September 18, 2015

Mid-South Aerial Photography Solutions, LLC

C. T. Walters, 

3807 Lucy Rd

Millington, TN, 38053

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: EXEMPTION REQUEST SECTION 333 OF THE FAA REFORM ACT OF 2012

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, Mid-South Aerial Photography 

Solutions, LLC (MAPS), requests an exemption from the following sections of Title 14, Code of

Federal Regulations §§ C.F.R. 61.23(a) and (b); 14 C.F.R.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); 91.417(a)&(b) to the extent necessary to allow MAPS to operate a UAS to perform aerial 

data collection as a business as described below.

This exemption will permit MAPS, to provide unmanned aircraft solutions with services for 

state, local, and commercial clients. MAPS is focused on providing solutions for utilizing 

unmanned aircraft for aerial data acquisition, photography and videography in the areas of 

Construction, Agriculture, Infrastructure, Real Estate, events/functions, television, 

cinematography and other applicable areas.

The requested exemption would permit the operation of small unmanned UAS under controlled 

conditions in airspace that is limited, predetermined, controlled access and would provide 

economic and safety enhancements to consumers currently using conventional aircraft. 

Unmanned Aircraft Systems Operated by MAPS:

1. DJI Phantom 2, and DJI Phantom 3 are vertical takeoff and landing aircraft with a Ground 

Control Station utilizing electronic tablet or smart phone systems/control software. Both 

systems have a maximum gross weight of approximately 4 lbs, while having a diameter of 16 

inches, height of 8 inches and maximum speed of approximately 30mph. They are equipped
with four 9 inch main rotors and are powered by Lithium Polymer battery supported electric 

motors. They carry miniature Zen Muse gyro-stabilized gimbal/camera and transmitter 

assemblies providing aerial photo and video capability.

2. DJI S-800 is a vertical takeoff and landing aircraft with a Ground Control Station utilizing

electronic tablet or smart phone systems/control software. The system has a maximum gross 

weight of approximately 16 lbs, while having a diameter of 2 feet 9 inches, height of 1 foot 10

inches and maximum speed of approximately 30mph. It is equipped with six 15 inch main 

rotors and powered by Lithium Polymer battery supported electric motors. It carries a small Zen 

Muse gyro-stabilized gimbal/camera and transmitter assembly providing aerial photo and video 

capability.

3. DJI S-1000 is vertical takeoff and landing aircraft with a Ground Control Station utilizing

electronic tablet or smart phone systems/control software. It has a maximum gross weight of 

approximately 22 lbs, while having a diameter of 3 feet 6 inches, height of 2 feet 1 inch and 

maximum speed of approximately 30mph. It is equipped with eight 15 inch main rotors and is 

powered by Lithium Polymer battery supported electric motors. It can carry small and medium 

sized Zen Muse gyro-stabilized gimbal/camera and transmitter assemblies providing aerial 

photo and video capability.

All UAS operated by MAPS will be operated by a PIC meeting all regulatory requirements for 

licensing and experience who possesses a requisite FAA Air Transport Pilot license (certificate # 

3402461); has an estimated 3500 PIC U.S. Navy helicopter hours; 15 years RC; 4 years of UAS 

experience, and a type rating in the Canadair Regional Jet (CRJ) 200/900. Additionally, all flights 

will be conducted with qualified observer to enhance line of sight operations and general 

safety. MAPS will follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components and follow 

safety protocols established to ensure safe flights. 

MAPS will provide additional information to support this exemption request as needed.

Sincerely,

C. T. Walters, President/MBR

Mid-South Aerial Photography Solutions