To: Docket Operations DOT Page 2 of 10

Contrast Visuals & Consulting Jonathan Howard 3904 Park Ave. Nashville, 37209 (615) 852-8182
Date: June 22, 2015 2015-06-27 21:00:01 (GMT)

U. S. Department ofTransportationDocketManagement System 1200 Ne•v JerseyAve., SE Washington, DC 20590 16155232048 From: Jonathan Howard

RE: Petition ofContrast Visuals 

### & Consulting for ExemptionPursuantto Section 333 of the FAA Reform Act Attn: To whom it may concern Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Contrast Visuals & Consulting, operator ofSmall Unmanned Aircraft Systems ("sUASs") equipped to conduct aerial photography and videography, hereby applies for an exemption from the listed Federal AviationRegulations ("FARs") to allow commercial operation ofits sUASs, so long as such operations are conducted \X.tithin and under the conditions outlined herein or as m.ay be establishedby the FAA as required by Section 333.1 As described more fully below, the requested exemption wouJd pem1it the operation of sinall, unmanned andrelatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow Contrast Visuals & Consulting to conduct commercial operations of small unmanned aircraft systems ("UAS") meeting orexceeding

# an ofthe operational and safety requirements Congress has set forth in Section 333. Page 2 Contrast Visuals & Consulting is a media/technology company owned andrun by Nathan Thompson. WithJonathan Howard being the PilotIn Command. Mr. Howard has been active in Radio ControlledAirc.raft for the past 2 years with experience rotary wing aircraft. Contrast Visuals & Consulting plans to exploit the capabilities ofUnmanned Aerial Systems to offer a multitude ofservices, including:

- Aerial surveying

- EventPhotography/Videography

- Agriculture purposes

- Real Estate Photography

- Aerial filmmaking andphotography

- Construction site inspections and monitoring StatutoryAuthority Section 333, titled ''Special Rules for Certain Unmanned Aircraft

**•~Y:SLIJU.l:S** , J-'IOVIUI::S tll.lii:I.:Ui:lU.I.:Sill I.UI :SI,;;I:li.JH):; t:.'l.fJl;Uiti,;;U I't\1"\. tlUtll\.JUZ,tll.ll.lll 01. :Stllt: I.:!VllTo: Docket Operations DOT Page 3 of 10 2015-06-27 21:00:01 (GMT) 16155232048 From: Jonathan Howard

UAS operations in the NAS. Section 333(a) states thatthe FAA "shall determine if certain umnanned aircraft systems may operate safely inthe national airspace system before completion ofthe (comprehensive) plan and rulemaking required by section 332(b)(l) ofthis Act orthe guidance requiredby section 334 ofthis Act." In Section 332(b)(l), Congress made

### it clearthat Section 333 provides amechanism for "expedited operation authorization" 

### ifseveral factors are met. Petitionermeets all requirements to pennit FAA approval ofcommercial UAS operations.
The PetitionerRequests ReliefFrom the Following: Regulations from

**,~.rhich** the exemption is requested:
14 C.F.R. Part 21 14 C.F.R. 45.23 (b)
14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 

### 91.9 (b) (2) 14 C.F.R. 91.109
14 C.F.R. 

### 91.119 14 C.F.R. 91.121Page 3 14 C.F.R. 

### 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401- 91.417)
UnmannedAircraft System sUASs are oftentimes seen as superiorto helicopters due to the smallerdevices cheaperequipment andpersonnel cost, reduced noise and as such, a much smaller environmental impactwhich promotes public safety.
We are petitioning li)r exemption to enable Contrast Visuals & Consulting to operate 

### a DJI Inspire 

### 1upgraded to the latest ±innware and equipped

### with a three-axis camera gimbal andusing a 4K camera. This sUAS has a built-in capabilityto limit the height

### it t1ies above the ground; to limit the radius ofthe distance it flies from the operator. The Inspire 1 also has the failsafe function ofthe autopilot system which means when the communicationbetweenthe MainController and the transmitter is disconnected, the outputs ofall command sticks from controller

