Brandon McDonald CEO Royal	Vision	Productions	LLC 1315	14 th St	Sw Puyallup,	WA	98371 253

- 576

- 0185 royalvisionnw@gmail.com

Re: Request for exemption from multiple regulatory provisions to allow the use of small unmanned aerial systems on land controlled by clients of Roy al Vision Productions LLC to assi st in the safe inspections of infrastructure and Photograph y or Videograph y for our clients.
To Whom It May

Concern, Roy al Vision Productions LLC (RVP) res pectfully requests an exemption from multiple provisions of Title 14 of the Code of Federal Regulations (C.F.R.) to permit the use of small unmanned aerial s ys tems (sUAS) to assist in the inspection of infra structure and photograph y or videograph y for our clients. I am requesting the exemption from these Title 14 codes with the objective to maximize safet y in the infrastructure inspection industry along with providing highly sought after, useful photography and videograph y for the real estate industry. RVP is requesting FAA exemption for sUAS safe operation photograph y and videography content. The intended plan of use of RVP’s sUAS would be beneficial to the public for many way s. Exemption would not completely eliminate the need for in

- person visual inspecti on of infrastructure, but it would make it a much safer operation. Utilizing the abilities of sUAS will help visualize the possibility of fault y infrastructure before going f or the in

- person inspection. RVP anticipates that the visualizati on you obtain from a sUAS would be a great asset regarding infrastructure safety assessme nts and preventative measures, a long with initial post acc ident assessment of infrastructure , before sending in

person inspectors or first responders. The approval for exemption, i n this case, would accelerate the public interest and enhance the safety and efficiency

of infrastructure operations. There are many reasons wh y infrastructure can fail or can cause infrastructure to be unusable for extended periods of time, extreme weathe r conditions such as heat and cold, heav y snow, earthquakes, landslides, torrential rain and other factors like excess weight, abandoned vehicles blocking and more , gi ving reason as to wh y inspections need to be done on a regular basis. Our potential clients’ employ ees routinel y inspect infrastructure, such as bridges, su pport structures, tunnels, rail road tracks and more. The work is being done b y personnel in motor vehicles, specialized equipment or on foot. While every

safet y precaution is being exercise d, there is alway s a risk associated with an employ ee going out onto a structure. In order to do this, usually they have to climb onto or over structures, which can be slippery , sharp or rough because they are exposed to the elements. Using a sUAS will not eliminate all risks associated with this type of work, butit will greatl y reduce the risks to employees b y having a remote, live streaming aerial view that would be impossible to get otherwise. Fixed wing aircraft are not suitable for these ty pes of jobs because of the altitude that they are required to fl y safely at. The images and video would be to far away to notice any

small anomalies in the assets, thus making the footage irrelevant. Helicopters would be a better option than fixed wing, but the fuel needed is highl y flammable, there is more risk to human safet y and it much more costly

. In the case of a nat ural disaster or collapse , first responders and infrastructure inspectors usually

go into a situation with little prior knowledge of what they are u p against because the urgency of the situation calls to bring people and property , if possible , to safety

a s fast and safe as they

can. RVP thinks a sUAS would help first responde rs b y providing them with a quick , live streaming assessment of the situation before they

proceed. For inspe ctors, it would give them a firsthand hand view of what part of the infrastructure has failed with out putting their life in danger. Helicopters and small planes have been used for p urposes like these in the past, but you can’t have them dispatched to the incident as fast as you can put a sUAS in the air. The cost to fuel planes and helicopters along with hiring pilots is not co st efficient compared to a sUAS. There is no fossil fuels powering the sUAS, nor does it require a cockpit active pilot, there for making it safer to fl y over natural disasters such a s post

- earthquake destruction, wildfires or collapsed infrastructure

. With the sUAS you can also get a more up

- close, controlled
v iew of collapsed infrastructure compared to a plane or helicopter. As you can see, a sUAS will not eliminate all risk from the operation s but it will provide a greatly beneficial added safet y measure to every job. This will be a highl y valued benefit in th e public’s interest. Using sUAS in the real estate industry is greatly beneficial to real estate agents, land surveyors, people in the market for purchasing real estate and people who greatl y value their propert y or landscape. RVP anticipates the continua l growth in the want for aerial views for high

