Aerial Oklahoma, INC

4501 N Classen Blvd, Suite 113

Oklahoma City, OK 73118

T: +1 405 840 8977

jtyeager@aerialok.com

March 30, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590 

Re: Request for Exemption Per PL 112-95 §333 from 14 CFR 61.113(a) and (b), 

14 CFR 91.103, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 

91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 

CFR 91.417(a) and (b)

Dear Sir or Madam:

Please consider this a request for an exemption of the above applicable sections of 

title 14 CFR for Aerial Oklahoma, INC for the purpose of conducting commercial 

aerial survey and photography operations with its small Unmanned Aircraft 

System (sUAS) within controlled access airspace, using licensed airmen, and 

employing a comprehensive safety, training, and planning program. The 

employment of sUAS platforms for these missions should provide the FAA with 

good cause to find that these operations enhance safety by eliminating the need 

to use conventional aircraft in the sometimes unique environments where an sUAS 

would be particularly adept, but a conventional aircraft may pose a hazard to its 

crew and those on the ground. 

Aerial Oklahoma, INC requests exemption from the following applicable 

regulations, pursuant to the Administrator’s authority to grant exemptions 

contained in 49 U.S.C. § 106(f), 40113, and 44701: 

14 CFR 21 Part H 

14 CFR 61.113(a) and (b),

14 CFR 91.103,

14 CFR 91.109, 

14 CFR 91.119, 
14 CFR 91.121, 

14 CFR 91.151(a), 

14 CFR 91.405(a), 

14 CFR 91.407(a)(1), 

14 CFR 91.409(a)(2), 

14 CFR 91.417(a) and (b) 

OPERATION OVERVIEW 

Our current staff are professionally trained airmen with commercial and ATP 

privileges and have thousands of hours experience with the regulations and 

operations of the National Airspace System, ensuring an equivalent, if not greater 

level of safety. 

Our operations utilize sUAS in a manner that provides services not offered by 

manned aircraft or enhances the level of safety at which the tasks can be 

completed in manned aircraft 

Examples of the proposed aerial photography operations include both real estate 

and insurance damage assessment. Both operations restrict the use of the sUAS 

to a small area typically encompassing a limited number of residential and 

commercial properties at a time. The areas in which the flight takes place can 

readily be protected with secured access by the staff of Aerial Oklahoma INC, 

comparable to that of a movie production set. The structures on these properties 

provided sufficient protection from the sUAS and can be completed with much less 

risk than what would be assumed in a manned operation at low altitudes.

Our intended film production operation would typically include both photography 

and videography for commercial purposes including promotional video and 

commercial production for businesses. These events are restricted to only the 

invited participants and are closed to the general public, providing the opportunity 

to operate only in an area where informed, consenting participants and personnel 

are present. By adhering to the restrictions and exemptions previously established 

to movie production entities Aerial Oklahoma, INC will be able to provide a level of 

safety equal to or greater than the manned aircraft that would typically provide 

these services.

Finally, our survey operation includes the orthomosaic mapping of both agriculture 

and construction sites utilizing our sUAS rotorcraft flying pre-programmed grids 

that can be interrupted and returned to a safe landing zone by our FAA certified 

pilots at any time. Currently these operations are executed by general aviation 

aircraft carrying hundreds of pounds of fuel and equipment flying at low altitudes 
and speeds. Our operation would greatly increase the level of safety, replacing 

large aircraft with an sUAS under 6.5 pounds and restricted to speeds no greater 

than 43 knots. These sites are areas that can readily be secured by Aerial 

Oklahoma personnel and would not provide any additional risk to the general 

public. 

All of Aerial Oklahoma, INC operations will be performed by FAA licensed pilots 

with trained Visual Observers and, where necessary, Site Security Coordinators, in 

controlled and secured environments only after a safety assessment has been 

completed and approved risk mitigation practices to a level equivalent to or less 

than the previous granted exemptions to the motion picture industry. 

Any operations under the exemption would be conducted in accordance with the 

strict parameters specified herein.

