# 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 fo r 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 sm all Unmanned Aircraft Systems (UAS )
to support its real estate sales photo and video production services to inclu de the use of small unmanned aircraft systems (UAS) to include aerial photo and video services . The requested exemption wou ld permit the operation of DJI Spreading Wings S800 and S1000 UAS to obtain aerial photographs and video for real estate s ales.

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 ther eby 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

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THE UNMANNED AIRCRAFT (UA)

DJI Spreading Wings S10 00 (primary system)

 S10 00 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 pr events operation in these areas

 DJI 5.8 GHz Video Downlink Transmitter

– FCC Lic ensed.

 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 volta ge as well as indicating p rox imity to airports and restricted airspa ce

. 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 S10 00

 DJI 5.8 GHz Video Downlink (same as S1000 )

 DJI IOSD Mark II Telemetry (same as S1000 )April 21

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GROUND STATION EQUIPMENT

The ground station equipment is comprised of a dual control system

.

 Primary controller is f or the Pilot in Command (PIC)

o 2.4 GHz radio control unit (FCC Licensed)

o 5.8 GHz video receiver (FCC Licensed)

o D isplay 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 awa reness 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 acco rding 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 clas s 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 U AS 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 license d. 6. P ermission will be obtained from the property owner. 7. Pilot and observer will be able to communicate by voice at a ll 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

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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 airp ort 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

- FLIGH T CHECKLIST

1. Weather conditions are suitab le 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 an d 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 t ransmitters. 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. Dur ing 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

reco rded. 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 V ersion 1.2

 A2 Flight Controller System User Manual Version 1.20

 iOSD (On Screen Display) User Manual Version 2.10

 Visual Advantage Preflight ChecklistApril 21

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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

- commerci al 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, t he airworthy condition of the UAS will b e 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 ai rcraft 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. Th e UAS will not be operated above 400 feet altitude. It will be opera ted 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 referen ce to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting availa ble 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 forecas t 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, a n exemption is requested. The UAS operations are always conducted within a few minutes of the takeoff and landing point and within a restrict ed 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

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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 o wner “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.

Give n 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 opera tor 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 ari se, 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. §§ 91.40 9(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b) to operate sm all 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 Ric hmond, VA 23238