Michael Ude 

South Bay Custom Video Productions, Inc. 

707 Torrance Blvd. #1 05 

Redondo Beach, CA 90277 

310-543-4901 

http://www.customvideo.tv/ 

Docket Operations, M-30 

U.S. Department of Transportation 

Room W12-140, West Building Ground. Floor 

1200 New Jersey Avenue, SE. 

Washington, DC 20590-0001 ~ ~ 

. , . 

I 

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

"Reform Act") and 14 C.F.R. Part 11, Vertical Approach Aerial Solutions, LLC 

(Operator) seeks an exemption from Federal Aviation Regulations (FARs) to 

allow commercial operations of their UASs (Unmanned Aerial Systems) for the 

purpose of conducting aerial photography, video, and survey for various 

industries. 

Regarding the Unmanned Aircraft Systems 

The requested exemption would support an application for a commercial 

Certificate of Authorization (COA) to use the below described UAS, so long as 

operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333. Like the FAA, it is 

the Operator's mission to provide the safest and most efficient means of Civil 

Commercial implementation into the National Airspace System (NAS). 

Furthermore, the Operator is comprised of members with the equivalent of a FAA 

Commercial Certificate or higher adding an additional layer of high regard for ~ 

safe operations as well as the necessary high-level of understanding of the NAS 

and FARs. 

Petition for Part 21; and 45.23(b); 61.113(a) & (b); 91.7(a); 91.9(b)(2); 91.103(b); 91.109; 

91.119; 91.1 21, 91.151{a); 91.203(a) & (b); 91.405(a); 91.407(a)(l); 91.409(a)(2); and 

91.417(a) & (b) of Title 14, Code of Federal Regulations I plan to operate another UAS, 

the PHANTOM 3 & similar units which each are comprised of an unma.llled aircraft (UA 

or PHANTOM) and a transportable ground station. The PHANTOM and UA are referred 

to as quad-copters with a maximum gross weight of around 5 pounds each. They are 

equipped with four rotors that are driven by electric motors powered by batteries. Each of 

the UA's have a maximum airspeed of around 20 knots. The UAS will have a small ultra6lightweight GoPro 3+ camera or equivalent onboard camera to the UAS and operate 

either of the UA's over various areas to record video for personal and marketing uses, 
aerial photography/videography for public and/or private use including real estate, 

wedding/event documentation, news gathering, architecture, lots, land surveying, 

engineering and other related professional activities. The UAS will also provide 

communities with new and picturesque representations of their city, businesses and their 

surroundings. Aerial videography for geographical awareness, real estate marketing, 

business advertising, and personal photography has been around for a long time through 

manned fixed wing aircraft and helicopters, but for small business owners, its expense 

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

service at a much lower cost. Furthermore, my small UAS will pose no threat to the 

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

aircraft. The operation of his UAS will minimize ecological damage and promote 

economic growth by providing new opportunities to individuals and businesses 

throu ghout the United States. --- - ~ --

The Pilot, Michael Ude, will provide the followi.TJ.g levels of safety: 

I will only operate in reasonably safe environments that are strictly controlled, are away 

from power lines, airports and densely populated areas; 

I will conduct extensive preflight inspections and protocols, during which safety carries 

primary importance. I will operate the UAS below 400 feet and within a radius distance 

of 1000 feet from the controller to both aid in direct line of sight visual observation; I will 

operate the UAS for up to 29 minutes per flight; 

I will land his UAS prior to the manufacturers recommended minimum level of battery 

power; I will operate his UAS only within visual line of sight (VLOS); 

I will use the UAS global positioning system (GPS) flight safety feature whereby it 

hovers and then slowly lands if communication with the remote control pilot is lost; 

I will conduct all operations under my own personal and flight safety protocols (including 

posting a warning sign reading: Attention Aerial Photography in Progress Remain Back 

150 feet) contained in the operating documents and will actively analyze flight data and 

other sources of information to constantly update and enhance the safety protocols; I will 

contact respective airports if operations will be within 5 miles to advise them of my 

estimated flight time, flight duration, elevation of flight and other pertinent information; I 

will always obtain all necessary permissions prior to operation; I will have procedures in 

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

Respectfully, 

~~ Michael Ude 11-30-2015 

President 

Custom Video Productions 

707 Torrance Blvd. #105 

Redondo Beach, CA 90277 

310-543-490i