April 17, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Attention: Flight Standards Service Director

Dear Mr. Duncan,

We at Photo Elevations LLC sincerely thank you for your time and consideration for the 

following review.

Re: Expedited Exemption Petition of Section 333 of the FAA Reform Act of 2012 to 

Operate Small Unmanned Aircraft Systems (sUAS) For Commercial Purposes 

Under the New “Blanketed” (COA) Below 200 feet Above Ground Level (AGL) 

policy for following Pursuant:

Photo Elevations LLC

Michael Finnegan, Owner/Operator

2508 Eagle Lane NE

Bemidji, MN 56601

218-368-1375

photoelevations@yahoo.com

I, Michael Finnegan, sole owner/operator of Photo Elevations LLC, prepared the 

following document. The use of the terms, “I” “My” “We” “Our” or “The Company” 

from here forth within this document refer to Photo Elevations LLC.

Photo Elevations LLC respectfully requests exemption from the following Federal 

Aviation Administration (FAA) regulations:

14 CFR Part 21, Subpart H, 14 CFR Part 27, 14 CFR sections 45.23(b), 61.101(e)(4) and 

(5), 61.113(a), 61.23(a) and (c), 61.315(a), 91.103, 91.105, 91.109, 91.119, 91.121, 

91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b), 

91.7(a).

About Photo Elevations LLC and UAS Commercial Applications

Based in Bemidji, MN, Photo Elevations LLC is a small, yet, rapidly growing company 

that is dedicated towards addressing a wide variety of photographic applications both on 

and off the ground. Our Aerial Division foresees an abundance of opportunity and 

discovery. Our initial requests for service have come with a strong demand from the Real 

Estate and Land Development markets. However, as the technology quickly proves its 

value, we will be heavily focused on agricultural monitoring of growth, development and 

deficiencies, as well as, commercial advertising, public safety services, such as, search 
and rescue emergencies, lake-ice safety monitoring and first responder for hazardous 

condition assessments like material spills and fires, both controlled and wild. We also 

project a wide variety of Environmental Safety and Conservation applications in the near 

future. This could include botanical and wildlife studies and safety assessments, as well 

as, forest canopy monitoring and expedited detection of invasive species like the Pine 

Bark Beetle, Emerald Ash Borer or the Forest Tent Caterpillar into Minnesota territories.

About Michael Finnegan, Owner/Operator, Photo Elevations LLC

I, Michael Finnegan, a long time advocate and hobbyist of many varied UAS’s, graduated 

from Brooks Institute of Photography, Santa Barbara, CA in 1996 with a BA in 

Illustration and Advertising Photography along with a Minor in Audio/Visual 

Photography and Videography. My pertinent collegiate resume also includes 

Meteorology courses at Montana State University. My decades experience and 

professionalism in difficult situation photography for commercial purposes is very vast. 

During my career, I have always placed public, crew and overall operational safety on the 

highest plateau. As an Ambassador of an amazingly new technology, Photo Elevations 

LLC will always strive to be an exemplary representative of proper UAS’s integration 

into National Air Space (NAS) for commercial applications. Our safety protocols and 

paramount professionalism will never be compromised.

Pilot In Command (PIC) Training Requirements

Photo Elevations LLC strongly believes the safe integration of UAS’s into National Air 

Space (NAS) is of the utmost importance and is wanting/willing to adhere to any 

additional regulations imposed by the FAA in order to maintain the NAS safety and 

security.

In order to maintain and advance those necessary safety and security protocols of an 

emerging industry, Any/All Photo Elevations LLC PIC’s must possess and complete the 

following FAA and Operator requirements before any consideration for commercial 

flight takes place:

1. All PIC’s must complete appropriate Pilot School training and pass the 

Aeronautics Knowledge Test conducted by the Federal Aviation Administration.

2. All PIC’s must be vetted by the Transportation Safety Administration (TSA).

3. All PIC’s must complete and log a minimum of 100 hours of advanced flight 

simulation time using our Real Flight Professional RF 7.5 flight simulation 

training programs.

4. All PIC’s must complete and log a minimum of 40 hours actual hands on flight 

training at our privately owned, expansive and rural located training facility.

5. All PIC’s must possess advanced safety training and knowledge, as well as, 

advanced training in Pre & Post flight planning, maintenance, checklists, etc.. 

