Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Petition of Spectrum Aerial & Photography Services for an Exemption Pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 

Director: Flight Standards Service: 

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

I 4 C.F.R. Part I I, Spectrum Aerial & Photography Services ("Spectrum Aerial") hereby applies 

for an exemption from the Federal Aviation Regulations ("FARs") identified below to allow 

commercial operation of small unmanned aerial vehicles (i.e., "small unmanned aircraft" or 

"UAS") for the purpose of conducting aerial photography, videography, property mapping, and 

inspection for the real estate industry. 

This petition for exemption is made based on information outlined in this Petition for Exemption, 

as well as the accompanying Spectrum Aerial documents; 

I. PIC Flight Operations Manual and; 

2. Operations Manuals 

(Collectively 2 and 3 are referred to as Documents & Manuals") 

3. User Guide and; 

4. Flight Manual' 

(Collectively 3 and 4 are referred to as "Manufacturer's Manuals"). 

Spectrum Aerial submits these supporting materials as confidential documents pursuant to 14 

C.F.R. § 11.35(b), as the materials contain confidential commercial and/or proprietary 

information that Spectrum Aerial has not and will not share with other requesting parties. 

Additionally, these documents contain operating conditions and procedures that are not generally 

available to the public and are protected from release under the Freedom of Information Act, 5 

U.S.C. § 552 et. seq. 

For your convenience, this Petition is organized as follows: 

I. Description of Petitioner 

1

• The tenn "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not limited 

to: operations and flight manuals, user guides, component maintenance manuals, pilot training manuals, service 

information letters and, safety/service bulletins. 
Vl. 

VII. 

VIII. 

IX. 

X. 

I. 

IV. Spectrum Aerial

s Proposed UAS Operations Meet the Requirements of 

Section 333 of the Reform Act 

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and 

Operational Capability 

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the 

Operations Manuals 

V. Regulations From Which Exemption is Requested 

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 

91.203(a)( I) 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and 

Identification Requirement~ 

D. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2); 91.417(a) and (b): 

Maintenance Inspections 

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot 

Privileges and Limitations 

F. 14 C.F.R. § 91 .7(a): Civil Aircraft Airworthiness 

G. 14 C.F.R. § 91 .9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and 

Registration 

H. 14 C.F.R. § 91.103: PrenightAction 

I. 14 C.F.R. § 91.109(a): Flight Instruction 

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes 

K. 14 C.F.R. § 91.121: Altimeter Settings 

L. 14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions 

Drug and Alcohol Program 

Public Interest 

Privacy 

Federal Register Summary 

Conclusion 

DESCRIPTION OF PETITIONER 

Spectrum Aerial is based in Plantation, FL, working in photography and videography services 
Upon the grant of the 333 Exemption the Company

s business will specialize in real estate 

photography and vidcography of residential, commercial and industrial properties for the 

promotion of properties for sale and land development and additionally will offer services for 

property mapping and inspection. 

Spectrum Aerial's staff are well trained and experienced in providing support as visual observers 

("YO") for the pilot in command ("PIC") in addition to any other needed on site assistance. 

All of the equipment owned by Spectrum Aerial is of the highest quality gear and has been able 

to provide these services safely and without any cJaims or incident. Spectrum Aerial's goal is to 

advise the perspective client that Spectrum Aerial is following all the applicable state and federal 

rules to ensure the safety of the public while providing the client with a competitive and cost 

effective product. 

Spectrum Aerial seeks an exemption to allow for photography, videography and other related 

media products. 

The contact information for Petitioner is as follows: 

Eric L. lgualada 

Spectrum Aerial & Photography Services 

6815 NW 1ih St. 

Plantation, FL 33313 

Phone: 954.868.9066: Email: Ericigualada@gmail.com 

II. DESCRIPTION OF PROPOSED OPERATION 

Spectrum Aerial seeks an exemption pursuant to Section 333 of the Reform Act to operate the 

DJI F550 and DJJ Spreadingwing S-800 (referred to as SA-UAS) (under 551bs) for the proposed 

operations discussed herein below. All UAS operations will occur under tightly controlled 

conditions on private property or approved location where Spectrum Aerial has received 

verifiable permission to operate from the landowner, controller or authorized representative. The 

proposed UAS operations will be conducted in accordance with the conditions and limitations of 

this Petition for Exemption and Spectrum Aerial's Operations Manuals. As detailed in Spectrum 

Aerial's Operations Manuals, all UAS operations will be limited to daytime VFR conditions, 

within visual line-of-sight ("VLOS") of the operator, in uncontrolled airspace, and will occur at 

least 5 mm away from an airport reference point. Moreover, Spectrum Aerial's Operations 

Manuals incorporate redundant safeguards to assure the aircraft does not travel outside the 

controlled area of UAS operations, including GPS "geo-fencing" technologies. 

