David Lyman

President & CEO

BetterView Marketplace, Inc.

1250 Jones St., #1402

San Francisco, CA 94109

+1 (415) 967­3227

dlyman@better.vu

May 14, 2015

U.S. Department of Transportation

Docket Operations, M­30

1200 New Jersey Avenue, SE

Room Wl2­140, West Building Ground Floor

Washington, DC 20590­0001

Re: Petition of BetterView Marketplace, Inc. for an Exemption Pursuant to Section

333 of the FAA Modernization and Reform Act of 2012 to Operate Unmanned

Aircraft Systems

Dear Sir or Madam:

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

and 14 C.F.R. Part 11, BetterView Marketplace, Inc. seeks an exemption from the Federal

Aviation Regulations identified below to allow for the commercial operation of the DJI

Phantom 2 ("Phantom 2"), DJI Phantom 2 Vision+ (“Phantom 2 Vision+”), DJI Inspire 1

(“Inspire 1”), and 3D Robotics Iris+ (“Iris+”) (collectively, the “sUAS”) unmanned aircraft

systems for aerial data collection.

BetterView requests that the FAA review this petition pursuant to its "summary grant" process

as the FAA has already granted exemptions similar in all material respects to this petition to

use the Phantom 2, Phantom 2 Vision+, Inspire 1, and Iris+ for aerial data collection. See FAA

Grant of Exemption Nos. 11204, 11318, 11419, 11452, 11466, 11469.

I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED

BetterView requests exemption from the following regulations:

1

• 14 C.F.R Part 21, Subpart H;

• 14 C.F.R Part 27;

1 As set forth in section IV.B.2, BetterView will operate under similar operating conditions as those

required in the other grants of exemption, in which exemptions for certain FARs was deemed by the FAA

as “not necessary.” Accordingly, BetterView does not request FAA exemption from 14 C.F.R. 45.23(b),

91.103, and 91.109(a). Should the FAA determine that relief from these or any other regulation is required

for the operations proposed herein, BetterView will be happy to submit an amendment to this request and

include justifications for those necessary additional exemptions.

1
• 14 C.F.R § 61.113;

• 14 C.F.R § 91.7;

• 14 C.F.R § 91.9(b)(2);

• 14 C.F.R § 91.119;

• 14 C.F.R § 91.121;

• 14 C.F.R § 91.151(a) & (b)

• 14 C.F.R § 91.203 (a) & (b);

• 14 C.F.R § 91.405(a);

• 14 C.F.R § 91.407(a)(1);

• 14 C.F.R § 91.409(a)(2);

• 14 C.F.R § 91.417 (a) & (b).

This petition incorporates the material contained in the BetterView UAS Operations and

Maintenance Manual, Phantom 2 User Manual, Phantom 2 Quick Start Guide, Phantom 2

Vision+ User Manual, Phantom 2 Vision+ Quick Start Guide, Smart Flight Battery Safety

Guidelines, Phantom Pilot Training Guide, Inspire 1 User Manual, Inspire 1 Quick Start Guide,

Iris+ Operation Manual, and Iris+ Flight Checklist (collectively, the "Manuals").

The Manuals are submitted herewith as confidential under 14 C.F.R. § 11.35(b), because they

contain commercial and proprietary information that BetterView has not and will not share with

others, is not available to the public, and is protected from release under the Freedom of

Information Act, 5 U.S.C. § 552 et seq.

II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS

This petition for exemption is submitted in accordance with Section 333 of the Reform Act.

Congress has directed the FAA "to safely accelerate the integration of civil unmanned aircraft

systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the

FAA Administrator is to permit operation of an unmanned aircraft system ("UAS") where it

does not create a hazard to users of the national airspace system ("NAS") or the public or

pose a threat to national security based on the following considerations:

• The size, weight, speed and operational capability;

• Operation in proximity to airports and populated areas; and

• Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant

exemptions from the agency's safety regulations and minimum standards when the

Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§

106(f), 44701­44716, et seq. A party requesting an exemption must explain the reasons why

the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect

2
safety or how it would provide a level of safety at least equal to the existing rules. 14 C.F.R. §

11.81.

