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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION OF EXEMPTION OF: 

AEROLENS

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE 

CODE OF FEDERAL REGULATIONS SECTIONS:

CONCERNING COMMERCIAL OPERATION OF THE “DJI INSPIRE 1” UNMANNED 

AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

Submitted: June 7, 2015 

By: TOM CASKA, CEO AEROLENS & MATT DUNN, AEROLENS
 

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GLOSSARY

ATO – Air Traffic Organization

COA – Certificate of Authorization

ESC – Electronic Speed Control

FCC – Federal Communications Commission

UAS – Unmanned Aerial System

NAS – National Air Space

PIC – Pilot in Command

SVFR – Special Visual Flight Rule

VFR – Visual Flight Rule

VMC – Visual Meteorological Conditions

VO – Visual Observer 
 

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TABLE OF CONENTS

I. DESCRIPTION OF PETITIONER p5

II. DESCRIPTION OF PROPOzat OPERATIONS p6

A. Closed-set Filmmaking and Cinematography

B. Aerial Survey & Inspection of Industrial/Construction Sites, Utility Power 

Generation Facilities & Infrastructure

C. Aerial Analysis & Inspection for the Agriculture & Insurance Industry

D. Aerial Imaging for the Real Estate Industry

E. Research and Development

III. RELEVANT STATUTORY AUTHORITY p9

IV. AEROLENS’ PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS 

OF SECTION 333 OF THE REFORM ACT p10

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

Operational Capability

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

Aerolens Operational Manuals

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED p14

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

§91.203(a)(1)

B: 14 C.F.R. §21.191 (a) and (b): Research and Development & Showing 

Compliance 

with Regulations

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

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

Identification Requirements

E. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): 

Maintenance Inspections

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

Privileges and Limitations

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

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

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

Registration

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

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

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

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

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

VI. DRUG AND ALCOHOL PROGRAM p22

VII. PUBLIC INTEREST p23

VIII. PRIVACY p24

IX. FEDERAL REGISTER SUMMARY p25

X. CONCLUSION p26

APPENDIX A. p27

APPENDIX B. p28

APPENDIX C. p29

APPENDIX D. p30
 

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I. DESCRIPTION OF PETITIONER

Based in Australia, Aerolens (Petitioner) is an aerial imaging company dedicated to providing technologically 

driven and innovative solutions to a variety of industries. Its founders, Tom Caska (CEO) and Matt Dunn 

(Chief Remote Pilot) each have wide-ranging experience in the aviation industry. Tom has experience in 

aviation business and holds an Airline Transport Pilot Licence. He has actively flown with an international 

Australian airline for a number of years. Matt is a professional aviation weather observer and has performed 

this role for a period of 8 years with the Australian Government. He has had a hands-on role using remote 

sensing technologies at a number of locations throughout Australia. Tom and Matt are graduates of the 

University of New South Wales and hold Honours Degrees in Aviation (Flying) and Aviation (Management) 

respectively. 

Building upon this extensive and varied aviation experience, Aerolens seeks an exemption to allow 

commercial operations of small UAS to provide aerial photography, video and analysis services across a wide 

range of industries including: 

 Film & Television;

 Real Estate;

 Surveying, Building and Construction;

 Agriculture;

 Insurance;

 Utilities & Power-Generation; and,

 Environmental.

The contact information for Petitioner is as follows:

Tom Caska

CEO Aerolens 

Terrigal, NSW, Australia

Phone: (+61) 422 150 144

Email: tom@aerolens.com.au
 

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II. DESCRIPTION OF PROPOSED OPERATION

Aerolens seeks an exemption pursuant to Section 333 of the Reform Act to operate the DJI Inspire 1 UAS for 

the proposed operations discussed below. All UAS operations will occur under tightly controlled conditions 

on property where Aerolens has received 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 the Aerolens Operational Manuals which are made up of the 

Aerolens Operations Manual, the Aerolens Flight Manual – DJI Inspire 1 and the Aerolens Maintenance 

Manual – DJI Inspire 1.

As detailed in the Aerolens Operational 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 miles away from an airport. The details contained with the Aerolens Operational Manuals incorporate 

redundant safeguards to ensure the aircraft does not travel outside the controlled area of UAS operations, 

including through the use of GPS technologies.

