FAA Petition for Exception for “Imaging Mapping Technical Professionals, LLC”. 

July 14, 2015

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 and Part 11 of the Federal Aviation 

Regulations

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 C.F.R. Part 11, “Imaging, Mapping & Technical Professionals, LLC”, here after referred

to as IMTP, LLC being the operator of small Unmanned Aircraft Systems (UAS), seeks an 

exemption from the Federal Aviation Regulations (“FARs”) listed below and discussed in 

supplement attachment. 

The requested exemption would permit commercial operation of IMTP, LLC’s small UAS(s) 

which weigh less than 55 lbs., for the purposes of aerial imaging, inspection, surveying and 

mapping. 

These aerial systems acquire a series of high quality digital images and/or video for reference 

and measurement applications, and as such reduce the need for conventional aircraft. This has 

the additional benefit of reducing environmental impact as well as lowering operational 

expenses for our customer base (e.g., real estate imaging, site inspection, environmental 

assessments, geo-spatial data acquisition etc.).

IMTP, LLC’s proposed operations (under the exemption) will adhere to exacting requirements,

under strictly visual flight rules (VFR) and/or condition(s). It will insure an equivalent level of 

safety to that of any currently authorized manned aircraft under modification by the FAA’s 

Section 333.

The requested exemption would permit commercial imaging and remote sensing operations 

through off-the-shelf, professional aerial platforms from DJI (www.dji.com) and 3D Robotics 

(3drobotics.com).

These small unmanned aerial system’s will be operated in strict adherence to all manufactures 

operational parameters and following all proposed part 107 provisions for small UAS.

IMTP, LLC’s will utilize operators who have passed an FAA approved ground school, possess 

an existing pilot certificate (e.g., Sport Pilot, Recreational Pilot, Private Pilot, Commercial, etc...)

and have completed training on the UAS being operated.
These small unmanned aerial systems possess automated control features, and will be within 

visual sight of the respective operator in Class G airspace; unless otherwise approved in 

advance by the FAA.

With the before mentioned in mind, IMTP, LLC respectfully submits that small unmanned aerial 

vehicles from DJI (www.dji.com) and 3D Robotics (3drobotics.com) could be used in lieu of 

comparatively hazardous conventional platforms and/or systems. 

IMTP, LLC believes that by approving the requested exemptions enhanced safety would be 

achieved, with additional economic benefits to the general public.

IMTP, LLC further believes that said approval would fulfill the Secretary of Transportation’s and 

FAA Administrator’s responsibilities under Section 333(c) of the Reform Act to “establish 

requirements for the safe operation of such aircraft systems in the national airspace system.”

IMTP, LLC’s current mailing address & contact information is as follows:

Imaging, Mapping & Technical Professionals, LLC

Attn: Laura Malta

Address: 209 Osborn Avenue, Point Pleasant Borough, NJ 08742-2225

Phone: 732-267-1434

Email: lbmalta@imtprofessionalsllc.com

The regulations from which the exemption is requested are as follows: 

 14 C.F.R. Part 21

 14 C.F.R. 45.23(b)

 14 C.F.R. 61.113(a) & (b)

 14 C.F.R. 61.133(a)

 14 C.F.R. 91.7(b)

 14 C.F.R. 91.9(b)(2)

 14 C.F.R. 91.109(a)

 14 C.F.R. 91.119

 14 C.F.R. 91.121

 14 C.F.R. 91.151(a)

 14 C.F.R. 91.203(a) & (b)

 14 C.F.R. 91.405(a)

 14 C.F.R. 91.407(a)(1)

 14 C.F.R. 91.409(a)(2)

 14 C.F.R. 91.417(a) & (b)

Very truly yours, 

Laura Malta, President & CFO

Dr. Raymond A. Birchler Jr. GISP, CTO 

Cc: Supplement Attachment: Exemptions Requested
Supplement Attachment- Part 1

IMTP, LLC seeks exceptions similar to the excerpts here-after cited (“APPLICABLE LEGAL 

STANDARD UNDER SECTION 333“) and modified in passages from Aerial Pros LLC

Exemption No. 11416 of (Blairstown NJ 07825).