AIRCRAFT 

Aerial Oklahoma, Inc will operate the four-rotor DJI t600 aka DJI Inspire 1 sUAS 

which is a commercially available off-the-shelf sUAS. The sUAS is rotocopter 

configuration and will weigh no more than 6.5 pounds. It will operate no faster 

than 43 knots groundspeed. The aircraft are agile, having the ability to hover, and 

move about its three axes simultaneously. The aircraft will be operated below 400 

feet Above Ground Level (AGL) and continuously within the Pilot in Command’s 

(PIC) line of sight, so as to not create a hazard to users of the national airspace 

system or public. The aircraft is equipped with failsafe protocols that return the 

aircraft to a predetermined point and land if any abnormalities are present. 

Because of the sUAS’ specifications and flight characteristics, it poses no threat to 

national security. 

These limitations and conditions that Aerial Oklahoma, INC agrees to be bound to 

include: 

1. The sUAS will weigh less than 6.5 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 15 minutes.

Flights will be terminated at 25% battery power reserve should that occur

prior to the 15 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL.
5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual

Observer and based on results of the safety assessment may include a

security coordinator

6. sUAS pilot will be an FAA licensed airman with at least a private pilot’s

certificate and third class medical. The observer will hold at least a third

class medical.

7. The UAS will only operate within a confined “Sterile Area” where Aerial

Oklahoma, INC have control over an person and or property that will be

operated near and/or above.

8. A briefing will be conducted in regard to the planned sUAS operations prior

to each mission. It will be mandatory that all personnel who will be

performing duties within the boundaries of the safety perimeter be present

for this briefing.

9. The operator will file a FAA Form 7711-1, or its equivalent, as modified in

light of the requested exemption, with the appropriate Flight Standards

District Office.

10. The operator will obtain the consent of all persons involved in the filming

and ensure that only consenting persons will be allowed within 30 feet of

the flight operation. This radius may be reduced further based upon an

equivalent level of safety determination with the advanced permission of

the relevant FSDO.

11. The operator will submit a written Plan of Activities to the FSDO three days

before the proposed shoot unless otherwise advised by the FSDO.

12. Pilot and observer will have been trained in operation of UAS generally and

received up-to-date information on the particular UAS.

13. Observer and pilot will at all times be able to communicate by voice

14. Written and/or oral permission from the relevant property holders will be

obtained.

15. All required permissions and permits will be obtained from territorial, state,

county or city jurisdictions, including local law enforcement, fire, or other

appropriate governmental agencies.

16. If the sUAS loses communications or loses its GPS signal, the UAS will have

capability to return to a pre-determined location within the Security

Perimeter and land.

17. The sUAS will have the capability to abort a flight in case of unpredicted

obstacles or emergencies.
sUAS CONTROL 

The control of the sUAS will be through a Radio Transmitter and Receiver 

manufactured by DJI Industries operating on the 2.4ghz and 5.8ghz spectrum. 

The DJI C1 Control System is FCC approved and provides range of greater than 

2km. The Control Link system also provided telemetry status of the link strength 

and critical flight information on its built in display. 

sUAS PAYLOAD 

The DJI t600 is designed to carry it’s purpose built camera system which is fully 

integrated into the design of the sUAS platform. Any change from a known 

configuration will result in a notation in the aircraft log from a company approved 

technician and in accordance with Aerial Oklahoma, INC’s Flight operations 

manual Section 5.6. Prior to resuming commercial operations the sUAS will be 

flight tested in accordance with our maintenance procedures outlined in our FOM. 

AIRWORTHINESS CERTIFICATION 

The sUAS to be operated by Aerial Oklahoma, INC weight less than 10 lbs. fully 

loaded, carries neither a pilot nor passenger, carries no explosive materials or 

flammable liquid fuels, and operates exclusively within a secured area as set out 

in the FOM. Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by the operator, pursuant to the FOM’s 

requirements and will provide a greater degree of safety to the public and 

property owners than conventional operations conducted with airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these 

same criteria demonstrates that there is no credible threat to national security 

posed by the UAS, due to its size, speed of operation, location of operation, lack 

of explosive materials or flammable liquid fuels, and inability to carry a substantial 

external load. 

