James Dacri, AeroHiView

163 Madrone Ave

Larkspur, CA 94939

Telephone: 415-515-7807

Email: jdac@pacbell.net

September 7, 2015 

U. S. Department of Transportation 

Docket Management System 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE 

Washington DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir or Madam: 

We respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of 

the Federal Aviation Regulations.

 

Petitioner:

James Dacri, AeroHiView (AHV)

163 Madrone Ave

Larkspur, CA 94939 

Telephone: 415-515-7807

Email: jdac@pacbell.net

AHV intends to incorporate the use of sUASs for a variety of projects which may include but not 

be limited to project and construction management, inspections and monitoring; environmental 

review projects; aerial surveying; agricultural projects; educational and research projects; remote 

sensing projects, wildlife and forestry monitoring projects; aerial filmmaking, photography and 

real estate purposes; search and rescue, etc. 

Specific Section(s) seeking exemption:

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 
Specific Section(s) seeking exemption(cont.):

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) and (b) 

14 C.F.R. 91.215 

14 C.F.R. 91.104 through 91.417 

Extend of relief requested:

To permit commercial operation of Small Unmanned Aircraft Systems (sUASs) for operations 

conducted within and under the conditions outlined herein or as may be established by the FAA 

as required by Section 333. 

Said exemption would permit the operation of sUASs under controlled conditions in limited, 

predetermined and controlled airspace. Upon granting of this proposed exemption request, AHV

would conduct commercial operations of sUASs meeting or exceeding all operational and safety 

requirements per Section 333. 

Public Benefit:

1. Project and construction management, inspections and monitoring. The use of sUASs on 

construction sites may improve the safety of workers, local residents and general public by

assessing potential dangerous situations. Falls and injuries may be reduced or eliminated 

through a more thorough review of the construction sites. In some cases, sUASs may 

reduce the reliance of helicopters or small aircraft to monitor said sites. This may improve 

safety as well as reduce environmental impact by reducing energy usage; 

2. Environmental Review projects. The use of sUASs during the process of reviewing projects 

as required by 24 C.F.R. 50.4, 58.5 and 58.6 would provide a more in-depth Environmental 

Review of the project site as well as surrounding areas. Reliance of helicopters or small 

aircraft may be eliminated; 

3. Aerial surveying. The use of sUASs in connection with aerial surveying of smaller areas 

may eliminate the use of helicopters or aircraft. This could provide a more cost effective, 

safer and more energy efficient product; 

4. Agricultural projects. Wildlife and Forestry projects. The use of sUASs could assist with 

surveying agricultural projects as well as wildlife and forestry projects by providing 

information when problems occur, vermin infestation, fire hazards, etc.; 

5. Remote Sensing projects. The use of sUASs could provide views and information for 

remote and inaccessible areas. This could promote worker safety as well as reduce the 

reliance on helicopters and aircraft; 

6. Educational and Research projects. The use of sUASs could provide information for said 

projects in a more cost effective and efficient manner than other available options
7. Aerial filmmaking, photography and real estate purposes. The use of sUASs 

may provide a point of view previously unavailable through other means. 

They would be more cost effective, efficient and more safely than helicopters 

and aircraft; and 

8. Search and rescue. The use of sUASs may provide assistance to local law 

organizations during search and rescue missions. SUASs may reach areas 

unattainable or viewable with helicopters and aircraft. SUASs may be 

implemented quicker as time is of the essence during search and rescue 

operations. 

Reasons why the exemption would not adversely affect safety or how the exemption would

provide a level of safety at least equal to the existing rule.

Proposed operations using sUASs provide increased safety enhancement especially when 

compared with helicopters and aircraft for the following reasons: 

1. The sUASs will weigh less than ten (10) pounds; 

2. Flights will be operated within the visual line of sight of the pilot; 

3. Maximum total flight time for each operational flight will be thirty (30) minutes. Flight 

times may be less than thirty (30) minutes as the UAS will continuously monitor battery 

reserve and return to the ground station with at least 20% battery power reserved; 

4. Flights will be operated at an altitude of 200 feet AGL. Flights will never exceed 400 

feet AGL; 

5. Minimum crew for each operation will consist of the sUAS pilot and a Visual Observer; 

6. A briefing will be conducted daily by all personnel working with said sUAS; 

7. All onsite personnel and client employees will be required to execute a waiver. 

Verbal/written consent will be required of all persons within 100 feet of flight operation; 

8. Written and/or oral permission from relative property owners will be obtained prior to 

operating the sUAS; 

9. All permits, permissions, etc. will be obtained from local government offices as required; 

10. The sUAS operated will weigh less than 55 pounds including payload (camera, lens, 

gimbal, etc.); and 

11. The sUAS will operate at speeds less than 50 knots, hover and simultaneously move 

vertically and horizontally; 

12. The sUAS will have the capability to return and land at the pre-determined location with 

the Security Perimeter should the sUAS lose communication or GPS signal during any 

operations; 

13. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies; 

14. Operations will not be conducted over densely populated areas or heavily traffic 

highways; 
15. Operations will not be conducted within five (5) NM of an airport or heliport

AHV will abide by all regulations including the following: 

1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. Airworthiness 

Certificates; 