III. DESCRIPTION OF BETTERVIEW AND ITS SERVICES

BetterView operates in the insurance and construction industries and is focused on facilitating

building and infrastructure inspections through aerial photography, videography and data

collection. BetterView plans to use the sUAS for inspection and data collection services that it

currently provides to its existing clients in the construction and insurance industries. The

information collected by the sUAS will aid BetterView inspect, monitor and oversee projects

for its clients across the country. The introduction of the sUAS into BetterView’s operations

will make the inspection process safer and more efficient. Importantly, use of the sUAS for

inspections avoids the involvement of lifts, ladders, scaffolds and other equipment at a height

above the surface. Injuries and fatalities of individuals performing inspections under such

conditions are well­documented.

BetterView will use only qualified pilots and will operate under the FAA 333 Exemption

requirements and limitations. By combining the latest technology and automation with with a

long track record of safe and successful structural inspections, BetterView seeks regulatory

exemptions that will allow it to employ the sUAS in the aerial inspections of properties.

Applicant Information

The name of the applicant is:

BetterView Marketplace, Inc.

The primary contact for this applicant is:

David D. Lyman

President & CEO of BetterView Marketplace, Inc.

1250 Jones St., #1402, San Francisco, CA 94109

Phone: (415) 967­3227

E­mail: dlyman@better.vu

IV. DESCRIPTION OF PROPOSED OPERATIONS

BetterView is requesting exemptions from applicable Federal Aviation Regulations (FARs)

pursuant to Section 333 of the Reform Act to perform aerial imagery and data collection for

aerial roof inspections.

3
This type of imagery and data collection is currently performed for BetterView by human

inspectors using ladders and other hi­lift devices. Use of the sUAS will reduce safety risks

because the sUAS will not expose inspectors to high, slippery, steep, or weather exposed

roofs. In addition, sUAS operations can be performed at considerable cost savings. The sUAS

will allow for better and safer imagery of facilities than can be produced by using an inspector

climbing on the exterior of buildings.

The sUAS operations proposed in this petition are similar in all material respects to relief

previously granted by the FAA in Grant of Exemption Nos. 11204, 11318, 11419, 11452,

11466, 11469. The reasons stated by the FAA in granting the exemptions listed above also

apply to this petition, and the grant of this petition is in the public interest.

A. Aircraft to be Operated

1. DJI Phantom 2

BetterView will operate the DJI Phantom 2 for aerial imaging and data collection operations.

The FAA has already approved the Phantom 2 for commercial use in FAA Exemption No.

11318 (FAA Docket No. FAA–2014–1057) and FAA Exemption No. 11466 (FAA Docket No.

FAA–2015–0262). The Phantom 2 is a battery powered quadcopter with a maximum weight of

2.9 pounds. Maximum flight time is approximately 25 minutes.

2. DJI Phantom 2 Vision+

BetterView will operate the DJI Phantom 2 Vision+ for aerial imaging and data collection

operations. The FAA has already approved the Phantom 2 Vision+ for commercial use in FAA

Exemption No. 11452 (FAA Docket No. FAA–2015–0233) and FAA Exemption No. 11469

(FAA Docket No. FAA–2015–0236). The Phantom 2 Vision+ is a battery powered quadcopter

with a maximum weight of less than 2.8 pounds. Maximum flight time is approximately 25

minutes.

3. DJI Inspire 1

BetterView will operate the DJI Inspire 1 for aerial imaging and data collection operations. The

FAA has already approved the Inspire 1 for commercial use in FAA Exemption No. 11204

(FAA Docket No. FAA–2014–0886), FAA Exemption No. 11318 (FAA Docket No.