- end propert y and sizeable parcels of land. Using a sUAS on private land will not adversel y affect safet y. It will be used in a contr olled environment, only photographing the home or propert y that is to be list ed or showcased. These ty pes of operations don’t call for flights to ascend to altitude s greater than 200 feet, all done while keeping the sUAS in direct line of sight. Using sUAS for real estate listing purposes is very beneficial to the selling agent and to potential buy ers. For the listing agents, it show cases home s in a unique way that focuses on the exterior of the home and its propert y in a single picture instead of multiple. It also showcases unique landscape features better than ground photographs or video. For potential buy ers this is a great way to view the propert y without being there in pe rson. If you live out of the state that you intend to move to, sUAS are very

beneficial because they show you a complete over view of the propert y, the house and how well the grounds have been maintained . The aerial operators that fly fixed wing aircraft o ver properties can only get shots from one angle and need to fl y at great altitudes for safe operations. The qualit y of the photos from these altitudes aren’t nearl y as good as what can be achieved with up close, sUAS photos. RVP can also get multiple angl es of the house, showing the front, back and sides of the house and propert y. A sUAS will also benefit land survey ors and people that are proud of their propert y orlandscape alike. Surveyors normally use satellite imagery to view a property . The images yo u get from satellites don’t provide high details in their photos because of their altitude. RVP hopes that survey ors will utilize our services to provide them with photos that show more detail of the land they are surveying and the topography associated wi th that land. For people that are proud of their landscape or completed landscaping projec t, the best way for them to capture a good overview photo of their work is by standing on the roof of their home . This is a very dangerous way to get a photograph with the potential to fall off, so it would be in their best interest to have the photos done by a sUAS. It’s a safe, effective way

to get the photographs and RVP can shoot it at multiple angles giving the client the best possible view of their hard work.
**Gr anting an exemption would not adversely affect safety.**  The comparison to remote controlled model aircraft, manned civil aircraft and sUAS are greatl y diverse. They have different methods of staying airborne, fuel or power source, abilit y to carry a payload of passengers or cargo and much more. The design and use profiles of model and civil aircraft are very different to sUAS, this is why Iwould like to focus on wh y the sUAS operations would not adversel y affect safety. A granted exemption to RVP will not a dversely affect safet y. RVP is up

- to

- date and knowledgeable on all FAA regulations on safe operating procedures for sUAS. RVP plans to only

fl y the sUAS over client owned or controlled land or property, at altitudes lower than 300 feet to ensure we pose no threat to other aircraft, onl y operate during day light hours, out of congested areas when applicable , and at least 5 miles away from any airport. Our potential clients in real estate and infrastructure operations have already taken certain action to prev ent unauthorized access. For example, rail road tracks are usually elevated, fenced or otherwise secured to prevent public access. And bridges are temporaril y closed to traffic while inspections are taking place. In real estate, most properties are fenced or gated off to prevent public access. RVP intendeds to use the sUAS at low altitudes and low speeds during all of our operations. If the situation arises that we may

need to fly

near an airport, contact will be made with the air control tower and instruct ions from them will be followed, even if it means we are not allowed to fl y. If an exemption is granted that allows the commercial use of sUAS in these industries, it will enhance safet y while reducing risk. If a helicopter was allowed to operate in close proximity to the ground, people and structures, the risks presented are much greater and can cause much more damage to propert y or human life than a sUAS could. These helicopters weigh thousands of pounds and carry over 100 gallons of highl y flammable jet fuel and the sheer mass of these aircraft greatly dwarf the sUAS. We plan to use the DJ I Inspire 1, it weighs just about 5 pounds fully loaded, is battery

powered and virtuall y eliminates all risk because of the reduced mass and lack of combustible fuel. H elicopters and fixed wing aircraft need to fly to and from the inspection site, whereas the sUAS is carried to, launched and lands at the site. The strict operation conditions described abov e and below , with a sUAS weighing less than 55 pounds, will provide an equivalent level of safet y to support the grant of theexemptions requested. Operating the sUAS at low speeds, low altitude and in controlled environments is a much safer operation than conventional helicopters operating in clos e proximity to people and the ground.
To ensure safet y for people associated with the operation as well as the public, the sUAS flight area will be restricted to granted access by the company . A security perimeter will be established before an y flight take s place as part of pre

