August 31, 2015

Attention: 

USDOT

Docket Management System

1200 New Jersey Ave. SE

Washington, DC 20590

Petitioner:

Persuasion Interactive Media

Leo Anthony Geis, CTO

2940 S. Goshen Way

Boise, Idaho 83709

208.861.2477

Petition of Persuasion Interactive Media for Exemption Pursuant to Section 333 of the FAA Modernization & 

Reform Act (2012)

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, Persuasion 

Interactive Media, planned operator of Small Unmanned Aircraft Systems (sUAS) equipped to conduct aerial 

remote sensing, photography, and videography, hereby applies for an exemption from the subsequently listed 

Federal Aviation Regulations ("FARs") to allow commercial operation of its sUAS.

Persuasion Interactive Media CTO Leo Anthony Geis is one of approximately 40 Master Aerial Photographers in 

the world and has 14 year of experience in terminal, enroute, and oceanic Air Traffic Control, including positions 

as full-performance controller, supervisor, and training manager. In 2001 Mr. Geis was contracted by the 

Department of Energy/Idaho Nuclear Engineering Laboratory to train its robotics engineers in the construction 

and operation of remote control and robotic helicopters.

All Persuasion Interactive Media sUAS Pilots In Command (PIC) will be rated, current pilots. As enumerated 

below, the requested exemption would permit the operation sUAS under controlled conditions in airspace that is:

1. Predetermined

2. Limited

3. Controlled.

The proposed exemption would allow Persuasion Interactive Media to conduct commercial operations sUAS 

meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333.

Persuasion Interactive Media is a media/technology company that intends to offer various sUAS-based services, 
including Active and Passive Remote Sensing:

• Practice Flights with No Commercial Purposes

• Near-Infrared Photography and Videography

• Thermographic Infrared Photography and Videography

• Ultraviolet Photography and Videography

• Visible Band Photography and Videography

• Audio-Including Sound Pressure Level-Monitoring and Collection

Specific applications of our technology include but are not limited to:

• Real Estate (Commercial and Residential)

• Artistic Applications such as Cinematographic and Photographic Production

• Environmental Monitoring

• Construction Monitoring

• Structural Assays

• Engineering

• LiDAR

• Events

• Emergencies

• Education and Research

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil

UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if

certain unmanned aircraft systems may operate safely in the national airspace system

before completion of the (comprehensive) plan and rule making required by section

332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section

332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited

operation authorization” if several factors are met. Petitioner meets all requirements to

permit FAA approval of commercial UAS operations.

The Petitioner Requests Relief From the Following:

• 14 C.F.R. Part 21

• 14 C.F.R. 45.23 (b)

• 14 C.F.R. 61.113(a) and (b)

• 14 C.F.R. 91.7 (a)

• 14 C.F.R. 91.9 (b) (2)

• 14 C.F.R. 91.109

• 14 C.F.R. 91.119

• 14 C.F.R. 91.121

• 14 C.F.R. 91.151(a)

• 14 C.F.R. 91.203 (a) & (b)

• 14 C.F.R. 91.205 (b)

• 14 C.F.R. 91.215

• 14 C.F.R. (91.401 – 91.417)

Persuasion Interactive Media petitions for exemption specifically to operate DJI Inspire 1 UAS flight platforms and 

imaging using various cameras/imaging devices. The Inspire 1 has a built-in capability to limit the height it flies 
above the ground altitude at takeoff, to limit the radius of the distance it flies from the operator, and to deny 

operations in various airspace classes. The Inspire 1 also has a failsafe autopilot system: when the communication 

between the main controller and the receiver is substantially compromised and the GPS signal is sufficient the 

system will automatically trigger Return To Home (“RTH”) functionality and land the sUAS.

Persuasion Interactive Media will only operate its Inspire 1 sUAS:

• • After successful completion of all maintenance in accordance with the manufacturers 

specifications

• • After a thorough preflight inspection compliant with manufacturer’s instructions

• • During daylight hours

• • In line of sight of the minimum crew: an sUAS Operator and an Observer

• • While Operator and Observer are in constant voice communications

• • So as to not create a hazard to users of the National Airspace System or the public

• • Within parameters specified in either Letter of Agreement or COA when within 5 miles of an 

airport

• • Yielding to other aircraft

• • Within a maximum flight time 20 minutes or at more than 25% of battery power, whichever 

occurs first

• • Limiting flight to 400AGL or no more than 100’ above the highest obstacle within 500’

• • At 50 knots or less

• • Within 500’ of the PIC

• • Never over an open assembly of people

• • Compliant with conditions specified in the FAA’s exemption document

Respectfully,

Leo A. Geis

CTO, Persuasion Interactive Media