Documents

• Petition of Exemption

• Acknowledgement Letter

• UAS Flight Log

• UAS Maintenance Test Flight Log

• UAS Maintenance Log

• Copy of Rotary Pilot Certificate
PETITION OF EXEMPTION

for Aerial Photography Solutions

a) Michael John Morris

3603 Luminoso Lane West

Round Rock, TX 78681

(512)550-7040

Mimorr32@yahoo.com

b) Request exemption from part 21, subpart Hand Sections 45.23(b), 61.113(a) and (b),

91.7(a), 91.9(b )(2), 91.1 03(b ), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b),

91.405(a), 91.407(a)(l), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal

Regulations (14 CFR).

c) This exemption would allow Aerial Photography Solutions to operate the Phantom 2 quad copter 

unmanned aircraft system (UAS) to conduct aerial videography and cinematography to develop and 

enhance the marketing campaigns and operations of businesses as well as to provide any civil 

assistance as requested. This exemption would allow Aerial Photography Solutions to enhance

several industries to include: real estate, special events, construction, mining, site surveys, news 

gathering, roofing/chimney inspections, etc. Additionally, it would also allow businesses who would 

otherwise be priced out of aerial photography marketing opportunities to take advantage of this new 

frontier.

The extent of each relief requested will be as follows:

CFR 45.23(b) Display of marks; general

I request the UAS not to be either a certificated aircraft or a certificated "experimental" aircraft. 

Exemption from display of marks is requested due to its size and the airspace that it will operate in.

CFR 61.113(a) and (b) Private pilot privileges and limitations: Pilot in command

As I, Michael John Morris, currently hold a commercial rotarcraft certificate with instruments as well 

as a private single-engine land certificate with a third-class airmen medical certificate and currently a 

UH-60L PIC for the US Army, I understand the importance to be knowledgeable of the National 

Airspace System (NAS). However, I request that a non-certificated pilot be able to operate the UAS 

with direct and written discretion of a certificated pilot with proper ground, operation and airspace 

training that is established by that certificated pilot. This appointed pilot would be tested in aircraft 

operation, maintenance, emergency procedures and the NAS before assuming operation of the UAS. 

A proper training program will be in place with documentation and training logs.

CFR 91.7(a) Civil aircraft airworthiness

Given that the UAS will not require an airworthiness certificate in accordance with 14 CFR part 21, I 

request exemption. Also, there is no FAA regulatory standard for determining the airworthiness of an 

UAS. The manufacturer’s operating documents will be used by the operator to determine if the UAS 

is airworthy.
CFR 91.9(b) (2) Civil aircraft flight manual, marking, and placard requirements

Followed by exemption from CFR 45.23(b). Manufacturer’s operating manual shall be used and kept 

by the operator on location of UAS operations.

CFR 91.103(b) Preflight action

While there is no approved airplane or rotorcraft flight manual available for the UAS, the 

manufacturers operating manual is requested to be used for proper preflight. Runways and airports 

will not be used to deploy or recover the UAS excluding them from the preflight/planning action.

CFR 91.109 Flight introduction; simulated instrument and certain flight tests

Although the UAS does not allow operation with a dual set of controls, proper hands-on training of

UAS operation will be given to any operational pilot by another pilot who has sufficient UAS 

operation hours. Simulated training may be used for sufficient operational training. All pilots will be 

familiar with preflight actions, routine flight operations, and emergency procedures.

CFR 91.119 Minimum safe altitudes: general

Notification of all residing tenets on which property the UAS is intended to operate on will be 

coordinated in advance. Tenets will be aware of the exact time and area that the UAS will be 

operating in.

CFR 91.121 Altimeter settings

The UAS operator will maintain a GPS that will have derived altitude capabilities to report feet AGL. 

Altitudes to be flown will be reported to local ATC before flight.

CFR 91.151(a) Fuel requirements for flight in VFR conditions

The UAS operator will land the UAS prior to the manufacturer's recommended minimum level of 

battery power of 30%. The UAS shows a low voltage warning when 30% battery life is remaining. 

