December 28, 2015 

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., S.E.

Washington, DC 20590

Petition of Fly High Aerials, LLC for Exemption Pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012 

Petitioner:

Fly High Aerials, LLC

Jonathan Suska, Managing Member

PO Box 388, 1300 Main Street

Belmar, NJ 07719

Tel. 732.784.7750

Email: jon@flyhighaerials.com

Fly High Aerials, LLC is seeking an Exemption Request Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations from: 14 C.F.R. Part 21, Subpart H; 14 C.F.R. 45.23 and 14 

C.F.R. 45.29; 14 C.F.R. 61.23; 14 C.F.R. 61.113(a) and (b) and14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 

14 C.F.R. 91.9; 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 

91.151(a); 14 C.F.R. 91.203 (a) and (b) and 14 C.F.R. 91. 715; 14 C.F.R. 91.205 (b); 14 C.F.R. 

91.215; 14 C.F.R. Subpart E (91.401 – 91.417)

Fly High Aerials, LLC is seeking exemption in order to operate small Unmanned Aircraft Systems 

(sUAS) for commercial purposes while complying with FAA regulations. The requested exemption 

would permit the operation of small, unmanned sUAS under controlled conditions in the NAS that 

is 1) limited 2) predetermined 3) controlled as to access. Approval of this exemption would thereby 

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

to “...establish requirements for the safe operation of such aircraft systems in the national airspace 

system.” Section 333(c) of the Reform Act.

The sUAS aircraft used in these commercial operations will be the DJI Inspire 1. This UAS weighs 

less than 55 pounds, has GPS abilities, carries no passengers, and is a common aircraft used in 

similar exempt businesses.Full specifications for this particular aircraft can be found here for 

reference: http://www.dji.com/product/inspire-1/info#specs

Commercial purposes include: Aerial videography and photography operations for commercial, public 

and residential use, including but not limited to: real estate, weddings, special events, construction 

site exception and monitoring, home inspections, aerial mapping and surveying, golf courses, 

railroad and bridge inspections, local promotional marketing material, sporting events, and closed-set 

filming for motion pictures, television, and web production.
The use of sUAS technology for these commercial purposes positively effect the public interest. 

Human life is not required on board sUAS which greatly reduces risk of manned aircraft accidents, 

environment emissions are reduced, and new emerging markets help increase local economies.

Until any future rules regarding the Pilot in Command (PIC) dictate otherwise, Fly High Aerials, LLC 

will comply with the current rules that the FAA has set forth, stating that the PIC must hold either an 

airline transport, commercial, private, recreational, or sport pilot certificate, as well as a valid 

driver’s license, and also meets 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. jSteel Design, LLC will require background 

checks, UAS training and test flights of all PICs before any commercial flights take place. Fly High 

Aerials, LLC will conduct all flights in accordance with the FAA standards and regulations set forth by 

the exemption. 

The minimum crew for each commercial operation will consist of the sUAS Pilot and a Visual 

Observer. The sUAS will be operated within the visual line of sight at all times and pre-flight inspection will be done prior to flight determine the sUAS is in a condition for safe flight. Home points will be 

set prior to flight to ensure a safe “return to home” landing in the event that there is a lose of communication between the controller and the aircraft. All flights will be grounded once battery levels reach 

30% of capacity. 

Fly High Aerials, LLC will require maintenance and inspections to be performed based on the 

requirements of the manufacturer in order to maintain air worthiness. All repair and maintenance will 

be performed by qualified personnel. 

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

obtained prior to flight. Any filming of people will be of those who have consented to being filmed or 

otherwise have agreed to be in the area where filming will take place. All flights will occur in 

accordance with any state or local laws regarding privacy. 

Any aircraft flown by Fly High Aerials will be registered in accordance with Section 44711 and Part 47 

and Part 45, Subpart C.

Fly High Aerials, LLC respectfully requests that the FAA grant its exemption allowing for commercial 

operation of sUAS equipment within it’s authority pursuant to the Federal Aviation Act, 85 P.L. 726 

(1958).

If any additional information is needed regarding this petition please do not hesitate to reach out.

Respectfully,

Jonathan Suska

Fly High Aerials, LLC

PO Box 388, 1300 Main Street

Belmar, NJ 07719

jon@flyhighaerials.com