Visual Advantage

5 Lorraine Station Road

Richmond, VA 23238

April 21, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor Room W12-140

Washington, DC 20590

RE: Visual Advantage’s Petition for Exemption to Operate Unmanned Aircraft Systems for Aerial 

Photography and Videography

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. Part 

11, Visual Advantage hereby applies for an exemption from the Federal Aviation Regulations (FARs) 

listed herein and any other necessary to allow its operation of small Unmanned Aircraft Systems (UAS) 

to support its real estate sales photo and video production services to include the use of small unmanned 

aircraft systems (UAS) to include aerial photo and video services. The requested exemption would 

permit the operation of DJI Spreading Wings S800 and S1000 UAS to obtain aerial photographs and 

video for real estate sales.

BACKGROUND

Visual Advantage provides photo and video production services to support commercial and residential 

real estate sales in the state of Virginia and has plans to expand services on a regional basic from 

Virginia to Florida. Traditional photography and videography is current used for interior and exterior 

jobs. Visual Advantage would like to support its services and include aerial photography and 

videography through the use of small UAS.

The Unmanned Aircraft (UA) described herein is smaller, lighter and more maneuverable than 

conventional aircraft running on combustible fuel, operates at lower altitudes with no people on board 

and will thereby reduce current risk levels and enhance safety. With a small payload and maximum 

flight time of only 15 minutes, this offers little or no risk to national security.
April 21, 2015 Page 2

THE UNMANNED AIRCRAFT (UA)

DJI Spreading Wings S1000 (primary system)

 S1000 Airframe

o Professional grade.

o Under 25 pounds takeoff weight

o 8 motors

o 7 to 15 minute flight time depending on battery size

 DJI A2 - Flight Controller with GPS

o Provides Fail Safe features that allow the aircraft to return to the launch point and 

land automatically in the event the command and control signal is lost or the battery 

has reached a pre-determined threshold. If battery reaches a critical level, the aircraft 

will descend and land at the current location. Control of the aircraft is maintained 

during descent to allow the PIC to guide it to a safe landing.

o Home Lock function allows safe return of the aircraft in the event of a motor failure

o Contains a database of airports and restricted airspace and automatically prevents 

operation in these areas

 DJI 5.8 GHz Video Downlink Transmitter – FCC Licensed.

 DJI iOSD Mark II - On Screen Display of Telemetry. The iOSD Mark II superimposes 

telemetry data on the video downlink to provide the pilot with heading, speed, height, 

distance, GPS information, and current battery voltage as well as indicating proximity to 

airports and restricted airspace. Direction back to launch point is also indicated.

DJI Spreading Wings S800 EVO (Backup System)

 S800 EVO Airframe

o Professional Grade

o Under 18 pounds takeoff weight

o 6 motors

o 7 to 15 minute flight time depending on battery.

 DJI A2 – Flight Controller. Same as S1000

 DJI 5.8 GHz Video Downlink (same as S1000)

 DJI IOSD Mark II Telemetry (same as S1000)
April 21, 2015 Page 3

GROUND STATION EQUIPMENT

The ground station equipment is comprised of a dual control system.

 Primary controller is for the Pilot in Command (PIC)

o 2.4 GHz radio control unit (FCC Licensed)

o 5.8 GHz video receiver (FCC Licensed)

o Display of video and telemetry

 Camera Controller operates the camera gimbal and does not affect aircraft control.

o 2.4 GHz radio control unit. (FCC Licensed)

o 5.8 GHz video receiver (both PIC and Cameraman receive the same signal)

o Display of video and telemetry

o Directional antenna for improved video reception.

GROUND CREW

 Pilot in Command (PIC). The pilot in command will have at least a private pilot license and 

a third class medical.

 Camera Operator (optional). The Camera operator controls the camera onboard the aircraft 

for photography and videography missions.

 Visual Observer (VO). The visual observer will provide additional situational awareness 

during flight operations.

OPERATIONAL PARAMETERS

1. The UAS will weigh less than 55 pounds.

2. Flights will be operated within visual line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 15 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 30 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet (122 meters) AGL. Unless a 

specific COA is obtained, the limit will be according to the “blanket” COA of 200 feet (61 

meters). Typical operations are at or below the tree canopy level and within the bounds of the 

owner’s property.

5. UAS pilot will be an FAA licensed airman with at least a private pilot’s certificate and third class 

medical. PIC will have completed operator and safety training from Visual Advantage. PIC will 

also have accumulated and logged at least 25 hours total time as a UAS rotorcraft pilot including 

at least 10 hours logged as a UAS pilot with a multi-rotor UAS and 5 hours in the same make 

and model of UAS proposed under this exemption request. AMA rules will be used to 

accumulate flying time and practice emergency procedures. PIC will also remain current for the 

type of aircraft for which the PIC is licensed.

6. Permission will be obtained from the property owner.

7. Pilot and observer will be able to communicate by voice at all times during the operation.

8. The UAS will only be operated during daytime hours in VFR weather conditions.

9. Operations may not be conducted aboard a moving device or vehicle.
April 21, 2015 Page 4

10. Operation near airports will be conducted according to the “blanket” COA unless another COA 

is obtained.

