Peter	Spero -	C:	+1	847.902.9590	-	Peter@AeroVistaInnovations.com

August	22,	2015	

U.	S.	Department	of	Transportation		

Docket	Management	System	

1200	New	Jersey	Ave.,	SE	

Washington,	DC	20590	

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

Aviation	Regulations	from	14	C.F.R.	45.23(b);	14	C.F.R.	Part	21;	14	C.F.R.	Part	61.113(a)	&	

(b);	91.7	(a);	91.9	(b)	(2);	91.103	(b);	91.109;	91.119;	91.121;	91.151	(a);	91.203	(a)	&	(b);	

91.405	(a);	91.407	(a)	(1);	91.409	(a)	(2);	91.417	(a)	&	(b).	

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,	AeroVista	Innovations,	operators of	Small	Unmanned	Aircraft	SYSTEMS	

(“sUASs”)	equipped	to	conduct	aerial	photography	and	cinematography	for	commercial	and	

residential	real	estate	and	closed---set	special	events,	hereby	applies	for	an	exemption	from	

the	listed	Federal	Aviation	Regulations (“FARs”)	to	allow	commercial	operation	of	its	sUASs,	

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

as	may	be	established	by	the	FAA	as	requires	by	Section	333.	

As	described	more	fully	below,	the	request	exemption	would	permit	the	operation	of	small,	

unmanned,	and	redundant	sUAS	under	controlled	conditions	in	airspace	that	is	1)	limited	2)	

predetermined	3)	controlled	as	to	access	and	4)	would	provide	safe	operations	and	

affordability	to	the	existing	real	estate	and	closed---set	special	event	industries	currently	

using	conventional	aircraft.	Approval	of	this	exemption	would	thereby	enhance	safety,	

promote	industry	growth	and	fair	competition	through	affordability	of	aerial	photography	

and	cinematography	and	fulfill	the	Secretary	of	Transportation’s	(the	FAA	Administrator’s)	

responsibilities	to	“...	establish	requirements	for	the	safe	operation	of	such	aircraft	systems	

in	the	national	airspace	system.”	Section	333	of	the	Reform	Act.	

The	name	and	address	of	the	applicant	is:	

AeroVista	Innovations,	LLC

Attn:	Peter	Spero (Licensed	Pilot	and	co-owner	of	AeroVista	Innovations,	LLC)

Ph:	847.902.9590

Email:	Peter@AeroVistaInnovations.com

Address:	1344	Sunnyside	Ave.,	Highland	Park,	IL	60035
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

Regulations	from	which	the	exemption	is	requested:

14	C.F.R.	Part	21

14	C.F.R.	45.23	(b)

14	C.F.R.	61.3

14	C.F.R.	91.7	(a)

14	C.F.R.	91.9	(b)	(2)

14	C.F.R.	91.103

14	C.F.R.	91.109

14	C.F.R.	91.119

14	C.F.R.	91.121

14	C.F.R.	91.151	(a)

14	C.F.R.	91.203	(a)	&	(b)

14	CFR	§	91.205(b)

14	CFR	§	91.215

14	C.F.R.	91.405	(a)

14	C.F.R.	407	(a)	(1)

14	C.F.R.	409	(a)	(2)

14	C.F.R.	417	(a)	&	(b)

This	exemption	application	is	expressly	submitted	to	fulfill	Congress’	goal	in	passing	Section

333(a)	through	(c)	of	the	Reform	Act.	This	law	directs	the	Secretary	of	Transportation	to

consider	whether	certain	unmanned	aircraft	systems	may	operate	safely	in	the	national	

airspace	system	(NAS)	before	completion	of	the	rule	making	required	under	Section	332	of	

the	Reform	Act.	In	making	this	determination,	the	Secretary	is	required	to	determine	which	

types	of	UASs	do	not	create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	

national	security	in	light	of	the	following:

•	The	UAS’s	size,	weight,	speed	and	operational capability;

•	Operation	of	the	UAS	in	close	proximity	to	airports	and	populated areas;	and

•	Operation	of	the	UAS	within	visual	line	of	sight	of	the	operator.

Reform	Act	§ 333	(a).	Lastly,	id	the	Secretary	determines that	such	vehicles	“may	operate	

safely	in	the	national	airspace	system,	the	Secretary	shall	establish	requirements	for	the	safe	

operation	of	such	aircraft	in	the	national	airspace	system.”	Id.	§333(c).

