May 11, 2015

Exemption No. 11526

Regulatory Docket No. FAA–2015–0339

Ms. Mary Whitworth

Florida Aerial Services, Inc.

1628 Dale Mabry Suite 105

Lutz, FL 33548

Dear Ms. Whitworth:

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 letter posted to the public docket on February 10, 2015, you petitioned the Federal 

Aviation Administration (FAA) on behalf of Florida Aerial Services, Inc. (hereinafter 

petitioner or operator) for an exemption. The petitioner requested to operate an unmanned 

aircraft system (UAS) to conduct aerial photography for the media and advertising industries 

for pre-planned, controlled area, photographic and surveying services.

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.

Airworthiness Certification

The UAS proposed by the petitioner is are the Steadidrone QU4D and DJI Inspire 1.

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 
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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 collection1. 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, 

delegated to me by the Administrator, Florida Aerial Services, Inc. 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.

 

1 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.
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Conditions and Limitations

In this grant of exemption, Florida Aerial Services, Inc. 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 Steadidrone QU4D 

and DJI Inspire 1 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.

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, 
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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.

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.
5

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 

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.
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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.

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.
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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.
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This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam,

Pursuant to §333 of the FAA Modernization and Reform Act of2012 (the Reform Act) and 14 

C.F.R. Part 11, Florida Aerial Services, Inc., operator of Small Unmanned Aircraft Systems 

(sUASs) equipped to conduct aerial photography for the media and advertising industries for 

pre-planned, controlled area, photographic and surveying services, hereby applies for an 

exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation 

of its sUASs, 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. Florida Aerial Services Inc's current operation of sUASs for commercial purposes has 

been halted to comply with recently enacted federal aviation regulations pertaining to sUASs.

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

unmanned and relatively inexpensive 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.

The name and address of the applicant is: Florida Aerial Services, Inc, Attn: Mary Whitworth 

Ph: +1-(813)-264-7911 Email: mary@fastaerial.com Address: 1628 Dale Mabry Ste 105, Lutz, 

Fl 33548-3034.

Florida Aerial Services, Inc. respectfully requests a grant of an exemption of the following 

sections of Title 14 of the Code of Federal Regulations:

o 14 CFR 21; o 14 CFR 91, et seq.; o 14 CFR 45.23 (b);

Addr: 1628 Dale Mabry Ste 105, Lutz, Fl 33548-3034

Ph: + 1-(813)-264-7911 Email: mary@fastaerial.com

Web: www.fastaerial.com

Re: Exemption Request Pursuant To Section 333 ofthe FAA Reform Act of2012 • 14 CFR 

61.113 (a) & (b);

14 CFR 407 (a)(l); 

14 CFR 409 (a)(2); • 14CFR417(a)&(b). 

Florida Aerial Services, Inc. also respectfully requests an Exemption from Section 333 of the 

FAA Reform Act and Part 11 of the Federal Aviation Regulations from:

•

14 CFR 45.23(b); 14 14 C FR Part 21;  CFR 61.1 13 (a) & (b); 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) (2); • 91.417 (a) & (b).

I. The Extent of Relief Florida Aerial Services, Inc. Seeks and the Reason It Seeks Such Relief:

Florida Aerial Services, Inc. submits this application in accordance with the Reform Act, 112 
P.L. 95 §§331-334, seeking relief from any currently applicable federal aviation regulations 

PARs pertaining to UASs (unmanned aircraft systems) and operating to prevent Florida Aerial 

Services Inc. contemplated commercial photography, Photographic mapping, and other flight 

operations within the U.S. national airspace system.

The Reform Act in §332 provides for such integration of civil UASs into our national airspace 

system as it is in the public's interest to do so. Florida Aerial Services lightweight UASs meet 

the definition of "small unmanned aircraft" as set forth in §331 and combined with a sterling 

safety record in similar industries, Florida Aerial Services light duty UASs are ideal recipients 

of exemption by the intent of the Reform Act.

