Rachel Olivera

www.acorporateimage.com

rolivera@acorporateimage.com

(203) 612-5044

35 Corporate Drive, Suite 1035

Trumbull, CT 06611

U.S.	Department	of	Transportation Docket	Management	System

1200	New	Jersey	Ave.

SE Washington,	DC	20590

Re:	Exemption	Request	Under	Section	333	of	the	FAA	Reform	Act	and Part	11	of	the	

Federal	Aviation	Regulations

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,	Visual	Aerial	Pros,	seeks	an exemption	from Federal	Aviation	

Regulations	(“FARs”)	detailed	below	for (1)	3DR	Solo quadcopter	manufactured	by	3D	

Robotics and	(1)	DJI	Phantom3	quadcopter manufactured	by	DJI Innovations.

The	requested	exemption	would	support	an	application	for	a	commercial Certificate	of	

Authorization	to	use	the	system	to	support	aerial	photography and	videography. The	3DR	

Solo	(3.9lb)	and	DJI	Phantom3	(3lb)	consist of	a	battery	operated	aircraft,	a	tablet-based	

ground	control	station	and/	a RC	Controller,	and	associated communications	equipment.	

Both	aircrafts carry	an	onboard	geo-referenced	gimbaled	camera	that	allows	it	to	

obtain photography	and	videography.

The	Unmanned	Aircraft	System	will	be	operated	in	the	field	with	a	PIC	in accordance	with	

FAA	Policy	N	8900.227	Section	14	"Operational Requirements	for	UAS".

A	Corporate	Image respectfully	requests	the	grant	of	exemption	allowing	to operate	

lightweight,	remote	controlled	UAS's	lawfully	and	safely.

A	Corporate	Image also	respectfully	requests	Exemption	Request	Section 333	from	(but	

not	limited	to)	the	Specific	Sections	of	Title	14	of	the	Code	of Federal Regulations	and	part	

ll	of	the	Federal	Aviation.	Regulations	listed below.

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)

The	extent	of	relief	A	Corporate	Image seeks	and	the	reason	why:

A	Corporate	Image	is	seeking	relief	from	any	applicable	FARs	operating	to prevent	A	

Corporate	Image	from	conducting	aerial	shots	of	real	estate	and other	possible	legal flight	

operations.	The	weight	of	the	UAS	meets	the definition	of	''small	unmanned	aircraft”	

found	in	section	331	"The	Reform Act”.	A	Corporate	Image seeks	to	operate legally	as	a	
Rachel Olivera

www.acorporateimage.com

rolivera@acorporateimage.com

(203) 612-5044

35 Corporate Drive, Suite 1035

Trumbull, CT 06611

small	business	that cater	mostly	to	real	estate	agents.	Realtors	are	not	allowed	to	use	

UAS's	or hire	unless	they	or	the	person	they	hire,	is	allowed	by	the FAA	to	fly	a	UAS. A	

Corporate	Image	would	satisfy	the	need	for	safe	and	affordable	aerial shots.

At	less	than	7	pounds,	A	Corporate	Image uses	UAS	that	is	considerably less	than	55	

pounds	including	the	camera	that	is	attached.	The	UAS	will	be used	at	speeds under	35	

mph	because	of	the	nature	of	the	business	and the	limited	physical	capabilities	of	the	

UAS.	It	is	designed	to	hover	and	take pictures/video.	The	UAS	will	be	in accordance	with	

flying	well	below	400ft.

The	UAS	in	which	A	Corporate	Image would	be	using	only	utilizes	battery power	for	its	

operations.	There	are	no	combustible	fuels	used	in	the	UAS that	Visual	Aerial Pros	uses.	

The	maximum	flight	time	for	our	particular UAS	is	20	minutes	battery	life.	It	will	fly	no	

more	than	15	minutes	maximum at	one	time	at	one	location.	The amount	of	time	the	UAS	

will	be	in	the	air, less	than	400ft,	is	very	minimal.

A	Safety	system	in	place	for	A	Corporate	Image UAS	includes	a	GPS	mode that	allows	the	

UAS	to	return	home	if	communication	is	lost.	Further,	the GPS	onboard allows	the	UAS	to	

return	back	to	its	launched	position	if	the battery	life	of	the	UAS	is	low.

THE	GROUND	STATION	PART	OF	THE	SYSTEM:

A	Pilot	in	Command	(PIC)	in	operational	control	of	a	flight	operation	from beginning	to	

end	and	who	controls	the	UAS	while	in	the	air.	Additionally, the	line	of	site	of	the UAS	will	

not	leave	the	sight	of	the	PIC.

A	2.4GHz	radio	transmitter/controller	operated	by	the	PIC	to	control	the U.AS while	in	

flight;

A	radio	receiver	receiving	live	video, and	flight	data	from	the	on-board camera	and	

computer.	It	projects	it	all	in	one	screen	to	the	Pilot	in Command.

