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 th e 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 a nd 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

- 60 4, 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 mappin g, 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 commercial ly 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 sm all 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 safe ty 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 giv es 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 pr ovides 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 cam era. 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
Obse rver (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 v ery 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 Cert ificates 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 op erating 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) Ove r 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 soug ht 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 t he 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 a n 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 poi nt 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 aircr aft 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) E xcept 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 servi ce 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, e ach 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 whi ch 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 d ate

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 par agraph (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 repai red 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 reconnaissan ce. 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 personne l 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 acciden t 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 AG L

➢ 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 fro m 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

haz ard 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 fo r 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 thre at to national security. sUAS Vision, LLC operation will also provide a benefit to the public interest as detailed in this petition.