Considerations for relief include a combination of sUAS physical characteristics, safety 

features, and safe practices identified in §333:

• sUAS weight, • sUAS overall size, • sUAS speed over ground,

• sUAS flight zone characteristics,

- Non-operation near airports (civilian or military), 

- Tightly controlled operation in populated areas, 

the client. ific co Specnsideration is outline below.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

• Operation of the UAS by VLOS. • Coordination by a minimum of 2 persons, 2 staff 

members of Florida Aerial Services and one safety official from

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited 

operating area associated sUASs, an exemption from Part 21 Subpart H meets the requirements 

of an equivalent level of safety under Part 11 and §333 of the Reform Act. 1l1e Federal 

Aviation Act (49 U.S.C.§4470 1 (f)) and §333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and populated areas of the 

particular sUAS. In all cases, an analysis of these criteria demonstrates that the UAS operated 

without an airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) 

operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated by Florida Aerial Services, Inc. is less than 2kg. with maximal 

payload consisting of remote sensing instrumentation, carries neither no persons, carries no 

explosive or flammable materials including combustible fuels, and operates exclusively within 

a secured area. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by both the pilot (PIC), 'spotter' role designated to act as both the 

remote sensing controller and secondary monitor for safety issues, and a technician, which 

assists in matters related to maintaining the sUAS and also monitors for safety concerns and 

liaisons to the on-site safety officials. These enhancements to current safety practices and 

regulations, which already apply to civil aircraft, provide a greater degree of safety to the 

public and property owners than conventional aircraft operations conducted with airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria 

demonstrates that there is no intrinsic credible threat to national security posed by the UAS, 
due to its size, speed of operation, location of operation, lack of intrinsic explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. §45.23 (b). Marking of the Aircraft The regulation requires: When marks include 

only the Roman capital letter "N" and the registration number is displayed on limited, restricted 

or light-sport category aircraft or experimental or provisionally certificated aircraft, the 

operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot 

station, in letters not less than 2 inches nor more than 6 inches high, the words "limited;' 

"restricted;' "light-sport;' "experimental;' or "provisional;' as applicable.

Even though the sUAS will have no airworthiness certificate, an exemption may be needed as 

the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word 

"Experimental" can be placed. Given the size of the sUAS, two-inch lettering will be 

impossible. The word "Experimental" will be placed on the frame in compliance with §45.29 

(f) at a size suitable for the available space.

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the 

identification of the UAS as "Experimental." The FAA has issued the following exemptions to 

this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

Further markings include the use of flashing green LED illumination on the underside of the 

sUAS frame which stands at contrast against a blue or white sky.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

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

Command. §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 a ground crew member 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 persons on board. The area of operation is controlled and restricted, and all flights are 

planned and coordinated in advance. 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 as requested with a private pilot in the ground crew 

exceeds the present level of safety achieved by 14 C.P.R. §61.1 13 (a) & (b).

14 C.P.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 Manual for maintenance and use of safety check lists 

prior to each flight, a subset of which are provided in enclosed Supplemental material, an 

equivalent level of safety will be provided.

14 C.F.R. §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. §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 to carry a physical flight manual on 
the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at 

the ground control point where the pilot flying the sUAS will have immediate access to it. The 

FAA has issued the following exemptions to

this regulation: Exemption Nos. 8607,8737,8738,9299, 9299A, 9565,95658, 10167, 10167A, 

10602,32827, and 10700.

14 C.F.R. §91.103: Preflight action This regulation requires each PIC to take certain actions 

before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not 

be provided for the aircraft an exemption will be needed. The PIC will take all actions 

including reviewing weather, flight battery requirements, landing and takeoff distances and 

aircraft performance data before initiation of flight. Further, we have proprietary manuals 

created with the help of sUAS experts, the manufacturer, the regional sUAS vendor and policy 

holding insurer and continue to work with these organizations to ensure best safe practices are 

adhered to.

14 C.P.R. §91.109: Flight instruction §91.103 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. sUASs 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. See Exemption Nos.5778K & 9862A. 

The equivalent level of safety provided by the fact that neither a pilot nor passengers will be 

carried in the aircraft and by the size and

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

speed of the aircraft. Enhancing this safety is the technology inherent in the remote controls 

utilizing digital communications which is paired to the sUAS making it nearly impossible to 

unintentionally or intentionally have the control communications interrupted.

