August 12, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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

Development of Methods to conduct aerial data collection, photography and videography consisting 

of structural inspections of homes and businesses (roofs), pipelines (oil and gas), real estate and golf 

course marketing and surveys and other flight operations that could be performed safely and more 

cost effectively with the use of small UAS. 

Dear Sir or Madam: 

In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under section 333 of 

the FAA Modernization and Reform Act of2012, Visualytics Group LLC. (Petitioner or Visualytics), is 

petitioning for an exemption from the Federal Aviation Regulations ("F ARs") and other rules/statutes 

pertaining to small Unmanned Aircraft Systems ("UAS") to conduct aerial data collection, photography 

and videography consisting of structural inspections of homes and businesses (roofs), pipelines (oil and 

gas), real estate and golf course marketing and surveys and other flight operations that could be 

performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. 

national airspace system as compared to a manned aircraft. Operations will be performed only at the 

request of and with the authorization and permission of clients or their authorized agents in order to 

facilitate commerce and raise awareness ofthe beneficial uses ofUAS's. So long as such operations are 

conducted within and under the 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 of integrating small UAS for civil use in to our national airspace and 

providing economic 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 FAA to allow Visualytics to pursue these activities it began researching in 

2014. 

In addition, 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, 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 of a regulation prescribed 

under§§ 44701(a) or (b) or in§§ 44702-44716 ofthe Act ifthe Administrator finds the exemption in the 

public interest. 

Obtaining a Section 333 exemption would allow Visualytics the authority to do further research and 

development in a safe and efficient manner without burdening the FAA with additional requests for each 

of our UAS platforms and operations. Currently, the FAA does not allow civil operations (meaning 

operations other than 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 exemption to operate small UAS to further develop 

its research and development of this emerging technology. 

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244 
Visualytics small UAS are aircraft weighing significantly less than 55 lbs. (details are provided within). 

They operate at slow speeds (under 45kts) and within line of sight within the areas described in this 

petition. Such operations will ensure that the small UAS operated by Visualytics will not create a hazard 

to other aircraft operating in the national airspace, to the general public or pose a threat to national 

security as dictated by the Federal Aviation Regulations (FAR). 

B. NAME AND ADDRESS OF THE PETITIONER: 

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 of the location of the 

pilot. All aircraft and pilots must comply with applicable sections of Title 14 ofthe Code ofFederal 

Regulations (14 CFR) to operate within the National Airspace. Unmanned aircraft are unable to comply 

with certain sections of 14 CFR as the regulations were written prior to the consideration of small UAS 

operating within the national airspace. Therefore Visualytics is requesting an exemption from certain 

parts of 14 CFR cited below in addition to such further exemptions and relief as the FAA may determine 

is necessary to permit the operations described herein. 

14 CFR Part 61.113 (a) and (b)- Private pilot privileges and limitations 

14 CFR Part 91.119 (c) - Minimum safe altitudes over congested and other areas 

14 CFR Part 91.121 - Altimeter settings 

14 CFR Part 91.151 (a) - Fuel requirements for flight in VFR conditions 

14 CFR Part 91.405 (a)- Maintenance required 

14 CFR Part 91.407 (a)- Operation after maintenance, preventive maintenance, rebuilding or alteration 

14 CFR Part 91.409 (a) (1) and (2)- Inspections 

14 CFR Part 91.417 (a) and (b)- Maintenance Records 

61.113(a) & (b). Visualytics request relief in order to facilitate the utilization of pilots, who hold a private 

pilot (or greater) certificate. UAS operations will always be conducted by one of the two licensed 

commercial and private pilots. Combined, Visualytics Pilots have 4000+ total flight hours, holding multiengine instrumented fixed wing ratings; one Pilot holds a current airline transport license as well as a 

Class I Medical certificate. Visualytics exceeds the minimum requirements mandated thus ensuring 

compliance of the National Air Space (NAS). This positions Visualytics to ensure the safety of the public 

at large. Any pilots operating under this exemption would be required to comply with any conditions set 

forth and in similar fashion to the previously granted exemptions. 

All Pilot in command (PIC) operating under this exemption would be required to comply with any 

conditions as set forth and in a similar fashion to the previously granted exemptions. All UAS operations 

will utilize a visual observer (VO) at all times while under this requested exemption. The PIC and VO 

must be able to communicate verbally at all times 

91.119(c) Discussed in Exemption 11138 (DOUGLAS TRUDEAU) (see reference 1), operations 

conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to 

essential persons, or objects that would not be possible without additional relief. The petitioner requests 

modification, waiver or exemption and clarification concerning the terms "congested areas" and "densely 

• 

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244 
populated". Visualytics requests waiver for this condition to allow reasonable and responsible operations 

with safety as our main concern in areas of subdivisions and neighborhoods if required. 

91.121 Discussed in Exemption 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 in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) (see reference 

2), prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, 

including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been 

granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides 

battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of 

powered flight. Information provided in the operating documents discusses procedures regarding 

remaining battery power management. Those documents contain a condition in which the PIC will initiate 

a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed 

operations and the location of those proposed operations, The FAA found that a reduced minimum power 

reserve for flight in daytime VFR conditions was reasonable. 

91.405(a). 91.407(a)(l). 91.409 (a)(l) & (2). 91.417(a) & (b) Discussed in Exemption 11138 

(DOUGLAS TRUDEAU) (see reference 1), Visualytics proposes to inspect and ensure that the UAS is in 

a condition for safe flight in accordance with the 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 sufficient to ensure that safety would 

not be adversely affected. 