The	Federal	Aviation	Act	expressly	grants	the	FAA	the	authority	to	issue	exemptions.	This	

statutory	authority	by	its	terms	includes	exempting	civil	aircraft,	as	the	term	is	defined	

under	§40101	of	the	Act,	that	includes	sUASs,	from	the	requirement	that	all	civil	aircraft	

must	have	a	current	airworthiness	certificate.

The	Administrator	may	grant	an	exemption	from	a	requirement	of	a	regulation	prescribed	

under	subsection	(a)	or	(b)	of	 this	section	or	any	sections	44702 ---	44716	of	 this	 title	if	

the	Administrator	finds	the	exemption	in	the	public	interest.	49	U.S.C.	§44701(f)	See	also

49	USC	§44711(a);	49	USC	§44704;	14	CFR	§91.203	(a)	(1).

Flight	Vehicle:	
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

AeroVista	Innovations proposes	to	use	two	sUASs;	1)	DJI	Inspire	1 & 2)	3D	Robotics	Solo.	

Both	of	these	aircrafts	has	four	rotors	and	four	motors	in	a	quadcopter	configuration	(X4).	

Both	sUASs	weigh	less	than	55	lbs.	including	payload.	They	operate,	under	normal	conditions	

at	a	speed	of	no	more	than	50	knots	and	have	the	capability	to	hover,	and	move	in	the	vertical	

and	horizontal	plane	simultaneously.	Both	sUASs	are	equipped	with	GPS	and	auto---return	

function	to	the	predetermined	safe	landing	area	as	well	as	allowing	reading	of	magnetic	

interference	that	can	cause	loss	off	GPS	signal.	The	sUASs	will	operate	only	in	line	of	sight	and	

will	operate	only	within	a	sterile	closed---set	area	of	a	residential	or	commercial	listing	or	a	

closed---set	special	event.	Such	operations	will	insure	that	the	sUASs	will	“not	create	a hazard	

to	users	of	the	national	airspace	system	or	the	public.”	(Reform	Act	Section	333	(b)).

Given	the	small	size	of	the	sUASs	involved	and	the	restricted	sterile	environment	within	

which	they	will	operate,	the	applicant	falls	squarely	within	that	zone	of	safety	(an	equivalent	

level	of	safety)	in	which	Congress	envisioned	that	the	FAA	must,	by	exemption,	allow	

commercial	operations	of	UASs	to	commence	immediately.	Also due	to	the	size	of	the	UASs	

and	the	restricted	areas	in	which	the	relevant	sUASs	will	operate,	approval	of	the

application	presents	no	national	security	issue.	Given	the	clear	direction	in	Section	333	of	

the	Reform	Act,	the	authority	contained	in	the	Federal	Aviation	Act,	as	amended;	the	strong	

equivalent	level	of	safety	surrounding	the	proposed	operations,	and	the	significant	public	

benefit,	including	enhanced	safety,	reduction	in	environmental	impacts,	including	reduced	

emissions	associated	with	allowing	UASs	for	movie	and	television	operations,	the	grant	of	

the	requested	exemptions	is	in	the	public	interest.	Accordingly,	the	applicant	respectfully	

requests	that	the	FAA	grant	the	requested	exemption	without	delay.

AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY

AeroVista	Innovations proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	

that	have	the	characteristics	and	that	operate	with	the	limitations	listed	herein.	These	

limitations	provide	for	at	least	an	equivalent	or	even	higher	level	of	safety	to	operations	

under	the	current	regulatory	structure	because	the	proposed	operations represent	a	safety	

enhancement	to	the	already	safe	aerial	photography	and	cinematography	filming	operations	

conducted	with	conventional	aircraft.

These	limitations	and	conditions	to	which	AeroVista	Innovations agrees	to	be	bound	

when	conducting	commercial	operations	under	an	FAA	issued	exemption	include:

ØØ The	sUAS	will	weigh	less	than	55	lbs.

ØØ Flights	will	be	operated	within	line	of	sight	of	a	pilot	and/or	observer.

ØØ Maximum	total	flight	time	for	each	operational	flight	will	be	30	minutes	or	less.