14 C.F.R. §91.119: Minimum safe altitudes §91.119 establishes safe altitudes for operation of 

civil aircraft. §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 closely mimics the 

behavior of a helicopter, and the exemption requests authority to operate at altitudes up to 400 

AGL, an exemption may be needed to allow such operations. As set forth herein, the UAS will 

never operate at higher than 400 AGL or beyond unaided visual line of sight, whichever is 

closer. It will however be operated in a restricted area with security officials tasked with 

ensuring public safety, and where buildings and people will not be exposed to operations 

without their pre-obtained consent and training.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well 

as the location where it is operated. No flight operation will be taken without the permission of 

the property owner in the case of private property or local officials in the case of public 

property or private property with public interests. Because of the advance notice to the property 

owner and participants in the remote sensing activity, all affected individuals will be aware of 

the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighing 

far more than the maximum 2kg of Florida Aerial Service's sUAS’s proposed herein and the 
lack of flammable fuel, any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or below 500 AGL. In addition, the lowaltitude operations of the sUAS will ensure separation between these small- UAS operations 

and the operations of conventional aircraft that must comply with §91.119.

14 C.F.R. §91. 121 Altimeter Settings §91.121 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 altitude read out, an exemption may be 

needed. An equivalent level of safety will be achieved by the operator, confirming the altitude 

of the launch site shown on the GPS altitude indicator before flight. The PIC and Technician 

will also ensure effective pairing with multiple GPS sources to guarantee accurate detection of 

height.

14 C.F.R. §9 1.15l (a): Fuel Requirements for Flight in VFR Conditions §91.151 (a) 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 15 minutes of powered flight in hover mode with out payload. 

Florida Aerial Service's sUAS will not be able to meet the 30 minute reserve requirement in 14 

CPR §91.151. Operating the small UAS, in a tightly controlled area where only people and 

property owners or official representatives who have signed waivers will be allowed, with less 

than 30 minutes of reserve power, does not engender the type of risks that Section 9l.l51(a) was 

intended to alleviate given the size and speed of the small UAS. Florida Aerial Services, Inc.

believes that an equivalent level of safety can be achieved by limiting flights to » 10 minutes 

or 25% of battery power whichever happens first. This restriction would be more than adequate 

to return the sUAS toils planned landing zone from anywhere in its limited operating 

area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673, and 10808.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

14 C.P.R. §91.203 (a) & (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 2kg 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 pilot flying the sUAS will have immediate access to 

them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions 

to this regulation. A representative sample of other exceptions includes Exemption Nos. 

9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.P.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections T hese 
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. Maintenance will be accomplished by the operator 

pursuant to the flight manual. An equivalent level of safety will be achieved because these 

small UASs are very limited in size and will carry a small payload and operate only in 

restricted areas for limited periods of time. If mechanical issues arise the UAS can land 

immediately and will be operating from no higher than 400 feet AGL. The operator will ensure 

that the UAS 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 familiar 

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

equivalent level of safety.

An exemption granted to Florida Aerial Services, Inc. would permit its operation of 

lightweight, unmanned, remotely controlled, sUASs in a tightly controlled environment with 

limited airspace. Florida Aerial Services, Inc utilizes local business' safety officers in 

specifically determined areas (designed flight zone) to mitigate injury and property damage 

while fulfilling clients' goals. Technical enhancements to current safety controls will allow 

Florida Aerial Services, Inc to operate exceeding current safety specifications, and stay ahead 

of, or meet, new ones being implemented by the FAA and Department of Transportation. 

Further, Florida Aerial Services, Inc conducts its operations in compliance with protocols 

described herein or as otherwise established by the FAA.

