August 12, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations 

from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 

91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b). 

Application: FAA-2015-0117 

To Whom It May Concern: 

In pursuant with Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, 

Maria Galli Photography Corp, a leading image and video firm in the Miami area and an operator of a 

small Unmanned Aircraft System (sUAS) for the Aerial Photography and Videography, seeks an exemption 

from the Federal Aviation Regulations (FARs) to allow commercial operations of its sUAS. Regulations 

("FARs") to allow commercial operation of its sUASs, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by Section 333. 

As described more fully below, the requested exemption would permit the operation of small, unmanned 

and relatively inexpensive sUAS under controlled conditions in airspace that is limited, predetermined, 

controlled as to access take photos and record videos for its clients. Approval of this exemption would 

thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) 

responsibilities to " ... establish requirements for the safe operation of such aircraft systems in the national 

airspace system." Section 333(c) of the Reform Act. 

Information Supporting this Petition as Specified in 14 C.F.R. §11.81 

(a) Your name and mailing address and, if you wish, other contact information such as a fax number, 

telephone number, or e-mail address; 

Maria Galli Photography Corp 

Attn: Maria Galli 

150 SE 25th RD, Apt 14-1 

Miami, FL 33129 

917-208-9167 

info@mariagalliphotography.com 

(b) The specific section or sections of 14 C.F.R. from which Maria Galli Photography Corp seeks an 

exemption 

• 21- Subpart H Certification procedures for products and parts, Airworthiness 

Certificates 

• 45.23 - Display of marks; general 

• 61.113 - Private pilot privileges and limitations: Pilot in command 

• 91.103- Preflight Actions 

• 91.105- Flight crewmembers at stations 

• 91.109- Flight instruction; Simulated instrument flight and certain flight tests 

• 91.119- Minimum safe altitudes: General 

• 91.121- Altimeter settings 

• 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions 

• 91.203- Civil aircraft: certification required 
• 91.405- Maintenance required 

• 91.407- Operation after maintenance, preventative maintenance, rebuilding, and 

alteration 

• 91.409 -Inspections 

• 91.417- Maintenance records 

(c) The extent of relief Maria Galli Photography Corp seeks, and the reason Maria Galli Photography Corp 

seeks the relief 

Maria Galli Photography Corp seeks an exemption for several provisions of 14 C.F.R. Parts 21, 45, 61, and 

91 to the extent to operate small UASs to record aerial photography and videography purposes. 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) ofthe Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not create a hazard to users 

of the NAS or the public or pose a threat to national security in light of the following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act§ 333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system" 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness 

certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the 

exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR 

§91.203 (a) (1}. 

14 C.F.R. 21- Subpart H Certification procedures for products and parts, Airworthiness Certificates 

Maria Galli Photography Corp seeks exemption from 14 C.F.R. 21, Subpart H which states the certification 

procedures for products and parts as well as airworthiness certificates. The sUAS to be operated 

hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive 

materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the 

Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by both the operator, pursuant to the Manual's requirements, and under the requirements 

and in compliance with local public safety requirements, to provide security for the area of operation as is 

now done with conventional filming. The FAA will have advance notice of all operations. These safety 

enhancements, which already apply to civil aircraft operated in connection with motion picture and 

television production, provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart 

H. Lastly, application of these same criteria demonstrates that there is no credible threat to national 

security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and inability to carry a substantial external load. 
Maria Galli Photography Corp has developed our own procedures and protocols to promote and provide 

safe flying experiences for our PIC(s) which can be viewed in section (e) of this petition. Unlike other civil 

aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, 

pursuant to the Manual's requirements, and under the requirements and in compliance with local public 

safety requirements, to provide security for the area of operation. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

Maria Galli Photography Corp seeks exemption from 14 C.F.R. 45.23, which discusses the display of 

marks. Specifically, section 45.23 states, "(a) each operator of an aircraft must display on that aircraft 

marks consisting of the Roman capital letter "N" (denoting United States registration) followed by the 

registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman 

capital letter (b) when marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot 

station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," 

"light- sport," "experimental," or "provisional," as applicable". 