### \Viii go to the centerposition. Ifthe GPS signal is good enough, the system will automatically trigger Return to Home andwill land safely.
Please refer to the link to the DJI Inspire 1 Instruction Manual for the performance limitations and flight operations. htln.//downloacL£11!:. .innovations.com/downloads/inspire lien/Inspire I User Manual 

### vl.2 en.pdf
Aircraft weight is 104oz. withbattery, 3 Axis Camera Gimbal and CameraTo: Docket Operations DOT Page 4 of 10 2015-06-27 21 :00:01 (GMT) 16155232048 From: Jonathan Howard

A Pre-night inspection willbe perfom1edby the PIC in accordance with the tactory instmction manual. An added step will be the inspection ofthe propellers. A propeller v\ill be replaced ifit has any nicks and cracks with a manufacturers authorized propeller. The sUAS will be maintained in accordance with the manufacturers instruction manual and onlymanufacturer's authorized replacement parts will beused. FCC Information This DJI Cl transmitterused for contro1ling the sUAS complies with part 15 ofthe FCC ru.les. Operation is subjectto the following two conditions: 

### (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation. The DJI C1radio transmitter used. for controlling the sUAS is wireless technologywhich has been tested and found to be compliantwith the applicable regulations governing a radio transmitter in the 2.400GHz to 2.4835GHz frequency range. Antenna SeparationDistance When operating ourDJI C 1transmitter, the PIC will maintain a separation distance ofat least 5 em between his body (exduding fingers, hands, wrists, ankles and feet) and. the antenna to meet RF exposure safety requirements as determinedbyFCC regulations. Pilot in Command and Observer Qualifications and Duties The PIC will maintain at least 2 hours 11ying time and 3 takeoffs andlandings within 30 days in the type ofUAS utilized in opemtions. The PIC wili have atleast 50 hours total time andatleast 30 hours flying Radio Controlled Model Aircraft ofwhichwlll be 10 hours Hying sUAS's. Training will be conducted at a local Radio Control Club flying field. Perch Photography has the ability to provide "dual controls" utilizing two DJI Cl transmitters with a wire]ess link between the transmitters. One transmitter is designated the master transmitter and the other transmitter is designated as a slave. The PIC instmctor, utilizing the master transmitter, \vill be at all times be able assume control ofthe sUAS. ThePIC is responsible for the safe and. efficient operation ofthe airc.raft. Specific duties include all pretlightpreparation, in Hight operation, post nightrequirements, all procedures including but not limited to: Safe in llight operations Risk Mitigation to Persons andproperty Airfield. Suitability

The Observer must have the visual acuity to observe the sUAV and be able to communicate clearly with the PIC. The Observers duties are;To: Docket Operations DOT Page 5 of 10 2015-06-27 21 :00:01 (GMT) 16155232048 From: Jonathan Howard



### warning the PIC ofany impending obstacles in the night path ofthe sUAS. warning the PIC ofany deviations in the planned flight path ofthe sUAS. warning the PIC should anyunauthorized personnel appear in the area ofthe planned flight. The Observerwill have the authority to order the PIC to terminate the flight should he feel the t1ight cannot be conducted safely. General Operating Standards

• Contrast Visuals & 

### Consulting will only operate its sUAS 

### in line ofsight ofa pilot and/orobserver andwill operate at sites that arc a 'su±1icient distance' from populated areas. Such operations will insure that the sUAS will''not create a hazard to users ofthe national airspace system orthe public."

• Before an operation ofa sUAV within 5NM 

### ofan airport with a control tower, the control towerwi11 be called to gain pen11ission to operate the sUAS. The PIC will give theposition, altitude and the times the sUAV will be operated. The sUAS will not be operated at an altitude ofover 150 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling. Before an operation ofa sUAS within 5NM ofa non-tower controlled, airport operators will be notiHed and the PIC will give the right ofway to avoid Hying in the proximity of fulJ-scale aircraft. Atno time will the sUAV be operated within the final approach course and the takeoffcourse ofanyrunway. The sUA V will notbe operated. at an altitude of over 150 feet AGL. Weather minimums will be 3 miles visibility and a 1000 J()ot 

### ceiling.

• Maximum night time for each operational11ight will be a maximum of25 minutes.

