11/16/2015 

U.S. Department of Transportation

Docket Management System 

1200 New Jersey Avenue, S.E. 

West Building Ground Floor, Room W12

Washington, DC 20590 

RE: Petition of Thorn Aerial Imaging for 

operate Unmanned Aircraft Systems p

Act. 

Petitioner: 

Chandler Thorn 

Thorn Aerial Imaging 

299 San Leon 

Irvine, CA 92606 

Tel: (707) 333-5625 

Email: info@thornaerialimaging.com

Email: chandlerthorn2@gmail.com

Website: ThornAerialImaging.com

Dear Sir or Madam, 

 Pursuant to Section 333 of the FAA Mode

Thorn Aerial Imaging hereby petitions the Federal Avia

C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1

FAA deems necessary, to enable Thorn Aerial Imaging 

(sUAS) for aerial data collection and imaging so long as such operations are conducted within and under 

the conditions outlined herein or as may be established by the FAA as required by Section 333. 

As described in more detail below, the requested exemption would per

sUAS under controlled, limited, and predetermined conditions in the National Airspace System (NAS). 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's 

responsibilities to establish requirements for the safe operations of such aircraft systems in the NAS. 

West Building Ground Floor, Room W12-140 

RE: Petition of Thorn Aerial Imaging for exemption from certain Federal Aviation regulations 

rate Unmanned Aircraft Systems pursuant to Section 333 of the FAA Modernization and Reform 

info@thornaerialimaging.com

333 of the FAA Modernization and Reform Act (FMRA) and 14 C.F.R. part 11, 

hereby petitions the Federal Aviation Administration (FAA) for exemption from 14 

C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), and any other rules the 

Thorn Aerial Imaging to operate Small Unmanned Aircraft S

ial data collection and imaging so long as such operations are conducted within and under 

the conditions outlined herein or as may be established by the FAA as required by Section 333. 

As described in more detail below, the requested exemption would permit the operation of 

sUAS under controlled, limited, and predetermined conditions in the National Airspace System (NAS). 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's 

quirements for the safe operations of such aircraft systems in the NAS. 

exemption from certain Federal Aviation regulations to 

ursuant to Section 333 of the FAA Modernization and Reform 

) and 14 C.F.R. part 11, 

) for exemption from 14 

C.F.R. §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

and (b), and any other rules the 

Aircraft Systems 

ial data collection and imaging so long as such operations are conducted within and under 

the conditions outlined herein or as may be established by the FAA as required by Section 333. 

mit the operation of 

sUAS under controlled, limited, and predetermined conditions in the National Airspace System (NAS). 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's 

quirements for the safe operations of such aircraft systems in the NAS. 
1) Specific Sections from which Exemptions are Sought:

a) 14 CFR Part 21, subpart H 

b) 14 CFR 45.23(b) 

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

d) 14 CFR Part 91: 

i) 91.7(a) 

ii) 91.9(b)(2) 

iii) 91.103 

iv) 91.109 

v) 91.119(c) 

vi) 91.121 

vii) 91.151(a) 

viii) 91.203 (a) and (b) 

ix) 91.405 (a) 

x) 91.407 (a) (1) 

xi) 91.409 (a)(1) and (2) 

xii) 91.417(a) and (b) 

2) Relief Sought for Proposed Operations:

a) Thorn Aerial Imaging wishes to operate small Unmanned Aircraft Systems (sUAS) for private and 

commercial purposes provided such operations are conducted within and under the conditions 

outlined by the FAA as required by Section 333. Use of sUAS make and models include but are 

not limited to DJI Phantom series, DJI Inspire series, DJI Spreading wings series, and Freefly 

Systems Alta series. Proposed areas for professional private and commercial services are to 

include but not limited to the following areas: 

i) Aerial video and/or photography for public and/or private use including television, public 

events, cinematography, and commercials. 

ii) Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority. 

iii) Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation. 

iv) Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, and mapping mining, agriculture, topography, inspections, and 

natural resources management. 

v) Aerial photography and/or video for public and/or private events such as wedding venues, 

golf courses, hotels, and resorts. 

3) Public Benefit:

a) Current methods of obtaining imagery, information, and data put human life in danger with 

such methods as helicopters which carry combustible fuel and other various dangerous activities 

such as scaffolding or rigging accidents. The use of sUAS in a controlled and predetermined 

operation alleviates the risk to human and property safety and wellness. Using sUAS also 

benefits the public because the sUAS reduces environmental impact by eliminating sources of 

hydrocarbon emissions from manned aircraft. Lastly, the economy will benefit from controlled 
operations of sUAS because the cost of obtaining this data will be far less expensive than current 

methods. 

