08/17/2015

Athos Aerial LLC

Attn: Chad Davis

4110 Lafayette St.

Dallas, Tx 75204 

469.237.1868 

cdavis6591@gmail.com

TO: Federal Aviation Administration

US Department of Transportation

Docket Management System

1200 New Jersey Ave. S.E

Washington, DC . 20590

Re:

Exemption Request Section 333 of the FAA Reform Act Pursuant to section 333 of the FAA 

Modernization and Reform act of 2012 (The Reform Act), and 14 C.F.R. Part 11, Athos Aerial 

LLC , herby seeks and applies for an exemption to the Federal Aviation Regulations (FARs) to 

allow Athos Aerial LLC to operate Small Unmanned Aircraft Systems (UAS) commercially in 

airspace regulated by the Federal Aviation Administration (FAA) under the conditions and 

limitations set forth in this petition. The requested exemption would permit Athos Aerial LLC to 

operate small, unmanned aircraft system (UAS) for the purpose of providing an aerial 

photography, survey, and inspection services to Municipalities, Utilities, and Private consumers. 

The areas of use will include both photo and video in the Utilities, Communications industry, real 

estate industry, surveying industry, construction industry, agricultural industry, and Oil and Gas 

industry. The UAS will be operated in airspace that is 1) limited 2) predetermined 3) would 

provide added safety enhancements to the already safe operations in the industry presently 

using conventional aircraft. system”

Exemption request to section 333 of the FAA Reform Act Plan 11 Specific to UAS operations.

14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) & (b); 14 CFR 91.103;14 CFR 

91.105; 14 CFR 91.109: 14 CFR 91.119(c);14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 

91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.401(a)(1) & (2); 14 CFR 91.417(a) 7 (b).
Dear Sir or Madam:

Commercial operation of an UAS, as described herein, which are equipped with camera(s) 

and sensors, would operate in the following manner:

· Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities. 

· Aerial video and/or photography of for public and/or private use including television, public 

events, cinematography and news gatherings. 

· Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority. 

· Aerial inspection/photography of residential/commercial utility infrastructure included 

but not limited to electrical power lines, wind turbines and cell towers. 

· Aerial video/photography or providing live video feed to assist with rescue operations in 

cases of an emergency or natural disaster only when the local authorities or government 

has requested it by contract and/or donation. 

· The ability to offer training to persons or individuals belonging to both private and/or 

public organizations that have interests in the use and application of UAS for the 

purpose of the safe operation of a UAS to enhance the safety of national aerospace 

system (NAS) as well as for protection of the persons and property. 

As described fully below, and to be used as FOM (exibit#1), the requested exemptions 

would permit the operation of a UAS under controlled conditions in the NAS that would be 

a) limited, b) controlled, c) predetermined, and d) will provide safety enhancements such as 

limited exposure to flight crew, climbing crews, weight of vehicles, speeds of usage, non 

use of volatile fuels, ect. Approval of this exemption would thereby enhance safety and fulfill 

the Secretary of Transportations (the FAA administrators) responsibilities to “....establish 

requirements for the safe operation of such aircraft systems in the national airspace system. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The primary vehicles to be used will be the DJI Inspire1 and Turbo Ace Matrix S. While 

vehicles may be upgraded as new technological and safety advanced occur the bar for 

operation and safety will be set by DJI Naza M V-2 Flight Controller, and any new vehicles 

or versions will exceed the current safety and operational standards. No vehicle operated 

by Athos Aerial LLC will be modified from the manufacturers design unless specifically 

directed by the same manufacturer. 

The operation limitations proposed for an equivalent or higher level of safety because 

operations will further enhance the safety of the persons and/or property using conventional 

aircraft. These limitations and conditions to which the applicant agrees to adhere to when 

conducting commercial operations under the FAA issued exemption as set forth in the flight 

operations manual include:
· The UAS will weigh less than 55 lbs 

· The UAS will have a maximum operating speed of no more than 100 mph 

· Flights will be operated within line of sight of the pilot in command and/or visual observer 

· Maximum flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs 

first 

· Flights will be operated at altitude of no more than 200feet above ground level and 

no more than 200 feet above an equivalent platform from which filming is planned. 

· UAS will NOT operate:

· 5 nautical miles (NM) from an airport having an operational control tower; or 

· 3 NM from an airport with a published instrument flight procedure, but not an 

operational tower; or 

· 2 NM from an airport without a published instrument flight procedure or an operational 

tower; or 

· 2 NM from a heliport with a published instrument flight procedure. 

· Minimum crew for each operation will consist of the UAS pilot(PIC), the visual observer 

(VO) and may include but not limited to a camera operator 

· The UAS pilot will be designated pilot in command and hold, at minimum, a sport pilot’s 

license along with a current state drivers license. If the PIC feels another operator to be 

qualified with the necessary skills to be pilot in command and possesses a pilot’s 

license along with current credentials, that person may be designated PIC provided 

they have a minimum of 20 hours of flight time with the UAS. 

· A briefing will be performed regarding the planned UAS operations prior to each 

day’s flight consisting of all days production activities 

· All flights will occur under visual flight rules meteorological conditions (VFR only). 

