December 6, 2015

U.S. Department of Transportation Docket Management System 1200 New 

Jersey Ave., SE Washington, DC 20590 

Petition of AERIA MEDIA LLC for Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012. 

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 

14 CFR Part 11, AERIA MEDIA LLC, hereby applies for an exemption from 

Federal Aviation Regulations (FARs) identified below, to allow commercial 

operations of small-unmanned aerial system (i.e., sUAS).

This exemption is in accordance with protocols outlined in this petition for 

exemption, the enclosed, the DJI UAS manufacturer’s operations and/or 

instructions manual, DJI UAS User’s Manuals, DJI UAS Quick Start Guides, and 

any other requirements established by the FAA pursuant to Section 333 of the 

Reform Act.

This exemption would permit commercial operation by AERIA MEDIA LLC, which 

uses the DJI Inspire1 and DJI Phantom 3 Professional to conduct agricultural 

and conservation research, real estate photography and videography, local 

promotional photography and videography to promote tourism, news gathering, 

fire and rescue, aerial mapping and survey, wildlife research and potential realtime waterborne predator threat detection and warning. AERIA MEDIA LLC’s 

operation under the exemption will be subject to strict operating requirements 

and conditions to ensure safety at all times and under conditions as may be 

modified by the FAA as required by Section 333.

UAS’s operated by AERIA MEDIA LLC will be operated under controlled VFR 

conditions at low altitude in airspace that is permitted in accordance with AERIA 

MEDIA LLC’s approved Certificate of Authorization (COA). Finally, the FAA ATC 

will approve the airspace in which the sUAS will operate in advance. 

AERIA MEDIA LLC respectfully submits this request for an exemption because it 

wishes to operate sUASs. The operations AERIA MEDIA LLC will be conducting 

will be in lieu of comparatively hazardous operations now conducted by others 

using fixed wing and rotary conventional aircraft. The FAA can have confidence 

that the operations will be conducted at an equivalent level or greater level of 

safety than those providers. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities under Section 333 of the Reform Act to “establish requirements 

for the safe operation of such aircraft systems in the national airspace system.”

For your convenience, AERIA MEDIA LLC has organized this Exemption request 

as follows: 
I. Petitioner’s Description

II. Relevant Statutory Authority 

III. Qualifications for Approval Under Section 333 of the Reform Act IV. 

Description of Proposed Operations

V. Regulations From Which Exemption is Requested

VI. Public Interest 

VII. Privacy

VIII.Federal Registry Summary IX. Conclusion 

I. Petitioner’s Description:

AERIA MEDIA LLC is headquartered in the City of Huntington Beach,CA, is a 

company that wishes to provide sUAS support to news services, real estate 

photography and videography, local promotional photography/videography, 

construction photography, mapping and surveying and assist coastal jurisdictions 

in monitoring for the presence of large oceanic predatory animals in an effort to 

notify beachgoers of their presence. AERIA MEDIA LLC intends to operate in a 

compliant and safe environment. AERIA MEDIA LLC plans on providing a wide 

range of services as the sUAS market expands.

AERIA MEDIA LLC’s goal is to operate in an accident-free environment by: 

• Demonstrating a commitment by the petitioner to operate in a compliant 

manner.

• Identify hazard and risk while eliminating or controlling all these risks. 

Petitioner will intervene and report when unsafe work practices or 

conditions appear to exist. 

• Train all support personal involved in flight operations to perform at the 

highest standard level. 

