Terrestrial Imaging, LLC

1 Grand Court

Colts Neck, New Jersey 07722

Owners FAA Ratings: Private Pilot, Single Engine Land, Multi Engine Land, Instrument 

Rating

July 3, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, D.C. 20590

by/for Terrestrial Imaging, LLC

1 Grand Court

Colts Neck, New Jersey 07722

RE: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation 

Regulations from 14 C.F.R. Part 21;14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a)&(b); 

91.7(a);91.9(b) (2); 91.103(b);91.109;91.121;91.151(a); 91.203(a)&(b);91.405(a); 

91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam:

This petition is being submitted with no legal counsel or consulting services.

I am submitting a petition for exemption for unmanned aircraft systems operations on 

behalf of my company Terrestrial Imaging, pursuant to the FAA Modernization and Reform 

Act of 2012 and the procedures contained within 14 C.F.R. 11. I am the owner of this 

business and am a licensed pilot with over 30 years of experience piloting small civilian 

airplanes. I have logged more than 1,350 hours of flight time and currently own a twin 

engine Cessna. I am born in the United States of American, have a current 3rd class FAA 

medical exam, and currently reside in New Jersey. I am also a graduate of NYU with a 

degree in computer science and electrical engineering. I also have a real estate license 

in the state of New Jersey and am engaged real estate sales, property management, and 

other real estate activities.

I am making a request for a waiver of the sections listed above so that my business, 

Terrestrial Imaging, LLC, can legally operate unmanned aircraft systems commercially in 

order to conduct aerial photography and videography services for residential, commercial 

and industrial real estate - and to survey privately owned land, and for events and 

promotional purposes. I understand that the current regulations require that a licensed 

pilot be at the controls of all unmanned aerial systems, and as a business, we intend to 

adhere to these regulations.

I am requesting the following exemptions under Section 333 of the FAA Reform Act of the 

Federal Aviation Regulations:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a)&(b);

91.7(a);

91.9(b) (2);

91.103(b);

91.109;

91.121;

91.151(a);

91.203(a)&(b);

91.405(a);

91.407(a) (1);

91.409(a) (2);

91.417(a)&(b)
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 published this past February. It is my understanding that the FAA will 

still review each Section 333 petition individually. However, I am hoping that the agency 

will accept my particular petition, and include it in the next summary grant, and issue 

me an exemption on the presumption that the FAA has “already granted a previous exemption 

similar to this request”. Apparently, 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.

UAS Description:

Although I am asking for an exemption for piloting unmanned aircraft systems up to 55 

pounds, Terrestrial Imaging plans on using commercially manufactured systems that will 

weight much less – somewhere between three and ten pounds. At the time of this 

application, our intentions are to fly both the DJI Phanton 3 and the 3D Robotics Solo 

drones – both weighing much less than 10 pound. From a safety and operational 

perspective, both of these units can be manually operated and software controlled making 

flight more predictable. These units have “return to home” features, geo-boundary 

limitations, and other safety features built into their hardware and software. Both of 

the companies that manufacture these devices have excellent reputations for providing all 

of the necessary tools and education to fly safely and respect FAA rules and 

regulations.

These UAS systems have limited flying time capabilities (approximately 20 minutes of 

flight on a charge), do not carry anything other than a camera, operate by battery power, 

and do not carry flammable fuel. In fact, in the event of the loss of communications 

with the pilot, these devices are programmed to “return to home” and/or travel a 

pre-determined route to land safely.

All pilots who operate unmanned aircraft systems for Terrestrial Imaging, LLC will be 

licensed pilots and will receive proper training on the UAS that they will be flying. 

Each pilot will be responsible for assuring that their UAS is airworthy before each 

flight, and will be responsible for conduction pre and post flight inspections. At no 

time during a flight will the UAS ever be out of line of site, and aircrafts will never 

be flown more than 35 miles per hour.

Additional Points:

UAS technology is changing rapidly, and so are the people that are piloting them. As a 

30 year seasoned pilot, I understand the importance of choosing reliable products that 

are built by reliable companies. Both DJI and 3D Robotics are companies managed by smart 

people who work closely with their pilot-clients to improve their products and the safety 

of them. Both of these companies respect the FAA’s rules and regulations and understand 

the value that a trained pilot adds to the safe operation of their products.

In addition, as the owner of Terrestrial Imaging, LLC I put emphasis on my 30 plus years 

of pilot experience flying both single engine and multi engine aircraft in VFR and IFR 

conditions. The FAA has already recognized my qualifications by issuing me a private 

pilot license; I hope you will come to the conclusion that my pilot license and the 

privileges that go with that should extend to unmanned aircraft systems used by my 
company.

Flight Operations and Maintenance:

In addition to my 30 plus years of flying experience, I also have more than 25 years of 

airplane ownership experience. There is a big difference between those that fly and 

those that fly and own their own plane. There is a much greater level of responsibility 

when you own your own plane. I believe this unique experience has taught me the 

importance of maintaining your plane, and the direct relationship between maintenance and 

safety. I will be leveraging this experience when flying unmanned aircraft systems, and, 

when overseeing other pilots who by for Terrestrial Imaging, LLC.

For the purpose of UAS activities, all flying will take place in VFR conditions and will 

end when the battery reserves reach 25 percent. Preflight and post-flight check lists 

will be used to help identify any defects prior to and after flight. Any UAS that do not 

meet the qualifications for safe flight will be removed from service until they have been 

repaired and deem airworthy. A flight briefing will take place before each flight and 

shared with anyone in the general vicinity of the flight.

All flying activity will be in accordance with current FAA UAS rules and regulations.

Section 333 Compliance and Appropriateness:

Based on the size of the craft that we will be using, the experience of the owner of the 

company, 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).

I eagerly await your approval.

Respectfully submitted,

Terrestrial Imaging, LLC

Christopher LoPresti, Private Pilot

1 Grand Court

Colts Neck, New Jersey 07722