This provides ample time for the UAS operator to land in an immediate safe area. Also, the UAS is 

equipped with an automated function that lands the aircraft immediately when a low battery is 

detected.

CFR 91.203(a) and (b) Civil aircraft: certification required

Operations of the UAS prove to be above safety standards due to its size, weight, speed, and limited 

operating area that it will be operated in.

CFR 91.405(a) Maintenance required

This only applies to aircraft with airworthiness certificates. Maintenance of the UAS will be 

performed by the operator. If a discrepancy is found during pre-flight it will be recorded on a 

"Maintenance Log" for personal history records.
CFR 91.407(a) (l) Operation after maintenance, preventive maintenance, rebuilding,

or alteration

This only applies to aircraft with airworthiness certificates. Maintenance test flights will be 

performed after each maintenance discrepancy is corrected as a safety precaution and recorded on a 

"Maintenance Test Flight Log" for personal history records.

CFR 91.409(a) (l) and (2) Inspections

This only applies to aircraft with airworthiness certificates. Pre-flight will be performed as a safety 

precaution by the operator using the outlined procedures in the operating documents.

CFR 91.417(a) and (b) Maintenance records

This only applies to aircraft with airworthiness certificates. Any maintenance performed on the UAS 

will be recorded on a "Maintenance Log" for personal history records

d) The UAS operations would provide more detailed and adequate information to potential 

individuals, companies looking to relocate to the Central Texas area and promote economic growth 

overall. Also, the aerial videography would allow small business owners a more feasible option for 

marketing and advertisement over the high cost of manned rotary/fixed wing aircraft as in the past. 

Additionally, the UAS operation increases the safety of patrons due to its small size and lack of 

combustible fuel compared to a large manned aircraft and reduces the ambient noise level helping to 

prevent noise complaints. Lastly, the UAS proves to be more ecological by emitting no exhaust 

fumes and requires no fossil fuels for operations.

e) UAS operations will not reduce the safety of other airborne pilots, operating pilots, or patrons that 

are in an area of UAS operation. Conversely, the UAS increases safety as it reduces flight operations 

by rotary wing aircraft flying at low levels while conducting videography operations which are 

conducive to a pilot becoming over task saturated and not recognize other flight dangers forcing them 

into a dangerous situation. Additionally the UAS size, weight, and speed do not pose a threat to the 

public or users of the NAS.

f) (1) Aerial Photography Solutions request exemption from the requirements of part 21, subpart 

Hand Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 

91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, 

Code of Federal Regulations (14 CFR).

 (2) This exemption will permit Aerial Photography Solutions to operate an Unmanned Aircraft 

System (UAS) for the purpose of conducting real estate and business videography and 

cinematography throughout the Central Texas area to provide a more feasible and safer option for 

real estate and small business owners advertising and marketing.

g) Supporting operating documents are attached. 

Michael J. Morris
November 14, 2014

Aerial Photography Solutions 14 November 2015

To whom it may concern,

I am submitting this Petition of Exemption for the purpose of allowing businesses the 

financial ability to use videography and cinematography as a marketing tool for their businesses, 

property, and or house. Also, to showcase land and housing options for newcomers to the Central 

Texas area who may be unfamiliar to its geography. I currently serve in the United States Army as 

UH-60A/L Blackhawk Instructor and Maintenance Test Pilot. I have served in the military for 22

years and as a pilot for the last 16 years. I have over 3100hrs of multi-turbine engine rotary time as 

well 150 hours of fixed wing time. Throughout my years of flying, I am very aware of the demands 

and safety consideration of operating in the National Airspace System.

I write this letter hoping to show that my experience allows us to realize, understand and 

respect the very issues that the FAA is facing with drones for commercial use. Our years of 

experience and knowledge make us more heightened and aware of the obstacles that lie ahead but 

make us respect the process. As an aviation enthusiast, we look forward to developing the UAS into 

the marketing world.

Sincerely,

Michael J. Morris

Aerial Photography Solutions