August 12, 2015
U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 

### Reference: Visualytics Group, LLC. Petition for Section 333 Exemption: Re: Research & 

### Development ofMethods to conductaerialdata collection, photography and videography consisting ofstructural inspections ofhomes and businesses (roofs), pipelines (oil and gas), realestate and golf course marketing and surveys and otherflight operations that could be performed safely and more cost effectivelywith the use ofsmall UAS.
Dear Sir orMadam:
In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Actof2012, Visualytics Group LLC. (Petitioner or Visualytics), is petitioning for an exemption from the Federal AviationRegulations ("FARs") and otherrules/statutes pertainingto small Unmanned Aircraft Systems ("UAS") to conduct aerial data collection, photography and videography consisting ofstructural inspections ofhomes and businesses (roofs), pipelines (oil and gas), real estate and golfcourse marketing and surveys and other flight operations that could be performed safely and more cost effectively withthe use ofsmall UAS at low altitude withinthe U.S. national airspace system as compared to a manned aircraft. Operations will be performed only atthe request ofand withthe authorization and permission ofclients ortheir authorized agents in orderto facilitate commerce and raise awareness ofthebeneficial uses ofUAS's. So long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333. 

### A. THE FAA'S LEGAL AUTHORITY TO GRANT THIS EXEMPTION REQUEST Visualytics shares Congress's vision ofintegrating small UAS for civil use into our national airspace and providingeconomic benefits and growth from this rapidly developing technology. Current law does not provide adequate authority to extend these research and development activities, and this application seeks interim authority from the FAAto allow Visualytics to pursue these activities itbeganresearching in 2014.
In addition, the Federal AviationAct 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, that includes UAS, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement ofa regulation prescribed under§§ 44701(a) or (b) orin§§ 44702-44716 oftheAct ifthe Administrator finds the exemption inthe public interest. Obtaining a Section 333 exemption would allow Visualytics the authority to do further research and development in a safe and efficient mannerwithout burdeningthe FAA with additional requests for each ofour UAS platforms and operations. Currently, the FAA does not allow civil operations (meaning operations otherthan public aircraft operations or model aircraft 

### I "hobbyist" activities which include research and development); therefore Visualytics has not been able to fully develop its UAS flight research. Through this petition, Visualytics seeks an exemptionto operate small UAS to further develop its research and development ofthis emerging technology.

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244Visualytics small UAS are aircraft weighing significantly less than 55 lbs. (details are provided within). They operate at slow speeds (under 45kts) and within line ofsightwithinthe areas described inthis petition. Such operations will ensure thatthe small UAS operatedby Visualytics will not create a hazard to other aircraft operatinginthe national airspace, tothe general public orpose a threatto national security as dictated by the FederalAviation Regulations (FAR).


### B. NAMEAND ADDRESS OFTHEPETITIONER: Visualytics Group LLC. 2864 Stackhouse St. Fort Worth, Texas 76244 Phone:214-316-6104 E-mail: david.rys@visualyticsgroupllc.com


### C. EXEMPTIONS REQUESTED:
The FAA considers unmanned aircraft as "aircraft" flown by a "pilot" regardless ofthe location ofthe pilot. All aircraft andpilots must comply with applicable sections ofTitle 14 ofthe Code ofFederal Regulations (14 CFR) to operate within the National Airspace. Unmanned aircraft are unable to comply with certain sections of 14 CFRas the regulations were written prior to the consideration ofsmall UAS operating withinthe national airspace. Therefore Visualytics is requesting an exemptionfrom certain parts of 14 CFRcitedbelow in addition to such further exemptions andreliefas the FAA may determine is necessary to permitthe operations described herein.
14 CFRPart 61.113 (a) and (b)- Private pilot privileges and limitations 14 CFRPart 91.119 (c)

- Minimum safe altitudes overcongested and other areas 14 CFRPart 91.121

- Altimeter settings 14 CFRPart 91.151 (a)

- Fuel requirements for flight inVFR conditions 14 CFRPart 91.405 (a)- Maintenance required 14 CFRPart 91.407 (a)- Operation aftermaintenance, preventive maintenance, rebuilding or alteration 14 CFRPart 91.409 (a) (1) and (2)- Inspections 14 CFRPart 91.417 (a) and (b)- Maintenance Records 61.113(a) 