2. 14 C.F.R. 45.23 Display of marks; general and 45.29 Size of marks; 

3. 14 C.F.R. 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations; 

4. 14 C.F.R. 91.7 Civil aircraft airworthiness; 

5. 14 C.F.R. 91.9 Civil aircraft flight manual, marking and placard requirements; 

6. 14 C.F.R. 91.109 Flight instruction; Simulated instrument flight and certain flight tests; 

7. 14 C.F.R. 91.119 Minimum safe altitudes: general; 

8. 14 C.F.R. 91.121 Altimeter settings; 

9. 14 C.F.R. 91.151 Fuel requirements for flight in VFR conditions; 

10. 14 C.F.R. 91.203 Civil aircraft: Certifications required; 

11. 14 C.F.R. 91.205 Powered civil aircraft with standard category U.S. airworthiness 

certificates: Instrument and equipment requirements; 

12. 14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use; 

13. 14 C.F.R. 91.401 Applicability; 

14. 14 C.F.R. 91.403 General; 

15. 14 C.F.R. 91.405 Maintenance required; 

16. 14 C.F.R. 91.407 Operation after maintenance, preventive maintenance, rebuilding or 

alteration; 

17. 14 C.F.R. 91.409 Inspections; 

18. 14 C.F.R. 91.411 Altimeter system and altitude reporting equipment tests and 

inspections; 

19. 14 C.F.R. 91.413 ATC transponder tests and inspections; 20. 14 C.F.R. 91.415 Changes 

to aircraft inspection programs; and 

21. 14 C.F.R. 91.417 Maintenance records. 

 

Privileges of exemption outside the United States.

AHV may wish to exercise the privileges of this exemption outside the United States should a 

contract with a governmental office require same. All required rules and regulations will be 

followed should this occur. 

Equipment and Specifications.

Phantom 3 Professional
Aircraft

Weight (Including Battery And Propellers)

1280 g

Diagonal Size (Including Propellers)

590 mm

Max Ascent Speed

5 m/s

Max Descent Speed

3 m/s

Hover Accuracy

Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m

Horizontal: +/- 1.5 m

Max Speed

16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level

6000 m

Operating Temperature

0°C to 40°C

GPS Mode

GPS/GLONASS

Camera

Sensor

Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

Lens

FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

ISO Range

100-3200 (video) 100-1600 (photo)

Shutter Speed

8s -1/8000s

Image Max Size

4000 x 3000

Still Photography Modes

Single Shot

Burst Shooting: 3/5/7 shots

Auto Exposure Bracketing (AEB): 3/5

Bracketed Frames at 0.7EV Bias

Time-lapse

Video Recording Modes

Phantom 3 Professional

UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

FHD: 1920x1080p 24/25/30/48/50/60
HD: 1280x720p 24/25/30/48/50/60

Phantom 3 Advanced

FHD: 1920x1080p 24/25/30/48/50/60

HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required

Max Bitrate Of Video Storage

Phantom 3 Professional

60 Mbps

Phantom 3 Advanced

40 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4, MOV (MPEG-4 AVC/H.264)

Operating Temperature

0°C to 40°C

Gimbal

Controllable Range

Pitch -90° to +30°

Stabilization

3-axis (pitch, roll, yaw)

Vision Positioning

Max Velocity

Less than 8 m/s (when 2 m above ground)

Altitude Range

30 cm-300 cm

Operating Range

30 cm-300 cm

Operating Environment

Surface with clear pattern and adequate lighting (Lux > 15)

Remote Controller

Operating Frequency

2.400 GHz-2.483 GHz

Max Distance

2000m (outdoors and unobstructed)

Video Output Port

USB

Operating Temperature
0°C- 40°C

Battery

6000 mAh LiPo 2S

Mobile Device Holder

For tablet or phone

Receiver Sensitivity (1%PER)

-101 dBm ±2 dBm

Transmitter Power (EIRP)

FCC: 20 dBm

CE: 16 dBm

Working Voltage

1.2 A @7.4 V

Battery Charger

Voltage

17.4 V

Rated Power

Phantom 3 Professional

100 W

Phantom 3 Advanced

57 W

Intelligent Flight Battery

Capacity

4480 mAh

Voltage

15.2 V

Battery Type

LiPo 4S

Energy

68 Wh

Net Weight

365 g

Max Flight Time

Approximately 23 minutes

Operating Temperature

-10°C to 40°C

Max Charging Power

100 W

App / Live View

Mobile App

DJI GO

EIRP
Also plan to buy the DJI Inspire 1 in the near future.

Please feel free to contact our office if there are any additional questions or concerns. 

Sincerely,

James Dacri

100mW

Live View Working Frequency

2.4GHz ISM

Live View Quality

720P @ 30fps (depending on conditions and mobile device)

Latency

220ms (depending on conditions and mobile device)

Required Operating Systems

iOS 8.0 or later

Android 4.1.2 or later

Recommended Devices

iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad mini 2, iPad mini 2 

Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, 

Android: Samsung tabs 705c, Samsung S6, Samsung S5, Samsung NOTE4, Samsung NOTE3, Goo

Nubia Z7 mini, SONY Z3 EXPERIA, MI 3, MI PAD

*Support for additional Android devices available as testing and development continues.