CameraView Photography and Video, LLC

Dennis Jones, Owner

- Pilot 20218 Rockhollow Dr Arcadia, Oklahoma 73007 405

- 641

- 4476 cameraview@airosurf.com

June 30, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Wa shington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam: Subject: Exemption Request Section 333 of the FAA Reform Act Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, Ca meraView Photography and Video would like to apply for an exemption from the following Code of Federal Regulations (C.F.R) to allow commercial operation of Small Unmanned Aircraft Systems ( SUAS ) for aerial imaging, video, mapping and photogrammetry . This v ideo and image data will be used for survey analysis, safety and/or damage inspection, aerial photography, right

- of

-way procurement and for producing orthorectified maps and images . These are services that will be offered and safely executed to various cli ents or industries with these types of needs. The operations of the service(s) will only be carried out with the proper approval from property owners and any other agencies requiring approval. Safety will be top priority before, during, and after operation s of the services.

CameraView Photography and Video will initially be flying a 3DR Solo multirotor SUAS

. Wehave successfully flown over 150 flights without any accidents (flying our Blade 350 QX2 and other multi

- rotor SUAS ).

CameraView Photography and Video is requesting exemption from the following CFRs : 14 C.F.R. Part 21 Subpart H 14 C.F.R. 45.27(a) 14 C.F.R. 45.29 (3) (c)(d)(e)(f)(g)(h) 14 C.F.R. 61.113 (a) & (b) 14 C.F.R. 91.103 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.203 14 C.F.R 91.151

### C.F.R. REGULA**TIONS**

**- REQUEST SPECIFIC EXEMPTION.** 

**14 C.F.R. Part 21, Subpart H: A irw**  **orthiness Certificates 14 CFR § 91.203**

CameraView Photography and Video seeks to request exemption from 14 C.F.R. Part 21, Subpart H Airworthiness Certificates 14 CFR to t he extent of not requiring a traditional airworthiness certificate for the o peration of a SUAS . The reason for

requesting the exemption is not applicable to SUAS characteristics. The information requested is based on a typical aircraft. The mechanical, electronic, and capacity characteristics for a SUAS are very different from a typical aircraft made for passenger or cargo transportation. CameraView Photography and Video will inspect each SUAS before and after each flight to assure air worthiness. The following is a re checklist that will be used:

Pre

- Flight 1. Check lock nuts on each prop. 2 . Check each prop for damage or wear. 3 . Check frame for cracks or loose screws. 4 . Ensure motors are level. 5 . Check landing gear is fixed and stable

. 6 . Secure battery with straps

. 7 . Any camera is properly secured to the gimbal or bracket and connect to SUAS. 8

. Check for any vibration or note abnormal prop noise.

Post

- Flight 1. Throttle down to idle 2. Wh ile idling, check and listen for abnormal vibrations and sounds. 3. Check for any structural damage to body, motors and landing gear.

SUAS used by CameraView Photography and Video weigh less than 10 pounds including payload. All SUAS will not have a maximum speed that will not exceed 55 mph. All SUAS are battery powered (Lithium Polymer (LiPo)) and carry no flammable fuel. In the event of communication failure, the SUAS will return to home (RTH) position (established before flight). The SUAS w ill be safely operated in an approved enviro nment , outside of all restricted air spaces

. **14 C.F.R. 45.27(a): Location of marks; non fixed**

**- wing aircraft.**  Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.2 7

. CameraView Photography and Video request exemption from 14 CFR 45.27 (a) to the extent of not following this regulation since it is applicable to a typical aircraft. There is no fuselage, cabin, or boom on a multi

- rotor SUAS . Ho wever the intent of assigning a unique identifier to a SUAS for the purposes of country and owner identification will be followed. The unique ID will be the owner’s phone number until further direction from the FAA.**14 C.F.R. 45.29 (3) (c)(d)(e)(f)(h): Size of Marks** 

Rotorcraft: must be at least 12 inches high, except that rotorcraft displaying before April 18, 1983, marks required by §45.29(b)(3) in effect on April 17, 1983, and rotorcraft manufactured on or after April 18, 1983, but before December 31, 1983, may display those marks until the aircraft is repainted or the marks are repainted, restored, or changed. (c) Width. Characters must be two

