197 N Main St, Unit 3

Boscawen, NH 03303

www.BirdsEyeView.aero

Page 1 of 12

January 8, 2016

From: 

Adam Sloan

BirdsEyeView Aerobotics

To: 

U.S. Department of Transportation, Docket Operations 

Room W12-140 of the west building 

Ground floor 

1200 New Jersey Avenue, SE. 

Washington, DC, 20590

PETITION FOR EXEMPTION OF:

BirdsEyeView Aerobotics

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE 

OF FEDERAL REGULATIONS PART 21, SUBPART H AND SECTIONS §§ 45.23(b), 61.113(a) & (b),

91.7(a), 91.9(b), 91.103, 91.109, 91.119, 91.121, 91.151(a) & (b), 91.203(a) & (b), 91.405, 91.407(a) 

(1), 91.409(a) (2), 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF FIREFLY6 AND 

QUANUM NOVA SMALL UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE 

FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Petition for Summary Grant

The FireFLY6 sUAS has been granted numerous previous petitions for exemptions by other companies 

and agencies. Therefore, BirdsEyeView Aerobotics wishes the Administrator to Summary Grant this 

petition. The FireFLY6 sUAS has been granted exemption in the following dockets:

 geoResource Technologies, Inc. Docket FAA-2015-0701-0003

 HAZON Solutions, Docket FAA-2015-0364-0001

 FlightWink UAV Aviation, Docket FAA-2015-0781-0003

 Airmada Inc, Docket FAA-2015-7995-0001

 3D UAV Aerial Services, Docket FAA-2015-7067-0001

 GPS Development, LLC d/b/a SkyViewHD, Docket FAA-2015-0147-0003t 
197 N Main St, Unit 3

Boscawen, NH 03303

www.BirdsEyeView.aero

Page 2 of 12

Contents

PETITION FOR EXEMPTION OF:......................................................................................................... 1

Petition for Summary Grant.................................................................................................................... 1

GLOSSARY OF ABBREVIATIONS.................................................................................................... 3

SUMMARY ............................................................................................................................................ 4

INTRODUCTION AND INTERESTS OF THE PETITIONER.................................................................. 4

UNMANED AIRCRAFT SYSTEMS: ....................................................................................................... 5

FIREFLY6 .......................................................................................................................................... 5

QUANUM NOVA................................................................................................................................ 5

BASIS FOR OUR PETITION ................................................................................................................. 6

CONDITIONS AND LIMITATIONS......................................................................................................... 6

SECTIONS OF 14 C.F.R FROM WHICH BIRDSEYEVIEW AEROBOTICS SEEKS EXEMPTION......... 8

14 C.F.R. (Format) Part 21 & Subpart H: Airworthiness certificates ................................................ 8

14 C.F.R. 45.23(b): Marking of the aircraft...................................................................................... 8

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command....................... 8

14 C.F.R. 91.7(a): Civil aircraft airworthiness.................................................................................. 9

14 C.F.R. 91.9(b) (2): Civil aircraft flight manual, marking and placard requirements...................... 9

14 CFR 91.103: Preflight action...................................................................................................... 9

14 C.F.R. 91.109: Flight instruction................................................................................................. 9

14 C.F.R. 91.119: Minimum safe altitudes ...................................................................................... 9

14 C.F.R. 91.121: Altimeter Settings............................................................................................. 10

14 C.F.R. 91.151(a): Fuel requirements for flight in VFR conditions.............................................. 10

14 C.F.R. 91.203(a) & (b): Carrying civil aircraft certification and registration ............................... 10

14 C.F.R. 91.405; 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections......................... 10

PUBLIC INTEREST ............................................................................................................................. 11

EQUIVALENT LEVEL OF SAFETY ..................................................................................................... 11

PRIVACY............................................................................................................................................. 11

NATIONAL SECURITY........................................................................................................................ 11
197 N Main St, Unit 3

Boscawen, NH 03303

www.BirdsEyeView.aero

Page 3 of 12

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AIM Aeronautic Information Manual

ATO Air Traffic Organization

CFR Code of Federal Regulations

COA Certificate of Authorization

EO Electro-Optical (TV Video)

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FPV First Person Video

GCS Ground Control Station

GPS Global Positioning System

HD High Definition

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

R/C Radio Control / Remote Controller

RTL Return To Launch

SAR Search and Rescue

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

sUAS Small Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
197 N Main St, Unit 3

Boscawen, NH 03303

www.BirdsEyeView.aero

Page 4 of 12

SUMMARY

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (The Reform Act), and 14 

C.F.R. Part 11, BirdsEyeView Aerobotics, an sUAS developer and provider, hereby applies for an 

exemption from the FARs listed below to allow operation of sUAS commercially in airspace regulated 

by the FAA so long as such operations are conducted with and under the conditions outlined herein or 

as may be established by the FAA as required by Section 333. 

