U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Section 333 of the FAA Reform Act of 2012

June 8, 2015

Dear Administrator,

I, Jonathan M. Petro, company owner and sUAS pilot, herein referred to as the petitioner, am 

writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures 

contained within 14 C.F.R. 11, to request that the petitioner, owner and operator of three small 

unmanned aircraft system (sUAS), request exemption from the Federal Aviation Regulations 

listed below and any regulation as required by the FAA that is deemed necessary in order to 

conduct commercial UAS operations as described.

The requested exemption would warrant said petitioner to safely and professionally provide forprofit services to both private and public entities within the State of Michigan and neighboring

states, utilizing one to three of the small unmanned aircraft systems for aerial still and video data 

capture for, but not limited to the following purpose:

- Aerial Property Survey (Video and/or Photo)

- Aerial Residential/Commercial Roof/Gutter inspections

- Aerial Flare Stack inspections

- Aerial Agricultural Survey/Crop Inspection/Crop Loss Inspection

- Aerial Real Estate Videography/Photography (Related to Sales)

- Aerial Videography/Photography of outdoor recreational activities/events**

- Fire, Flood and or Natural Weather related Damage Survey 

- Construction/Development (Structural Inspection)

- Search Assist to all entities (Private, Local and or Public)

**Disclaimer

The petitioner’s company, Innovative Aerial Media, provides aerial coverage of outdoor 

recreational activities and events for contracted parties.

Since the creation of Innovative Aerial Media (formally Great Lakes Aerial Photography), on 

08/26/2014, the petitioner has been dedicated to taking any and all measures necessary to ensure 

that Innovative Aerial Media (I.A.M.) holds the safety of the general public as its highest

priority. I.A.M. is committed to conducting all operations in a manner that sets a positive

example for other companies intending to conduct business in a similar market. I.A.M.’s 

objective is to encourage other sUAS operations to take the appropriate measures to operate

legitimately and in compliance with all regulations set forth by the FAA. In support of this effort, 

the petitioner purchased a 500 thousand dollar liability insurance policy, Certificate #: 

CL1552000472, (Included as PDF document attachment “I.A.M. Liability Insurance 
Document.PDF”) from the MRF - Meadowbrook Insurance Group on 8/29/2014, currently 

effective today. 

In addition, the safe integration of sUAS into national airspace, without out the risk of 

interference and/or hazard to manned aircraft, is paramount in the execution of any and all 

I.A.M. related activities. In the very first week of I.A.M.’s establishment, the petitioner made it a 

priority to contact all local law enforcement agencies and officials (specifically Portage and 

Kalamazoo County offices in Southwest Michigan) to discuss the use of (sUAS/UAV) in great 

detail as part of his ongoing effort to create a positive working relationship within the 

community. The petitioner, and all contracted employees, conduct business in a manner that is

courteous, respectful, and aware of the privacy rights of citizens. I.A.M. is and has been

committed to safely and professionally providing this new and unique service to the Southwest 

Michigan region while always operating within the legal guidelines of the law since August of 

2014. Due to the risks and costs involved with manned aircraft, I.A.M. fulfills a service that 

would otherwise not exist to consumers and entities, big and small. We offer services with the

knowledge that current manned aircraft operations pose a much greater risk of personal injury 

and/or death and extensive property damage. I.A.M. provides services with the intent of 

continuously enhancing the development and safe operation of unmanned aircraft systems.

The first sUAS that I.A.M. is requesting to operate and utilize in any and all services stated 

above is a consumer-class multirotor, quad-rotor aircraft. The aircraft is a BumbleBee 550 (less 

than 10 pounds total in weight) with all onboard components manufactured by DJI. The 

Bumblebee utilizes the DJI NAZA M-V2 Flight Controller (which is controlled by the DX7s 7-

Ch DSMX Radio System with AR8000 Receiver). This system has advanced settings that allow

for extraordinary stability as well as automatic GPS course correction, GPS lock, altitude, 

position hold stabilization, smart mode, follow me mode, emergency land mode, and land home 

safe mode. The state-of-the-art safety features literally re-track the sUAS’s exact flight route 

using the ground station software to guide the machine back to its original take-off location,

while focusing on precise elevations and position waypoints to eliminate the possibility of 

collision with obstructions that could potentially occur with other sUAS models. For example, 

less advanced automatic safety systems often utilize a “direct return home” safety feature, which 

guides the machine directly from its current position to its initial point of take-off, neglecting to 

factor in the potential for collision with tall objects.

