Detroit Aerial Imagery, LLC

1381 Delta Rd.

Walled Lake, MI 48390

T: +1 734 755 9636

justin.vandemark@gmail.com

January 13, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Request for Exemption Per PL 112-95 §333 from 14 CFR 61.113(a) and (b), 14 CFR 91.103, 14 CFR 

91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 

91.409(a)(2), 14 CFR 91.417(a) and (b)

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, operators at Detroit Aerial Imagery seek an exemption from Federal Aviation Regulations 

detailed herein for the operation of lightweight aerial imaging equipment, also referred to throughout 

as Small Unmanned Aerial Systems (sUAS), as well as their ground based operation equipment described 

within.

Our Aircraft:

Our operation will include two different sUAS, manufactured by DJI, the DJI Inspire 1 and the DJI 

Phantom 3. (sUAS manuals attached). 

The DJI Inspire 1 has the following flight and safety relatable features:

• Inspire 1 is a sUAS Quadcopter made by DJI that has a fixed gimbal and camera attached to the 

bottom. Inspire 1 has a maximum weight of 6.47 lb. (2965 grams), and a maximum range of 

5000m. 

• Inspire 1 has built in telemetry to allow the operator to see all onboard information relating to 

the safety of flight including but not limited to battery percentage remaining, overall health of 

the operating system, built-in GPS for position hold and automatic return-to-home, and multiple 

fail-safes for maximum safety.

• The onboard camera allows the operator to record High Definition video, as well as take 

camera stills. The video is transmitted real-time to the control and operator allowing the 

operator to see images to all sides of the sUAS utilizing an Apple iOS Device.
• DJI Inspire 1 is limited to a maximum assent rate of 5 m/s and has a maximum decent rate of 4 

m/s. It also has a limitation of maximum speed of 22 m/s or 49 mph.

• The Inspire 1 will be operated with a 5700maH lithium polymer battery allowing for flight 

times not to exceed 22 minutes.

The DJI Phantom 3 has the following flight and safety relatable features:

• Phantom 3 is a sUAS Quadcopter made by DJI that has a fixed gimbal and camera attached to 

the bottom. Phantom 3 has a maximum weight of 2.82 lb. (1280 grams), and a maximum range 

of 5000m. 

• Phantom 3 has built in telemetry to allow the operator to see all onboard information relating 

to the safety of flight including but not limited to battery percentage remaining, overall health 

of the operating system, built-in GPS for position hold and automatic return-to-home, and 

multiple fail-safes for maximum safety.

• The onboard camera allows the operator to record High Definition video, as well as take 

camera stills. The video is transmitted real-time to the control and operator allowing the 

operator to see images to all sides of the sUAS utilizing an Apple iOS Device.

• DJI Phantom 3 is limited to a maximum assent rate of 5 m/s and has a maximum decent rate of 

3 m/s. It also has a limitation of maximum speed of 16 m/s or 36 mph.

• The Phantom 3 will be operated with a 4480maH lithium polymer battery allowing for flight 

times not to exceed 23 minutes.

Our Ground Based Guidance and Control System:

• DJI Inspire 1 and DJI Phantom 3 are controlled using a DJI transmitter, operating on a 2.4GHz 

frequency to a maximum range of 5km. (Specific operating range of 2.400-2.483GHz.) (See DJI Inspire 1

Manual Appendix page 58 and DJI Phantom 3 Manual Appendix page 54 for all specifications.) These 

specifications fall within FCC guidelines for operators. Powered by a lithium polymer battery it has a 4 

hour time between charges.

• The DJI Inspire 1 and Phantom 3 transmitters have a built in GPS allowing the the sUAS to always know 

where to return to in the event of a failure.

• The sUAS transmitter will be controlled by a single operator, but will utilize a Visual Observer when 

necessary. 

Our Operator:

• Detroit Aerial Imagery will use a single operator for each flight, and when able/necessary use a Visual 

Observer to assist in keeping sight of the sUAS at all times. At no time will the sUAS be flown outside of 

visual line-of-sight and visual range.
• Our operator/owner holds a current Airline Transport Pilot rating with 4 years of experience as an 

Airline Pilot. (Certificate #3178335) 

• Our Operator/Pilot has a total of 2,770 hours of flight time at the time of filing.

• Our Operator/Pilot currently holds and will maintain a 1st Class medical certificate.

• Our Operator/Pilot has approximately 12 years of aircraft flight experience.

• The only pilot allowed to operate the sUAS under this exemption will be the Owner/Operator of 

Detroit Aerial Imagery, ATP Certificate #3178335.

