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 June 11, 2015 

Laura Heller 

Stratis Imaging, Inc. 

3213 W. Wheeler St., Suite 27 

Seattle, WA 98199 

Cell: (206)853-9407 

Email: laura@stratisimaging.com

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 (P.L. 112-95) 

Attachments: 

1) Stratis UAV Flight and Maintenance Manual 

2) Stratis UAV Pilot Training Manual 

 

To Whom It May Concern: 

On behalf of Stratis Imaging, Inc., (herein referred to as “Stratis”) co-founders Laura 

Heller and Geoffrey Heller, we request an exemption from the below stated sections of 

Title 14, Code of Federal Regulations. This is in accordance with the FAA’s Guidelines 

for Submitting a Petition for Exemption under section 333 of the FAA Modernization and 

Reform Act of 2012. This request is submitted based on the precedence set by and is 

similar to Exemptions No. 11062, 11109, 11112, and 11213. 

 14 CFR 61.101(e)(4) and (5) Recreational pilot privileges and limitations. 

For compensation or hire; In furtherance of business. 

It is Stratis intent to operate the UAS for commercial use for compensation or 

hire and for the pursuance of our business. 

 14 C.F.R. 61.113(a) Private pilot privileges and limitations: Pilot in 

command. 

As previously stated, it is Stratis intent to operate the UAS for commercial use 

for compensation or hire and for the pursuance of our business using a private 

pilot to command the UAS. 

 14 C.F.R. 61.23(a) and (c) Medical certificates: Requirement and 

duration. 

As Stratis intends to utilize a private pilot or sport pilot license holder who has 

a current US drivers license, an exemption from the need a medical certificate 

is requested. Further, the pilots UAS operations will be conducted on ground 

on a relatively light weight UAS vs. in-air on a manned aircraft. 
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 14 C.F.R. 91.7 (a) Civil aircraft airworthiness. 

Stratis Imaging requests an exemption since there is currently no certificate 

applicable to our operation other than the Section 333 Exemption which states 

that the PIC shall have the responsibility to determine airworthiness. This 

requirement is stated in the Flight and Maintenance Manual as well as in the 

Pilot Training Manual. 

 14 C.F.R. 91.119(c) Minimum safe altitudes: General. 

Stratis UAS will operate below 400 ft. This requirement is stated in the Flight 

and Maintenance Manual as well as the Pilot Training Manual. 

 14 C.F.R. 91.121 Altimeter Settings. 

The UAS will be equipped with a barometric pressure altimeter. Altitude 

shall be monitored using the UAS telemetry. 

 14 C.F.R. 91.151(a) (1) Fuel requirements. 

The UAS will be powered by battery and will operate for the intended 

operational time with at least five minutes remaining battery or with the 

reserve power recommended by the manufacturer if greater. 

 14 C.F.R. 91.405(a) Maintenance required. 

The Pilot will perform a preflight inspection of the UAS before each flight as 

outlined in the attached Flight and Maintenance Manual document. 

Additionally, if there is any alteration that affects the flight characteristics or 

safety, a functional test will be conducted prior to being deemed airworthy. 

 14 C.F.R. 91.407(a)(1) Operation after maintenance, preventive 

maintenance, rebuilding, or alteration. 

Procedures in the Flight Manual require the pilot to monitor the UAS during a 

preflight inspection for airworthiness. Any alteration shall be minor, not 

affect the safety of flight, and shall not affect the basic control and stability of 

the UAS. Additionally, if there is any alteration that affects the flight 

characteristics or safety, a functional test will be conducted prior to being 

deemed airworthy 

 14 C.F.R. 91.409(a)(1) and (2) Inspections. 

Procedures in the Flight Manual require the pilot to inspect the UAS during a 

preflight inspection for airworthiness prior to flight. Additionally, a flight test 

is required prior to the operational flight to ensure UAS readiness. 

 14 C.F.R. 91.417(a) and (b) Maintenance Records. 

Pilot and Operator procedures are required to monitor, inspect, and document 

any issues related to the UAS operation effectiveness. This requirement is 

stated in the Flight and Maintenance manual. 
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I. About Stratis Imaging 

Stratis Imaging Inc. was founded to innovate around UAS data collection and analysis. 

Additionally, Stratis Imaging will provide data collection services for multiple purposes, 

including mapping, surveying, inspection, analysis, and general videography. Our 

mission is to enhance commercial UAS data collection and analysis capabilities to 

provide new insights for industry use. Additionally, digital imaging data gathering 

service will be conducted to explore the UAS market as well as provide clients with high 

quality images and digital data. Stratis will be performing research and development 

around UAS digital imaging as well as operational digital imaging. 

One of our primary missions as a company is to ensure full compliance with all 

regulations that govern UASs. As such, our operations will be conducted within the 

acceptable FAA regulations with the exception of the herein requested exemptions. 