4) Safety Not Adversely Affected:

a) Aircraft will be registered and marked in accordance with Section 44711 and Part 47 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 the sUAS manufacturer, 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) The Pilot in Command (PIC) must hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, 

a territory, a possession, or the Federal government. The PIC must also meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her 

pilot certificate. 

d) sUAS will weigh less than 55 pounds. 

e) Flights will be operated within visual line of sigh (VLOS) of the pilot (operator) and/or designated 

observer (spotter). 

f) Maximum total flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 15% batter power reserve should that occur before the maximum 30 minutes. 

g) Flights will be operated at an altitude of no more than 400 feet above ground level (AGL). 

h) Aircraft speed will not exceed 65 mph. 

i) Flight operations will take place during daylight hours (hours of civil dawn and civil twilight). 

j) sUAS aircraft will only be flown inside Class G (uncontrolled) airspace and stay more than five 

miles from any airport or other location with aviation activities. 

k) The sUAS pilot/operator will be Pilot in Command (PIC). If the PIC determines another 

pilot/operator to be qualified with the necessary skills to be the PIC, that person can also be 

designated as the PIC provided they have a minimum of 10 hours of flight time with that specific 

sUAS model including at 5 takeoffs and landings. 

l) All flight operations will have a PIC along with an observer/spotter and sensor operator as 

necessary. 

m) A briefing will be conducted in regard to the planned sUAS operations prior to each flight 

operation. It is mandatory that all personnel involved with the operational duties of the flight 

be present for this meeting. 

n) The PIC and observer/spotter will, at all times, maintain verbal communication by voice or radio. 

o) Written and/or oral permission from the relevant property holders or property representatives 

will be obtained. 

p) If the sUAS loses communications or loses its GPS signal, the sUAS will have the capability to 

return to a pre-determined location and land autonomously or hover in the air waiting to reobtain signal. 

q) All flight operations will comply with the sUAS's manufacturer manual. 

r) All flight operations will comply with any applicable local FSDO requirements. 

s) All flight operations will be conducted in accordance with valid Certificates of Authorization. 

t) Any incidents will be reported within 24 hours of occurrence. 

u) Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with well-defined 

and tested lost link procedures. 
v) Preflight and standard operating procedures for flight operation are listed in section 5 found 

below. 

5) sUAS Checklist and Standard Operating Procedures:

a) Preflight: 

i) Weather and wind limits checked to be within tolerance (do not attempt to fly in winds 

exceeding 20mph) 

ii) Check surrounding area for civilians, animals, objects, and proximity to airports and other 

illegal flight areas 

iii) Confirm operating controller battery and sUAS battery are fully charged and secure 

iv) Thoroughly inspect each propeller for imperfections such as cracks or bends and install to 

aircraft if necessary 

v) Install and secure SD card 

vi) Remove camera lens cap and gimbal clamp 

vii) Place sUAS on level surface away from nearby civilians and objects, into the wind and facing 

away from the operator 

b) Power-Up: 

i) Power on transmitter and confirm full battery charge 

ii) Power on sUAS and confirm full battery charge 

iii) Open sUAS operating software through display and confirm successful connection to aircraft 

iv) Perform compass calibration if necessary as per operating manual 

c) Before Takeoff: 

i) Confirm satellite lock and return-to-home point is updated 

ii) Inspect all aircraft readings and data to ensure that the aircraft is operating at full capacity 

iii) Test all not-flight related hardware functionality such as camera and gimbal operations 

iv) Point aircraft away from operator 

v) Secure takeoff area and make sure there is nothing in a close proximity to the sUAS 

vi) Observers, authorized personal and crew warned of sUAS launch 

vii) Start sUAS propellers and allow to warm up while closely monitoring monitor readings 

d) Takeoff: 

i) Ascend the aircraft to a safe, predetermined height and initiate hover 

ii) Confirm GPS position hold and First Person View (FPV) live feed is working properly 

iii) Take note of weather conditions, battery levels, and time taken for safe takeoff. 

e) Mission: 

i) Confirm predetermined point at which mission will be terminated due to battery level (15%) 

(1) Weather such as wind may greatly affect return time, allow extra time to return to 

home point 

ii) Maintain radio connection and visual line of sight (VLOS) with aircraft 

iii) Utilize a trusted spotter who has been briefed on standard operating procedures to 

maintain visual contact when available 

iv) Verify recording status at all times 
f) Recovery: 

i) Position aircraft over return to home position and confirm landing area is clear of objects 

and civilians 

ii) Decrease altitude and hover at a safe altitude roughly 20 feet above the ground 

iii) Visually inspect landing area again for object or civilians 

iv) Lower aircraft slowly until landing gear is securely on a level surface (if level surface is not 

readily available recovery by hand may be authorized for safety) 

(1) If recovery by hand is used, once the catcher has securely confirmed a firm and safe 

grasp on the aircrafts landing gear (or predetermined safe secure point) power to the 

propellers may be terminated and no one may move until all propellers have safely 

powered down and stopped moving. 

v) Once aircraft is on the ground power to the propellers may be terminated. No one may 

approach the aircraft until all motors have powered down and propellers have stopped 

moving. 

g) Post Flight: 

i) Approach aircraft and power down primary battery 

ii) Power down transmitter and any other operating controllers or systems 

iii) Clean, inspect for any damages, and secure aircraft prior to storage or transport 

iv) Properly store aircraft, batteries, and transmitters in conditions outlined in the user's 

manual 

v) Prepare aircraft for next flight or storage 

6) Manuals

a) DJI Phantom 3 Professional: 

http://www.dji.com/product/phantom-3/download?gclid=CKOW5eHRkMkCFZKBaQodHWwNVg

b) DJI Inspire 1: 

https://www.dji.com/product/inspire-1/download

c) DJI Spreading Wings S1000: 

https://www.dji.com/product/spreading-wings-s1000/download

d) Freefly Alta: 

http://freeflysystems.com/software-manuals

Please advise us of any additional information or changes that may be required. 

Sincerely, 

Chandler Thorn 

Owner, Thorn Aerial Imaging