Lili Hemmel 

80 Fawnridge Dr. 

Long Valley, NJ 07853 

908-303-9771 

lhemmel@hotmail.com 

July 14th, 2015 

Dear Exemption Manager, 

I am submitting my Petition for Exemption for Unmanned Aircraft Systems operations. Lili 

Hemmel, is currently an UAS pilot with over 25 flight hours on the DJI Phantom Vision 2+. 

Ms. Hemmel takes the skills and education for the safe operation of UAS, very seriously. 

Ms. Hemmel’s focus is always on safety whenever flying these craft. 

Lili Hemmel’s request is for a waiver of the sections identified below in an effort to operate 

a UAS strictly and only for Aerial photography. 

In reference to the FAA announcement: 

http://www.faa.gov/news/updates/?newsId=82485

This announcement references the FAA’s experience in reviewing Section 333 petitions. 

These generally fall into two categories; film/television production and aerial data collection 

and that most of the exemption requests in these categories will likely be handled through 

the new summary grant process. 

Please note that many similar requests have been granted by the FAA including 

exemptions 11969, 11971, 11945, 11954, & 11959. These requests are all for Real Estate/

Aerial photography using the exact same UAS - the DJI Phantom Vision 2, the most 

commonly used UAS craft today.

With a solid understanding of FAA rules, and an awareness of National airspace, Lili 

Hemmel believes she should be granted an exemption. 

Ms. Hemmel’s request for a waiver of the section is not for operations for the purpose of 

“closed-set motion picture and television filming”, but rather her request is to operate a 

UAS for commercial purposes, specifically, for aerial photography. 

Ms. Lili Hemmel currently seeks exemption from:

Section of 14 CFR: parts 21 Subpart H, 27, 45.23(b), 45.27(a), 61.113(a) and (b), 

61.133(a), 91.7(a), 91.9(b)(2), 91.103, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) 

and (b), 91.319(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). If any other 

relevant section has been erroneously omitted or overstated for the intended operations, 

please feel free to suggest the missing or overstated section(s). 
 

Suggested Public Federal Register Summary: 

“The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS) 

under the new FAA “Summary Grant” approach, announced April 9th, 2015 http://

www.faa.gov/news/updates/?newsId=82485 that will help speed up Section 333 exemption 

approvals for many commercial UAS operators prior to finalizing the small UAS proposed 

rules. 

It is my understanding that the FAA will still individually review each Section 333 petition. 

However, it is hoped that the agency will accept this particular petition, and include it in the 

next summary grant, and issue an exemption on the presumption that the FAA has 

“already granted a previous exemption similar to this request”. 

The new interim policy includes the granting of a Certificate of Waiver or Authorization 

(COA) for flights at or below 200 feet to any UAS operator with a Section 333 exemption 

for aircraft that weigh less than 55 pounds, operate during daytime Visual Flight Rules 

(VFR) conditions, operate within visual line of sight (VLOS) of the pilots, and stay certain 

distances away from airports or heliports such as 5 nautical miles (NM) from an airport 

having an operational control tower; or 3 NM from an airport with a published instrument 

flight procedure, but not an operational tower; or 2 NM from an airport without a published 

instrument flight procedure or an operational tower; or 2 NM from a heliport with a 

published instrument flight procedure. It is also understood that the “blanket” 200- foot 

COA allows flights anywhere in the country except restricted airspace and other areas, 

such as major cities, where the FAA prohibits UAS operations. Ms. Hemmel plans to 

operate her small UAS at or below 200’ AGL, and comply with all rules and regulations. 

UAS Description: 

Lili Hemmel asking for an exemption for a UAS up to 55 pounds because she will be using 

a craft that will be flown operationally, weighing less than 5 pounds and more specifically a 

DJI Phantom Vision 2+. 

In the event a loss of communications occurs the Phantom Vision 2+ automatically returns 

to a pre-determined home point. Control may be regained in flight and the pilot can take 

over safe operations again if communication is reestablished. In the case of a GPS failure 

the craft will be able to be manually flown to a safe landing by the pilot. The UAS operates 

electrically, carries no flammable fuel, has an integrated GPS pilot system, provides 

location information along with height AGL, speed, battery life, has programmed no-fly 

zones for controlled airports, and provides direction of travel distance from the pilot. 

Additional Points: 

It is my hope that you find that the enhanced safety achieved using an unmanned aircraft 

with the specifications described by the petitioner which carries no passengers or crew, 

rather than a manned aircraft of significantly greater proportions, carrying crew in addition 

to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this 

exemption is in the public interest. 
 

Flight Operations: 

Ms. Hemmel is well aware of conducting safe flight operations and planning flight paths 

that minimize any overflight of crowds. Flights will end when battery reserve reaches 25 

percent. Preflight and post-flight checklists and UAS examinations will help detect any 

abnormalities prior to flight and after flight. Any UAS unable to satisfy safety checklists will 

be removed from service until the issue can be resolved. 

Granting this request would not adversely affect safety since operations would be in 

accordance with current UAS rules. 

Section 333 Compliance and Appropriateness: 

Based on the size of the craft, experience of the pilot, and operational goals, this request 

appears to be well suited for approval using the current criteria outlined in Section 333 of 

the FAA Modernization and Reform Act of 2012 (including new interim policies) 

Sincerely, 

Lili Hemmel 

80 Fawnridge Dr. 

Long Valley, NJ 07853 

908-303-9771 

lhemmel@hotmail.com