A. Aerial Photography, Videography, Property Mapping and Inspection 
• Trudeau, Realtor® (Exemption No. 11138) 

• Alon Sicherman (Exemption No. 11728) 

• Sokoler Medly (Exemption No. 11341) 

All UAS photography and videography operations will occur on private property or approved location in a controlled area away from spectators and persons not involved in the recording 

process. In addition, the tilming will be conducted between dawn and dusk to ensure maximum 

safety for the public and those involved in the manipulation and operation of the UAS; VFR 

conditions, at altitudes below 400' above ground level ("AGL"). 

As set forth below, Spectrum Aerial's operations provide an equivalent level of safety which is 

superior to performing the same work using conventional fixed-wing aircraft or helicopters. 

Small UAS video production is also safer than traditional manned aircraft performing the same 

function. Videographer-inspectors also frequently need to climb roof tops, trees, or otherwise 

perform elevated work, which exposes them to the risk of dangerous falls, electrocution or 

other work related injuries. In addition, depending on the nature of the video needed and 

inspection, proximity to equipment, and other mechanical hazards associated with industrial 

sites and construction facilities often involves a risk of exposure to hazardous conditions. The 

use of SA-UAS mitigates these hazards and is ultimately a much safer and cost efficient 

method of perfonning these and most other types of inspections. 

Moreover, conventional operations using rotorcraft and tixed-wing aircraft in low level 

operations present risks associated with vehicles weighing tens of thousands of pounds 

(including payload) and carrying large amounts of fuel which inherently presents significant fire 

hazards as well as exposure to other chemical contaminates. It is important to note the use of 

small UAS in this area will not only be safer and more cost effective to the perspective user or 

purchaser of the service, but the quality and expanse of acquired infonnation will be far more 

robust given the low cost associated with its acquisition and other potential consumers an 

inexpensive product. 

UAS video production is more reliable, and allows for the collection, dissemination, and storage 

of visual and other sensory data with greater precision and duration at a very low cost. Small 

UASs will also be capable of accessing and inspecting areas that would otherwise be inaccessible 

or highly dangerous using conventional aircraft or other inspection methods. 

III. RELEVANT STATUTORY AUTHORITY 

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the 

FAA Modernization and Reform Act of 2012 ("Refonn Act"). Congress has directed the FAA 

"to safely accelerate the integration of civil unmanned aircraft systems into the national airspace 

system." Pursuant to Section 333 of the Refonn Act. the FAA Administrator is to pennit 
Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest See 49 U.S.C. § 106(t) (defining the authority of the 

Administrator)~ 49 U.S.C. § 4470l(t) (permitting exemptions from§§ 4470l(a), (b) and 

§§ 44702- 44716, et seq.). A party requesting an exemption must explain the reasons why the 

exemption: (I) would benefit the public as a whole, and (2) would not adversely affect safety (or 

how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 

(petitions for exemption). 

IV. SPECTRUM AERIAL'S PROPOSED SA-UAS OPERATIONS MEET THE 

REQUIREMENTS OF SECTION 333 OF THE REFORM ACT 

The small SA-UAS operations proposed by Spectrum Aerial as noted above in this Petition for 

Exemption qualify for expedited approval pursuant to Section 333 of the Reform Act as each of 

the statutory criteria and relevant factors are satisfied. 

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and 

Operational Capability 

A Grant of Exemption is appropriate for operations conducted using the UASs due to their size 

weight, speed, and operational capability. 

• The SA-UAS utilized by Spectrum Aerial has been approved for use in prior 

Section 333 Grants of Exemption from the FAA.2 

• The SA-UAS weighs less than 55 pounds, including payload 

• The SA-UAS will not be flown at a ground speed in excess of 50 knots. The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 50 knot speed restriction. 

• Altitude information will be generated by equipment onboard the UAS as 

specified using GPS triangulation, digitally encoded barometric altimeter, radio 

altimeter, or any combination thereof. This information will be transmitted to the pilot 

via telemetric data feed. 

2See e.g., Grant of Exemption to Trudeau, Realtor® (Exemption No. 11138 ); Grant of Exemption to Alon 

Sic herman (Exemption No. 11728); Grant of Exemption to Sokoler Medly (Exemption No. 11341 ). 
with the Federal Communications Commission (

FCC

) and other appropriate 

government oversight agency requirements. The operating frequency for the SA-UAS 

is 2.4 GHz frequency bands. 

If the same operations were conducted using a helicopter, the aircraft's take-off weight would 

likely exceed 6,000 pounds depending on payload. The difference in weight between the SAUAS and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surrounding property in the event of an unintended accident or 

incident. In addition, the risk to the onboard pilot and camera operator is eliminated. 

