October 27, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, 

SE Washington DC 20590 

Re: Exemption Request§ 333 of the FAA Reform Act of the Federal Aviation Regulations 

from 14 CFR § 21; 61.113 (a) & (b); 61.133 (a); 91.7 {a); 91.9 (b); 91.109 (a); 91.119 (c); 91.121; 

91.151 {a); 91.203; 91.405 (a); 91.407 {a) {1); 91.409 (a) (2); 91.417 (a) & (b). 

Dear Sir or Madam, 

Pursuant to § 333 of the FAA Modernization and Reform Act of 2012 (The Reform Act) and 

14 C.F.R. Part 11, Maine Aerial Photography Services, LLC, operator of Small Unmanned Aircraft Systems 

(sUAS) equipped to conduct aerial filming and photographing to include: commercial and residential real 

estate, infrastructure inspections, construction, architecture, scientific research, environmental 

assessment, land surveying and mapping and other applicable areas for pre-planned, controlled areas, 

hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial 

operation of its sUAS, so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the Federal Aviation Administration (FAA) as required by§ 

333., Maine Aerial Photography Services, LLC operation of its sUAS for commercial purposes awaits a 

review and the anticipated granting of this petition by the FAA before conducting any operation for its 

clients to fully comply with all federal aviation regulations pertaining to sUAS. 

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and multi-rotor aircraft under controlled conditions in airspace that is 1) contained 2) 

predetermined 3) has on-site safety personnel controlling access, and 4) would provide increased safety 

and enhancements to clients business operations. 

I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level of 

safety. I look forward to working with your office. Please contact me at any time if you require additional 

information or clarification. 

The name and address of the applicant is: 

Maine Aerial Photography Services, LLC 

Tyler S. Plummer, President 

Phone: 207-798-1113 

Email: tyler.plummer@gmail.com 

Address: 28 Wiley Woods Way, Walpole ME, 04573 

1 
PUBLISHABLE SUMMARY 

The following summary is provided for publication in the Federal Register, should it be determined that 

publication is needed. 

Maine Aerial Photography Services, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 

333 of the FAA Modernization and Reform Act of 2012 from the requirements of 14 CFR § 21; 61.113 (a) 

& (b); 61.133 (a); 91.7 (a); 91.9 (b); 91.109 (a); 91.119 (c); 91.121; 91.151 (a); 91.203; 91.405 (a); 91.407 

(a) (1); 91.409 (a) (2); and 91.417 (a) & (b). This exemption request will permit Maine Aerial Photography 

Services, LLC to operate its sUAS commercially for the purpose of aerial filming and photographing to 

include: commercial and residential real estate, infrastructure inspections, construction, architecture, 

scientific research, environmental assessment, land surveying and mapping. Maine Aerial Photography 

Services, LLC will provide a service that is beneficial to industries and organizations that are already 

using, and/or seeking to use, sUAS's for these purposes with a legal and safe option. This will benefit the 

public with the controlled operation of sUASs and increase their integration into the NAS. 

The requested exemption should be granted because the proposed operation of the DJI 

Inspire 1, a small UAS (sUAS) weighing 6lbs. 7.52 oz., inclusive of battery and payload, conducted in the 

strict conditions outlined below, will provide an equivalent or better level of safety, as Congress 

intended, while still allowing commercial operations. The lightweight aircraft covered by the exemption 

is far safer than conventional operations conducted with helicopters and fixed-wing aircraft operating in 

close proximity to the ground and people. The seven factors Congress directed the FAA to consider 

when approving Section 333 exemption petitions- size, weight, speed, operational capability, proximity 

to airports, proximity to populated areas, and operation within visual line of sight- each support the 

request. In particular, the aircraft is small, and will operate at slow speeds, close to the ground, far from 

airports and in a low risk, low and controlled population environments. 

Name and address of petitioner: 

Maine Aerial Photography Services, LLC 

Tyler S. Plummer 

28 Wiley Woods Way 

Walpole Me, 04573 

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BACKGROUND OF PETITIONER 

Maine Aerial Photography Services, LLC is a limited liability company owned and operated by Tyler 

Plummer. Mr. Plummer has practiced recreational photography for the last decade honing his 

photography skills. He has been flying the OJ I Inspire 1 for a few months learning its capabilities, 

performing the necessary flying skills, and practicing using the sUAS in safe manner. Mr. Plummer has 

spent countless hours researching the industry and safety protocols. This will help to ensure a 

successful safe commercial sUAS business. 