II. Commercial and Public Benefits

We at Florida Aerial Services, Inc believe that granting this exemption request furthers the 

public interest by providing safe (by way of an unmanned system) and efficient means to meet 

technical problems solvable by elevated data collection instruments. Florida Aerial Services, 

Inc 's client base are typically small to medium sized business' looking to increase their 

awareness of structures or landscape on their respective properties through data collection other 

Public Interest 

aerial videography for geographical awareness and for real estate marketing has been around for a long 

time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has 

been cost-prohibitive. Granting this exemption to the petitioner would allow him to provide this service 

at a much lower cost. Further, the petitioner indicates his small UAS will pose no threat to the public 

given its small size and lack of combustible fuel when compared to larger manned aircraft. The 

petitioner also states that the operation of his UAS will minimize ecological damage and promote 

economic growth by providing information to companies looking to relocate or build in the state of 

Florida areas. 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

by photographic, video graphic or lidar based surveying. By moving these functions onto sUAS 

based aircraft, the potential for loss of life or property is diminished due to the greater control 

in a smaller and safer aircraft that holds no persons. Second, there are no reactive or 
combustible materials on board the sUAS and thus the potential for fire or explosions is greatly 

diminished. Third, the small size and extreme maneuverability of Florida Aerial Services, Inc

UASs allow the PIC to avoid hazards. Lastly, due to the nature of the remote sensing 

instrumentation onboard, the sUAS can maintain quite a safe distance between the aircraft and 

the object(s) undergoing scrutiny. Accordingly, Florida Aerial Services, Inc 's UASs have 

operated and will continue to operate at and above current safety levels.

A. The costs and benefits of your proposed action to society in general and specific groups 

within society as described above, Florida Aerial Services, Inc 's past customers have been 

small to medium business seeking a remote sensing solution to specific issues before a larger 

effort on their part would come underway. Examples include construction efforts that sought 

elevated photographic imagery of specific landforms to minimize cost of efforts to develop, a 

regional park service that wanted to quantify the changing lifecycle of it's flora by way of 

measuring leaf health through gradual chlorophyll depletion, and a local cities' Dept. Fish and 

wildlife that sought to collect images and wooded area data by way of photographic means of 

it's trees to serve as a supplement to it's routine repair and planning documentation.

The impact to society, financial and otherwise, would be extremely minimal. Indeed, it's been 

demonstrated that sUASs have the ability to drastically increase the information available to 

policymakers at a fraction of the cost of measuring this data by terrestrial means. One such 

impact would be inconvenience to directly proximal and non-essential personnel that would be 

displaced from public or business owned property if it is deemed to be unsafe. In this case we 

relay our needs for a f1ight zone with the requirement that it be safe from casual intrusions and 

allow the business time to shift operations in order to minimize potential safety issues. This is 

best performed with the aid of safety personnel that actively steer non-essential persons around 

the flight zone.

I. The effect of an exemption for Florida Aerial Services, Inc on the quality of the natural and 

social environments utilizing sUASs minimizes the requirement for conventional aircraft. This 

eliminates the need for an onboard pilot, time consuming adherence to regulations surrounding 

bookkeeping and submission of flight paths to local civilian or military airports, and 

detrimental effects to the environment caused by operating a combustible fuel based, large 

scale aircraft, with restrictions on the proximity to the target for remote sensing.

II. Flight Capabilities and Characteristics of Florida Aerial Services, Inc 's UASs Persuant to 

112 P.L. 95 §333 (a), concerns for public safety are mitigated by the overall capabilities and

characteristics of the sUAS. Florida Aerial Services, Inc UASs utilizes four (4) counterrotating propellers paired oppositely to each other for balance, control and stability. The total 

span of the sUAS is less than ""'1.2m allowing for stable flight or landing even with the sudden 

onset of detrimental environmental conditions. The sUAS's have a maximal unit+ payload mass 

of 2kg, including cinematic/photographic or other surveying equipment. 

III.Florida Aerial Services, Inc 's sUAS is designed to primarily hover in place to capture 

photographic data and then operate at less than a 35 knot maximum speed to then next point of 

interest. They are capable of vertical and horizontal operations but, in practice, is operated only 

within unaided VLOS of the PIC. In addition to the PIC, Florida Aerial Services, Inc employs a 

spotter (VOS role) and a technician (secondary VOS and on-site personnel liaison) which are 

within unaided verbal communication range. These personnel are supplemented by safety 

officials provided by the client who are instructed to cordon off the area of operations.