The requested exemption would permit BirdsEyeView Aerobotics to pursue its commercial interests in 

providing services to clients using sUAS in the following areas: 

1. Training

2. Inspection 

3. Surveillance

4. SAR

INTRODUCTION AND INTERESTS OF THE PETITIONER

BirdsEyeView Aerobotics is an sUAS developer and provider of safe, reliable unmanned aircraft for 

hobby, sport, and commercial applications in the form of the FireFLY6 VTOL Unmanned Aircraft 

System. 

BirdsEyeView Aerobotics wishes to petition for exemption in order to conduct internal and customer 

operator training, perform aerial data collection (mapping/agricultural), inspection, surveillance, and 

SAR operations. The FireFLY6 is designed to carry a variety of payloads such as Day EO, Thermal, HD

Video, High Resolution Still, and Multispectral sensors. The products of these sensors can then be 

used by clients to manage decisions pertaining their areas of responsibilities.

The Quanum Nova Quadcopter is to be used during initial operator training for mechanical and 

software familiarization and proficiency prior to progressing to the FireFLY6 VTOL. The NOVA may also 

be employed by BirdsEyeView Aerobotics in small area data collection, photography, or sensor testing.
197 N Main St, Unit 3

Boscawen, NH 03303

www.BirdsEyeView.aero

Page 5 of 12

UNMANED AIRCRAFT SYSTEMS:

FIREFLY6

BirdsEyeView Aerobotics seeks an exemption to operate the FireFLY6 Small Unmanned Aircraft for 

compensation or hire within the NAS. The FireFLY6 is a VTOL sUAS with a GCS. This sUAS provides 

for vertical takeoff or landing in confined areas where traditional fixed wing flight is impractical or 

unsafe. The aircraft is capable of transitioning between hover and forward-flight modes automatically 

without extensive pilot experience or training. In addition, the system is capable of automatic or manual 

takeoff and landings, including automated RTL in the event a system failsafe event is triggered.

The FireFLY6 has a maximum gross weight of approximately 9 pounds, 95 cm in length, 152 cm of 

wingspan and a maximum speed of 50 knots. The aircraft is propelled by six electric motors. The 

motors receive electrical power from two lithium polymer batteries. The FireFLY6 is constructed of 

frangible materials, mostly EPO Foam, light plywood, and plastics.

QUANUM NOVA

BirdsEyeView Aerobotics seeks an exemption to operate the Quanum NOVA Small Unmanned Aircraft

for compensation or hire within the NAS. The NOVA is a four-rotor miniature helicopter (QuadCopter) 

aircraft with GPS capability that is both flown via traditional R/C and/or GCS. The NOVA is 300mm X 

300mm in size, weighs 875g (flying), and has a typical flight endurance of 15 minutes. The NOVA 

contains an GPS based automatic flight controller capable of waypoint navigation and various pilot-inthe-loop modes. 

Use of the NOVA QuadCopter is primarily to facilitate operator training on the FireFLY6 sUAS, and for 

small-area data collection and photography.
197 N Main St, Unit 3

Boscawen, NH 03303

www.BirdsEyeView.aero

Page 6 of 12

BASIS FOR OUR PETITION

BirdsEyeView Aerobotics is petitioning for an exemption to operate FireFLY6 and NOVA aircraft using 

various sensors and GPS-enabled safety features. These sUAS are operated by a common GCS that 

provides instrumentation data of the aircraft and FPV. The GCS also visually depicts airspace within a 

five-mile radius of airports in order to provide the PIC situational awareness of local airspace.

The FireFLY6 and NOVA have a failsafe function that is triggered in the event communication is lost 

between the aircraft and the R/C transmitter or GCS Data Link. At that time, the aircraft will return to its 

point of takeoff, transition to Hover Mode (in the case of the FireFLY6), and land safely. If radio 

communication is restored, the PIC is able to regain control of flight and land manually. Additionally, 

there is a failsafe function that triggers when the lithium-polymer battery falls below an operator 

specified state of charge. In this case the aircraft will also return to its point of takeoff and land safely. 