The integration of sUASs into the National Airspace System (NAS) has the promise and potential to be 

equally transformative in the ways in which the public, educational and research institutions, businesses 

and non-profits pursues their interests and goals. Maine Aerial Photography Services, LLC will conduct 

its business using the OJ I Inspire 1 sUAS. The Inspire 1 is a vertical takeoff and landing sUAS with a 

maximum gross weight of less than 55 pounds and a maximum speed of less than 50 mph. The Inspire 1 

is driven by lithium polymer batteries and powered by electric motors. 

The aircraft registration application and all required supporting documentation for this sUAS will be 

forwarded to the FAA Aircraft Registration Branch, AFS-750, P.O. Box 25504, Oklahoma City, OK 73125-

0504. 

PUBLIC INTEREST AND HOW THE PUBLIC WILL BENEFIT 

This exemption request will permit Maine Aerial Photography Services, LLC to operate its sUAS 

commercially for the purpose of aerial filming and photographing to include: commercial and residential 

real estate, infrastructure inspections, construction, architecture, scientific research, environmental 

assessment, land surveying and mapping and other applicable areas. Maine Aerial Photography Services, 

LLC will provide a service that is beneficial to industries and organizations that are already using, and 

seeking to use, sUASs for these purposes with a legal and safe option. This will benefit the public with 

the controlled operation of sUASs and increase integration into the NAS. 

Granting the present petition will further the public interest by allowing Maine Aerial Photography 

Services, LLC to perform safely, efficiently, and economically, aerial video and photography of 

construction sites, real estate, and landscape over certain areas of the United States. Additionally, use of 

the OJ I Inspire 1 sUAS will decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. 

The integration of sUASs into the NAS will not only replace traditionally more expensive options or 

approaches, it will enable work to be done and decisions to be made in ways that were simply 

impossible to do previously. The commercial deployment of small unmanned aircraft systems offers the 

public a new, highly efficient and relatively inexpensive platform for collecting, analyzing and utilizing 

data and photographic/video imagery. 

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In deploying its sUAS, Maine Aerial Photography Services, LLC has developed specific performance 

standards, operating requirements, protocols and work processes that are aligned with the FAA's 

continuing mission, and result in safe operating practices that are consistently applied and continuously 

improved. For its part, Maine Aerial Photography Services, LLC recognizes the important role it plays in 

educating the public and building awareness of both the promise and precautions that accompany the 

commercial deployment of this new and exciting platform. 

The sUAS utilized by Maine Aerial Photography Services, LLC is battery-powered and serves as a safe, 

efficient and economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. 

A grant of exemption would allow Maine Aerial Photography Services, LLC to contribute to the reduction 

of manned aircraft needed to perform the aerial acquisition of data, video and photographic content 

and subsequently reduce the volume of manned aircraft in the NAS. 

Conducting aerial acquisitions with the DJIInspire 1 sUAS, instead of manned aircraft, will greatly benefit 

the public by drastically reducing the levels of air and noise pollution generated during traditional aerial 

video and still photography flight operations. By using battery power and electric motors, the DJIInspire 

1 sUAS produces no air pollution, and is the most viable environmentally conscious alternative to the 

cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and 

photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJIInspire 

1 sUAS, while reducing the carbon footprint of aerial acquisitions, also sharply reduces noise pollution, 

as the sUAS is propelled by battery powered electric motors, rather than an internal combustion 

engine. 

By using the DJIInspire 1 sUAS to perform aerial acquisitions, the substantial risk to life and property in 

the air and on the ground, which is usually associated with traditional manned aircraft flight operations, 

will be drastically reduced or completely eliminated. The DJI Inspire 1 sUAS (weighing approximately 6 

pounds 7.5 ounces at its maximum gross weight with a length of 17.3 inches and width of 17.7 inches, 

and with no fuel on board), has less physical potential for collateral damage to life and property on the 

ground, and in the air, compared to the manned aircraft that typically conduct similar operations 

(weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, 

and a fuel capacity of 180 gallons). 