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

EXEMPTION: 

Visualytics also requests exemption from such other F ARs as the FAA deems appropriate to enable the 

requested operations. If, during the effective dates of any Grant of Exemption issued pursuant to this 

Petition, the FAA issues interim or final rules for small UAS, Visualytics requests that it be relieved of 

the requirements of any conditions and limitations of said exemption and allowed to 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 Dll Phantom 

2 Vision+, the 3D Robotics Solo and the 3D Robotics X-SM. 

The Dll Phantom 2+ is a multi-rotor aircraft. The Phantom 2+ has a 1284g take-off weight (battery and 

propellers included). The Phantom 2+ carries a 5200mAh LiPo battery, which facilitates up to 25 minutes 

of flight time. It can be flown with either a radio or tablet and carries a 3-axis Camera Stabilization 

Gimbal with a 14 MegapixeV1 080p integrated camera system. The Phantom 2+ has a maximum cruise 

speed of 15 m/s. It features auto-takeoff and 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 GHz Wi-Fi module. 

The 3D Robotics Solo is a multi-rotor aircraft. The Solo has a flight time of 25 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, max payload: 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 76244 
144 em pitch); glass-reinforced nylon, autopilot: Pixhawk 2, software: APM Copter, communication: 

3DR Link 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 V de, battery charge time: -1.5 hours, controller battery: 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 3D Robotics X8-M is a multi-rotor aircraft. It weighs (with battery) 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 polymer battery. 

F. RISK MITIGATION 

Visualytics has reviewed FAA exemptions reference's 13 Conditions and Limitations section and 

believe that the procedures specified therein are reasonable and will be utilized in order to manage and 

mitigate risk and ensure public safety. 

A preflight checklist will be developed and employed to ensure that the UAS's airworthiness will be 

verified before launch. Airworthiness will be maintained by performance of routine inspections before 

each flight, maintaining flight and maintenance logs to record time on failure prone components. 

Visualytics request that in a manner similar to reference 13, be allowed to operate within 5 miles of an 

airport provided that: 

"The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The 

UA may not operate within 5 nautical miles of the geographic center of a non-towered airport as 

denoted on a current FAA published aeronautical chart unless a letter of agreement with that 

airport's management is obtained, and the operation is conducted in accordance with a NOT AM as 

required by the operator's COA. The letter of agreement with the airport management must be 

made available to the Administrator upon request." 

Operations within 5 miles of an 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 not requested due to the lack of mode C transponder. 

G. PUBLIC INTEREST 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental impact as 

compared to similar operations conducted with manned aircraft of greater proportions, carrying a crew 

and flammable fuel. 

In regards to performing inspections of homes and businesses (roofs) and pipelines (oil and gas) the UAS 

will minimize the risk to persons attempting to climb these structures and photograph problem areas. 

Safe, roof inspections conducted by human beings carries with it certain risks. Currently, inspectors need 

to physically climb onto the roof using ladders and other safety gear to conduct inspections. Sometimes, a 

two story/steep team is used, requiring two representatives and special safety harnesses. The dangers of 

inspecting any roof include losing one's footing, having a ladder slip, and being blown off a roof from 

wind shear. In addition to safety concerns, inspecting a roof by physically climbing on it has the potential 

to damage the roof. Using UAS for roof inspections avoids all of these risks. By utilizing UAS, 

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244 
Visualytics representatives will be able to reduce their exposure to hazards and rapidly obtain accurate 

assessments of the roof while remaining safety on the ground. Many of the pipelines (oil and gas) in our 

area travel in areas that are hard to reach by vehicle or foot and if an area is suspected of having problems 

the UAS can reach it to make an assessment easier and safer. 

The use of the UAS in order to 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 of their 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 operation time, 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 IN FEDERAL 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 relief from 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 of structural inspections of homes and 

businesses (roofs), pipelines (oil and gas), real estate and golf course 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 of the criteria provided in Section 333 ofthe FMRA regarding size, weight, speed, operating 

capabilities, proximity to airports and populated areas, operation within visual line of sight, and national 

security, provide more than adequate justification for the grant of the requested exemption allowing 

operation of Petitioner's use of small UAS for roof insurance 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 of exemption in circumstances similar in all material respects to those 

presented herein. In Grants ofExemption Nos. 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 Docket No. FAA-2014-0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA-2014-0642), the FAA found that the 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 of significantly greater proportions, carrying crew in addition to 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 76244 
Visualytics does not seek to exercise the privileges of this exemption, should it be granted, outside the 

United States. Our request is strictly to be granted authority for civil UAS R&D operations at specified 

locations within the national airspace system. 

Dar!:&·~ President I Managing Partner 

Visualytics Group LLC. 

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244 
References 

1) FAA Exemption No. 1113 8, Regulatory Docket No. F AA20 140481 in the matter of the petition of 

DOUGLAS TRUDEAU 

2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in the matter of the petition of 

ADVANCED AVIATION SOLUTIONS LLC 

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of 

FLYING CAM INC 

URL Links for attachment files 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 Vision Pilot Training 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/20 15/08/v5 09 06 15.pdf 

7) 3D Robotics Solo Preflight Checklist 

http:/ /3 drobotics.com/kb/preflight -checklist -solo/ 

8) 3D Robotics Solo Battery Safety 

http://3drobotics.com/kb/battery-safety-solo/ 

9) 3D Robotics X8+ Operation Manual 

http:/ /3drobotics.com/wp-content/uploads/20 15/04/X8-0peration-Manual-vC.pdf 

1 0) 3D Robotics X8+ Flight Checklists 

http://3drobotics.com/wp-content/uploads/20 15/04/X8-Checklist-vB.pdf 

11) 3D Robotics X8+ Safety Checklist 

http://3drobotics.com/kb/safety/ 

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244