The contact information for Petitioners is as follows: 

Paul Hefferon

AERIA MEDIA LLC 

316 16th Street #12

Huntington Beach, CA

ph. 530-228-2049

Email: paul@aeriamedia.com

II. Relevant Statutory Authority:

This petition for exemption is submitted to fulfill Congress’ goal in passing 

Section 333(a) through (c) of the Reform Act. Congress has directed the FAA “to 

safely accelerate the integration of civil unmanned aircraft systems into the 

national airspace system.” Pursuant to Section 333 of the Reform Act, the FAA 

Administrator is to consider whether certain unmanned

aircraft systems may operate safely in the National Airspace (“NAS”) before 
completion of the formal UAS rule-making, based on the following 

considerations:

• The UAS’s size, weight, speed, and operational capability

• Operation of the UAS in close proximity to airports and populated areas

• Operation of the UAS within the visual line of sight of the operator 

If the Secretary determines that such vehicles “may operate safely in the National 

Airspace System, the Secretary shall establish requirements for the safe 

operation of such aircraft in the National Airspace System”. 

Additionally, the FAA Administrator has general authority to grant exemptions 

from its safety regulations and minimum standards when the Administrator 

decides a requested exemption is in the public interest. A party requesting an 

exemption must explain the reasons why the exemption: (1) would benefit the 

public as a whole, and (2) would not adversely affect safety (or how it would 

provide a level of safety at least equal to the existing rules). 

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority, by its terms, includes exempting civil 

aircraft, as the term is defined under 40101 of the Act, from the requirement that 

all civil aircraft must have a current airworthiness certificate and those regulations 

requiring commercial pilots to operate aircraft in commercial service: 

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any of sections.

 

III. Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for expedited 

approval under Section 333 of the Reform Act.

The proposed operations would permit AERIA MEDIA LLC the use of small UAS 

systems under controlled conditions in airspace that is: (1) predetermined; and 

that (2) provides an Increased level of safety beyond that existing when fixed or 

rotor wing aircraft are used by others to accomplish the same purpose. 

AERIA MEDIA LLC submission places a duty on the Administrator to not only 

process applications for exemptions under Section 333, but for the Administrator, 

if he deems the conditions proposed herein require modification in order to allow 

approval, to supply conditions for the safe operation of the sUAS. AERIA 

MEDIALLC welcomes the opportunity to consult with FAA staff in order to

address any issues or concerns that this proposal may raise that they believe 

may require modification.

AERIA MEDIA LLC will use UASs that are multirotor, weighing less than 55 

pounds including payload. They will operate, under normal conditions, at speeds 

not to exceed 50 mph. The multi rotors have the capability to hover and move in 

the vertical and horizontal plane. Additionally the DJI Spreading Wings has 

redundancy built in that allows it to maintain safe flight even with the loss of a 

motor. AERIA MEDIA LLC’s UASs will operate in line of sight and during daylight 
hours. Real Help Inc will operate at or below 400 feet AGL. All required 

permissions and permits would be obtained from territorial, state, county or city 

jurisdictions, Including local law enforcement, fire, or other appropriate 

governmental agencies prior to operating a sUAS.

 

Given the small size of the sUAS involved and the environment within which they 

will operate, this AERIA MEDIA LLC’s exemption falls within the zone of safety 

and demonstrates an equivalent level of safety, in which Congress desired the 

FAA to permit commercial UAS operations by exemption pending completion of 

formal rule- making. Also, due to the size of the sUAS and the confined area in 

which the sUAS will operate, approval of the application presents no hazard in 

the NAS. 

Considering the clear direction in Section 333 of the Reform Act, the authority 

contained in the Federal Aviation Act, as amended, the equivalent level of safety 

surrounding the proposed operations, and the significant public benefit, the grant 

of the requested exemptions is also in the public interest.

 

IV. Description of Proposed Operations

To assist the FAA in its safety assessment of AERIA MEDIA LLC’s proposed 

sUAS operations, below is a summary of operational limitations and conditions 

that will ensure an equivalent or higher level of safety to operations conducted 

under current regulatory guidelines: 

1. The sUAS will weigh less than 55 pounds.

2. Flights will be operated within line of sight of the PIC and visual observer.

3. Maximum total flight time for each operational flight will be limited to the 

amount of time the sUAS can be flown and still maintain a reserve battery power 

of no less than 30%.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Flights will be operated at a lateral distance of least 100 feet from any 

inhabited structures, buildings, vehicles, vessels, people not associated with the 

operation or who have not signed a waiver in advance of the operation.