FAA–2014–1057), and FAA Exemption No. 11452 (FAA Docket No. FAA–2015–0233). The

Inspire 1 is a battery powered quadcopter with a maximum weight of less than 6.5 pounds.

Maximum flight time is approximately 18 minutes.

4
4. 3D Robotics Iris+

BetterView will operate the 3D Robotics Iris+ for aerial imaging and data collection operations.

The FAA has already approved the 3D Robotics Iris+ for commercial use in FAA Exemption

No. 11204 (FAA Docket No. FAA–2014–0886) and FAA Exemption No. 11419 (FAA Docket

No. FAA–2015–0185). The 3D Robotics Iris+ is a battery powered quadcopter with a

maximum weight of less than 3.7 pounds. Maximum flight time is approximately 22 minutes.

B. BetterView's Proposed Operations Demonstrate an Equivalent Level of

Safety

1. General Description of Proposed Flight Operations

BetterView proposes to operate within the limitations and performance specifications listed in

the Phantom 2, Phantom 2 Vision+, Inspire 1, and Iris+ Manuals. These limitations provide for

at least an equivalent, or higher, level of safety for operations under the current regulatory

structure because the proposed operations are safer than conventional operations using

helicopters or fixed wing aircraft which carry an operator and flammable fuel. The proposed

flight operations are similar in all material respects to operations already approved by the FAA

and are therefore subject to the FAA's "summary grant" process.

The proposed operations do not create any hazard to users of the national airspace system or

pose a threat to national security. The aircraft are battery operated with a maximum flight time

of less than 25 minutes. The vehicles weigh less than 10 pounds. The vehicles will be

operated at or below 400 feet AGL within the visual line of sight of the pilot in command.

BetterView's operations will be over private or controlled access property with the permission

of the owner/controller or authorized agent.

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The

proposed sUAS carry no fuel, and therefore the risk of fire following an incident or accident

due to fuel spillage is eliminated. Compared to manned aircraft, the proposed sUAS

operations will reduce the risk to participating persons in close proximity to the aircraft due to

the limited size, weight, operating conditions, and design safety features.

The FAA has determined that the risk of not having an electronic means to monitor and

communicate with other aircraft, such as transponders or sense and avoid technology, is

mitigated by placing limits on altitude, requiring stand­off distance from clouds, permitting

daytime operations only, and requiring that the aircraft be operated within visual line of sight

and yield right of way to all other manned operations.

5
The sUAS have the capability to operate safely after experiencing certain in­flight failures, as

specified in the Manuals. In addition, the aircraft respond to a lost­link event with a

pre­coordinated, predictable, automated flight maneuver.

2. Specific Limitations on Proposed Flight Operations

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

procedures listed below, and pilot certification requirements, BetterView's proposed

operations using the Phantom 2, Phantom 2 Vision+, Inspire 1, and Iris+ would "not create a

hazard to users of the national airspace system or the public or pose a threat to national

security." Reform Act Section 333(b)(1).

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

Phantom 2, Phantom 2 Vision+, the DJI Inspire 1, and the 3D Robotics Iris+

(collectively, the “sUAS”). Proposed operations of any other aircraft will require

a new petition to amend this grant.

2. The sUAS weigh less than 10 pounds.

3. Each aircraft will be identified by serial number, registered with the FAA, and

have identification (N­Number) markings as large as practicable.

4. Flights will be operated within visual line of sight of the pilot in command (PIC).

5. Prior to each flight, a zero altitude initiation point will be established and

confirmed for accuracy by PIC.

6. The PIC will ensure that before each flight, there is enough available power for

the UAS to conduct the intended operation and to operate after that for at least

five minutes or with the reserve power recommended by the manufacturer if

greater.

7. The sUAS will be operated only during daylight hours and in VFR conditions.

8. Flights will not exceed 400 feet AGL.

9. Flights will be operated at a lateral distance of at least 500 feet from any

persons or property not associated with the operation who have not given prior

permission.