At the time of this writing IMTP, LLC is aware of approximately thirteen existing exceptions 

granted in our operating area for similar purposes. They are as follows:

 Aerial_Media_Systems11297.pdf Lakes NJ 07417

 Aerial_Pros_LLC_11416.pdf Blairstown NJ 07825

 Air-Mods_Flight_Training_Center_Inc_11273.pdf Robbinsville NJ 08691

 Anderson_Rojas-Photography-11708.pdf Califon NJ 07830

 Fovea-Aero-Systems-LLC-11659.pdf Medford, NJ 08055

 Keystone_Aerial_Survey_11472.pdf PA

 Lauchit_Technologies_11411.pdf Rumson NJ 07760 & Haven NJ 07704

 Next-Generation_Aviation_Services_LLC_11311.pdf Ridgewood NJ 07450 & Park NJ 

07035

 Nixon_Engineering_Solutions_LLC_11252.pdf Ft Monmouth

 Principia_Inc_11633.pdf Parsippany NJ 07054 & Orange NJ 07079

 The_Aerial_Filming_Company_11362.pdf & Summit NJ 07902

 Unmanned_Aerial_Solutions_11445.pdf Waldwick NJ 07463

 Unmanned_Sensing_Systems_LLC_11356.pdf 

Unmanned_Sensing_Systems_LLC_11499.pdf Laurel NJ 08054
Supplement Attachment- Part 2

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 (as initial submitted via Aerial 

Pros LLC & modified via IMTP, LLC)

IMTP, LLC “submits that grant of this exemption application for use of the proposed UAS's in 

aerial imaging will advance the Congressional mandate in Section 333 of the Reform Act to 

accelerate the introduction of UASs into the national airspace system (“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 UASs do not create a hazard to users of the NAS or 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 operator”.

“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.’ Id. §333(c) ‘’Applicant submits that this 

provision places a duty on the Administrator to not only process applications for exemptions 

under Section 333, but for the Administrator, if he deems the conditions proposed herein require 

modification in order to allow approval, to supply conditions for the safe operation of the UAS. 

IMTP, LLC too “welcomes the opportunity to consult with FAA staff in order to address any 

issues or concerns that this proposal may raise that they believe may require modification”. 

“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 

44702-44716 of this title if the Administrator finds the exemption is in the public interest”

“49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1). 

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 transitioning to UASs 

for aerial inspections and survey photography. Accordingly, the applicant respectfully requests 

that the FAA grant the requested exemption without delay. “

Airworthiness of the UAS

“A critical element of the exemption application involves evidence of the airworthiness of the 

UAS. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 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 UAS. Our small UAS's will operate at low speed in a controlled 

environment, at least five miles from an airport and more than three miles from any city or 

densely populated area. 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 helicopter) 

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

Mandatory Operating Conditions 

Grant of the exemption to IMTP, LLC will be subject to the following mandatory conditions, 

which are based upon operating conditions set forth for operation of UAS by public entities 

pursuant to Certificates of Authorization, with additional restrictions: 

 All operations to occur in Class G airspace.

 Operations to be conducted over private or controlled-access property.

 Permission from land owner/controller required before commencing any flight.

 Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

 Aircraft to remain within Visual Line of Sight (VLOS).

o VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical

miles (NM). 

o Cylinder walls may be expanded by observer with ability to control aircraft.

 Operations to occur during daylight hours. 

 Aircraft to remain within Visual Line of Sight (VLOS). 

o VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical 

miles (NM). 

o Cylinder walls may be expanded by observer with ability to control aircraft.

 Above Ground Level (AGL) altitude to be restricted to 400 feet.

 All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline

azimuth of runway centerline measured from runway thresholds. 

 All required permissions and permits will be obtained from territorial, state, county or city, 

jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies. 

Operator Requirements

IMTP, LLC respectfully proposes that operator requirements should take into account the 

characteristics of the particular UAS. Certain UASs, such as the DJI Inspire and DJI S1000, are 

characterized by a high degree of control and various built-in technical capabilities that limit the 

potential for operation outside of the operating conditions set forth above. Please see details in 

the attached O&M manuals. Additional automated safety functions and safety enhancing 

features of the UAS's include the following: 

 Auto-pilot detection of lost GPS or of insufficient satellites initiates an immediate return 

to aircraft take-off location ("home")

 Low power on the aircraft triggers escalating alarms at GCS at 35% and 10%levels.