1More characteristics have been outlined in the enclosed supplemental materials.
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

off and otherwise minimize pedestrian access in the flight zone of the client's grounds. In the 

event of loss of visual of the UAS, the PIC can change flight controls from cartesian (X,Y,Z) 

based controls to radial (r,a ,h) based controls which allows the PIC to utilize one controller 

axis to recall the VAS to the PIC's position without concern to the current heading of the sUAS. 

In the event of loss of sight of the sUAS into an area containing hazards or possible hazards, 

the spotter has a heads-up-display containing a live video feed which can be used to locate the 

UAS while it maintains it's position in hover mode. The sUAS has demonstrated

it's ability to maintain it's position by GPS coordinates in hover mode in "-'2Skph wind gusts at 

rv25 feet representing an extreme environmental condition beyond the range of conditions 

within the scope for sUAS operation.

All of Florida Aerial Services, Inc 's sUASs utilize LiPo (lithium polymer) battery based power 

sources, decreasing safety risks from more easily combustible, fuel based, power sources. 

Flight times generally last between eight (8) to ten (10) minutes allowing the staff to work with 

small flight areas per phase. The maximum flight time without payload is 15 minutes, however 

practical safe operation limits this to 10 to give ample time to control the sUAS to a safe 

landing zone. Florida Aerial Services, Inc further restricts flight time by not operating its 

sUASs with less than twenty five percent battery capacity. Further safety management systems 

in place include a GPS mode that allows Florida Aerial Services, Inc sUASs to hover in place if 

communication with the PIC is lost and optionally follow a set of waypoints at a set speed and 

height to a 'home base' predesignated safe landing zone. In the event of UN-forseen motor(s) 

failure, the system will enter into a controlled descent while allowing full use of all UAS flight 

controls by the PIC. All commands sent via remote controller received during a controlled 

descent are translated to an 'as meant' paradigm meaning the flight control package will use it's 

realtime 3 dimensional position and compensate rotors control the sUAS regardless of spin 

velocity. 

This assures that if one system is compensated a safe and successful landing can still occur.

IV. Reasons Why an Exemption to Florida Aerial Services, Inc., Will Not Adversely 

Affect Safety Standards

Florida Aerial Services, Inc 's contends that operation of it's sUAS’s will not "create a hazard to 

users of the national airspace system or the public:' as stated in 112 P.L. 95 §333 (b). Given the 

diminutive size and weight of Florida Aerial Services, Inc 's sUASs, combined with their 

operation in cordoned off and well-controlled areas, Florida Aerial Services, Inc 's sUASs falls 

within Congress's contemplated safety zone. Florida Aerial Services, Inc sUASs have an 

established safety record bolstered by multi-point preflight checklist, awareness of their 

surroundings and intimate knowledge of the behavior of the sUAS platform in many weather 

conditions. T600’s safety record and implemented operational practices

demonstrate an awareness of public safety. Florida Aerial Services, Inc operations routinely 

provide a level of safety at least equal to existing rules, and in nearly every

instance, exceeds existing rules. Florida Aerial Services, Inc., has worked very closely with the 

regional vendors and support for this unit to create a tightly integrated and highly tolerant 
platform that has been tested thoroughly by a vendor with a proven record for safety and solid 

designs. Florida Aerial Services, Inc also continues to work closely with organizations to 

identify and mitigate sUAS platform risk due to their expertise in several industries closely

related to the aviation and transportation. Florida Aerial Services, Inc generally does not 

operate its UASs on or near airports and generally has only operated its fleet on private

grounds with cordoned off areas or areas under the control of the property owner I client with 

assistance by safety officials employed by the business and property owners. Florida Aerial 

Services, Inc determines the areas needed to fulfill the clients' goals and only operates its UASs 

in these flight zones and only in compliance with well regarded safety protocols set forth 

initially by the RC UAS trade and hobby groups and recently codified by relevant FARs.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 Florida Aerial 

Services, Inc standardized on the following practices to ensure safe operation of it's UASs:

• Work with on-site personnel to plan the flight goals, • Work with on-site personnel to 

restrict access to non-essential persons, • Operation by unaided VLOS operation only,