- flight control and all personnel associated with the operation will be briefed and must consent to be in the area. All others will be excluded from the operating area. During flight, RVP sUAS Pilot in Command (PI C) will stay in visua l line of sight with aircraft and will not fly a distance of more than .5 miles away from take off point or remote controller. All avenues to ensure PIC training is in full compliance and understanding of all FAA sUAS regulations, safe flight practices and sUAS specific operations are exercised . PI C must display their complete competence with new firmware updates, updated FAA regulations, aeronautical knowledge and UAS airmans hip skills before any flights outside of training take place. Two operators will c ontrol the UAS at all time s
. The PI C will control and watch the aircraft at all times, operator two will control the camera and camera operations at all times. An addition al ob server will be emplo yed if needed to ensure that all safet y precautions are bein g addressed and to aid the PIC with avoiding objects. There are no standards for either Private or Commercial sUAS pilot certificates. The safe operation and control of the UAS as described in this application does not depend on the t ype of FAA license he ld by the PIC. Given the restricted and controlled airspace within operations will take place, the key factors needed b y the PIC are knowledge of the airspace within the operation will take place and how that airspace fits into the National Airspace Sy stem (NAS). That knowledge can be and is gained primarily through ground school and not through flight training in fixed wing or rotor aircraft, nor does it depend on the acquisition of a commercial or private pilot’s certificate. Those certificates demonstrat e knowledge of the factors and skills needed for the safe operation of those ty

pes of aircraft (fixed wing or rotorcraft). It cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or ability to sa fel y operate a small unmanned aerial vehicle, within strictly controlled pre

approved airspace. Besides knowledge of airspace regulations, dexterity in the control and operation of the sUAS acquired from actual operation of the aircraft is the most important factor in establishing an equivalent level of safet y. **RVP Safety Operations and Procedures Overview** sUAS Out Of Box Standard Technology
The DJ I Inspire 1 Quadcopter we intend to use comes packed with standard technological safet y features that have be en tested and developed b y highly reputable industry partners. Features include ;
1

- Auto take off, auto land and Return To Home (RTH) features. Before flight starts, a home point will alway s be Global Positioning Sy stem (GPS) locked. If for anyreason the connection between the UAV and the remote contro ller is lost, the UAV has the ability

to automatically

return to its home point and land. 2

- Continually

computing battery

algorithms to make sure it alway s has enough battery to make it safely

back to the home point. Once it reaches that level it will automatically

RTH. Even though it has this feature, RVP’s safe practice is to manually return to home when battery level reaches 30% power reserve. 3

- Automatically

will land if battery

level becomes unstable or vol tage becomes abnormal. 4

- Live streaming video footage to screen attached to each operator’s remote controller. This user - friendly interface shows you every thing you need to know about the current health of your sUAS. It shows exactly how much battery

is remaining, UAV’s altitude, distance from remote controller, battery voltage, GPS maps location, flight path, how many satellites are locked on (averages 15 satellites linked at one time) , and much more. Having the live streaming video helps us see what the sUAS sees, along with being able to see its surroundings and have a better sense of spatial awareness. 5

- Max altitude limit. This allows us to program the UAV to stop climbing in elevation once it reaches a certain altitude. It is RVP’s policy to alw ay s mak e sure that the altitude limiter is set to stop at 350 feet before every flight to ensure we don’t put our sUAS or any other aircraft at risk. Operations
1

- sUAS will alway s be in line of sight of PIC. Operating with the UAV in direct line of sight at all ti mes will eliminate the possibility of loosing connection from the remote controller. 2