- thirds as wide as they are high, except the number “1”, which must be one

-sixth as wide as it is high, and th e letters “M” and “W” which may be as wide as they are high. (d) Thickness. Characters must be formed by solid lines one

-sixth as thick as the character is high. (e) Spacing. The space between each character may not be less than one fourth of the character width. (f) If either one of the surfaces authorized for displaying required marks under §45.25 is large enough for display of marks meeting the size requirements of this section and the other is not, full size marks must be placed on the larger surface. If neither surface is large enough for full

-size ma rks, marks as large as practicable must be displayed on the larger of the two surfaces. If no surface authorized to be marked by §45.27 is large enough for full

-size m arks, marks as large as practicable mus t be placed on the largest of the authorized surfaces. However, powered parachutes and weight

-shift

- control aircraft must display marks at least 3 inches high. (h) After March 7, 1988, each operator of an aircraft penetrating an ADIZ or DEW IZ must display on that aircraft temporary or permanent nationality and registration marks at least 12 inches high. CameraView Photography and Video request exemption from 14 CFR 45.29 (3) (c)(d)(e)(f)(g)(h) to the extent of not requiring identification marks of 12 inche s and applicable width, spacing, and thickness. Identification (phone number or FAA unique ID requirement) will be displayed on the motor arms of all multi

- rotor SUAS as large as possible without effecting performance of the SUAS . A n approximate sixe e stim ate would be about 1⁄2 inch font.

**14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command.**  (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. (c) A private pilot may not pay less than the pro rata share of the operating expenses of a flight with passengers, provided the expenses involve only fuel, oil, airport

expenditures, or rental fees.CameraView Photography and Video request exemption from 14 CFR 61.113 (a) to the

extent of not requir ing a pilot’s certificate at this time to operate a SUAS as pilot in command. CameraView Photography and Video request the acceptance of Academy of Model Aeronautics membership. This organization has a significant history with providing education for remote control devices including aircraft. Members have access to a centralized knowledge base for beginning and continuing education in aerodynamics. Academy of Model Aeronautics is located at: 5161 East Memorial Drive Muncie IN 47302 Phone: 765.287.1256

CameraView Photography and Video request exemption from 14 CFR 61.113 (b) to the extent of receiving some portion of payment for SUAS services but not to the extent of carrying passengers or cargo since it will be impossible for our SUAS to carry passenge rs or any cargo heavier than 120 grams (in additions to the Solo gimbal and

c amera). In addition, to the extent of using a remote controlled device and no passenger involvement, the risk of hazardous conditions and risk to life are significantly reduced. C ameraView Photography and Video SUAS operation will be equally or more safe than traditional rotorcraft. The exemption from this regulation will benefit the public by providing an opportunity for developing a market in SUAS services at a lower risks and l ower startup/operating costs than traditional rotorcraft services.

**14 C.F.R. 91.103 (b)(1), (b)(2): Preflight A ction**  Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— (a)... (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature. CameraView Photography and Video request exemption from 14 CFR 91.103 (b)(1) and (b)(2) to the extent of not requiring landing and takeoff distance calculation since there is no runway required (SUAS that will be used are Vertical Take Off and Landing (VTOL )). However, for safety, preflight checks do apply to the operation of a SUAS and will be adhered to:**Pre**

**- flight**  **and Post**

**- Flight**  **Checklist**

The following is are checklist that will be used:

**Pre**

**- Flight**  1. Confirm weather conditions. 2. Check lock nuts on each prop. 3. Check each prop for damage or wear. 4. Check frame for cracks or loose screws. 5. Ensure motors are level. 6. Check landing gear is fixed and stable

. 7. Secure battery with straps

. 8. Any camera is properly secured to the gimbal or bracket and connect to SUAS. 9. Power up camera. 10. Power up SUAS. 11 . Check voltage indication from flight controller and make note of current voltage and amperage. 12 . Note wind speed and direction. 1 3 . Check throttle is set to idle. 1 4 . Arm flight controller and check for errors or warnings. 15

. Pilot in Command (PIC) assures that no person, animal or vehicle no less than 10 meters from SUAS

. 16 . Check for any vibration or note abnormal prop noise. 17. Final check for any person, animal, or aerial/ground vehicle approaching flight path

area.