Additionally, the referenced flight and maintenance manual as well as the pilot training 

manual state these requirements in their respective context. Further, the UAS Pilot and 

observers engaged in operations are expected to be responsible for operating within these 

regulatory parameters. 

Safety of flight is a primary objective at all times for our company operations with a high 

standard of safety awareness. Stratis has taken several steps to ensure safety of flight in 

UAS operations: First, is to be fully compliant to the relevant UAS regulations as stated 

above, as these regulations are in place to enhance public safety. Second, is to train all 

pilots and observers as outlined in the referenced pilot training manual to ensure the pilot 

and observer are fully qualified on Stratis Imaging UASs. Third, is to conduct flights 

according the flight manual as stated in the Flight and Maintenance Manual, including 

safe abort procedures if an unsafe condition arises. Fourth, is to ensure the UASs are 

operationally safe as per the inspection and maintenance requirements as stated in the 

Flight and Maintenance Manual. Finally, Stratis Imaging sets the expectation that all 

UAS operators and participants are held to high standard of safety awareness while 

operating a UAS. 

The Co-founders of Stratis Imaging have extensive technology experience in both 

imaging as well as in aviation to help ensure a safe, mature and experienced approach to 

digital imaging and technology development on a UAS platform. Co-Founder Laura 

Heller has over 12 years experience with aviation Engineering and Management of 

commercial airplane flight controls and avionics systems development. She has also 

completed ground school training for a private pilot’s license and has hobbyist flight 

hours on several small UASs. Co-Founder Geoffrey Heller has over 20 years of 

Engineering Management and Software Engineering experience as well as experience 

with commercial software and hardware development. Additionally, he has extensive 

hobbyist hours designing, building, operating and maintaining UASs. As such, our 

qualifications, along with a certified pilot for UAS operation, provide the necessary 

qualifications for safe, compliant UAS operations. 
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II. UAS Description 

Stratis Imaging requests Section 33 exemption for the following UASs: 

• Stratis Model 1: A quadcopter built on a DJI Flamewheel F450 frame and 

running the Pixhawk flight controller 

• Stratis Model 2: A hexacopter built on a Tarot Iron Man 680 Pro frame and 

running the Pixhawk flight controller 

The weight of these UAS shall be compliant with the regulations stated as less than 55 lbs 

in the Section 333 Exemption guidance. Please see the Flight and Maintenance Manual 

for a detailed description and flight characteristics. As stated in the Flight and 

Maintenance manual as well as in the Pilot training manual, the pilot is responsible for 

UAS airworthiness which includes following the site check list, the UAV inspections, 

preflight checklist, and flight test. 

III. UAS Operations 

When conducting Stratis Imaging operations, the following requirements will be met. 

These requirements are embedded in the Stratis Flight and Maintenance Manual, where 

both the Pilot and Visual observers have full responsibility for compliance. 

• Operations will be performed only at the request of and with the authorization and 

permission of clients or their authorized agents in order to facilitate commerce and 

raise awareness of the beneficial uses of small unmanned air systems so long as such 

operations are conducted within and under the conditions outlined herein or as may 

be established by the FAA as required by Section 333 Exemption. 

• The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour). 

The PIC and/or VO will 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 UAS operating airspeed recommended by the 

aircraft manufacturer as required by Section 333 Exemption. 

• Operations will be conducted below 400 feet AGL, with instrumentation and 

telemetry set to report in feet AGL as required by Section 333 Exemption 

• The UAS will 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 as required by Section 333 Exemption. 

• All operations will utilize a visual observer (VO). The UAS 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 
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capability. The VO and PIC will be able to communicate verbally at all times, where 

electronic messaging or texting will not be used during flight operations. The PIC will 

be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC will ensure that the VO can perform the duties 

required of the VO. These shall be as required by Section 333 Exemption. 

• Operate and land the UAS prior to the manufacturer’s recommended minimum level 

of battery power or with 5 minutes of remaining battery power, whichever is greater, 

as required by Section 333 Exemption. 

• Operating documents will be immediately accessible to the PIC and/or VO during 

operations. We will be responsible for ensuring these documents are updated as 

necessary. 

• Use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers 

and then slowly lands if communication with the remote control pilot is lost. 

• Conduct all operations under the flight safety protocols contained in the operating 

documents and will actively analyze flight data and other sources of information to 

constantly update and enhance safety protocols. 

• Contact respective airports if operations will be within 5 miles to advise them of his 

estimated flight time, flight duration, elevation of flight and other pertinent 

information. 

• Upon any changes that affect UAS operations or flight characteristics, a functional 

flight test will be conducted prior to any further operations. The functional flight test 

will be conducted by a PIC with a VO and shall be at least 500 feet from other 

people, with no undue hazard to people or property. 