6. Minimum crew for each operation will consist of the sUAS PIC (and a Visual 

Observer/

Camera Operator when appropriate).

7. The sUAS PIC will be the petitioner Derick Travis Jack.

8. AERIA MEDIA LLC will designate a Pilot in Command (“PIC”) for each 

mission.

9. The sUAS will operate only within a confined safe and uncongested area.

10. Prior to the operations at a particular location, a site inspection will be 

conducted. On the

day of the mission the management person with operational control and the PIC 

will concur on performing the mission after reviewing all safety issue compliance.

11. Prior to initiating each mission a briefing will be conducted in regard to the 

planned sUAS operations. It will be mandatory that all personnel who will be 
performing duties within the boundaries of the safe and uncongested area be 

present for this briefing. 

12. AERIA MEDIA LLC’s crew will use a safety and airworthiness checklist. 

13. The sUAS will be maintained in compliance with the manufacturer’s 

guidelines. 

14. In the event of an accident involving a AERIA MEDIA LLC sUAS, petitioner 

will cease operations and report the accident to the NTSB and AFS-80.

15. PIC and VO will at all times be able to communicate by voice.

16. PIC, Camera Operator, VO, and Operational Personnel will have been 

trained and tested by the petitioners.

17. All required permissions and permits would be obtained in advance from 

territorial, state,county or city jurisdictions, including local law enforcement, fire or 

other appropriate governmental agencies.

18. In compliance with approved exemption, AERIA MEDIA LLC management 

will submit a written “Plan of Activities” to the local Flight Standards District Office 

(FSDO) having jurisdiction over the area of proposed filming three days in 

advanced of operations during film or movie productions.

19. If the sUAS loses communications signal, the sUAS will have the capability to 

return to a pre-determined location within the safe and uncongested area.

20. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the pilot and the observer.

21. The sUAS has the capability to abort a flight in case of unpredicted obstacles 

or emergencies.

22. AERIA MEDIA LLC, will assure no individuals’ privacy is violated.

23. Procedures have been established to contact ATC prior to operating in 

airspace other than G. 

V. Regulations From Which Exemption is Requested 

A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot 

in Command

B. 14 CFR § 91.103: Preflight Action

C. 14 CFR § 91.113: Right-of-Way Rules 

D. 14 CFR § 91.119 ©: Minimum Safe Altitudes

E. 14 CFR § 91.121: Altimeter Settings

F. 14 CFR § 91.151(b): Fuel Requirements for Flight in VFR Conditions

G. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections

 

A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot 

in Command

 

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the DJI sUAS’s

are remotely controlled with no passengers or property of others on board. 
AERIA MEDIA LLC respectfully proposes that the FAA should take into account 

the characteristics and procedures of the particular UAS. 

AERIA MEDIA LLC proposes that the actual operation of the DJI sUAS does not 

require the Pilot to hold a private pilot certificate. AERIA MEDIA LLC proposes 

the following requirements:

• Pilot in Command Requirements: 

1. The PIC must have accumulated and logged a minimum of twenty (20) hours 

as UAS pilot with the make and model of UAS to be utilized for operations 

under the exemption and three takeoffs and landings in the preceding 90 days. 

2. The PIC must have successfully completed the qualification process as 

required by the petitioner, to include a knowledge and skill test. 

B. 14 CFR § 91.103: Preflight Action 

AERIA MEDIA LLC requests an exemption from the preflight actions 

requirements of 14 CFR 91.113 that prescribes the preflight actions under which 

aircraft may operate:

 

The Petitioner shall, before beginning a flight, become familiar with all available 

information concerning that flight.

a) Flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, battery charge levels alternatives available if the planned flight cannot 

be completed, and any known traffic delays of which the pilot in command has 

been advised by ATC; 

b) For every flight the following takeoff and landing distance information: 

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data is required, the takeoff and landing 

distance data contained therein; and 

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, 

other reliable information appropriate to the aircraft, relating to aircraft 

performance under expected values of airport elevation and runway slope, 

aircraft gross weight, and wind and temperature. 