**Post**

**- Flight**  1. Throttle down to idle 2. Wh ile idling, check and listen for abnorma l vibrations and sounds. 3. Power off SUAS. 4. Power off controller. 5. Power off camera. 6. Check for any structural damage to body, motors and landing gear.

**14 C.F. R. 91.119 (c) : Minimum Safe A ltitudes**  Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surf ace, 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. (d) Helicopters, powered parachutes, and weight

-shift

- control aircraft. If the oper ation is conducted without hazard to persons or property on the surface

—(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b)

or (c) of this section, provided each person operating the helicopter complies with any routes o r altitudes specifically prescribed for helicopters by the FAA; and (2) A powered parachute or weight

-shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section. 14 CFR 91.119 (a)(b) and (d)

– These regulat ions are applicable to the operation of a SUAS and will be part of the flight route planning between pilot and co

- pilot to provide emergency landing area(s) and identifying restricted area(s). No flights will take place in restricted areas. CameraView Photography and Video request exemption from 14 CFR 91.119 (c) to the extent of requiring an altitude of more than 5 00 feet ab ove the surface. CameraView Photography and Video will fly all of our SUAS at 400 feet or below AGL. Any flight route 4 00 feet a bove the surface will increase the risk of loss of sight orientation in which the SUAS pilot must recover. People and property owners below flight route must also provide verbal or written permission before operations. All public safety regulations will al so be followed. Normal operations for services provided will be at very low

- altitude. This exemption will provide for more safe operations of a SUAS since the visual line of sight limit will mitigate loss of control. The size and weight of SUAS makes this exemption safer than current regulation for typical rotorcraft.

**14 C.F.R. 91.121: A ltimeter Settings**  (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. (b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the following table: Current altimeter setting lowest usable flight level 29.92 (or higher) 180 29.91 through 29.42 185 29.41 through 28.92 190 28.91 through 28.42 195 28.41 through 27.92 200 27.91 through 27.42 205 27.41 through 26.92 210 (c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum fligh t level, the pilot shall take the flight level equivalent of the minimum altitude in feetand add the appropriate number of feet specified below, according to the current

reported altimeter setting: Current altimeter setting Adjustment factor 29.92 (or higher) None 29.91 through 29.42 500 29.41 through 28.92 1,000 28.91 through 28.42 1,500 28.41 through 27.92 2,000 27.91 through 27.42 2,500 27.41 through 26.92 3,000 CameraView Photography and Video request exemption from 14 CFR 91.121 to the extent of not following all of the regulations (91.121) as it is written due to the fact that these regulations are applicable to a typical aircraft. However the intent of the regulation does need to be followed for SUAS operations. The flight controller used on any SUA S will be equipped with a micro barometer to provide altitude information via telemetry to the PIC . The barometer is integrated with the configuration and operation of the flight controller to provide a way for the pilot to maintain an “ altitude hold ” auto matically. The flight controller also provides the PIC altitude information. These feature s provide another reason supporting public and national airspace safety during SUAS operations. This specific technology, along with other advanced features, will foster economic sector growth as a whole. Due to the small SUAS and ability to maintain consistent altitude, this exemption will provide a safer environment than current regulations for full sized rotorcraft.

**14 CFR 91.151 (a) and (b): Fuel requirements f or flight in VFR conditions**  (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 spee d

— (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. CameraView Photography and Video request exemption from 14 CFR 91.151 (a) and (b) to the extent of not follow ing these regulations as it is written due to the fact that these regulations are applicable to a typical aircraft. However, the intent of the regulation is to insure the safe operation of the powered aircraft while in flight and provide for extra fuel in case of emergencies. This same approach and intent will be followed for the operation of SUAS

. During pre

-flight checks, the PIC will assure that the flight controller and SUAS have fully charged batteries.