 If the auto-pilot detects a lost-link to the GCS for longer than 30 seconds, landing

procedure begins. 
Given these safety features; IMTP, LLC proposes that operators of the UAS should not be 

required a specific pilot certificate. Instead, operators should be required to: 

 “have successfully completed, at a minimum, FAA private pilot ground school 

instruction and passed a FAA written examination or FAA-recognized equivalents”; 

 “have completed the sUAS training or a minimum of 40 hours training program for 

operation of the UAS's”.

 Either a FAA medical or state issued driver license.

IMTP, LLC “notes that the FAA has found that safety factors permitted operation of UASs by 

operators with these qualifications in the case of operations pursuant to public COAs when 

the mandatory operating conditions specified above were present. See Federal Aviation 

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational 

Approval, at 20-21 (July 30, 2013). The FAA has the statutory authority to grant exemptions 

to the requirements for and privileges associated with the grant of airmen’s certificates. 49 

USC §44701 (f).”

IMTP, LLC seeks an exemption from the FARs set forth above and in this Supplement 

Attachment “to allow commercial operations of a UAS's conducting” aerial imaging, 

inspection, surveying and mapping. 

“Approval of the exemption allowing commercial operations of the UAS for” aerial imaging, 

inspection, surveying and mapping work “will enhance safety by reducing risk. 

Conventional aerial inspection and survey operations, using jet or piston-powered aircraft 

present risks associated with vehicles that weigh in the neighborhood of 5,000 to 7,000 lbs., 

or more, carry large quantities of fuel, passengers, and, in some cases, cargo. Such aircraft 

must fly to and from the survey location. Other conventional manned climbing or manned 

lifts risk safety hazards associated with falls, electrical hazards, fuel related hazards, and 

inhalation hazards associated with the structures being inspected. In contrast, a UAS

weighing less than 55 lbs. and powered by batteries eliminates a portion of that risk given 

the reduced mass and lack of combustible fuel carried on board a manned aircraft and the 

lack of risks associated with manned lifts or manned climbing apparatus. The UAS will carry 

no passengers or crew and, therefore, will not expose any individuals to the risks associated 

with manned aircraft flights, manned lifts or climbing hazards. Additionally, no national 

security issue is raised by the grant of the requested exemptions. Given the size, load 

carrying capacity, speed at which it operates, and the fact that it carries no explosives or 

other dangerous materials, the UAS poses no threat to national security”.

“The operation of the UAS, weighing less than 55 lbs., for” aerial imaging, inspection, 

surveying and mapping work “in accordance with the strict conditions outlined above, will 

provide an equivalent level of safety supporting the grant of the exemptions requested 

herein, including exempting” IMTP, LLC “from the requirements of Part 21”. 

“The UAS’s satisfaction of the criteria set forth in Section 333 of the Reform Act—size, 

weight, speed, operating capabilities, lack of proximity to airports and populated areas, 

operation within visual line of sight, and national security—and its showing of an equivalent 

level of safety as it may relate to the requirement for FAA training, provide more than 

adequate justification for the grant of the requested exemptions allowing commercial 

operation of the UAS in the commercial” aerial imaging, inspection, surveying and 

mapping work. 
Supplement Attachment- Part 4

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY UNDER APPLICABLE 

RULES SUBJECT TO EXEMPTION 

IMTP, LLC “requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the UAS's”: 

14 C.F.R. § 45.23(b): Marking of the Aircraft 

“The regulation provides: 

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. 

The UAS's has no entrance to the cabin, cockpit, or pilot station on which the word 

“Experimental” can be placed. Given the size of the UAS, two-inch lettering will be 

impossible. The word “Experimental” will be placed on the forward fuselage in 

compliance with §45.29(f). The equivalent level of safety will be achieved by having the 

UAS marked on its forward fuselage as required by § 45.29(f) where the pilot, observer, 

and others working with the UAV will see the identification of the UAS as “Experimental.”

