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Docket Operations, M-30 , 

U.S. Department of Transportation Docket Management SystenL 

1200 New jersey Avenue SE 

Room Wl2··140 

West Building Ground Floor 

Washington, D.C. 20590 

Aerial Images and Inspections 

44 Blackburn Road 

New Hill, North Carolina 2756:2 

Re: r;;xemption Request for Section 333 of the FAA f.~eform Act and Part 11 of the 

Federal Aviation Regulations f:·om 14 C.F.R. 91.7 (a), 14 C.F.R. 91.9 (b) (2), 1.4 C.F.R. 

91.103, 14 C.F.R 91.119,14 C.F.R. 91.121,14 C.F.R. 91.405 (a), 14 C.F.R. 91.407 

(a)(l), 14 C.F.R 91.4·09 (a)(1)&(2), 14 C.F.R. 91.41·;· (a)&(b), 14 C.F.R. § L~5.23 (b). 

To Whorn ft May Concern 

This application is being submitted on my own behalf. 

As required by Section 333 ofi:he Federal Aviation Administration (FAA) 

Modernization and Reform Ac of 2012 and 14 C. F.~. Part 11, Aerial Images and 

Inspections (All) applies for an exemption from tlv~ above listed federal regulations. 

All operates small, unmanned aircraft equipped to conduct photography and 

videography for the real estate industry, engineering inspectors, landscape 

gardeners, and site development engineers. If this <:xemption is granted, all 

operations will be conducted within and under the conditions established by the 

FAA. 

This exemption would permit the operation of sm<d1, unmanned, and relatively 

inexpensive Unmanned Aircraft Systems (UAS) under controlled conditions in 

airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would 

provide safety enhancements :o the already safe operations in the real estate and 

engineering industries presently using lifting devices such as cranes and 

conver1tional aircraft. Approved of this exemption V!ould enhance safety and fulfill 

the Secretary of Transportation's responsibilities t J establish requirements for the 

safe operation of such aircraft systems in the natio :1al airspace system. 

The petitioner, Gregory A. Green has been flying remote control aircraft since the 

mid-1970 and has recently began tlying quadcoptcrs, both for recreational purposes 

and vvith thE~ intent of forming Aerial Images and Inspections. He has acquired over 

100 hours with quadcopters. Granting this petitior would be in the interest of the 

public, property on the ground, and the national al ~space system. 

The aircraft to be used is a DJl Phantom 2 Vision+ 

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For additional information, please contact: 

Owner: Gregory Green 

Aerial !mages and Inspections 

44 Blackburn Road 

Nevv Hili, North Carolina 2756:~ 

919-S64-67B1 

Regulations from which the exemption is requested: 14 C.F.R. 91.7 (a}, 14 C.F.R. 91.9 

(bJ(2), 14 C.F.R. 91.103,14 C.F.R. 91.119,14 C.F.R. <:'1.121, 14 C.F.H. 91.405 (a), 14 

C.F.R. 91.407 (a)(1), 14 C.F.R. 91.409 (a)(1)&(2), 14 C.F.R. 91.417 (a)&(b) 

Section 333 (a)( c) allows the Secretary ofTranspor:ation to determine the ability of 

an unmanned aircraft to opera·:e safely in the National Air Space. The Secretary· is 

directed to deterrnine which UAS are able to operat2 safely without posing a threat 

to persons, property on the grc und, the nation airsr•ace system, or to national 

security. These determinations will be made based .1pon several factors: 

The vveight, speed, and operati·Jnal capability are important components of the 

aircraft as welt as whether or not the aircraft will b;~ operated in close proximity to 

airports and population centers. 

All aircraft are quad copters WE-ighing five pounds or less with the camera included. 

The camera is the only payload of these UAS. They c,perate at speeds no greater than 

30 miles per hour, have the car>ability to hover, and move in the vertical and 

horizontal plane. They will only operate in line of si :e. These very restrictive 

operations heip ensure the UAS will not create a ha::ard to the public or the national 

airspace system. 

As a result, All aircraft clearly present an equivalen': level of safety to the NAS as 

envisioned by Congress. The relatively small size of the UAS and restrictive 

operati.onai parameters imposed by Air will result in an improved level of safety to 

the NAS and the public when compared with traditi )nal methods of conducting 

photography and videography :Jt real estate, landscaping, and engineering 

preparatior1 sites. As a result, All respectively requests the Secretary of 

Transportation grant our petition of exemptions frcm Section 333. 

Aircraft and Equivalent Level of Safety 

The applicant ask.s that' the exemption requested above apply to unmanned civil 

aircrafts that have the characteristics and operate 'Nith the limitations as described 

below. These limitations provide for at least an equivalent or higher level of safety 

to operations under the current regulatory structur~ because the proposed 

operations represent a safety enhancement to the c perations conducted with other 

equipment such as cranes and conventional aircraft. 

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The following limitations and conditions to which All agrees to follow when 

conducting commercial operations under an FAA i~;sued exemption include: 

L The UAS will weigh less thar: 5 lbs. 