• Flights will be tem1inated at 25% battery powerreserve should that occurprior to the 25 minute limit. ·

• The sUAV will beprogrammed so thatitwill not be operated at an altitude ofno more than 400 feet AGL, and not more than 200 feet above an elevatedplatform from which filming is planned.

• Minimum crew f{)r each operationwill consistofthe sUAS Pilot, and Visual Observer.

• The sUAV operatedby the petitioner weighs less than 55 pounds, inc1uding the payload (i.e. camera, lens, and gimbals).

• The sUAV will operate at speeds ofno more than60 .knots, can hover, and can simultaneously move vertically andhorizontally.

• Giventhe small size ofthe sUA V and the restricted sterile environment within which they will operate, our sUAV operations adhere to the Reform Act's safety requirements. The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, 

### it operates at lower altitudes with no people on board and wi11 thereby reduce current risk levels and thereby enhance safety and diminishTo: Docket Operations DOT Page 6 of 10 2015-06-27 21:00:01 (GMT) 16155232048 From: Jonathan Howard

the likelihood ofdeath or serious bodily injury. With a small payload and maximum nighttime ofonly 25 minutes, this is offers little orno riskto national security.
Low level oblique photos and video from several angles arc far more effective than groundbased. imagery for displaying the characteristics oflarge, complex properties with several buildings and large trees. The applicants in the pasthave chartered 2-scat fullsized helicopters for this purpose, which has proven more costly than manypotential clients have been able to afford. The benefits ofreduced cost and improved quality of presentation from the UA wm be valuable to and benefitmany buyers and sellers ofreal property. Additionally, we request that we be allowed to use our system tobenefit first responders nearby who might require assistance, including fire fighters, the polke, the sheriti, etal., while remaining subjectto all limitations cited in this application as we do so. (a) No flight will be made with a Gross weight exceeding 15 pounds; (b) All operations must occurin FAA Class G airspace atno more than 400 ft AGL, at an airspeed ofno more than 60 knots andno further than 1NM from the PIC; (c) All operations mustutilize a visual observer (V0). The VO and PIC must be able to communicateby voice at all times during a flight operation; (d) Operations will be restricted to lllghts overprivate property with the pennission ofthe property owner; (e) Allrequiredpermits will be obtained from state and local governmentpriorto operation; 

### (l) Contrast Visuals & Consultingwill not be operated over densely populated areas; (g) Contrast Visuals & Consulting willnot be operating over any open-air assembly of people; (h) Contrast Visuals & Consulting will not be operating overheavily trafficked roads;

As well as the mentioned above, our sUAV has a $1,000,000 liability insurance policy.



### EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY
Contrast Visuals & Consulting requests an exemption from the following regulations as well as any additional regulations that maytechnically apply to the operation ofthe sUA V System:To: Docket Operations DOT Page 7 of 10 2015-06-27 21:00:01 (GMT) 16155232048 From: Jonathan Howard



### 14 CFR Part 21, Airworthiness Certificates This part establishes the procedures for the issuance ofan airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the DJI Inspire 1under either orboth ofthe following provisions:

21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a)

### Research anddevelopment. Testing new aircraft design concepts, new aircratt equipment, new aircralt installations, new aircrait operating techniques, ornew uses for aircraft. (b) 

### Showing compliance with regulations. Conducting night tests and other operations to show compliance with the airworthiness regulations including flights to show compliance torissuance oftype and supplemental type certificates, tlights to substantiate major design changes, and flights to show compliance with the function andreliability requirements of the regulations. Since the experimental certifkatecan be used for commercial purposes such as market surveys, sales demonstrations, and customer crewtraining, we would expect that an experimental certificate wouldpermit ourcommercialpurpose as well. The aircraft wm not cany persons orproperty, will not carry fuel, and will only lly under strict operational requirements. Combined with the UA's lightweight, being constructed primarily ofcarbon fiber andplastic, we propose that the UA will be at least as safe, if not safer, than a conventional1y certificated aircraft performing the same mission. Ifan experimental airworthiness certificate is not appropriate for this application, then\ve request an exemption of 14 CFR Part 21, S1ibpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level ofsafetyoutlined in the previous paragraph. 