Our Business Intent:

Detroit Aerial Imagery will be utilizing the sUAS for multiple projects from time to time. These include:

• Precision Farming

Based in Southeast Michigan, we have a large amount of interest in using our sUAS to inspect and 

photograph produce fields (corn, soybeans, potatoes, etc) for precision farming. Utilizing a sUAS to 

inspect fields instead of a costly traditional helicopter or airplane will not only save a significant amount 

of money, but also increase safety over traditional methods that utilize gas/turbine helicopters.

• Microwave Tower Inspection

Inspecting microwave towers (including cellular telephone towers) traditionally requires a human 

inspection. Utilizing a sUAS to inspect these towers greatly improves safety and will prevent deaths of 

tower Inspectors. We have a significant amount of interest from companies doing business throughout 

Michigan to conduct such inspections.

• Bridge Inspections

Similar to inspecting towers with the use of sUAS, the required inspections of local bridges and 

overpasses will see a significant amount of increased safety.

• Livestock Search and Inspection

Searching for cattle and other livestock utilizing traditional means is both time consuming and 

ineffective. We plan to utilize the sUAS to aid farmers and ranchers in making this process much faster, 

saving time and money.

• Insurance Inspections of Home and Property

Detroit Aerial Imagery has a significant amount of interest from local and regional Insurance companies 

and adjusters to utilize the sUAS to conduct inspections of property and structures. By utilizing a sUAS to 

conduct inspections of rooftops, farm fields, and other property, the insurance company stands to save 

a significant amount of time inspecting such property after storms. Also, utilizing a sUAS will increase 

safety by preventing adjusters from having to climb tall ladders and roofs to make such inspections.

• Factory Inspections (both internal and external)
Similar to tower and bridge inspections, we plan to use a sUAS to conduct inspections within and outside 

of manufacturing facilities. These dangerous and costly inspections will be made safer and less

expensive with use of our sUAS.

• Commercial Advertising Video and Photography

Detroit Aerial Imagery has a significant amount of interest in taking video and photos for advertising in 

our local area. Utilizing a sUAS will offer a significant improvement to the agency with regards to both 

safety and cost. Using a 6 lb. or less sUAS compared to a gas turbine helicopter or aircraft will offer a 

considerable safety margin as well as cost savings advantage.

• Real Estate Photography and Videography

Real Estate photography will see a significant impact with our services, allowing real estate agents a 

much more competitive product at a much lower price. Safety will also be increased as well as 

productivity by utilizing out services.

• Yacht Sales Photography and Videography

Detroit Aerial Imagery has seen a significant interest in utilizing out sUAS to capture video and photos 

for Yacht sales near the numerous lakes in the Northwest Metro Detroit area. We will utilize the sUAS

to increase scope of sales to the yacht brokers. We can offer again a more cost competitive product and 

a much safer development method over the current use of airplanes and gas/turbine helicopters.

• Police/Fire/Search and Rescue

Detroit Aerial Imagery intends to offer our services on a voluntary and pro bono basis for multiple local 

services including but not limited to Police services, fire-fighting services, and search and rescue. These 

services will increase safety associated with law enforcement and search and rescue. The services will 

be offered free of charge to the community.

Our Safety and Operating Plan:

Utilizing our sUAS in a safe manner is of upmost importance. Safety will be the guiding principle of our 

operation, both with respect to the National Airspace System, as well as those on the ground. including 

persons and property.

Our Safety plan will start with complying with all Federal Aviation Regulations, as well as conducting 

audits of safety procedures set forth within Detroit Aerial Imagery to keep up to date with the safest 

practices.

Our initial safety philosophy will be based on the premise of “Be Safe Before Takeoff”. We will complete 

preflight checklists set forth by DJI, the sUAS manufacturer, as well as do thorough post-flight 

inspections. (see attached manual for the complete checklist) We will also complete post-flight checklist 

and debriefs to constantly monitor our procedures and identify any changes that can be made, similar to 

those set forth on airline flight decks.
Maintenance and repair of our sUAS will be conducted solely by the manufacturer, DJI, by its employees 

or designated technicians. With respect to safety, Detroit Aerial Imagery believes the manufacturer 

holds higher maintenance abilities.

Detroit Aerial Imagery will comply with the following at all times when conducting commercial 

operations:

1. All operations will remain outside Class A,B,C,D airspace. 

2. Our operating system will be programmed before all flights to avoid airports so as not to 

accidentally fly too close to one. The onboard system will not allow either of our sUAS to fly into 

such airspace. This is an automatic safety feature within the Inspire 1 and Phantom 3.