- The sUAS of choice wi ll weigh less than 55 pounds and fly at a speed no greater than 50 Knots. 3

- Battery

reserve will alway s exceed the amount needed for actual flight time

. 4

- Flights will alway s stay below 400 Feet Above Ground L evel (AGL). 5

- Spotter will be used if necessary for the operation to ensure maximum safety

. 6

- Radio frequency

spectrum analy sis will be conducted before every flight for optimal connection between UAV and remote controller. 7

- A flight path will be planned out and the airspace that will be used will be thoroughl y checked for telephone or electricit y wires, trees, or other objects that could cause an interference with the sUAS . A briefing going over the day ’s activities will be mandatory for anyone involved in the operations within the safet y perimeter for the project. 8

- Operator will obtain consent from everyone involved in the sUAS operations being performed. Whomever does not consent will be asked to stay 100 feet back from the op eration while sUAS is operational

. 9

- PI C, camera operator and extra spotter , if available , will alway s be able to communicate b y voice. 10

- Written, or verbal permission from propert y owner/s will be obtained before every flight.11

- If in range of any airport, verbal permission from Air Traffic Control Tower must be obtained before an y flight. All altitude information needs to be reported in FEET AGL. 12

- The operator’s manual and this petition of exemption must be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operator’s manual, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operator’s manual. 13

- All maintenance of sUAS must be up to date as explained in the operator’s manual maintenance schedule. If maintenance is not complete, the sUAS will be grounded until completed. 14

- A thorough inspection by the PI C of the sUAS must be done prior to each flight to ensure its safe to fly . I f the inspection reveals something that prohibits the UAV from having a safe, successful flight, it shall be grounded until the issue has been resolve d and it is clear it is in a safe condition to fly . All maintenance and repairs will be documented in aircraft records. 15

- The operator must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requi rements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be established and identified in the operator’s manual. At a minimum, requirements for the following must be included in the operator’s manual:

a. Actuators / Servos; b. Transmission (single rotor); c. Powerplant (motors); d. Propellers; e. Electronic speed controller; f. Batteries; g. Mechanical dy

namic components (single rotor); h. Remote command and control; i. Ground control station (if used); and j. Any other components as determined by the operator
16

- Prior to operations conducted for the purpose of infrastructure inspections or real estate purposes, the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 6 1.51(b), a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS ty

pe (single blade or multirotor). Prior documented flight experience that was obtained in complianc e with applicable regulations may satisfy this requirement. Training, proficiency , and experience

- building flights can also be conducted under this petition of exemption to accomplish the required flight cycles and flight time. During training, proficiency , and experience

- building flights, all persons not essential for flight operations are considerednonparticipants, and the PI C must operate the UAV with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 17

- The UAV may

not be operated directl y over an y person, except authorized and consenting personnel, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency

. 18

- All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable

. 19

- The operator must develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures must be added t o the operator’s manual. 20

- At least three day s before sch eduled sUAS flight or operation , the operator of the UAS affected b y this exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed infrastructur e inspection. The 3

- day

notification may

be waived with the concurrence of the FSDO. The plan of activities must include at least the following: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS operations conducted under this petition of exemption; c. Name and phone number of the person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N

- number of UAS to be used; e. Name and certificate number of UAS PI Cs i nvolved in the event; f. A statement that the operator has obtained permission from propert y owners and/or local officials to condu ct the operation event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption

- holder or rep resentative; and h. A description of the flight activity , including maps or diagrams of an y area, city , town, count y, and/or state over which sUAS operation will be conducted and the altitudes essential to accomplish the operation.
21

- The documents required under 14 CFR §§ 91.9 must be available to the PIC at the Ground Control Station of the UAS an y time the aircraft is operating. These documents must be made available to the Administrator or an y law enforcement official upon request. 22

- UAS operations may

not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized

.**Support for Petition for Exemption**
In accordance with the procedural requirements of 14 C.F.R. §11.81, RVP provides the following information:
**Contact Information:**
Brandon McDonald
CEO Roy al Vision Productions LLC
1315 14 th ST SW Puy allup, WA 98371
253