ØØ Flights	will	be	terminated	at	25%	battery	power	reserve	should	that	occur	prior	to	

the	30	minute	limit.

ØØ Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL	or,	not	more	than

200	feet	above	an	elevated	platform	for	which	filming	is	planned.

ØØ Minimum	crew	for	each	operation	will	consist	of	the	sUAS	Pilot,	the	Visual	Observer,	

and	the	Camera	Operator.

ØØ sUAS	Pilot	will	also	meet	the	flight	review	requirements	specified	in	14	C.F.R	61.56	in	

an	aircraft	in	which	the	Pilot	is	rated	on	his	or	her	pilot	certificate.
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

ØØ The	sUAS	will	only	operate	within	a	confined	sterile	closed---set	area	with	a	set	

safety	perimeter,	the	boundaries	of	which	will	be	determined	by	production	

personnel	and	the	sUAS	PIC	based	on	the	site---specific	filming	activities	and	speed	

of	the	sUAS	required	for	the	operation,	and	coordinated	with	the	jurisdictional	FAA	

FSDO	and	local	government	officials	as	applicable.

ØØ A	briefing	will	be	conducted	in	regards	to	the	planned	sUAS	operations	prior	to	each	

day’s	production	activities.	It	will	be	mandatory	that	all	personnel	who	will	be	

performing	duties	within	the	boundaries	of	the	safety	perimeter	be	present	for	this	

briefing.

ØØ The	sUAS	Pilot	and/or	Aerial	Coordinator	will	ensure	this	safety	perimeter	that	only	

consenting	production	personnel	will	be	allowed	within	100	feet	of	the	sUAS	

operation	by	not	permitting	anyone	who	had	not	been	briefed	or	whom	is	not	

involved	in	production	to	be	in	the	closed---set	area.

ØØ Observer	and	PIC	will	at	all	times	be	able	to	communicate	by	voice	and/or	two	way	

radio	communication	system.

ØØ Written	and/or	oral	permission	from	the	relevant	property	holders	will	be	obtained.

ØØ If	applicable,	all	required	permissions	and	permits	will	be	obtained	from	territorial,	

state,	county	or	city	jurisdictions,	including	local	law	enforcements,	fire,	or	other	

appropriate	governmental	agencies.

ØØ If	the	sUAS	loses	communications	or	loses	its	GPS	signal,	the	sUAS	will	have	the	

capability	to	return	to	a	pre---determined	location	within	the	Security	Perimeter	

and	land	safely.

ØØ The	sUAS	will	have	the	capability	to	abort	flight	in	case	of	unpredicted	obstacles	or	

emergencies.

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§91.203	(a)	(1)	

Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedural	requirements	for	

the	issuance	of	airworthiness	certificates	as	required	by	FAR	§91.203	(a)	(1).	Given	the	size	

and	limited	operating	area	associated	with	the	aircraft	to	be	utilized	by	the	Applicant,	an	

exemption	from	Part	21	Subpart	H	meets	the	requirements	of	an	equivalent	level	of	safety	

under	Part	11	and	Section	333	of	the	Reform	Act. The	Federal	Aviation	Act	(49	U.S.C.§44701	

(f))	and	Section	333	of	the	Reform	Act	both	authorize	the	FAA	to	exempt	aircraft	from	the	

requirement	for	an	airworthiness	certificate,	upon	consideration	of	the	size,	weight,	speed,	

operational	capability,	and	proximity	to	airports	and	populated	areas	of	the	particular	UAS.	

In	all	cases,	an	analysis	of	these	criteria	demonstrates	that	the	UAS	operated	without	an	

airworthiness	certificate,	in	the	restricted	environment	and	under	the	conditions	proposed	

will	be	at	least	as	safe,	or	safer,	than	a	conventional	aircraft	(fixed	wing	or	rotorcraft)	

operating	with	an	airworthiness	certificate	without	the	restrictions	and	conditions	

proposed.

