U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, S.E. 

West Building Ground Floor, Room W12-140 

Washington, DC 20590 

RE: Docket ID: FAA-2014-1081 

Petition for Exemption under Section 333 of the FAA Modernization and Reform Act 

and Part 11.81 of the Federal Aviation Regulations 

April 24, 2015

Petitioner: 

William Kruger, DBA Above All Imaging

183 Pelican Circle #1302

Breckenridge, CO 80424

Tel.: 330-606-7593

Email: kruger.will@gmail.com

Dear Sir or Madam, 

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

Act) and 14 C.F.R. Part 11.81, William Kruger, DBA Above All Imaging, hereby applies 

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

commercial operation of its small, unmanned aircraft for photogrammetry, 

photography/cinematography, industrial inspections, search & rescue, and analyses. All 

operations shall be conducted within and under the conditions and limitations outlined 

previously by the FAA as required by Section 333 and conducted in compliance with the 

attached operator’s manuals. 

1. Sections from which exemptions are sought: Application is hereby made for 

exemption from: 

a. 14 CFR Part 21, subpart H 

b. 14 CFR Part 61.113(a) and (b) 

c. 14 CFT Part 91:

i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417
2. Relief sought:

a. William Kruger, DBA Above All Imaging wishes to operate small Unmanned 

Aircraft Systems (sUAS) for commercial purposes to include (but not be 

limited to) photogrammetry, photography/cinematography, industrial 

inspections, search & rescue, and analyses. This relief is sought because 

commercial use of sUAS is currently prohibited by law unless performed 

under an exemption.

b. This exemption will cover use of the following airframes, all of which will 

weigh less than 55 pounds including payload and energy sources:

i. CarbonCore H650 Foldable Multi-rotor (6-propeller hexagonal frame, 

carbon fiber):

1. Total weight with maximum allowable payload: 9.3lbs.

2. Dimensions: Greatest width: 650mm (25.59in), Height (with 

landing gear): 14.25”

3. Maximum speed: 30kts

4. Battery system (1x 4-cell, 14.8 volt, 16,000maH lithiumpolymer) provides fifteen (15) minutes of flight time, and two 

(2) minutes of reserve flight time.

5. NAZA-M Flight Controller (with GPS and compass) is 

installed on this sUAS, and is the most advanced system 

currently available, with latest firmware release. 

6. Use of First-Person View (“FPV”) for advanced flight safety; 

provides real-time video downlink from sUAS as well as 

critical flight systems status to video monitor on transmitter.

ii. DJI F550 Flamewheel Multi-rotor (6-propeller hexagonal frame, 

plastic/metals):

1. Total weight with maximum allowable payload: 6.5lbs

2. Dimensions: Greatest width: 550mm (21.65in), Height (with 

landing gear): 10.5”

3. Maximum speed: 30kts

4. Battery system (4-cell, 14.8 volt, 5000maH lithium-polymer) 

provides eight (8) to twelve (12) minutes of flight time, and 

one (1) minute of reserve for RTH function if necessary.

5. NAZA-M Flight Controller (with GPS and compass) is 

installed on this sUAS, and is the most advanced system 

currently available, with latest firmware release. 

6. Use of First-Person View (“FPV”) for advanced flight safety; 

provides real-time video downlink from sUAS as well as 

critical flight systems status to video monitor on transmitter.

iii. DJI Phantom 2 (see www.dji.com/product/phantom-2)

iv. Flight Controller and Fail-Safe systems: 

1. The existing flight control technology that William Kruger, 

DBA Above All Imaging utilizes is the DJI NAZA-M Flight 

Controller, which provides these safety features:

a. GPS Attitude Control: Prior to flight operation, the GPS 

records latitude and longitude, and that position 
becomes the origin of flight. Once airborne, the GPS 

holds the sUAS in this position, and does not deviate

from it, unless the operator changes the mode. This 

level of safety safeguards the sUAS, preventing it from 

drifting away, and posing a potential risk of injury or 

damage to property. 

b. Attitude Control: The flight controller disables the GPS, 

and allows operator to control the sUAS in a manner 

consistent with manual flight. The onboard stability 

systems keep sUAS horizontally stabilized, to prevent 

erratic flight performance.

c. Return-to-Home (“RTH”): If the operator, under any 

circumstances, deems the operation of the sUAS to 

become a risk to persons, property, or the sUAS itself, 

the RTH command may be invoked, safely returning 

the sUAS to the origin of flight, subsequently landing 

and powering down autonomously. This feature is a 

design protocol that allows the operator to dismiss 

operation in the event of his or her inability to control 

the sUAS, as in with an emergency situation.

v. Other models to be added by future amendment to this exemption.

