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

Washington, 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, 

CameraView 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 video 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 clients 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 operations of the services. 

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

We have 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. REGULATIONS - REQUEST SPECIFIC EXEMPTION.

14 C.F.R. Part 21, Subpart H: Airworthiness 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 the extent of not requiring a 

traditional airworthiness certificate for the operation 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 are 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. While 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 will be safely operated in an approved environment, 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 §45.27.

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. However 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 the 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 marks, 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 marks, marks as large as practicable must 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

DEWIZ 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 inches 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. An approximate sixe estimate 

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 requiring 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 

passengers or any cargo heavier than 120 grams (in additions to the Solo gimbal and 

camera).

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. 

CameraView 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 lower startup/operating costs 

than traditional rotorcraft services. 

14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action

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. 

13. Check throttle is set to idle.

14. 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. While idling, check and listen for abnormal 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 Altitudes

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 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.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation 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 or 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 regulations 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 500 feet above the surface. CameraView 

Photography and Video will fly all of our SUAS at 400 feet or below AGL. 

Any flight route 400 feet above 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 also 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: Altimeter 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 

flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet 
and 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 SUAS

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” automatically.

The flight controller also provides the PIC altitude information. These features 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 for 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 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.

CameraView Photography and Video request exemption from 14 CFR 91.151 (a) and 

(b) to the extent of not following 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 publication 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 structures 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, including 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. Using 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 will 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 25% of battery life is remaining.

6. Flights will normally be operated at an altitude less than 400 feet AGL. The maximum 

airspeed will not be more than 55 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 with 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 operation landing the SUAS using the RTH feature.

Terms and Definitions

Flight Controller – Used to aid the pilot in flying and steering the SUAS 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 view 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.