AERIA MEDIA LLC will not operate sUAS’s under IFR conditions, or when the 

ceilings are below 1000 feet and the visibility is below 3 statute miles. DJI’s 

sUAS’s do not have published approved Airplane or Rotorcraft Flight Manual 

containing takeoff and landing distance data. 

Equivalent Level of Safety 

The PIC along with the person having operational control must assure that the 

weather will be adequate to complete the mission in VFR condition. AERIA

MEDIA operates in Southern California, where weather conditions are 

consistently favorable; UAS performance should not be affected. Prior to 
commercial operations the intended sUAS will be test flown at gross weight to 

test performance limitations prior to conducting sUAS operations. 

C. 14 CFR 91.113: Right-of-Way Rules 

AERIA MEDIA LLC requests an exemption from 14 CFR 91.113 Right-of- way 

rules, requiring vigilance by each person operating an aircraft so as to see and 

avoid other aircraft. When a rule of this section gives another aircraft the right-ofway, the pilot shall give way to that aircraft and may not pass over, under, or 

ahead of it unless well clear. 

AERIA MEDIA LLC will operate small pilotless UAS’s and cannot comply with 

these rules as they have been written 

Equivalent Level of Safety 

AERIA MEDIA LLC will operate sUAS’s at or below an altitude of 400 feet AGL, 

well below the normal operating altitude of other aircraft. AERIA MEDIA LLC 

specifies that a Pilot in Command with experience will perform each mission and 

have knowledge of the avoid rules. It’s the responsibility of the PIC to cease 

operations and land the UAS immediately whenever and aircraft comes into the 

vicinity creating a potential threat or safety concern. Operations will not 

recommence until the potential threat is clear or safety concern has been 

resolved. 

D. 14 CFR. § 91.119: Minimum Safe Altitudes 

AERIA MEDIA LLC requests an exemption from the minimum safe altitude 

requirements of 14 CFR 91.119 that prescribes the minimum safe altitudes under 

which aircraft may operate:

Over any congested area of a city, town, or settlement, or over any open air 

assembly of persons, an altitude of 1,000 feet above the highest obstacle within 

a horizontal radius of 2,000 feet of the aircraft. 

Over other than congested areas at an altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum 

altitudes when it can be operated “without hazard to persons or property on the 

surface,” provided that “each person operating the helicopter complies with any 

routes or altitudes specifically prescribed for helicopters by the FAA.”

To provide the intended operations, the sUAS is normally operated below 400 

feet AGL. Additionally, due to the nature of the proposed operations, the sUAS 

will maintain a lateral distance of at least 100 feet from inhabited structures, 

buildings, vehicles, and vessels, and from people not associated with the 

operation. 
Equivalent Level of Safety 

Compared to flight of normal aircraft, AERIA MEDIA LLC’s multi-rotor aircraft 

weigh less than 55 pounds, and given the lack of flammable fuel, any risk 

associated with these operations is far less than those that presently exist with 

conventional aircraft. An equivalent level of safety will be achieved given the size, 

weight, and speed of the UAS, as well as the location where it is operated. As set 

forth in the Operations Manual, the sUAS will be operated in a safe and 

uncongested area, where buildings and people will not be exposed to operations 

without their pre-obtained consent. Because of the advance notice to the 

property owners and participants, all affected individuals will be well aware of the 

planned flight operations. 

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with 

aircraft that are subject to the minimum safe altitude regulations. Finally, the 

successful safety record of the DJI sUAS’s demonstrates that the sUAS can be 

safely used at these lower altitudes and closer operating environments. 

