David Young

Owner

HovrVision, LLC

9206 Andrew Dr.

Manassas Park, VA 20111

US Department of Transportation

Docket Operations

1200 New Jersey Avenue, SE

Washington, DC 20590

February 27, 2016

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act 

of 2013, 49 § U.S.C 44701(f), and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

I, David Young, am the sole-owner of HovrVision, LLC, a Virginia Limited Liability Company 

specializing in aerial video and photography services. The purpose of this communication is to relay my 

Petition for Section 333 Exemption under Section 333 of the FAA Modernization and Reform Act of 

2012 (“FMRA”).

Pursuant to Section 333 of the FMRA, HovrVision, LLC herby requests a determination by the Secretary 

of Transportation authorizing commercial operations of UAS for the purposes of aerial photography and 

videography, mapping, industrial equipment and power line surveillance, agricultural crop surveillance, 

aerial inspections, data collection, augmented real estate listings, commercial videos, and other work 

related to aerial photography. HovrVision, LLC does not intend to use UAV’s for closed set filming. 

Flight operations will utilize the off-the-shelf DJI family of unmanned aircraft to include the Phantom 3 

(Standard, Advanced, Professional, 4K) and the Inspire 1 (including the Inspire 1 Pro). Conduct of UA 

operations will be with respect to FMRA Section 333© and the UAS “Blanket COA”.

Exemption is necessary to effect the determination requested pursuant to FMRA Section 333. The 

attached documentation includes detailed exemption requests that demonstrate how these exemptions are 

in the public interest and will maintain at least an equal level of safety to existing regulations. Authorizing 

HovrVision, LLC to conduct commercial UAS operations will result in less disruptive, safer, and more 

cost effective solutions than manned aviation equivalents due to the low altitude environment, given the 

size, speed and inherent risk of traditional commercial helicopter operations. These commercial 

operations often occur in the unsafe areas of the height-velocity diagram requiring special precision and 

skill. HovrVision, LLC will conduct the commercial UAS operation in a manner that will meet, and in 

many cases exceed, the current level of safety of commercial helicopter operations. Small UA have a low 

noise signature, and carry no volatile fuel, will limit collateral damage in the event of catastrophic failure. 

The low expense of operation compared to cost prohibitive manned aviation alternatives allows a greater 

economic benefit to businesses. For these reasons, granting an exemption under FMRA Section 333(c) is 
in the public interest. UAS technology used for these commercial purposes benefit the public interest in 

the following ways: 

 Reduces the collateral damage risks to life and property associated with low altitude helicopter 

operations in undesirable portions of the height-velocity envelope. 

 Increased economic wellbeing to local businesses via cost reductions. 

 Enabling aerial business solutions to be available to a larger market. 
Table of Contents

I. Exemptions Requested 

II. Commercial Operation/Operator

III. Unmanned Aircraft System (UAS)

IV. UAS Pilot-in-Command (PIC) 

V. Public Interest 

VI. Summary 

VII. Relevant URLs

I. Exemptions Requested 

Pursuant to 14 C.F.R. § 11.81(e), HovrVision, LLC requests exemption from the following 

regulations: 

 14 C.F.R. Part 21 Subpart H – Airworthiness Certificates

o Establishes: The procedural requirements for the issuance of airworthiness 

certificates as required by 14 C.F.R. § 91.203(a)(1) 

Given the small size of the UA and the safeguards that will be taken as outlined below, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety 

under Part 11 and Section 333 of the FMRA with consideration “of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular 

UAS.” 

 14 C.F.R. § 45.23(b) – Aircraft Marking and Identification Requirements 

o When marks include only the Roman capital letter "N" and the registration number 

is displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near 

each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches 

nor more than 6 inches high, the words "limited," "restricted," "light-sport, 

"experimental," or "provisional," as applicable. 

HovrVision, LLC will ensure compliance with § 45.29(f) to meet the intent of the 

regulation by displaying the registration number in the largest practicable lettering. 

 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) and 61.101 – Recreational, Private and 

Commercial Pilot Privilege and Limitations

o 14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) of this 

section, no person who holds a private pilot certificate may act as pilot in command 

of an aircraft that is carrying passengers or property for compensation or hire; nor 

may that person, for compensation or hire, act as pilot in command of an aircraft. (b) 

A private pilot may, for compensation or hire, act as pilot in command of an aircraft 

in connection with any business or employment
o 14 C.F.R. § 61.133: (a) Privileges – (1) General. A person who holds a commercial 

pilot certificate may act as pilot in command of an aircraft – (ii) For compensation 

or hire, provided the person is qualified in accordance with this part and with the 

applicable parts of this chapter that apply to the operation.

o 14 C.F.R. § 61.101: (a) A person who holds a recreational pilot certificate may not 

act as pilot in command of an aircraft:

 For compensation or hire;

 In furtherance of a business; 

UA operations will employ a PIC who holds, at a minimum, a recreational or sport pilot 

certificate of any category or class and a valid driver’s license. 

