SOUNDVIEW

AERIAL PHOTOGRAPHY, INC.

Commercial...Industrial...Real Estate...Advertising

Vertical...Oblique...Custom Color...Black and White

May 12, 2015

U. S. Department of Transportation, Docket Operations

West Building Ground Floor Room W12-140

1200 New Jersey Ave.

S E Washington, DC 20590

RE: Petition of Soundview Aerial Photography, Inc. for Exemption Pursuant to 

Section 333 of the FAA Reform Act

Attn: To whom it may concern

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

Act) and 14 C.F.R. Part 11, Soundview Aerial Photography, Inc., operator of Small 

Unmanned Aircraft Systems (sUASs) equipped to conduct aerial photography and 

videography, hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its sUASs, so long as such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.1

Soundview Aerial Photography, Inc. has been providing quality aerial photography 

services in the Washington state Puget Sound area continuously for over 27 years since it 

was formed in 1987. The main portion of our work is supplying the construction industry 

with documentation of their projects. We have been involved in many high profile 

projects over the years. Danny P. Crowell is a FAA licensed commercial pilot with a 

current FAA medical certificate and has current aircraft and commercial personal liability

policies for the company and pilot. We use a FAA registered N26RH Cessna Skywagon 

185 aircraft.

As described more fully below, the requested exemption would permit the operation of 

small, unmanned and relatively inexpensive sUAS under controlled conditions in 

airspace that is 1. Limited; 2. Predetermined; and 3. controlled. The proposed exemption, 

if granted, would allow Soundview Aerial Photography, Inc. to conduct commercial 
operations of small, unmanned aircraft systems (“UAS”) meeting or exceeding all of the 

operational and safety requirements Congress has set forth in Section 333.

Soundview Aerial Photography, Inc. is a media/technology company that plans to exploit 

the capabilities of Unmanned Aerial Systems to offer a multitude of services, including:

- Aerial surveying

- Remote sensing

- Agricultural support

- Real Estate Photography

- Aerial filmmaking and photography

- Construction site inspections and monitoring

- Wildlife and forestry monitoring

- Educational and research operations

Statutory Authority: Section 333, titled “Special Rules for Certain Unmanned Aircraft

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil

UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if

certain unmanned aircraft systems may operate safely in the national airspace system

before completion of the (comprehensive) plan and rulemaking required by section

332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section

332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited

operation authorization” if several factors are met. Petitioner meets all requirements to

permit FAA approval of commercial UAS operations.

The Petitioner Requests Relief From the Following:

Regulations from which 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. 91.121

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)
Unmanned Aircraft System:

sUAVs are oftentimes seen as superior to helicopters due to the smaller devices cheaper

equipment and personnel cost, reduced noise and as such, a much smaller environmental

impact which promotes public safety.

I am petitioning for exemption to enable Soundview Aerial Photography, Inc. to operate a 

DJI Inspire 1 equipped with a three-axis gimbals and using High-Def cameras. This

sUAV has a built-in capability to limit the height it flies above the ground, to limit the 

radius of the distance it flies from the operator and to exclude it from Class B, C and D 

airspace including a no-fly zone feature. The Inspire 1 also has the failsafe function of the 

Naza-M autopilot system which means when the communication between the Main 

Controller and the transmitter is disconnected, the outputs of all command sticks from 

controller will go to the center position. If the GPS signal is good enough, the system will 

automatically trigger Return to Home and will land safely.

The above specifications meet with the Model Aircraft Operating Standards as set

below:

• Soundview Aerial Photography, Inc. will only operate its sUAS in line of sight of a 

pilot and/or observer and will operate at sites that are a 'sufficient distance' from 

populated areas within the sterile area described in the FOPM. Such operations will 

insure that the sUAS will "not create a hazard to users of the national airspace system or 

the public."

• When flying sUAV within 5 miles of an airport, airport operators will be notified and 

the operator will give the right of way to avoid flying in the proximity of full-scale 

aircraft.

• Maximum flight time for each operational flight will be 20 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the

20 minute limit.

• The sUAV will be programmed so that it will not be operated at an altitude of no more

than 400 feet AGL, and not more than 200 feet above an elevated platform from which 

filming is planned.

• Minimum crew for each operation will consist of the sUAS Pilot, and Visual Observer.

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload 

(i.e. camera, lens, and gimbal).
• The sUAV will operate at speeds of no more than 50 knots, can hover, and can

simultaneously move vertically and horizontally.

• Given the small size of the sUAS and the restricted sterile environment within which

they will operate, our sUAS operations adhere to the Reform Act's safety requirements.

The UA, 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 will thereby reduce current risk levels and thereby enhance safety and diminish 

the likelihood of death or serious bodily injury. With a small payload and maximum 

flight time of only 20 minutes, this is offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than 

ground based imagery for displaying the characteristics of large, complex properties with 

several buildings and large trees. The applicants in the past have chartered 2-seat fullsized helicopters for this purpose, which has proven more costly than many potential 

clients have been able to afford. The benefits of reduced cost and improved quality of 

presentation from the UA will be valuable to and benefit many buyers and sellers of real 

property.