The	UAS,	weighing	less	than	7lbs	fully	loaded,	is	powered	by	batteries	and operates	with	

no	people	on	board	which lowers	the	likelihood	of	death	or serious	bodily injury.	With	a	

small	payload	consisting	of	harmless electronics	such	as	a	camera	and	GPS,	the	UASs	only	

purpose	is	to	be used	as	a	tool	to	take	pictures	and	videos.

Low	level	aerial	photos	and	video	from	several	angles	are	far	more effective	than	ground	

based	photos.	Low	level	aerial	video	and	pictures show	the	layout	of properties	with	the	

advantage	of	seeing	more	in	one photo	or	short	video.

Current	applicants	have	used	helicopters	and	small	planes	for	this	purpose but	the	cost	of	
Rachel Olivera

www.acorporateimage.com

rolivera@acorporateimage.com

(203) 612-5044

35 Corporate Drive, Suite 1035

Trumbull, CT 06611

fuel,	time,	and	emissions	of	such	aircraft	is	not	efficient enough	for	most customers	to	

afford.

The	benefits	of	reduced	cost	and	improved	efficiency	of	the	UAS	allows future	customers	

to	afford	this	service	with	a	faster	turnaround	time	at	a lesser	cost.

Additionally,	I	respectfully	request	that	A	Corporate	Image be	allowed to	use	the	UAS	to	

benefit	possible	first	responders	our	local	area	for actions	that	could benefit	the	public.	

Such	as,	fires	and	search	and	rescue.

A	Corporate	Image will	not	operate	a	UAS	near	airports	and	generally	does not	fly	over	

crowds.	Situational	awareness	is	most	important.	The	areas where	A	Corporate	Image

conducts	aerial	photography	is	predetermined which	allows	for	a	controlled	environment	

to	operate	safely.

With	allowing	A	Corporate	Image to	conduct	business	with	a	light	weight UAS,	it	could	

very	well	help	the	economy	and	benefit	people	in	first response	situations. Further,	A	

Corporate	Image	UAS	is	considerably	lighter than	the	alternative	which	is	a	helicopter	or	

small	plane.	Currently,	A	Corporate	Image has	2	UAS which	only operates	off	20	minutes	

of	battery	power. Therefore,	the	UAS	used	by	A	Corporate	Image would	only	have	a	flight	

time of	5	- 15	minutes	at	one	time.	The	likelihood	of injury	or	even	death	with such	a	small	

unmanned	aircraft,	compared	to	an	aircraft	flown	by	a	person loaded	with	combustible	

fuel,	is	considerably	low

SUMMARY:

A	Corporate	Image is	more	than	willing	to	follow	the	safety	guidelines	of	the FAA	Policy	N	

8900.227	Section	14	"Operational	Requirements	for	UAS'1 with	the appropriate	

exemptions	for	flying	a	small	UAS.

A-No	flight	will	be	made	with	a	UA	Gross	weight	exceeding	55lbs

B- All	operations	must	occur	in	FAA	Class	G	airspace	at	no	more	than	400 ft.	AGL,	at	an

airspeed	of	not	more	than	25	knots	and	no	further	than	3/4 NM	from	the	Pilot In	Charge

C- Operations	will	be	restricted	to	flights	over	private	property	with	the permission	of	the	

property	owner

D- All	required	permits	will	be	obtained	from	state	and	local	government prior	to	

operation

E- The	UAS	will	not	be	operated	over	densely	populated	areas
Rachel Olivera

www.acorporateimage.com

rolivera@acorporateimage.com

(203) 612-5044

35 Corporate Drive, Suite 1035

Trumbull, CT 06611

F- The	UAS	will	not	be	operated	at	air	shows

G- The	UAS	will	not	be	operated	over	any	open-air	assembly	of	people

H-The	UAS	will	not	be	operated	over	heavily trafficked	roads

I-The	UAS	will	not	be	operated	within	5	NM	of	an	airport	or	heliport

J- Operations	will	be	restricted	to	day	only	and	weather	conditions equivalent	to	VFR

K- The	PIC	will	notify	property	owner	about	the	operation	and	risk	before the	first	flight	at	

each	new	location;

L- No	flight	may	be	made	without	a	Pre-Flight	Inspection	by	the	PIC	before each	operation	

to	ascertain	that	the	UAS	is	in	a	condition	safe	for	flight	(see Appendix	A).

My	operations	above	are	the	bare	minimum	safety	guidelines	A	Corporate	Image will	

follow.	A	Corporate	Image is	also	more	than	willing	to	follow	any additional	

safety requirements	if	not	listed	above.

A	Corporate	Image	believes	flying	its	UAS	as	a	small	business	within	the safety	parameters	

of	the	FAA,	can	help	people	and	promote	the	economy.

The	name	and	contact	information	of	the	applicant	is:

A	Corporate	Image	and	A	Storybook	Image

35	Corporate	Drive

Suite	1035

Attn;	Rachel	Olivera

Cell	Phone:	203-258-5702

Email: rolivera@acorporateimage.com	

A	Corporate	Image respectfully	requests	that	the	FAA	grant	its	exemption request	without	

delay.	I	very	much	look	forward	working	together.	Thank	you	for your	time.

Respectfully,

Rachel	Olivera

A	Corporate	Image