 14 C.F.R. 91.7(a) – Civil Aircraft Airworthiness

o No person may operate a civil aircraft unless it is in an airworthy condition. 

The PIC will conduct pre and post flight inspections in accordance with manufactures 

maintenance manual(s) and guidance. During flight, the PIC will adhere to § 91.7(b) and 

abort air operations immediately upon identification of an in-flight emergency or other 

unsafe condition. By complying with procedures outlined by the manufacturer, an 

equivalent level of safety will be achieved. 

 14 C.F.R. 91.9(b) Civil aircraft flight manual, marking, and placard requirements

o (b)(2) prohibits operation of U.S.-registered civil aircraft unless there is available in 

the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. 

By keeping all operating documents, manuals, authorizations and exemptions in a binder 

available for inspection by pilots and other authorities, HovrVision, LLC meets the intent 

of the regulations and therefore achieve an equivalent level of safety. 

 14 C.F.R. 91.109(a) – Flight Instruction

o No person may operate a civil aircraft (except a manned free balloon) that is being 

used for flight instruction unless that aircraft has fully functioning dual controls. 

The majority of sUAS by design are developed with single operational control through the 

use of pre-determined GPS enabled waypoints programmed before or during flight in 

addition to the use of a single hand held transmitter or control station controlled by the PIC. 

The design does not allow for dual controls during flight training and therefore the 

exemption is requested to train operators, build experience, and maintain proficiency. An 

equal level of safety will be achieved by conducting all training in sterile environments. 

Training sessions will be accomplished separately from flights conducted for compensation 

or hire. 

 14 C.F.R. 91.119 (c) – Minimum Safe Altitudes

o Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: (b) Over any congested area of a city, town, or 
settlement, or over any open air assembly of persons, an altitude of 1,000 feet above 

the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over 

other than congested areas. An altitude of 500 feet above the surface, except over 

open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) 

Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation 

is conducted without hazard to persons or property on the surface— (1) A helicopter 

may be operated at less than the minimums prescribed in paragraph (b) or (c) of this 

section, provided each person operating the helicopter complies with any routes or 

altitudes specifically prescribed for helicopters by the FAA. 

Commercial UAS operations will be conducted at or below the maximum altitude 

authorized by COA. Given the size, weight and lack of fuel; combined with operation 

limitations listed below, the operation will be conducted with a greater level of safety than 

exists with current manned aviation operations. 

 14 C.F.R. 91.121 – Altimeter Settings 

o Each person operating an aircraft shall maintain the cruising altitude or flight level 

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating... 

SUAS are equipped with Global Positioning System (GPS), which provide altitude and 

geolocation data to the operator without utilizing an altimeter. Due to this fact, an 

exemption is required. GPS are precise within a few feet and combined with fail-safes and 

a visual observer the operation will meet an equivalent level of safety.

 14 C.F.R. 91.151(a) – Fuel Requirements for Flight in VFR Conditions

o No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the 

first point of intended landing and, assuming normal cruising speed— (1) During 

the day, to fly after that for at least 30 minutes; 

This regulation is written based on the capabilities of a traditional aircraft, which have 

flight times of several hours or greater; therefore, with the majority of sUAS, which have 

flight times of only an hour or less, this regulation would effectively deny the ability of the 

air vehicle to operate. 

The PIC will achieve an equivalent level of safety by complying with all manufacturer 

guidelines and the DJI low battery failsafe system. 

 14 C.F.R. 91.215(b) – ATC Transponder and Altitude Reporting Equipment and Use. 

o All airspace, unless otherwise authorized or directed by ATC, no person may 

operate an aircraft in the airspace described in paragraphs (b)(1) through (b)(5) of 

this section, unless that aircraft is equipped with an operable coded radar beacon 

transponder having either Mode 3/A 4096 code capability, replying to Mode 3/A 

interrogations with the code specified by ATC, or a Mode S capability, replying to 
Mode 3/A interrogations with the code specified by ATC and intermode and Mode 

S interrogations in accordance with the applicable provisions specified in TSO C112, and that aircraft is equipped with automatic pressure altitude reporting 

equipment having a Mode C capability that automatically replies to Mode C 

interrogations by transmitting pressure altitude information in 100-foot increments. 