3. Operations conducted by Detroit Aerial Imagery will always remain within visual line-of-sight 

of the sUAS. Never to exceed the limitations of our operator’s eye sight. We will limit the 

maximum range of the sUAS to not exceed a single person’s visual eye-sight range. Utilizing the 

software within the sUAS will help to maintain this limit, not to exceed 300m. (.186 miles)

4. Our sUAS will never carry an implement not approved by the manufacturer and will never 

exceed a weight of 55 lb. as stated within this exemption.

5. All operations conducted by Detroit Aerial Imagery will be at an altitude of less than 400ft 

AGL, while the majority of our operations will be at an altitude less than 200ft AGL. The Inspire 

1 and Phantom 3 have an automatic altitude limit built in and will be set and checked by our 

operator prior to every flight operation as part of the pre-flight inspection.

6. Detroit Aerial Imagery will not conduct operations with a speed in excess of 27 knots. The 

Inspire 1 and Phantom 3 sUAS have an automatic speed limiter that will be set and checked 

prior to every flight by the operator as part of the pre-flight inspection checklist.

7. All operations will be conducted in Day VFR conditions. Minimum flight visibility for all 

operation will be 5 miles. Minimum cloud ceilings will be 2000ft OVC (overcast) or BKN (broken).

8. All operations will be conducted away from densely populated areas. Detroit Aerial Imagery

will work with local officials to make sure any required local documents or permits are attained 

prior to each flight.

9. Prior to each flight our operator will conduct a safety audit of the area to be flown. An 

assessment will be made with regards to persons, property, and weather. This assessment will 

allow our operator to determine whether a safe operation and outcome will be expected.

10. Our operation will utilize a single, dual-band transceiver and will maintain a “listening 

watch” of airspace surrounding the operations. (eg. we will monitor both local frequency 122.8 

as well as maintain watch of emergency frequency 121.5.) Our operator will also make traffic 

advisories of our operation location and maximum altitudes prior to all flights utilizing the sUAS.

11. Prior to operating under this exemption, our operator will obtain a Certificate of Waiver or 

Authorization (COA) from the FAA Air Traffic Organization.
The current regulations that we seek exemption from are:

A. 14 CFR Part 21 (h) Airworthiness Certification

• Under this part we seek exemption to apply for and maintain airworthiness certification for 

our sUAS. Model and serial number of our sUAS will be provided within.

B. 14 CFR Part 91 Subpart A: Airworthiness 91.7 (a) Civil Aircraft Airworthiness

• Under this part, “no person may operate a civil aircraft unless it is in airworthy condition.” 

• We seek exemption from this part, as we will keep our sUAS in a safe, reliable, and airworthy 

condition, it may not meet all standards as set for by this part of the FAR’s. Our operator will 

assume all responsibility for determining that the sUAS is in a condition safe for flight, as well as 

a condition that will not harm other people or property. This will be accomplished using specific 

guidelines from the manufacture, DJI, as well as following any guidance set for for routine 

maintenance.

C. 14 CFR Part 91 Subpart C: 91.203: Certifications Required

• Under this part, (a) no person may operate an aircraft unless it has within it the following; An

appropriate and current airworthiness certificate. This part also includes regulations regarding 

the use of fuel tanks, which do not apply. 

• We seek exemption from this part as an airworthiness certificate does not apply to our specific 

sUAS.

D. 14 CFR Part 91 Subpart B; 91.119 Minimum Safe Altitude

• Under this part, (a) no person may operate an aircraft below an altitude allowing, if power 

fails, an emergency landing without undue hazard. (c) over other than congested areas an 

altitude below 500ft AGL. 

• We seek exemption from this part due to the nature of the operation, as well as the safety 

procedures set forth will have little to no risk of damaging any person or structure.

E. 14 CFR Part 91 Subpart B; 91.121 (a)(1) Altimeter Setting

• This section pertains to setting an altimeter setting below 18,000 ft to a reported altimeter 

reporting station setting. 

• We seek expedition from this part as our sUAS has no way of setting an alternate altimeter 

setting. With a built-in barometer, the Inspire 1 and Phantom 3 use real-time data to determine 

altitude during each flight. Operating less than 400ft AGL, we feel our sUAS will have little to no 

impact on other participating aircraft. Also, with flights not to exceed 16 minutes (22 minute 

battery, and landing at 30% battery remaining) our sUAS will not need to recalibrate its 

altimeter while in flight.

F. 14 CFR Part 91 Subpart B; 91.151 Fuel Required for VFR flight

• This section contains requirements for fuel in VFR flight for combustion engines. 
• We seek exemption from this part as our sUAS operates off of battery power only. We feel 

our operations will not compromise safety to either the operator or property as we have set 

forth a procedure to land our sUAS when the battery level reaches 30%, or approximately 6 

minutes flight time remaining. The Inspire 1 and Phantom 3 have built in battery telemetry that 

feeds information real time to the operator and an alarm notifies the operator of minimum 

battery level remaining. (See attached manual for more information)

G. 14 CFR Part 91 Subpart E; 91.405 Maintenance Required

• This section contains requirements for the operator to maintain and have inspected the 

aircraft in accordance with Part 43 of the CFR. Under this section it is required to keep 

maintenance logbooks with the aircraft. It also requires the aircraft to contain placards of the 

inoperative equipment. 