### 14 CFR45.23 Display of

### marks; general and 45.29 

### Size of

### marks. These regulations provide that each aircraftmust display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance to the cabin, cockpit, orpilot station. The sUAV does not have an entrance inwhich the word "EXPERIMENTAV' canbeplaced, and may not have a registration number assigned to itby the FAA. Wepropose to achieve an equivalent level ofsafety by including the word "EXPERIMENTAL" in the placard on the top ofthe aircraft, as shown above, where the PIC (Pilot In Control), YO (Visual Observer) andothers in the vicinity ofthe aircraft while itis preparing for launch will be able to see the designation. Additionally, we teel thatthe pem1anent placarddiscussed inthe previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a highcontrast flag orbannerthat contains the words "UnmannedAirc.raft Ground Station" in letters 3 inches high orgreater. Since the aircraftwill operate within 3/4 NM ofthe ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point oforigin.To: Docket Operations DOT Page 8 of 10 2015-06-27 21:00:01 (GMT) 16155232048 From: Jonathan Howard



### 14 CFR 61.113 Private pilotprivileges and limitations: Pilot in Command and 61.133 Commercial pilotprivileges and limitations. The regulation provides that no person that holds a Private Pilot certificate may act as pilotin Command ofan aircraft for compensation orhire. Subparagraph (h) allows a private pilot to act as pilot in commandofan aircraft inconnectionwith any business or employment

### if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers orproperty for compensation or hire. Ourproposed operations require that the PIC must maintain at least 2 hours flying time and 3 takeoffs and landingswithin 30 days in the type ofUAS utilized in operations. The PIC will have at least 50 hours total time and atleast 30 hours flying Radio Controlled Model Aircrait ofwhichwill be 30 hours ofsUA V's Flight time. Since the aircraft cannot carry passengers orproperty, we feel we meet the intent of61.113 Subparagraph (b) eventhough the intent ofthis application is to conduct a business. 

### 14 CFR 91.7 Prohibits the Operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be applicable 

### in the form contemplated by the FARs, this Regulation is inapplicable. 

### 14 CFR 91.9 Civil aircraftflight manual, marking, and placard requirements. This regulation provides thatno person may operate an aircraft unless a current, approved Hight manual is in the aircmfl:. We assume that the intent ofthis requirement is to ensure that flight manual ini(mnation is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would notbe available to the crew during flight operations. To obtain an equivalent level ofsafety andmeetthe intent of91.9, we propose that a current, approved sUA V Flight Manual must be available to the crew at the ground station anytime the aircraft is in, orpreparing for, flight. 

### 14 CFR 91.109 FlightInstruction; Simulated instrumentflight and certain flight tests The regulation states that "No person may operate a civil aircraft that is beingused for flight instruction unless that aircraft has fully functioning dual controls." Training 

### will be conducted at a local Radio Control Club t1ying field. Perch Photography has the abilityto provide "dual controls" utilizing two DJI Cl transmitters with a wireless link between the transmitters. One transmitter is designated the master transmitter and the other transmitter is designated as a slave. The PIC instructor, utilizing the master transmitter, will be at all times be able assume control ofthe sUA V. 

### 91.ll9Minimum safe altitudes: GeneraL The regulation states that over s;parsely populated areas the aircraft cannotbe operated closerthan 500 feet to any person, vessel, vehicle, or structure. Since the typical mission ofthe sUAS wouldbe photography or survey ofpersons, vessels, vehicles or structures 

### itwouldbe necessary to operate closer than 500 feet to the items listed. Operations will onlybe flown overproperty orpersons where permission has been obtained and careful pre-planned Hight path has beenperfom1ed. The aircraft will be operated at a low altitude allowing, ifa powerunit fails, an emergency landingwithout undue hazard to persons or property on the surface. Therelbre we maintain that due to theTo: Docket Operations DOT Page 9 of 10 2015-06-27 21:00:01 (GMT) 16155232048 From: Jonathan Howard



### small size ofthe UAS, the hazard to persons, vehicles and structures is minimal comparedto mam1ed aircran, which should be considered in granting the exemption. CFR91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reterence to an altimeter setting available within 100 NM ofthe aircraft. The sUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conf1ict with other aircraft. An Above Ground Level altimeter measurement above the takeoffpoint is transmitted via radio from the sUAS on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout. 14 CFR 91.151 Fuel requirements for flight in VFR conditions. Theregulation provides that no person may begin a fllght in an airplane under day-vFR conditions unless there is enough fuel to fly to the iirstpoint ofintended landing and to iJy 