This requirement applies— 

(1) All aircraft. In Class A, Class B, and Class C airspace areas; 

(2) All aircraft. In all airspace within 30 nautical miles of an airport listed in 

appendix D, section 1 of this part from the surface upward to 10,000 feet MSL; 

(3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not 

originally certificated with an engine-driven electrical system or which has not 

subsequently been certified with such a system installed, balloon or glider may 

conduct operations in the airspace within 30 nautical miles of an airport listed in 

appendix D, section 1 of this part provided such operations are conducted— 

(i) Outside any Class A, Class B, or Class C airspace area; and 

(ii) Below the altitude of the ceiling of a Class B or Class C airspace area designated 

for an airport or 10,000 feet MSL, whichever is lower; and 

(4) All aircraft in all airspace above the ceiling and within the lateral boundaries of a 

Class B or Class C airspace area designated for an airport upward to 10,000 feet 

MSL; and 

(5) All aircraft except any aircraft which was not originally certificated with an 

engine-driven electrical system or which has not subsequently been certified with 

such a system installed, balloon, or glider— 

(i) In all airspace of the 48 contiguous states and the District of Columbia at and 

above 10,000 feet MSL, excluding the airspace at and below 2,500 feet above the 

surface; and 

(ii) In the airspace from the surface to 10,000 feet MSL within a 10-nautical-mile 

radius of any airport listed in appendix D, section 2 of this part, excluding the 

airspace below 1,200 feet outside of the lateral boundaries of the surface area of the 

airspace designated for that airport. 

The sUAS to be used in the proposed operation does not come equipped with a 

transponder. No transponder exists for the sUAS, which can be installed. The petitioner 

requests relief from the exemption to the extent required to operate in areas in which a 

transponder is required according the applicable regulations in this part. 

The PIC will achieve an equivalent level of safety by complying with all provisions of the 

COA under which operations are to be conducted. The sUAS flown under this exemption 
will comply with all altitude limits and airport standoff distances required by COA, which 

mitigate hazards to aircraft controlled by the ATO in congested airspace. 

 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b) – Maintenance 

Inspections 

o 91.405(a) States: Each owner or operator of an aircraft—(a) Shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter

o 91.407(a)(1) States: (a) No person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration unless—(1) It has 

been approved for return to service by a person authorized under § 43.7 of this 

chapter

o 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no 

person may operate an aircraft unless, within the preceding 12 calendar months, it 

has had—(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. No inspection performed under paragraph 

(b) of this section may be substituted for any inspection required by this paragraph 

unless it is performed by a person authorized to perform annual inspections and is 

entered as an ‘‘annual’’ inspection in the required maintenance records.

o 91.417(a) & (b) States: (a) Except for work performed in accordance with §§ 

91.411 and 91.413, each registered owner or operator shall keep the following 

records for the periods specified in paragraph (b) of this section: (paragraphs 1 (i –

iii), 2 (i – vi)); (b) The owner or operator shall retain the following records for the 

periods prescribed: (paragraphs 1 – 3) 

The PIC will conduct Pre/Post flight inspections and maintenance in accordance with the 

manufacturer’s guidance as stated in the operations manual. If maintenance is required, the 

PIC will conduct a dedicated test flight will be conducted to ensure safety before resuming 

commercial operations. All inspection, maintenance and alterations will be documented and 

maintained in a record. These actions will meet the intent of the regulations from which 

exemption is being requested and lead to an equivalent level of safety. 

II. Commercial Operator/Operation 

Any UA flown under this exemption will be controlled by a certificated PIC. The PIC will hold, at a 

minimum, a recreational or sport pilot certificate. 

For each flight, HovrVision, LLC: 

 Will conduct a comprehensive worksite inspection and analysis, identifying limits of customer 

property or authorized access areas.

 Will operate in those areas only with the consent of the landowner or designated representative.

 Will identify potential obstructions or other hazards to safe operation.
 Will clear the area of personnel or bystanders that are non-essential to the operation, 

maintaining at a minimum safe distance from non-participating persons.

 Will at all times yield to manned air traffic.

 Will operate within VLOS and during daylight hours only.

 Will operate under visual flight rules, in visual meteorological conditions, for the airspace in 

which the flight is conducted.

 Will not exceed the maximum altitude as defined in the COA under which flight authorized, as 

determined by the installed GPS.

 Will keep operating documents, manuals, authorizations and exemptions in a binder available 

for inspection.

 Will immediately terminate flight, in the safest manner possible, when safety to persons or 

property become compromised.

 Will terminate flight, in the safest manner possible, when unable to comply with these 

limitations or any other limitations granted as part of this exemption. 

In order to remain at an altitude at or below the attitude prescribed by the applicable COA, relief is 

needed from Section 91.119 (c). By following these operating standards, the commercial operation 

will meet an equivalent level of safety to the regulation in which relief is sought. 