The following summary is provided for publicatio n in the Federal Register: Petitioner asks for an exemption from the following rules: 14 C.F.R. Part 21 14 C.F.R. 45.27(a)14 C.F.R. 45.29 (3) (c)(d)(e)(f)(g)(h)

14 C.F.R. 61.113 (a) & (b) 14 C.F.R. 91.103 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.203 14 C.F.R 91.151 If CameraView Photography and Video has erroneously omitted any other relevant section or, overstated any relevant section for our intended operations, please feel free to suggest the missing or overstated section(s). The purpose of this request is to operate a small unmanned vehicle (10lbs or less) for aerial imaging, video, and surveillance services. Exemption from the C.F.R. regulations will provide for safer operations than using traditional methods of rotorcraft. Furthermore, a SUAS powered by batteries eliminates all risks associated with larger rotorcraft

– fuselage, flight crew and fuel. SUAS do not require high

- speed aerodynamics of large mechanical moving structure s to achieve lift that is typical of rotorcraft thus reducing risk even further. The operation of small SUAS , weighing less than 10 lbs., will be conducted under strict rules and conditions outlined herein, will provide an equivalent or better level of safety supporting the grant of the exemptions requested herein, inclu ding exempting the applicant from the requirements of Part 21 and allowing commercial operations. The SUAS operate at slower speeds, close to the ground, and in a controlled environment and, as a result, are far safer than conventional operations conducted with rotorcraft operating in close proximity to the ground and people. Granting these SUAS exemptions will foster the opportunity for small businesses to create opportunities to use aerial imaging products at extremely lower start

- up and operating cost. U sing battery operated SUAS, at lower altitudes, will be safer for the public and easier on the environment (noise pollution, fossil fuel production).

**Response to Section 333 (b) (1)** Section 333 (b) (1) ASSESSMENT OF UNMANNED AIRCRAFT SYSTEMS

— In making the determination under subsection: (b), the Secretary shall determine, at a minimum

— (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security. CameraView Photography and Video is addressing this mandate by flying SUAS that have visual indicators to aid in determining flight orientation and enhance visual line of sight capabilities. The key design features are bright white LEDs in front and bright red LEDs in the rear.**Operational Procedures**

CameraView Photography and Video wi ll abide by the following limitations, restrictions, and procedures when conducting its SUAS operations under an FAA issued exemption: 1. The SUAS will be less than 10 pounds. 2. Operations will only be conducted during daylight hours. 3. Flight operations will not occur within 5 miles of any public or private airport. 4. Flights will be operated within visual line of sight of a PIC. For safety the PIC must be focused on flying 100%. 5. Maximum total flight time for each operational flight will be 30 minutes. The flight controller used with our SUAS will maintain battery life calculation and alert the pilot to return to home (RTH) when 2 5% of battery life is remaining. 6. Flights will normally be operated at an altitude less than 400 feet AGL. The maxi mum airspeed will not be more than 5 5 mph. 7. Based on the service provided a flight area will be determined ahead of operations via ground survey. The flight area will contain the flight route and a risk assessment will be determined before proceeding wit h planning and operations. 8. All involved in the SUAS “services” transaction will agree to the flight area and restrictions. 9

. All flights that occur over private or controlled access property with the property owner’s prior consent and knowledge. Images taken will be of individuals who have also consented to being filmed or otherwise have agreed to be in the area where aerial photography will take place. 10 . Any unauthorized persons entering the flight area will require the PIC to abort the flight operat ion landing the SUAS using the RTH feature.

**Terms and Definitions** Flight Controller

– Used to aid the pilot in flying and steering the S UAS via software program executing on a microprocessor. This device also contains an Inertia Measuring Unit (IMU). IMU

– Accelerometer, Gyroscope, and Magnetometer Return to Home (RTH)

– This is a setting performed before flight using GPS to record the longitude and latitude of the start location. First Person View (FPV)

– Transmitted video from the SUAS giving a forward v iew of the UAS in real time either on a monitor. Visual Line of Sight

– The view of the UAS in clear plain sight of the operator while having 100% control.