6. All PIC’s must pass Photo Elevations LLC strictly monitored final flight tests.

The Photo Elevations LLC Operator and PIC’s would also strictly respect any/all further 

requirements and regulations set by the FAA including but not limited to the following:
1. The UAS must weigh less than 55 pounds, including payload.

2. Operations for closed-set motion picture and television filming are not permitted.

3. The UAS would never exceed a speed of 87 knots (100 miles per hour).

4. All flights are strictly limited to the current COA height of less than 200 feet

above ground level (AGL). Any higher altitudes would require a new COA 

approval from the FAA.

5. The UAS must be operated within the unaided visual line of sight (VLOS) of the 

PIC at all times.

6. The Operator is responsible for maintaining and inspecting the UAS to ensure that 

it is in a condition for safe flying.

7. Pre and Post Flight safety inspections and documentation.

8. No flight operations will be held at night and conducted under visual 

meteorological conditions (VMC).

9. The UA will not operate within 5 nautical miles (NM) of any airport with an 

operational tower; or 3 NM from an airport with a published instrument flight 

procedure; or 2 NM from an airport without a published instrument flight 

procedure or operational tower; or 2 NM from a heliport with a published 

instrument flight procedure.

10. Any UAS’s operated by Photo Elevations LLC would be properly identified by

serial number, registered in accordance with 14 CFR 47, and have (N-Number) 

markings as large as practicable.

11. The UA must remain clear and give way to all manned aviation operations and 

activities at all times.

12. The UAS may not be operated by the PIC from any moving device or vehicle.

Proposed UAS’s For Exemption and Their Physical Descriptions

Depending on our photographic, environmental safety and/or atmospheric conditional 

needs, we have three UAS’s prepared for business operations. At this time we formally 

request exemption for the DJI Phantom 3, DJI Inspire 1 and DJI Spreading Wings 

S1000+; all of which have had precedent rotorcraft UAS Section 333 exemption approval 

by the FAA. As performance and safety technologies quickly advance, we too should 

advance with them. Therefore we respectfully request the approval to update our DJI 

series systems software and hardware when need be as long as they fit within the FAA’s 

UA size and weight parameters and follow all further imposed regulations.

These are the latest models in their class from DJI, a worldwide leader in technologically 

advanced small rotorcraft, radio controlled (RC) aircraft. Each of the proposed models 

are equipped with highly advanced control and navigational features and fit within the 

prior safety requirements set forth by the FAA.

Included with this petition for exemption are the proposed model flight safety guidelines, 

battery safety guidelines and maintenance manuals for the DJI Inspire 1, Phantom Series 

and Spreading Wing S1000+ series. Due to the large size data files of the pilot training 
manual and user manuals (exceeding the 10MB file maximum allowed for online 

submissions) and prior precedent exemption grants by the FAA for each proposed UAS, 

full user manuals (containing all specifications) are not included with this petition. They

are available upon request or at the following website links:

DJI Inspire 1:

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf 

DJI Spreading Wings S1000+

http://download.djiinnovations.com/downloads/s1000_plus/en/S1000_Plus_User_Manual_v1.2_en.pdf

DJI Phantom Series: (Phantom 3 manual not yet available online)

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_

Manual_v1.8_en.pdf

DJI Pilot Training Manual:

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_Pilot_

Training_Guide_v1.1_en.pdf

UAS Radio Frequencies

All devices used will comply with the FCC usage and emissions regulations and 

guidelines. The radio frequencies used will also comply with the allotted FCC 

frequencies for data transmission and vehicle control in unlicensed frequency bands. 

(More on radio frequencies provided on the specification/user manuals included with this 

petition.)

About our Location

Bemidji is located in North-Central Minnesota. With a population of nearly 15,000, 

Bemidji is a central hub of an expansive rural territory made up of agriculture farmlands 

and dynamic forests both privately and publicly owned. Lakes, bogs and grasslands are 

also abundant. A majority of our aerial operations would take place in extremely remote, 

rural locations.

Public Safety, Privacy and Environmental Impact

Photo Elevations LLC is very excited to have our foot in on the ground floor of such an 

extraordinary and electrifying new industry. As mentioned before, flight safety is of the 

highest importance and we vow to maintain all regulations and guidelines to the highest 

standards. These standards would also adhere towards all privacy rights and 

environmental impact issues.