The PIC can set a minimum state of charge in the battery failsafe to allow the drone sufficient energy to 

return from any phase of its mission.

Under the requested exemption, BirdsEyeView Aerobotics ensures all operators have completed sUAS 

education and training programs including all applicable regulations and guidance documents such as

aeronautical background information including charts, NOTAMs and aircraft circulars, radio

communications procedures, basic sUAS Aerodynamics, weather factors, and safe operations 

procedures.

CONDITIONS AND LIMITATIONS

As the operator of these aircraft, BirdsEyeView Aerobotics is committed to the following conditions and 

limitations on its operations. BirdsEyeView Aerobotics understands that failure to comply will be 

grounds for the immediate suspension or rescission any exemption granted.

1. Operations are limited to the sUAS stated above when weighing less than 55 pounds 

including payload.

2. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per hour)

3. The aircraft will be operated at an altitude of no more than 400 feet (122 meters) AGL

unless under the allowance of a Standard COA approved independently.

4. The aircraft will be operated within VLOS of the PIC or SO at all times. This requires the 

PIC to be able to use human vision unaided by any device other than corrective lenses, 

as specified on the PIC’s or SO’s U.S. driver’s license.

5. All operating documents needed to operate the aircraft will be accessible during flight 

operations and made available to the administrator upon request. The operator will also 

present updated and revised documents if it petitions for extension or amendment.

6. Any aircraft that has undergone maintenance or alterations that affect the aircraft 

operation or flight characteristics, e.g. replacement of a flight critical component, will 

undergo a functional test flight prior to conducting further operations. 
197 N Main St, Unit 3

Boscawen, NH 03303

www.BirdsEyeView.aero

Page 7 of 12

7. BirdsEyeView Aerobotics is responsible for maintaining and inspecting the sUAS to 

ensure that it is in a condition for safe operation.

8. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the sUAS 

is in a condition for safe flight.

9. BirdsEyeView Aerobotics will follow all third-party equipment manufacturer’s 

maintenance, overhaul, replacement, inspection, and life limit requirements for the 

aircraft and aircraft components.

10. The PIC will hold a sUAS flight training certificate and a valid U.S. driver’s license issued 

by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government.

11. BirdsEyeView Aerobotics will not permit any PIC to operate unless the PIC 

demonstrates the ability to safely operate the sUAS in a manner consistent with how the 

sUAS will be operated to acquire aerial data, including evasive and emergency 

maneuvers and maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours and currency will be logged in a manner 

consistent with 14 CFR § 61.51(b). BirdsEyeView Aerobotics will operate flights for the 

purposes of training BirdsEyeView Aerobotics PICs and SOs (training, proficiency, and 

experience building) and determining the PIC’s ability to safely operate the sUAS.

12. The aircraft will not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport’s management is 

obtained or otherwise permitted by a COA.

13. The aircraft will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

14. If the sUAS loses communications, the aircraft will return to the takeoff location.

15. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

16. The PIC will be prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the aircraft to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

17. All operations shall be conducted in accordance with an ATO -issued COA if the blanket 

COA does not cover the intended operation.

18. Documents used by BirdsEyeView Aerobotics to ensure the safe operation and flight of 

the sUAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be 

available to the PIC at the GCS of the sUAS any time the aircraft is operating.

19. The aircraft will remain clear and give way to all manned aviation operations and 

activities at all times.

20. The sUAS may be operated by the PIC from a moving device or vehicle; however, 

specific requests will be made via subsequent COA.

21. All flight operations will be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: a. Barriers or structures are present that 

sufficiently protect nonparticipating persons from the aircraft or debris in the event of an 

accident; or b. The owner/controller/operator of any vessels, vehicles or structures has 

granted permission for operating closer to those objects and the PIC has made an 

assessment of the risk of operating closer to those objects and determined that it does 

not present an undue hazard.
197 N Main St, Unit 3

Boscawen, NH 03303

www.BirdsEyeView.aero

Page 8 of 12

22. The PIC, SO, operator trainees or essential persons will not be considered 

nonparticipating persons under this exemption.

23. All operations conducted over private or controlled-access property will be conducted 

with the permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be obtained 

for each flight to be conducted.

24. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be reported to 

the FAA's sUAS Integration Office (AFS −80) within 24 hours. Accidents shall be 

reported to the National Transportation Safety Board (NTSB) per instructions contained 

on the NTSB Web site: www.ntsb.gov.