### & (b). Visualytics request reliefin orderto facilitate the utilization ofpilots, who hold a private pilot (or greater) certificate. UAS operations will always be conducted by one ofthe two licensed commercial andprivatepilots. Combined, Visualytics Pilots have 4000+total flight hours, holdingmultiengine instrumented fixed wingratings; one Pilotholds a current airline transport license as well as a Class I Medical certificate. Visualytics exceeds the minimum requirements mandated thus ensuring compliance ofthe National Air Space (NAS). This positions Visualytics to ensure the safety ofthe public at large. Any pilots operating underthis exemption wouldbe required to comply with any conditions set forth and in similar fashion to the previously granted exemptions.
All Pilot in command (PIC) operatingunderthis exemption would be required to comply with any conditions as setforth and in a similarfashion tothe previously granted exemptions. All UAS operations will utilize a visual observer (VO) at all times while underthis requested exemption. The PIC and VO mustbe able to communicate verbally at all times 91.119(c) Discussed inExemption 11138 (DOUGLAS TRUDEAU) (see reference 1), operations conducted closerthan 500 feet to the ground may require that the UA be operated closerthan 500 feet to essential persons, or objects that would notbe possible without additional relief. The petitionerrequests modification, waiver orexemption and clarification concerning the terms "congested areas" and "densely 

# • Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244populated". Visualytics requests waiver for this condition to allow reasonable and responsible operations with safety as our main concern in areas ofsubdivisions and neighborhoods ifrequired.
91.121 Discussed inExemption 11138 (DOUGLAS TRUDEAU) (see reference 1) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information. 91.151(a) Discussed inExemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) (see reference 2), prior reliefhas been granted for manned aircraftto operate at less thanthe prescribed minimums, including ExemptionNos. 2689, 5745, and 10650. In addition, similar UAS specific reliefhas been granted in ExemptionNos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery powerremaining in percentto the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided inthe operating documents discusses procedures regarding remaining battery powermanagement. Those documents contain a condition inwhich the PIC will initiate a landing procedure when battery remaining reaches a specified level. Giventhe limitations onproposed operations and the location ofthose proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VFRconditions was reasonable. 91.405(a). 91.407(a)(l). 91.409 (a)(l) 

### & (2). 91.417(a) 

### & (b) Discussed inExemption 11138 (DOUGLAS TRUDEAU) (see reference 1), Visualytics proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance withthe operating documents. The FAA found that adherence to the petitioner's operating documents and the conditions and limitations specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficientto ensure that safety would not be adversely affected.


### D. SPECIFIC SECTIONS OF 14 

### C.F.R. FROMWHICH PETITIONERS SEEKAN EXEMPTION: Visualytics also requests exemptionfrom such other FARs as the FAA deems appropriate to enable the requested operations. If, duringthe effective dates ofany Grant ofExemption issued pursuantto this Petition, the FAA issues interim orfinal rules for small UAS, Visualytics requests that itbe relieved of the requirements ofany conditions and limitations ofsaid exemption and allowedto comply with any less burdensome applicable regulations that may have become effective.


### E. THEUAS Visualytics specifically proposes to conduct UAS operations using small UAS including the DllPhantom 2 Vision+, the 3D Robotics Solo andthe 3DRobotics X-SM.
The DllPhantom 2+is a multi-rotor aircraft. The Phantom 2+ has a 1284gtake-offweight (battery and propellers included). The Phantom 2+ carries a 5200mAhLiPo battery, which facilitates up to 25 minutes offlight time. Itcanbe flown with either a radio ortablet and carries a 3-axis Camera Stabilization Gimbal with a 14 MegapixeV1080p integrated camera system. The Phantom 2+has a maximum cruise speed of 15 m/s. Itfeatures auto-takeoffand landing, auto go home and landing, GPS waypoint navigation, direction lock, and GIS mapping. A remote controller and Wi-Fi Communications system; 5.8 GHz remote control receiver, flight control system and a 2.4 GHzWi-Fi module.
The 3D Robotics Solo is a multi-rotor aircraft. The Solo has a flight time of25 minutes; 20 minutes with payload, a range of.5 miles (.8 km), max speed: 55 mph (89 km/h), max ascent speed of 10m/sin stabilize mode; 5 m/s in "fly" mode, maxpayload: 420 g, max altitude: 400 feet perF AA regulation, user adjustable (122m), motors: 880 kV, propellers: 10" diameter 4.5" pitch self-tightening (24 em diameter

