	FAA	to	exempt	UASs	from	airworthiness	certificates	in	consideration	

of	weight,	size,	speed,	maneuverability	and	proximity	to	areas	such	as	airports	and	dense	

populations.	Advanced	Aerial	Imaging,	LP	meets	or	exceeds	each	of	these	elements	

As	of	March	23,	2015	the	FAA	has	stated	that	it	will	automatically	grant	a	“blanket”	

COA	for	flights	at	or	under	200	AGL	to	any	UASs	operator	with	a	section	333	exemption.	

14	CFR	91.203(a&b)	provides	for	carrying	of	civil	aircraft	certifications	and	

registrations.	These	are	inapplicable	for	the	same	reasons	stated	above.	The	equivalent	

level	of	safety	will	be	achieved	by	maintaining	such	certifications	and	registrations	at	

Advanced	Aerial	Imaging,	LP	operations	center.

14CFR91.7	(a)	prohibits	the	operation	of	an	aircraft	without	an	airworthiness	

certificate.	As	no	such	certificate	will	be	applicable	in	the	form	contemplated	by	FAR’s	this	

regulation	is	inapplicable.

14	CFR	91.9(b)(2)	Civil	Aircraft	Flight	Manual	in	Aircraft	

14	CFR	91.9(b)(2)	requires	an	aircraft	flight	manual	in	the	aircraft.	As	there	are	no	

pilots	or	passengers,	and	given	the	size	of	the	UASs	this	regulation	is	inapplicable.	An	

equivalent	level	of	safety	will	be	achieved	by	maintaining	such	certifications	and	

registrations	at	Advanced	Aerial	Imaging,	LP	operations	center.	

The	FAA	has	previously	issued	exemptions	to	this	regulation	in	Exemptions	No’s	

8607,8737,8738,9299,9299A,9565,9565B,10167,10167A,10602,10700	and	32827.

14	CFR	91.119	Minimum	safe	altitudes,	prescribes	safe	altitudes	for	operation	of	

civil	aircraft.	It	allows	helicopters	to	be	operated	at	lower	altitudes	in	certain	conditions.	

Advanced	Aerial	Imaging,	LP	will	only	operate	its	UASs	at	or	below	200AGL.	They	will	be	

operated	on	a	will	defined	AOR	that	has	been	carefully	reviewed	for	hazards	and	minimizes	

the	presence	of	any	persons	not	essential	for	these	operations.	Flights	will	only	be	over	

private	property	that	the	owner	has	consented	and	all	persons	within	this	video	area	also	

give	consent	for	this	filming.	Compared	to	flight	operations	of	conventional	and	traditional	

aircraft	or	rotorcraft	weighing	far	more	than	50	lbs.,	operating	below	500	AGL	with	

flammable	fuel	UASs	operations	present	a	far	smaller	risk	to	the	public.	
Approval	of	these	333	Exemptions	allowing	commercial	operations	of	small	UASs	in	

the	service	of	aerial	photography	will	greatly	enhance	safety	by	reducing	the	overall	risk	

associated	with	traditional	aircraft.	Traditional	aerial	photography	requires	large	aircraft

with	flammable	fuel	to	fly	in	close	proximity	of	populated	areas	and	people	in	general.	With	

the	use	of	small	UASs	of	55	lbs.	or	less,	battery	operated	and	fling	below	200	feet	AGL	the	

risk	of	injury	of	people	on	the	ground	or	the	crew	has	been	reduced	or	almost	erased.	The	

granting	of	the	use	of	these	small	UASs	by	Advanced	Aerial	Imaging,	LP	will	give	the	people	

another	avenue	to	express	themselves	and	to	have	a	video	record	to	share	with	family	and	

friends	forever.	

Granting	Advanced	Aerial	Imaging,	LP the	above	exemption	will	allow	for	the	expansion	of	

UAS	systems	into	the	future	for	the	safe	conduct	of	free	enterprise	and	the	enjoyment	of	

the	masses.	

Advanced	Aerial	Imaging,	LP	respectfully	requests	the	FAA	grant	its	exception	without	delay.	

The	FAA	has	the	authority	to	issue	the	exemption	sought	by	Advanced	Aerial	Imaging,	LP

pursuant	to	the	Federal	Aviation	Act,	85	P.L.	726	(1958)	as	amended	(the	ACT).	

Sincerely,

Charles	Lockwood

Advanced	Aerial	Imaging,	LP

3210	Dunbar	Lane

Tallahassee,	Fl	32311

advancedaerialimaging@gmail.com	
Appendix

Operation	Manuals:

• DJI	Inspire	1	 - http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

• DJI	Phantom	2	- http://download.djiinnovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_e

n.pdf