E. 14 C.F.R. § 91.121: Altimeter Settings 

AERIA MEDIA LLC seeks an exemption from 14 CFR 91.121, which requires a 

person operating an aircraft to maintain cruising altitude or flight level by 

reference to an altimeter that is set to the elevation of the departure airport or 

barometric pressure. An exemption is required because the sUAS does not have 

a barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved by following these procedures: 1. 

AERIA MEDIA LLC will confirm the altitude of the launch site shown on the GPS 

altitude indicator before flight. 2. Moreover, the PIC will use the GPS altitude 

indicator to constantly monitor the sUAS’s height, thus ensuring operation at safe 

altitudes. 

F. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions 

AERIA MEDIA LLC requests an exemption from 14 CFR § 91.151(a)’s fuel 

requirements for flight in VFR conditions. Section 91.151 states:

a) No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing, and 

assuming normal cruising speed –

(1) During the day, to fly after that for at least 25 minutes; or 

(2) At night, to fly after that for at least 45 minutes. 

The batteries powering AERIA MEDIA LLC’s UAS’s provide approximately 10-24 

minutes of powered flight. To meet the 30 minutes reserve requirement in 14 

CFR 91.151, sUAS flights could not be conducted. Given the limitations on the 

sUAS’s proposed flight area and the location of its proposed operations within a 

predetermined area, a safety margin based on a reserve amount of battery life is 

needed. 
AERIA MEDIA LLC will not be conducting any sUAS flights at night. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operations will be 

conducted on-site without significant transit time by the sUAS. All flights will be 

planned to terminate with no less than 30% reserve battery power still available. 

This restriction would be more than adequate to return the sUAS safely to its 

planned landing zone from anywhere in its confined area of 

operation even in the event of an unexpected occurrence. Operation of the sUAS 

with less than 30 minutes of reserve fuel does not include the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed of the small 

UAS, and the proximity of the flight operation to the landing zone. Moreover, 

operation will be limited to controlled areas where only people and property 

owners, or official representatives will be allowed. 

G. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections

AERIA MEDIA LLC also seeks an exemption from the maintenance inspection 

requirements contained in 14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2), 

91.417(a) and (b). These regulations specify maintenance and inspection 

standards in reference to 14 CFR Part 43. 14 CFR 91.405(a) (stating that each 

owner or operator of an aircraft “shall have the aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections...have 

discrepancies repaired as prescribed in part 43 of this chapter”). An exemption to 

these regulations is needed because Part 43 and these sections only apply to 

aircraft with an airworthiness certificate, which the sUAS will not have. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because maintenance and 

inspections will be performed in accordance with the DJI User’s Manuals. The 

operator will ensure that the sUAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance performed. 

The operator is the person most familiar with the aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety. 

If mechanical issues arise, the sUAS’s size and carrying capacity, and the fact 

that flight operations will only take place in pre-designated areas for limited 

periods of time during daylight hours, creates less risk than that associated with 

conventional rotorcraft performing the same operation. 

VI. PUBLIC INTEREST 

Granting AERIA MEDIA LLC an exemption furthers the public interest. National 

policy set by Congress favors early integration of UAS into the national airspace 

in controlled, safe working environments such as those propose in this petition. 
AERIA MEDIA LLC would like to help facilitate safe integration of sUAS’s into 

mainstream USA in the following areas: 

• Agriculture and Conservation 

AERIA MEDIA LLC would introduce and demonstrate to farmers of all types that 

the sUAS can aid commercial agriculture, land management and conservation 

efforts by assessing crops, mapping flood zones, measuring snow pack and 

more. The sUAS can fly pre-configured missions via the fully automated ground 

station, which allows for time-lapse photos of fields, crops and known land tracts. 

It also can accurately recreate the same pattern during all seasons, providing 

invaluable data for land and soil management. Using HD video, HD photos, and 

IR cameras allows for detailed analysis and recording. With photo rendering 

software, 3D maps and topography can be used in conjunction with time- lapse 

photos to create highly detailed maps for erosion, flood mapping and other 

critical aspects of land management. 