 5 nautical miles (NM) from an airport having an operational control tower; or

 3 NM from an airport with a published instrument flight procedure, but not an operational 

tower; or

 2 NM from an airport without a published instrument flight procedure or an operational 

tower; or

 2 NM from a heliport with a published instrument flight procedure

11. Maximum speed 50 knots.

PRE-FLIGHT CHECKLIST

1. Weather conditions are suitable for VFR flight and wind is 20 knots or less.

2. Measure battery voltage to make sure batteries are sufficiently charged before takeoff.

3. Verify that all wiring connections are tight.

4. Raise and lock all rotor arms. Inspect for cracks, damage, and loose hardware.

5. Check to make sure propellers are secure and free from dirt, cracks and chips.

6. Turn on camera equipment.

7. Install main battery and check balance.

8. Verify all switch positions on the RC transmitters. Generally they are all in the forward position

with the exception of the Mode which should be set to “GPS”.

9. Turn on radio control transmitters and video equipment.

10. Connect the UAS main battery. Check for radio connection with RC transmitters and video 

downlink.

11. During warmup, check the A2 Flight Controller LED indicator. One green flash indicates GPS 

mode. Wait for both of the following LED indications:

a. A string of 10 or more green flashes indicating that the forward direction has been 

recorded.

b. 2 or less red flashes to indicate that 5 or more GPS satellites have been obtained. This 

may also be observed on the video telemetry.

12. Announce your intention to take off by announcing “Take Off”.

DOCUMENTATION

The following documents are attached and provided to support this petition.

 DJI Spreading Wings S800 EVO User Manual Version 1.10

 Spreading Wings S1000 User manual Version 1.2

 A2 Flight Controller System User Manual Version 1.20

 iOSD (On Screen Display) User Manual Version 2.10

 Visual Advantage Preflight Checklist
April 21, 2015 Page 5

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN EXEMPTION

A. 14 C.F.R. §§ 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in Command.

These regulations limit private pilots to non-commercial operations. Because the UAS will not carry a 

pilot or passengers and be operated within limited areas and altitudes, the proposed operations can 

achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to

have a private pilot’s license rather than a commercial pilot’s license to operate this small UAS.

B. 14 C.F.R. § 91.7(a) Civil Aircraft Airworthiness

While the UAS will not have an airworthiness certificate in accordance with 14 C.F.R. part 21, Subpart 

H, the airworthy condition of the UAS will be the responsibility of the PIC in accordance with 14 C.F.R. 

§ 91.7(b).

C. 14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and other areas

This regulation establishes safe altitudes for operation of civil aircraft over areas other than congested 

areas. Visual Advantage requests relief from this section with respect to persons involved in the 

operation as well as vehicles and structures. The UAS will not be operated above 400 feet altitude. It 

will be operated in a defined area where people and buildings will not be exposed to operations without 

their pre-obtained consent.

D. 14 C.F.R. § 91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As the UAS does not have a barometric altimeter, an exemption is 

requested. The UAS Flight Controller utilizes GPS equipment aided by a static pressure sensor to 

determine and maintain altitude. The aircraft altitude above the takeoff point is provided in the video 

downlink telemetry information and provides sufficient information for the PIC to maintain altitudes at

or below the 400 foot (122 meter) limitations.

E. 14 C.F.R. § 91.151(a) Fuel requirements for flight in VFR conditions

Section 91.151(a) prohibits an individual from beginning “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 cursing 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.”

Given that the UAS aircraft only fly for a maximum of 30 minutes and typically carry about 15 minutes 

of batter power, an exemption is requested. The UAS operations are always conducted within a few 

minutes of the takeoff and landing point and within a restricted area. Visual Advantage believes that 

terminating the flight with 25% remaining battery power provides an equivalent amount of safety that is 

intended by section 191.151(a).
April 21, 2015 Page 6

F. 14 C.F.R. § 91.405(a) Maintenance Required; 

14 C.F.R. § 91.407(a)(1) Operation after maintenance, preventative maintenance, rebuilding or 

alteration; 

14 C.F.R. §§ 91.409(a)(1) and (2) Inspections; 

14 C.F.R. §§ 91.417(a) and (b) Maintenance Records

These regulations require that an aircraft operator or owner “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...,” and 

others shall inspect or maintain the aircraft in compliance with part 43.

Given that the sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to the Petitioner. Maintenance will be accomplished by the operator pursuant to the 

Owner’s Manuals. An equivalent level of safety will be achieved because these small UAS are very 

limited in size and will carry a small payload and operate only in restricted areas for limited periods of 

time. If mechanical issues arise, the UAS can land immediately and will be operating from no higher 

than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initial flight, 

perform required maintenance and keep a log of any maintenance performed. Moreover, the operator is 

the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. The FAA issued exemption to these regulations in 

Exemption No. 11062.

SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER

Petitioner: Visual Advantage

Sections of 14 C.F.R Affected: §§ 61.113(a) and (b); § 91.7(a); § 91.119(c); § 91.121; § 91.151(a); § 

91.405(a); § 91.407(a)(1); §§ 91.409(a)(1) and (2); §§ 91.417(a) and (b)

Description of Relief Sought: Visual Advantage seeks relief from the requirements of 14 C.F.R. §§ 

61.113(a) and (b); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 

91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); 14 

C.F.R. §§ 91.417(a) and (b) to operate small unmanned aircraft systems (UAS) for the purpose of real 

estate aerial photo and video production.

Respectfully Submitted,

John Hancock

President

Visual Advantage

5 Lorraine Station Road

Richmond, VA 23238