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 Management 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: edward@VIVA.network

Website: www.VIVA.network

To Whom It May Concern,

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

14 C.F.R. Part 11, VIVA Media Group is applying for an exemption from Federal 

Aviation Regulations to allow commercial operation of its small Unmanned 

Aircraft Systems (“sUAS”).

VIVA Media Group is a solutions-based marketing and media company. Our 

creative team formulates strategic initiatives based on specific client needs. 

Visual communication is a key component for successful projects. Capturing 

quality video, images and site data from aerial 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, which required a pilot, crew and a photographer flying 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 inspections, 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 DJI 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, 

vertically, 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 documentation 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 obstacles 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 will 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, specifically when performing future activities with sUAS 

on project sites and surrounding areas. Therefore, the utilization 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 Affected:

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 will 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 least 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 operating. 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 device 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 not 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 properly 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 in 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 other governing bodies.

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

Respectfully,

Edward James Rodriguez

VIVA Media Group