UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

AERIAL VIDEO SYSTEMS

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE

WALKERA TALI H500 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on September 8, 2015

Joseph R Pascal Jr.

DBA: Aerial Video Systems

921 West Lakeshore Dr.

Carriere, MS 39426

601-347-8222

joe.pascal@yahoo.com
2

TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS .................................................................................3

SUMMARY.........................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER..................................................4

BACKGROUND .................................................................................................................4

BASIS FOR PETITION.......................................................................................................5

NAME AND ADDRESS OF PETITIONER.................................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH AVS SEEKS

EXEMPTION.................................................................................................................8

THE EXTENT OF RELIEF AVS SEEKS AND THE REASON AVS. SEEKS THE 

RELIEF ........................................................................................................................11

THE REASONS WHY GRANTING AVS'S REQUEST WOULD BE IN THE

PUBLIC INTEREST....................................................................................................14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY..............................................................................17

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........37

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE

TO SUPPORT AVS'S REQUEST...............................................................................38

CONCLUSION.................................................................................................................38
3

GLOSSARY OF ABBREVIATIONS

 AVS Aerial Video Systems

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

C.F.R. Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing
4

SUMMARY

Aerial Video Systems seeks exemption from the requirements of 14 C.F.R §§ 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b),

to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and

Reform Act of 2012 (FMRA). This exemption will permit Aerial Video Systems to operate an

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial

video/filmmaking, photography, aerial inspections (energy/utilities) and acquisitions over

certain areas of the United States and Gulf of Mexico

INTRODUCTION AND INTERESTS OF THE PETITIONER

Aerial Video Systems, (hereinafter referred to as “AVS”) is an unmanned aircraft systems

provider that integrates engineering and manufacturing of UAS with video and photography

services that enable the technology for federal, state, local, and commercial clients. AVS is 

focused on providing solutions for utilizing unmanned aircraft to safely and efficiently Film, 

Video and capture data that is precise, accurate, and timely.

AVS’s mission is to use unmanned aircraft to simplify and increase the effectiveness of

Filmmaking, Photography and data collection in: Controlled Movie Making Sets, Areas of 

Natural Disasters (with proper approval), Natural Resources (on shore/off shore) Conservation, 

Construction and Infrastructure, Precision Agriculture, as well as Inspection and Monitoring.

As set forth in this Petition, AVS seeks to commercially operate its 

Walkera Tali H500 6-Bladed UAS. As stated in the mission above.

BACKGROUND

Unmanned Aircraft System: Walkera Tali H500 UAS

AVS seeks an exemption to operate the Walkera Tali H500 UAS for compensation or

hire within the National Airspace System (“NAS”). The Tali H500 UAS is comprised of a
5

vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) and a transportable Ground

Control Station (GCS). The Tali H500 UA has a maximum gross weight of approximately

5 pounds, while having a diameter of 24 inches, rotor span of 36 inches, and maximum speed

of 15 mph. The Tali H500 UA is equipped with six propellers, each being driven by a Lithium

Polymer battery powered electric motor.

The Tali H500 UA that will be operated by AVS will be registered in accordance with 

49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration,

and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Markings.

 Figure 1: The Walkera Tali H500 UA.

 BASIS FOR PETITION

Petitioner, Aerial Video Systems, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform
6

Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby

petitions the Administrator to operate the Tali H500UAS in the NAS, and for an exemption

from the requirements of 14 C.F.R §§ 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the size, weight, speed, and limited operating area associated with the

unmanned aircraft and its operation, AVS’s operation of the Tali H500 UAS meets the

conditions of Section 333 and therefore, will not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, AVS requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only

apply to aircraft with an airworthiness certificate.

AVS submits that the requested relief is proper since an equivalent level of safety will be

ensured. AVS, as manufacturer of the Tali H500 UAS, will use its technicians to perform

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques,

and practices prescribed in the manufacturer’s maintenance manual. Furthermore, AVS will 

document and maintain all maintenance records for the Tali H500 UAS.
7

AVS seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

Tali H500 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part

21, Subpart H. As such, AVS submits that it will ensure that the Tali H500 UAS is in an

airworthy condition, prior to every flight, by determining that the UAS is in compliance with

the Tali H500 UAS Operator Manual, the Walkera Family of Systems Operations Manual, and

the Tali H500Maintenance Manual, and that the UA is in condition for safe flight.