B. Approval is Warranted Based on the Operational Restrictions Set Forth in 

Spectrum Aerial's Operations Manuals 

Spectrum Aerial's Operations Manuals and the Manufacturer's Manual for the selected SA-UAS 

will contain all the procedures and limitations necessary to safely and successfully perform the 

operations specified in this Petition for Exemption. To assist the FAA in making a safety 

assessment of Spectrum Aerial's proposed operations, below is a summary of operational 

limitations and conditions that Spectrum Aerial will adhere to, and which will ensure an 

equivalent or higher level of safety to operations conducted under current regulatory guidelines: 

I. The SA-UAS weighs Jess than 55 pounds, with payload. 

2. All operations shall be conducted over private or controlled-access property with 

verifiable permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be obtained 

for each scheduled flight prior to operation. 

3. All UAS operated under the Grant of Exemption will 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 will be as large as 

practicable. 

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot-in 

Command ("PIC") of the SA-UAS, and one or more Visual Observers ("Observer") as 

necessary to safely conduct the mission. 

5. PICs shall possess either a 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 will also meet the flight review 

requirements specified in 14 C.F.R 61.56 in an aircraft in which the PIC is rated on 

his or her pilot certificate. 
8. Electronic messaging or texting will not be permitted during night operations. 

9. The additional requirements identified in the Grant of Exemption shall be added to 

the Spectrum Aerial's Operations Manuals. The Operations Manuals will be 

maintained and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations in the Grant of Exemption and Spectrum 

Aerial's Operations Manuals, the conditions and limitations in the Grant of 

Exemption shall take precedence and must be followed. Otherwise, Spectrum Aerial 

shall follow the procedures outlined in their Operations Manuals. 

I 0. Spectrum Aerial may update or revise its Operations Manuals. Revisions will be 

tracked and a revised copy of the Manual will be provided to the Administrator upon 

requesL Spectrum Aerial will also present an updated and revised Operations 

Manuals if it petitions for extension or amendment to its Grant of Exemption. If an 

update or revision would affect the basis upon which the FAA grants the exemption, 

Spectrum Aerial will seek an amendment to its Grant of Exemption. Spectrum Aerial 

will contact the FAA's UAS Integration Office (AFS-80) if questions arise regarding 

updates or revisions to the operating documents. 

II. Spectrum Aerial Operations Manuals and its Grant of Exemption will be available to 

the PIC at the ground control station anytime the SA-UAS is operating. 

12. The PIC is prohibited from beginning a SA-UAS flight unless (considering wind and 

forecast weather conditions) there is enough power to fly to the first intended point of 

landing, and assuming normal cruising speed, to fly after that for at least 10 minutes. 

13. Maximum total flight time for each operational flight using the SA-UAS will be 

limited to 40 minutes or the amount of time the UAS can be flown and still maintain a 

reserve battery power of no less than 25%, whichever occurs first. 

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never 

enter navigable controlled airspace without timely prior written authorization and 

approval from the FAA. In the event the structure being inspected exceeds 400 feet 

AGL, the UAS will not be operated more than I 00 feet above the highest point on the 

structure, and no more than 50 feet horizontally from the structure. 

15. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons. (persons other than the PIC, VO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 
owner/controller of such vessels, vehicles or structures has granted permission 

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, and; 

c. Operations nearer to the PIC, YO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a). 

16. The SA-UAS 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. 

I 7. The SA-UAS may not operate within 5 nm of an airport reference point as denoted on 

a current FAA-published aeronautical chart unless a letter of agreement with that 

airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the Spectrum Aerial COA. The letter of agreement with the 

airport management will be made available to the Administrator upon request. 

18. Prior to each flight the PIC shall inspect the SA-UAS to confirm that it is in a 

condition safe for flight. The pre-flight inspection will account for all discrepancies, 

e.g. inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents as well as equipment updates. The PIC shall not 

operate any SA-UAS if the inspection reveals a condition that affects the safe 

operation of the SA-UAS until the necessary maintenance has been performed and the 

SA-UAS is found to be in a condition for safe flight. The ground control station shall 

be included in the preflight inspection. All maintenance and alternations must be 

properly documented in the UAS's records as required by Spectrum Aerial's 

Operations Manuals. 

19. Spectrum Aerial will timely carry out its maintenance, inspections, and record 

keeping requirements in accordance with the Operations Manuals. Maintenance, 

inspection, and alterations will be fully noted in the SA-UAS records, including total 

time in service, description of work accomplished, date completed and the signature 

of the authorized person returning the SA-UAS to service. 

20. Any SA-UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics (e.g., replacement of a flight critical component) 

must timely undergo a functional test flight in accordance with Spectrum Aerial's 

Operations Manuals. The PIC who conducts the functional test flight must make an 

entry in the UAS aircraft records of the flight. The requirements and procedures for a 

functional test flight and SA-UAS record entry shall be included in the Spectrum 

Aerial's Operations Manuals. 
3. Spectrum Aerial will obtain an Air Traffic Organization (

ATO

) issued Certificate of 

Waiver or Authorization, otherwise known as a COA, prior to conducting any 

operations under this Grant of Exemption. A NOT AM will be issued as required by 

the COA. All operations will be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements. 

24. 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. 