10. Flights will be limited to a ground speed of 100 mph (87 knots).

6
11. Minimum crew for each flight will consist of a PIC and a Visual Observer (“VO”).

The VO may be used to satisfy the visual line­of­sight requirement as long as

the PIC maintains visual line­of­sight capability. The VO and PIC must be able

to communicate at all times. The PIC must be designated before the flight and

cannot transfer his or her designation for the duration of the flight.

12. The PIC will hold either an airline transport, commercial, private, recreational,

or sport pilot certificate. The PIC will also hold a current FAA airman medical

certificate or a valid U.S. driver's license issued by a state or the Federal

Government. The PIC will also meet the flight review requirements specified in

14 CFR § 61.56.

13. Prior to the flight, a Mission Plan will be created setting forth the limitations for

the flight as well as contact information for the PIC.

14. The flight operations will yield the right of way to other manned aircraft

operations.

15. All persons who are not involved with BetterView's operations will be required

to be at least 500 feet from flight operations.

16. The aircraft will only operate over private or controlled access property with the

permission of the owner/controller or authorized representative.

17. The sUAS will not operate within 5 nautical miles of an airport unless a letter of

agreement is obtained.

18. All required permissions and permits will be obtained from territory, state,

county or city jurisdictions prior to flight.

19. The PIC will obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations under this

grant of exemption. This COA will also require the operator to request issuance

of a Notice to Airman (NOTAM) not more than 72 hours in advance, but not

less than 48 hours prior to the operation.

20. If the aircraft loses communications, it will have the capability to return to a

pre­determined location within the operational area and land.

21. If the aircraft loses its GPS signal it will have the capability of being flown

manually to a predetermined location within the operational area and land.

7
22. The flight will be aborted in case of unpredicted obstacles or emergencies.

23. sUAS operations will be conducted within the parameters of the Manuals.

3. Flight Recovery, Lost Communications, and Lost GPS Procedures

The flight recovery, lost communications, and lost GPS procedures are more fully

documented in the attached UAS Manuals.

V. SPECIFIC FAR EXEMPTIONS REQUESTED

BetterView seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45,

61, and 91 for purposes of conducting the requested operations using the Phantom 2,

Phantom 2 Vision+, Inspire 1, and Iris+. Listed below are (1) the specific FAR sections for

which exemption is sought, and (2) the operating procedures and safeguards that BetterView

has established which will ensure a level of safety better than or equal to the rules from which

exemption is sought. See 14 C.F.R. § 11.81 (e).

A. 14 C.F.R. Part 21, Subpart H ­ Airworthiness Certificates and 14 C.F.R. §

91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under

the Reform Act that the UAS selected provides an equivalent level of safety when compared

to aircraft normally used for the same application. These criteria are met with this petition, and

therefore no exemption is needed. See Grant of Exemption No. 11062, Docket No. FAA

2014­0352 at 13­14, 22. If, however, the FAA determines that there are some characteristics

of the Phantom 2, Phantom 2 Vision+, Inspire 1, or Iris+ that fail to meet the requirements of

the Reform Act, an exemption is requested.

Equivalent Level of Safety​: The Phantom 2, Phantom 2 Vision+, Inspire 1, and Iris+ are safe

when taking into account their size, weight, speed, and operational capability. They weigh

less than 10 pounds and will be flown at speeds less than 100 miles per hour, and in visual

line of sight of the operator. The UASs do not carry pilots, passengers, explosive materials, or

flammable liquid fuels. The UASs will be operated within the parameters of their respective

Manuals.

The proposed operations will be at least as safe as, or safer than, conventional rotorcraft or

fixed wing aircraft operating with an airworthiness certificate without the restrictions and

conditions proposed here.

