### September 2, 2015

Exemption No. 12720 Regulatory Docket No. FAA

- 2015

- 2508

Mr. Paul Craig Boutin

President Aerial Video Solutions, Inc. 2304 W. Eagle Feather Road Phoenix, AZ 85085

Dear Mr. Boutin :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated June 2, 2015 , you petitioned the Federal Aviation Administration (FAA) on

behalf of Aerial Video Solutions, Inc. ( hereinafter petitioner or operator ) for an exemption

. The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography and videography

.

See Appendix A for the petition submitted to the FAA des cribing the proposed operations and

the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on th is petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner are the , DJI Phantom 2 Vision+, DJI Inspire 1, and Tarot

680PRO

.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria

### 2

provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the

aircraft and its operation, the Secretary of Transportation has determined that this aircraft

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from

14 CFR part 21

, C ertification pr ocedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the peti tioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public i nterest.

Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Aerial Video Solutions, Inc. is gran ted an exemption

from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data

collection

. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.

### 3

Conditions and Limitations

In this grant of exemption, Aerial Video Solutions, Inc. is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2

Vision+ , DJI Inspire 1, and Tarot 680PRO when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture an d television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC 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 FAA

- issued airman medical cer tificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC a lways maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her des ignation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations st ated in this grant of exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations 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 operating documents,

### 4

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating

document s. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must p etition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at

least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensur e that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inop erable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a conditio n for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption must comply with all manufactu rer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s lice nse issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

### 5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers an d maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with approp riate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. 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.

16. The UA may 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 air port symbo l 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 issued to the exemption holder. The letter of agreement with the airport managem ent must be made available to the Administrator or any law enforcement official upon request.

17. The UA may 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 PI C.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve

power recommen ded by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intend s to conduct operations that cannot be conducted under the terms of the attached COA

.

### 6

22. 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− Num ber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be ava ilable to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonpartici pating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons r emain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and

b. The owner/ controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard

.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or aut horized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the opera tional area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

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

.

### 7

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a mot ion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. 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 aerial filming conducted under this grant of exemption;

c. Name and phone number of th e 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 certific ate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available t o the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes

essenti al to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specifie d in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,

parts 45, 47, 61, and 91.

### 8

This exemption terminates on September 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/ s/

John S. Duncan Director, Flight Standards Service

EnclosuresPage 1 of 9

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE West Building Ground Floor Room W12

- 140 Washington, D.C. 20590

RE: Petition for Exemption Under Section 333 of the Federal Aviation Administration

Modernization and Reform Act of 2012 , public 112

- 95 Feb. 14, 2012, Section 333

Dear Sir or Madam,

Pursuant to Section 33 of the FAA Modernization Act of 2012 and 14 CFR Part 11, Aerial Video Solutions, Inc. ( AVS ) operator of Small Unmanned Aircraft Systems (UAS),

e quippe d to provide cost effective aerial imagery services , hereby applies for an Exemption from the listed Federal Aviation Regulations (FAR) to allow commercial Operations of it’s UAS, so long as such operations are conducted within and under

The conditions and limitations outlined herein or as may be established by the FAA As required by Section 333.

These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure specifically, a safety en hancement to aerial imagery and videography conducted by manned aviation operations

The use of UAS for aerial imagery and videography by AVS reduces the need for personnel to use manned aircraft activities to perform the same function.
Therefore it is in the best interest of the Public for the FAA to approve the Requested exemptions.

The applicant, Paul Craig Boutin, for Aerial Video Solutions, Inc., has be en involved in

aviation for 35 years and radio controlled vehicles for over 5 years. Currently h olds a Commercial Pilots Certificate with an Instrument rating received in 1980. Formally educated at Embry Riddle Aeronautical University in Aeronautical Science. Paul has an in

depth understanding of the capabilities and safety concerns involved in thi s technology and

that it has enormous potential benefit to the community.