Additionally, I request that I be allowed to use my system to benefit first responders

nearby who might require assistance, including fire fighters, the police, the sheriff, et al.,

while remaining subject to all limitations cited in this application as I do so.

(a) No flight will be made with a Gross weight exceeding 55 pounds;

(b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, 

at an airspeed of no more than 25 knots and no further than 1/8th NM from the PIC;

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able

to communicate by voice at all times during a flight operation;

(d) Operations will be restricted to flights over private property with the permission 

of the property owner;

(e) All required permits will be obtained from state and local government prior to 

operation;

(f) Soundview Aerial Photography, Inc. will not be operating over densely populated 

areas;

(g) Soundview Aerial Photography, Inc. will not be operating over any open-air 

assembly of people;

(h) Soundview Aerial Photography, Inc. will not be operating over heavily tracked 

roads;
(i) Soundview Aerial Photography, Inc. will not be operating within 5 NM of an 

airport or heliport without prior permission.

I respectfully request exemption under Section 333 to enable Soundview Aerial 

Photography, Inc. to operate efficient, limited, low-risk commercial sUAV operations for 

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

whilst keeping our skies safe.

Sincerely,

Dan Crowell, President

Soundview Aerial Photography

14105 Burn Rd.

Arlington, WA 98223

(360)691-4419 (office)

(425)478-2424 (cell)

dan@soundviewaerial.com

www.soundviewaerial.com
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Soundview Aerial Photography, Inc. requests an exemption from the following 

regulations as well as any additional regulations that may technically apply to the 

operation of the sUAS:

14 CFR Part 21, Airworthiness Certificates. This part establishes the procedures for 

the issuance of an airworthiness certificate. While the FAA continues to work to develop 

airworthiness standards for Unmanned Aerial Systems, I request an experimental 

certificate be issued for the DJI Inspire 1 under either or both of the following provisions:

21.191 Experimental certificates. Experimental certificates are issued for the 

following purposes:

(a) Research and development. Testing new aircraft design concepts, new 

aircraft equipment, new aircraft installations, new aircraft operating techniques, or new 

uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other 

operations to show compliance with the airworthiness regulations including flights to 

show compliance for issuance of type and supplemental type certificates, flights to 

substantiate major design changes, and flights to show compliance with the function and 

reliability requirements of the regulations. Since the experimental certificate can be used 

for commercial purposes such as market surveys, sales demonstrations, and customer 

crew training, I would expect that an experimental certificate would permit my

commercial purpose as well. The aircraft will not carry persons or property, will not carry

fuel, and will only fly under strict operational requirements. Combined with the UA's 

light weight, being constructed primarily of carbon fiber and plastic, I propose that the 

UA will be at least as safe, if not safer, than a conventionally certificated aircraft 

performing the same mission. If an experimental airworthiness certificate is not

appropriate for this application, then I request an exemption of 14 CFR Part 21, Subpart 

H, and the requirement for an airworthiness certificate in general, citing the equivalent 

level of safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations 

provide that each aircraft must 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 near the entrance to the cabin, 

cockpit, or pilot station. The sUAS does not have an entrance in which the word 

"EXPERIMENTAL" can be placed, and may not have a registration number assigned to 

it by the FAA. I propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the 

PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft 

while it is preparing for launch will be able to see the designation. Additionally, I feel 

that the permanent placard discussed in the previous paragraph will provide the aircraft's
registration information at the ground station. Finally, I will display at the ground station 

a high contrast flag or banner that contains the words "Unmanned Aircraft Ground 

Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM 

of the ground station, the banner should be visible to anyone that observes the aircraft and 

chooses to investigate its point of origin.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 

61.133 Commercial pilot privileges and limitations. The regulation provides that no 

person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for 

compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command 

of an aircraft in connection with any business or employment if: (1) The flight is only

incidental to that business or employment; and (2) The aircraft does not carry passengers 

or property for compensation or hire. My proposed operations require that the PIC must 

hold at least a Private Pilot Certificate issued by the FAA and since the aircraft cannot

carry passengers or property, I feel I meet the intent of 61.113 Subparagraph (b) even

though the intent of this application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without 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 aircraft flight manual, marking, and placard requirements. This 

regulation provides that no person may operate an aircraft unless a current, approved 

flight manual is in the aircraft. I assume that the intent of this requirement is to ensure 

that flight manual information is available to the aircrew while operating the aircraft. I 

request an exemption to this requirement since the aircraft is not only too small to carry 

documentation, the documentation would not be available to the crew during flight 

operations. To obtain an equivalent level of safety and meet the intent of 91.9, I propose 

that a current, approved sUAS Flight Manual must be available to the crew at the ground 

station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight 

tests. The regulation states that "No person may operate a civil aircraft that is being used 

for flight instruction unless that aircraft has fully functioning dual controls." The sUAS 

System groundbased control station consists of a small hand-held radio transmitter and 

while it does not offer a second set of "controls", both the student and instructor can, and 

will, operate the single set of controls simultaneously. With both student and instructor 

having "hands-on" the controls during flight, I feel that this technique meets the intent 

91.109 and provides an equivalent level of safety.

