sUAS Vision, LLC

122 Tom Nora Place

Villa Rica, Georgia 30180

Phone: (404) 597-7521

August 20, 2015

United States Department of Transportation

Federal Aviation Administration

Docket Operations

1200 New Jersey Avenue SE

Washington DC 20590

Re: Petition for an exemption seeking relief from specific sections of Title 14 CFR under 

Section 333 of the FAA Modernization and Reform Act of 2012 (Public Law 112-95)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11 

sUAS Vision, LLC hereby seeks an exemption from the Federal Aviation Regulations as 

detailed below for the purpose of conducting commercial Unmanned Aerial System (UAS) 

operations in the National Airspace System (NAS).
TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS..............................................................................3

NAME AND ADDRESS OF THE PETITIONER...............................................................4

BACKGROUND AND OPERATING DESCRIPTION........................................................4

DESCRIPTION OF UAVs AND GCS............................................................................5

SECTIONS OF 14 CFR FROM WHICH

sUAS VISION, LLC SEEKS EXEMPTION......................................................................8

PUBLIC INTEREST................................................................................................12

SAFETY...............................................................................................................12

SUMMARY SUITABLE FOR THE PUBLIC REGISTER...................................................13

ADDITIONAL INFORMATION, VIEWS, AND ARGUMENTS.............................................13
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

ATC Air Traffic Control

ATO Air Traffic Organization

UAV Unmanned Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control System

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

Section 333 FAA Modernization and Reform Act of 2012 Section 333

SOP Standard Operating Procedures

sUAS small Unmanned Aircraft Systems

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing
NAME AND ADDRESS OF THE PETITIONER:

The name and address of the petitioner is:

sUAS Vision, LLC

Sonny Brown, Owner

122 Tom Nora Place

Villa Rica, GA 30180

(404) 597-7521

Airline Transport Pilot #3026463

Certified Flight Instructor #3026463CFI

FAA Second Class Medical Certificate issued 05/21/2015

Private Corporation Captain, Challenger 604

BACKGROUND AND OPERATING DESCRIPTION

sUAS Vision, LLC seeks exemption from the requirements of 14 CFR FAR Parts 91.7 (a), 91.9 

(b) 2, 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a)1, 91.409 (a) 1 and 2, 91.417 (a) and (b) 

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012. This exemption will 

permit sUAS Vision, LLC to obtain an appropriate Certificate of Authorization to operate the 

described UAV aircraft below within the NAS for the commercial purpose of collecting aerial 

photo and video information and data.

sUAS Vision, LLC was formed in 2015 by Sonny Brown. Mr. Brown is an active Part 91 

commercial pilot for a private corporation. Mr. Brown holds ATP certificate #3026463 with Type 

Ratings in the BE-300, CE-525, CE-560XL, CL-604, G-100, and IA-1125 aircraft. Mr. Brown 

also is an FAA certified flight instructor and holds a valid FAA Second Class Medical Certificate.

Mr. Brown has been flying RC aircraft recreationally for over 20 years and has 2 years of 

experience operating the type of UAVs that will be flown under the desired exemption. sUAS 

Vision, LLC seeks to provide aerial photo and video services for a variety of clients. Examples of 

services shall include but not be limited to; construction job site progression and mapping, 

search and rescue, golf course mapping, mining research, residential/commercial real estate 

brokers, insurance companies, roofing/construction contractors, filming/cinematic companies.

As set forth in this petition, sUAS Vision, LLC seeks to commercially operate it’s UAVs with the 

highest level of safety and professionalism consistent with Mr. Brown’s long history as an 

aviation professional.
Description of UAVs and Ground Control Station (GCS)

DJI Phantom 2 Vision+:

The DJI Phantom 2 Vision+ is a small quadcopter that takes off and lands vertically (VTOL). It is 

powered by 4 electric motors and a 5200mAh battery pack. It has a ready to fly gross weight of 

2.8 pounds and can fly for a duration of 14 minutes on a fully charged battery. It has a maximum

airspeed of approximately 33 knots. It has a sophisticated onboard flight controller with GPS 

integration that provides stabilized flight and extremely precise control from the portable Ground 

Control Station (GCS). There is a flight telemetry system that delivers flight data from the 

onboard flight computer to the GCS including altitude AGL, horizontal and vertical speed, 

battery voltage, compass direction of flight and direction back to the takeoff point. The flight 

controller also has many built-in safety features that will command the Phantom to return to the 

takeoff point in the event of a Loss of Link (LOL). There is a low battery voltage indication at 