The ground station consists of ground-breaking features that are vital to the operation, safety, and 

in-flight information of the sUAS. These features include telemetry sensors that monitor altitude, 

groundspeed, GPS location, and battery life for both the transmitter and aircraft, as well as an 

audible and vibration alert for aircraft low battery. In addition, the sUAS features Aircraft LED 

visual alert indicators for low battery, GPS loss, and communication loss. The sUAS has the 

ability to link with a smartphone or tablet for video link separate from the on-board display, if 

needed. In addition, all three sUAS machines are equipped with the DJI Lightbridge HD vide 

download system, which provides real-time, wireless HD video display for up to two miles (in 

optimal conditions). This is a very advanced video downlink system that I.A.M. purchased 

separately and to both the Bumblebee 550 and the Phantom 2, Vision Plus (as it is very 

expensive and is not included with the stock models). However, the DJI inspire-1 does come 
with the DJI Lightbridge HD Video Downlink as its primary stock wireless video transmission 

system.

The second sUAS that I.A.M. is requesting to operate and utilize in any and all services stated 

above is a consumer-class multirotor, quad-rotor aircraft. The aircraft is a DJI Phantom 2, Vision 

Plus. The high capacity, high performance 5200mAh Lithium Polymer battery offers up to 25 

minutes of flight time. It provides battery capacity data, over charge/discharge protection, as well 

as maintenance reminders making the battery extremely safe and reliable. The upgraded remote 

control comes with many new features. A gimbal control dial, trainer port, built-in rechargeable 

LiPo battery with a capacity of 2000mAh, battery level LED indicators and throttle-locking 

feature that holds the throttle stick in place when descending are all included. The new remote 

control is compatible with the Phantom 2 Vision+ and Phantom 2. A new, anti-static compass 

has been developed, with a protective shell to help shield the sUAS during all flight conditions.

An integrated GPS auto-pilot system offers position holding, altitude lock and stable hovering to 

focus attention on capturing video footage. 

If the Phantom 2 and its controller are disconnected during flight, the system’s failsafe protection 

will activate, automatically alerting the pilot when optimal signal is reached, the Phantom 2 also 

includes a return-home and land automatically feature. A one-key Go-Home function can be 

installed to activate this feature manually. In order to increase flight safety and prevent 

accidental flights in restricted areas, the new firmware for the Phantom 2 series includes a No 

Fly Zone feature.

The third sUAS that I.A.M. is requesting to operate and utilize in any and all services stated 

above is a consumer-class multirotor, quad-rotor aircraft. The aircraft is a DJI Inspire 1- it is one 

of the most advanced sUAS systems DJI has ever produced weighing in at under seven pounds. 

The petitioner requests exemption to operate a BumbleBee 550 frame equipped with the DJI 

NAZA M-V2 flight controller, equipped with a three-axis H33D Gimbal and GoPro Hero 3 PlusBlack Addition Camera. The DJI Phantom 2 Vision Plus with ground station software and GPS 

safety systems and lastly, the DJI Inspire-1, which is one of the most advanced multi-rotor 

consumer quadcopters manufactured by DJI in history. The DJI Inspire-1 has all of onboard

safety features as the Bumblebee 550 and DJI Phantom 2 Vision Plus, with far more advanced 

upgrades and features

In addition to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, The 

petitioner will—

a. Only operate its sUAS in direct visual line of sight of the pilot.

b. Never operate at altitudes greater than 400 ft.

c. Always take-off and land sUAS in a pre-designated area that is blocked off with rope,

cones, ect. and secured by at least two qualified safety crew members.

d. Operate over private or public sites only with prior permission from property owner 

or owner’s agent or legal authorities as allowed by law.

e. Terminate or postpone a scheduled flight when any unsafe condition exists, such 

as high wind speeds and or rain/thunderstorms.
f. Operate at a ground speed of no more than 15 mph.

g. Terminate flight when battery voltage drops to 40% of flight time.

h. Operate in accordance with the guidance and standards set forth by the FAA, AMA, 

the sUAS manufacturer and the administrator.

i. Never operate any sUAS machine on a contracted job that is not fully covered under

I.A.M.’s liability insurance policy. 

.

