LEMS ROGA Lewis Roca RothRerber t.t.P Thomas J. Dougherty 

1200 Seventeenth Street, Suite 3000 Fldmitte.d in Colorado ROTHOERBER Denvrr,C080202 (1)303.028.9524(r)303.G23.9222 

TDoughertyoDLRRLaw.com 

August 25, 2015 

U.S. Department of Transportation 

Docl<et Management System 

1200 Rlew Jersey Ave., S.E. 

Washington, D.C. 20590 

Re: Petition of Imago Visual for Grant of Exe ►r,ption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 

To Whom it May Concern: 

Pursuant to Section 333 of FAA Modernization and Reform Act of 2012 (P.L. 112-95, February 14, 

2012)(FMRA) and the provisions of 14 C.F.R. § 11.$1, Imago Visual hereby petitions for an 

exelnption from the Federal Aviation Regulations (FAR) identified herein for purposes of operating 

a small unmanned aircraft systern (sUAS) for aerial photography and videography purposes. The 

aerial photography and videography will be used for various architectural and real estate 

marketing purposes. This Petition meets all requirements for the grant of the relief requested 

herein. Furthermore, Imago Visual respectfuliy submits that this Petition qualifies for approval 

under the Federal Aviation Administration's (FAA) summary grant program (14 C.F.R. § 11.87) as it 

is consistent with numerous Petitions previously approved for substantially similar purposes, 

in support of this Petition, lmago Visual states as follows: 

Petitioner 

The Petitioner is Emilie Downs, doing business as Imago Visual. Petitioner's contact information is: 

Ernilie Downs 

Imago ilisual 

3135 W. 31st Avenue 

Denver, Colorado 80211 

Telephone: 303-929-8626 

E-Ulail Address: Emilie@imagovisual.com 

Descrit;stion of P'resposed Small Unrnanned Aircraft Systerrr Operations 

(1) Small Unmanned Aircraft System 

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AIbuqueique: I Casper I Coleradu Spr ❑7ys I Deriver I Las Vegas I Fhoen x I Reno I Silicon Ve:ilep I Tucson I hI;RLaw.com 
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Imago Visual proposes to operate the following sUAS for the purposes described in this Petition: 

DJI Inspire 1, DJI Phantom 3 Professioilal, and 3DR Solo. The design and operational characteristics 

of each sUAS are available at: DJI Inspire 1( http://www.dii.com/product/inspire-1/spec ); DJI 

Phantom 3 Professional ( http://www.dii.com/product/phantom-3/spec ); and 3DR Sola 

( http:/f3drobotics.com/soio-gopro-drone-specs/ ). 

Imago Visual will follow the manufacturers' recommended operating procedures for each sUAS. 

The rnanufacturers' recomi -nended operating procedures for each sUAS are available at: DJI Inspire 

1 ( http://download.d ]iinnovations.corri/downloads/inspire 1/en/Inspire 1 User Manual v1.4 en.pdf ); DJi Phantom 3 

Professional ( http://download.diiinnovations.com/downloads/

` phantorn 3/en/Phantom 3 Professional User Manual v1.4 en.pdf 

); 3DR Solo ( http://3drobotics.com/wp-content/uploads/2015/08/v5Og 06 15.pdf ) 

Imago Visual's proposed sUAS will utilize the following operating radio frequencies: DJI Inspire 1, 

5.725-5.825 GHz, 2.400-2.483 GHz; DJI Phantom 3 Professional, 2.400 -2.483 GHz; and 3DR Solo, 

2.4 GHz. As specified by the manufacturers, the communication distance and receiver sensitivity 

of each sUAS is as follows: DJI Inspire 1— 2,000 m and 13dBm@5.8G, 20dBm@2.4G; DJI Phantom 3 

Professional — 2,000 m and -101 dBm +/- 2 dBm; 3DR Solo — 800 m, N/A. Operation and control of 

the sUAS will comply with all applicable Federal Communications Commission regulations and any 

other applicable government agency requirements. 

Documentation concerning the design and operational characteristics, operating procedures, radio 

frequencies, maintenance, and other specifications and operating considerations of the sUAS 

Imago Visual proposes to operate has been submitted to the FAA in support of other Section 333 

Exemption 'Petitions which have been granted. l In the interest of efficiency, Imago Visual is not 

submitting additional copies of such documentation with its Petition. 

