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June 11, 2015

Aubrey Perry

Elevated Visions, LLC

7 Edenton Ct.

Ocoee, FL 34761

407-504-7284

aubrey@elevatedvisions.net

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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

the Federal Aviation Regulations 

Attachments:

1) Phantom 3 Quick Start Guide

2) Phantom pilot training guide

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, Elevated Visions LLC (“Elevated Visions”), an operator of the 

DJI PHANTOM 3 (“PHANTOM 3”) Unmanned Aircraft System (“UAS”), seeks exemption 

from the Federal Aviation Regulations (“FARs”) as described below. 

The exemption request will permit Elevated Visions to operate UASs commercially for the 

purpose of aerial photography and videography. The reason for such a general and broad 

based request is that Elevated Visions wishes to utilize a business strategy of horizontal 

integration in order to capitalize on opportunities as they arise without the turnaround 

time associated with additional exemptions. Elevated Visions' business model is based 

on the idea of offering ad hoc small UAS services to individuals or companies who wish 

to employ these services as a safe, effective, and legal option to enhance their business.

Elevated Visions will provide a service that is beneficial to an industry that is already using, 

and seeking to use, UASs for these purposes with a legal and safe option while providing 

relevant experience and information to the FAA and the UAS community. This will benefit 

the public with the controlled operation of UASs by Elevated Visions and increased 

integration into the National Airspace System (“NAS”). 

All operations by Elevated Visions will strictly adhere to safety, applicable FARs, Operator’s 
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Handbook, applicable Airworthiness Directives, and all other guidelines from the FAA. 

Elevated Visions will, at all times, conduct operations in a manner as to maintain the same

level of safety as current manned aircraft operations. 

Elevated Visions will operate exclusively in controlled conditions, within visual line of sight 

(“VLOS”), at low altitudes of 400 feet above ground level (“AGL”), or no higher than 200 feet 

above the highest obstacle with prior Flight Safety District Office approval. Any UAS in 

operation by Elevated Visions will not exceed 55 lbs. weight. 

At all times Elevated Visions will have a Chief Pilot responsible to properly train, maintain 

safe operations, ensure currency requirements are met, and consistently assure an open 

line of communication with the FAA.

The UASs operated by Elevated Visions satisfies the criteria set forth in Section 333 of the 

Reform Act–size, weight, speed, operating capabilities, operation within visual line of sight, 

and national security–and showing an equivalent level of safety to manned aircraft flights 

through appropriate pilot certification and safety focused standards of operation, providing 

more than adequate justification for the grant of the requested exemptions allowing 

commercial operations. 

The UAS

The Phantom 3 is a consumer grade small rotorcraft in the quadcopter configuration with an 

advertised weight of less than 46 Ounces (1280g) designed primarily to carry aloft a high 

definition camera. It has an advertised maximum speed of less than 32 knots (16m/s) and a 

maximum climb rate of less than 1200 feet per minute (5 m/s). It is powered by four electric 

motors with a distance between motors of less than 14 inches (289mm). It utilizes an internal 

inertial measuring unit (IMU) with integrated barometric sensor augmented with global 

positioning system (GPS) to maintain its geospatial orientation and position. It is controlled 

primarily through an FCC certified radio control (RC) unit. Real time video and telemetry 

information is transmitted back to a ground control station allowing the operator and/or PIC 

to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, camera 

imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or 

GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can 

be preprogrammed by the PIC. Battery life limits flight times to approximately 23 minutes. 

The onboard flight controller will warn the pilot via telemetry and external lighting cues before 

reaching a low battery state. An automatic termination of flight and landing will be initiated 

when the battery reaches a predetermined low state. It is anticipated that flights will usually 

last less than 15 minutes. More information is available in attachment 1. 

Risk mitigation

Elevated Visions has reviewed FAA exemptions reference’s 1-3 Conditions and Limitations 

section and believes 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 
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developed and employed to ensure that the UA 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. These 

documents will be made available to the FAA and SoT to assist in future implementation of 

safety standards and regulations. The petitioner will only operate the UAS over designated 

properties with the owner’s consent. Flight plans will be predetermined to limit the UASs 

flight time and limit safety concerns. Elevated Visions will take into account distance from 

persons and potential flight obstacles prior to operating the UAS. UAS operation will always 

be within VLOS of the PIC and the observer. 

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. Additionally, 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 videography/photography. Aerial photography is a valuable 

marketing tool that can lead to increased commerce and enhance personal photography. 

Aerial surveying and inspections can increase work site efficiency, improve volumetric 

estimations and reduce risks. The petitioner will provide clients with photographic data for 

these purposes on a ‘for hire’ basis acting as an independent contractor. A visual observer 

will be utilized. Flight data including UA flight time, Control Unit operation time, incident, 

accident, and details concerning any deviations from normal operations will be available to 

FAA for use in collecting data regarding the use of UAS as part of this application. This data 

may be submitted to FAA via traditional means or other means as required.