The petitioner requests exemption from 14 CFR part 61.113 Private Pilot Privileges, Pilot 

in Command Section (a). Although the petitioner is a current certified commercial pilot the 

petitioner may elect to utilize certified private pilots with class III medical to conduct operations 

with the sUAS. In the Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA 

determined that a PIC with a private pilot certificate operating the Astraeus UAS would not 

adversely affect operations in the NAS or present a hazard to persons or property on the ground. 

The petitioner requests the same consideration and limitations as previously granted.

Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness. As no Airworthiness Certificate is 

available for this sUAS the petitioner requests exemption under this part utilizing a preflight 

inspection and the manufacturer’s documents for determining compliance of the sUAS 

airworthiness. The petitioner warrants compliance to part 91.7(b) in that the operation will only 

be conducted after a thorough preflight and pre-mission planning inspection is completed, to 

include current and forecast weather, airspace, notams, area of operations, and notice issued to 

non-participating persons in local proximity. The petitioner will utilize the Yuneec, Q500 

Instruction Manual, quick start guide and the petitioner’s own pre-flight checklist included in the 

attached supplements to determine the sUAS airworthiness.

The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe Altitudes.

The petitioner requests exemption from Section (c) with the following conditions and limitations. 

The petitioner requests the exemption due to the scope of the operations to be performed and the 

requirement to operate below 400 feet AGL. The Petitioner’s primary mission would be to 

record data or survey of persons, property or structures as listed above. The sUAS size, weight, 

speed and limited operating times and area, as well as the soft materials used in the construction 

of the sUAS, would provide an equivalent or greater level of safety as intended under this part. 

The Q500 is a helicopter as defined by CFR Title 14, FAR Part 1, general definitions. The sUAS 

has a 4vertical to near vertical descent in the event of a power failure. Fly-a-ways would be the 

greatest or most dangerous risk to non-participating persons. The Q500 has no documented (flyaway), while operated under GPS lock within the parameters of the Q500 operating instructions. 

The Q500 is a very stable, low rotor speed sUAS that maneuvers, under GPS lock, relatively 

slow compared to similar sized sUAS. In an emergency the sUAS would be quickly brought 

down per the loss of control procedure as described in the emergency procedures checklist, 

adequate time to complete the procedure would exist due to the 0 to 15 mph operational 

groundspeed of the Q500. The risk to persons 100 feet away would be at no greater risk than 

persons located 500 feet away. The petitioner requests exemption from the 500-foot altitude

restriction and the 500-foot standoff restriction from persons, property or vessel applied to 

previous grants of exemptions. 

 
The petitioner requests exemption from 14 CFR Part 91.121, Altimeter settings. The sUAS 

will not have a typical barometric altimeter onboard the aircraft, the petitioner intends to operate 

the sUAS within VLOS and at or below 400 feet AGL, combined with the petitioner’s intention 

to limit the altitude of the UAS through flight limit function on the sUAS, has been previously 

ruled to be a sufficient method for ensuring the sUAS operations do not adversely affect safety. 

The altitude information will be generated by GPS equipment installed onboard the aircraft, 

and/or a static pressure sensor (barometer), which aids in estimating the altitude.

The petitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for flight 

in VFR conditions, prior relief has been granted for manned aircraft to operate at less than the 

prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar 

sUAS-specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, 

Visual Flight Rules (VFR) conditions. The petitioner’s UAS provides low battery warnings that 

indicate the PIC must command the UA’s return to the launch point when low battery capacity 

voltage is reached. The UAS also provides 2 and 3rd increased intensity critical low battery 

warnings through audio and vibration indicating that the UA must be landed immediately, 

additionally a failsafe automatic landing will occur when the battery is at absolute critical low 

voltage. The petitioner warrants that the sUAS will be landed immediately upon battery alert or 

no longer than 12 minutes whichever occurs first. The petitioner will not initiate a flight unless 

(considering wind and forecast weather conditions) there is enough power to fly at normal 

cruising speed to the intended landing point and land the UA with 40% battery power remaining.

The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401-417),) Maintenance 

required, 91.407(a) (1) Operation after maintenance, preventive maintenance, rebuilding, 

or alteration, 5 91.409(a) (1) and (2) Inspections, and 91.417(a) and (b) Maintenance 

records.

Sincerely,

Jonathan M. Petro

Innovative Aerial Media

10911 Cressey Road

Plainwell, MI 49080