(2) Small Unmanned Aircraft System Pilot-in-Command (PIC) 

Imago Visual's PIC for the proposed sUAS operations will hold either an airline transport, 

commercial, private, recreational, or sport pilot c?rtificate. Additionally, Imago Visual's PIC will 

iiold a current FAA airman medical certificate or a valid U,S, driver's license. The PIC will also meet 

the flight review requirements specified in 14 C.F.R. § 61.56 in an aircraft in which he or she is 

rated on his or her- pilot certificate. 

- See, e.g., DJI Inspire 1(Exemption No. 12500, Docket No. FAA-2015-1256, August 18, 2015), DJI Phantom 3 

Professional (Exemption No. 12515, Docket No. FAA-2015-1445, August 19, 2015), 3DR Solo (Exemption No. 11832, 

Docket No. FAA-2015-1166, June 16, 2015) 

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(3) Small Unrr3anned Aircraft System Operations 

Imago Visual intends to operate its sUAS for the purpose of capturing videos and photos of real 

estate and multi-family housing, and to provide architects and project developers with aerial views 

of building sites. 

Imago Visual's sUAS operations will adhere to the folloNAring conditions and limitations: 

1. sUAS operations will be limited to the following aircraft: DJI Inspire 1, DJI Phantom 3 

Professional, and 3DR Solo. The unmanned aircraft will weigh less than 55 pounds including payload. 

2. No operations for the purpose of closed-set motion picture and television filming will be 

conducted. 

3. The unmanned aircraft will not be operated at a speed exceeding 87 knots (100 miles per 

hour), as determined by groundspeed or calibrated airspeed, and in no case will the unmanned 

aircraft be operated at airspeeds greater than the maximum operating airspeed recommended by 

the aircraft manur'acturer. 

4. The unmanned aircraft will be operated at an altitude of no more than 400 feet above 

ground level. 

5. The unmanned aircraft will be operated within visual line of sight (VLOS) of the PIC at all 

times using hurnan vision unaided by any device other than corrective lenses, as specified on the 

PIC's FAA-issued airman medical certificate or U.S. driver's license. 

6. AII operations will utilize a visual observer (VO). The unmanned aircraft will be operated 

within the VLOS of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC will be able to 

communicate verbally at all times, and the PIC will be designated before the flight and will not 

transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can 

perforrn the duties required of the V0, 

7. The operating documents (including this exemption and all documents needed to operate 

the sUAS and conduct its operations in accordance with the conditions and limitations stated in 

the grant of exemption) will be accessible during sUAS operations and will be made available to 

the Administrator upon request. If a discrepancy exists between the conditions and limitations in 

the exemption and the procedures outlined in the operating documents, the conditions and 

limitations of the exemption will take precedence and will be followed. Otherwise, the operator 

will follow the procedures as outlined in the operating documents. 

8. If the sUAS 11as undergone maintenance or alterations that affect the sUAS operation or 

flight characteristics, it will undergo a functional test flight prior to conducting further operations 

under the exemption. Functional test fliglits will only be conducted by a PIC with a VO and will 

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remain at least 500 feet from other people. The functionai test flight will be conducted in such a 

manner so as to not pose an undue hazard to persons and property. 

9. The operator will maintain and inspect the sUAS to ensure that it is in a condition for safe 

operation. 

10. Prior to each flight, the PIC wiil conduct a pre-flight inspection and determine the sUAS is in 

a condition for safe flight. The pre-flight inspection will account for all potential discrepancies. Ifi 

the inspection reveals a condition that affects the safe operation of the sUAS, the aircraft will not 

operate until the necessary maintenance has been performed and the sUAS is found to be in a 

condition for safe flight. 

11. The operator wili follow the sUAS manufacturer's mairrtenance, overhaul, replacement, 

inspection, and life limit requirernents for the aircraft and aircraft components. 

12. The sUAS operated under this exemption will comply with all manufacturer safety bulletins. 

13. Under this grant of exemption, the PIC will hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC wiil also hold a current FAA airman medical 

certificate or a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a 

territory, a possession, or the Federal government. The PIC will also meet the flight review 

requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate. 

14. The operator will not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the sUAS in a manner consistent with how the sUAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours and currency wili be 

logged in a manner consistent with 14 C.F.R. § 61.51(b). 

15. sUAS operations will not be conducted during night, as defined in 14 C.F.R. § 1.1. Ail 

operations will be conducted under visual meteorological conditions. 