Conclusion

Elevated Visions is requesting this exemption for the purposes of aerial photography, 

videography. The reason for such a general and broad based request is that Elevated 

Visions wishes to utilize a business strategy of horizontal integration and maximize 

economies of scope in order to capitalize on opportunities as they may arise in the future 

without the long turnaround time associated with additional exemptions. Elevated Visions'

business model is based on the idea of offering ad hoc small UAS services to individuals or 

companies who wish to employ these services as a safe, effective, and legal option to 

enhance their business or hobby. The primary purpose of seeking this exemption is to obtain 

the capability to offer those services while remaining in compliance. 
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SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN

EXEMPTION

A. 14 C.F.R. §§ 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in 

Command. 

These regulations limit private pilots to non-commercial operations. Because the UAS 

will not carry a pilot or passengers and be operated within limited areas and altitudes, 

the proposed operations can achieve the equivalent level of safety of current operations 

by requiring the PIC operating the aircraft to have a private pilot’s license rather than a 

commercial pilot’s license to operate this small UAS. 

B. 14 C.F.R. § 91.7(a) Civil Aircraft Airworthiness 

While the UAS will not have an airworthiness certificate in accordance with 14 C.F.R. 

part 21, Subpart H, the airworthy condition of the UAS will be the responsibility of the 

PIC in accordance with 14 C.F.R. § 91.7(b). 

C. 14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and other areas 

This regulation establishes safe altitudes for operation of civil aircraft over areas other 

than congested areas. Elevated Visions requests relief from this section with respect to 

persons involved in the operation as well as vehicles and structures. The UAS will not 

be operated above 400 feet altitude. It will be operated in a defined area where people 

and buildings will not be exposed to operations without their pre-obtained consent. 

D. 14 C.F.R. § 91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the UAS does not have a 

barometric altimeter, an exemption is requested. The UAS Flight Controller utilizes 

GPS equipment aided by a static pressure sensor to determine and maintain altitude. 

The aircraft altitude above the takeoff point is provided in the video downlink telemetry 

information and provides sufficient information for the PIC to maintain altitudes at or 

below the 400 foot (122 meter) limitations. 

E. 14 C.F.R. § 91.151(a) Fuel requirements for flight in VFR conditions 

Section 91.151(a) prohibits an individual from beginning “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 cursing 

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.” 
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Given that the UAS aircraft only fly for a maximum of approximately 25 minutes and 

typically carry about 15 minutes of batter power, an exemption is requested. The UAS 

operations are always conducted within a few minutes of the takeoff and landing point 

and within a restricted area. Elevated Visions believes that terminating the flight with 

25% remaining battery power provides an equivalent amount of safety that is intended 

by section 191.151(a). 

F. 14 C.F.R. § 91.405(a) Maintenance Required; 

14 C.F.R. § 91.407(a)(1) Operation after maintenance, preventative 

maintenance, rebuilding or alteration; 

14 C.F.R. §§ 91.409(a)(1) and (2) Inspections; 

14 C.F.R. §§ 91.417(a) and (b) Maintenance Records 

These regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain 

the aircraft in compliance with part 43. 

Given that the sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Elevated Visions. Maintenance will be 

accomplished by the operator pursuant to the Owner’s Manuals. An equivalent level of 

safety will be achieved because these small UAS are very limited in size and will carry a 

small payload and operate only in restricted areas for limited periods of time. If 

mechanical issues arise, the UAS can land immediately and will be operating from no 

higher than 400 feet AGL. The operator will ensure that the UAS is in working order 

prior to initial flight, perform required maintenance and keep a log of any maintenance 

performed. Moreover, the operator is the person most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition to provide the equivalent level of

safety. The FAA issued exemption to these regulations in Exemption No. 11062. 

SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER

Petitioner: Elevated Visions, LLC. 

Sections of 14 C.F.R Affected: §§ 61.113(a) and (b); § 91.7(a); § 91.119(c); § 91.121; § 

91.151(a); § 91.405(a); § 91.407(a)(1); §§ 91.409(a)(1) and (2); §§ 91.417(a) and (b) 

Description of Relief Sought: Elevated Visions, LLC seeks relief from the requirements 

of 14 C.F.R. §§ 61.113(a) and (b); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. 

§ 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 

C.F.R. §§ 91.409(a)(1) and (2); 14 C.F.R. §§ 91.417(a) and (b) to operate small 

unmanned aircraft systems (UAS) for the purpose of aerial photography and 

videography. 
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Respectfully submitted,

Aubrey Perry

Founder and CEO

Elevated Visions, LLC

7 Edenton Court

Ocoee, FL 34761

407-504-7284