14	C.F.R.	§	45.23	(b).	Marking	of	the	Aircraft

The	regulation	requires:

When	marks	include	only	the	Roman	capital	letter	"N"	and	the	registration	number	is	

displayed	on	limited,	restricted	or	light---sport	category	aircraft	or	experimental	or	

provisionally	certificated	aircraft,	the	operator	must	also	display	on	that	aircraft	near	each	

entrance	to	the	cabin,	cockpit,	or	pilot	station,	in	letters	not	less	than	2	inches	nor	more	than
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

6	inches	high,	the	words	"limited,"	"restricted,"	"light---sport,"	"experimental,"	or

"provisional,"	as	applicable.

Even	though	the	sUAS	will	have	no	airworthiness	certificate,	an	exemption	may	be	needed

as	the	sUAS	will	have	no	entrance	to	the	cabin,	cockpit	or	pilot	station	on	which	the	word	

“experimental”	can	be	placed.	Given	the	size	of	the	sUAS,	two	inch	lettering	will	be	

impossible.	The	word	“Experimental”	will	be	placed	on	the	fuselage	in	compliance	with

§45.29	(f).

The	equivalent	level	of	safety	will	be	provided	by	having	the	sUAS	marked	on	its	fuselage	as	

required	by	§45.92	(f)	where	the	pilot,	observer	and	others	working	with	the	sUAS	will	see	

the	identification	of	the	sUAS	as	“Experimental”.	The	FAA	has	issued	the	following	

exemptions	to	this	regulation	to	Exemptions	Nos.	10700,	8738,	10167	and	10167A.

14	C.F.R.	§91.7(a):	Civil	aircraft	airworthiness.

The	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	airworthy	

condition. As	there	will	be	no	airworthiness	certificate	issued	for	the	aircraft,	should	this	

exemption	be	granted,	no	FAA	regulatory	standard	will	exist	for	determining	airworthiness.	

Given	the	size	of	the	aircraft	and	the	requirements	contained	in	the	Manual	for	maintenance	

and	use	of	safety	check	lists	prior	to	each	flight,	as	set	forth	in	Sections	J,	L	and	Q,	an	

equivalent	level	of	safety	will	be	provided.

14	C.F.R.	§	91.9	(b)	(2):	Civil	Aircraft	Flight	Manual	in	the	Aircraft.

Section	91.9	(b)	(2)	provides:

No	person	may	operate	a	U.S.---registered	civil	aircraft	...

The	sUAS,	given	its	size	and	configuration	has	no	ability	or	place	to	carry	such	a	flight	

manual	on	the	aircraft,	not	only	because	there	is	no	pilot	on	board,	but	because	there	is	no	

room	or	capacity	to	carry	such	an	item	on	the	aircraft. The	equivalent	level	of	safety	will	be	

maintained	by	keeping	the	flight	manual	at	the	ground	control	point	where	the	pilot	flying	

the	sUAS	will	have	immediate	access	to	it.The	FAA	has	issued	the	following	exemptions	to	

this	regulation:	Exemption	Nos.	8607,	8737,	8738,	9299,	9299A,	9565,	9565B,	10167,

10167A,	10602,	32827,	and	10700.

(2)	For	which	an	Airplane	or	Rotorcraft	Flight	Manual	is	not	required	by	§21.5	of	this

chapter,	unless	there	is	available	in	the	aircraft	a	current	approved	airplane	or	Rotorcraft	

Flight	Manual,	approved	manual	material,	markings,	and	placards,	or	any	combination	

thereof.

14	C.F.R.	§	91.103:	Preflight	action

This	regulation	requires	each	pilot	in	command	to	take	certain	actions	before	flight	to	insure

the	safety	of	flight.As	FAA	approved	rotorcraft	flight	manuals	will	not	be	provided	for	the	

aircraft	an	exemption	will	be	needed.	An	equivalent	level	of	safety	will	be	set	forth	by	the	

pre---flight	checklist	as	set	forth	in	the	Flight	Operations	Manual.The	PIC	will	take	all	

actions	including	reviewing	weather,	flight	battery	requirements,	landing	and	takeoff	

distances,

aircraft	performance	data	and	setting	the	pre---determined	safe	landing	area	in	case	of	loss	of

GPS	communication	before	initiation	of	flight.