25. If the SA-UAS loses communication with the PIC, it will have the capability to safely 

return to a pre-determined location within the operational area and land safely. 

26. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the PIC and the Observer. 

27. The SA-UAS will have the capability to safely abort flight in the case of unpredicted 

obstacles or emergencies. 

28. PICs and Observers will have at least a current Class Ill Medical Certificate or a valid 

and current U.S. driver's license issued by a state. 

29. Prior to conducting operations for filming, the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR § 61.51 (b), a minimum of 200 flight cycles and 

25 hours total time as a UAS rotorcraft pilot and at least I 0 hours logged as a UAS 

pilot with a similar SA-UAS type platform. This requirement can be achieved by 

flights conducted and logged as a hobbyist. 

30. Prior to conducting operations for filming, the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR § 61.51 (b), a minimum of hours pursuant to 14 

CFR § 61.51(b) as UAS pilot operating the make and model of SA-UAS to be utilized 

for operations under the exemption and three take-offs and three landing in the 

preceding 90 days. 

31. Operations shall occur during daytime VFR Meteorological Conditions; flights under 

special visual flight rules ("SVFR") shall not be conducted. 

32. The SA-UAS shall remain clear and yield the right of way to all other manned 

operations and activities at all times (including, but not limited to, ultralight vehicles, 

parachute activities, parasailing activities, hang gliders, etc.). 
any film

flight operations while in motion from atop any elevated platform vehicle or 

device. 

35. Before conducting operations, the radio frequency spectrum used for operation and 

control of the SA-UAS will comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements. 

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 

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§ 

40 I 0 I of the Act, including UASs, from its safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interesl.3 

Spectrum Aerial seeks an exemption from several interrelated provisions of Title 14 of the Code 

of Federal Regulations (" 14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the 

requested operations using SA-UAS platforms noted above. Listed below are: (I) the specific 

sections of 14 C.F.R for which exemption is sought, and (2) the operating procedures and 

safeguards that Petitioner has established which will ensure a level of safety better than or equal 

to the rules from which exemption is sought:' 

UNMANNED AIRCRAFT SYSTEM 

A. 14 C.F.R. Part 21, Subpart H -Airworthiness Certificates and 14 C.F.R. 

§91.203(a)( I) 

The FAA has stated that no exemption is needed from this section if a finding is made under the 

Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met and in point of fact 

exceeded, and therefore no exemption is needed. 5 If, however, the FAA determines that there 

are some characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, 

an exemption is requested. 

349 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed pursuant to Sections 44701(a) and (b) and Sections 44702- 44716). ~ 14 C.F.R § 11.81 (e), which requires a petition for exemption to include: The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which you seek exemption. 

5See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22). 
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contingencies or failures as noted below.6 7 

Additionally, the SA-UAS carries neither pilots nor passengers, carries no explosive materials or 

flammable liquid fuels, or other elements identified by Homeland Security as being prohibitive 

and operate exclusively within the parameters stated in Spectrum Aerial's Operations Manuals. 

Operations conducted under this exemption will be closely controlled and monitored by the PIC operator and will be conducted in compliance with local public safety requirements, to provide 

security for the area of operation. Spectrum Aerial will also provide the FAA with advance notice 

of all operations via NOTAMs as required by the applicable COA. In all cases, operation of the 

SA-UAS under the proposed conditions will be at least as safe as, or safer than, conventional 

rotorcraft operating with an airworthiness certificate. Lastly, the SA-UAS do not need a means to 

communicate with other aircraft or ATC, because those capabilities will be solely possessed by 

the PIC and Observer, who are not onboard the SA-UAS.8 In addition, no sense-and-avoid 

technology is necessary for the SA-UASs because they will be operated at all times in VFR 

conditions and within VLOS of the PIC and Operator.9 

6See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-20 14-0803 at pg. 3 ): "The [DJI S I 000] 

has the capability to operate safely after experiencing certain in-flight contingencies or failures and uses an autopilot system to maintain UAS stability and control. The UAS is also able to respond to a loss of global positioning 

system (GPS) or a lost-link event with a pre-coordinated, predictable, automated flight maneuver, and manual flight 

control functionality as a backup. These safety features provide an equivalent level of safety compared to a manned 

aircraft performing a similar operation." 

7See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): The SA-UAS can be 

operated entirely by a touch-screen, map-based interface. This means the operator only needs to command the 

system where to go, and the system does all the flying for the operator. The SA-UAS can be operated in both semi 

and fully autonomous flight modes, with the operator simply clicking on a map to create a pre-planned flight path 

for a tlight. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system 

cannot enter areas deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS has built-in 

intelligent fault handling which allows the SA-UAS to detect a system fault while in the air and automatically fly 

back to its takeoff location and land. Faults that can be detected include: loss of communication; exceeding pre-set 

wind thresholds; and low battery levels. 

