VIVA Media Group

143 North St. Ste. E
Brownsville, TX 78521

www.VIVA.network

contact @VIVA.network

Page 1 of 5 U

. S. Department of Transportation July 6, 2015 Docket Managemen t System Washington, DC



## Petition for Exemption Under 14 CFR 11.81 to Allow Commercial Use of Unmanned Aircraft Systems

Petitioner/ Applicant Information:

VIVA Media Group

143 North St. Ste. E
Brownsville, Texas 78521

Edward James Rodriguez , Partner

Phone: 956

- 525

- 0006

Email: e dward@VIVA.network

Website: www.VIVA.network

To Whom It May Concern,

Pursuant to Section 333 of the FAA Modernization a nd Reform Act of 2012 and 14 C.F.R. Part 11, VIVA Media Group is app lying for an exemption from Federa l Aviation Regulations to allow commercial operation of its small Unmanned Aircraft Systems (“sUAS”).

VIVA Media Group is a solutions

- ba sed marketing and media company . Our

creative team formulates strategic initiatives based on specific client needs.

V isual communication is a key component for successful projects. Capturing quality video, images and site data from a erial perspectives will be imperative and invaluable for our process, moving forward.VIVA Media Group

143 North St. Ste. E
Brownsville, TX 78521

www.VIVA.network

contact @VIVA.network

Page 2 of 5 VIVA Media Group is seeking exemption/ relief from the following sections of Title 14 of the Code of Federal Regulations:

 14 CFR 61.113(a)

 14 CFR 91.7(a)

 14 CFR 91. 119

 14 CFR 91.121

 14 CFR 91.151(b)

 14 CFR 91.405(a)

 14 CFR 91.407(a)(1)

 14 CFR 91.409(a)(1) and (2) 1

 4 CFR 91.417(a) and (b)

Reasons why VIVA Media Group is seeking exemption/ relief :

VIVA Media Group is requesting exemption status for the use of small Unmanned Aircraft Systems (sUAS) in a commercial capacity. We wish to pursue safe and legal entry into the National Air Space (NAS). In previous years, aerial media was obtained from the use of large, manned and fueled single

- engine aircraft, whi ch required a pilot, crew and a photographer flyi ng over populated areas

. This process was not cost

- effective for companies to have facilitated as frequently as needed in order to improve their protocol and safety inspections. For our purposes, important data and media will be obtained more effectively and safely from a sUAS than it would be with traditional manned

aircraft methods.

VIVA Media Group will apply this technology to the following (but not limited to): new and existing construction site ins pections, site progress reporting and analyses, land surveying, logistics planning, thermal imaging, property highlight
videos, etc.VIVA Media Group

143 North St. Ste. E
Brownsville, TX 78521

www.VIVA.network

contact @VIVA.network

Page 3 of 5 Aircraft, Increased Level of Safety and the Public Benefit:

Currently and specifically, VIVA Media Group will operate D JI Phantoms (versions 2 and 3) and a 3DR Solo. These small multi

- rotor units (quadcopters) carry a gimbal with an FPV camera affixed. These units can be maneuvered in any single direction or in any combination of the following: forwards, backwards,

verti cally, horizontally, hover in place, rotate clockwise/counterclockwise, etc. See attached supporting documentation, including user manuals, safety guidelines and quick

- start guides for different UA models being utilized. As required for compliance, all d ocumentation and relevant manuals will be readily

available to the PIC.

Each sUA is equipped with a “return to home” safety feature which utilizes GPS technology that returns the aircraft to its initial launching location upon command, during low battery levels or loss of communication. Additionally, if there are any unexpected obst acles or emergencies that come up during the flight, the sUAS will be capable of aborting the flight. Furthermore, as required by 14 CFR Section 45.29(f), and due to the small size of the unmanned aircraft, the sUAS will have identifiable markings that wil l be as large as practicable on the largest surface available.

Safeguards and best practices are embedded in our company culture. Securing this exemption status from the Federal Aviation Administration would enhance our ability to reduce risk, specifical ly when performing future activities with sUAS on project sites and surrounding areas. Therefore, the utiliz ation of sUAS is in the public interest.VIVA Media Group

143 North St. Ste. E
Brownsville, TX 78521

www.VIVA.network

contact @VIVA.network

Page 4 of 5 Safety Not Adversely A ffected :

In summary, VIVA Media Group will adhere to the following conditions and limitations if exemption status is granted:

 We will fly in low

- risk, controlled

- access environments.

 Aircraft will weigh less than 55 pounds.

 Unless prior written approval is provided, all sUAS flights will be at

or below 200 feet AGL.

 Operations wi ll occur during day time Visual Flight Rules (VFR) conditions, from sunrise to sunset.

 Operations will occur within visual line of sight (VLOS) of pilot and visual

observer.

 Operations will be conducted specified distances away from airports or heliports.

 PIC will consider wind and forecast weather conditions and also ensure there is enough available power for the UA to conduct the intended operation. In addition, PIC will terminate each flight session accordingly, in order to operate after that for at le ast five minutes if needed or with the reserve power recommended by the manufacturer if greater.

 At a minimum, the crew for each sUAS operation will include the Pilot In Charge (PIC) and a Visual Observer (VO), both will communicate verbally

for duration of each flight.

 Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the aircraft is ope rating. These documents will be made available to the Administrator or any law enforcement official upon request.

 The sUAS will remain close enough to the operator/pilot for the operator to be capable of seeing the aircraft with vision unaided by any devic e other

than corrective lenses.

 Prior to each flight, a pre

- flight inspection will be conducted per

manufacturer’s recommendation/ user manuals to determine if the UAS is in a condition for safe flight.VIVA Media Group

143 North St. Ste. E
Brownsville, TX 78521

www.VIVA.network

contact @VIVA.network

Page 5 of 5  The sUAS will not operate directly over any persons n ot directly involved in the operation. All flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless express permission and approval is received from property owner.

 Operator will pro perly maintain and frequently inspect the UAS to ensure that it is in a condition for safe operation.

 All aircraft will be identified by serial number and registered with FAA in accordance with 14 CFR part 47, and have identification (N

- Number) markings i n accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

 Each flight will be logged in the PIC’s logbook and the aircraft logbook

 In addition, VIVA Media will adhere to all other applicable rules set forth by

the FAA and othe r governing bodies.

Please don ’ t hesitate to contact us if you require any additional information.

Respectfully,

Edward James Rodriguez

VI VA Media Group