91.119 Minimum safe altitudes: General. The regulation states that over sparsely 

populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, 

vehicle, or structure. Since the typical mission of the sUAS would be photography or 

survey of persons, vessels, vehicles or structures it would be necessary to operate closer 

than 500 feet to the items listed. Operations will only be flown over property or persons 

where permission has been obtained and careful pre-planned has been performed. The 
aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency 

landing without undue hazard to persons or property on the surface. Therefore I maintain 

that due to the small size of the UAS, the hazard to persons, vehicles and structures is 

minimal compared to manned aircraft, which should be considered in granting the 

exemption.

CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain 

cruising altitudes by reference to an altimeter setting available within 100 NM of the 

aircraft. The sUAS will always fly below 400 feet AGL and will not need to maintain 

cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the sUAS onboard 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. The regulation 

provides that no person may begin a flight in an airplane under day-VFR conditions 

unless there is enough fuel to fly to the first point of intended landing and to fly after that 

for at least 30 minutes. I feel the intention of this paragraph is to provide an energy

reserve as a safety buffer for delays to landing. The sUAS is battery operated and the 

maximum duration of flight from a single battery charge is 18 minutes with a 20% 

reserve. Since the aircraft will never fly more than 1/8 NM from the point of intended 

landing, a full battery charge at launch will ensure that I meet the reserve energy 

requirement of this paragraph. I request an exemption 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 regulation 

provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. Additionally,

subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight 

of 5.3 pounds, the sUAS is too small to carry documentation, does not have an entrance, 

and is not capable of carrying passengers or crew. To obtain an equivalent level of safety 

and meet the intent of 91.203, I propose that documents deemed appropriate for this 

aircraft by the FAA will be co-located with the crew at the ground control station and 

available for inspection upon request. In order to identify the aircraft, I propose that the 

information found on airworthiness and registration certificates be permanently affixed to 

the aircraft via placard containing the following information plus the word 

"EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, 

Alterations. The regulation provides that the operator is primarily responsible for 

maintaining the aircraft in an airworthy condition, including compliance with part 39 and 

43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to 

service by a person authorized under 43.7" after maintenance and inspection. It is my

intention that the PIC perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service." The PIC will ensure that the 
aircraft is in an airworthy condition prior to every flight and in addition conduct detailed 

inspections after every two hours of flight. Maintenance performed by the PIC is limited 

to repairing small cracks, replacing a propeller, checking electrical connections and

updating software and firmware for the on-board computer. All other maintenance will be

performed by the manufacturer or their designated repair facility. The PIC will document 

work performed in accordance with 91.417. I feel that due to the size, construction, and 

simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

Safety and Benefits of the UAS. Soundview Aerial Photography, Inc. will be using the 

UAS in a variety of applications that generally require expensive full-size manned 

aircraft to complete. Small, light, unmanned aerial vehicles offer myriad benefits over the 

use of full-sized manned aircraft for electric power line inspection, oil/gas pipeline 

inspection, advanced agriculture, film and still photography, just to name a few.

Replacing significantly larger manned aircraft carrying crew and flammable fuel with 

small UAS carrying no passengers or crew creates a much greater margin of safety for 

the pilots and crew. By granting Soundview Aerial Photography, Inc.‘s requested 

exemptions, the FAA will help drive development of safe and successful commercial 

UAS operations and will advance the public knowledge base for such operations. 

Soundview Aerial Photography, Inc. is committed to promoting the UAS research efforts 

of policymakers including the FAA, NASA, DOD and DARPA by sharing data from its 

commercial UAS operations and serving as a resource for future UAS research

operations. Thus, the FAA has good cause to grant this Petition.

Conclusion. As pointed out in this application, all the SUAs which my company would 

use, under authorization by the US DOT-FAA, are small, light-weight devices operated 

within the line of sight of the Pilot-in-Command (PIC), less than 400 feet above the 

ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, or other 

location with aviation activities, unless the air traffic control authorities (ATC) have been 

notified and have authorized each flight within a radius of this distance. 

My sUAV has proven capability for controlled flight. They are devices offered for 

general sale on the market around the world and have often been used as Model Aircraft 

in the USA. I am certain that the studies conducted until now by the FAA, about Section 

332, Public Law 112 -95, 2014, have already provided you with the assurances on the 

airworthiness of sUAVs such as mine.

For the foregoing reasons, the exemptions requested herein should be granted and 

Soundview Aerial Photography, Inc. should be permitted to conduct small UAV

operations in accordance with its manuals and all other operating parameters deemed 

necessary and appropriate by the FAA. The submission of this application and its 

contents is the best demonstration that indeed it is possible to pursue the authorization 

process so that some sUAVs may be used for legitimate commercial activities and under 

reasonably safe conditions.