All flight operations are global positioning system (GPS) controlled, making the system easy to navigate. At any 

point if the operator is not explicitly commanding the system to move, the system automatically holds its GPS 

position. The tlight control system employs not only GPS positioning but a variety of sensors including sonar, 

barometric pressure, temperature, wind speed and others to ensure stability so long as wind thresholds are not 

exceeded. Also a !light termination link -to prevent a 'fly away' or other potentially dangerous situation- is 

available to the operator." 

8See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13). 
Subpart H, supra. 

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements 

Spectrum Aerial seeks an exemption from the aircraft marking and identification requirements 

contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 

• 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard 

requirements, provides that: 

No person may operate a U.S.-registered civil aircraft unless that aircraft 

is identified in accordance with Part 45 of this chapter. 

• 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

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. 

• 14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally 

on both surfaces of the cabin, fuselage, boom, or tail the marks required by 

§ 45.23. 

In a previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft "have identification (N-Number) markings in 

accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable."w 

Equivalent Level of Safety 

All SA-VAS flown by Spectrum Aerial will bear N-number markings that are as large as 

practicable in accordance with 14 C.F.R. Part 45, Subpart C. 11 

10. FAA Docket No. FAA-2014-0352. 

IlSee, e.g., FAA Docket No. FAA-2014-0352, at 14. 
91.405(a) (stating that each owner or operator of an aircraft 

[s]hall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ... have discrepancies 

repaired as prescribed in part 43 of this chapter"). An exemption from these regulations is needed 

because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which 

the VAS platforms to be operated under this grant of exemption. will not have. (Emphasis added) 

Equivalent Level of Safety 

An equivalent level of safety will be achieved or exceeded because maintenance and inspections 

will be timely performed in accordance with the Manufacturer's Manual and any required 

manufacturer Safety or Service Bulletins. Further, as required by Spectrum Aerial's Operations 

Manuals, the PIC wilt conduct a pre-flight inspection of the SA-UAS and all associated 

equipment to account for all discrepancies and/or inoperable components. Maintenance will be 

performed and verified to address any conditions potentially affecting safe operation of the SAUAS and no flights will occur unless, and until, all flight critical components of the SA-UAS 

have been found to be airworthy and in a condition safe for operation. A functional test flight will 

be conducted following the replacement of any flight-critical components. As required by 

Spectrum Aerial's Operations Manuals, the PIC who conducts the functional test flight will make 

an entry in the SA-UAS aircraft records of the flight. 

Spectrum Aerial's Operations Manual also includes requirements to follow the manufacturer's 

UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit 

requirements for the following applicable components: powertrain system (powerplant), 

propellers, avionics and control surfaces (including aHerons/elevons), structures & airframe, 

camera system, electricaJ systems (including batteries), ground control station, hazard 

accessories, and spare parts. Further, Spectrum Aerial's Operations Manuals also include 

procedures to document and maintain a record of the SA-UAS's maintenance, preventative 

maintenance, alterations, status of replacement/overhaul component parts, and the total time in 

service of the SA-UAS used under this Grant of Exemption. As a whole, the maintenance and 

inspection procedures required in Spectrum Aerial's Operations Manuals ensure that an 

equivalent or higher level of safety will be achieved. 

PILOT-IN-COMMAND OF THE UAS 

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations 

Spectrum Aerial seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate 

holders from flying aircraft for compensation or hire, and would also require a second class 

medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC 

matches the airspace in which the PIC will be operating, as well as requiring certifications if the 

private pilot is carrying passengers or cargo for hire. In this case, while the SA-UASs will be 

operated as part of a commercial operation, they carry neither passengers nor cargo. In the Grant 
Equivalent Level of Safety 

The restrictions Spectrum Aerial has placed on its SA-UAS operations meet or exceed the 

restrictions similarly imposed on Astraeus Aerial. Spectrum Aerial will operate on private 

property or approved location away from persons and property not involved in the operation. 

Spectrum Aerial will also obtain an ATO issued COA prior to conducting any operations under 

this Grant of Exemption. All operations will be conducted in accordance with airspace 

requirements in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements. A NOT AM will also be issued as required by the applicable COA. 

In addition to these flight restrictions, Spectrum Aerial will further ensure safe operation by 

requiring that any PIC be thoroughly versed not only in airspace and communication issues 

pertaining to all aircraft operators but also in the unique aspects of SA-UAS flight. As set forth 

in the Operations Manuals, pilots will have experience not only in SA-UAS operations generally but have logged flight time in the specific make and model used for the operations before they 

are pennitted to participate in commercial flights on behalf of Spectrum Aerial. The pilot 

qualification. training, and currency requirements in the Operations Manuals ensure that 

Spectrum Aerial pilots are competent and proficient in the SA-UAS they are operating. Spectrum Aerial's training and qualification requirements are consistent with those contained in prior FAA 

Section 333 Grants of Exemption, and will provide a higher level of competency and proficiency for its pilots and will ensure at least an equivalent level of safety to the public. 