Sincerely,

Paul Craig Boutin

President Aerial Video Solutions, Inc. ( AVS ) 2304 w. Eagle Feather Rd. Phoenix, AZ 85085

480

- 575

- 1156 pboutin321@msn.com

submitted: June 2 n d , 2015Page 2 of 9



### Requested Exemptions from Regulations :

14 C.F.R Part 21.185
Airworthiness Certificate
AVS recommends that in consideration of the size, weight, speed and limited operating area associated with these aircraft and their operation, the Secretary of Transportation determines
that these aircraft meet the conditions of Section 333.

14 C.F.R. Part 4 5.23(b) Display of marks
AVS UAS shall 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 will be as large as practicable.

14 C.F.R. Part 61.113(a) Private pilot privileges and limitations The FAA has found in previous grants of exemption that a PIC with a private pilot certificate operating a UAS would not adversely affect operations in the NAS or present a hazard to

persons o r property on the ground.

14 C.F.R. Part 61.133(b) Commercial pilot privileges and limitations The FAA has found in previous grants of exemption that a PIC with a private pilot ce rtificate operating a UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground.

14 C.F.R. Part 91.7(a)
Civil Aircraft Airworthiness
AVS recommends that in consideration of the size, weight, speed and limited operating are a associated with this aircraft and its operation, the Secretary of Transportation determines that
these aircraft meet the conditions of Section 333.

14 C.F.R. Part 91.9(b)(2) &(c) Civil Aircraft Flight Manual, Marking, and Placard Requirements

The FAA has previously determined that relief from these sections is not necessary. Relevant materials may be kept in a location accessible to the PIC in compliance with the regulations.

14 C.F.R. Part 91.103 Preflight Action As FAA approved flight manuals wi ll not be provided for the aircraft an exemption will be

needed. Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoff distances, along will all of those found in attachment "DJI Pilot Training" . An equivalent level of safety will be provided by preflight protoco l (see attachment) to properly match the machine.Page 3 of 9

14 C.F.R. Part 91.109(a) Flight Instruction
AVS will conduct all flight training through procedures specified in Training Instruction (see attachment) during dedicated training sessions. Based on previous decisions made by the FAA
for UAS petitions regarding this regulation,

14 CFR 91.109 UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is

achieved through the use of a control box that communicates with the aircraft via radio

communications. The equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft, and by the speed and size of the aircraft

.

14 CFR 91.113 (a) and (b)
AVS can achieve an equivalent level of safety as achieved by current regulations because the
UAS does not carry pilot nor passenger. While helpful, a pilots' license will not ensure remote control piloting skills.

14 C.F.R. Part 91.119(c)
Minimum Safe Altitude Aircraft will be operated below 400 AGL, but not over congested areas.

14 C.F.R. Part 121 Altimeter Settings The proposed aircraft have a barometric altimeter and GPS derived altitude capabilities. AVS recommends that the altimeter be set to zero feet AGL rather than local barometric pressure or field altitude before flight. Considering the limited altitude of the proposed operations.

14 C.F.R. Part 91.151(a) Fuel Requirements in VFR
Prior relief ha s been granted for manned and unmanned aircraft to operate at less than prescribed minimums.

14 C.F.R. Part 91.203(a) and (b) Certifications Required Original intent of these regulations was to display an aircraft’s airworthiness, certification and

reg istration documents so they would be easily available to inspectors and passengers. Based

on the FAA Section 333 of the Reform Act, authorizes 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 UAS. In all cases, an analysis of these criteria demonstrates that the UAS 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 (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.Page 4 of 9

14 C.F.R. Part 91.405(a) Maintenance Required Given these section only apply to aircraft with an airworthiness certificate, theses sections do not apply to this applicant. As a safety precaution, operator will perform preflight inspections and
ensure UAS is in working condition b efore initiating each flight.

14 C.F.R. Part 91.407(a)(1) Operation after Maintenance
Given this section only appl ies to aircraft with an airworthiness certificate, theses sections do not apply

to this applicant. As a safety precaution, operator will perform preflight inspections and ensure
UAS is in working condition before initiating each flight.

14 C.F.R. Part 91.409(a)(1) and (2) Inspections
Given this section only appl ies to aircraft with an airworthiness certificate, theses sections do not apply to this applicant. As a safety precaution, operator will perform preflight inspections and
ensure UAS is in working condition before initiating each flight.