Previously, such services as high-resolution digital aerial real estate photography, surveying and 

inspections were limited and affordable to a relatively small group of agencies, companies and 

organizations with significant operating capital. The granting of this exemption will enable Maine Aerial 

Photography Services, LLC to change this by deploying its sUAS in ways that make aerial photography 

and other sUAS services accessible and affordable to a significantly larger portion of individuals, 

organizations and businesses. The many new forms of aerial content would have immediate and direct 

benefits to service providers, business owners and consumers alike. 

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PUBLIC SAFETY 

With safety as its primary operational requirement, Maine Aerial Photography Services, LLC will plan, 

conduct and manage its flight operations within very specific and well-defined operating limitations and 

standards detailed in its flight checklists and operating protocol (see Attachment G). These protocols 

also clearly define the roles and responsibilities of the pilot in charge (PIC), visual observer (VO) and the 

client representative working with Maine Aerial Photography Services, LLC. 

In seeking this exemption, Maine Aerial Photography Services, LLC submits that the DJIInspire 1 sUAS 

can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by the characteristics of 

the DJIInspire 1 sUAS, the pilot certification requirements, and the specific operating limitations. The 

specifications of the DJIInspire 1 sUAS (see Attachments A and B) demonstrate its safe characteristics. 

The DJIInspire 1 sUAS does not create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security considering its size, weight, speed, and operational capability. Many of the 

functional capabilities and features of the DJIInspire 1 sUAS enable it to be operated in a highly 

controlled, precise and safe manner. The DJIInspire 1 sUAS autonomous flight and navigation modes 

enable it to remain within a defined operational area. Also, the DJI Inspire 1 sUAS may be operated in 

both manual and fully autonomous flight modes. A complete description of the flight and navigational 

modes of the DJIInspire 1 sUAS is provided on pages 12-16 and 45-50 of the DJIInspire 1 User Manual 

(see Attachment B). 

The DJIInspire 1 sUAS includes automatic return-to-home-point or hover functionality in the event of 

loss of the control link or navigation. When the control link is lost, the DJIInspire 1 sUAS will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJIInspire 1 sUAS does not reacquire 

control link data from the ground control station/remote controller, the sUAS will assume that the 

control link is lost and will return to the home position (i.e., failsafe mode) via GPS, and will descend to 

the takeoff position and shutdown. A complete description of the failsafe functions of the DJIInspire 1 is 

provided on pages 13-15 of the DJJ Inspire 1 User Manual (see Attachment B). 

Whether helping to protect the public, inspecting infrastructure, conducting site and land surveys or 

acquiring aerial imagery and video, Maine Aerial Photography Services, LLC will be providing its 

customers with more accurate and timely information. The real-time situational awareness and 

improved decision-making this achieves will enable Maine Aerial Photography Services, LLC's customers 

and clients to communicate with and more safely serve and support their respective constituents. Strict 

adherence to specific flight operations protocols (see Attachment G), the use of the DJIInspire 1 sUAS 

configured with significant safety functionality, the acquisition of an accurate understanding of both the 

flight operations area and its adjacencies using Maine Aerial Photography Services LLC's Pre-Flight Safety 

Briefing and On-Site Flight Plan(see Attachment J), and the use of Maine will provide a level of safety 

and oversight that is in complete alignment with the FAA's mission to "provide the safest, most efficient 

aerospace system in the world." [FAA online document, Public Guidance for Petitions for Exemption 

Filed under Section 333. Rev. 9/25/2014] 

5 
PRIVACY 

All flights will occur over private or controlled~access property with the property owner's or controlling 

authority's prior consent and knowledge. Aerial photography and video capture will be of people who 

have provided their written consent (see Attachment K) to being photographed or have been authorized 

to be in the area where flight operations are taking place. Establishing and maintaining tight controls 

over access to the flight operations area will minimize privacy issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Maine 

Aerial Photography Services, LLC's proposed operation of the DJI Inspire 1 sUAS will not implicate any 

privacy issues. Specifically, the OJ I Inspire 1 sUAS will be operated under detailed operational protocols 

designed to ensure client or property owner involvement as well as local law enforcement notification. 

Flight operations will be conducted in accordance with Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.R. § 91.119. 