SECTIONS OF 14 C.F.R FROM WHICH BIRDSEYEVIEW 

AEROBOTICS SEEKS EXEMPTION

14 C.F.R. (Format) Part 21 & Subpart H: Airworthiness certificates

Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates 

as required by FAR §91.203(a)(1). Given the size and limited operating area associated with the 

aircraft to be utilized by BirdsEyeView Aerobotics, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform 

Act. The Federal Aviation Act (49 USC §44701(f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability and proximity to airports and 

populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates 

that the sUAS operated without an airworthiness certificate, in the restricted environment and 

under the conditions proposed, will be at least as safe, or safer, than a conventional aircraft 

operating with an airworthiness certificate without the restrictions and conditions proposed.

14 C.F.R. 45.23(b): Marking of the aircraft

This regulation requires that certain experimental, provisionally certified aircraft, or light-sport 

category aircraft to be marked with letters between 2 inches and 6 inches high “limited”, 

“restricted,” “light-sport,” “experimental,” or “provisional,” near each entrance to a cabin, cockpit 

or pilot station. Even though the sUAS will have no airworthiness certificate, an exemption may 

be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the 

word “Experimental” can be placed. Given the size of the sUAS, 2-inch lettering may be 

impossible. BirdsEyeView Aerobotics will mark the sUAS as practicable.

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the sUAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the pilot operating the aircraft to have completed a 

sUAS flight-training course. Unlike a conventional aircraft that carries the pilot and passengers, 

the sUAS is remotely controlled. The area of operation is controlled and restricted, and all flights 
197 N Main St, Unit 3

Boscawen, NH 03303

www.BirdsEyeView.aero

Page 9 of 12

are planned and coordinated in advance. The risks associated with the operation of the sUAS 

are so diminished from the level of risk associated with commercial operations contemplated by 

Part 61 when drafted, that allowing operations of the sUAS as requested exceeds the present 

level of safety achieved by 14 CFR 61.113(a) and (b).

14 C.F.R. 91.7(a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft BirdsEyeView 

Aerobotics contemplates operating, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness. Given the size of the aircraft, frangible 

construction, and the operational restrictions put on the aircraft, an equivalent level of safety will 

be provided.

14 C.F.R. 91.9(b) (2): Civil aircraft flight manual, marking and placard requirements

The sUAS, given its size and configuration has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained 

by keeping the Operating Manuals at the ground control point where the pilot flying the sUAS 

will have immediate access to it.

14 CFR 91.103: Preflight action

This regulation requires the PIC take certain actions before each flight to ensure the safety of 

flight. An exemption is needed from this requirement, as the pilot will take separate preflight 

actions, including checking for weather conditions, checking flight battery or fuel requirements, 

checking takeoff and landing distances, and all other actions in the Operating Manual and safety 

checklists. These actions will provide an equivalent level of safety

14 C.F.R. 91.109: Flight instruction

Section 91.103 provides that 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. By design, sUAS do not have fully functional dual controls. Flight control is 

accomplished through the use of a GCS that communicates with the aircraft via radio 

communications. The equivalent level of safety is provided by the fact that neither a pilot nor 

passengers will be carried in the aircraft, the ability to control the sUAS via radio signals from 

the controller is unaffected by the size and speed of the aircraft.

14 C.F.R. 91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. The sUAS will never 

operate at altitude higher than 400 AGL and all operations will occur during daylight hours under 

VMC only. The equivalent level of safety will be achieved given the size, weight and speed of 

the sUAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner. Because advance notice to the property owner and any onsite 

personnel, as well as the precautions outlined below, all affected individuals will be aware of the 

planned flight operations. Flight operations will be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC or SO), vessels, vehicles and structures, 
197 N Main St, Unit 3

Boscawen, NH 03303

www.BirdsEyeView.aero

Page 10 of 12

unless operations do not present an undue hazard. The sUAS will remain within visual line of 

sight of the PIC or SO. Flight operations will be conducted at least 5 miles from an airport. The 

PIC or SO will provide notification to the local Flight Standards District Office and airport 

controller of all operations within 5 miles of an airport. The FAA will have advance notice of all 

operations through the filing of notices-to-airmen. Compared to flight operations with aircraft or 

rotorcraft weighing far more than the sUAS proposed herein, any risk associated with our 

operations is far less than those presently presented with helicopters and other conventional 

aircraft operating at or below 500 feet AGL. In addition, the low-altitude operations of the sUAS 

will ensure separation between these sUAS operations and the operations of conventional 

aircraft that must comply with Section 91.119.