A. Closed-set Filmmaking and Cinematography

Aerolens seeks to use small UAS for the purpose of conducting scripted, closed-set filming for the motion 

picture, television, and web industry. Aerolens has tailored its operations to meet the requirements established 

by the FAA in prior grants of exemption authorizing commercial use of UAS in the motion picture and 

television filmmaking industry, including:

 Astraeus Aerial (Exemption No. 11062)

 Aerial MOB, LLC (Exemption No. 11066)

 Dronair Solutions (Exemption No. 11671)

 Pictorvision, Inc. (Exemption No. 11067)

 HeliVideo Productions, LLC (Exemption No. 11065)

 Snaproll Media, LLC (Exemption No. 11063)

 RC Pro Productions Consulting, LLC d/b/a Vortex Aerial (Exemption No. 11064)

 Flying-Cam, LLC (Exemption No. 11080)

 Aerocine, LLC (Exemption No. 11150)

 Team 5, LLC (Exemption No. 11158)

 Alan D. Purwin (Exemption No. 11161)

 Helinet Aviation Services, LLC (Exemption No. 11160)

 Picture Factory, Inc. (Exemption No. 11178)

All UAS filmmaking operations will occur on private property in a controlled area, away from spectators and 

persons not involved in the filming. In addition, aerial filming will be conducted during daylight, VFR 

conditions and at altitudes below 400' AGL. As set forth below, all Aerolens operations provide an equivalent 

level of safety that is superior to performing the same work using conventional fixed-wing aircraft or 

helicopters.

B. Aerial Survey & Inspection of Industrial/Construction Sites, Utility Power-Generation Facilities and 

Infrastructure

Aerolens seeks to use small UAS for the purpose of conducting aerial imaging for safety monitoring of 

controlled access industrial and construction sites, utility power-generation, transmission and distribution 

facilities, and infrastructure. Traditional methods of inspecting these types of infrastructure, including flare 
 

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stacks, elevated pipelines and power lines, tanks, and steep rooftops, expose inspecting engineers to risk of 

harm or serious injury. Inspectors need to climb tower or otherwise perform work at elevated heights, which 

exposes them to the risk of dangerous falls. In addition to this, depending on the nature of the inspection, 

proximity to equipment often involves a risk of exposure to hazardous chemicals or oxygen-deficient 

atmospheres, burns from steam or hot equipment, and other mechanical hazards associated with industrial 

sites and construction facilities. The use of small UAS mitigates these hazards and enables a much safer 

method of performing these types of inspections.

The use of small UAS for inspection is also safer than traditional manned aircraft performing the same 

function. Conventional operations using rotorcraft and fixed-wing aircraft in low level operations present risks 

associated with vehicles weighing thousands of pounds and carrying large amounts of fuel. Small UAS

inspection is more reliable, and allows for the collection, dissemination, and storage of visual and other 

sensory data with greater precision and duration. Small UAS will also be capable of accessing and inspecting 

areas that would otherwise be inaccessible using conventional aircraft or other inspection methods.

C. Aerial Analysis & Inspection for the Agriculture & Insurance Industries

Aerolens seeks to use small UAS for the purpose of conducting aerial analysis and inspection of sites for the 

agriculture and insurance industries. Aerolens has tailored its operations to meet the requirements established 

by the FAA in prior grants of exemption authorizing commercial use of UAS in insurance industry including: 

 OpenSky Drones (Exemption No. 11691)

 Principia, Inc (Exemption No. 11633)

 AgEagle LLC (Exemption No. 11480)

 T&K LLC (Exemption No. 11619)

 UAV Field Services Inc (Exemption No. 11512)

 HAZON Solutions, LLC (Exemption No. 11487)

 Erie Insurance Group (Exemption No. 11293)

The use of small UAS for aerial analysis and inspections is safer than traditional manned aircraft performing 

the same function at very low altitudes. Conventional operations using rotorcraft and fixed-wing aircraft in 

low level operations present risks associated with vehicles weighing thousands of pounds and carrying large 

amounts of fuel. Small UAS inspection is more reliable, and allows for the collection, dissemination, analysis 

and storage of visual and other sensory data with greater precision and duration. Small UAS will also be 

capable of accessing and inspecting areas that would otherwise be inaccessible or too costly using 

conventional aircraft or other inspection methods.