16. The unmanned aircraft will not operate within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Directory or for airports not denoted with an 

ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, 

unless a letter of agreement with that airport's management is obtained or otherwise permitted 

by a COA issued to the exemption holder. The letter of agreement with the airport management 

will be made available to the Administrator or any law enforcement official upon request. 

17. The unmanned aircraft will not be operated less than 500 feet below or less than 2,000 

feet horizontally frorn a cloud or when visibility is less than 3 statute miles from the PIC. 

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18. If the sUAS loses communications or loses its GPS signal, the unmanned aircraft wil) return 

to a pre-determined (ocation within the private or controlled-access property. 

19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC will not begin a flight unless (considering wind and forecast weathet - conditions) 

there is enough available power for the unmanned aircraft to conduct the intended operation and 

to operate after that for at feast five minutes or with the reserve power recornmended by the 

manufacturer if greater. 

21. AII sUAS operations wilf be conducted in accordance with an ATO-issued COA or the 

"blanket" COA issued with the exemption. 

22. The unmanned aircraft operated in accordance with the exemption will be identified by 

serial number, registered in accordance with 14 C.F.R., Part 47, and have identification 

(N—Number) markings in accordance with 14 C.F.R., Part 45, Subpart C, using markings as large as 

practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the sUAS and 

any documents required under 14 C.F.R, §§ 91.9 and 91.203 will be available to the PIC at the 

Ground Controi Station of the sUAS any time the aircraft is operating. These documents will be 

made available to the Administrator or any law enforcement official upon request. 

24. The unmanned aircraft will remain cfear and give way to all manned aviation operations 

and activities at all times. 

25. The sUAS will not be operated by the PIC from any moving device or vehicle. 

26. AII flight operations will be conducted at ieast 500 feet from a!1 nonparticipating persons, 

vessels, vehicles, and structures unless: 

a, Barriers or structures are present that sufficiently protect nonparticipating persons 

from the unmanned aircraft and/or debris in the event of an accident. The operator will ensure 

that nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the unmanned aircraft, 

flight operations will cease immediately in a manner ensuring the safety of nonparticipating 

persons; and 

b. The owner/controiler of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has niade a safety assessment of the risE< of 

operating cioser to those objects and determined that it does not present an undue hazard. 

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27. AII operations will be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operationai area as defined by the applicable COA will be repor - ted to the FAA's 

UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB'Web site: 

www.ntsb.goy. 

Consistent with its business purpose of providing aerial photography and videography to property 

owners, architects, and project developers, Imago Visual will operate its sUAS over private or 

controlled-access property with the permission of the property owner or authorized 

representative with whom Imago Visual has contracted. Imago Visual's unmanned aircraft will not 

operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA 

Airport/Facility Directory or for airports not denoted with an ARP, the center of the airport symbol as 

denoted on the current FAA-published aeronauticai chart, unless a letter of agreernent with that 

airport's rnanagement is obtained or otherwise permitted by a COA issued to the exemption holder. 

The letter of agreement with the airport management will be made availabie to the Administrator or 

any iaw enforcement official upon request. 

AII Imago Visual sUAS operations wiil be conducted within the VLOS of the PIC who will be assisted 

by a VO who will also maintain the unmanned aircraft within VLOS at all times. The VO and PIC will 

be able to communicate verbally at all times. Imago Visual's PIC will conduct a pre-flight safety risk 

assessment of the intended operating area as well as a pre-flight inspection of the sUAS consistent 

with the manufacturers' recommendations. 

Imago Visual expects that it will be able to complete most of its anticipated sUAS operations 

within the 200 foot altitude authorization provided by the "blanl<et" COA to be issued with this 

exemption. To the extent Irnago Visual requires operations at a higher altitude, it will apply for 

and obtain an appropriate COA from the relevant ATO. 