Maria Galli Photography Corp will need exemption from this regulation due to the small size of the aircraft 

and that there is no cabin, cockpit, or pilot station for the aircraft. The words "Experimental" has been 

placed on the fuselage in compliance with §45.29 (f) where the pilot, observer and others working with 

the sUAS will see the identification of the UAS as "Experimental." Maria Galli Photography Corp will also 

register each aircraft in operations with a certified "N" number as required. The FAA has issued the 

following exemptions to this regulation to Exemptions Nos. 10700,8738, 10167 and 10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Maria Galli Photography Corp seeks exemption from 14 C.F.R. 61.113, which discusses private pilot 

privileges and limitations for the Pilot in command (PIC). 

Maria Galli Photography Corp is seeking exemption from this regulation, because Maria Galli Photography 

Corp believes that there is inconclusive· evidence that a person with a private pilot certificate can 

successfully maneuver a sUAS without first hand flight experience with the particular sUAS. In fact, having 

a private pilot license does not automatically ensure competence at flying an sUAS in 3'd person view as 

required to properly operate an sUAS within the required line of sight. However, we believe that the PIC 

and our FOVO (Field Operation Visual Observer) must be able to understand and correctly interact with 

the general aviation community. Therefore, we believe our own flight training with the sUAS will be more 

than satisfactory. Our PIC and FOVO will be both certified in Ground School equivalent training to be able 

to properly interact with General Aviation protocols. They will also actively pursue at minimum a sport 

pilot's license as well have the necessary medical qualifications. 

14 C.F.R. 91.103- Preflight Actions 

Maria Galli Photography Corp seeks exemption from 14 C.F.R. 91.103 which states that each pilot in 

command shall, before beginning a flight, become familiar with all available information concerning that 

flight. This information must include: (a) For a flight under IFR or a flight not in the vicinity of an airport, 

weather reports and forecasts, fuel requirements, alternatives available ifthe planned flight cannot be 

completed, and any known traffic delays of which the pilot in command has been advised by ATC; actions, 

including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft 

performance data before starting a flight. 

Maria Galli Photography Corp will be operating our sUAS in VFR. Our operations manual already includes 

preflight procedures directly pertaining to our sUAS which includes equipment checklist as well a 

preplanning details regarding weather conditions, review of any possible flight path of general aviation, 

our mission flight path and weather conditions amongst other parameters required to complete the 

mission. 
14 C.F.R. 91.105- Flight crewmembers at stations 

Maria Galli Photography Corp seeks exemption from 14 C.F.R. 91.105, which discusses flight 

crewmembers at stations. Specifically, 91.105 states "(a) During takeoff and landing, and while en route, 

each required flight crewmember shall {1) Be at the crewmember station unless the absence is necessary 

to perform duties in connection with the operation of the aircraft or in connection with physiological 

needs; and (2) Keep the safety belt fastened while at the crewmember station. (b) Each required flight 

crewmember of a U.S.-registered civil aircraft shall, during takeoff and landing, keep his or her shoulder 

harness fastened while at his or her assigned duty station. This paragraph does not apply if (1) The seat at 

the crewmember's station is not equipped with a shoulder harness; or (2) The crewmember would be 

unable to perform required duties with the shoulder harness fastened. 

Maria Galli Photography Corp will need exemption from this regulation due to the fact that the sUAS will 

not have a flight crew or crew stations other than the PIC and a FOVO. The PIC, not being in the aircraft, 

therefore will also not have to be restrained into a seat via shoulder harness or safety belt at the time of 

the flight. 

14 C.F.R. 91.109- Flight instruction; Simulated instrument flight and certain flight tests 

Maria Galli Photography Corp seeks exemption from 14 C.F.R. 91.109, which discusses flight instruction, 

simulated instrument flight, and certain flight tests. Specifically, 91.109 states "(a) No person may operate 

a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft 

has fully functioning dual controls. However, instrument flight instruction may be given in an airplane that 

is equipped with a single, functioning throw over control wheel that controls the elevator and ailerons, in 

place of fixed, dual controls, when (1) The instructor has determined that the flight can be conducted 

safely; and (2) The person manipulating the controls has at least a private pilot certificate with 

appropriate category and class ratings. (b) An airplane equipped with a single, functioning throw over 

control wheel that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight 

instruction to conduct a flight review required by §61.56 of this chapter, or to obtain recent flight 