III. Unmanned Aircraft System 

HovrVision, LLC seeks exemption to operate the DJI UASs to include the Phantom 3 (Standard, 

Advanced, Professional, 4k) and the Inspire 1 (including the Inspire 1Pro). Other UAS types may be 

requested in future amendments. The UASs will be flown via a combination of RC control and 

tablet/electronic touch-screen device. This UA type is a GPS equipped, multirotor helicopter. A quadcopter type rotorcraft utilizing four motors. Lithium-polymer batteries power the UA. 

The UASs also has several fail-safes for loss of RC signal, loss of GPS, and low battery as outlined in 

the respective Operation Manuals. The UASs display visual and emit an audible low battery alerts at 

which time the UA will automatically engage the landing sequence. Based upon those safeguards, I 

request exemption from Section 91.151(b) Fuel requirements for flight in VFR conditions.

Given the size, weight, speed, and controlled operating area associated with the UA to be utilized, an 

exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) is 

requested. Exemption is sought from § 45.23 Marking of the aircraft. The UA will display the 

registration number in the largest practicable lettering. HovrVision, LLC seeks to be exempt from § 

91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections will be 

conducted according to operations manual and prudent judgment as previously outlined to determine 

the integrity and safety of the UASs and associated equipment. Further, relief is required from 

91.7(a), which prohibits the operation of an aircraft without an airworthiness certificate and 91.9(b) 

(2) requiring an approved flight manual in the aircraft. The UASs will not be operating with an 

airworthiness certificate therefore, this would be inappropriate. The UASs are too small to carry the 

operating documents so an equivalent amount of safety can be achieved through keeping the 

operating documents and manuals in a location available for inspection. 
IV. UAS Pilot in Command (PIC) 

Under part § 61, recreational, sport and private pilots are limited to non-commercial operations, 

however HovrVision, LLC can ensure UAS operations will achieve an equivalent level of safety as 

current regulation because UASs do not carry any pilots or passengers. A commercial pilot certificate 

will not ensure RC piloting ability, as the psychomotor skills are different. The inherent risks of 

operating a UAS are far less than in the commercial activities outlined in 14 CFR part 61, et seq., thus 

exemption is requested from § 61.101 Recreational Pilot Privileges and Limitations. PICs will 

maintain recent flight experience on the UASs. Training and experience flights will be conducted 

separate from commercial operations. 

V. Public Interest 

Given the above stated evidence, procedures, and precautions operating UASs commercially for the 

purposes of aerial photography and videography, mapping, industrial equipment and power line 

surveillance, agricultural crop surveillance, aerial inspections, data collection, augmented real estate 

listings, commercial videos, and other work related to aerial photography will ultimately be in the 

public interest. These operations, when executed with prudence, will exceed the current level of 

safety as the regulations from which exemption is sought. UAS operations will allow greater access to 

commercial aerial services that were not previously economically feasible for many firms. This will 

provide a much needed economic uplift to the community and hence the public. UAS operations are 

associated with less risk of collateral damage to persons and property while limiting disruptive noise 

pollution associated with low altitude aviation operations. 

VI. Summary 

Pursuant to Section 333 of PL 112-95 commonly known as the “FAA Modernization and Reform Act 

of 2012”, HovrVision, LLC, hereby applies for authorization to conduct commercial unmanned aerial 

systems (UAS) operations for the purposes of aerial photography and videography, mapping, 

industrial equipment and power line surveillance, agricultural crop surveillance, aerial inspections, 

data collection, augmented real estate listings, commercial videos, and other work related to aerial 

photography listings.

Rules for which exemption is sought: 

 14 C.F.R. Part 21 Subpart H

 14 C.F.R. § 45.23(b)

 14 C.F.R. § 61.101, 61.113 and 61.133(a)(1)(ii)

 14 C.F.R. § 91.7(a)

 14 C.F.R. § 91.9(b)

 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. § 91.215(b)

 14 C.F.R. § 91.405(a)

 14 C.F.R. § 91.407(a)(1)

 14 C.F.R. § 91.409(a)(2)

 14 C.F.R. § 91.417(a) & (b)

VII. Relevant URLs

Due to the number of UAS models included in this exemption and the size of the user manual files 

and relevant documents, URL links are being provided for each UAS where all user manuals and 

product documents can be located.

 Phantom 3 Standard

o http://www.dji.com/product/phantom-3-standard

 Phantom 3 Advanced

o http://www.dji.com/product/phantom-3-adv

 Phantom 3 Professional

o http://www.dji.com/product/phantom-3-pro

 Phantom 3 4k

o http://www.dji.com/product/phantom-3-4k

 Inspire 1

o http://www.dji.com/product/inspire-1

 Inspire 1 Pro

o http://www.dji.com/product/inspire-1-pro-and-raw

Thank you for your prompt attention and consideration. Please do not hesitate to contact me with any 

questions or concerns.

Respectfully,

David Young

Owner

HovrVision, LLC

hovrvision@gmail.com