VizionAir, LLC. 100 Liverton Lane. Louisville, KY Phone: (317) 363-5618 October 5, 

2015

U. S. Department of Transportation, Docket Operations

 West Building Ground Floor, Room W12-140 1200 New Jersey Ave, SE

Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012 and 

Part 11 of the Federal Aviation Regulations from: 14 CFR 61.23(a) & (c); 14 CFR 61.101 

(e) (4) & (5); 14 CFR 61.113 (a); 14 CFR 61.315 (a); 14 CFR 91.7 (a); 14 CFR 91.119 (c); 

14 CFR 91.121; 14 CFR 91.151 (a) (1); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 

CFR 91.409 (a) (1) & (2); 14 CFR 91.417 (a) & (b)

Dear Exemption Manager,

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

Act) and 14 C.F.R. Part 11, VizionAir, LLC herein after also known as the operator, is an 

operator of small Unmanned Aircraft Systems (sUAS) or Unmanned Aircraft (UA). 

VizionAir, LLC is an aviation technology and services company that plans to exploit the 

capabilities of UA to offer a multitude of services, including:

Aerial surveying, mapping and data collection Remote sensing

Educational and research operations

Wildlife and forestry monitoring

Aid in disaster and emergency management and monitoring, civil first response, 

communications relay, search and rescue, monitoring fire hazards, cleanup effort 

supervision, damage assessment and estimation

Aid civil engineering: waterways and shipping, forestry, fishery protection, pollution 

control and air sampling and crop performance

and crop performance

Railroad and motor-vehicle road inspection

Telecommunications infrastructure inspection

Utility, Energy systems and electrical engineering inspections and asset management 

Agricultural surveying and produce field management

Livestock management and accountability

Unmanned aircraft flight school

Aerial filmmaking and photography

Construction site inspections and monitoring
Oil and gas pipeline inspection/patrolling and oil-field inspection

Real estate and marketing

Aerial event security, surveillance and crowd management

Aerial imagery evidence for property insurance claims

VizionAir, LLC hereby applies for an exemption from the listed Federal Aviation 

Regulations (FARs) to allow

VizionAir, LLC hereby applies for an exemption from the listed Federal Aviation 

Regulations (FARs) to allow commercial operation of their UA, with full understanding 

that operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333. As described more fully 

below, the requested exemption would permit the operation of small, unmanned and 

relatively inexpensive UA under controlled conditions in the National Airspace System 

(NAS) regulated by the Federal Aviation Administration (FAA). Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of Transportation’s 

(the FAA Administrator’s) responsibilities to “...establish requirements for the safe 

operation of such aircraft systems in the national airspace system.” Section 333(c) of 

the Reform Act.

The name and address of the applicant is:

VizionAir, LLC. Attn: Andrew B. Duffin 100 Liverton Lane

Louisville, KY 40222

Phone: (317) 363-5618 Email: info@thevizionair.com

Regulations from which the exemption is requested:

14 CFR 61.23 (a) & (c) – Medical certificates: Requirements and duration

14 CFR 61.101 (e) (4) & (5) – Recreational pilot privileges and limitations

14 CFR 61.113 (a) – Private pilot privileges and limitations: Pilot in command

14 CFR 61.315 (a) – What are the privileges and limits of my sport pilot certificate?

14 CFR 91.7 (a) – Civil aircraft airworthiness

14 CFR 91.119 (c) – Minimum safe altitudes: General

14 CFR 91.121 – Altimeter settings

14 CFR 91.151 (a) (1) – Fuel requirements for flights in Visual Flight Rules (VFR) 

conditions

14 CFR 91.405 (a) – Maintenance required

14 CFR 91.407 (a) (1) – Operation after maintenance, preventative maintenance, 

rebuilding, and alteration

14 CFR 91.409 (a) (1) & (2) – Inspections
14 CFR 91.417 (a) & (b) – Maintenance records

Regulatory Basis for Exemption Request

This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate 

safely in the national airspace system (NAS) before completion of the rulemaking 

required under Section 332 of the Reform Act. In making this determination, the 

Secretary is required to determine which types of UA do not create a hazard to users of 

the NAS or the public or pose a threat to national security in light of the following:

The UA’s size, weight, speed, and operational capability;

Operation of the UA in close proximity to airports and populated areas Operation of the 

UA within visual line of sight of the operator.