AVS also seeks an exemption from the requirements of Section 91.121, entitled

Altimeter Settings, as the Tali H500 UAS is equipped with a barometer and Global Positioning

System (GPS) equipment, which ensures that a ground level pressure setting will be established

prior to each flight. The Tali H500 UA’s barometer and GPS equipment ensure safety by

providing the PIC with adequate information concerning altitude of the UA, above ground level

(AGL), as shown on the heads-up display of the GCS.

Additionally, AVS seeks an exemption from the requirements of Section 91.151(b), Fuel

requirements for flight in VFR conditions. AVS submits that safety will not be affected by

terminating flights of the battery powered Tali H500 UA after 20 minutes of continuous flight,

which would allow for five minutes (i.e, 20 percent) of battery power remaining.

In accordance with 14 C.F.R. § 11.81, AVS provides the following information in

support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner is:

Joseph R Pascal, Jr.(dba) Aerial Video Systems

921 West Lakeshore Dr.

Carriere, MS 39426 

The point of contact for this Petition and specific contact information is as follows:
8

Joseph R. Pascal Jr.

921 West Lakeshore Dr.

Carriere, Mississippi 39426

Tel: (601) 347-8222 | 

Email: joe.pascal@yahoo.com

B. The Specific Sections Of 14 C.F.R. From Which AVS Seeks Exemption.

1. AVS Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

2. AVS Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in relevant

part:

(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;
9

(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;

3. AVS Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b),

states the following:

(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.

4. AVS Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) 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[.]

5. AVS Seeks Exemption From The Requirements Of Section 91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 of this

chapter[.]

6. AVS Seeks Exemption From The Requirements Of Sections 91.409(a)(1)

And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:
10

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft

unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been

approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part

21 of this chapter.

7. AVS Seeks Exemption From The Requirements Of Sections 91.417(a)

And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered

owner or operator shall keep the following records for the periods specified in paragraph

(b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the

100-hour, annual, progressive, and other required or approved inspections, as appropriate,

for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance

of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the work

performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return

to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required

to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last

inspection required by the inspection program under which the aircraft and its appliances

are maintained.
11

(v) The current status of applicable airworthiness directives (AD) and safety directives

including, for each, the method of compliance, the AD or safety directive number and

revision date. If the AD or safety directive involves recurring action, the time and date

when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration

to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the

work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this

chapter shall be retained until the defects are repaired and the aircraft is approved

for return to service.

C. The Extent Of Relief AVS Seeks And The Reason AVS Seeks The Relief.

1. Extent of Relief AVS Seeks And The Reason AVS Seeks Relief From 

Section 91.7(a).

AVS seeks the requested relief because the Tali H500 UAS does not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, AVS will 

ensure that the Tali H500 UAS is in an airworthy condition based upon its compliance with the

operating documents prior to every flight, and as stated in the conditions and limitations below.
12

2. Extent of Relief AVS Seeks And The Reason AVS Seeks Relief From

Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight

operations of the Tali H500 UAS, which utilizes a barometer and GPS equipment, to ensure that 

a ground level pressure setting will be established prior to each flight, in order to report altitude 

to the PIC. AVS seeks the requested relief because the Tali H500 UAS does not utilize a typical

barometric altimeter onboard that may be set as contemplated by Section 91.121. As more fully

set forth below, an equivalent level of safety will be maintained since the Tali H500 UAS is 

equipped with a barometer and GPS equipment, which will ensure that a ground level pressure 

setting will be established prior to each flight, and provides the PIC with altitude information of

the UA, above ground level (AGL), on the heads-up display of the ground control station (GCS).

3. Extent Of Relief AVS Seeks And The Reason AVS Seeks Relief From

Section 91.151(b).

Relief from Section 91.151(b), entitled Fuel Requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered Tali H500 UA, during

daylight hours in visual meteorological conditions under visual flight rules (VFR), to continue

for a total duration of 20 minutes, which will ensure that the UA will land with five minutes (i.e.,

20 percent) of battery power remaining. AVS seeks the requested relief, because without an

exemption from Section 91.151(b), the flight time duration of the battery powered Tali H500

UA will severely constrain the practicality of any aerial acquisition and research flight operations

which AVS proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the Tali H500 UAS, and

AVS’s proposed operating limitations, ensure that AVS
13

will safely operate the battery powered Tali H500 UA during daylight hours in VFR conditions

for a total flight duration of 15 minutes, landing with five minutes of battery power remaining.