Statutory Authority fmr Reguested Exemptions 

The FMRA authorizes the Secretary of Transportation to determine whether an unmanned aircraft 

system, as a result of its size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create a hazard to users of the 

national airspace system or the public or pose a threat to national security; and whether a 

certificate of waiver, certificate or authorization, or airworthiness certificate under 49 U.S.C. § 

44704 is required for the operation of the unmanned aircraft systern. (P.L. 112-95, Section 333(a)- 

(b)) If the Secretary determines that the unmanned aircraft system may operate safely in the 

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

unmanned aircraft system in the national airspace system. (P.L. 112-95, Section 333(c)) 

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Furthermore, the FAA Administrator is authorized to grant exemptions from otherwise applicable 

FARs wheri it is determined that the exemption is in the public interest. (49 U.S.C. § 44701(f)) The 

Adrninistrator may also summarily grant a petition when: the petition would not set a precedent; 

the relief requested is identical to exemptions granted previously; delaying action on the petition 

would adversely affect the petitioner; and the petition was properly filed. (14 C.F.R. § 11.87) 

Specific Federal Aviation Regulations From Which Exemptions Are Requested 

Imago Visual requests an exemption from the following provisions of the Federal Aviation 

Regulatioois for purposes of conducting the sUAS operations described herein: 

61.23(a) and (c) Medical Certificates 

61.101(e)(4)-(5) Recreationai Pilot Priviieges and Limitations 

61.113(a) Private Pilot Privileges and Limitations 

61.315(a) Sport Pilot Privileges atid Limitations 

91.7(a) Civil Aircraft Airworthiness 

91.9(b)(2), 91.203(a)-(b) Carrying Aircraft Flight Manual, Certification, and Registration 

in the Aircraft 

91.9(c) and related 45.23(b) Civil Aircraft Identification Requirements and Display 

and 45.27(a) and Location of Marks 

91.119(c) Minimum Safe Altitudes Over Other Than Congested Areas 

91.121 Altimeter Settings 

91.151(a)(1) Fuel Requirements for Flight in VFR Conditions 

91.405(a), 91.407(a)(1), Maintenance and Inspection Requirements 

91.409(a)(1)-(2), 

91.417(a)-(b) 

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Basis fcsr Reguested Exerntstions: Public Benefit, Na Adverse Safety Impacts, Equivalent Level of 

Safetv 

With respect to each exemption identified above, the following information explains why such 

exemption would benefit the public as a whole, would not adversely affect safety, and/or would 

provide a level of safety at least equivalent to the existing rule. 

61.23(a) and (c) Medical Certificates 

These FARs generally require the PIC to hold an appropriate medica) certificate to exercise pilot 

privileges. ®n March 24, 2015, the FAA announced that a third class medical certificate is no 

longer required for sUAS PICs. A sUAS PIC operating under a valid Section 333 Exemption may 

have eitlier medical certificate or a valid driver's icense. 2 Therefore, Imago Visual requests an 

exemption from the applicable medical certificate requiremerits consistent with the Section 333 

Exernptions previously granted to nurnerous appiicants for commercial sUAS operations 

substantially similar to those described herein, 3 

61.101(e)(4)-(5) Recreational, Private, and Sport Pilot Privileges and Limitations 

61.113(a), 61.315(a) 

These FARs generally prohibit a recreational, private, or sport pilot from acting as a PIC for 

compensation or hire, or in furtherance of a business. Imago Visual intends to conduct sUAS 

operations in furtherance of its business as a comrnercial marketing and branding company. The 

FAA has previously announced that commercial sUAS operations may be conducted by any person 

holding a valid sport, recreational, or private pilot certificate. 4 Therefore, Irnago Visual requests 

and exemption from the prohibition on commercial operatio ►is by a sUAS PIC holding a sport, 

recreational, or private pilot certificate consistent with the Section 333 Exemptions previously 

granted to numerous appiicants for conimercial sUAS operations substantially similar to those 

described herein. s 

91.7(a) Civil Aircraft Airworthiness 

This FAR prohibits a person from operating a civil aircraft unless it is in an airworthy condition. 

Imago Visual is not requesting an airworthiness certificate for the sUAS described herein. 

Furthermore, the FAA has determined that the sUAS PIC may assess and confirm the airworthiness 

of the sUAS prior to flight. Imago Visual's sUAS operating procedures will require and provide 

guidance to the PIC to ensure that the sUAS is in an airworthy condition prior to flight and will, 

` See httpsj- /www.faa,gpy/news/upda_tes[?newsld=f32495 

See, e.g., Exemption No. 12382, Docket No. FAA-2015-1817 (August 10, 2015); Exernption No. 12385, Docicet No. 

FAA-2105-1805 (August 10, 2015); Exemption No. 12389, Doc<et No. FAA-2015-1260. 

' See note 2 supra. 

S See note 3 supra. 