20% battery power remaining, and a “hard warning at 15% remaining that will begin a slow 

descent for landing. The user can define maximum flight parameters such as altitude and/or 

lateral distance from the GCS. The Phantom 2 Vision+ has a 3 axis gimbal that provides 

stabilization for a small digital camera allowing for smooth and accurate photo and video

acquisition. The Phantom 2 Vision+ uses a mobile device to transmit live video feed that 

displays live video data and flight information to the operator and/or Visual Observer (VO).
DJI Phantom 3 Professional:

The DJI Phantom 3 Professional is an upgraded version of the DJI Phantom 2 Vision+ sharing 

all of the features and improving on them. The Phantom 3 Professional boast a new feature 

taken from the higher end Dji Inspire 1 called lightbridge downlink. It gives the Phantom 3 

Professional slightly more range than the Phantom 2 Vision+. It also has a new visual 

positioning system, again taken from the Inspire 1, allowing the Phantom 3 to better maintain its 

position at lower altitudes. Flight characteristics for the Phantom 3 Professional are the same as 

described above for the Phantom 2 Vision+. The user can define maximum flight parameters 

such as altitude and/or lateral distance from the improved GCS. The Phantom 3 Professional 

also has a 3 axis gimbal that provides stabilization for an upgraded small digital camera allowing 

for smooth and accurate photo and video acquisition. The Phantom 3 Professional uses a 

mobile device to transmit live video feed that displays live video data and flight information to 

the operator and/or Visual Observer (VO).
DJI Inspire 1:

The DJI Inspire 1 is a more complex UAV from DJI. It also is a small quadcopter that takes off 

and lands vertically (VTOL). It is powered by 4 electric motors and a 5700mAh battery pack. It 

has a ready to fly gross weight of 6.47 pounds with a flight duration of 18 minutes on a fully 

charged battery. It has a maximum speed of 43 knots. The Inspire 1 has the capability to have 

two operators, one flying the UAV while the other operates the camera. It has a lot of the same 

features that the above Phantoms have, ex; gps lock, auto pilot, ground control station, 

lightbridge link, etc. Another feature of the Inspire 1 is retractable landing gear. This allows for 

360 degree rotation of the 4k camera. The user can define maximum flight parameters such as 

altitude and/or lateral distance from the GCS. The Inspire 1 uses a mobile device to transmit live 

video feed that displays live video data and flight information to the operator and/or Visual 

Observer (VO).

Ground Control Station (GCS):

The GCS consists simply of an application used on a mobile device (iPhone) to pilot the UAV. 

The mobile device is attached to the RC transmitter to view the live image of the on board 

camera. This makes the GCS very portable and allows for flexibility and ease of use. The RC 

transmitter transmits on the 2.4 GHZ band at a power of 100mw and requires no FCC license to 

operate.
SPECIFIC SECTIONS OF 14 CFR FROM WHICH sUAS Vision, LLC SEEKS 

EXEMPTION AND THE EXTENT OF RELIEF SOUGHT AND THE REASON THAT 

THE RELIEF IS SOUGHT

The petitioner believes that as per Section 333 of PL 112-95, and in consideration of the size, 

weight, speed, and limited operating area associated with the aircraft and its operation, that 

relief from 14 CFR Part 21 Subpart H regarding Airworthiness Certificates is not necessary and 

therefore relief is not sought.

FAR Part 91.7 (a) prescribes that;

No person may operate a civil aircraft unless it is in an airworthy condition.

Relief is requested to maintain an airworthy condition by compliance with the operating 

procedures and documents prescribed in this petition prior to every flight.

FAR Part 91.9 (b) 2 prescribes that;

(b) No person may operate a U.S.-registered civil aircraft—

(1) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this 

chapter unless there is available in the aircraft a current, approved Airplane or Rotorcraft 

Flight Manual or the manual provided for in § 121.141(b); and

(2) (2) For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 

of this chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or any 

combination thereof.

Relief is requested to comply by keeping all relevant company operating procedures, limitations, 

logbooks, and checklists in a location accessible to the PIC.

Far Part 91.119 prescribes in part that;

Except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes:

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.
Relief is sought for FAR 91.119 (c) because that UAV aircraft will be operated below 400 feet 

AGL and would not be able to comply with this subparagraph. Petitioner would operate in 

accordance with the limitations described in this petition or by any other limitations the FAA 

deems necessary.

Far Part 91.121 prescribes in part that;

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of 

that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, 

the current reported altimeter setting of an appropriate available station;

or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure;

or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

Relief is sought because the UAV aircraft does not have a typical barometric altimeter on board, 

and all reported altitudes will be reported in feet AGL.