14 C.F.R. Part 91.417 (a) and (b)

Maintenance Records
Given this section only appl ies to aircraft with an airworthiness certificate, theses sections do not apply to this applicant. As a safety precaution, operator will perform preflight inspections and
ensure UAS is in workin g condition before initiating each flight.

Aerial Video Solutions, Inc. (AVS) is seeking relief from all FARs above preventing applicant from conducting cost effective aerial imagery services taken at levels less than 400ft, at a speed less than 33.5 mph , and with a maximum fligh t time of 25 minutes,. The UAS’s proposed to be

used are listed below are all under 35 pounds. T he UAS meets the definition of "small

unmanned aircraft system " found in section 333 "The Reform Act". In order to obtain high quality photography and video the UAS will be used at speeds much less than it's top speed of 33.5 mph. Due to the UAS being battery powered there are no combustible fuels onboard. Maximum flight time for this particular UAS is 25 minutes battery life, flights to be terminated with 25% battery life remaining. Given the size, weight, speed, and limited operating area associated with
the aircraft to be utilized

. AVS find s this exception to be reasonable with an equivalent, or greater, level of safety to be reached by the operator.Page 5 of 9



### Public Interest :

Removal of human risk from flight operations.

AVS operations of UAS to perform aerial imagery and videography will reduce risk to life and property by decreasing the requirements of personnel to operate manned aircraft to perform

these tasks.

AVS will use battery

- powered UAS that serve as safe and efficient alternatives to the manned
aircraft commonly utilized to conduct aerial imagery and videography.

Also, the flight data, inspection results, recorded observations and lessons learned from these operations will be compiled to further enhance its current safety program.

AVS proposes that the exemptions requested herein apply to civil aircraft that have the
characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations unde r the current regulatory structure because the proposed operations represent a safety enhancement to aerial imagery and videography conducted by manned aircraft.

Reduction in gas emissions associated with powered flight.

Improvement upon cost efficiencies associated with manned flight.

National policy set by Congress favors early integration of UAS into the NAS in controlled, safe,
working environments such as those proposed in this petition. In addition, the public also has an interest in reducing the haz ards and emissions associated with alternate use of helicopters to
conduct similar operations.



### PRIVACY :

All flights will be conducted in accordance with any and ALL federal, state and local laws regarding privacy

AVS will voluntarily participate in the “NoFlyZone” registry and proactively stay current with
updates

- https://www.noflyzone.org/Page 6 of 9



### Aircraft and Equipment requested to be used for compensation or hire :

All aircraft weigh less then 55 pounds

AVS proposes to use Four unmanned aircraft systems (UAS) for aerial video & still photography

DJI Phantom 2 Vision+ V2.0 Quad

- Rotor

- PIC will operate UAS in safe manner that will not
pose threat to person or property and with assistance from a visual observer (VO)

DJI Phantom 2 Vision+ V3.0

- PIC will operate UAS in safe manner that will not pose threat to

person or property and with assistance from a visual observer (VO)

DJI Inspire 1

- PIC will operate UAS in safe manner that will not pose threat to person or

property and with assistance from a visual observer (VO)

Tarot 680PRO Six

- Axis Hexacopter

– Equipped with the DJI NAZ

- M V2 Control, GPS and Navigation (same system as other DJI UAS). PIC will operate UAS in safe manner that will not
pose threat to person or property and with assistance from a visual observer (VO)

AVS will use the following ground support equipment :

DJI laptop Ground Control Station (DJI aircraft)

DJI iPad Ground Control Station (DJI aircraft)

If the UA S loses communications or loses its GPS signal, it will return to a pre

- determined

l ocation within the planned operating area and land or be recovered in accordance with the operating documents.

Altitude awareness will be maintained via a radio communicati ons telemetry data link, which downlinks from the aircraft to the PIC for active monitoring of the flight path. The altitude information will be generated by GPS equipment installed on the aircraft. Prior to each flight, a

zero altitude initiation point wi ll be established and confirmed for accuracy by the UAS PIC.

Pilot In Command : Prior to commercial operations conducted for the purpose of aerial imagery and videography

,

T he PIC will :

Have a minimum of twenty hours of total time as a UAS pilot

A t least ten hours logged as a UAS pilot with similar UAS type (quad or hex rotor)

Have a minimum of five hours as a UAS PIC operating the make and model of the UAS

T hree take

- offs and landings in the preceding 3 0 days.