experience or an instrument proficiency check required by §61.57 when (1) The airplane is equipped with 

operable rudder pedals at both pilot stations; (2) The pilot manipulating the controls is qualified to serve 

and serves as pilot in command during the entire flight; (3) The instructor is current and qualified to serve 

as pilot in command of the airplane, meets the requirements of §61.195{b), and has logged at least 25 

hours of pilot-in-command flight time in the make and model of airplane; and (4) The pilot in command 

and the instructor have determined the flight can be conducted safely. (c) No person may operate a civil 

aircraft in simulated instrument flight unless (1) The other control seat is occupied by a safety pilot who 

possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft 

being flown. (2) The safety pilot has adequate vision forward and to each side of the aircraft, or a 

competent observer in the aircraft adequately supplements the vision of the safety pilot; and (3) Except in 

the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning dual controls. However, 

simulated instrument flight may be conducted in a single-engine airplane, equipped with a single, 

functioning, throw over control wheel, in place of fixed, dual controls of the elevator and ailerons, when 

(i) The safety pilot has determined that the flight can be conducted safely; and (ii) The person 

manipulating the controls has at least a private pilot certificate with appropriate category and class 

ratings. (d) No person may operate a civil aircraft that is being used for a flight test for an airline transport 

pilot certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless 

the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in 

command of the aircraft". Again, Except when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an 

emergency landing without undue hazard to persons or property on the surface. (b) Over congested 

areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, 

an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or 

sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight-shift-control 
aircraft. If the operation is conducted without hazard to persons or property on the surface- (1) A 

helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, 

provided each person operating the helicopter complies with any routes or altitudes specifically 

prescribed for helicopters by the FAA; and (2) A powered parachute or weight-shift-control aircraft may 

be operated at less than the minimums prescribed in paragraph (c) of this section (a) Each person 

operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, 

by reference to an altimeter that is set, when operating-(1) Below 18,000 feet MSL, to-(i) The current 

reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If 

there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported 

altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a 

radio, the elevation of the departure airport or an appropriate altimeter setting available before 

departure; or (2) At or above 18,000 feet MSL, to 29.92" Hg. (b) The lowest usable flight level is 

determined by the atmospheric pressure in the area of operation as shown in the following table: 

Mar.ia Galli Photography Corp believes that there is inconclusive evidence that a person with a private 

pilot certificate or license can successfully maneuver or train someone to use an sUAS without first hand 

flight experience with the particular sUAS. Flying in 3rd person orientation requires built-up experience in 

that form of flying for many years. Therefore, we believe our own flight training, pilot protocols and first 

hand experiences with the sUAS as laid out in our Flight Operations Manual meets and exceeds the 

requirements necessary to safely operate our sUAS for the tasks we purpose. Also, the sUAS will be 

operated by a remote control, which will only require a single person operator and dual controls for flight 

operation will not be necessary. 

14 C.F.R. 91.119- Minimum safe altitudes: General 

Maria Galli Photography Corp seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe 

altitudes. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to 

operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming 

is planned, an exemption may be needed to allow such operations. As set forth herein, except for the 

limited conditions stated in the Manual, the UAS will never operate at higher than 400 AGL. It will 

however be operated in a restricted area with security perimeter, where buildings and people will not be 

exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the 

location where it is operated. No flight will be taken without the permission of the property owner or 

local officials. Because of the advance notice to the property owner and participants in the filming activity, 

all affected individuals will be aware of the planned flight operations as set forth in the Manual. 

Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs. 

proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than 

those presently presented with conventional aircraft operating at or below 500 AGL in the movie industry. 

In addition, the low-altitude operations of the sUAS will ensure separation between these small- UAS 

operations and the operations of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. 91.121- Altimeter settings 

Maria Galli Photography Corp seeks exemption from 14 C.F.R. 91.121, which discusses altimeter settings 

for lowest usable flight level since sUAS multirotor operations will be within this ground to low-altitude 

airspace. 