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

8
14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of

normal category rotorcraft. To the extent the Phantom 2, Phantom 2 Vision+, Inspire 1, or

Iris+ would otherwise require certification under Part 27, BetterView seeks an exemption from

Part 27's airworthiness standards for the same reasons identified in the request for exemption

from 14 C.F.R. Part 21, Subpart H.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

BetterView seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying

aircraft for compensation or hire and would also require a second class medical certificate.

The purpose of Part 61 is to ensure that the skill and competency of any PIC matches the

airspace in which the PIC will be operating, as well as requiring certifications if the pilot is

carrying passengers or cargo for hire.

While the UAS will be operated as part of a commercial operation, they carry neither

passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA­2014­0352, the

FAA determined that the unique characteristics of UAS operation outside of controlled

airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to

have a commercial pilot certificate and a class II medical certificate. The FAA has also

determined that the required knowledge for a commercial pilot covers the same fundamental

principles as a private pilot.

The FAA has also granted exemptions allowing operations by people who hold an airline

transport, commercial, private, recreational, or sport pilot certificate with a current FAA airman

medical certificate or a valid U.S. driver's license issued by a state or the Federal

Government. The PIC must also meet the flight review requirements specified in 14 CFR §

61.56. See FAA Exemption No. 11374.

BetterView will ensure the PIC will meet the requirements listed in the above paragraph.

BetterView will also ensure the PIC will have completed the manufacturers' training guidelines

outlined in the Manuals.

The FAA stated in its grant of an exception to Astraeus Aerial the "the FAA considers the

overriding safety factor for the limited operations proposed by the petitioner to be the

airmanship skills acquired through VAS­specific flight cycles, flight time, and specific make

and model experience, culminating in verification through testing." See Exemption No. 11062,

Docket No. FAA 2014­0352, at p. 18. The proposed operations can achieve an equivalent

level of safety by requiring the knowledge and experience in Phantom 2, Phantom 2 Vision+,

Inspire 1, and Iris+ operations described above.

9
The restrictions BetterView has placed on its UAS operations meet or exceed the restrictions

similarly imposed on Astraeus Aerial in FAA Docket No. FAA­2014­0352 and those listed in

the FAA's "summary grant" process.

D. 14 C.F.R. § 91.7(a)­(b): Civil Aircraft Airworthiness

BetterView seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be

in airworthy condition to be operated. The FAA has stated that no exemption is required to the

extent that the requirements of Part 21 are waived or found inapplicable. Accordingly,

BetterView requests that the requirements for Section 91.7 be treated in accordance with FAR

Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19.

The agency similarly found that relief from section 91.7(b) is not warranted, which places

responsibility on the PIC to ensure an aircraft is in a condition safe for flight. See Grant of

Exemption to Astraeus Aerial, Docket No. FAA­2014­0352, Exemption No. 11062, p. 19. To

the extent, an exemption is required under section 91.7(a) or (b), BetterView respectfully

requests that the FAA find compliance with the manufacturer’s manuals, the BetterView UAS

Operations and Maintenance Manual, and requirements of the grant of exemption, a sufficient

means for ensuring the sUAS are and remain in an airworthy condition.

E. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 14 C.F.R.

§§ 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.­registered civil aircraft­

...

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5

of this chapter, unless there is available in the aircraft a current

approved Airplane or Rotorcraft Flight Manual, approved manual

material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it

has within it the following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued

10
under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible

to passengers or crew.

BetterView does not request an exemption from this section but instead notifies the FAA that,

in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, the UAS

flight manual, registration certificate and other documentation will be kept at the control station

with the PIC during flight. The Chief Counsel's Office has held that for all UAS operations, this

alternate method constitutes full compliance with the regulations. See also Grant of

Exemption No. 11062, pp. 19­20, and Grant of Exemption No. 8607.

F. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas

BetterView requests an exemption from the minimum safe altitude requirements of 14 C.F.R.