Far Part 91.151 (a) prescribes that;

(a) No person may begin 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.

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 

minutes.
Relief is sought to operate at less than the prescribed minimums because UAV will never be 

flown more than 1/2 mile from the point of intended landing, and that safety will be maintained 

by monitoring the elapsed time in flight, real time battery voltage condition, and the 2 level low 

battery warnings detailed above in the UAV description. The PIC will never begin a flight unless 

there is enough power to fly to the intended point of landing at normal cruising speed and still 

land with 20% battery power remaining.

Far Part 91.405 (a), 91.407 (a) 1, 91.409 (a) 1 and 2, 91.417 (a) and (b) prescribe that -

91.405 (a)

Each owner or operator of an aircraft—

(a) 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;

91.407 (a) 1

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under §43.7 of this 

chapter; and

91.409 (a) 1 and 2

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by §43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 

21 of this chapter.

91.417 (a) and (b)

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in paragraph 

(b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of 

the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and
(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return 

to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to 

be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its appliances 

are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives 

including, for each, the method of compliance, the AD or safety directive number and 

revision date. If the AD or safety directive involves recurring action, the time and date 

when the next action is required.

(vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration 

to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the 

work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under §43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service.

Relief from these sections is sought because it is our intention to perform any maintenance and 

inspections as described in the operations manual of either UAV above and that this will ensure 

a high level of safety. The PIC will be responsible for ensuring that the aircraft is in airworthy 

condition prior to every flight. The PIC will document any work performed in the aircraft logbook 

as well as cumulative flight time.
PUBLIC INTEREST

The use of sUASs can significantly promote safe and effective Construction Jobsite inspection 

and tracking. The use of sUASs can reduce the risk to workers while inspecting, surveying, or 

monitoring installation of work that requires ladders, scaffolds or other potentially hazardous 

means of elevated access. sUASs can inspect, photograph, video and collect data on 

inaccessible areas that otherwise would require worker inspection, in addition to providing 

facility security and emergency response reconnaissance. sUASs can also provide high 

resolution aerial imagery, elevation measurement, mapping, and thermal imagery data. 

Reducing manned flight and human inspection of such sites through sUAS use for site imaging 

will reduce risk to workers and ground personnel and create an improved safety operating 

environment. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or 

accident. The sUASs that will be used carry no fuel, and therefore the risk of fire following an 

incident or accident due to fuel spillage is eliminated.

THE REASONS WHY GRANTING THE REQUEST WOULD NOT

ADVERSELY AFFECT SAFETY

Because of the speed, weight, size, and limited operating area associated with the proposed 

UAV aircraft operations, the Petitioner submits that our proposed flights would not create a 

hazard to other users of the NAS or to the public, or otherwise pose a threat to national security. 

I also submit that sUAS Vision, LLC can safely operate in the NAS pursuant to FMRA Section 

333 because:

➢ The PIC is qualified and has an abundance of operational experience.

➢ Flights will be operated within line of sight of a pilot and/or observer. 

➢ Flights will be terminated at 20% battery power reserve. 

➢ Flights will be operated at an altitude of no more than 400ft AGL 

➢ Flights will only be operated in reasonably safe environments that are strictly controlled, 

are away from airports and actively populated areas. 

➢ A briefing will be conducted for planned UAS operations prior to each flight. 

➢ Consent will be obtained from all persons involved in the operation. 

➢ If the UAS loses communications, the UAS will be placed in "Return to Home" mode and 

will return to its point of takeoff. 

➢ The UAS flight will be aborted should circumstances arise that would create a potential 

hazard to person or property.

➢ sUAS Vision, LLC will operate to ensure the highest level of safety to ourselves, our 

clients, and the public.
SUMMARY SUITABLE FOR THE PUBLIC REGISTER

sUAS Vision, LLC seeks exemption from the requirements of 14 CFR Parts 91.7 (a), 91.9

(b) 2, 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a) 1, 91.409 (a) 1 and 2, 91.417 (a) and

(b). This exemption will permit sUAS Vision, LLC to commercially operate a UAV aircraft for the 

purpose of collecting aerial photo and video assets for a variety a clients.

ADDITIONAL INFORMATION, VIEWS, AND ARGUMENTS

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 Section 333. 

As stated above, sUAS Vision, LLC will operate safely in the NAS without creating an undue 

hazard to other users of the NAS, the general public, or by posing a threat to national security. 

sUAS Vision, LLC operation will also provide a benefit to the public interest as detailed in this 

petition.