The aircraft intended for use by the operator includes the DJI Phantom 2, DJI Phantom 

3, DJI Inspire 1, 3DR Solo, Kespry Drone & PrecisionHawk Lancaster. All of these 

aircraft have previously been approved by the FAA in other applicant’s

All of these aircraft have previously been approved by the FAA in other applicant’s 

Section 333 exemptions. Exemptions Nos. 11278, 11275, 11267, 11260, 11172, 

11253, 11343, 11800, 11238 and 11230.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may 

operate safely in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft in the national airspace system.” Id. 

§333(c) (emphasis added).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority by its terms includes exempting civil aircraft, as the term is 

defined under §40101 of the Act, which includes UA, from the requirement that all civil 

aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of 

this title if the Administrator finds the exemption in the public interest. 49 U.S.C. 

§44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

(1).

VizionAir’s UA are rotorcraft, weighting 55 or fewer pounds including payload. The UA 

operate under normal conditions at a speed of no more than 50 knots and have the 
capability to hover and move in the vertical and horizontal plane simultaneously. The 

UA will be operated only in line of sight and will be operated only within a 

predetermined and protected flight area under the permission of the property 

representative. The UA will be operated under the below listed limitations and 

conditions to which the operator agrees to be bound when conducting commercial 

operations under an FAA issued exemption, as well as any other limitations the FAA 

may place on future operations. Such operations will insure that the UA will “not create 

a hazard to users of the national airspace system or the public as per the Reform Act 

Section 333 (b).

Given the clear direction in Section 333 of the Reform Act, the authority contained in 

the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding 

the proposed operations, and the significant public benefit, including enhanced safety, 

reduction in environmental impacts, including reduced emissions associated with 

allowing UA for aerial data collection, the grant of the requested exemptions is in the 

public interest. Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption without delay.

The FAA has issued grants of exemption in circumstances similar in material respects 

to those presented in this petition. In Exemptions Nos. 11280, 11279, 11278, 11275, 

11273, 11271, 11269, 11267, 11260, 11253, 11250, 11230, 11213, 11112, 11109

Aircraft and Equivalent Level of Safety

14 C.F.R. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the 

procedural requirements for the issuance of airworthiness certificates as required by 

FAR §91.203 (a) (1). The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of 

the Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational 

capability, and proximity to airports and populated areas of the particular UA. In all 

cases, an analysis of these criteria demonstrates that the UA 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.

The UA to be operated hereunder are rotorcraft weighing less than 55 pounds including 

payload, carries neither a pilot nor passenger. Carries no explosive materials or 

flammable liquid fuels, and operates exclusively within visual line of sight of the pilot in 

command (PIC) and a visual observer (VO). They operate at a speed of less than 50 

knots and have the capability to hover and move in the vertical and horizontal plane 
simultaneously within a predetermined and protected flight area as described below. 

Such operations will insure that the UASs will not create a hazard to the users of the 

national airspace system. Unlike other civil aircraft, operations under this exemption 

will be tightly controlled and monitored by both the operator and under the 

requirements and in compliance with local public safety requirements, to provide 

security for the

area of operation. The FAA will have advance notice of all operations. These safety 

enhancements provide a

area of operation. The FAA will have advance notice of all operations. These safety 

enhancements provide a greater degree of safety to the public and property owners 

than conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that 

there is no credible threat to national security posed by the UA, due to its size, speed 

of

operation, location of operation, lack of explosive materials or flammable liquid fuels, 

and inability to carry a

operation, location of operation, lack of explosive materials or flammable liquid fuels, 

and inability to carry a substantial external load.

The Secretary of Transportation has previously determined that these aircraft meets the 

conditions of Section 333. Therefore, the FAA has found that request of relief from 14 

CFR part 21, and any associated noise certification and testing requirements of part 

36, is not necessary. This has been stated in exemptions to this regulation in 

Exemptions Nos. 11280, 11279, 11278, 11275, 11273, 11271, 11269, 11267, 11260, 

11253, 11250 and 11230

The applicant proposes that the exemption requested herein apply to 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 under the 

current regulatory structure.

These limitations and conditions to which the operator agrees to be bound when 

conducting commercial operations under an FAA issued exemption include:

The UA; DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, 3DR Solo, Kespry Drone and 

PrecisionHawk Lancaster will weigh less than 55 pounds including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend the 

exemption.
Operations for the purpose of closed-set motion picture and television filming are not 

permitted.