Demonstrate DJI Pilot Training profici encyPage 7 of 9

AVS will not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be opera ted under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures.

PIC qualification flight hours will be logged

. The VO w ill also be required to complete the operator’s training requirements. A record of training will be documented and made available upon request by the Administrator



### Visual Observer : All operations will utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC will be able

to communicate verbally at all times. Electronic messaging or texting will not be permitted during flight operations. The PIC will be designated before the flight. The PIC will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the

functions prescribed in the operating documents. The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based
obstacles/obstructions and is not permitted to operate the camera or other instruments.



### Training : Will Include and re q uire:

DJI Pilot / Flight Training Guide: (see attachment)

AV S Training guide ( available upon request )



### Maintenance : AVS will carry out its maintenance, inspections, and record keeping requirements, in

accordance with the manufacturer operating documents and manuals . Maintenance, inspection, alterations, and status of replacement/overhaul component parts will be noted in the aircraft records, including total time in service, description of work accomp lished, and the signature of

an authorized AVS person before returning the UAS to service.



### Flight Operations :

All flights will occur under Visual Flight Rules Meteorological Conditions (VFR) only.

All operations must utilize a VO. The VO may be used to satisfy the Visual Line of Sight (VLOS) requirement

.

The PIC and VO will have been trained in operation of UAS and receive up

- to

- date information for the particular UAS to be operated.

Mission planning will be accomplished prior to flight. A preflight briefing will be conducted by the PIC and VO, as well as with any other observers (company representatives, licensed inspectors, etc.) prior to commencement of operations.

PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight.Page 8 of 9

The Ground Control Station will be included in the preflight ins pection.

All maintenance and alterations will be properly documented in the aircraft records. to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight

The UA S will be operated within visual line of sight (VLOS) of the P IC at all times.

The UA S will be operated at an altitude of no more than 400 feet above ground level (AGL),

UAS operations will not be conducted during night,

UAS will be operated with all manufacturer safety bulletins.

The UA S will not operate within 5 miles of an airport

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

If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined l ocation within a designated location and land autonomously.

The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point

and land the UA S wit h 2 5 % battery power remaining.

All operations shall be conducted over private or controlled

- access property with permission
from the land owner/controller or authorized representative. Permission from land
owner/controller or authorized re presentative will be obtained for each flight to be conducted.

The UA S may 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.

The UA S will not be flown a t an indicated airspeed exceeding 30 knots.

The UAS may not be operated by the PIC from any moving device or vehicle.

The UA S must remain clear and give way to all manned aviation operations and

activities at all times.

Operating characteristics and mainte nance procedures are outlined in the attached operations

user manuals. The radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requi rements.

AVS shall obtain all necessary consent and permissions prior to operation of those being filmed or an agreement to be in the designated filming area prior to filming taking place.Page 9 of 9

Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required, will be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon reque st.

Before conducting operations, the radio frequency spectrum used fo r operation and control of

the UAS shall comply with the Federal Communications Commission (FCC) or other appropriate
government oversight agency requirements.



### Conclusion : AVS requests a review of the aforementioned relief request at the earliest date practicable. We believe we have addressed all the requests and requirements set forth by Section 333 relief guidance and that our request is in line with previously approved relief requests. It is our

recommendation that the Secretary of Transportation and FAA a pprove the exemption for Aerial Video Solutions, Inc.

, due to the favorability of the public interest and the ability of the exemption to provide a level of safety at l east equal to that provided by the rules from which exception is being sought.

Sincerely,

Paul Craig Boutin

President Aerial Video Solutions, Inc. ( AVS ) 2304 w. Eagle Feather Rd. Phoenix, AZ 85085

480

- 575

- 1156 pboutin321@msn.com



### ATTACHMENTS:

DJI Phanton2 User Manual

- http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.8_en.pdf DJI Inspire1 User Manual

- http://download.dji

i nnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en. pdf DJI Training Manual

- http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_Pilot_Training_Guide_v1.1_en.pdf DJI Safety Guidelines

- http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_Safety_Guid elines_en.pdf UAS Flight Log (sample)
AVS Protocols