- 576

- 0185
royalvisionnw@gmail.com

**Regulatory Provisions From Which RVP Seeks Exemption** RVP believes it may

need an exemption from the following provisions to conduct the proposed operations. In some instances, relief is needed because relief from another provision renders compliance with the regulation at hand infeasible. 333 Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R. §91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. §91.405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.40 9(a)(1)&(2) 14 C.F.R. §91.417(a)&(b) RVP believes an exemption is only needed from the above

- listed regulatory provisions. To the extent that the FAA believes that additional relief is required for RVP to conduct the operations described here, we request an exemption from any such regulatory provisions as well.**The Extent of**  **Requested Relief and the Reasons Relief is Needed Section 333 Aircraft Exemption Status:**  Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate based on a consideration of the size, weight, speed, operational capability of the particular UAS, as well as its proximity to airports and populated areas. An analy sis of these criteria demonstrates that the sUAS operated without an airworthiness certificate in the areas and under the conditions proposed b y RVP will be at least as safe, or safer, than a conventional aircraft (fix ed wing or rotorcraft) operating with an airworthiness certificate without the conditions proposed in this request. The sUAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates exclusively

within a secured area. Unlike o ther civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator and observer. Operations will be conducted in compliance with the FAA and with local public safet y requirements to provide securit y for the area o f operation as is now done with conventional equipment, infrastructure insp ection and real estate photography . These safet y enhancements provide an expanded degree of safet y to the inspectors over conventional operations. Lastl y, application of these same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its siz e, speed of operation, location of operation, lack of explosive materials and inability to carry a substantial external load. Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, this meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certif icate, upon consideration of the size, weight, speed, operational capability , and proximity to airports and populated areas of the particular sUAS. In all cases, an anal ys is of these criteria demonstrates that the UAS operated without an airworthiness cert ificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions propose d.14 C.F.R. §61.113(a) and (b) **§61.113 Private pilot privileges and limitations: Pilot in command.** (a) Except as provided in paragraphs (b) through (h) 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 priv ate pilot may , for compensation or hire, act as pilot in command of an aircraft in connection with an y business or employment if: (1) The flight is only

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

f or compensation or hire.

***** RVP anticipates using specialized, highl y trained sUAS staff to conduct the sUAS operations. While these individuals will not hold commercial pilots lisence. The sUAS operations will not carry

persons or propert y for compensation or hire because of the size, s ince it will be used solely to assist in the inspections of infrastructure, bridges, rail road tracks, tunnels, out buildings and real estate. T he employ ees’ operation of the sUAS will not be incident al to their employ ment with RVP , and they will be compensated for such work. Without an exemption, the pilot would be required to hold a commercial pilot certificate under §61.133. However, the risk associated with the proposed operations is less than the risk posed b y a traditional aircraft. The sUAS will fly at altitudes well below the permissible limits for other civil aircraft, eliminating the risk to other aircraft, and within a geographical envelop e under the sole control of RVP clients. Accordingl y, the risk wou ld be limited to RVP personnel, who will be appropriatel y outfitted in safet y gear, and RVP’s client’s propert y on the ground. Requiring a commercial pilot certificate would provide no appreciable safet y benefit and would needlessl y impose additional cost on RVP . Because the contemplated operations would not comply with §61.113(b)(1) and none of the other exceptions to paragraph (a) apply , relief is needed from both paragraphs (a) and (b).