14	C.F.R.	§91.109:	Flight	instruction:

Section	91.103	provides	that	no	person	may	operate	a	civil	aircraft	(except	a	manned	free	

balloon)	that	is	being	used	for	flight	instruction	unless	that	aircraft	has	fully	functioning
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

dual	controls.	sUASs	and	remotely	piloted	aircraft,	by	their	design	do	not	have	fully	

functional	dual	controls.	Flight	control	is	accomplished	through	the	use	of	a	control	box	that	

communicates	with	the	aircraft	via	radio	communications. The	FAA	has	approved	

exemptions	for	flight	training	without	fully	functional	dual	controls	for	a	number	of	aircraft	

and	for	flight	instruction	in	experimental	aircraft.	See	Exemption	Nos.5778K	&	9862A.The	

equivalent	level	of	safety	provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be	

carried	in the	aircraft	and	by	the	size	and	speed	of	the	aircraft.

14	C.F.R.	§91.119:	Minimum	safe	altitudes

Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft. Section	91.119	(d)

allows	helicopters	to	be	operated	at	less	than	the	minimums	prescribed,	provided	the	person	

operating	the	helicopter	complies	with	any	route	or	altitudes	prescribed	for	helicopters	by	

the	FAA.As	this	exemption	is	for	a	sUAS	that	is	a	helicopter	and	the	exemption	requests	

authority	to	operate	at	altitudes	up	to	400	AGL,	or	not	more	than	200	above	an	elevated	

platform	from	which	filming	is	planned,	an	exemption	may	be	needed	to	allow	such	

operations. The	sUAS	will	never	operate	at	higher	than	400	AGL.	It	will	however	be	operated	

in	a	restricted	area	with	security	perimeter,	where	buildings	and	people	will	not	be	exposed	

to	operations	without	their	pre---obtained	consent.

The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	speed	of	the	UAS	as	

well	as	the	location	where	it	is	operated.	No	flight	will	be	taken	without	the	permission	of	

the	property	owner	or	local	officials.	Because	of	the	advance	notice	to	the	property	owner	

and	participants	in	the	filming	activity,	all	affected	individuals	will	be	aware	of	the	planned	

flight	operations.	Compared	to	flight	operations	with	aircraft	or	rotorcraft	weighting	far	

more	than	the	maximum	55lbs.	proposed	herein	and	the	lack	of	flammable	fuel,	any	risk	

associated	with	these	operations	is far	less	than	those	presently	presented	with	

conventional	aircraft	operating	at	or	below	500	AGL	in	aerial	photography	and	

cinematography	industry.	In	addition,	the	low---	altitude	operations	of	the	sUAS	will	

ensure	separation	between	these	sUAS	operations	and	the	operations	of	conventional	

aircraft	that	must	comply	with	Section	91.119.

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	sUAS	may	not	have	a	

barometric	altimeter,	but	instead	a	GPS	altitude	read	out,	an	exemption	may	be	needed.	An	

equivalent	level	of	safety	will	be	achieved	by	the	operator,	pursuant	to	the	Pre	Flight	Check	

list,	confirming	the	altitude	of	the	launch	site	shown	on	the	GPS	altitude	indicator	before	

flight.

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	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.”
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

The	battery	powering	the	sUAS	provides	approximately	40	minutes	of	powered	flight.	To	

meet	the	30	minute	reserve	requirement	in	14	CFR	§91.151,	sUAS	flights	would	be	limited	

to	approximately	10	minutes	in	length.	Given	the	limitations	on	the	UAS’s	proposed	flight	

area	and	the	location	of	its	proposed	operations	within	a	predetermined	area,	a	longer	time	

frame	for	flight	in	daylight	or	night	VFR	conditions	is	reasonable.

AeroVista	Innovations believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	

scope	of	prior	exemptions.	See	Exemption	10673	(allowing	Lockheed	Martin	Corporation	to	

operate	without	compliance	with	FAR	91.151	(a)).	Operating	the	small	UAS,	in	a	tightly	

controlled	area	where	only	people	and	property	owners	or	official	representatives	who

have	signed	waivers	will	be	allowed,	with	less	than	30	minutes	of	reserve	fuel,	does	not	

engender	the	type	of	risks	that	Section	91.151(a)	was	intended	to	alleviate	given	the	size	

and	speed	of	the	small	UAS.	Additionally,	limiting	sUAS	flights	to	10	minutes	would	greatly	

reduce	the	utility	for	which	the	exemption	will	be	granted.