D. Aerial Imaging for the Real Estate Industry 

Aerolens seeks to use small UAS for the purpose of conducting aerial analysis and inspection of private and 

commercial sites for the real estate industry. Aerolens has tailored its operations to meet the requirements 

established by the FAA in prior grants of exemption authorizing commercial use of UAS in the real estate 

industry. 

The use of small UAS for aerial photography is safer than traditional manned aircraft performing the same 

function. Conventional operations using rotorcraft and fixed-wing aircraft in low level operations present risks 

associated with vehicles weighing thousands of pounds and carrying large amounts of fuel. Aerolens is 

committed to upholding privacy laws and regulations associated with aerial imaging, particularly in suburban 

locations where sensitivities to the use of small UASs exist. 
 

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E. Research and Development

Aerolens seeks to use small UAS for the purpose of furthering its research and development aspirations. As 

part of Aerolens’ vision, the organization is committed to developing innovative ways in which to use current 

technologies for the purposes of enhancing the livelihoods of the general public, widespread communities and 

industries throughout the United States. Research and development using the proposed small UAS will have 

the potential to assist industries including agriculture, emergency response, construction and surveying, 

environmental monitoring and other government agencies. 
 

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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 ("Reform 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 Reform 

Act, the FAA Administrator is to permit unmanned aircraft systems to operate in the National Air Space 

(NAS) where it is safe to do so based on the following considerations:

● 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 the visual line of sight of the operator.

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(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f) (permitting 

exemptions from §§ 44701(a), (b) and §§ 44702 – 44716, et seq.). 

A party requesting an exemption must explain the reasons why the exemption: (1) 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).
 

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IV. AEROLENS'S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 

333 OF THE REFORM ACT

The small UAS operations proposed by Aerolens 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 DJI Inspire 1 due to its size weight, 

speed, and operational capability. 

 The DJI Inspire 1 has been approved for use in prior Section 333 Grants of Exemption from the FAA.

 The DJI Inspire 1 weighs less than 10 pounds, including payload.

 The DJI Inspire 1 will not be flown at a ground speed in excess of 50 knots.

 Altitude information will be generated by equipment on-board 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.

 The UAS will have system redundancies and independent functionality to ensure the overall safety 

and predictability of the system. If connection to the remote control or ground control station is lost, 

failsafe systems will permit the UAS to return to a predetermined location and safely land without 

injury or damage.

 The radio frequencies used for operations and control of the UAS comply with the Federal 

Communications Commission (FCC) and other appropriate government oversight agency 

requirements. The operating frequencies for the DJI Inspire 1 are 2.4 GHz (ground to air) and 5.8 

GHz (ground to ground) for communications. 

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

Manuals

The Aerolens Operational Manuals and the DJI Manufacturer's Manual for the selected 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 Aerolens’ proposed operations, 

below is a summary of operational limitations and conditions that Aerolens will adhere to, and which will 

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

1. The UAS weighs less than 10 pounds, fully loaded.

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

land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight 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 UAS, and one or more Visual Observers (VO) as necessary to safely conduct the mission.

5. PICs shall possess at least a Private Pilot's Certificate and current Class III Medical Certificate. 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.
 

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6. The UAS shall be operated within VLOS of the PIC and VO at all times. The PIC must use human 

vision unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued 

medical certificate.

7. The PIC and VO designated for any operation will be able to communicate verbally at all times.

8. Electronic messaging or texting will not be permitted during flight operations.

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

Operational Manuals. The Operational 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 Aerolens Operational Manuals, the conditions and limitations in the Grant of 

Exemption shall take precedence and must be followed. Otherwise, Aerolens shall follow the

procedures outlined in their Operational Manuals.

10. Aerolens may update or revise its Operational Manuals. Revisions will be tracked and a revised copy 

of the Manual will be provided to the Administrator upon request. Aerolens will also present updated 

and revised Operational 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, Aerolens

will seek an amendment to its Grant of Exemption. Aerolens will contact the FAA’s UAS Integration 

Office (AFS-80) if questions arise regarding updates or revisions to the operating documents.