OPERATING PARAMETERS OF THE UAS 

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Inasmuch as there will be no airworthiness certificate issued for the UASs, Spectrum Aerial 

seeks an exemption from 14 C.F.R. § 91 . 7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is required for 14 C.F.R. § 

91. 7(a) to the extent that the requirements of Part 21 are waived or found inapplicable. n 

Accordingly, Petitioner requests that the requirements for§ 91.7(a) be treated in accordance with 

Section V (A), supra. 

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

§ 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 

12Exemption No. 11062 (FAA Docket No. FAA-2014-0352). 

uSee ld. at 13-14, 22. 
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. 

Pursuant to 14 C.F.R. § 9 I .203(a) and (b): 

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has 

within it the following: 

(I) 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. 

Given the small size and configuration of the SA-UAS, it would be impossible to keep 

airworthiness documents and other aircraft manuals on board the SA-UAS because there is 

simply no room and the SA-UAS has no cabin or cockpit. As a way to comply with the code 

Spectrum Aerial will maintain the documents with the PIC and make them available for 

inspection. 

Equivalent Level of Safety 

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 

91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS flight 

manual, registration certificate, and other required documents from the ground control station 

from which he or she is operating the aircraft. 14 As this FAA Office of Chief Counsel Opinion 

clarifies, the intent of the rule is to ensure the pilot has access to these key documents during 

flight. Therefore, an equivalent level of safety will be achieved by ensuring that the pilot has 

access to the documents at the ground control station from which he or she is piloting the UAS. 

H. 14 C.F.R. § 91.103: Preflight Action 

Spectrum Aerial seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become 

familiar with specific information before each flight, including information contained in the 

FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all 

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and Regulation, 

to John Duncan, FAA Right Standards Service (Aug. 8, 2014); see also Docket No. FAA-2014-0352 at 16-18. 
Manuals and the Manufacturer

s Manual. The PIC will perform a series of checklists designed to 

identify any defects or inoperable components in accordance with the Spectrum Aerial's 

Operations Manuals, including checklists covering Pre-Flight, Launch, Landing, and Post-Flight 

procedures. The PIC will also be required to review weather, tlight requirements, battery charge, 

landing and takeoff distance, UA performance data, and contingency landing areas-before 

initiation of flight. Spectrum Aerial's Operations Manuals and the Manufacturer's Manual will be 

kept at the ground control station and will be accessible to the PIC at all times while operating 

the UAS. 

I. 14 C.F.R. § 91.109(a): Flight Instruction 

Spectrum Aerial seeks an exemption from 14 C.F.R. § 91.1 09(a), which provides in pertinent part 

that "[n]o 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." UASs and remotely 

piloted aircraft, by their design, do not have functional dual controls. Instead, night control is 

accomplished through the use of a device that communicates with the aircraft via radio 

communications. Accordingly, an exemption will be required for the flight instruction 

requirements of 14 C.F.R. § 91 .1 09(a). 

Equivalent Level of Safety 

Given the size and speed of the UASs that Spectrum Aerial intends to use, an equivalent level of 

safe training can still be performed without dual controls because no pilot or passengers are 

aboard the UAS, and as required by the Spectrum Aerial's Operations Manuals, all persons will 

be a safe distance away in the event that the UAS experiences any difficulties during flight 

instruction. Moreover, as required by the Spectrum Aerial's Operations Manuals, all flight 

training wil1 be conducted in controlled and sterile environment. As a whole, the safety 

procedures provided for in Spectrum Aerial's Operations Manuals ensure that the proposed UAS 

operations provide an equivalent or higher level of safety than that provided by the night 

instruction regulations. 

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes 

Spectrum Aerial requests an exemption from the minimum safe altitude requirements of 14 

C.F.R. § 9 I .119(c). 15 Section 91.119 prescribes the minimum safe altitudes under which aircraft 

may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, 

1sRelief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency landing 

without undue hazard to persons or property on the ground in the event of a failure. Petitioner's proposed UAS 

operations will not occur over congested areas, and therefore an exemption from § 91. 119(b) will not be necessary. 

See e.g., Grant of Exemption No. 11157 to Slugwear, Inc., dba Like on a tree Aerial (FAA-2014-0534 at 15). 
height exceeds 400 feet AGL, the SA

UAS will not be operated more than 100 feet above the 

highest point on the structure, and within 50 feet horizontally of the structure. Additionally, due 

the nature of the proposed operations, the Pilot and/or Observers(s) may need to be less than 500 

feet away from the SA-UAS. 

Equivalent Level of Safety 

Compared to flight operations with rotorcraft weighing far more than the maximum weights 

proposed herein, and given the lack of flammable fuel with the above noted UASs, any risk 

associated with these operations is far less than those which presently exist with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the 

SA-UASs, as well as the controlled location where the operations will occur. In order to avoid 

any risk to manned aircraft, !light operations will be restricted to 400 feet AGL or below, or 

when inspecting a U.S. structure whose height exceeds 400 feet AGL, within 100 feet above the 

highest point on that structure and 50 feet horizontally of the structure. 