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244144 em pitch); glass-reinforced nylon, autopilot: Pixhawk 2, software: APM Copter, communication: 3DRLink secure WiFi network, frequency: 2.4 GHz, weight: 3.3lbs. (1.5 kg) 

### I 3.9lbs. (1.8 kg) with camera and Solo Gimbal, dimensions: 10 in. tall (25 em), 18 in. (46 em) motor-to-motor, flight battery: Lithium polymer 5200 mAh 14.8 Vde, battery charge time: -1.5 hours, controllerbattery: 2600 mAh 7.2 Vdc rechargeable lithium ion. (Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style and pilot skill. Listed flight time applies to elevations less than 2,000 feet above sea level).
The 3DRobotics X8-M is a multi-rotor aircraft. Itweighs (withbattery) 7.7 lbs. (3.5 kg), dimensions: 13.7 in x 20.1 in x 11.8 in (35 em x 51 em x 30 em), payload capacity of.4lbs. (200 g). Radio range of.6 miles (1 (km), flight time of 14 minutes, maximum operational wind speed of25 mph (11 m/s), a Pixhawk autopilot system, 4S 10000 mAh lOC lithium polymerbattery.


### F. RISKMITIGATION Visualytics has reviewed FAA exemptions reference's 13 Conditions and Limitations section and believe that the procedures specifiedtherein are reasonable and will be utilized in orderto manage and mitigate risk and ensure public safety.
A preflight checklist will be developed and employedto ensure thatthe UAS's airworthiness will be verified before launch. Airworthiness will be maintained by performance ofroutine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components. Visualytics requestthat in a manner similarto reference 13, be allowedto operate within 5 miles ofan airport providedthat:
"TheUA maynot operate in Class B, C, orD airspacewithoutwritten approval from the FAA. The UA may not operatewithin 

### 5 nautical miles ofthe geographic centerofa non-towered airport as denoted on a currentFAA published aeronautical chart unless a letterofagreementwith that airport's management is obtained, and the operation is conducted in accordancewith a NOT AM as required by the operator's COA. The letter ofagreementwith the airportmanagement must be made availableto the Administrator upon request." Operations within 5 miles ofan airport are not anticipated to be routine but Visualytics is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations within class B airspace are notrequested due to the lack ofmode C transponder. 

### G. PUBLIC INTEREST
Use ofthe UAS in lieu ofa manned aircraft would enhance safety and reduce the environmental impact as compared to similar operations conducted with manned aircraft ofgreater proportions, carrying a crew and flammable fuel.
Inregards to performing inspections ofhomes and businesses (roofs) and pipelines (oil and gas) the UAS will minimize the riskto persons attempting to climb these structures and photograph problem areas. Safe, roofinspections conducted by humanbeings carries with it certain risks. Currently, inspectors need to physically climb onto the roofusing ladders and other safety gearto conduct inspections. Sometimes, a two story/steep team is used, requiring two representatives and special safety harnesses. The dangers of inspecting any roofinclude losing one's footing, having a ladder slip, and beingblown offa rooffrom wind shear. In addition to safety concerns, inspecting a roofby physically climbing on it has the potential to damage the roof. Using UAS for roofinspections avoids all ofthese risks. By utilizing UAS,

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244Visualytics representatives will be able to reduce their exposure to hazards and rapidly obtain accurate assessments ofthe roofwhile remaining safety onthe ground. Many ofthe pipelines (oil and gas) in our area travel in areas that are hard to reach by vehicle or foot and ifan area is suspected ofhaving problems the UAS can reach it to make an assessment easier and safer.
The use ofthe UAS in orderto facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits oftheir desired photographic subjects that cannot be displayed through ground level photography. Aerial photography and videography is a valuable marketing tool that can lead to increased commerce. The VO will be utilized at all times that the UAS is performing duties for compensation and the PIC will hold, as a minimum, a Private Pilot license. Flight data including UAS flight time, Control Unit operationtime, incident, and details will be recorded for each flight and made available to the FAA at any time needed. Any deviations from normal operations will also be recorded and made available to FAA.