4. Extent Of Relief AVS Seeks And The Reason AVS Seeks Relief From

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only

apply to aircraft with an airworthiness certificate, AVS requests relief from these Sections

because the Tali H500 UAS does not require an airworthiness certificate. As set forth more

fully below, the Tali H500 UAS meets the conditions of Section 333 of the FMRA for

operation without an airworthiness certificate. Accordingly, AVS, which manufactures the

Tali H500 UAS, will use AVS technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the

manufacturer’s maintenance manual. Furthermore, AVS will document and maintain all

maintenance records for the Tali H500 UAS.

D. The Reasons Why Granting AVS’s Request Would Be In The Public

Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing AVS to safely,

efficiently, and economically perform aerial acquisitions and research over rural areas of the

United States, commercially, in support of government entities, agriculture, scientific studies,

wildlife monitoring, forestry operations, and the oil and gas industries. Additionally, use of the

Tali H500 UAS will decrease congestion of the NAS, reduce pollution, and provide significant

benefits to the economy. Notably, the benefits of AVS’s proposed operation of the Tali H500

UAS will be realized without implicating any privacy issues.
14

1. The Public Will Benefit From The Aerial Acquisition And Research

Performed.

AVS submits this Petition to commercially operate the Tali H500 UAS and perform

aerial acquisition and research throughout rural areas of the United States, in support of

government entities, agriculture, scientific studies, wildlife monitoring, forestry operations,

mining, and the oil and gas industries. The Tali H500 UAS will provide safe, efficient, and

economical aerial acquisition and research operations to further each of these fields, all of which

are critical to the well-being of the general public.

The specific operations that AVS will perform with the Tali H500 UAS demonstrate how

the requested exemption will directly benefit the above-referenced industries and the public. In

agriculture, the aerial acquisition performed by the Tali H500 UAS will be used to predict and

increase crop yields. In the oil and gas industry, the Tali H500 UAS will be used to aid in 

facility inspections, survey and plan new worksites, conduct volumetric analysis, and perform

right of way analysis. In the movie industry, The Tali H500 UAS will be a safe and stable 

camera platform. The Tali H500 UAS will also further environmental management by

researching invasive species, mapping deforestation, and surveying point source pollution.

2. The Public Will Benefit From Decreased Congestion Of The NAS.

The Tali H500 UAS is battery powered and serves as a safe, efficient, and economical

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use

of a Tali H500 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and

air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and departing aircraft will be reduced.
15

The Tali H500 UA does not require an airport to takeoff or land. Likewise, a reduction of

manned aircraft conducting aerial survey missions would result in fewer aircraft that must be 

handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of 

flight operations.

3. The Public Will Benefit From The Safety And Efficiency Of The Tali H500

UAS.

Conducting aerial acquisitions with the Tali H500 UAS, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated

during traditional aerial survey flight operations. By using battery power and electric motors, the

Tali H500 UAS produces no air pollution, and is the most viable environmentally conscious

alternative to the cabin class, six cylinder internal combustion twin engine aircraft that are

typically utilized for aerial acquisitions, while burning approximately 20-30 gallons per hour of

leaded aviation fuel. The Tali H500 UAS, while reducing the carbon footprint of aerial

acquisitions, also reduces noise pollution, as the UA is propelled by battery powered electric

motors, rather than an internal combustion engine.

By using the Tali H500 UAS to perform aerial acquisitions, the substantial risk to life

and property in the air and on the ground, which is usually associated with traditional manned

aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the

lack of flight crew members located onboard the aircraft, the Tali H500 UA (weighing

approximately 5 pounds at its maximum gross weight with a diameter of 24 inches, rotor span of

36 inches, and with no fuel on board), has less physical potential for collateral damage to life and

property on the ground, and in the air, compared to the manned aircraft that typically conduct

aerial acquisitions (weighing approximately 6,500 pounds with a wingspan of approximately 40

feet, a length of 34 feet, and a fuel capacity of 180 gallons).
16

4. Performing Aerial Acquisition Operations With The Tali H500 UAS

Will Benefit The Economy.

In addition to being safe and efficient, the Tali H500 UAS is also an economical

alternative to using manned aircraft to conduct aerial acquisitions. As such, operation of the

Tali H500 UAS will allow United States based companies, like AVS, to remain competitive

and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel

and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded 

aviation fuels, U.S. owned and operated companies must adopt new and alternative technology

in order to remain competitive. Operating the battery powered Tali H500 UAS is one such

technology that not only allows companies greater operational flexibility compared to manned

aircraft, but provides such flexibility without the high operational cost of a traditional manned

aircraft.