11. Aerolens Operational Manuals and its Grant of Exemption will be available to the PIC at the ground 

control station anytime the UAS is operating.

12. The PIC is prohibited from beginning a 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 DJI Inspire 1 will be limited to 20

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 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 100 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:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UA and/or debris in the event of an accident. The operator must 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 and/or;

b. The aircraft is operated near vessels, vehicles or structures where the 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, VO, operator trainees or essential persons do not present an 

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

16. The 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.
 

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17. The UAS may not operate within 5 nm of an airport reference point as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that airport’s management is obtained, 

and the operation is conducted in accordance with a NOTAM as required by the Aerolens 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 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. The PIC shall not

operate the UAS if the inspection reveals a condition that affects the safe operation of the UAS until 

the necessary maintenance has been performed and the UAS is found to be in a condition for safe 

flight. The ground control station shall be included in the pre-flight inspection. All maintenance and 

alternations must be properly documented in the UAS records as required by the Aerolens Operational 

Manuals.

19. Aerolens will carry out its maintenance, inspections, and record keeping requirements in accordance 

with the Operational Manuals. Maintenance, inspection, and alterations will be noted in the UAS

records, including total time in service, description of work accomplished, and the signature of the 

authorized person returning the UAS to service.

20. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics (e.g., replacement of a flight critical component) must undergo a functional test flight 

in accordance with the Aerolens Operational 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 UAS record entry shall be included in the Aerolens Operational Manuals.

21. The UAS will be operated and maintained according to the Manufacturer's Manuals and any required 

manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements of the

Aerolens Operational Manuals.

23. Aerolens 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 NOTAM 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 UAS loses communication with the pilot, it will have the capability to return to a predetermined 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 VO.

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

emergencies.

28. All PICs and VOs will have at least a current Class III Medical Certificate.

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 10 hours logged as a UAS pilot with a similar UAS type.

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 54 CFR § 61.51(b), a minimum of 10 hours as 

UAS pilot operating the make and model of the UAS to be utilized for operations under the exemption 

and three take-offs and three landing in the preceding 90 days.
 

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31. Operations shall occur during daytime Visual Meteorological Conditions (VMC); flights under special 

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

32. The 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.).

33. UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

34. The UAS will not be operated from an elevated platform or moving device/vehicle.

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

will comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.
 

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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 § 40101 of the Act, including UAS, 

from its safety regulations and minimum standards when the Administrator decides a requested exemption is 

in the public interest.

Aerolens 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 a 

UAS. Listed below are: (1) 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)(1) 

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 therefore no exemption is needed.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.

Equivalent Level of Safety

Aerolens' use of the DJI Inspire 1 is safe when taking into account its size, weight, speed, and operational 

capability. As set forth in the description of proposed operations in Section IV (A), the DJI Inspire 1 weighs 

less than 10 pounds, including payload and will not be flown at a ground speed in excess of 50 knots. This

UAS is also equipped with safety features that will allow Petitioner to operate the UAS safely after 

experiencing any unexpected in-flight contingencies or failures.

Operations conducted under this exemption will be closely controlled and monitored by the operator and will 

be conducted in compliance with local public safety requirements, to provide security for the area of 

operation. Aerolens 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 DJI Inspire 1 under the proposed conditions will be at 

least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate.

Lastly, the UAS does not need a means to communicate with other aircraft or ATC, because those capabilities 

will be possessed by the PIC and VO, who are not on-board the UAS. In addition, no sense-and-avoid 

technology is necessary for the UAS because it will be operated at all times in VFR conditions and within 

VLOS of the PIC and Operator.

B. 14 C.F.R. §21.191 (a) and (b): Research and Development & Showing Compliance with Regulations

Aerolens seeks an exemption in relation to the research and development requirements contained in 14 C.F.R. 

§21.191 (a) and (b).

 14 C.F.R. §21.191 (a) Research and Development, states:
 

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Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft 

operating techniques, or new uses for aircraft.

 14 C.F.R. §21.191 (b) Showing Compliance with Regulations. states: 

Conducting flight tests and other operations to show compliance with the airworthiness regulations including 

flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate 

major design changes, and flights to show compliance with the function and reliability requirements of the 

regulations.