The UA will 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.

The UA must be operated at an altitude of no more than 200 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

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 certificate or 

U.S. driver’s license

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 always maintains VLOS capability. The VO 

and PIC must be able to communicate verbally at all times; electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before 

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

PIC must ensure that the VO can perform the duties required of the VO.

The exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in the 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 the exemption and the procedures outlined in the operating documents, 

the conditions and limitations therein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. 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

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 
the grant of exemption. If the operator determines that any update or revision would 

affect the basis upon which the FAA granted the exemption, then the operator must 

petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office 

(AFS-80) may be contacted if questions arise regarding updates or revisions to the 

operating documents.

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.

The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

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. inoperable 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 condition for safe flight.

The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

Each UAS operated under the exemption must comply with all manufacturer safety 

bulletins. 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 license issued by a state, the District of Colombia, Puerto Rico, a territory, 

a possession, or the Federal government. The PIC must also meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his 

or her pilot certificate.

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 and 

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 
(training, 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 the exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

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.

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 airport symbol 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 management must be made available to the Administrator 

or any law enforcement official upon request.

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 PIC.

when visibility is less than 3 statute miles from the PIC.

If the UAS loses communications or loses its GPS signal, the UA must return to a 

predetermined location within the private or controlled-access property.

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

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 

recommended by the manufacturer if greater.

Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of the attached COA.
All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (N- 6 

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

as large as practicable.

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 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 request.

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

at all times. The UAS may not be operated by the PIC from any moving device or 

vehicle.

All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons,

vessels, vehicles, and structures unless:

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 remain 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

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 the exemption.

All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each 

flight to be conducted. Any incident, accident, or flight operation that transgresses the 

lateral or vertical boundaries

of the operational area as defined by the applicable COA must be reported to the 

FAA'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.

Unless otherwise specified in the grant of exemption, the UAS, the UAS PIC, and the 

UAS operations must

Unless otherwise specified in the 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.

14 CFR § 61.23 (a) & (c): Medical certificates: Requirements and duration.

This regulation sets forth medical certificate requirements for pilots-in-command of 

aircraft in that a holder must have a first-class medical certificate when exercising the 

PIC privileges of an airline transport pilot certificate. Furthermore, the requirement 

states that the PIC must hold at least a second-class medical certificate when 

exercising PIC privileges of a commercial pilot certificate, or must hold at least a thirdclass medical certificate when exercising PIC privileges of a private pilot certificate, 

recreational pilot certificate, or flight instructor certificate. It also states that a person 

must hold and possess either a medical certificate issued under § 61.67 or a U.S. 

driver's license when exercising the privileges of a PIC of a sport pilot certificate in a 

light-sport aircraft other than a glider or balloon.

The FAA is granting relief from § 61.23(a) to allow any pilot that holds one of the pilot’s 

certificates (discussed above) to operate a UAS with a U.S. issued driver’s license, in 

lieu of an FAA-issued medical certificate. The FAA is also granting relief from § 61.23(c) 

to allow sport pilot certificate holders to operate aircraft other than LSA with a U.S. 

issued driver’s license. The FAA has issued the following

exemptions to this regulation: Exemption Nos.11278, 11275, 11269, 11267, 11260, 

11256, 11253, 11252, 11240 and 11230.

14 CFR § 61.101 (e) (4) & (5): Recreational pilot privileges and limitations.

This section limits recreational pilots to non-commercial operations and that they may 

not act as pilot in command of a recreational aircraft for compensation or hire, or in the 

furtherance of a business. Unlike a conventional aircraft that carries the pilot and 

passengers, the UA is remotely controlled with no living thing on board. The area of 

operation will be predetermined and in a protected flight area under the permission of 

the property representative, and all flights are planned and coordinated in advance. The 

FAA has issued the following exemptions to this regulation: Exemption Nos.11278, 

11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.
14 CFR § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command.

This section limits private pilots to non-commercial operations and that they may not 

act as pilot in command of an aircraft that is carrying passengers or property for 

compensation or hire. Unlike a conventional aircraft that carries the pilot and 

passengers, the UA is remotely controlled with no living thing on board. The area of 

operation will be predetermined and in a protected flight area under the permission of 

the property representative, and all flights are planned and coordinated in advance. The 

FAA has issued the following exemptions to this regulation: Exemption Nos.11278, 

11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.