• Real Estate 

The sUAS can be used in all areas of real estate, including agricultural, vacant 

land, commercial, residential and industrial properties. Using a sUAS, real estate 

professionals can create promotional videos, photos and unique shots that 

normal camera aspects cannot capture. The remote platform is great for new 

planning, zoning and large developments. Simple and easy-to-use video and 

photos allow for multiple height pictures and elevation views. 

• Movies and Videography 

Whether the shot requires unique views and expansive panning or extreme 

altitude with radical views, the UAS is designed to hold up under demanding 

conditions. Because of the autopilot feature with pre-designed mission 

management and R/C control interrupt, the pilot and camera operator can easily 

create the ultimate shot with HD video or HD still photos. When working close in 

on a closed set the hazards to the actors are greatly reduced due to the size of 

the sUAS.

• News Gathering 

Similar to movies and videography, each news assignment may require a 

completely different shot or view of a scene. With budgets for traditional 

helicopter use being greatly reduced, the UAS is the perfect solution to allow for 

easy news gathering for a fraction of the cost. The sUAS can and will be 

operated in a safe manner away from the public, while the traditional helicopter 

must hovers over persons and property increasing the danger to individuals. 

• Fire and Rescue and coastal predator detection and warning. 

AERIA MEDIA LLC would introduce and demonstrate to fire and rescue 

personnel the sUAS’s reliability and the capability to perform in extreme 

situations. The ability to offer real time HD and IR video facilitates placing 

personnel and equipment in the right places. Additionally with the recent increase 

in shark sightings, AERIA MEDIA would offer our services to help scan, detect, 

and notify authorities to the presence of large predatory animals. This could save 
lives and increase safety at hundreds of miles of affected coastline. AERIA 

MEDIA LLC’s mission is to assist governmental agencies safely into the NAS.

VII. Privacy 

AERIA MEDIA LLC knows that many individual have concerns about privacy 

from the operations of sUAS’s. AERIA MEDIA LLC has created a privacy notice 

that informs residents, commercial property owners, churches, schools, and 

governmental organizations of our intent to conduct commercial drone operations 

in proximity to their property. 

VIII. Federal Registry Summary 

Pursuant to 14 CFR Part 11, the following summary is provided for publication in 

the Federal Register, should it be determined that publication is needed:

AERIA MEDIA LLC seeks an exemption from the following rules:

14 CFR Part 61.113 (a) and (b); 14 CFR 91. 103; 14 CFR 91.113; 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). 

Approval of this exemption request allows AERIA MEDIA LLC to conduct 

commercial operations with small and lightweight unmanned aerial systems. 

AERIA MEDIA LLC’s vision is to enhance safety of sUAS operations in the NAS 

while reducing risk to the general public and property owners. 

The DJI sUAS’s, weighing less than 55 pounds and powered by batteries, 

eliminates virtually all of the risk given the reduced mass and lack of combustible 

fuel carried on board. The sUAS is transported to the designated mission area 

and set up there. The sUAS will carry no passengers or crew and, therefore, will 

not expose them to the risks associated with manned aircraft flights. The 

operation of this small UAS will provide an equivalent level of safety, supporting 

the grant of the exemptions requested herein, including exempting the applicant 

form the requirements of several regulations and allowing commercial 

operations. These lightweight sUAS’s operate at slow speeds, close to the 

ground and in a safe and uncongested environment. As a result, they are far 

safer than conventional aerial survey and inspection operations conducted with 

fixed wing aircraft or helicopters. 

If additional information is required, or if you have any questions regarding this 

Petition for Exemption, please contact the undersigned. 

Paul Hefferon, Owner/Petitioner AERIA MEDIA LLC 

Business phone: 530-228-2049

Email: paul@aeriamedia.com