14 C.F.R. 91.121: Altimeter Settings

This regulation requires each person operating the aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure.” The sUAS will have a barometric altimeter, in 

addition to a GPS altitude read out. An equivalent level of safety will be achieved by the PIC 

confirming the altitude of the launch site shown on the GCS altitude indicator before flight and 

comparing the reading to its barometer reading.

14 C.F.R. 91.151(a): Fuel requirements for flight in VFR conditions

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Relief from 

Section 91.151(a)(1) is requested to the extent required to allow flights of sUAS during daylight 

hours in VFR conditions to continue until 90 percent of remaining battery power or fuel reserves 

remain. BirdsEyeView Aerobotics seeks the requested relief because without an exemption 

from Section 91.151(a)(1), the flight time duration of the selected aircraft will be reduced and 

severely constrain the practicality of any aerial acquisition of data that BirdsEyeView Aerobotics

proposes to conduct pursuant to this Petition. The technical specifications of the proposed 

sUAS, their Operations Manuals, and BirdsEyeView Aerobotics’ proposed operating limitations, 

ensure that BirdsEyeView Aerobotics will safely operate the selected aircraft during daylight 

hours in VFR conditions until 90 percent of remaining battery power or fuel reserves remain.

14 C.F.R. 91.203(a) & (b): Carrying civil aircraft certification and registration

The sUAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. 

Therefore, there is no ability or place to carry certification and registration documents or to 

display them on the sUAS. An equivalent level of safety will be achieved by keeping these 

documents at the ground control point where the pilot flying the sUAS will have immediate 

access to them, to the extent they are applicable to the sUAS.

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

These regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given 

that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to BirdsEyeView Aerobotics. Maintenance will be accomplished pursuant 
197 N Main St, Unit 3

Boscawen, NH 03303

www.BirdsEyeView.aero

Page 11 of 12

to the user guide or operating manual. An equivalent level of safety will be achieved because 

these aircraft are limited in size and will carry a small payload and operate only in restricted 

areas for limited periods of time. If mechanical issues arise, the sUAS can land immediately and 

will be operating from no higher than 400 feet AGL. The PIC will ensure that the sUAS is in 

working order prior to initiating flight, perform required maintenance and keep a log of any 

maintenance performed. Moreover, the PIC is the person most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

PUBLIC INTEREST

Approval of exemptions allowing commercial operations of UASs for aerial acquisition of data enhances 

safety while reducing risk. Manned aircraft in certain application create a greater risk because the 

aircraft are much larger and carry an onboard human pilot. In contrast, a sUAS weighing 55 pounds or 

less will carry no passengers or crew and, therefore, will not expose them to the risks associated with 

manned aircraft flights. In addition, streams of aerial data will allow large commercial entities to make 

decisions about how to best deploy ground resources and ensure the safety and cost-effectiveness of 

their operations.

EQUIVALENT LEVEL OF SAFETY

BirdsEyeView Aerobotics proposes that the exemption requested herein apply to civil aircraft that have 

the characteristics and that operate within the limitations listed herein. These limitations provide for at 

least an equivalent or even higher level of safety to operations under the current and proposed 

regulatory structure.

PRIVACY

All flights will occur over private or controlled access property with the property owner’s prior consent 

and knowledge. Images or video taken of individuals will have consented to being filmed or otherwise 

they will be made anonymous.

NATIONAL SECURITY

Given the small size of the sUAS involved and the restricted environment within which they will operate, 

our petition presents no national security issue. We respectively request exemption under Section 333 

to enable BirdsEyeView Aerobotics to operate efficient, limited, low-risk commercial sUAS operations 

for the activities stated respecting at all times the space and privacy of citizens and property while 

keeping airspace safe.
197 N Main St, Unit 3

Boscawen, NH 03303

www.BirdsEyeView.aero

Page 12 of 12

Hereby Submitted,

Adam R. Sloan

Adam R. Sloan

CEO

BirdsEyeView Aerobotics

197 N Main St, Unit 3

Boscawen, NH 03303

Prepared by:

Erich J. Freymann

Erich J. Freymann

Flight Technician

BirdsEyeView Aerobotics