By operating the Tali H500 UAS, companies such as AVS can remain competitive and

profitable, and therefore, provide greater job stability to employees and contractors, which will 

ultimately contribute to growth of the U.S. economy. Improved financial performance of

U.S. companies, through commercial use of the Tali H500 UAS, provides a stable workforce

that increases consumer spending; improves local, state, and federal tax revenues; and allows

companies to invest in research and development in order to remain competitive both in the

United States and abroad.

5. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for

decades, AVS’s proposed operation of the Tali H500 UAS will not implicate any privacy

issues. Specifically, the Tali H500 UAS will be operated in mostly rural areas, and in

accordance with all Federal Aviation Regulations, including the minimum altitude requirements
17

of 14 C.F.R. § 91.119. Most significantly, the Tali H500 UA will not be operated closer than

500 feet to any person, vessel, vehicle, or structure, which is not directly involved in the

operation.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or

How The Exemption Would Provide A Level Of Safety At Least Equal To That

Provided By The Rule From Which AVS Seeks Exemption.

1. Reasons Why The Tali H500 UAS Meets The Conditions Of The FAA

Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the

unmanned aircraft and its operation, AVS’s operation of the Tali H500 UAS meets the

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification

and sets forth requirements for considering whether a UAS will create a hazard to users of the

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section

333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later

than 180 days after the date of enactment of this Act, the Secretary of Transportation

shall determine if certain unmanned aircraft systems may operate safely in the national

airspace system before completion of the plan and rulemaking required by section 332 of

this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under

subsection (a), 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; and

(2) ) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United States Code,

is required for the operation of unmanned aircraft systems identified under

paragraph (1).
18

(c) Requirements for Safe Operation.--If the Secretary determines under this section that

certain unmanned aircraft systems may operate safely in the national airspace system,

the Secretary shall establish requirements for the safe operation of such aircraft systems

in the national airspace system.

In seeking this exemption, AVS submits that the Tali H500 UAS can operate safely in the

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the Tali H500

UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The Tali H500 UAS Demonstrate Its Safe

Characteristics.

The Tali H500 UAS does not create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security considering its size, weight, speed, and operational

capability.

i. Technical Specifications Of The AVS UAS.

Unmanned Aircraft

System

The Tali H500 is an Unmanned Aircraft System that is comprised of

vertical takeoff and landing (VTOL) unmanned aircraft and a

transportable ground control station.

Unmanned Aircraft

Dimensions

Diameter: 24 inches

Rotor span: 36 inches

Engine

(Propulsive Unit)

Engine (Propulsive Unit)

(6) DeVention Inc. P/N : WK-WS-34-

001 (Electric)

FAA Engine Type Cert: None

Propulsive Unit Type: 22.2V, 5400mAh capacity, Lithium ion

battery powered, direct drive electric motor
19

.

Motor, Controller Sub-Assembly:

Manufacturer: Walkera

Model: WST15AH®ESC f H500

Type: Brushless Speed 

Controller

Motor, Battery:

Manufacturer: Walkera, Inc.

Type: 1(one) x Lithium Ion

5400m Amp hour each

22.2V (nominal) 6S

Fuel Not Applicable.

NOTE: The Tali H500 UAS is powered by one Lithium

Polymer rechargeable batteries, P/N Tali H500-Z-22 6S.

Engine (Propulsive Unit)

Limits

Max Power Output: 1HP(6) 

Maximum RPM: 6000 (500kv)

Maximum Motor Temperature: 170 °F (77 °C)

NOTE: The motor temperature is not displayed to the

operator.

Maximum motor, controller sub-assembly

temperature: 194 °F (90 °C)

Power On (Engine and Rotor Tach, neither visible to operator)

Maximum 6000 RPM

Minimum 3000 RPM

Propeller and

Propeller Limits

(4) Walkera Inc. P/N 30490

FAA Propeller Type Certificate: None

Propeller Type: 2-blade, plastic, fixed pitch, tractor

Propeller Sub-Assembly:

Manufacturer: APC Propeller

Model: W3049

Diameter (Nominal): 7 in.

(4) Walkera Inc. P/N 30488

FAA Propeller Type Certificate: None

Propeller Type: 2-blade, plastic, fixed pitch, tractor
20

NA

Battery Command &

Control

Type: 1(one) x Lithium Ion

5400m Amp hour each

22.2V (nominal) 6S 

Airspeed Limits Vne (Never Exceed Speed) 15 knots 

Empty Weight C.G.