Applicant	believes	that	an	equivalent	level	of	safety	can	be	achieved	by	limiting	flights	to	30	

minutes	or	25%	of	battery	power	whichever	happens	first.	This	restriction	would	be	more	

than	adequate	to	return	the	sUAS	to	its	planned	landing	zone	from	anywhere	in	its	limited	

operating	area.

Similar	exemptions	have	been	granted	to	other	operations,	including	Exemptions	2689F,

5745,	10673,	and	10808.

14	C.F.R.	§91.203	(a)	and	(b):	Carrying	Civil	Aircraft	Certification	and	Registration

The	regulation	provides	in	pertinent	part:

(a)	Except	as	provided	in	§	91.715,	no person	may	operate	a	civil	aircraft	unless	it	has

within	it	the	following:

(1)	An	appropriate	and	current	airworthiness	certificate.	.	.	.

(b)	No	person	may	operate	a	civil	aircraft	unless	the	airworthiness	certificate	required	by	

paragraph	(a)	of	this	section	or	a	special	flight	authorization	issued	under	§91.715	is	

displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or	crew.

The	UAS	fully	loaded	weighs	no	more	than	55	lbs	and	is	operated	without	an	onboard	pilot.

As	such,	there is	no	ability	or	place	to	carry	certification	and	registration	documents	or	to	

display	them	on	the	sUAS.

An	equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the	ground	

control	point	where	the	pilot	flying	the	sUAS	will	have	immediate	access	to	them,	to	the	

extent	they	are	applicable	to	the	sUAS.The	FAA	has	issued	numerous	exemptions	to	this	

regulation.	A	representative	sample	of	other	exceptions	includes	Exemption	Nos.	9565,

9665,	9789,	9789A,	9797,	9797A,	9816A,	and	10700.

14	C.F.R.	§91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b):	Maintenance	Inspections	

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	these	section	and	Part	43	apply	only to	aircraft	with	an	

airworthiness certificate,	these	sections	will	not	apply	to	the	applicant.	Maintenance	will	be	

accomplished	by	the	operator	pursuant	to	the	flight	manual	and	operating	handbook.	An
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

equivalent	level	of	safety	will	be	achieved	because these	small	UASs	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	

initiating	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.

Pursuant	to	14	C.F.R.	Part	11,	the	following	summary	is	provided	for	publication	in	the

Federal	Register,	should	it	be	determined	that	publication	is	needed:

Applicant	seeks	an	exemption	from	the	following	rules:

14	C.F.R.	§21,	subpart	H;	14	C.F.R	45.23(b);14	C.F.R.	§§	61.113(	a)	&	(b);91.7	(a);	91.9	(b)	

(2);91.103(b);91.109; 91.119;	91.121;	91.151(a);91.203(a)	and	(b);	91.405	(a);	91.407	(a)	

(1);	91.409	(a)	(2);	91.409	(a)	(2) and	91.417	(a)	&	(b)	to	operate	commercially	a	small	

unmanned	vehicle	(55lbs	or	less)	in	aerial	photography	and	cinematography	for	residential	

and	commercial	real	estate	and	closed---set	special	events.

Approval	of	exemptions	allowing	commercial	operations	of	sUASs	for	aerial	photography	

and	cinematography	for	real	estate	and	close---set	special	events	will	enhance	safety	by	

reducing	risk.	Conventional	real	estate	aerial	photography	and	cinematography	use	jet	or	

piston	powered	aircraft	which	carry	large	amounts	of	combustible	fuel	posing	increased	

risk.	Conversely,	sUASs	carry	no	combustible	fuel,	weigh	only	55	lbs.	or	less	comparatively	

to	3,000+	lbs.	of	a	conventional	aircraft,	are	much	more	easily	maneuverable	and	do	not

ferry	to	and	from	the	production location.	Additionally,	flying	at	or	below	400	AGL	sUAS	will

be	no	factor	with	fixed	wing	and	rotor	wing	aircraft.