· The operator will obtain verbal/written consent of all persons involved with the 

planned operations and ensure only consenting persons will be allowed within 100 

feet of the flight operation, and the radius may be reduced to 30 feet based upon an 

equivalent level of safety determination, as required under the FOM. With the 

advance permission of the FFDO, operations at closer range may be approved. 

· The PIC and VO will have been trained in operation of UAS and receive up-to-date 

information for the particular UAS to be operated. 

· The PIC and VO will be able to communicate by voice, radio, and/or text at all times. 

· Written and/or verbal permission and permits will be obtained from territorial, state, 

county or city jurisdictions, including law enforcement, fire or other appropriate 

governmental agencies. 

· If the UAS loses communications with the remote controller or losses GPS signal, the 

UAS will have the capability to return to a pre-determined location within a designated 

location and land autonomously. 

· The UAS will have the capability to abort a flight and return to designated landing area in 

case of unpredicted obstacles, weather, or emergencies. 

· VO or PIC instructed to switch UAS to automatically return home in event 

either are incapacitated.
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. Sec 91.203(a)(1)

The UAS will operate @ 55lbs or less (Gross), carries neither a pilot or passenger*, carries no 

explosive materials or flammable liquid fuels*, and operates in within a secured and predetermined designated area, at altitudes not to exceed 200 ft ALT or speeds in access of 100 

MPH.

14 C.F.R. Sec 91.105 Flight crew members at station

Exemption may be required, the PIC may not leave his station nor shall VO leave station . In 

event that PIC or VO become incapacitated, UAS is to automatically return to designated 

landing area, as outlined in FOM

14 CFR Sec 91.109 Flight Instruction (Dual Controls)

Requiring that no person shall operate a civil aircraft for flight instruction unless the aircraft has 

fully functioning dual controls.UAS and Remote controlled aircraft by design do not have dual 

controls, to do so on a radio controlled aircraft would lower the ability to safely operate the 

UAS. This section cannot reasonably apply

14 C.F.R. Sec 45.23(b). Marking of the Aircraft

Although exemption from said section cannot benefit nor exceed current stipulations, physical 

limitations of UAV are reality, such as cabins, letter size, ect. The UAV will operate under my 

control with registration lettering sized to fit fuselage in compliance of said section 45.23(b) 

under conditions and or limitations deemed mandatory by FAA . I and my colleges must be held 

responsible for compliancy, on behalf of Public’s safety and shared air space, as well as its 

need to indentify and Enforce the accountability and of this growing industry.

14 C.F.R. Sec 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command

By current regulations because the applicants UAS does not carry passengers, or property. 

The use of UAS is far less dangerous (weight, speed, Fuel) than the inherent usage of 

commercial activities outlined in 14 CFR.16. The pilot in command shall have a current Private 

pilots license as well as a Current state drivers licsence which will equal if not exceed safety 

regulations outlined in 14 CFR 16.113.(a) & (b).

14 C.F.R. Sec. 91.103: Preflight Action:

Exemption is requested due to fact that FAA rotor flight manuals are not available for UAV. The 

PIC will take all actions as stated in FOM, under normal procedures included but not limited to 

review of weather, examination of batteries for flight time analysis, landing and takeoff 

distances as well as flight and aircraft performance in flight.

14 C.F.R. Sec 91.119; Minimum Safe Altitudes

Mandates safe altitude for operation of civil aircraft and allow helicopter to operates less then 
minimums prescribed, providing the person operating helicopter complies with any route with 

and or altitudes prescribed for Helicopter’s by FAA. Being that UAV is of Helicopters standards 

and operation a request for exemption to operate at altitude’s not to exceed 200 AGL or not 

more than 200 ft above any elevated platform from which take off is necessary to achieved 

filming. In the event of such particular flight plan, property owners, filming crews and other 

personnel would all be briefed as to safety and conduct procedures during flight. FOB or ATC 

having jurisdiction in such area would have notification and briefing as mandated.

14 C.F.R. Sec 91.121 Altimeter Settings

The requirement of PIC is to use altimeter as means to navigate aircraft to cruise altitudes to 

and from corresponding airports as predetermined in flight plan, unless ordered otherwise. As 

the UAS has no barometric altimeter, but instead uses GPS altitude read out, an exemption 

would need be applied. Per a pre flight check list and live flight data monitoring, the altitude of 

launch site will be predetermined and therefore calculated into the UAS- GPS indicator before 

flight.

14 C.F.R. Sec 91.151(a): Fuel Requirements for Flight in VFR Co

Fuel requirements for flight. The maximum flight time under ideal conditions is 30 minutes with 

the current manufacturers battery pack. The proposed rule under this exemption would require 

the UAS to return to its point of launch if its battery reaches less than 25% provides a higher 

standard of safety when applied to UAS.

14 C.F.R. Sec 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections

Referring to maintenance, preventive maintenance, and alterations to the UAS. The operator 

will provide minor maintenance and inspection to the UAS, documented as outlined in the 

operational and safety guidelines. Given the size and simplicity of the UAS combined with 

the operational and safety guidelines outlined in this petition the operator can maintain or 

exceed the required level of safety.

Sincerely

Chad Davis

Athos Aerial LLC