2. Flights will be operated witl: in line of sight of a pdot and/or observer when 

necessary. The pilot and obser;er will be able to co :nmunicate with each other at all 

times. 

3. Maximum total f1ight time for each operational fl ght will be 25 minutes. Flights 

vlill be terminated at 25 percent battery power should that occur prior to the 25 

minute limit. 'The battery of the UAS represents the fuel of the vehicle and provides a 

much safer and predictable en'!ironment than traditional flammable fuels. 

4·. Flights will be operated at an altitude of no more than 200 feet above ground level 

(AGL). 

S. Crew for each operation will consist of the UAS P Jot. 

6. The UAS Pilot will be the Pilot in Command (PIC) 

7. The UAS will only operate within a confined area 

B. The operator will obtain the consent of all persor.s involved in the photography 

and filming. 

9. Pilot and observer will have been trained in oper:ltion ofUAS generally and 

received up-to-date information on the particular UAS to be used. 

10. Written andjor oral permi~:sion from the releva.nt property holders will be 

obtained. 

11. If the UAS loses communicc:tions or loses its GP:; signal, the UAS will have 

capability to return to a pre-determined location and land. This is called the Return 

to Ground (RTG) capability. 

12. Any applicable state rules and regulations will be strictly adhered to at all times. 

These limitations and conditions satisfy Part 91.10::;, Part 91.109, Part 91.1.19 and 

Part 9:L151.. 

CF.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. § 91.203 (a) (1) 

Subpart H, entitled Airworthin1:ss Certificates. 

Based upon the size of the UAS. its limited operating area, and the other limitations 

and conditions presented above, it is obvious the UAS could operate with an 

equivalent level of safety without an airworthiness :ertificate. The FAA Act ( 49 

USC.§ 4470l(f) and Section 333 of the Reform Act authorize the FAA to exempt 

a\rcrafts from the requirement for an airworthines:: certificate, upon consideration 

of the size, weight, speed, operational capability, an :l proximity to airports and 

populated areas of the particular UAS. 

'fhe UAS to be operated by All is less than 5 pounds fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials or fJammabJe liquid fuels, and 

\Vill operate exclusively within a secured area. Operations under this exemption will 

be tightly controlled and monitored by the operator. These safety enhancements 

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provide a greater degree of saf~ty to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Application of these crite ·ia demonstrates there is no 

credible threat to national sect: rity posed by the UAS, due to its size, speed of 

operation, location of operation, lack of explosive n~ aterials or flammable liquid 

fuels, an.d inability to carry a substantial externallc:1d. 14 C.F.R. § 45.23 (b). Ail 

respectively requests the FAA Administrator grant .m exemption from this 

requirement. 

49 US.C §44711: Additionally due to the UAS limikd size and the lack of a cabin, 

cockpit, or pilot station, it is impossible to mark thE' aircraft as required by 

regulation. An exemption is ne(essary and requested for this requirement. 

Additionally no person may operate a U.S.-registerrd civil aircraft for which a flight 

manual is not required by Section 21.5, unless then· is available in the aircraft a 

currently approved airplane or Rotorcraft flight manual, approved manual material, 

markings, and placards, or a combination of the abc ve. However the UAS, given its 

size and configuration has no ability or place to carry such a flight manual on the 

aircraft The equivalent level of safety will be maint:tined by keeping the flight 

manual at the ground control point where the pilot flying the UAS will have 

imrnediate access to it An exemption is requested f)r this requirement. 

14 CF.R § 91.103: Preflight action: This regulation .nstructs the pilot in command to 

perform certain preflight actions to insure the safety of night, the public, property 

and the NAS. As an FAA approved flight manual wili not be provided for the aircraft, 

an exemption will be needed. Following the instrucUons in the UAS operating 

n1anual. will. provide an equivalent level of safety. Additionally the PIC will take 

preflight actions by reviewing weather forecasts, t1i ght battery requirements, 

landing and takeoff distances, c:md aircraft perform;:_nce data before initiation of 

night. 

14 CF.R. § 91.109: Flight instn;ction: Section 91.10:3 provides that no person may 

operate a civil aircraft that is b1~ing used for flight irstruction unless that aircraft has 

fully functioning dual controls. Remote control airuaft such as UAS are operated 

through communications betw:=en the aircraft and;:: remote control transmitter. 

These transmitters are not built with dual control c1pability. As such it is 

irnpossible to meet this requirEment and an exemption is requested. An equivalent 

level of safety is provided sincE the aircraft does not carry passengers and because 

of the limited size and speed of the aircraft. 

14 C. F. R. § 91.119: Minimum S<::fe Altitudes Section: 91.119 establishes safe altitudes 

for operation of civil aircraft. Section 91.119( d) onl.v allows helicopters to be 

operated at iess than the minimums prescribed under certain conditions. 

Technically the LJAS could be considered to be a he!: copter and an exemption will be 

needed to operate at altitudes not to exceed 200 feet AGL. 