The experimental certificate can be used for commercial purposes in terms of developing new operating 

techniques to gather aerial imaging.

Equivalent Level of Safety

The UAS will not carry persons, fuel, and all operations will adhere to the flying restrictions and limitations 

referred to previously. All flights will be conducted in accordance with the Aerolens Operational Manuals and 

will require the PIC and VO at all times. The DJI Inspire 1 operated by Aerolens weighs less than 10 pounds 

and is constructed primarily of carbon fibre and plastic. It is therefore proposed that this UAS will be at least 

as safe and most likely safer than a larger commercial fixed-wing aircraft or helicopter performing the same 

aerial operations. 

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

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent that Aerolens’ small UAS would otherwise require certification under Part 

27, Petitioner seeks an exemption from Part 27's deemed unsafe or unnecessary to fly over. The petitioner 

states further that the UAS has built-in intelligent fault handling which allows the DJI Inspire 1 to detect a 

system fault while in the air and automatically fly back to its take-off location and land. Faults that can be 

detected include: loss of communication; exceeding pre-set range 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 flight 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 flight termination link – to prevent a 'fly away' or other potentially dangerous 

situation – is available to the operator.

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

Aerolens 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 
 

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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."10

Equivalent Level of Safety

All UAS flown by Aerolens 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.

E. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections

Aerolens seeks an exemption from the maintenance inspection requirements contained in 14 C.F.R. § 

91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and 

inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 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 UAS to be operated under this grant of exemption will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. 

Further, as required by the Aerolens Operational Manuals, the PIC will conduct a pre-flight inspection of the 

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 UAS and no flights will occur unless, and until, all flight critical components of the 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 the Aerolens Operational Manuals, the PIC who 

conducts the functional test flight will make an entry in the UAS aircraft records of the flight.

Aerolens' Operational Manuals also includes the requirement 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 ESCs), structures & airframe, camera system, electrical systems (including batteries), ground 

control station, hazard accessories, and spare parts. Further, Aerolens' Operational Manuals also includes 

procedures to document and maintain a record of the UAS maintenance, preventative maintenance, 

alterations, the status of replacement /overhaul component parts, and the total time in service of the UAS used

under this Grant of Exemption. As a whole, the maintenance and inspection procedures required in Aerolens’

Operational Manuals ensure that an equivalent or higher level of safety will be achieved.
 

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PILOT-IN-COMMAND OF THE UAS

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

Aerolens 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 UAS will be operated as part of a commercial operation, it carries neither passengers nor 

cargo. In the Grant of Exemption to Astraeus Aerial12, the FAA determined that the unique characteristics of 

UAS operation outside of controlled airspace did not warrant the addition cost and restrictions attendant with 

requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate. The fulfilment of 

the additional requirements for a private pilot to become qualified as a commercial pilot would not lead to any 

additional safety benefits when UAS operations are involved.

Equivalent Level of Safety

The restrictions Aerolens has placed on its UAS operations meet or exceed the restrictions similarly imposed 

on Astraeus Aerial. Aerolens will operate on private property away from persons and property not involved in 

the operation. Aerolens 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 NOTAM will 

also be issued as required by the applicable COA.

In addition to these flight restrictions, Aerolens 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 UAS flight. As set forth in the Operational Manuals, pilots will have experience not only 

in UAS operations generally but have logged flight time in the specific make and model used for the 

operations before they are permitted to participate in commercial flights on behalf of Aerolens. The pilot 

qualification, training, and currency requirements in the Operational Manuals ensure that Aerolens' pilots are 

competent and proficient in the UAS they are operating. Aerolens' 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.

OPERATING PARAMETERS OF THE UAS

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

Inasmuch as there will be no airworthiness certificate issued for the UAS, Aerolens 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. Accordingly, Petitioner requests that the requirements for § 91.7(a) be treated in 

accordance with Section V(A), supra.

H. 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

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness documents and 

other aircraft manuals on-board the aircraft. 
 

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Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft –...

(2) For which an Airplane or Rotorcraft Flight Manual is 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.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

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

(1) 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 UAS, it would be impossible to keep airworthiness documents 

and other aircraft manuals on board the UAS because there is simply no room and the UAS has no cabin or 

cockpit.