### H. SUMMARY TO BE PUBLISHED INFEDERAL REGISTER
Petitioner: Visualytics Group LLC
Sections of 14 C.F.R. Affected: Part§§ 61.113(a) and (b); § 91.119(c); § 91.121; § 91.151(a); § 91.405(a); § 91.407(a)(l); §§ 91.409(a)(l) and (2); §§ 91.417(a) and (b). Description of Relief Sought: Petitioner seeks relieffrom the requirements of 14 C.F .R. Part 14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b) to conduct aerial data collection, photography and videography consisting ofstructural inspections ofhomes and businesses (roofs), pipelines (oil and gas), real estate and golfcourse marketing and surveys and other flight operations subject to operating procedures that meet or exceed those that the FAA requires for similar operations for internal Visualytics Group Research & Development purposes. 

### I. CONCLUSION
Satisfaction ofthe criteria provided in Section 333 ofthe FMRA regarding size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line ofsight, and national security, provide more than adequatejustification for the grant ofthe requested exemption allowing operation ofPetitioner's use ofsmall UAS for roofinsurance inspections, oil and gas pipeline inspections, aerial photography, cinematography and videography pursuant to the Operations Manual. Allowing Visualytics this exemption would give Visualytics the ability to continue research and development beyond the limits imposed today. Additional testing would benefit not only Visualytics and its clients, but would serve as a partnership with the FAA and others within the UAS community to advance this new and emerging technology in a safe and controlled environment.
The FAA has issued grants ofexemption in circumstances similar in all material respects to those presented herein. In Grants ofExemptionNos. 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), 11109 to Clayco, Inc. (see Docket No. FAA-2014-0507), 11112 to VDOS Global, LLC (see DocketNo. FAA-2014-0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA-2014-0642), the FAA found thatthe enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft ofsignificantly greater proportions, carrying crew in additionto flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244Visualytics does not seekto exercise the privileges ofthis exemption, should it be granted, outside the United States. Ourrequest is strictly to be granted authority for civil UAS R&D operations at specified locations withinthe national airspace system.

# Dar!:&·~ President I Managing Partner Visualytics Group LLC.

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244

### References 1) FAA ExemptionNo. 11138, Regulatory DocketNo. FAA20140481 in the matter ofthe petition of DOUGLAS TRUDEAU 2) FAA ExemptionNo. 11136, Regulatory DocketNo. FAA-2014-0508 inthe matter ofthe petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA ExemptionNo. 11080 Regulatory Docket No. FAA20140355 in the matter ofthe petition of FLYING CAM INC


### URL Links for attachmentfiles over 30 MB: 1) Phantom 2 Vision+ User Manual http://download.djiinnovations.com/downloads/phantom 2 vision plus/en/Phantom 2 Vision Plus Use r Manual vl.8 en.pdf 2) Phantom Quick Start Manual http://download.djiinnovations.com/downloads/phantom/en/PHANTOM Quick Start Manual v1.7 en.p df 3) Phantom 2 VisionPilotTraining Guide http://download.djiinnovations.com/downloads/phantom 2 vision plus/en/Phantom 2 Vision Plus Pilo t Training Guide vl.l en.pdf 4) Phantom 2 Vision Release Notes http://download.djiitmovations.com/downloads/phantom 2 vision plus/en/Phantom 2 Vision Plus Rei ease Notes en.pdf 5) Phantom 2 Vision Battery Safety Guidelines http://download.djiinnovations.com/downloads/phantom 2 vision plus/Smart Flight Battery Safety G uidelines.pdf 6) 3D Robotics Solo User Manual http://3drobotics.com/wp-content/uploads/2015/08/v5 09 06 15.pdf 7) 3D Robotics Solo Preflight Checklist http:/ /3drobotics.com/kb/preflight-checklist-solo/ 8) 3D Robotics Solo Battery Safety http://3drobotics.com/kb/battery-safety-solo/ 9) 3DRobotics X8+ Operation Manual http:/ /3drobotics.com/wp-content/uploads/2015/04/X8-0peration-Manual-vC.pdf 1 0) 3D Robotics X8+ Flight Checklists http://3drobotics.com/wp-content/uploads/2015/04/X8-Checklist-vB.pdf 11) 3DRobotics X8+ Safety Checklist http://3drobotics.com/kb/safety/

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244