Range

-1 to 1 inches of datum

Datum Centroid of Vehicle

Maximum Weights Ramp 5 lbs.

Takeoff 5 lbs.

Landing 5 lbs.

Empty Weight 3.8lbs.

NOTE: Empty Weight Excludes weight of battery and

Camera/Gimbel.

Frequencies 902-928 MHz (ISM Band)

2.4 GHz (ISM Band)

NOTE: FCC license is not required to utilize the above

frequencies; uplink and downlink are on the 900Mhz band. If

video is utilized, uplink, downlink, and video are all on

2.4 Ghz.

Computer Software Avionics embedded processor, 
21

Minimum Crew (1) The Tali H500 UAS can be operated by a single operator.

Number of Seats (0) Not Applicable.

Fuel Capacity Not Applicable.

Oil Capacity Not Applicable.

Max. Operating Altitude 1,200 ft. AGL

Rotor Blade and Control

Movements

Fixed Rotor Control. Vehicle control is achieved through varying

thrust of each motor individually

Nominal Endurance 20 minutes above 32 °F (0 °C)

12 minutes below 32 °F (0 °C)

Ambient Outside Air 

Temperature (OAT)

Maximum OAT: 120 °F (49 °C)

Minimum OAT At Altitude: -20 °F (-29 °C)

Wind Limitation 9.7 knots

Maintenance This Tali H500 UAS must be maintained in accordance with the

manufacturer’s maintenance manual, or later FAA accepted revision.

ii. The Tali H500 UAS Autonomous Flight And Navigation

Modes Enable The UAS To Remain Within A Defined

Operational Area.

A complete description of the autonomous modes and methods of navigation for the

 Tali H500 UAS is provided in the Tali H500 UAS Operator Manual 
22

A copy of the Tali H500 UAS Operator Manual, which contains proprietary information, is

On file, at AVS’s office of operation.

iii. The Tali H500 UAS Is Designed For Complete Autonomy

From Launch To Landing Even In The Unlikely Event Of Loss

Of The Control Link Or Navigation.

Although a degradation or loss of the control link, and/or degradation or loss of the

source of navigation is unlikely, it is a situation that is well planned for and therefore, is a benign

event. The Tali H500 is designed for complete autonomy from launch to landing with a line of 

sight operator in the loop monitoring the airframe.

The Tali H500 uses a two-stage failsafe approach for all avionics failure conditions,

including the event of a loss of communications (“Lost Link”). Upon loss of the

communication signal, the w Tali H500 will attempt to reacquire the link. If after 10 seconds

the link has not been reacquired, the Tali H500 will continue to attempt to reacquire the link 

while maintaining the current altitude and navigating to the home waypoint, which is the same

as the location of the ground control station. Once at the home waypoint, the Tali H500 will 

hover while continuing its attempt to reacquire the link for 30 seconds (to allow for rebooting

of the ground control station, if needed). The Tali H500 will then continue to attempt to reacquire the link while it navigates through the landing procedure.

The landing procedure for Lost Link is identical to a normal landing procedure. The

Tali H500 will enter into a hover-land procedure; descending while reducing speed until contact

with the ground. During this decent and touchdown, the Tali H500 will remain in controlled

flight.
23

Loss of GPS signal will result in a two-tiered recovery approach. Upon loss of a GPS

signal, the Tali H500 will immediately hover in an attempt to reacquire a signal. If after 15 

seconds, a GPS signal is not reacquired, the UAS will enter tier-two recovery. At any time

during either tier-one or tier-two recovery, the operator can take over with augmented control

and utilize its onboard magnetometer to navigate back to the home waypoint through deadreckoning. During this failure mode, the observer will call out UAS position and movement

back to the operator. Once the UAS is close enough to resolve orientation, or if operating with 

a live video payload, the operator can engage manual control and perform a manual landing at

the pre-decided landing site.

If a cascade of failures has occurred and Lost-Link has also occurred during tier-two

recovery, the Tali H500 will enter into a hover-land procedure; descending while reducing

speed until contacting the ground. Throughout this decent and touchdown, the Tali H500 will 

remain in controlled flight.

The Tali H500 Operator Manual “Emergency Procedures” fully describes the features of 

the Tali H500 UAS, and sets forth the UAS’s operation in the event of a power loss, loss of 

communications, loss of GPS signal, loss of video link, or software crash.
24

iv. Safe Mobile Operation Of The Tali H500 UAS.