Maine Aerial Photography Services, LLC has developed a Pre-Flight Safety Briefing and On~Sight Flight 

Plan protocol template (see Attachment J) that will be completed and reviewed with the client's onsite 

representative prior to the commencement of any operation or project. This detailed diagram of the 

operational environment will provide the PIC}, VO(s), and any other designated support and security 

personnel with a full understanding of the site or subject's structural characteristics, layout, topography, 

adjacencies, and all significant and relevant natural and man made features within the operational area. 

This will enable Maine Aerial Photography Services, LLC to acquire a detailed understanding of the larger 

geographical context surrounding the flight operations area and review relevant factors with the client 

before the commencement of any work or service. 

CONDITIONS AND LIMITATIONS 

As set forth in Maine Aerial Photography Services, LLC Flight Operations and Procedures Manual 

(FOPM), which includes: All manufacturer documentation for the Inspire 1 sUAS and Maine Aerial 

Photography Services, LLC proprietary operations documentation for all sUAS operations (e.g., Flight 

Checklists and Operations Protocols, Pilot Flight Log, sUAS Flight Log, Monthly Maintenance Log, PreFlight Safety Briefing and On-Site flight plan, and Permission to Conduct Onsite Flight Operations 

Consent Form), the applicant proposes the following limitations and conditions: 

1. UAS must weigh less than 55 pounds; 

2. UAS airspeed is not to exceed 50 knots; 

3. UAS flights may not operate at more than 400 AGL. Altitudes reported to ATC must be in feet AGL; 

4. UAS must be operated within Visual Line of Sight (VLOS) of the PIC and VO; 

5. All operations will utilize aVO. The VO may be utilized as long as the PIC maintains VLOS capability 

and can communicate with the VO at all times; 

6. The operator's manuals and flight operations protocols will be amended to and revised as new 

conditions and/or limitations become known; 

6 
7. The PIC will conduct a full inspection of the sUAS (including remote controllers) to ensure it is in full 

working order and safe for flight prior to every takeoff; 

8. A functional test flight must be performed following the maintenance, alteration or repair of any 

sUAS. Test flights will be performed by the PIC prior to the sUAS's return to service. All such test flights 

will be noted and logged in the Monthly Maintenance log( see Attachment 1), the PIC's personal Pilot 

Flight Log (see Attachment L) and the sUAS Flight Log (see Attachment H). 

9. The operator must follow the manufacturer's sUAS aircraft/component, maintenance, overhaul, 

replacement inspection and life limit requirements. The following must be included in the operator's 

manual; 

a. Actuators/Servos; 

b. Power plant (motors); 

c. Propellers; 

d. Electronic speed controller; 

e. Batteries; 

f. Mechanical or dynamic components; 

g. Remote command and controller(s); 

h. Navigational screen/interface; and any other component(s) as determined by the operator. 

10. The PIC must possess at minimum a light sport pilot certificate and a valid U.S. driver's license. 

Additionally, the PIC must meet the flight review requirements specified in 14 CFR § 61.56; 

11. A PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum 

of 200 flight hours and 25 hours as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot 

with a similar sUAS type; 

12. A PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum 

of five hours as a sUAS pilot operating the make and model of sUAS to be utilized for operations under 

the exemption and three takeoffs and three landings in the preceding 90 days. The PIC must operate the 

sUAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119; 

13. The PIC and VO must have completed a qualification process; 

14. A flight demonstration, administered by an operator and a qualified pilot must be completed and 

documented in accordance with the operator's manual; 

15. The sUAS may not be operated directly over any person, except authorized and consenting 

inspection and/or operations personnel, below an altitude that is hazardous to persons or property; 

16. All participating persons must be essential and consent to the sUAS operation which should require 

no further FSDO or ASI approval; 

17. The operator must ensure that no persons are allowed within 500 feet of the area except those 

consenting to be involved and who are necessary for the on-going operation of the entity being 

inspected or photographed; 

18. If the sUAS loses communications or loses its GPS signal, the sUAS must return to a predetermined 

location within the security perimeter of the flight operations area and land or be recovered in 

accordance with the operator's manual; 

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

accordance with the operator's manual; 

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20. Each operation must be completed within 20 minutes flight time or with no less than 25% battery 

power remaining, whichever occurs first; 