FLIGHT CREW

Flight Crew (14 CFR 61.113 (a) and (b)) “Flights are planned and coordinated in 

accordance with manual.” Prior to flight, the PIC and Visual Observer (VO) (“flight 

crew”) will have completed the qualification process as outlined in the operator’s 

manual. The Pilot in Command will possess, at minimum, a private pilot’s 
certificate, meet applicable recent flight experience requirements and hold at least 

a third class medical. The Visual Observer will be trained in accordance with the 

company’s FOM and will undergo routine competency checks.

PREFLIGHT ACTION

In accordance with 14 CFR 91.103, the PIC will, at minimum, receive a weather 

briefing, survey the launch and recovery environments and review takeoff and 

landing distances and other applicable aircraft performance data, check the 

aircraft and ground station/transmitter battery levels, and brief the Visual 

Observer (VO) and any other supporting crew on the mission, safety, and 

contingencies. All flights will be conducted in Day VMC conditions. Minimum flight 

crew shall include the PIC, Visual Observer to assist with seeing-and-avoiding 

other aircraft, a Site Security Coordinator as determined by preflight risk analysis. 

FLIGHT INSTRUCTION

Flight Instruction (14 CFR 91.109), No pilot or passengers will be carried aboard.

MINIMUM SAFE ALTITUDES

Aerial Oklahoma, INC requests authority to operate at altitudes up to but not 

exceeding 400 feet AGL within a specifically defined, controlled, restricted 

perimeter per 14 CFR 91.119. Aerial Oklahoma, INC will establish and maintain a 

security perimeter for the purpose of protecting structures and people not 

associated with the operation. In establishing the security perimeter, Aerial 

Oklahoma, INC will receive the permission of the owner of the property upon 

which the ground crew will stage and above which the aircraft will operate, and at 

no time will the sUAS be operated directly over a person. Should the flight take 

place over public lands, Aerial Oklahoma, INC will obtain the permission of the 

governing body of jurisdiction. Obtaining permission to operate will serve as 

notification to the property owner or governing body that operations will be taking 

place. The sUAS will be continuously operated at an altitude which will allow a 

safe descent and recovery should a mechanical issue arise. 

ALTIMETER SETTING

The sUAS does have an internal barometric altimeter along with GPS altimeter. In 

meeting 14 CFR 91.121, an equivalent level of safety provided is by preflight 

action where the PIC will compare the GPS altimeter with the MSL altitude of the 

safe operating perimeter as ascertained by applicable aeronautical and 
topographical charts and make an calibration as necessary. If GPS signal is lost, 

the sUAS will use the internal barometric altimeter as a failsafe along with the 

vertical distance sensors inherent with the DJI t600’s design (DJI Vision 

Positioning Technology) to return to the predetermined safe area.

FUEL REQUIREMENTS

Aerial Oklahoma, INC seeks exemption from 14 CFR 91.151(a). The sUAS is 

powered by a battery, which provides up to 20 minutes of powered flight. Because 

of the absence of flammable operating fluids, an sUAS would not pose the same 

level of risk as a conventional aircraft. All participants in safe operating perimeter 

have been informed and educated, and have indicated consent. All Aerial 

Oklahoma, INC PICs will terminate flights when remaining battery power level 

reaches 25%. 

sUAS MAINTENANCE

Aerial Oklahoma, INC requests exemption from 14 CFR 91.405(a), 14 CFR 

91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) and (b). The sUAS does 

not have an airworthiness certificate. Aerial Oklahoma, INC and/or DJI North 

America will conduct all maintenance on the sUAS in accordance with the flight 

operations manual and pilot operating handbook. All maintenance will be 

conducted by a trained Aerial Oklahoma, INC associate. Because of relatively 

small operating perimeter, any mechanical issues that may arise during flight 

could be quickly mitigated by terminating the flight. 

Privacy

Because the purpose of operation is commercial, the consent to operate on a 

property or establishment of a contract would imply consent from the owner or 

authority with jurisdiction. Film or photos would only be taken of people who 

consent. 

 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 

2012 (size, weight, speed, operating capabilities, proximity to airports and 

populated areas and operation within visual line of sight and national 

security) provide more than adequate justification to grant Aerial 

Oklahoma, INC’s requested exemption, allowing for Aerial Oklahoma, INC

sUAS commercial operations for the purpose of photography, film and 

survey.
Sincerely, 

Jamin T Yeager

CEO 

Aerial Oklahoma, INC

 

 Jamin Yeager