14 C.F.R. 91.119(c) **§91.119 Minimum safe altitudes: General.** Except when necessary

for takeoff or landing, no person may operate an aircraft below the following altitudes: *** (b) Over congested areas. Over an y congested area of a cit y, 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) Ov er 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 an y person, vessel, vehicle, or structure. *****

RVP submits that the only relief it requires from §91.119 is from the minimum altitudes listed in paragraph s (b) and (c). Relief is required from paragraph (b) for fixed wing operations because asset evaluation of bridges, railroads , and other structures may be near a populated area. Asset evaluation from 1,000 feet above an y obstacle within a horizontal radius of 2,000 feet would pose inefficient to the operation and asset evalu ation. Operations at this altitude would pose a heightened risk of collision with another aircraft , safety

can only be assured through an exemption. RVP’s sUAS operations near populated areas would be limited to 150 feet AGL and temporary closures or restricted access to the area of operat ion while sUAS is in operation would be strictly enforced. Relief is required from paragraph (c) for fixed wing operations because asset evaluation conducted at 500 feet or higher is insufficiently distinct to be meaningful to the operation . Since operatio ns at this altitude also pose a heightened risk of collision with another aircraft, safety can onl y be assured through the grant of an exemption. The anticipated uses of the sUAS are described above in the Operations section . Additionally , relief should no t be needed from paragraph (a) because an emergency landing of the aircraft due to a power failure will not create an undue hazard to persons or propert y on the surface. As noted in the explanation of why an exemption will n ot adversely affect safet y, RVP clients has exclusive use of the land over which the sUAS will b e operated, and public ac cess is restricted. It also has exclusive use of significant portions of land adjacent to the infrastructure and structures that will be the objects of evaluation and anal ys is. RVP ’s Clients tightly control access to land and have the ability to assure that no individuals unassociated with the planned operations are on the affected land. As such, the risk of injury

is minimal.

14 C.F.R. 91.121 **14 C.F.R. §91.121 Alti meter Settings**  This regulation requires each person operating an aircraft to maintain cruising altitude b y reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” ***** As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may

be needed. An equivalent level of safet y will be achieved b y the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground

- based on

- screen display . This altitude information will be generated b y equipment installed on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or an y combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the pilot.

14 C.F.R. 91.151 **§91.151 Fuel requirements for flight in VFR conditions.** (a) 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 fl y a fter that for at least 30 minutes. (b) No person may

begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weath er conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 20 minutes. ***** Operating the sUAS in a pre

- defined area with less than 30 minutes of reserve fuel does not raise the type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in the event it has to be flown to an alternate airport or circle the planned airport in the event o f unanticipated conditions. RVP does not intend to use the sUAS for point

- to

- point flights and will not operate the sUAS beyond visual line of sight. Nor will the sUAS require an airport in order to land. Rather, RVP will operate the sUAS using pre - planned flight paths (taking into account weather conditions) designed to allow the sUAS to fly

to the point of intended landing. As suc h, there is no need for a time

- based e xcess fuel requirement. Rather it should be sufficient to require onl y as much additional excess flight capacit y as necessary to safel y lan d the sUAS. We believe that a 30 % battery reserve is more than sufficient to meet this objective.14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b) **§91.405 Maintenance required.** 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; ***** **§91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.**  (a) No person may

operate any

aircraft that has undergone maintenance, rebuilding, or alteration unless

– (1) It has been appr oved for return to service b y a person authorized under §43.7 of this chapter; ***** **§91.409 Inspections.** (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

__ (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service b y a person authorized by §43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. ***** **§91.417 (a) & (b)** *****
RVP believes that an exemption from these three maintenance requirements is appropriate because the FAA has not developed maintenance standards that would allow an operator to meet the part 91 maintenan ce requirements. In particular, there are no individuals authorized by the FAA to approve a sUAS for return to service under §91.407(a) or to conduct the initial airworthiness and annual return to service inspections required b y §91.409( a). RVP will mainta in the aircraft as in structed in the owner’s manual and will not operate the aircraft until it has reasonabl y determined that any needed repairs have been made. However, because of the technical impossibility of meeting the requirements of §§91.405(a), 407 (a), 409(a) and 417(a)&(b), we believe an exemption from these provisions is appropriate.Please feel free to contact me at an yt ime, via phone number or email provided if there are an y questions or concerns. Thank you for your time and consideration.

