1

June 11 , 2015

Aubrey Perry
Elevated Visions, LLC

7 Edenton Ct.
Ocoee, FL 34761

407

- 504

- 728 4 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 an d 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' busine ss 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’s2

Handbook, applicable Airworthiness Directives, and all othe r 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 visu al line of sight (“VLOS”), at low altitudes of 400 feet above ground level (“AGL”), or no higher than 200 feet

ab ove the highest obstacle with prior Flig ht Safety District Office approval. Any UAS in operation by Elevated Visions will not exceed 55 lbs. we ight.

At all times Elevated Visions will have a Chief Pilot responsible to properly train, maintain safe operations, ensure currency requirements are met, and consistently a ssure 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 flight s 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 rot orcraft 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 t han 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 con troller 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 a utomatic 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 checklis t will be3

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 failur e 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 t he 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 inspec tions 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 uti lized. 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 applicat ion. This data may be submitted to FAA via traditional means or other means as required.



### Conclusion

Ele vated Visions is requesting this exemption for the purposes of aerial photography

, videography . The reason for such a general and broad based request is th at 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 see king this exemption is to obtain the capability to offer those services while remaining in compliance.4



### 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 res pect 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

- obtai ned 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 down link 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 individ ual 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 af ter that for at least 30 minutes; or (2) At night, to fly

after that for at least 45 minutes.”5



### 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 tha t 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 thi s 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, t hese 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 paylo ad 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 initi al 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. §§ 61.11 3(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 syste ms (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