The	operation	of	small	UASs,	weighting	less	than	55	lbs.,	conducted	in	the	strict	conditions	

outlined	above,	will	provide	an	equivalent	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.	These	lightweight	aircraft	operate	at	slow	

speeds,	close	to	the	ground,	and	in	a	sterile	environment	and,	as	a	result,	are	far	safer	than	

conventional	operations	conducted	with	traditional	aircraft	which	pose	a	safety	risk. There	

are	no	personnel	on	board	the	sUASs	and	therefore	the	likelihood	of	death	or	serious	bodily	

injury	is	significantly	diminished.	All	flights	will	occur	over	private	or	controlled	access	

property	with	the	property	owner’s	prior	consent	and	knowledge.	Filming	will	be	of	people	

who	have	also	consented	to	being	filmed	or	otherwise	have	agreed	to	be	in	the	area	where	

filming	will	take	place.	AeroVista	Innovations will	provide	an	equivalent	or	better	level	of	

safety	as	that	achieved	under	the	current	FAR’s. All	Aerovista	sUAV	operators	are	

licensed	pilots.
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

AeroVista	Innovations respectfully	request	that	the	FAA	grants the	exemption	request.	

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	of	2012------size,	

weight,	speed,	operating	capabilities,	proximity	to	airports	and	populated	areas	and	

operation	within	visual	line	of	sight	and national	security	– provide	more	than	adequate	

justification	for	the	grant	of	the	requested	exemptions	allowing	commercial	operation	of	

applicant’s	UAS	in	aerial	photography	and	cinematography	for	the	real	estate	industry	and	

close---set	special	events	pursuant	to	the	Manuals	appended	hereto.

Sincerely,

Peter	Spero

AeroVista	Innovations,	LLC.
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

Appendix 

FAR section Subject Justification

14 CFR § 

45.23(b)

Requirement to display registration

number on vehicle Insufficient space on vehicle

14 CFR Part 21 Aircraft certification requirements and 

procedures

Designed for manned aircraft; not suitable for off----

the----shelf sUAS

14 CFR § 61.3 Requirement for pilot certificate

Part 61 requirements designed for manned aircraft,

not sUAS; petition describes training for sUAS oper

ator

14 CFR § 91.7 

(a) Airworthiness requirement

Designed for manned aircraft; not suitable for off----

the----shelf sUAS

14 CFR § 91.9 

(b) (2) 

Requirement for manual to be

available in the cockpit No one aboard to read manual

14 CFR § 

91.103(b)

Requirement for crew members to be

onboard Unmanned vehicle

14 CFR § 

91.109

Requirement for dual controls during

flight instruction

No one aboard to operate controls

14 CFR § 

91.119 Minimum altitudes for safe flight Safety requires operation below these altitudes

14 CFR § 

91.121 Altimeter settings No one aboard to read altimeter

14 CFR § 

91.151(a) Fuel requirements Vehicle does not use fuel

14 CFR § 

91.203 (a) & (b)

Requirement for registration and

airworthiness certificates to be on

board

No one aboard to read certificates

14 CFR § 

91.205(b) Cockpit instruments No one aboard to read

Requirement Instruments

14 CFR § 91.215 Transponder requirement

Vehicle has insufficient useful load; will be operated

below ATC radar coverage

14 CFR § 91.405 (a) Inspection requirements

Designed for manned aircraft; not suitable for off----the----

shelf sUAS

14 CFR § 91.407(a)

(1) 

Inspection approval

requirements 

Designed for manned aircraft; not suitable for off----the----

shelf sUAS

14 CFR § 91.409 (a)

(2) Airworthiness inspection

Designed for manned aircraft; not suitable for off----the----

shelf sUAS

14 CFR § 91.417 (a) Maintenance records Designed for manned aircraft; not suitable for off----the----
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

& (b) requirements shelf sUAS

DJI INSPIRE SPECS

Aircraft

Model

T600

Weight (Battery Included)

2935 g

Hovering Accuracy (GPS Mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s 

Yaw: 150°/s 

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time 

Approximately 18 minutes 

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range

-10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

Gimbal

Model

ZENMUSE X3

Output Power (With Camera)

Static: 9 W

In Motion: 11 W

Operating Current
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

Station: 750 mA 

Motion: 900 mA

Angular Vibration Range

±0.03° 

Mounting 

Detachable

Controllable Range 

Pitch: -90° to +30° 

Pan: ±320°

Mechanical Range 

Pitch: -125° to +45° 

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera

Name

X3

Model

FC350

Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size

4000x3000

ISO Range

100-3200 (video)

100-1600 (photo)

Electronic Shutter Speed

8s - 1/8000s

FOV (Field Of View)

94°

CMOS

Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti-distortion

Still Photography Modes

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

Time-lapse

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage

60 Mbps

Supported File Formats
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

FAT32/exFAT 

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required.

