Docket Operations, M-30: 

U.S Department of Transportation (DOT) 

1200 New Jersey Ave SE, Rm W12-140 

West Building Ground Floor 

Washington, DC 20590 

Gareth John 

View by Video, !nc 

1420 Celebration Blvd 

Suite 200 

Celebration, FL 34747 

Tel: (877) 828-0508 

September 03 2015 

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) (.c) (d) (it) (f) (g) (h), 61.113 

(a) & (b), 91.103, 91.119, 91.121. 91.203. 91.151 

Following the format of FAA Exemption No. 11138 -Regulatory Docket No. FAA- 2014-048, 11 

have included: 

PHANTOM 2 VISION PLUS User Manual 

PHANTOM 2 VISION PLUS Smart Battery Safety Guidelines 

PHANTOM 2 VISION PLUS Pilot Training Guide 

I 

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

11, !, Gareth John, a professional V!deographer and Photographer for the Rea! Estate Industry 

for the past 10 years, am preparing this exemption request myself and would like to apply for an 

exemption from the following Code of Federal Regulations (C.F.R) in order to be allowed 

commercial operation of lightweight Unmanned Aircraft Systems (sUAS) for aerial imaging and 

video of Orlando, Kissimmee, Davenport, Clermont, Fort Myers, Cape Coral, Sarasota and 

Tampa, primarily but not limited to landmarks and homes listed for sale and/or rental. 

I have 2 years experience in flying hobby quad copters for recreational purposes without 

incident. I have added a hobby grade DJI Phantom 2 PLUS quad copter (equipped with four 

rotors that are driven by electric motors powered by batteries, the UAS has a maximum 

airspeed of 32 knots) to my inventory with intent for aerial videography/cinematography and 

photography to enhance real estate listing videos and vacation rental home promotion, following 

an exemption and approval by the FAA. 

My exemption request would permit operation of ultra-light weight, unmanned (piloted by remote 

control) in predetermined areas away from general public, airports, heliports and vehicular 

traffic, under 400ft. and after carefully reviewing, inspecting and examining the area of aerial 

observation. This would allow for community videos and within property boundaries for 

individual homeowner real estate listing videoslphotos. I will abide by all FAA requirements to 
ensure this exemption will provide a level of safety in accordance with existing rules and will 

only operate in a safe environment that is strictly controlled, are away from power lines, 

elevated lights, airports and actively populated areas; and I will conduct extensive preflight 

inspections and protocols, during which safety is of the utmost importance. 

14 C.F.R. Part 21. Subpart H: Airworthiness Certificates 14 CFR § 91.203 

Given the size, weight, speed, and limited operating area associated with the aircraft to be 

utilized, I am asking exemption from 14CFRpart21, Subpart H (Airworthiness Certificates) 

and§91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is 

warranted and meets the requirements for an equivalent level of safety under14CFRpart 11 and 

Section 333 of P.L. 112-95 (Section 333). 

14 C.F.R. 45.27(a): location of marks: non fixed-wing aircraft. 14 C.F.R. 45.29 (3) (c) (d) (e) 

(f)(h): Size of Marks 

Furthermore I request an exemption from §45.23 Marking of the aircraft because my UAS will 

not have a cabin, cockpit or pilot station on which_ to mark certain words or phrases. Additionally 

two -inch lettering is difficult to place on such a small aircraft with dimensions smaller than the 

minimal lettering requirement. I understand the need for markings and will mark my UAS in the 

largest possible lettering by placing the word "Experimental" or assigned number or name 

(based on a request or ruling by the FAA) on its fuselage as required by §45.29(f) so that 

anyone shadowing as a spotter will see the markings. I also ask for an exemption from 

§§91.405{a),91.407(a)(1 ), 91.409(a)(2) and 91.417(a) and(b) Maintenance inspections may be 

required and should be granted since they only apply to aircraft with an airworthiness certificate. 

As a safety precaution I will perform a preflight inspection of my UAS before each flight as 

outlined in the OJI Phantom Vision Plus operating documents. 

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command. 

Under §61.113 (a) and(b) private pilots are limited to non-commercial operations, however I can 

achieve an equivalent level of safety as achieved by current regulations because my UAS does 

not carry any pilots or passengers. While helpful, a pilots' license will not ensure remote control 

piloting ski11s. The risks of operating a UAS are far less than the risk levels inherent in the 

commercial activities outlined in 14 CFR part61 ,et seq., I request an exemption from §61.113 

Private Pi!ot Privl!eges and Limitations. 

14 C.F.R. 91.103 (b) (1}, (b)(2}: Preflight Action. 

If granted an exemption I agree to additional safety procedures including, but not limited to: 

1. Ensuring the UAS remains within a radius distance of 1 000 feet from the controller to aid in 

direct line of sight visual observation. 

2. Operate the UAS for 3-7 minutes per flight; land my UAS according to the manufacturer's 

recommended minimum level of battery power. 

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3. Operate my UAS only within visual line of sight (VLOS). 

4. Use the UAS' g~obal positioning system and Global Navigation Satellite System and Vison 

Positioning System (GPS/GLONASS) flight safety feature; it hovers, returns to its take-off 

location and then slowly lands if communication with the remote control is lost. 

5. I will operate and will actively analyze flight data and other sources of information to 

constantly update and enhance my safety protocols. 

6. Contact respective airports if operations will be within 5 miles to advise them of estimated 

t.!ight time, flight duration, etevation of flight and other pertinent information. 

7. Always obtain all necessary permissions prior to operation. 

8. Have procedures in place to abort flights in the event of safety breaches or potential danger. 

9. Ensure that all operational firmware and software is kept up to date at all times. 

Aerial videography for geographical awareness of real estate marketing has been around for a 

long time through manned fixed winged aircraft and helicopters, but for small business, its 

expense has been cost-prohibitive. Granting this exemption would allow me to provide this 

service at a much lower cost. Further, my small UAS, when used properly, will pose no threat to 

the public given its small size and lack of combustible fuel when compared to larger manned 

aircraft. The operation o1 a UAS wi11 minimize eco1ogica1 damage and promote econorntc growth 

by providing information to companies looking to relocate or develop real estate in Orlando and 

its surrounding areas !n the state of Florida. 

suomlttect respectfully, 

Gareth John 

President 

View by Video, Inc 

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