•

Operation in phases 10 minutes in length, O peration to m inim al 25% 

power, Operation of device to GPS aided readout to 300ft at maximum, erous N um preprogrammed fail-safes that ensure specific behavior per issue, Three main roles supplemented 

by on-site safety personnel, Employ controlled lifecycle management of components to guard 

against multiple failures,

• • • • • • •

Perform a site check day(s) before flight to identify potential issues, Subscribe to relevant local 

weather and safety alerts, expertly choose data collection instruments and accessories to 

minimize flight requirements or expertise, Florida Aerial Services, Inc has experience in 

similar fields and has adapted this experience in it's use of UASs to increase safety. In 

combination to the ever expanding knowledge repositories from hobbyists and experts alike, 

Florida Aerial Services, Inc is constantly evolving it's practices when there is a clear benefit to 

operations or increased safety element.

A. Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed:

Florida Aerial Services, Inc {applicant) seeks an exemption from the following rules: 14 C.P.R. 

§21, subpart H; 14 C.F.R 45.23(b); 14 C.P.R. §§61.113( a) & (b); 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) (2); 91.409 (a) {2) and 91.417 (a) & (b) to operate commercially a small unmanned 

vehicle (11kg or less) in elevated photographic and remote sensing operations.

Approval of exemptions allowing commercial operations of sUASs in the media industry will 

enhance safety by reducing risk associated with conventional aircraft operations and other 

means of elevated remote sensing involving persons. The public benefit served by approval of 

this petition is increased awareness of characteristics of difficult imaging targets. A sUAS 

weighing fewer than 1lkg and powered by sealed batteries eliminates virtually all associated 

risk inherent in operating conventional aircraft in close proximity to buildings or persons or 

otherwise elevating persons to a position they would be able to collect needed data.
The operation of small UASs, weighting less than 55lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein, including exempting the applicant from the requirements of Part 

21 and allowing commercial operations.

1628 Dale Mabry Ste 105, Lutz, Fl 33548-3034 mary@fastaerial.com +1-(813)-264-7911

PIC VLOS Best,

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

As identified and described herein, Mary Whitworth, a commercial pilot, 4/2014 Class II 

Medical Certificate, and her company Florida Aerial Services, Inc, is an experienced, 

recognized media services professional in the various photographic industries. Mrs. Whitworth

and her companies have been producing and delivering media and technical solutions for the 

media service industry for twenty eight (28) years with nearly a spotless safety record.

The FAA has been given the authority to issue the exemption to Florida Aerial Services, Inc

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek your 

consideration and approval of this petition.

encl: Supplement A: Physical characteristics of UAS encl: Supplement B: Flight Operation and 

Procedures Manual (FOPM) related to operation encl: Supplement C: Flight maps in Florida 

Aerial Services, Inc regional base

VI.

Supplement B :Summary Sections of Flight Operations and Procedure Manual (FOPM) • All 

regular and irregular operations are noted with timestamps, relevant UAS metrics and 

corrective action procedures (CAP) that are performed. - Note: All irregular behavior have 

root cause analysis performed before UAS operation is resumed.

Emergency Procedures • Loss of Remote Signal

- The flight package features an optional enhanced fail-safe which returns the UAS to 

the home base waypoint via the same path taken to point of lost signal. 

- The UAS will then perform a hover over this waypoint and then a controlled landing. • 

Loss of GPS signal 

- The system will operate in GPS assisted mode with three (3) satellites. - At loss of three (3) 

GPS satellites, manual mode can be activated or the flight package can be

programmed to perform a controlled landing to the home base waypoint. - Ground based 

height ranging is performed by a separate system and so loss of GPS will not impact

controlled landing in a safe manner. • Loss of Engine Power

- In the event of one (1) (or to two oppositely positioned) rotor or motor failure the 

system will enter into controlled spin where all controls are translated based on current 

orientation and will behave as normal operation to the PIC to ensure a safe landing, 

- In the event of multiple rotor or motor failures the flight package can be configured to 

preform a safe landing or attempt operation to home base waypoint. - Note : Behavior 

of the landing location is highly dependent on the position and number of rotors/motors 

that are affected. 

• Loss of Ground Control Software - This will not affect operation of the flight. The unit will 
be piloted to a safe landing area and then

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