May 20,20 15 

Aerial Earth PhotoDrones LLC 

3700 Dean Drive #2802 

Ventura, CA 93003 

US Department of Transportation and 

Federal Aviatjon Adminjstration 

800 Independence Avenue, S.W. 

Washington, DC 2059 1 

Attn: Dan Ngo, Program Analyst, Aircraft & Airport Rules Division 

Re: Docket No. FAA-2015-0196 

Petition for Authorization/Permit 

US Congress PL 112-95,2012, Section 333, FAA Reform 

Act, for limited, safe and responsible commercial use of 

Small Unmanned Aircraft (SUA) 

Thank you for responding to my petition for waiver of the above Section 333. I would like to 

state that I would like a temporary waiver until the certification process is approved and 

available. At that time, I will gladly apply for the certification as stated in Section 333. Until 

then, I do request a waiver. Per your request for further explanation under Title 14, Chapter 1, 

Subchapter B, Part II , Subpart A, § 11.81 , I will provide the necessary answers below. 

• The specific section or sections of 14 CFR from which I seek relief and the extent of the 

relief I seek. Please find brief explanations in Appendix A. 

14 C.F.R. Part 21 

14 C.F.R. 45.23(b 

14 C.F.R. 61.113(a) & (b 

14 C.F.R. 6 1.133(a) 

14 C.F.R. 9 1.7(a) 

14 C.F.R. 9 1.9(b)(2) & (c) 

14 C.F.R. 9 1.103 

14 C.F.R. 91.109(a) 

14 C.F.R. 9 1.119 

14 C.F.R. 9 1.203(a) & (b) 

14 C. F. R. 9 1. 3 19( a)( I ) 

14 C.F.R. 91.405(a) 

14 C.F.R. 91.407(a)( l) 

14 C.F.R. 91.409(a)(2) 

14 C.F.R. 91.417(a) 

• Reasons why granting the request would be in the public interest~ that is, how it would 

benefit the public as a whole. 

By obtaining a temporary waiver to permit commercial operations, Aerial Earth 

PhotoDrones LLC would perform aerial surveys of archaeological, environmental, power 

company (oil fields, gas and oil pipelines, land survey, leak detection, etc.), including 
Aerial Earth PhotoDrones LLC 

3700 Dean Drive #2802 

Ventura, CA 93003 

photography, survey and visual inspection without requiring ' boots on the ground' survey 

work over possible hazardous or sensitive terrain. This benefits not only the people 

involved for safety reasons, but also the public since a quick aerial survey could detect 

possible dangerous or hazardous conditions. For instance, an aerial survey over the 

landscape could locate possible fire danger (since California is in a severe drought) and 

eliminate the need of humans or equipment to enter these drought locations, could locate 

threatened or endangered species of plants (thereby preserving habitat) and again 

eliminate the need of humans to impact the area, fi nd critical habitat that is threatened 

due to the ongoing drought or human carelessness, or detect leaks or impending leaks in 

pipelines. By using a small and efficient quadcopter, the necessity for human personnel 

or conventional aircraft is eliminated. This means a more economical, quick and safe 

means to obtain vital information. 

• Any additional information, views, or arguments available to support your request. 

As a licensed private pilot, and the holder of two Bachelor degrees in Archaeology and 

Environmental Resource Management/Conservation Biology, and on my third year of 

graduate school for my Master of Arts degree in Archaeology, along with more than 

fifteen years experience as an archaeologist, conservation biologist, and water resource 

management specialist, I believe I am in a unique position as a woman-owned business to 

perform the above-mentioned duties. I have already received several requests to perform 

aerial photography of two archaeological sites and have contacts with several 

environmental consultants and power companies for additional survey work. If granted a 

temporary waiver to use my unmanned aerial aircraft for commercial purposes, I can 

begin these jobs immediately. 

I also have a business license and all necessary documents filed for my business. My quadcopter, 

and proposed future purchase of a hexacopter, are both under 55 pounds, as stipulated by the 

proposed statute, will be used for day time use only, with visual-line-of-sight operations, under 

400 feet AGL. 

Thank you very much for your time. If you require any additional information, please do not 

hesitate to contact me. My phone number is 805-861-9800 and my email is 

gai I bellenger@yahoo. com. 