§ 91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 500

feet to any person, vessel, vehicle, or structure. The Manuals provide for BetterView

operations at least 500 feet from persons and structures not involved in the operations. The

FAA has already determined that relief from Section 91.119(c) is warranted for UAS

operations in uncongested areas with similar flight restrictions as those imposed by

BetterView. See Grant of Exemption No. 11062, p. 20­21.

Equivalent Level of Safety​: Compared to flight operations with rotorcraft or fixed wing

aircraft weighing far more than the maximum weights proposed herein, and given the lack of

flammable fuel, any risk associated with these operations is far less than those that presently

exist with conventional aircraft. An equivalent level of safety will be achieved given the size,

weight, and speed of the UAS, as well as the locations where it is operated. In order to avoid

any risk to aircraft, flight operations will be restricted to 400 feet AGL or below. Other aircraft

are already prohibited from operating closer than 500 from structures where BetterView

operates. This is airspace where other aircraft do not normally operate. As set forth in the

Manuals and herein, the UAS will be operated in the remote sites, away from persons or

structures not involved in the operation. All persons who are not involved with BetterView's

operations will be required to be at least 500 feet from flight operations. This will pose no risk

to the public because other aircraft are not operating in these areas.

G. 14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating

an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to

the elevation of the departure airport. The UASs proposed here use both barometric pressure

sensors and GPS to determine altitude but do not have the ability to set in a current altimeter

setting. An exemption is required to the extent that the UAS does not have a barometric

altimeter setting. The altitude of the UAS is monitored by the PIC on the ground control station

and by the visual observer.

11
Equivalent Level of Safety​: The FAA has stated that an equivalent level of safety can be

achieved if the aircraft will be operated at or below 400 feet AGL and within visual line­of­sight

in addition to GPS based altitude information relayed in real time to the operator. See Grant of

Exemption No. 11062, p. 20­21. As the attached Manuals indicate, the UAS will be operated

at or below 400 feet AGL and otherwise comply with the limitations in the Grant of Exemption

No. 11062.

H. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

BetterView requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in

VFR conditions. Section 91.151 states:

(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 fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on the UAS battery power means that no meaningful flight

operations can be conducted while maintaining a 30 minute reserve. The aircraft are battery

powered with a maximum flight time of approximately 25 minutes for the Phantom 2, 25

minutes for the Phantom 2 Vision+, 18 minutes for the Inspire 1, and 22 minutes for the Iris+.

The PIC will ensure that before each flight, there is enough available power for the UAS to

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

reserve power recommended by the manufacturer if greater.

Equivalent Level of Safety​: The FAA has stated that an equivalent level of safety is provided

if the UAS flight is conducted under daytime VFR flight conditions using VLOS, and

terminated with at least 25% reserve battery power still available. See Grant of Exemption No.

11062, p. 21­22. The FAA's "summary grant" process provides that the PIC is prohibited from

beginning a flight unless there is enough available power to conduct the intended operation

and to operate after that for at least five minutes or with the reserve power recommended by

the manufacturer if greater. See FAA Exemption No. 11374 (FAA Docket No. 2015­0091 at p.

5). The Manuals here provide that the PIC will ensure that before each flight, there is enough

available power for the UAS to conduct the intended operation and to operate after that for at

least five minutes or with the reserve power recommended by the manufacturer if greater.

I. 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b):

Maintenance Inspections

12
BetterView seeks an exemption from the maintenance inspection requirements contained in

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations

specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14

C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft

inspected as prescribed in subpart E of this part and shall between required inspections ...

have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption from

these regulations is needed because Part 43 and these sections only apply to aircraft with an

airworthiness certificate, which the UAS proposed here will not have.

Equivalent Level of Safety​: An equivalent level of safety will be achieved because

maintenance and inspections will be performed in accordance with the Manuals. This includes

maintenance, overhaul, replacement, and preflight inspection requirements. See Exemption

No. 11062 (FAA Docket No. 2014­0352, at p. 14­15) and Exemption No. 11374 (FAA Docket

No. 2015­0091, at p. 4).