As set forth in the Operations Manuals, the SA-UASs will be operated in a restricted area, and all 

flights will be operated at a lateral distance of at least 500 feet from any nonparticipating 

persons, unless that person is in a position where he or she is shielded from the SA-UAS and any possible debris resulting from its failure. As required by the Operations Manuals, flights will be 

terminated if a nonparticipating person within 500 feet of the SA-UAS leaves a shielded 

position. Further, its operations will occur at least 500 feet away from vehicles or structures 

unless the property owner/controller timely has granted permission and the PIC has made a 

safety assessment of the risk of operating closer to those objects and, operations near the PIC or 

Observer will not present an undue hazard per § 91.119(a). Adherence to these restrictions in 

Spectrum Aerial's Operations Manuals will ensure operations can be conducted without 

compromising public safety. 16 

K. 14 C.F.R. § 91.121: Altimeter Settings 

Spectrum Aerial seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating 

an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to 

111See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19): "If barriers or structures are 

present that can sufficiently protect nonparticipating persons from the UA or debris in the event of an accident, then 

the UA may operate closer than 500 feet to persons afforded such protection. The operator must also 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. When considering how 

to immediately cease operations, the primary concern is the safety of those nonparticipating persons. In addition, the 

FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the 

owner/controller of any such vessels, vehicles or structures grants permission for the operation and the PIC makes a 

safety assessment of the risk of operating closer to those objects and determines that it does not present an undue 

hazard." 
can be achieved in circumstances where: (I) the UAS will be operated below 400 feet AGL or bclow17, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the operator at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude initiation point is established for the PIC to confirm accuracy of the on board GPS. 18 

The SA-UAS that Spectrum Aerial intends to use for the proposed operations will meet all these operational characteristics. Moreover, as required by Spectrum Aerial's Operations Manuals, the PIC will be required to calibrate the aircraft's GPS compass prior to each night operation. Like prior FAA Section 333 Grants of Exemption, the SA-UAS Spectrum Aerial intends to use, and the safety mitigation procedures contained in the Operations Manuals, both ensure that an equivalent level of satety or greater level will be achieved, and a Grant of Exemption to the requirements of § 191.121 is therefore appropriate. 

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Spectrum Aerial requests an exemption from 14 C.F.R. § 91.151 (a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: 

(a) No person may begin 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. 

Here, the technological limitations on UAS battery power means that no meaningful flight operations can be conducted while still maintaining a 30-minute battery reserve. An exemption from the fuel requirements of 14 C.F.R. § 91. 151 (a) is therefore required. Moreover, it is not Spectrum Aerial's intention to fly the SA-UASs at night. 

Equivalent Level of Safety 

In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by prohibiting the PIC from beginning a SA-UAS flight unless (considering wind and forecast weather conditions) there was enough power to fly to the first intended point of landing and, 

17If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than l 00 feet above the highest point on the structure. 

'HSee Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at21 ). 
safely land the

SA

UAS as soon as possible. Like the VDOS Grant of Exemption, Spectrum 

Aerial's use of the SA-UAS, combined with the requirements of Petitioner's Operations Manuals, 

ensure that an equivalent level of safety can be achieved and in fact exceeded. 

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. I I I 61 ), the FAA 

determined that an equivalent level of safety to the fuel requirements for flight in VFR conditions 

could be achieved by prohibiting the PIC from beginning a flight with the UA unless 

(considering wind and forecast weather conditions), there was enough power to safely fly at 

normal cruising speed to the intended landing point and land the UA with 25% battery power 

remaining. Spectrum Aerial will adhere to this limitation for its SA-UAS flights. 

The SA-UAS includes a low battery warning system and the amount of battery reserve power 

remaining is continuously transmitted to the PIC via telemetric data feed, which downlinks from 

the SA-UAS to a ground-based-on-screen display.20 As required by Spectrum Aerial's 

Operations Manuals, the PIC will promptly tly the SA-UAS back to the home launch location or 

pre-determined abort location where it may safely land, while still maintaining a minimum of 

25% reserve battery power. Spectrum Aerial submits that the procedures requiring flights to be 

safely tenninated once the batteries fall below 25% capacity, combined with the requirement that 

flights only be conducted within a secure, isolated area, using a UAS weighing less than 55 

pounds, and within VLOS of the PIC and Observer(s), ensure that the proposed operation will 

provide an equivalent or higher level of safety to the public to that provided by the regulations 

from which exemption is sought. 

VI. DRUG AND ALCOHOL PROGRAM 

Spectrum Aerial will have policies in place to ensure that no person may participate in SA-UAS 

flight operations if they are under the influence of alcohol or any drug. 

VII. PUBLIC INTEREST 

The public interest will be served by granting Spectrum Aerial's Petition for Exemption. 