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thereby, provide an equivalent level of safiety to that otherwise required by this FAR, Therefore, 

Imago Visual requests an exemption from the civil airworthiness certification requirement 

consistent with the Section 333 Exemptions previously granted to numerous appiicants for 

commercial sUAS operations substantially similar to those described herein." 

91.9(b)(2), Carrying Aircraft Flight Manual, Certification, and Registration in 

91.203(a)-(b) the Aircraft 

These FARs generally prohibit a person from operating a civil aircraft unless an approved flight 

rnanual, rnanual inaterial, marl<ings, placards, or a combination thereof and an airworthiness 

certificate is avaiiable in the aircraft. Given the size of the sUAS identified herein, it would not be 

possible to have such information available in the sUAS. Furtherniore, having such information 

available in the sUAS provides no public benefit or safety purpose since there is no person in the 

sUAS to view this information. The FAA has clarified that "the intent of these regulations is met if 

the pilot of the unmanned aircraft has access to these documents at the control station from 

which he or she is operating the aircraft."' Imago Visual will ensure that its sUAS PIC has access to 

the relevant docurnents at the control station from which the sUAS will be operated, thereby 

providing an equivalent level of safety to that otherwise required by these FARs. Therefore, Imago 

Visual requests an exemption from the requirements to maintain these docut -nents in the aircraft 

consistent with other Section 333 Exemptions granted for comniercial sUAS operations. $ 

91.9(c) and related Civii Aircraft Identification Requirements and Display and Location 

45.23(b) and of Marks 

45.27(a) 

These FARs require that civil aircraft be identified by displaying their registration number in a 

specified manner and location. Due to the srnall size and configuration of the sUAS which imago 

Visual intends to operate, it is not possible to compiy with the marking size and location 

requirements of these FARs. The FAA has previously deterrnined that the intent of these 

requirements is satisfied provided that the sUAS have identificafiion markings that are as large as 

practicable. The sUAS to be operated by Imago Visual will display its registration number with 

marl<ings as large as practicable consistent with the requirements of 14 C.F.R., Part 45, subpart C, 

and consistent with the Section 333 Exemptions previousEy granted to numerous applicants for 

commercial sUAS operations substantially similar to those described herein. 9 

6 See note 3 supra. 

' FAA Memorandum, Interpretation regording whethercetrtain required documents may be kept ot an unmanned 

aircraft's controt station, Dean E. Griffith, Attorney, AGC-220 (August 8, 2014) 

E See, e.g., Exemption No. 12174, Docket No. FAA-2015-1851. 

' See note 3 supra. 

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91.119(c) Minirnum Safe Altitudes Over Other Than Congested Areas 

This FAR prohibits operations of an aircraft below 500 feet above the surface, except over open 

water or sparsely populated areas, and not closer than 500 feet to any person, vessel, vehicle or 

structure. Imago Visual's intended sUAS operations will involve aerial photography and 

videography of products and/or buildings. To accomplish the intended commercial purposes, 

these operations will need to occur below 400 feet above the ground and may require operations 

closer than 500 feet to the subject of the photography or videography. To ensure an equivalent 

level of safety as would otherwise be required by this FAR, Imago Visual will conduct its sUAS 

operations with the consent and cooperation of the product or building owner and in a controlled 

environment. These safety measures, together with the small size, weight, and operating speed of 

the sIJAS will ensure the safety of persons and property on the ground. Therefore, Imago Visuai 

requests an exemption from the minimum safe altitude requirements of this FAR consistent with 

the Section 333 Exemptions pr- eviously granted to numerous applicants for commercial sUAS 

operations substantially similar to those described herein. lo 

91.121 Altimeter Settings 

This FAR specifies the requirements for use of an altimeter to maintain the cruising altitude or 

flight level of an aircraft, The sUAS to be operated by Imago Visual wiil not be equipped with a 

standard altimeter. Nowever, to ensure an equivalent level of safety as would otherwise be 

required by this FAR, Imago Visual's sUAS will be operated in the VLOS of the PIC and at an aititude 

of 400 feet above the ground or lower. Furthermore, the altitude of the sUAS will be reported to 

the PIC based on GPS or other information reiayed from the sUAS to the ground control station, 

and such altitude reporting shall be confirmed as part of the preflight inspection of the sUAS. 