BetterView will follow the UAS manufacturer's maintenance requirements. As provided in the

Manuals, flights will not be conducted unless a flight operations checklist is performed that

includes all of the aircraft's components.

VI. PUBLIC INTEREST

Granting BetterView's petition for exemption furthers the public interest. National policy set by

Congress favors early integration of UAS into the NAS in controlled, safe working

environments such as proposed in this petition. By granting this petition, the FAA will fulfill

Congress's intent of allowing UAS to operate safely in the NAS before completion of the

rulemaking required under Section 332 of the Reform Act.

The enhanced safety achieved by replacing people with ladders on steep, high, slippery or

unfamiliar roofs with small UAS carrying no passengers or crew and operated under the

specific guidelines and procedures proposed by Petitioner gives the FAA good cause to find

that the UAS operations enabled by the instant Petition are in the public interest.

VII. PRIVACY

All flights will occur over private property either owned by BetterView or with the owner's

consent. All flights will be conducted in accordance with any federal, state or local laws

regarding privacy.

13
VIII. SUMMARY FOR FEDERAL REGISTER

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

Federal Register, should it be determined that publication is needed:

BetterView Marketplace, Inc. seeks an exemption from the following rules for the commercial

operation of a small unmanned aerial system to inspect buildings.: 14 C.F.R Part 21, Subpart

H; 14 C.F.R Part 27; 14 C.F.R § 61.113; 14 C.F.R § 91.7; 14 C.F.R § 91.9(b)(2); 14 C.F.R §

91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203 (a) & (b); 14 C.F.R

§ 91.405(a); 14 C.F.R § 91.407(a)(1); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the operator, the general public and

property owners from the substantial hazards associated with performing equivalent work

using traditional conventional aircraft and rotorcraft.

BetterView requests that the FAA grant this petition using the "summary grant" process such

that publication in the Federal Register is not required. This petition would not set a

precedent, and any delay in acting on this petition would be detrimental to the petitioner.

IX. ATTACHMENTS

Attachment 1: BetterView UAS Operations and Maintenance Manual

Attachment 2: Phantom 2 User Manual

Attachment 3: Phantom 2 Quick Start Guide

Attachment 4: Phantom 2 Vision+ User Manual

Attachment 5: Phantom 2 Vision+ Quick Start Guide

Attachment 6: Smart Flight Battery Safety Guidelines

Attachment 7: Phantom Pilot Training Guide

Attachment 8: Inspire 1 User Manual

Attachment 9: Inspire 1 Quick Start Guide

Attachment 10: Iris+ Operation Manual

Attachment 11: Iris+ Flight Checklist

Attachments are confidential documents submitted under 14 C.F.R. § 11.35(b) and are

exempt from disclosure under the Freedom of Information Act, 5 U.S.C. § 552 et seq., and

any other requirements established by the FAA pursuant to Section 333 of the Reform Act). If

you have any questions or require any additional information, please do not hesitate to

contact the undersigned representative of BetterView Marketplace, Inc..

X. CONCLUSION

14
Satisfaction of the criteria provided in Section 333 of the Reform Act ­ size, weight, speed,

operating capabilities, proximity to airports and populated areas, operation within visual line of

sight, and national security considerations ­ provides more than adequate justification for the

grant of the requested exemptions to permit BetterView to operate the UASs proposed here.

Furthermore, this petition warrants review by the FAA under the "summary grant" process for

immediate approval.

Granting the requested exemption will benefit the public interest as a whole in many ways,

including (1) significantly improving safety and reducing risk by alleviating human exposure to

danger; (2) improving the quality of services BetterView can provide to its customers; and (3)

decreasing operating costs compared with traditional aerial imaging.

Respectfully submitted,

BetterView Marketplace, Inc.

By

David D. Lyman

President & CEO

1250 Jones St., #1402

San Francisco, CA 94109

Telephone: (415) 967­3227

dlyman@better.vu

15