• A preflight inspection will be conducted by the PIC and/or VO prior to operations. 

Any condition that may affect the safe operation of the UAS will not be flown in 

operations until the UAS has been restored to a safe flight condition. The PIC is 

responsible to ensure that the UAS is airworthy as part of the preflight inspection. 

Refer to the UAS User’s Manual. 

• The UAS operators will follow the manufacturer’s recommended maintenance; 

overhaul, replacement, inspection, and life limit requirements for the UAS’ and will 

comply with all manufacturer safety bulletins as described in the UAS Flight and 

Maintenance manual. 

• Have procedures in place to abort flights in the event of safety breaches or potential 

danger. 

IV. UAS Pilot in Command (PIC) 
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• The UAS will be operated by a PIC who holds either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC will 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 will 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. 

• The operators will ensure that the PIC demonstrates the ability to operate the UAS 

safely and within regulations under this requested exemption. This includes 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). 

• Dedicated training sessions will be conducted as necessary to ensure the PIC is 

qualified to operate the UAS. During training, proficiency, and experience-building 

flights, all persons not essential for flight operations are to be considered 

nonparticipants, and the PIC will operate the UA with appropriate distance from 

nonparticipants. 

Additional Requirements: 

• The PIC shall successfully complete the pilot training as described in the pilot 

training manual prior to operation of the UAS’. This includes a minimum of 20 hours 

of flight hours on either Stratis Imaging's UAS and/or UAS of similar configuration. 

• The VO shall successfully complete the VO training as described in the pilot training 

manual prior to the operation of the UAS. 

V. RF Communications 

The UAS’ will operate under the following Radio Frequencies. All frequencies are used 

in compliance as per FCC Part 18 rules for operating in the specified ISM frequency 

bands. 

Flight Control: 

 Control frequency / Working Frequency: 2.4 GHz ISM 

 Control Channel Numbers of Transmitter: 16 

 Communication Distance: >1.5km 

 Receiver Sensitivity: > - 100 dBm 

 Power Consumption of Transmitter: < 20 dBm 

 Working Current/Voltage: 100mA @ 5V 

Telemetry (Bi-Directional): 

 Telemetry Transmitter Frequency: 915 Mhz ISM 

 Communication Distance: >1.5km 

 Receiver Sensitivity: > - 100 dBm 

 Power Consumption of Transmitter: <= 20 dBm 
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 Working Current/Voltage: 100mA @ 5V 

Camera / Live Video to Monitor: 

 Video Transmitter Frequency: 5.8 Ghz ISM 

 Communication Distance: >200m 

 Receiver Sensitivity: > - 100 dBm 

 Power Consumption of Transmitter: <= 20 dBm 

 Working Current/Voltage: 100mA @ 5V 

VI. Public Benefit 

Utilizing UAS for the purposes of aerial image data gathering and analysis is a growing 

industry that takes advantage of the small, lightweight, and less expensive technologies. 

Contrasted with manned aircraft, there is substantial more versatility, far less cost, and 

significant reduction in risk to the public by utilizing UASs. Additionally, more 

extensive research and development can be conducted to enhance image data gathering 

and analysis technologies. This is one of Stratis Imaging’s primary intentions. Because 

of this research and development, valuable new technologies will be developed. This can 

add jobs to the economy, improve industry efficiency, and increase awareness of our 

environment in ways not previously possible. By granting this exemption, these benefits 

can be achieved to the betterment of public overall. 

VII. Confidentiality 

We request that the FAA refrain from publishing any of the Stratis Imaging’s provided 

documents to the public. This includes the UAS Flight and Maintenance Manual as well 

as the UAS Flight Training Manual. These documents are intended for Stratis employees 

and the FAA personnel only who are responsible for the evaluation and determination of 

this exemption request. 

VIII. Summary 

Stratis Imaging requests an exemption from the below list of regulations for UAS 

commercial operations, including data collection and analysis services as well as research 

and development. 

14 C.F.R 61.101(e)(4) and (5) 

14 C.F.R. 61.113(a) 

14 C.F.R. 61.23(a) and (c) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.119(c) 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) (1) 

14 C.F.R. 91.405(a) 

14 C.F.R. 91.407(a)(1) 

14 C.F.R. 91.409(a)(1) and (2) 

14 C.F.R. 91.417(a) and (b) 
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The public will benefit by virtue of additional employment, safer methods of data 

gathering, and potentially new technologies available to industry. It is our commitment 

to comply with all of the conditions and limitations stated within the exemption, should it 

be granted. 

Please contact the undersigned for any further information or questions regarding this 

petition. Thank you for your consideration. 

Respectfully, 

Laura Heller 

Founder, Stratis Imaging, Inc.