14 CFR § 61.315 (a): What are the privileges and limits of my sport pilot certificate?

This section limits sport pilots to non-commercial operations and that they may not act 

as pilot in command of an aircraft that is carrying passengers or property for 

compensation or hire, or in the furtherance of a business. They also may not carry 

more than one passenger, fly at night, and under other restrictions that are outside of 

the scope of intended flights of the UA. Unlike a conventional aircraft that carries the 

pilot and passengers, the UA is remotely controlled with no living thing on board. The 

area of operation will be predetermined and in a protected flight area under the 

permission of the property representative, and all flights are planned and coordinated 

in advance. The FAA has issued the following exemptions to this regulation: Exemption 

Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.

14 CFR § 91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft for maintenance and use of

preflight actions as prescribed by the aircraft’s manufacturer prior to each flight, and 

given the FAA’s prior

preflight actions as prescribed by the aircraft’s manufacturer prior to each flight, and 

given the FAA’s prior approval of the same types of aircraft to be used in previous 

exemptions to this requirement (as set forth in Exemptions Nos. 11278, 11275, 11267, 

11260, 11253 and 11230) we believe we can maintain a high standard of safety and 

due regard as to the aircraft’s airworthiness during flight

operations. The FAA has issued the following exemptions to this regulation: Exemption 

Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.
14 CFR § 91.119 (c): Minimum safe altitudes. 14 CFR § 91.119 (c): Minimum safe 

altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 

(d) allows helicopters to be operated at less than the minimums prescribed, provided 

the person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for UAS that are rotorcraft and the 

exemption requests authority to operate at altitudes up to 200 feet AGL, an exemption 

may be needed to allow such operations. As set forth herein, the UA will never operate 

at higher than 200 feet AGL, will always be operated under VLOS of both the PIC and 

VO, its area of operation will be predetermined and in a protected flight area under the 

permission of the property representative, all flights are planned and coordinated in 

advance and the UA will remain clear of, and give way to all manned aviation 

operations and activities at all times.

The equivalent level of safety will be achieved given the size, weight, speed of the UA 

as well as the location where it is operated and under the conditions previously stated. 

Compared to flight operations with aircraft or rotorcraft weighting far more than the 

maximum 55pounds proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with 

conventional aircraft operating at or below 500 feet AGL. In addition, the low-altitude 

operations of the UA will ensure separation between these small- UAS operations and 

the operations of conventional aircraft that must comply with Section 91.119. The FAA 

has issued the following exemptions to this regulation: Exemptions Nos. 11278, 11275, 

11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230.

14 CFR § 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 UA may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be 

needed. An equivalent level of safety will be achieved by the operator, pursuant to the 

manufacturer’s published procedures and live flight data monitoring, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight. In the event 

that the GPS altitude read out system becomes none functional during flight, the UA 

will also have a pre-programmed maximum flight limit of 200 feet programmed into 

them so that they may not fly above unapproved altitude limits. The FAA has issued the 

following exemptions to this regulation: Exemptions Nos. 11278, 11275, 11269, 11267, 

11260, 11256, 11253, 11252, 11240 and 11230.
14 CFR § 91.151(a) (1): 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 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.”

The LiPo battery powering the DJI Phantom 2, DJI Phantom 3, and 3DR solo provides 

approximately 20 minutes of powered flight while the LiPo battery powering the DJI 

Inspire 1, Kespry Drone, and PrecisionHawk Lancaster provides approximately 30 

minutes of flight. The PIC will not begin a flight unless 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 

recommended by the operation and to operate after that for at least five minutes or 

with the reserve power recommended by the

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

recommended by the manufacturer if greater.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of 

prior exemptions, and that flight with less than 30 minutes of reserve fuel, does not 

engender the type of risks that Section 91.151(a) was intended to alleviate given the 

size and speed of the small UAS. Similar exemptions have been granted to other 

operations, including Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 

11253, 11252, 11240 and 11230.

14 CFR § 91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417(a) & (b): Maintenance Inspections.

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 these sections and Part 43 apply 

only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant.