Therefore, Imago Visual requests an exemption from the minimum safe altitude requirements of 

this FAR consistent with the Section 333 Exemptions previously granted to numerous applicants 

for commercial sUAS operations substantially similar to those described herein. 11 

91.151(a)(1) Fuel Requirements for Flight in VFR Conditions 

This FAR requires that aircraft operating under VFR conditions must have enough fuel to fly to the 

first point of intended landing and, assuming normal cruising speed, during the day to fly at least 

30 minutes thereafter, Due to the present technological limitations of sUAS batteries, it is not 

possible to meet this requirernent and conduct reasonable commercial sUAS operations. To 

ensure an equivalent level of safety as would otherwise be required by this FAR, Imago Visual will 

operate its sUAS consistent with the manufacturer's recommended reserve power or for the 

intended operational tirne plus five minutes, whichever is greater. Therefore, Imago Visual 

requests an exemption from the minimum safe altitude requirements of this FAR consistent with 

lo See note 3 supro. 

11 See note 3 supro. 

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the Section 333 Exemptions previousiy granted to numerous applicants for commerciai sUAS 

operations substantially similar to those described herein. 12 

91.405(a), Maintenance and Inspection Requirements 

91.407(a)(1.), 

91.409(a)(1)-(2), 

and 91.417(a)-(b) 

These FARs generaliy specify the maintenance, inspection, and related records requirements for 

aircraft, consistent with the requirements of 14 C.F.R., Part 43. Part 43 applies only to aircraft with 

an airworthiness certificate and is, therefore, inapplicable to the sUAS to be operated by Imago 

Visual. Imago Visual will ensure an equivalent level of safety as would otherwise be required by 

these FARs by maintaining and inspecting its sUAS consistent with the manufacturer`s 

recommendations concerning maintenance, preventative maintenance, parts replacernent, and 

alterations, as well as any subsequently issued safety notices or bulletins. Furthermore, the sUAS 

PIC will perform prefiight inspections consistent with the sUAS operating documents. Therefore, 

Imago Visual requests an exemption from the minimum safe altitude requirements of this FAR 

consistent with the Section 333 Exemptions previously granted to nurnerous applicants for 

commercial sUAS operations substantially similar to those described herein. 13 

Federal Register Summary 

While Imago Visual requests that this Petition be granted summarily without the need for 

publication and public comment, the following summary is provided pursuant to 14 C.F.R., Part 11 

should the FAA determine that publication and comment is necessary: 

Petitioner, Imago Visual, requests an exemption from the following rules contained 

in Title 14 of the Code of Federai Reguiations: 45.23(b); 45.27(a); 61.23(a) and (c); 

61.101(e)(4)-(5); 61.113(a); 61.315(a); 91.7(a); 91.9(b)(2); 91.203(a)-(b); 91.9(c); 

91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1)-(2); and 

91.417(a)-(b). 

The requested exemptions will benefit the public as a whole by reducing the risl<s 

associated with use of manned aircraft to conduct aerial photography and 

videography, and wiil ensure that there is no adverse effect on safety by providing 

for an equivalent level of operational safety, 

' See note 3 supra. 

' See note 3 supra. 

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Conclusion 

For the reasons described herein, Imago Visual's proposed small unmanned aircraft operations will 

benefit the public as a whole, will not adversely affect safety, and will provide a level of safety 

equai to that which would otherwise be provided by the Federal Aviation Regulations from which 

exemptions are sought. Furthermore, due to the size, weight, speed, operational capability, 

proximity to airports and populated areas, and intended operations within visual line of sight, 

Imago Visual's sUAS and related operalions will not create a hazard to users of tlie national 

airspace system or the pubiic or pose a threat to national security. The relief requested herein is 

consistent with numerous Section 333 Exemptions previously granted for commercial sUAS 

operations substantiaily similar to those described herein and would not set a precedent. This 

petition has been timely filed and delay of the requested relief would adversely affect Imago 

Visual by delaying its ability to legaliy offer and provide the services described herein to the public. 

Accordiiigly, Imago Visual submits that this Petition is appropriate for summary approval pursuant 

to 14 C.F.R. § 11.87. 

Imago Visual appreciates your expeditious consideration of this Petition. Should you require any 

additional information, please contact me at 303-628-9524 or tdoughertY@Irrlaw.com . 

Sincerely, 

~ 

Thomas J. Doug erty 

LEWIS RQCA ROTHGERBER LLP 

Attorneys for Imago Visual 

TJD:jsm 

cc: Ms. Emilie Downs 

2005522519 1