Operating Temperature Range

0° to 40° C

Remote Controller

Name

C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (Outdoor And Unobstructed)

2 km

EIRP

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port 

USB, mini-HDMI 

Power Supply

Built-in battery

Charging

DJI charger

Dual User Capability

Host-and-Slave connection

Mobile Device Holder

Tablet or Phone

Max Mobile Device Width

170mm

Output Power

9 W

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C 

More than 3 months: 22° to 28° C 

Charging Temperature Range

0-40° C

Battery

6000 mAh LiPo 2S

Charger

Model

A14-100P1A

Voltage

26.3 V

Rated Power

100 W
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

Battery (Standard)

Name

Intelligent Flight Battery

Model

TB47

Capacity

4500 mAh

Voltage

22.2 V

Battery Type

LiPo 6S High voltage battery

Energy

99.9 Wh

Net Weight

570 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C 

More than 3 months: 22° C to 28° C 

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Battery (Optional)

Name

Intelligent Flight Battery

Model

TB48

Capacity

5700 mAh

Voltage

22.8 V 

Battery Type 

LiPo 6S

Energy

129.96 Wh

Net Weight

670 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20 to 45° C 

More than 3 months: 22° to 28° C 

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Vision Positioning

Velocity Range

Below 8 m/s (2 m above ground)
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

Altitude Range

5-500 cm

Operating Environment

Brightly lit (lux > 15) patterned surfaces

Operating Range

0-250 cm

3D	Robotics	Solo	Specs

Aircraft

Weight (Including Battery, Propellers, and Gimbal)

1800 g

Diagonal Size (Including Propellers)

580 mm

Max Ascent Speed

5 m/s

Max Descent Speed

5 m/s

Max Speed

55 mph (ATTI mode, no wind)

Max Payload

420g

Flight Mode 

GPS

Auto Pilot

Pixhawk2

Operating Temperature

0°C to 40°C GPS

Camera Type

GoPro Hero 4 Black

 Sensor

Optical Sensor - CMOS

Lens

Ultra Wide FOV

ISO Range

100-6400 (video) 100-800 (photo)

Shutter Speed

Video: Shutter Speed - Max:1/fps Min:1/8192

Photo: Shutter Speed – Max:0.5 sec. Min. 1/8192
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

Video Recording Modes

				4K 30/25/24 fps, Ultra Wide FOV

				2.7K 50/48/30/25/24 fps Ultra Wide, Medium FOV

 1410p 80, 60, 50, 48, 30, 25, 24 fps Ultra Wide FOV

1080p 120, 90, 60, 50, 48, 30, 25, 24 fps

 Ultra Wide, Medium (excludes 120 and 90 fps), Narrow FOV

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required

Max Bitrate Of Video Storage

60 Mbps

Supported File Formats

					AT32/exFAT

			 Photo: JPEG, DNG

			 Video: MP4, MOV (MPEG-4 AVC/H.264)

 

 Software

 APM:Copter

Operating Temperature

0°C to 40°C

Gimbal

Controllable Range 

Pitch -0° to -90° 

Stabilization

3-axis (pitch, roll, yaw)

Remote Controller Operating Frequency

2.400 GHz

Max Distance

.5 miles

Video Output Port

HDMI

Operating Temperature

0°C to 40°C
Peter	Spero	– Cell:847.902.9590	– Peter@AeroVistaInnovations.com

Controller Battery

2600 mAh 7.2 Vdc 

lithium ion

Mobile Device Holder 

For tablet or phone

Communication: 

3DR Link secure WiFi network

Intelligent Flight Battery Capacity

5200 mAh

Voltage

14.8 V Battery

Type Lithium 

Polymer

Max Flight Time 

Approximately 25 minutes 

Operating Temperature

-10°C to 40°C

Max Charging Power

100 W App / Live View

Mobile App

3DR Solo App

Live View

Solo Secure WiFi Network – Tablet of SmartPhone

Live View Quality

720P @ 30fps (depending on conditions and mobile device)

 Latency - 180ms (depending on conditions)