An equivalent level of safety will be achieved because these small UASs 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 UA can land immediately and will 

be operating from no higher than 200 feet AGL and within VLOS of the PIC and VO. 
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. inoperable 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 condition for safe flight. The operator must follow the UAS 

manufacturer’s maintenance, overhaul, replacement, inspection, and life limit 

requirements for the aircraft and aircraft components. The FAA has issued the following 

exemptions to this regulation: Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 

11256, 11253, 11252, 11240 and 11230.

Privacy

All flights will occur over private or controlled access property with the property 

representative or owner’s prior consent and knowledge. Filming will be of people who 

have also consented to being filmed or otherwise have agreed to be in the area where 

filming will take place.

All flights will occur in accordance with any state or local laws regarding privacy. 

Additional Views, Information & Summary

As a public benefit VizionAir LLC. will advance:

-Research into future safety guidelines for the use of UAS,

-Reduction in dangers by limiting the use of larger rotorcraft or fixed-wing aircraft, -

Reducing carbon emissions, &

-Advancement of science through advanced data collection

*********

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:

Applicant seeks an exemption from the following rules:

14 CFR 61.23(a) & (c); 14 CFR 61.101 (e) (4) & (5); 14 CFR 61.113 (a); 14 CFR 61.315 

(a); 14 CFR 91.7 (a); 14 CFR 91.119 (c); 14 CFR 91.121; 14 CFR 91.151 (a) (1); 14 CFR 

91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a) (1) & (2) and 14 CFR 91.417 (a) & 

(b) to operate commercially a small unmanned vehicle

(55pounds or less) for the purpose of aerial surveying, mapping and data collection; 

remote sensing;
(55pounds or less) for the purpose of aerial surveying, mapping and data collection; 

remote sensing; educational and research operations; wildlife and forestry monitoring; 

aid in disaster and emergency management and monitoring, civil first response, 

communications relay, search and rescue, monitoring fire hazards, cleanup effort 

supervision, damage assessment and estimation; aid civil engineering: waterways and 

shipping, forestry, fishery protection, pollution control and air sampling and crop 

performance; railroad and motor-vehicle road inspection; telecommunications 

infrastructure inspection; utility, energy systems and electrical engineering inspections 

and asset management; agricultural surveying and produce field management; 

livestock management and accountability; unmanned aircraft flight school; aerial 

filmmaking and photography; construction site inspections and monitoring; oil and gas 

pipeline inspection/patrolling and oil-field inspection; real estate and marketing; aerial 

event security, surveillance and crowd management and aerial imagery evidence for 

property insurance claims.

Approval of exemptions allowing commercial operations of UA in the listed industries 

will enhance safety by reducing risk. Conventional flight operations using jet, piston or 

multi-engine powered aircraft occasionally operate at extremely low altitudes to 

complete some of the requested uses and in extreme proximity to people and 

structures. This presents associated risks as these vehicles weigh in excess of 3,000 

pounds and carry large amounts of jet A or other fuel. Such aircraft must fly to and 

from the mission location. In contrast, a UA weighing fewer than 55 pounds, powered 

by batteries, virtually

eliminates all of the above risks given the UA’s reduced mass and lack of combustible 

fuel carried on board. The UA is carried to the mission site. The UA will carry no 

passengers or crew, therefore, the UA will not

expose them to the risks associated with manned aircraft flights. expose them to the 

risks associated with manned aircraft flights.

The operation of small UASs, weighting less than 55 pounds, conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight aircraft 

operate at slow speeds, close to the ground but under 200 feet AGL, and within visual 

line of sight of the pilot in command and a visual observer. As a result, the small UASs 

are far safer than conventional flight operations conducted with large manned aircraft.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, 

weight, speed, operating capabilities, proximity to airports and populated areas, 
operation within visual line of sight, national security and the significant public benefit 

as well as the positive economic impacts – provide more than adequate justification for 

the grant of the requested exemptions allowing commercial operation of applicant’s 

UA. Granting Vizionair, LLC. the above exemptions will allow for the expansion of UAS 

systems into the future, in a professional, safety conscious culture steeped in the 

tradition of Aviation. VizionAir,LLC. respectfully requests that the FAA grant its 

exception without delay. The FAA has the authority to issue the exemption sought by 

Vizionair,LLC. pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the 

"Act").

Sincerely,

Andrew B. Duffin

VizionAir, LLC. President