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. 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.

I. 14 C.F.R. § 91.103: Pre-flight Action

Aerolens 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 information necessary to safely conduct the flight, an 

exemption is requested to the extent that an FAA-approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Aerolens' Operational 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 Aerolens Operational Manuals, including checklists covering 

Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to review weather, 

flight requirements, battery charge, landing and take-off distance, UAS performance data, and contingency 

landing areas before the initiation of flight. Aerolens' Operational 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.
 

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

Aerolens seeks an exemption from 14 C.F.R. § 91.109(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." UAS and remotely piloted aircraft, by their design, do not have 

functional dual controls. Instead, flight 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. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UAS that Aerolens 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 

Aerolens Operational Manuals, all persons will be a safe distance away in the event that the UAS experiences 

any difficulties during flight instruction. Furthermore, as required by the Aerolens Operational Manuals, all 

flight training will be conducted in a controlled and sterile environment. As a whole, the safety procedures 

provided for in Aerolens’ Operational Manuals ensure that the proposed UAS operations provide an 

equivalent or higher level of safety than that provided by the flight instruction regulations.

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

Aerolens requests an exemption from the minimum safe altitude requirements of 14 C.F.R.

§ 91.119(c). 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, or structure in non-congested 

areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those 

minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided 

that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for 

helicopters by the FAA."

An exemption is required because the proposed UAS operations will normally need to occur below 400 feet 

AGL. In circumstances where the UAS is used to inspect a structure whose height exceeds 400 feet AGL, the 

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 VO(s)

may need to be less than 500 feet away from the UAS.

Relief 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. 

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 UAS, any risk associated with these operations is far less than 

those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given the

size, weight, and speed of the UAS, as well the controlled location where the operations will occur. In order to 

avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL or below, or when 
 

20

inspecting a 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 Operational Manuals, the UAS 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 UAS and any possible debris resulting from UAS failure. As 

required by the Operational Manuals, flights will be terminated if a nonparticipating person within 500 feet of 

the UAS leaves a shielded position. Further, UAS operations will occur at least 500 feet away from vehicles 

or structures unless the property owner/controller 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 VO will not present 

an undue hazard per § 91.119(a). 

It is also noted that in Grant of Exemption No. 11138 (FAA -2014-0481 at 19) that 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. Adherence to the restrictions contained 

in Aerolens' Operational Manuals will ensure all flying operations can be conducted without compromising 

safety.

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

Aerolens 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 the elevation of the departure 

airport or barometric pressure. An exemption is required to the extent that the UAS do not have a barometric 

altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. § 91.121 can be 

achieved in circumstances where: 

(1) the UAS will be operated below 400 feet AGL or below; 

(2) within VLOS;

(3) where GPS based altitude information is relayed in real time to the operator at a ground-based onscreen display and, 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.

The UAS that Aerolens intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by Aerolens' Operational Manuals, the PIC will be required to calibrate 

the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants of Exemption, 

the UAS Aerolens intends to use, and the safety mitigation procedures contained in the Operational Manuals, 
 

21

both ensure that an equivalent level of safety will be achieved, and a Grant of Exemption to the requirements 

of § 191.121 is therefore appropriate.

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

Aerolens 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.

Equivalent Level of Safety

In the Grant of Exemption to Alan Purwin (Exemption No. 11161), 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 DJI S1000 unless (considering wind and forecast weather conditions), there 

was enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% 

battery power remaining. The DJI S1000 is a physically larger sized and heavier UAS when compared to the 

DJI Inspire 1 that Aerolens will be operating. 

Like the DJI S1000, the DJI Inspire 1 used by Aerolens includes a low battery warning system and the amount 

of battery reserve power remaining is transmitted to the PIC via telemetric data feed, which downlinks from 

the UAS to a ground-based-on-screen display and provides an estimated remaining flight time in minutes and 

seconds as well as a percentage of overall battery charge remaining. As required by Aerolens' Operational 

Manuals, the PIC will promptly fly the UAS back to the home launch location or pre-determined abort 

location where the UAS may safely land, while still maintaining a minimum of 25% reserve battery power. 