3. Public benefit:

a. Use of sUAS technology to obtain imagery, information and data currently 

obtained by use of manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents 

(e.g., infrastructure inspections) and due to other dangerous activities 

that can be avoided (e.g., scaffolding/rigging failures during stack or 

bridge inspections).

ii. Reduces the cost of obtaining such information, which benefits 

consumers and the economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon 

emissions from manned aircraft.

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and 

Part 47 and Part 45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the 

manufacturer. All repair and maintenance work will be conducted or approved 

by qualified personnel such as those authorized by Robotic Skies (or 

equivalent), and will require a test flight after such work. Records of all 

maintenance and repair work will be kept in a maintenance log for each 

aircraft.

c. All flight operations will be conducted by at least two individuals (PIC and 

observer) who will maintain verbal communication capability with each other 
at all times during the flight, and who will remain stationary on the ground

during the flight operations:

i. A Pilot In Command (PIC) who possess the following credentials:

1. An Airman Certificate issued under 14 CFR 61 (private pilot 

license) screened by the TSA.

2. A Third Class medical certificate issued under 14 CFR 67.

3. A bi-annual flight review under 14 CFR 61.56

4. Successful completion of a UAS knowledge test in a specified 

form.

5. At least 200 cycles and 25 hours of flight experience in a UAS 

rotorcraft (or UAS fixed-wing in the case of fixed-wing flight 

operations under this exemption). Such cycles and hours may 

be gained during flights under this exemption if a safe distance 

is maintained from persons in accordance with 14 CFR 91.119.

6. At least 5 hours of flight experience and 3 takeoffs and 

landings in make and model being flown in the prior 90 days. 

Such cycles and hours may be gained during flights under this 

exemption if a safe distance is maintained from persons in

accordance with 14 CFR 91.119.

ii. A Visual Observer.

iii. A Sensor Operator as necessary.

d. All operations will be conducted in accordance with valid Certificates of 

Authorization.

e. All flight operations will comply with the following:

i. The manufacturers’ user manuals.

ii. William Kruger, DBA Above All Imaging Flight Operations and 

Procedures Manual (FOPM) and Aircraft Flight Manuals (AFM), 

which include lost communication and other emergency and safety 

procedures.

iii. Conducted in VMC conditions during daylight hours.

iv. PIC and VO will maintain VLOS at all times.

v. Pre-flight inspections (including ground control station, if any) and 

safety risk assessments will be conducted prior to each flight.

vi. Flight altitudes will remain below 400 feet above ground level.

vii. Flight ground speeds will not exceed 50 knots.

viii. Not intrude into Class B, C or D airspace, or published approach, SID 

or STAR, or take place within 5 nautical miles of an airport.

ix. Not be made near persons as required in 14 CFR 91.119 and not over 

persons on the ground without their prior permission.

x. Each flight will be logged in both the PIC’s logbook and the aircraft 

logbook.

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 

minutes, whichever occurs first.

xii. Any incidents will be reported within 24 hours of occurrence.
xiii. William Kruger, DBA Above All Imaging will maintain liability 

insurance of at least $1,000,000 issued by a major aviation insurance 

underwriter.

xiv. Any applicable local FSDO requirements.

xv. All other applicable regulations concerned with the operation of

aircraft.

f. Aircraft will use FCC compliant 2.4 GHz for command & control of the 

aircraft with well-defined and tested lost link procedures. 

Please advise us of any additional information or changes that may be required.

Sincerely, 

William Kruger

DBA Above All Imaging