Sincerely, 

t{~~ Gail Bellenger 

Ovmer, Aerial Earth PhotoDrones LLC 

3700 Dean Drive, #2802 

Ventura, CA 93003 

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Aerial Earth PhotoDrones LLC 

3700 Dean Drive #2802 

Ventura, CA 93003 

A()Jlendix A 

14 C.F.R. Part 21, Subpart H: Ainvorthiness Certificates 

14 CFR § 91.203(a)(l) 

Due to the size and weight (under 10 pounds) and the limited area of operation of my DJI 

Phantom 2 Vision+ Quadcopter (and future hexacopter), I request that this certification be 

waived under Part 21 Subpart H. This would abide by safety measures under Part 11 and Section 

333 of the Refonn Act. 

14 C.F.R. § 45.23 & 91.9(c): Marking of the Aircraft 

As the DJl Quadcopter is a small, unmanned vehicle, containing its' serial number located under 

the battery bay, with ample room for future registration numbers and/or appropriate additional 

markings to be affixed, Aerial Earth PhotoDrones LLC will mark the quad with whatever marks 

are appropriate to designate inspection or registration in the future. The FAA has previously 

issued the following exemptions to this regulation, see Exemption Nos. 8738, I 0 167, I 0167 A 

and 10700. 

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations. 

Aerial Earth PhotoDrones LLC, does not operate any aircraft that carries a pilot or passengers 

and is, in fact, controlled remotely with a handheld transmitter. However, I personally do hold a 

private pilot certificate (93504636). I request exemption from this rule to allow additional pilots, 

after training, to operate the quad. The DJI Quadcopter is associated with a smart phone/personal 

computer application that displays battery life, altitude, aircraft climbing speed and flight speed, 

and is equipped with a fail-safe automatic aircraft return to home feature should the battery fail 

or deplete. The is a warning light set-up to notify the operator should the GIS or Wi-Fi system 

not be operating correctly. 

14 C.F.R. § 91.7(a): Civil aircraft airworthiness. 

I will personally maintain the quadcopter to assure it is undamaged and ainvorthy at all times, 

including a visual pre-flight check prior to each and every flight. DJI, the manufacturer of the 

quadcopter has a solid safety reputation. Aerial Earth PhotoDrones LLC also has a drone copter 

repair facility nearby should any damages occur. 

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. 

Due to the small size of the Phantom 2 Vision+ Quadcopter, it is not possible to carry a flight 

manual aboard, however, the flight manual is always available while flying. The FAA has 

previously issued the following exemptions to this regulation: Exemption Nos. 

8607,8737,8738,9299, 9299A, 9565,95658,10167, 10167A, 10602,32827, and 10700. 

14 C.F.R. § 91.103: Preflight action 

Aerial Earth PhotoDrones LLC always conducts a preflight check of the quadcopter prior to any 

flight. The instruction manual is always available and carried onsite. 

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Aerial Earth PhotoDrones LLC 

3700 Dean Drive #2802 

Ventura, CA 93003 

14 C.F.R. § 91.109(a) & 91.319(a)(l): Flight Instruction 

The Phantom 2 Vision+ Quadcopter is controlled via a single remote transmitter. The quadcopter 

is programmed via software equipped with waypoints or by line-of-sight via the transmitter 

controller. The FAA has previously exempted this requirement, Exemption Nos. 5778K & 

9862A. 

14 CFR § 91.119: Minimum Safe Altitudes 

To abide by this regulation, Aerial Earth PhotoDrones LLC never flies above 400 feet AGL, 

within five miles of any airport, over populated areas or people. Due to the purpose of relatively 

low-flying aerial photography and survey, I am requesting an exemption from Section 91.119(c). 

Permission to fly over privately held land will be obtained by the landowner or manager ahead of 

any flight. 

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

Aerial Earth PhotoDrones LLC requests waiver of this regulation due to the fact that the 

Phantom 2 Vision+ Quadcopter is small, unmanned and does not have the capacity to carry or 

display certificates in a location visible for the flight crew, as the operator especially remains on 

the ground. Any and all necessary certificates will remain with the operator or within close 

proximity. There have been previous exemptions to this regulation. 

14 C.F.R. § 91.40S(a); 407(a)(l); 409(a)(2); 417(a): Maintenance Inspections 

As the Phantom 2 Vision+ Quadcopter does not regularly require routine maintenance and has 

the capacity to perform its own systems verification, with alerts if there are any problems, Aerial 

Earth PhotoDrones LLC requests a waiver for this regulation. A pre-flight check is always 

performed by the operator prior to any and all flight, which includes a systems check, visual 

inspection of the quadcopter and verification that all batteries and equipment are fully charged 

prior to flight. 

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