Congress has established a national policy that favors early integration of UAS into the NAS in 

controlled, safe working environments such as those proposed in this Petition. Granting this 

Petition for Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) of the 

19. Grant of Exemption No. 11112to VDOS Global, LLC (FAA-2014-0382 at 10). 

20. The SA-UAS ground control station displays the UAS's position, navigation route, tail number, altitude, 

heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and 

orientation relative to the UAS. 
properties, staff of Petitioner, unsuspecting passersby, inspecting engineers from relevant organizations and all those who may be in the local vicinity. Traditional methods of inspecting and monitoring potential locations and relevant sites and facilities requires location personnel to climb towers, trees, venture onto precarious roofs and other dangerous scenarios, perform elevated work for which the individual is neither trained nor equipped to perform, which 

exposes them to unnecessary risk of serious physical injury from dangerous falls or other physical mishaps. Moreover, inspectors/surveyors are often unnecessarily exposed to hazardous conditions, unsafe environments, culturally tense situations and other hazards associated with 

identifying specific locations for potential recording sites to be used in the end product. The use of small UAS can eliminate these hazards and ultimately create a much safer method of 

performing these types of inspections creating a sater environment for the public as well 

as 

Spectrum Aerial employees. 

The use of small UAS also enhances safety and reduces risk to the surrounding public because, unlike manned aircraft weighing thousands of pounds, carrying crew in addition to flammable 

fuel, the UAS carry no passengers, crew or explosive fuel. Furthermore, in the unlikely event of 

an accident, Spectrum Aerial's small battery powered SA-UAS presents significantly Jess danger to persons on the ground when compared to operations by conventional manned aircraft.21 As 

Petitioner's SA-UAS are battery powered, the public will also benefit from a reduction in 

harmful petroleum based emissions associated with conventional aircraft performing in the same functions proposed herein. Air quality will naturally be improved with the reduction of fuel 

powered vehicles. 

Lastly, as recognized by the FAA in prior Section 333 Grants of Exemption to filmmakers, UAS provide an additional economic tool for the aerial filming notwithstanding the industry, adding a greater degree of flexibility, which supplements the current capabilities offered by manned aircraft.22 The quality of the finished product is enhanced and provides a greater finished product demand which will aid the current UAS industry and provide additional jobs as the cost of providing the needed product is greatly reduc

ed while reducing the difficulty with which the finished product is created. The demand for the current industrial product is increasing and will continue to increase given the enhanced flexibility of production; therefore, given the lower cost, 

21See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): "Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner's UAs will 

weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the aircraft. The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals or property in the event of an incident or accident. Risk to an onboard pilot and crew during an incident or accident is eliminated with the 

use of a UA for the aerial filming operation." 

22See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-20 14-0794 at 18). 
g

g p

y

p

p

property with permission from the land owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will be obtained for each night to be 

conducted. 

IX. FEDERAL REGISTER SUMMARY 

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

FEDERAL REGISTER, should it be determined that publication is needed: Petitioner seeks an 

exemption from the following rules in Title 14 of the Code of Federal Regulations: 

Part 21, Subpart H; Part 27; 45.23(b ); 45.27(a); 61.113; 91.7(a); 91.9(b )(2); 91.9(c ); 

91.103; 9l.l09(a); 91.119(c); 91.121; 91.15l(a); 91.203 (a) & (b); 91.405(a); 91.407(a) (I); 91.409(a) (I) & (2); 91.417 (a) & (b). 

The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general 

public, property owners and city structures from the substantial hazards associated with 

performing equivalent film work and aerial video production with conventional fixed-wing 

aircraft, rotorcraft, or other methods. 

X. CONCLUSION 

Spectrum Aerial's Petition for Exemption satisfies the criteria articulated in Section 333 of the 

Reform Act of 2012 which includes weight; speed; operating capabilities; proximity to airports 

and populated areas; operation within VLOS and national security. The proposed SA-UAS 

operations will benefit the public as a whole by improving safety and reducing risk by alleviating 

human exposure to danger while lowering the attendant related costs thereby increasing the 

demand for the finished product. In consideration of the foregoing, this Petition for Exemption 

provides the FAA with more than adequate justification for granting the requested exemptions 

allowing Spectrum Aerial to use small SA-UAS sin the recorded production of its product. 

We thank you for your prompt consideration of our requested exemptions. 

Eric L. Igualada 

Spectrum & Photography Services 

6815 NW 121h St. 

Plantation, FL 33313 

Phone: 954.868.9066: Email: Ericigualada@gmail.com 
I. General Operations Manual 

2. PIC Operating Manual 

3. Company Protocols 

4. Location Protocols 

5. Flight Communications Protocols 

6. Departing Location Protocols 

7. Transmitter Protocols 

8. Preflight Checklist 

9. Post Flight Checklist 

I 0. Equipment Checklist 

II . UAS Manufacturer's Manuals 

a. User Manuals 

b. UAS Maintenance Manuals