21. The operator must contain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also 

require the operator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but no 

less than 48 hours prior to the operation; 

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 (NNumber) markings in accordance 

with 14 CFR part 45, Subpart C. Markings must be as large as possible; 

23. The operator must develop procedures to document and maintain a record of the sUAS 

maintenance, alterations, status of replacement/overhaul component parts and the total time in service 

of the sUAS; 

24. Each sUAS operated under this exemption will comply with all manufacturing safety bulletins; 

25. The operator will develop sUAS technician qualification criteria. 

26. The pre-flight inspections section of the operator's manual will include the requirement that the 

pre-flight inspection will account for all discrepancies, e.g., inoperable components, items, or 

equipment; 

27. Before conducting operations, the radio frequency spectrum used for operation and control of the 

sUAS will comply with the FCC or other appropriate government oversight agency requirements; 

28. At least three days before a scheduled aerial filming flight operation the operator of the sUAS 

affected by this exemption will submit a written plan of activity to the local FSDO with jurisdiction over 

the area of the proposed inspection. The 3-day notification may be waived with the concurrence of the 

FSDO. The plan of activities will include the following: 

a. Dates and times for all flights 

b. Name and phone number of the operator for the sUAS flight operation conducted 

under this grant of exemption 

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

sUAS 

d. Make, model, and serial and N-number of sUAS to be used 

e. Name and certificate number of sUAS PIC(s) involved in the flight operation 

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

local officials to conduct the flight operation; the list of those who gave permission 

shall be made available to the inspector upon request 

g. Signature of exemption-holder or representative 

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

town, county, and/or state over which the flight operation will be conducted and 

the altitudes essential to accomplish the operation 

i. The documents required under 14 CFR §§91.9 and 91.203 must be available to the 

PIC at the ground control station of the sUAS any time the aircraft is operating. 

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

enforcement official upon request. 

8 
29. The sUAS must remain clear and yield the right of way to all other manned operations and activities 

at all times (including, but not limited to ultra-light vehicles, parachute activities, parasailing activities, 

hand gliding, etc.); 

30. sUAS operations may not be conducted during night, as defined in 14 CFR § 1.1 

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

special visual flight rules (SVFR) are not authorized; 

32. The sUAS cannot be operated by the PIC from any moving device or vehicle; 

33. The sUAS may not be operated less than 500 feet below or less than 2000 feet horizontally from a 

cloud or when visibility is less than 3 statute miles from the PIC; 

34. The sUAS may not be operated in class B, C, or D airspace without written approval from the FAA. 

The sUAS may not operate within 5 nautical miles of the geographic center of a non-towered airport as 

denoted on a current FAA- published aeronautical chart unless a letter of agreement with the airport's 

management is obtained, and the operation is conducted in accordance with a NOT AM as required by 

the operator's COA. The letter of agreement with the airport management must be made available to 

the administrator upon request; 

35. Any 1) Incident, 2) Accident, or 3) Flight operation that transgresses the lateral or vertical boundaries 

of the operational area as defined by the applicable COA must be reported to the Federal Aviation 

Administration's (FAA) UAS Integration Office (AFS-80) within 24 hour. Accidents must be reported to 

the National Transportation Safety Board (NTSB) per instruction contained on the NTSB website: 

www.ntsb.gov. Further flight operations may not be conducted until the incident, accident or 

transgression is reviewed by the AFS-80 and authorization to resume operations is provided; 

36. The sUAS, PIC and operator will comply with all applicable parts of 14 CFR including, but not limited 

to, parts 45, 47, 61, and 91. 

LIST OF PROPRIETARY FliGHT OPERATIONS, STANDARDS, PROTOCOLS AND 

PROCEDURES DOCUMENTATION 

As noted earlier, Maine Aerial Photography Services LLC's FOPM includes all manufacturers' 

documentation for the OJI Inspire 1 sUAS, as well as a number of flight operations protocols, 

requirements and procedures Maine Aerial Photography Services, LLC considers proprietary. Together, 

these documents governing the planning, management and execution of all Maine Aerial Photography 

Services, LLC flight operations. The FOPM is reviewed and updated on a regular basis to ensure it is 

accurate, current and reflects any new FAA requirement, change of standard and any improvement or 

addition to its flight operations Maine Aerial Photography Services, LLC considers to be in its clients' and 

the public's best interest. 

