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March 11, 2015

US 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 and the 

requirements contained within 14 C.F.R. Part 11, Prestige Aerial requests an exemption from 

Federal Aviation Regulations (FARs) detailed below for the 3D Robotics Inc. (3DR) IRIS+, Aero

and X8+ unmanned aircraft systems.

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

Authorization to provide aerial photography and videography services. The 3DR IRIS+, Aero and 

X8+ vehicles all utilize the same internal electronics and flight systems for consistency and 

compatibility, with the difference being different airframe configurations adapted for specialized 

applications and environments. Each vehicle carries a geo-referenced camera that allows it to 

conduct precision photography and videography services.

The managing principal of our company, and UAV pilot, is an FAA Certified Single Engine 

Land (“ASEL”) private pilot with experience in both certificated and experimental aircraft. He 

has extensive experience in flight operations in the National Airspace System (“NAS”) and is a 

member of the Aircraft Owners and Pilots Association (“AOPA”), the Experimental Aircraft 

Association (“EAA”), and the Academy of Model Aeronautics (“AMA”). In addition, he has 

participated in numerous FAA Safety seminars earning credits towards the WINGS Pilot 

Proficiency Program over the last 9 years. 

The unmanned aircraft included in this exemption will be operated in the field with both a 

Pilot in Command (PIC) and a ground-based Visual Observer (VO) in accordance with the FAA 

Policy N 8900.227 Section 14 "Operational Requirements for UAS" with the following additional 

operating restrictions:

1. All operations will occur in Class G airspace at no more than 400ft AGL

2. Operations will be operated over private property with the permission of the land owner

3. All required permits will be obtained from state and local government prior to operation

4. The aircraft will not be operated over urban or populated areas

5. The aircraft will not be operated at air shows or over an open-air assembly of people

6. The aircraft will not be operated over heavily trafficked roads

7. Operations will be limited to day and visual meteorological conditions (“VMC”)
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8. Aircraft will remain within visual line of sight at all times

9. While the aircraft is airborne, the VO will be positioned within voice distance to the PIC

10. PIC will file a NOTAM providing radial/DME, radius, and a date/time group for each 

operation

The PIC and VO will meet the requirements outlined in the FAA Policy N 8900.227 Section 16 

Personnel Qualifications. The PIC and VO will perform maintenance on the system along with 

completing an in-service on maintenance, safety procedures, and operator conduct (See 

Attachments) as part of their initial training. We do not anticipate the need for a supplemental 

pilot, due to the simplicity of the system.

We submit that the combination of strict operation under the guidelines established in 8900.227 

and the aircraft's light weight, historically demonstrated flight performance, and a fully qualified 

flight crew, the FAA can have confidence that the operation will have an equivalent or greater 

level of safety of a manned aircraft performing the same mission.

The name and contact information of the applicant are:

Prestige Aerial

Attn: Matthew Johnson

Phone: 210-509-7777

Email: mjohnson@prestigeaerial.com

The regulations from which the exemption is requested are as follows:

14 CFR Part 21

14 CFR 91.203

14 CFR 45.23, 45.29

14 CFR 91.9

14 CFR 61.113(a) & (b), 61.133(a)

14 CFR 91.109, 91.119

14 CFR 91.121, 91.151

14 CFR Subpart E (91.401-91.417)

FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. We look forward to hearing from your office. Please contact us at any time.

Sincerely,

Matthew Johnson

Founder, Prestige Aerial
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Appendices:

A. Exemption Request and Equivalent Level of Safety

B. Safety Guidelines (Safety Check Procedure)

C. Safety Log

D. UAV Operator Guidelines & Code of Conduct

E. Operations Manual IRIS+

F. Flight Checklist IRIS+

G. Maintenance Procedures IRIS+ and X8+

H. Operations Manual X8+

I. Flight Checklist X8+

J. Operations Manual Aero

K. Flight Checklist Aero

L. Maintenance Procedures Aero

M. Flight Log