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The equivalent level of safety will be achieved give'! the size, weight, and speed of 

the UAS, as -vvell as the location where it is operateci. No rlight will be taken without 

the permission of the property owner. Because of the advance notice to the property 

owner and any participants in the activity, all affected individuals wm be aware of 

the planned flight operations. Compared to tlight O:Jerations with aircraft or 

rotorcraft \Neighing far more than the maximum 5 :lOunds, and the lack of 

ftan1mable fuet any risk associated with these oper::~tions is far less than those 

presently presented with conv2ntional aircraft. In addition, the low-altitude 

operations of the UAS will ensure separation between these small UAS operations 

and the operations of conventi:mal aircraft that must comply witb14 C.F.R. § 

91.119. 

Section 91.121 Altimeter Settings: This regulation requires each person operating 

an aircraft to maintain cruisin~; altitude by reference to an altimeter. However the 

U/\S only has a GPS altitude re<:1dout on the remote ;:ontrol box operated by the pilot. 

Therefore an exemption is nee.jed. An equivalent level of safety will be achieved by 

the operator maintaining awareness with the GPS .::ltitude in an identical fashion as 

a pilot would in an aircraft with an altimeter. 

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

9Ll5l(a) prohibits an individual from beginning a tlight in an airplane under VFR 

conditions unless the aircraft has enough fuel to tly to the point of intended landing, 

and, assuming normal cruising speed (1) during the clay, to fly after that for at least 

30 minutes; or (2) at night, to fly after that for at le; st 45 minutes. Since the battery 

of the UAS has enough power for approximately 30 minutes of l1ight, this 

requirement is impossible to meet. Under this scenario, the aircraft would not have 

any flight time remaining to ac~~omplish its tasks. VVith the limitations and 

conditions /\.!1 has already agreed to implement, a !'light time based on battery life is 

reasonable. 

An exemption from 14 C.F.R. § 91.151(a) falls within the scope of other exemptions. 

T'he UAS will be operated in a controlled area with only clients present. Since the 

UAS has only 30 minutes of battery life, the type of !'isks that Section 91.1S(a) ·1.vas 

intended to minimize will not be present, espedally considering the size and speed 

of the small aircraft. 

An equivalent level of safety can be achieved by lim ting Jlights to 25 minutes as 

already agreed or 25 percent of battery power, whichever happens first. This 

limitation ·vvili allow the pilot sufficient time to retu ·n the aircraft to its 

predetermined landing area. 

14 C.FJt §§ 91.203(a) and (b): Carrying Civil AircraFt Certification and Registration. 

The UAS is a very small aircraft, weighs less than 5 pounds, and consequently, i.s f~1r 

too small to carry either passengers or crew memtwrs. As such, it is impossible to 

carry the airworthiness certitlcation and registration documents, or to display them 

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on the aircraft. An equivalent level of safety can be achieved by maintaining these 

documents, appropriately, at the airfield with the p lot. 

14 C.F.R. §§ 91.405(a); 407(a)(1); 409(a)(2); 41.7(a) and (b): Maintenance 

Inspections. 

These regulations require that an aircraft operator or owner shall have that aircraft 

inspected and shall have discrepancies repaired as prescribed in Part 43 of this 

chapter, and others shall inspect or maintain the aircraft in compliance with Part 43. 

Since these secti.ons and Part 43 apply only to aircnft with an airworthiness 

certificate, these sections should not apply to the applicant The operator will 

perform ali maintenance required by the flight marual. The manual also 

recommends the operator verify that the aircraft is in safe operating condition. 

perform any required maintenance as mentioned before the flight, and to keep a iog 

of any maintenance done. The recommendations wm be accomplished. An 

equivalent level of safety willl: e furthered because these UAS are very small and 

applicant has agreed to operat~ only in restricted a ·eas, no higher than 200 feet 

AGL, and for a short period of time. If a mechanical problem should arise, the UAS 

would land immediately. 

Applicant be.lieves all of the requirements of Sectio 1 333 of the Reform Act of 2012 

have been rnet and exernption from all parts of the Act, as requested, is appropriate. 

As stipulated above, the UAS is very small and can ·:ravel at 30 miles per hour at 

most 'The aircraft will not be operated within closE~ proximity to airports and 

densely populated areas, with a visual line of sight, and will not be a hindrance to 

the national air space. 

Your consideration of this request is appreciated. 

Gregory A. Green 

Aerial Imagery and Inspection; 

44 Blackburn Road 

New Hill, North Carolina 2756 2 

(_. 910' . -· J .) l- 6 '4 -- 6~(31 It . 

aerj.aJskyimages@gmail.com 

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To: July 15, 2015 

Docket Operations, M-30 

US Department of Transportation Docket Management System 

1200 New Jersey Avenue SE 

Room W12-140 

West Building Ground Floor 

Washington, D.C 20590 

From: 

Owner: Gregory Green 

Aeriallmages and Inspections 

44 Blackburn Road 

New Hill, North Carolina 27562 

919··564-6781 

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