U ~S r Departn1ent of Transportation, Docket Operations 

West Building Ground Floor, Room w12B140 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590 

Petition for Exe1nption Under 14 CFR § 11.81 to Allow 

Commercial Use of Unmanned Aircraft Systems 

Petitioner: Minnesota Drone Photography 

Theodore Knaeble, CEO 

621 E 19th Street 

Minneapolis, MN 55404 

Tel.; (507) 384-1856 

Email: Theo.Knaeble@gmail.com 

Website: MNDronePhotography.com 

To Whom It May CQncern, 

This application is substantially based on the FAA's findings in Exemption No. 

11351 granted tQ bizUAS Corp on April17, 2015, and exemption number 11977 

granted to Wiregrass Aerial Photography on Juiy 6 2015 and in reliance on the 

analysis provided therein. 

1. Sections from which exemptions are sought: Application is hereby made for 

exemption from; 

a. FAA Modernization and ReformActof2012, PL 112-95 FEB.14, 2012, 

Section 333 

b.14 CFR Part 21, subpart H 

c. 14 CFR Part 61.113(a) and (b) 

d. 14 CFT Part 91: 

i. 91.103(b)(2) 

ii. 91.105 

iij. 91~109 

. iv. 91.1~9 

v. 91.1~1 

vi. 91.151 

vii. 91.405 ' .l 

I '• • .' : .,_ .. _,. 
viii. 91.407 

ix. 91.409 

X. 91.417 

2. Relief sought: 

a. Minnesota Drone Photography, wishes to operate small Unmanned Aircraft 

Systems ( sUAS) for commercial purposes to include (but not be limited to) 

videography, cinematography, photogrammetry, industrial inspections and 

analyses. This relief is sought because commercial use of sUAS is currently 

prohibited by law unless performed under an exemption. 

b. This exemption will cover use of the following airframes, all of which will 

weigh less than 55 pounds including payload and energy sources: 

i. D JI Inspire 1 

ii. Other models to be added by future amendment to this exemption. 

3. Public benefit: 

a. Use of sUAS technology to obtain imagery, information and data currently 

obtained by use of manned flight or manual methods: 

i. Reduces statistical risk to human life due to manned aircraft 

accidents (e.g., power line inspections) and due to other dangerous activities 

that can be avoided (e.g., scaffolding/rigging failures during stack or bridge 

inspections). 

ii. Reduces the cost of obtaining such information, which benefits 

consumers and the economy. 

iii. Reduces environmental impact by eliminating sources of 

hydrocarbon emissions from manned aircraft. 

4. Safety not adversely affected: 

a. Aircraft will be registered and marked in accordance with Section 44 711 

and Part 4 7 and Part 45, Subpart C. 

b. Aircraft will comply with maintenance and inspection requirements of the 

manufacturer. All repair and maintenance work will be conducted or 

approved by qualified personnel such as those authorized by Robotic Skies 

(or equivalent), and will require a test flight after such work Records of all 

maintenance and repair work will be kept in a maintenance log for each 

aircraft. 

c. All flight operations will be conducted by at least two individuals (PIC and 

observer) who will maintain verbal communication capability with each 

other at all times during the flight, and who will remain stationary on the 

ground during the flight operations: 
i. A Pilot In Command (PIC) who possess the following credentials: 

1. An Airman Certificate issued under 14 CFR 61 (private pilot 

license) screened b.v the TSA 

2. A Third Class medical certificate issued under 14 CFR 67. 

3. A bi-annual flight review under 14 CFR 61.56 

4. A certificate of competency for UAS issued by UMEX (or 

equivalent certification). 

5. At least 200 cycles and 25 hours of flight experience in a UAS 

rotorcraft (or UAS fixed-wing in the case of fixed-wing flight 

operations under this exemption). Such cycles and hours may 

be gained during flights under this exemption if a safe distance 

is maintained from persons in accordance with 14 CFR 91.119. 

6. At least 5 hours of flight experience and 3 takeoffs and 

landings in make and model being flown in the prior 90 days. 

Such cycles and hours may be gained during flights under this 

exemption if a safe distance is maintained from persons in 

accordance with 14CFR 91.119. 

ii. A Visual Observer. 

iii. A Sensor Operator as necessary. 

d. All flight operations will be conducted in accordance with valid Certificates 

of Authorization. 

e. All flight operations will comply with the following: 

i. The manufacturers' Aircraft Flight Manuals and Oneration 

Guidelines 

ii. Wiregrass Aerial Photography flight operations policies including 

lost communication and other emergency and safety procedures. 

iii. Conducted in VMC conditions during daylight hours. 

iv. PIC and VO will maintain VLOS at all times. 

v. Pre-flight inspections (including ground control station, if any) and 

safety risk assessments will be conducted prior to each flight 

vi. Flight altitudes will remain below 400 feet above ground level. 

vii. Flight ground speeds will not exceed 50 knots. 

viii. Not intrude into Class B, CorD airspace, or published approach, 

SID or STAR, or take place within 5 nautical miles of an airport 

ix. Not be made near persons as required in 14 CFR 91.119 and not 

over persons on the ground without their prior permission. 

x. Each flight will be logged in both the PIC's logbook and the aircraft 

logbook. 

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 

minutes, whichever occurs first. 
xii. Any incidents will be reported to NTSB within 24 hours of 

occurrence. 

xiii. Minnesota Drone Photography will maintain liability insurance of 

at least $1,000,000 issued by a major aviation insurance underwriter. 

xiv. Any applicable local FSDO requirements. 

xv. All other applicable regulations concerned with the operation of 

aircraft. f. Aircraft will use 2.4 GHz for control of the aircraft, and 5.8 

GHz for sending data with well-defined and tested lost link 

procedures. 

Please advise of any additional information or changes that may be 

required. 

Sincerely, 

Theodore 

~~. Knaeble CEO, Minnesota Drone Photography 

July 7th 2015