C.F.R. 91.121 states, 

Current altimeter setting Lowest usable flight level 

29.92 (or higher) 180 

29.91 through 29.42 185 

29.41 through 28.92 190 

28.91 through 28.42 195 
28.41 through 27.92 200 

27.91 through 27.42 205 

27.41 through 26.92 210 

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the 

pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number 

of feet specified below, according to the current reported altimeter setting:" 

Current altimeter setting Adjustment factor 

29.92 (or higher) None 

29.91 through 29.42 500 

29.41 through 28.92 1,000 

28.91 through 28.42 1,500 

28.41 through 27.92 2,000 

27.91 through 27.42 2,500 

27.41 through 26.92 3,000 

Maria Galli Photography Corp sUAS uses both GPS altitude and barometric sensors and relays that 

information to our ground station. However, this data is used help the sUAS to automatically maintain 

position hold at the required elevation and therefore this code is not pertinent the general functionality 

of this sUAS. 

14 C.F.R. 91.151- Fuel requirements for flights in Visual Flight Rules (VFR) conditions 

Maria Galli Photography Corp seeks exemption from 14 C.F.R. 91.151, which discusses fuel requirements 

for flight in VFR conditions. Specifically, 91.151 states "(a) No person may begin a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to 

fly to the first point of intended landing and, assuming normal cruising speed- (1) During the day, to fly 

after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. (b) No person 

may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather 

conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 20 minutes". 

Maria Galli Photography Corp sUAS has a typical mission time of less than 15 minutes with maximum 

flight time of 25 minutes per flight. Since this amount less than the 30-minute reserve minimum, this 

reserve minimum would not even make sense in allowing the sUAS a chance to fly. According to Maria 

Galli Photography Corp's aircraft flight manual under "In-Flight" section, the PIC is instructed to maintain 

flight until battery power reaches 30%, or 1

51 level warning. At this level, landing procedures will be 

initiated and the PIC will safely land the craft at the take off location. As a back up, once the sUAS reads 

10%, 2"d level warning, the flight control system automatically take over and initiates safe landing 

sequence. Maria Galli Photography Corp policy outlined in our Flight Operations Manual achieves 

satisfactory safety standards. 

Maria Galli Photography Corp believes that an appropriate and current airworthiness certificate would 

not be necessary to fly a sUAS given the size of the aircraft and the necessary level of skill needed to 

operate the aircraft. Before putting in to service, each of our sUAS goes through our own airworthiness 

procedures of minimum test flight and reliability checks. Also, our sUAS are recalibrated each at the site 

location before each flight to ensure that all systems functions as designed. Maria Galli Photography Corp 

seeks exemption from this regulation because we believe this rule was not meant for a sUAS and 

operators. 

14 C.F.R. 91.405, 91.407, 91.409, and 91.417 

Maria Galli Photography Corp seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 91.417, which 

discusses required aircraft maintenance, operation after maintenance, preventive maintenance, 
rebuilding, or alteration, inspections, and maintenance records. In Maria Galli Photography Corp aircraft 

flight manual, maintenance and inspection procedures have been established for the aircraft. Maria Galli 

Photography Corp believes these regulations are meant for manned operated aircrafts and not unmanned 

systems, therefore making them unnecessary. Nevertheless, we seek an exemption from any such 

specific provisions to the extent FAA finds it necessary to grant this request. 

(d) The reasons why granting Maria Galli Photography Corp request would be in the public interest; that 

is, how it would benefit the public as a whole. 

Maria Galli Photography Corp is classified as an engineering company by the U.S. Department of 

Transportation and provides services to aerial support for commercial interest. Maria Galli Photography 

Corp use of a sUAS can assist in making task safer and minimize human exposure to being at dangerous 

elevations. Maria Galli Photography Corp sUAS usage in the aerial photography and cinematography will 

also reduce the time required to capture the needed scenes as compared to convention helicopters or 

airplanes. Ultimately, the result is quick completion of task and reduction of dangerous elevation 

perspective needs. 

(e) The reasons why granting the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which Maria Galli 

Photography Corp seeks exemption Our Engineering department will provide a level of safety that 

exceeds the level of safety required by the FAA for its use on sUAS. The following are Maria Galli 

Photography Corp safety procedures, featur~s, regulations, and operating specifications for our sUAS: 

• Our staff shall include at minimum of a FAA-rated private or recreational flight certificate as well 

as ground school certification. 