Brandon McDonald CEO, Roy al Vision Productions LLC

**Summary for Federal Register Publication** Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register should the FAA determine that publication is needed.
Petitioner: Roy al Vision Productions LLC
Sections of 14 C.F.R. Affected: 333 Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R. §91.119 (b)& (c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. §91.405( a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a) 14 C.F.R. §91.417(a)&(b) Brief Description Of Relief Sought : Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 C.F.R., 61.113(a)&(b)), 91.119 (b)& (c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 91.417(a)&(b) to c onduct sUAS operations over RVP Client’s owned or controlled land, solely

during daylight hours, to assist in the safe evaluation an d anal ys is of infrastructure operations and real estate . In general, sUAS operat ions are intended to be conducted in areas remote from both congested areas and airports. Some operations may be near populated or congested areas, in which case extra safety precautions for operation will be enforced. The nature o f operations anticipated by RVP requires that the sUAS be flown at relativel y low altitudes. RVP expects that in mos t cases , the sUAS will be flown less than 75 feet from the highest structure along the path of the sUAS and in no instances will be flown higher than 400 feet above the ground. Accordingly, the risk of interference with other aircraft is minimal.**Proposed	Aircraft	(sUAS)	Make	and	Model	For	Proposed	Operations: DJI	Inspire	1** 

**Specifications	Information:** 

# AIRCRAFT Model T600 Weight	(Battery	Included) 2935	g Hovering	Accuracy	(GPS	mode) Vertical:	0.5	m Horizontal:	2.5	m Max	Angular	Velocity Pitch:	300°/s Yaw:	150°/s Max	Tilt	Angle 35° Max	Ascent	Speed 5	m/s Max	Descent	Speed 4	m/s Max	Speed 22	m/s	(ATTI	mode,	no	wind) Max	Service	Ceiling	Above	Sea Level 4500	m	(Default	altitude	limit:	120	m	above	takeoff	point) Max	Wind	Speed	Resistance 10	m/s Max	Flight	Time Approximately	18	minutes Motor	Model DJI	3510H Propeller	Model DJI	1345T Indoor	Hovering Enabled	by	default Operating	Temperature	Range

- 10°	to	40°	C Diagonal	Distance 559	to	581	mm Dimensions 438x451x301	mm Power	Spectral	Density 9.06mW/MHz 

# CAMERA Name X3 Model FC350 Total	Pixels 12.76M Effective	Pixels 12.4M Image	Max	Size 4000x3000 ISO	Range 100

- 3200	(video)100

- 1600	(photo) Electronic	Shutter	Speed 8s

- 1/8000s FOV	(Field	of	View) 94° CMOS Sony	EXMOR	1/2.3” Lens 20mm	(35mm	format	equivalent)f/2.8	focus	at ∞ 9	Elements	in	9	groups Anti

- distortion Still	Photography	Modes Single	shoot Burst	shooting:	3/5/7	frames Auto Exposure	Bracketing	(AEB):	3/5	bracketed	frames	at	0.7EV Bias Time

- lapse Video	Recording	Modes UHD	(4K):	4096x2160p24/25,	3840x2160p24/25/30 FHD:	1920x1080p24/25/30/48/50/60 HD:	1280x720p24/25/30/48/50/60 Max	Bitrate	of	Video	Storage 60	Mbps Supported File	Formats FAT32/exFAT Photo:	JPEG,	DNG Video:	MP4/MOV	(MPEG

- 4	AVC/H.264) Supported	SD	Card	Types Micro	SD Max	capacity:	64	GB.	Class	10	or	UHS

- 1	rating	required. Operating	Temperature	Range 0°	to	40°	C 

# CHARGER Model A14

- 100P1A Voltage 26.3	V Rated Power 100	W 

# BATTERY	(OPTIONAL)
Name Intelligent	Flight	Battery Model TB48 Capacity 5700	mAh Voltage 22.8	V Battery	Type LiPo	6S Energy 129.96	Wh Net	Weight 670	g Operating	Temperature	Range

- 10°	to	40°	C Storage	Temperature	Range Less	than	3	months:

- 20	to	45°	C More	than	3	months:	22°	to	28°	C Charging	Temperature	Range 0°	to	40°	C Max	Charging	Power 180	W