The FAA has issued the following exemptions to this regulation to Aerial Pros, 

Exemption No. 10700, and to others, including Exemption Nos. 8738, 10167 and 

10167A”. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

14 CFR § 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 with the aircraft to be utilized by” IMTP, 

LLC, “an exemption from Part 21 Subpart H meets the requirements of an equivalent 

level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation 

Act (49 U.S.C.§44701 (f)) and Section 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 UAS. Our small UAS's will be operated at low speed in a 

controlled environment; at least five miles from an airport” with a control tower or 3 miles 

from instrument approach or 2 miles, from other airports or heliports. “ An analysis of 

these criteria demonstrates that the UAS's 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 helicopter) operating with an 

airworthiness certificate without the restrictions and conditions proposed.”
“The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured area. Like other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by the operator, pursuant to the 

Manual's requirements, and under the requirements and in compliance with local public 

safety requirements, to provide security for the area of operation as is currently done on 

active construction sites. The FAA will have advance notice of all operations. These 

safety enhancements, which already apply to civil aircraft operated in connection with 

construction sites, power plant sites and the like provide a greater degree of safety to the 

public and property owners than conventional 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 credible threat to national security posed by the 

UAS, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and ability to carry an external load no greater than 

two lbs.”

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

Command; Commercial Pilot Privileges and Limitations. 

“Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the UAS in this case is 

remotely controlled with no passengers or property of others on board. Section 

61.133(a) requires an individual with a commercial pilot’s license to be pilot in command 

of an aircraft for compensation or hire.” IMTP, LLC “respectfully proposes that operator 

requirements should take into account the characteristics of the particular UAS”. IMTP, 

LLC “UAS has a high degree of control and various built-in technical capabilities that 

strictly limit the potential for operation outside of the operating conditions set forth in the 

exemption application”. 

“The UAS have {sic} navigation and control system comprised of a Ground Control 

Station (GCS) and auto-pilot system. All flights utilize precision GPS guidance. In the 

case of unplanned events, the operator inputs evasive maneuvers from the control unit, 

and the control unit executes that maneuver. Operator interventions include diversion to 

the right; initiation of holding at present position; suspension of mission; fly back to 

launch point; fly to point and hold; abort mission and land; and emergency power cut off 

and land (Flight Termination System). Given these safety features”. IMTP, LLC

“proposes that operators of the UAS should not be required to hold a commercial or 

private pilot certification. Instead, operators should be required to: have successfully 

completed, at a minimum, FAA approved ground instruction and passed the FAA written 

examination or FAA-recognized equivalents; have completed a UAS training program or 

a minimum 40 hours training program for operation of the UAS”. IMTP, LLC “notes that 

the FAA has found that safety factors permitted operation of UASs by operators with 

these qualifications in the case of operations pursuant to public COAs where the 

mandatory operating conditions specified above are present. See Federal Aviation 

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational 

Approval, at 20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 

U.S.C.§44701(f) to waive the pilot requirements for commercial operations”. Given 

these conditions and restrictions, an equivalent level of safety will be provided by 

allowing operation of the UAS without a {sic} commercial pilot’s certificate, under the 

conditions set forth herein. The risks associated with the operation of the UAS (given its 

size, speed, operational capabilities, and lack of combustible fuel) are so diminished 
from the level of risk associated with private pilot operations or commercial operations 

contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing 

operations of the UAS as set forth above meets or exceeds the present level of safety 

provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a 

commercial pilot to operate the aircraft under §61.133(a).”

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

“This regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. Should the exemption be granted allowing commercial operation of 

the UAS without an airworthiness certificate, no standard will exist for airworthiness of 

the UAS. Given the size of the aircraft and the requirements that have presumably 

already been met for the UAS (for instance, the UAS’s Operations and Maintenance {sic}

Manual and Safety Manual and Checklist), an equivalent level of safety will be achieved 

by insuring compliance with the “IMTP, LLC “manuals prior to each flight”

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

“The regulation provides: No person may operate a U.S.-registered civil aircraft ... 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. 

(2) Given the size and configuration of the UAS, it 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”.

“The equivalent level of safety will be achieved by keeping the flight manual (see, e.g., 

User Guide, Exhibit 4) at the ground control point where the pilot flying the UAS will have 

immediate access to it. The FAA has issued to others the following exemptions to this 

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

10167A, 10602, 32827, and 10700”. 