• During operations at minimum, we will have a Pilot In Charge (PIC) and a Flight Operations Visual 

Observer (FOVO) certified under safe operations protocols. 

• The flight area of the sUAS will be observed for best take off and landing locations. Desired 

conditions include: flat and level surfaces clear of debris, at least 15ft from power lines and 

structures, and a minimum distance of 12ft from the PIC and observers. 

• The sUAS will also be in the Visual Line of Sight (VLOS) to both the PIC and FOVO during all flights. 

• Flights must take place during good weather conditions with no rain, low laying clouds, or heavy 

winds. All flights will take place during daylight hours with no night flights. 

• The PIC(s) of the sUAS will at least have 12 training hours or 24 flights accrued before being 

designated working flights. 

• All batteries must be charged completely before each flight and each flight must end when the 

battery has a 30% power level remaining. 

• A visual safety inspection will occur before each flight, testing propeller tightness, security mount 

of camera/detection equipment, remote range test, and proper safety equipment is adorned to 

PIC and FOVO. 

• The sUAS will be flown under a height of 500ft AGL. 

• No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity during a critical phase 

of flight so as to ensure that the sUAS is in a condition for safe flight operation and in a 

configuration appropriate for the purpose of the intended flight. 

• If there is more than just an operator at a site during a flight, the PIC operator and observer or 

FOVO will maintain two-way communication with each other during all operations; if unable to 

maintain two-way communications, or if any condition occurs that may otherwise cause the 

operation to be unsafe, the operator will immediately conclude the operation. 

• If the communication link is lost, the sUAS will go into fail-safe mode and safely descend to its 

designated home-point location. If the communication link is reconnected during fail-safe mode, 

control of the sUAS can be regained before landing occurs at the home-point location. 

• There is no fuel or payload to the sUAS, therefore there will be no potential explosives or risk of 
explosion if a crash occurs with the sUAS. 

• The sUAS will feature a built in compass that will be recalibrated at every site to maintain 

accurate directional readings and help in keeping the sUAS stable during flights. 

• The sUAS will record GPS location data once Ready to Fly status has been obtained. A minimum 

of 6 satellites will activate the Ready to Fly status. As well as full auto-pilot return-to-home 

feature. 

• The aircrafts to be operated will include: the DJI S1000 with a wheelbase diameter of 1000mm 

and a flying weight of less than 221bs for heavy lift, the DJI lnspire1 with a wheelbase of just 

under 600mm and less than 7 lbs flying weight for medium lift as well as a DJI Phantom 3 aircraft 

with a wheelbase of 350mm and less than 3 lbs flying weight for light lift. 

• The aircrafts vertical and horizontal aspect concerning hovering accuracy is less than 0.5m and 

1.Sm respectfully. With a maximum wind resistance of 18mph. 

• The aircraft runs off a high quality Li-Po battery. 

• A NOT AM will be issued between 48 and 72 hours before flight is to occur and will be 

coordinated with the applicable FSDO. 

(f) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The rule from which you seek the 

exemption; and (2) A brief description of the nature of the exemption you seek 

Petitioner: Maria Galli Photography Corp. 

Sections of 14 C.F.R. Affected: 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 

91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 91.407; 91.409; and 91.417 

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F .R. 21 Subpart H; 

45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii); 91.151(a)(1); 91.203; 91.405; 

91.407; 91.409; and 91.417 to perform aerial photography and videography subject to operating 

procedures that meet or exceed those that FAA requires. 

(g) Any additional information, views or arguments available to support your request 

Please see the introduction to this exemption request. 

(h) If you want to exercise the privileges of your exemption outside of the United States, the reason why 

you need to do so 

The Operations described in this exemption request will be conducted wholly within the United States. 

Attached hereto, and submitted as a confidential document, is our Field Operations Manual. We 

respectfully submit that good cause exists so that this confidential manual does not need to be published 

in the Federal Register. 
Since I will continue to be an adviser to Maria Galli Photography Corp, please do not hesitate to call or 

contact me via email at dan@AiertSintl.com if you have any questions or concerns. 

Respectfully submitted, 

Dan Q Pham, P.E. 

Principal Engineer 

AlertS International, LLC 

4302 Hollywood Blvd, #303 

Hollywood, FL 33021 

954-918-3888