• We seek exemption from this part as our sUAS will not be operating with inoperative 

equipment and is too small to carry logbooks. We also seek exemption due to no certified 

maintenance technicians will work on the sUAS. Under this exemption August Aerial will be 

completing pre-flight and post-flight inspections, and any required maintenance or repairs will 

be completed by the manufacturer, DJI, or one of its certified technicians.

H. 14 CFR Part 91 Subpart E; 91.407 Operation After Maintenance

• This part requires an aircraft that has undergone repair, rebuilding, alterations, or general

maintenance to be approved by an authorized person required by CFR 43.9 and CFR 43.11.

• We seek exemption from this part as these inspections do not pertain to our operation of the 

sUAS. The operator will be responsible for determining the airworthiness of the sUAS prior to 

each flight. After maintenance provided by the manufacturer, the operator will complete test 

flights before any operation in the vicinity of persons or property to assure all systems are 

functioning normally.

I. 14 CFR Part 91 Subpart E; 91.409 Inspections

• This section provides details of the required inspection on an aircraft. No person will operate 

an aircraft unless in the preceding 12 months has had (1) an annual inspection (2) an issuance of 

an airworthiness certificate.

• We seek exemption from this part as the inspection and airworthiness certificate to not apply 

to our sUAS. Our operator will be responsible for the inspection and airworthiness 

determination prior to each flight and will have the sUAS repaired by the manufacturer or one 

of its certified technicians, if the sUAS is found to be in a state other than intended but the 

manufacturer.

J. 14 CFR Part 91 Subpart E; 91.417 Maintenance Records

• This section requires the owner/operator to complete and retain a list of all records pertaining 

to the work performed, the date of completion, the signature of the inspector, and all work 

performed on the aircraft.
• We seek exemption from this part as the inspections and technician work will not apply. Our 

operator will be responsible for determining the airworthiness of the sUAS prior to each flight 

and will not operate the sUAS in any condition other than intended by the manufacturer. The 

operator will keep records of all work completed by the maintenance facility. 

K. 14 CFR Part 91 Subpart B; 91.103 Preflight Action

• This section requires each pilot prior to flight will become familiar will all available information 

pertaining to that flight including runway lengths, flight information, weather, etc. For any flight, 

runway lengths at airports of intended use, and the following takeoff and landing distance 

information include; all applicable information relating to aircraft performance, airport 

elevation, runway slope, aircraft gross weight, wind and temperature.

• We seek exemption from this part as our operator, while utilizing all available information for 

the safe operation of the sUAS, will not have the above information available for most flights. 

The operator will use good judgement and all resources available to ascertain the information 

necessary for the safe operation of the sUAS. A preflight inspection will be accomplished 

according to the manufactures instructions prior to each flight.

L. 14 CFR Part 91 Subpart B; 91.105 Flight Crew members Stations

• This section pertains to the required crew members being at their stations during all phases of 

flight, and requires the use of seat belts and shoulder harnesses.

• We seek exemption from this section as it pertains to aircraft with flight crew member 

stations. Our sUAS does not have such stations.

M. 14 CFR Part 91 Subpart B; 91.9 Placement of Manual

• This part states no aircraft may operate without a manual onboard the aircraft.

• Our sUAS is not large enough to carry such operating manual. We will however carry a current 

manufacturer manual in the sUAS carrying case along with the operator on all flights.

N. 14 CFR Part 45.23

• Under this part, it is required that each operator must display on that aircraft marks consisting 

of the Roman capital N followed by the registration number of the aircraft.

• Our sUAS is too small to attach the “N” number. We seek exemption from this part as we will 

be attaching the registration or serial number as required on the sUAS.

Detroit Aerial Imagery and its owners are committed to a “Safety First” atmosphere. We are committed 

to conducting our operation in accordance with all Federal Aviation Regulations and maintaining a safety 

margin of at least those regulations while striving to exceed expectations set forth by the FAA. We are 

confident we can approach our operations with safety while adding a significant advantage to our 

community both through private and civil services.
Detroit Aerial Imagery is prepared to respond to any concerns and look forward to working with you on 

this important exemption. Please contact us with any other questions or concerns.

Sincerely yours,

Justin VanDemark

Detroit Aerial Imagery, LLC