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REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED: 

14 CFR Part 21 

14 CFR 61.113 (a) & (b) 

14 CFR 61.133 (a) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.109 (a) 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

14 C.F.R. 21: Certification Procedures for Products and Parts 

This section outlines requirements for the issue of design and production approvals, airworthiness 

certificates, and other airworthiness approvals. Maine Aerial Photography Services, LLC is aware that if 

an exemption is granted as per Section 333, an airworthiness certificate would be issued and a request 

for exemption from Part 21 is unnecessary. However, as outlined in the List of Limitations and 

Conditions in this application, as well as all of the Attachments to this application, comprising the FOPM, 

Maine Aerial Photography Services, LLC seeks to uphold the same level or exceeded level of safety as 

described in Part 21 of 14 C.F.R. 

14 C.F.R. § 61.113 (a) & (b), 61.133 (a): Private Pilot Privileges and Limitations: Pilot in 

Command. Commercial Pilot Privileges and Limitations. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have a private pilot's license rather than a 

commercial pilot's license to operate this sUAS. Unlike a conventional aircraft that carries the pilot and 

passengers, the sUAS is remotely controlled with no living being on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance as set forth in the 

FOPM. The level of safety provided by the requirements included in the FOPM exceeds that provided by 

a single individual holding a commercial pilot's certificate operating a conventional aircraft. The risks 

associated with the operation of the sUAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as 

requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. 

§61.113 (a) & (b). 

10 
14 C.F.R. § 91.7 (a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained in the FOPM for maintenance and use of safety checklists prior to each flight, 

an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in 

the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. The sUAS, given its size and configuration has no 

ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, 

but because there is no room or capacity to carry such an item on the aircraft. 

14 C.F.R. § 91.109 (a): Flight Instruction 

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that 

is being used for flight instruction unless that aircraft has fully functioning dual controls. sUAS and 

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. 

14 C.F.R. § 91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption 

is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption 

may be needed to allow such operations. As set forth herein, except for the limited conditions stated in 

the Manual, the UAS will never operate at higher than 400 AGL. It will however be operated in a 

restricted area with security perimeter, where buildings and people will not be exposed to operations 

without their pre-obtained consent. The equivalent level of safety will be achieved given the size, weight 

and speed of the sUAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner or local officials. Because of the advance notice to the property owner 

and participants in the activity, all affected individuals will be aware of the planned flight operations as 

set forth in the FOPM. 

14 C.F.R. § 91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting 

available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS 

11 
altitude read out, an exemption is needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the FOPM, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. 

14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions 

This regulation prohibits an individual from beginning "a flight in an airplane under VFR conditions 

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed- {1) During the day, to fly after that for at least 

30 minutes; or (2) At night, to fly after that for at least 45 minutes." The battery powering the sUAS 

provides approximately 18 minutes of powered flight. To meet the 30-minute reserve requirement in 14 

CFR § 91.151, sUASs flights would be limited to approximately 10 minutes in length. Given the 

limitations on the sUAS proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. 

Limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption will be 

granted. An equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of battery 

power whichever is reached first. This restriction would be more than adequate to return the sUAS to its 

planned landing zone from anywhere in its limited operating area. 

14 C.F.R. § 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a 

civil aircraft unless it has within it the following: {1) An appropriate and current airworthiness certificate . 

. . . (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph 

(a) of this section or a special flight authorization issued under §91. 715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew. The sUAS, fully loaded, weighs no more than 

SSibs. and is operated without an onboard pilot. As such, there is no ability or place to carry 

certification and registration documents or to display them on the sUAS. An equivalent level of safety 

will be achieved by keeping these documents at the ground control point where the PIC flying the sUAS 

will have immediate access to them, to the extent they are applicable to the sUAS. 