### afterthat tor at least 20 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a sa1ety bufferfor delays to landing. The sUAVis battery operated and the maximum duration 

### offlight trom a single battery charge is 15 minutes with a 20% reserve. Since the aircraft will never fly more than 1NM from the point ofintended landing, a full battery charge at launch will ensure thatwe meet the reserve energy requirement ofthis paragraph. We request anexemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". 14 CFR 91.203(a) & 

### (b) Civil aircraft: Certifications required. The regulationprovides that an airworthiness certificate, with the registration number assignedto the aircraft and a registration certificate mustbe aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that itis legible to passengers or cre\v." At a maximum gross weight of5.3 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable ofcarrying passengers or crew. To obtain an equivalent level ofsafety and meet the intent of91.203, wepropose that documents deemed appropriate for this aircraftbythe FAA will bewith the crew at the ground control station and avai1able for inspection upon request. 14 CFR SubpartE (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations The regulationprovides that the operator is primarilyresponsible for maintaining the aircraft in an aiffi'orthy condition, including compliance withpart 39 and43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under43.7" after maintenance and inspection. It

### is our intention that the PIC perfom1maintenance and inspection ofthe aircraft and "he authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy conditionprior to every Jllght andin addition conduct detailedinspections after every two hours offlight. Maintenance perlonnedby the PIC 

### is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and Hrmware for the

**on~board** 

### computer. All othermaintenance will be pertom1edbythe manufacturer or their designated repairfacility. The PlC will documentworkperformed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level ofsafety.To: Docket Operations DOT Page 10 of 10 2015-06-27 21:00:01 (GMT) 16155232048 From: Jonathan Howard



### Safety and Benefits ofthe UAS
Contrast Visuals & Consulting will be using the UAS in a variety ofapplications that generally require expensive full-size mannedaircraft to complete. Small, light, unmanned aerial vehicles offermyriadbenet1ts overthe use offull-sized manned aircraft for electric powerline inspection, oil/gas pipeline inspection, advanced agriculture, film and stiiJ photography,justto name a few. Replacing significantly largermanned aircraft carrying crew and t1ammable fuel with small UAS carrying no passengers orcrew creates a much greatermargin ofsafety for the pilots and crew. By granting PerchPhotography's requested exemptions, the FAA will help drive development ofsafe and successful commercial UAS operations andwill advance the public knowledge base for such operations. Contrast Visuals & Consulting is committedto promoting theUAS research eJiorts ofpolicymakers including the FAA, NASA, 

### DOD and DARPAby sharing data from its commercialUAS operations and serving as a resource for future UAS research operations. Thus, the FAA has goodcause to grant this Petition. 

### Conclusion
As pointedout in this app11cation, all the SUAs which our company woulduse, under authorization by the US DOT-FAA, 

### are small, llght-weight devices operated within the line ofs1ght ofthe Pilot-in-Command (PIC), Jess than 400 feet above the ground and outside 

### 5 miles from any airport, heliport, seaplane base, spaceport, or otherlocation with aviation activities, unless the airtraffic control authorities (ATC) have been notified and have authorized each flight within a radius ofthis distance.
A11 ourUASs have proven capability f()r controlled flight. They are devices ofli:red for general sale on the marketaroundthe world and have oftenbeenused as Model Aircraft in the USA. We are certain that the studies conducteduntil nowbythe FAA, about Section 332, Public Law 112-95, 2014, have already provided youwith the assurances on the airworthiness ofSUAs suchas ours. For the 11.)regoing reasons, the exemptions requested herein shouldbe granted and Contrast Visuals & Consulting should bepermitted to conduct small UAS operations in accordance with its manuals and all other operatingparameters deemed necessary and appropriate bythe FAA. The submission ofthis application and its contents is the best demonstration that indeed 

### it is possible to pursue the authorization process so that some SUAs may be used for legitimate commercial activities and under reasonably safe conditions. Signed