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction 

“These regulations provide 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. The UAS is a remotely piloted aircraft and by design, does 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. If instruction is 

accomplished through a training program, as set forth in Exhibit 2, an equivalent level of 

safety will be assured. 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 will be 

achieved by the manufacturer providing the training as outlined, for example, in Exhibit 2 

and through the use of experienced and qualified pilots familiar with the UX5.”
14 CFR § 91.119: Minimum Safe Altitudes 

“Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 

91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 

feet above the surface, except over open water or sparsely populated areas. In those 

cases, the aircraft may not be operated closer than 500 feet to any person, vessel, 

vehicle, or structure. As set forth herein, the UAS will never operate at higher than 400 

feet AGL. It will, however, be operated to avoid congestion. Because aerial survey work 

must be accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, 

an exemption from Section 91.119(c) is needed”.

“The equivalent level of safety will be achieved given the size, weight, speed, and material 

with which the UAS's are built. Also, no flight will be taken without the permission of the land 

owner or those who control the land. Because of the advance notice to the landowner, all 

affected individuals will be aware of” aerial imaging, inspection, surveying and mapping

flights. Compared to “aerial imaging, inspection, surveying and mapping work ”

operations conducted with aircraft or rotorcraft weighing far more than 55 lbs. and carrying 

flammable fuel, any risk associated with these operations will be far less than those currently 

allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the lowaltitude operations of the UAS will maintain separation between these small-UAS operations 

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

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 UAS batteries provide approximately 15-40 minutes of 

powered flight. Without an exemption from § 14 CFR 91.151, the UAS’s flights would be 

limited to approximately 20 minutes in length. Given the limitations on its proposed 

operations and the location of those proposed operations, a longer time frame for flight 

in daylight VFR conditions is reasonable. IMTP, LLC also “believes that an exemption 

from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See 

Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance 

with 91.151(a)). Operating the small UAS, without 30 minutes of reserve fuel does not 

engender the type of risks that Section 91.151(a) was meant to prevent given the size 

and speed at which the UAS operates. The fact that it carries no pilot, passenger, or 

cargo also enhances its safety. Additionally, limiting UAS flights to 20 minutes would 

greatly reduce their utility. In the unlikely event that the UAS should run out of fuel, it 

would simply land. Given its weight and construction material, the risks are less than 

contemplated by the current regulation”. IMTP, LLC also “believes that an equivalent 

level of safety can be achieved by maintaining 5 minutes of reserve fuel, which, would 

be more than adequate to return the UAS to its planned landing zone from anywhere in 

its operating area”.
14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

“This regulation provides as follows: 

(a) . . . no person may operate a civil aircraft unless it has . . . 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 UAS's fully loaded weighs no more than 55 lbs. As such, there is no ability or place 

to carry certification and registration documents or to display them on the UAS. In 

addition, there is no pilot on board the aircraft. An equivalent level of safety will be 

achieved by keeping these documents at the ground control point where the pilot flying 

the UAS will have immediate access to them. 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.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections 

“Section 91.405(a) requires 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 . . . .” Section 91.407 similarly makes reference to 

requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the 

issuance of an air worthiness certificate. Section 91.417(a) requires the owner or 

operator to keep records showing certain maintenance work that has been accomplished 

by certificated mechanics, under Part 43, or licensed pilots and records of approval of 

the aircraft for return to service. Maintenance of the UAS's will be accomplished by the 

owner/operator pursuant to the manual. An equivalent level of safety will be achieved 

because the UAS is small in size, will carry no external payload, will operate only in 

restricted predetermined areas and is not a complex mechanical devise. As provided in 

the attached Maintenance Manual and the Safety Checklist, the operator of UAS will 

ensure that the UAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance that is performed. Moreover, the 

operator is the person most familiar with the aircraft and is best suited to maintain the 

aircraft in an airworthy condition and to ensure an equivalent level of safety.

SUMMARY OF SECTION 333 EXEMPTION REQUEST 

IMTP, LLC “hereby provides pursuant to Part 11 a summary of its exemption application to 

allow commercial operation of: DJI & 3D Robotics sUAS for aerial imaging, inspection, 

surveying and mapping work.

“An exemption is requested from the following regulations: 

14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 

14 C.F.R. 91.7(b); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 

C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 

C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a) & (b).”