Aerolens submits that the procedures requiring flights to be safely terminated 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 10 pounds, and within VLOS of the PIC and VO(s), ensure that the proposed 

operation will provide an equivalent or higher level of safety to that provided by the regulations from which 

exemption is sought.
 

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VI. DRUG AND ALCOHOL PROGRAM

Aerolens will have policies in place to ensure that no person may participate in UAS flight operations if they 

are under the influence of alcohol or any drug.
 

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VII. PUBLIC INTEREST

The public interest will be served by granting Aerolens' Petition for Exemption. Congress has established a 

national policy that favours 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 fulfil Congress' goal in 

passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's assessment of whether 

certain UAS may operate safely in the NAS before completion of the statutorily required rulemaking. The 

proposed UAS operations in this Petition for Exemption significantly improve safety and reduce risk harm or 

serious injury to inspecting engineers. Traditional methods of inspecting monitoring industrial and 

construction sites, and utility power-generation facilities and infrastructure requires inspectors to climb towers 

or otherwise perform elevated work, which exposes them to the risk of dangerous falls. Inspectors are often

exposed to hazardous chemicals or oxygen-deficient atmospheres, burns from steam or from hot equipment, 

and other mechanical hazards associated with industrial sites and construction facilities. The use of small UAS

can eliminate these hazards and is ultimately a much safer method of performing these types of inspections.

The use of small UAS also enhances safety and reduces risk because, unlike manned aircraft weighing 

thousands of pounds, carrying crew in addition to flammable fuel, the UAS carry no passengers or crew. 

Further, in the unlikely event of an accident, Aerolens small battery powered UAS presents significantly less 

danger to persons on the ground when compared to operations by conventional manned aircraft. It is noted 

that in the Grant of Exemption No. 11158 the Petitioner identified that manned helicopters performing similar 

aerial filming and imaging functions 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 10 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. The 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. 

As Petitioner's UAS are battery powered, the public will also benefit from a reduction in harmful emissions 

associated with conventional aircraft performing in the same functions proposed herein. Lastly, as recognized 

by the FAA in prior Section 333 Grants of Exemption to filmmakers, UAS provide an additional tool for the 

aerial filming industry, adding a greater degree of flexibility, which supplements the current capabilities 

offered by manned aircraft.22
 

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VIII. PRIVACY

All Aerolens UAS operations will be conducted in accordance with applicable federal, state, and local laws 

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

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

owner/controller or authorized representative will be obtained for each flight to be conducted.
 

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IX. FEDERAL REGISTER SUMMARY

Pursuant to 14 C.F.R. Part 11, 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; 21.191 (a) & (b) Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 

91.109(a); 91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 

(a) & (b).

The exemption will enhance safety by reducing risk to the general public and property owners from the 

substantial hazards associated with performing equivalent film work, aerial inspections, and environmental 

monitoring of industrial sites, transmission and storage facilities, construction facilities and precision aerial 

surveys with conventional fixed-wing aircraft, rotorcraft, or other methods.
 

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X. CONCLUSION

Aerolens' Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of 2012 

including weight, speed, operating capabilities, proximity to airports and populated areas, operation within 

VLOS and national security. The proposed UAS operations will benefit the public as a whole by improving 

safety and reducing risk by alleviating human exposure to danger. In consideration of the foregoing, this 

Petition for Exemption provides the FAA with more than adequate justification for granting the requested 

exemptions allowing Aerolens to use small UAS for: 

(1) scripted, closed-set filming for the motion picture, television, and;

(2) aerial inspection, surveying, environmental monitoring, monitoring of industrial sites,

transmission and storage facilities, construction facilities and precision aerial surveys.

We thank you for your prompt consideration of our requested exemptions. Should you have any questions, or 

if you need any additional information to support the requested exemptions, please contact the undersigned.

Very truly yours,

Tom Caska, 

CEO Aerolens 
 

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APPENDIX A. AEROLENS OPERATIONS MANUAL

(Attached as separate document)
 

28

APPENDIX B. AEROLENS FLIGHT MANUAL: DJI INSPIRE 1

(Attached as separate document)
 

29

APPENDIX C. AEROLENS MAINTENANCE MANUAL

(Attached as separate document)
 

30

APENNDIX D. DJI INSPIRE 1 OPERATIONAL MANUAL

(Attached as separate document)