14 C.F.R. § 91.405 (a); 407 (a) {1); 409 (a) (2); 417 {a) & {b): Maintenance Inspections 

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ... " and 

others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and 

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. The operator pursuant to the FOPM will accomplish maintenance. An equivalent level of 

safety will be achieved because this sUAS is very limited in size and will carry a small payload and 

operate only in restricted areas for limited periods oftime. If mechanical issues arise the sUAS can land 

immediately and will be operating from no higher than 400 feet AGL. As provided in the FOPM, the 

operator will ensure that the sUAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most 

12 
familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety. 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

Maine Aerial Photography Services, LLC submits that grant of this exemption application advances the 

Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of sUASs into the 

NAS if it can be accomplished safely. This law directs the Secretary of Transportation to consider 

whether certain UASs may operate safely in the NAS before completion of the rulemaking required 

under Section 332 of the Reform Act. In making this determination, the Secretary is required to 

determine which types of sUASs do not create a hazard to users of the NAS, the public, or pose a threat 

to national security in light of the following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the PIC. 

Reform Act§ 333 (a) (1). If the Secretary determines that such vehicles "may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system." ld. § 333 (c). 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act, 

from the requirement that all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service: 

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any of sections 4470244716 of this title if the 

Administrator finds the exemption is in the public interest. 

The grant of the requested exemption is in the public interest based on the clear direction in 

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the 

strong equivalent level of safety surrounding the proposed operations; and the significant public benefit, 

including enhanced safety and cost savings associated with use of UASs for aerial 

videography/photography, the reduction or elimination of unregulated operators, and the safe 

integration of UASs. Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay. 

CONCLUSION 

As set forth herein, Maine Aerial Photography Services, LLC seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 from the requirements of 14 

CFR § 21; 61.113 (a) & (b); 61.133 (a); 91.7 (a); 91.9 (b); 91.109 (a); 91.119 (c); 91.121; 91.151 (a); 

91.203; 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b), which will permit safe operation of the 

13 
sUAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial 

imagery over small, defined operational areas of the United States. 

Approval of the exemption allowing commercial operations of Maine Aerial Photography Services, LLC 

sUAS will increase safety by permitting an operator to conduct a service safely by adhering to the 

prescribed guidelines. The exemption will also encourage the education of sUAS operators and the 

adoption of FAA guidelines and approval for commercial sUAS operations as pertains to Maine Aerial 

Photography Services, LLC employees and contractors. It will allow Maine Aerial Photography Services, 

LLC to provide a service that benefits the public and local businesses. It benefits the public through a 

higher level of safety of sUAS operations and through a smooth integration of sUASs into the NAS. This 

will assist the FAA with its mission of promoting aviation while preserving safety of aviators, the public 

and property. The sUAS operated by Maine Aerial Photography Services, LLC satisfies the criteria set 

forth in § 333 of the Reform Act- size, weight, speed, operating capabilities, operation within visual line 

of sight, and national security - and showing an equivalent level of safety to manned aircraft flights 

through appropriate pilot certification and safety-focused standards of operation. This provides more 

than adequate justification for the grant of the requested exemptions allowing commercial operations. 

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public by allowing 

Maine Aerial Photography Services, LLC to safely, efficiently and economically operate the sUAS 

commercially within the NAS. 

Res~ rz_ __ 

Tyler S. Plummer 

Maine Aerial Photography Services, LLC 

(Written with reference to exemption letters retrieved from www. faa.gov) 

14 
ATTACHMENTS 

DJIInspire 1 Manufacturer Documentation 

A. DJIInspire 1 Overview and Specifications Data Sheet 

B. DJIInspire 1 User Manual_v1.2.pdf 

C. DJI Inspire 1 Safety Guidelines.pdf 

D. DJIInspire 1 Quick Start Guide.pdf 

E. DJIInspire 1 Maintenance Manual_vl.O.pdf 

F. DJIInspire !Intelligent Flight Battery Safety Guidelines.pdf 

Maine Aerial Photography Services, LLC Proprietary Documentation 

G. Maine Aerial Photography Services, LLC Flight Checklists and Operating Protocol 

H. Maine Aerial Photography Services, LLC sUAS Flight Log 

I. Maine Aerial Photography Services, LLC Monthly Maintenance log 

J. Maine Aerial Photography Services, LLC Pre-Flight Safety Briefing and On-Site Flight Plan 

K. Maine Aerial Photography Services, LLC Permission to Conduct Onsite Flight Operations 

Consent Form 

l. Maine Aerial Photography Services, LLC Pilot Flight Log 

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