This new sUAS technology virtually releases both the environmental and economic 

restraints on a level never fathomed before in the aerial photography industry. 

Traditional methods of piloted aircraft for our proposed purposes are extremely 
expensive, produces high levels of toxic emissions into the atmosphere, carry large 

payloads of flammable fuel and greatly increase the risk of human endangerment. For 

those reasons, Photo Elevations LLC believes its proposed services are in the best Public 

Interest.

Our small, lightweight, micro UAS’s run on rechargeable LiPo batteries and produce zero 

toxic emissions during flight. They’re highly controllable with advanced safety features 

for stabilization, GPS navigations, electronic speed controllers, autopilot safety modes 

and real-time data transmissions and recording. Overall, the proposed UAS’s greatly 

increase public safety and benefits as compared to conventional methods of aerial 

photography. 

Pre and Post Flight Checklist/Inspections

To include, but not be limited to the following:

1. Inspect all parts and system components for proper working condition. 

 Including, but not limited to:

a. Actuators/Servos

b. All Motors

c. Wiring and Connectors

d. Propellers, cleaned, inspected for damage, mounted correctly

e. Electronic Speed Controllers 

f. Batteries Levels and Condition of all power supplies.

g. Remote Control Functions and Settings

h. Ground Station equipment and connections

 

2. Conduct preflight safety discussions and assessments regarding areas of 

concern and taking steps to minimize all safety risks prior to flight.

3. Proper clearance of NAS, if need be, and proper permission for land use.

4. Spectator, Crew and Public Safety management.

5. Must have on hand all necessary flight documents, handbooks, 

exemptions, etc.

6. All preflight inspections and operational testing recommended in the UAS 

user and operational manuals.

Conditions

Photo Elevations LLC will only conduct operational flights under ideal visual 

meteorological conditions (VMC). No flights will take place in obstructed view 

locations or during unpredictable weather conditions. No flights will be conducted less 

than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is 

less than 3 statute miles from the PIC. No flight operations will be conducted at night. 

All flights will be aborted in the event of unpredicted obstacles or emergencies.
Licensing and Supporters of Photo Elevations LLC

Photo Elevations LLC has obtained proper State and Local licensing, extensive liability 

insurance coverage, and proper Federal and State Tax Identification Numbers, as well as, 

approval support from local Law Enforcement, Bemidji Fire Dept., City Council 

Members, Local Business Owners and the Chamber of Commerce. Acceptance of this 

emerging technology is growing fast through the use of the tremendous visual benefits. 

Seeing is believing and Photo Elevations LLC wants to help show our Community a new 

vision and the amazing reimbursements that flow with.

Petition Summery

Petition Pursuant:

Photo Elevations LLC

Michael Finnegan, Owner/Operator

2508 Eagle Lane NE

Bemidji, MN 56601

218-368-1375

photoelevations@yahoo.com

Re: Expedited Exemption Petition of Section 333 of the FAA Reform Act of 2012 

Photo Elevations LLC respectfully requests exemption from the following Federal 

Aviation Administration (FAA) regulations:

14 CFR Part 21, Subpart H, 14 CFR Part 27, 14 CFR sections 45.23(b), 61.101(e)(4) and 

(5), 61.113(a), 61.23(a) and (c), 61.315(a), 91.103, 91.105, 91.109, 91.119, 91.121, 

91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b), 

91.7(a).

Proposed UAS’s: DJI Phantom 3, DJI Inspire 1, DJI Spreading Wings S1000+

Proposed Uses:

Real Estate and Land Development

Agricultural

Commercial Photography

Public Safety Services

Aerial Surveying 

Botanical and Wildlife Studies/Assessments 

Invasive Species Detection

Conclusion

Photo Elevations LLC would like to thank you again for your time and consideration. 

The FAA has granted prior exemptions in circumstances similar in all material respects to 

those presented in this petition. We strongly believe our services will greatly benefit the 

surrounding community and serve in the public’s overall best interest as a whole. For the 

preceding reasons listed throughout this petition, Photo Elevations LLC formally asks for 

these exemptions. Thank you.

Sincerely,

Michael Finnegan