The Tali H500 UAS may be safely operated by a Pilot-in-Command (PIC) and safety

observer co-located with a GCS on a mobile vehicle or watercraft, in order to efficiently perform

aerial acquisition operations of large areas, additional limitations and requirements apply to 

mobile operations of the Tali H500 UAS, including the following:

The driver/operator of the mobile vehicle must be licensed and fully understand his/her

role in the operation.

The mobile vehicle must be organized and clear of any unnecessary debris prior to the

operation.

Equipment and personnel positioning within the vehicle must be predetermined and

agreed upon by the team. Each team member must use appropriate safety restraint

equipment, and such equipment should not interfere with safe flight.

The PIC must have ready communication with the driver/operator of the mobile vehicle,

as well as the safety observer.

The route of the mobile vehicle must be determined prior to operation. The PIC must

ensure that no part of the route will obscure the safety observer’s view or cause any

physical obstacles or obstructions to any member of the flight team.

The Area of Interest (AOI) must be large enough to warrant mobile operations, and the

UA cannot be allowed to exit the AOI under any circumstance. The only change to the

standard operating procedures (SOP’s) with mobile operations must be an update of the

LOL (Loss of Link) site. Mobile operations are only permitted if suitable LOL sites are
25

within 500 ft. of the PIC at all times. The entire AOI must also meet the “sterile

environment” of a static site, otherwise mobile operations are prohibited.

b. Flight Operations Of The Tali H500 UAS Are Limited To The

Line Of Sight Of A Certificated Pilot in Command With

A Safety Observer.

AVS will only utilize certificated Commercial pilots who possess a valid 2

nd Class 

airman medical certificate, to act as a pilot in command (PIC) of the Tali H500 UAS. 

Additionally, a safety observer will assist all pilots.

c. Flights Of The Tali H500 UAS Will Be Conducted Pursuant To

Specific Operating Limitations.

In seeking this exemption, AVS proposes to commercially operate the Tali H500 UAS for the 

special purpose of conducting aerial video/filmmaking, photography, aerial inspections 

(energy/utilities) and acquisitions over certain areas of the United States and Gulf of Mexico,

pursuant to the following specific operating limitations:

1) Operations authorized by the grant of exemption will be limited to the following

aircraft described in the operating documents, which is an six-rotor, vertical takeoff and

landing, unmanned aircraft weighing less than 6 pounds: Walkera Tali H500. Proposed

operations of any other aircraft will require a new petition or a petition to amend the

grant.

2) The Tali H500 UA may not be flown at an indicated airspeed exceeding 14.5 knots.
26

3) The Tali H500 UAS must be operated at an altitude of no more than 1,200 feet above

ground level (AGL). All altitudes reported to ATC must be in feet.

4) The Tali H500 UAS must be operated within visual line of sight (VLOS) of the Pilot

in Command (PIC) at all times. This requires the PIC to be able to use human vision

unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued

airman medical certificate.

5) All operations must utilize a Visual Observer (VO). The VO may be used to satisfy

the VLOS requirement, as long as the PIC always maintains VLOS capability. The VO

and PIC must be able to communicate verbally at all times. The PIC must be designated

before the flight and cannot transfer his or her designation for the duration of the flight.

The PIC must ensure that the VO can perform the functions prescribed in the operating

documents.

6) The operating documents and the grant of exemption must be maintained and made

available to the Administrator upon request. If a discrepancy exists between the

conditions and limitations in the exemption and the procedures outlined in the operating

documents, the conditions and limitations in the grant of exemption take precedence and

must be followed. Otherwise, the operator must follow the procedures as outlined in its

operating documents. The operator may update or revise its operating documents. It is

the operator’s responsibility to track such revisions and present updated and revised

documents to the Administrator upon request. The operator must also present updated

and revised documents if it petitions for extension or amendment to the grant of

exemption. If the operator determines that any update or revision would affect the basis

upon which the FAA granted the exemption, then the operator must petition for

amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may

be contacted if questions arise regarding updates or revisions to the operating documents.

7) Prior to each flight, the PIC must inspect the Tali H500 UAS to ensure it is in a

condition for safe flight. If the inspection reveals a condition that affects the safe

operation of the Tali H500 UAS, the Tali H500 UAS is prohibited from operating until 

the necessary maintenance has been performed and the Tali H500 UAS is found to be

in a condition for safe flight. The Tali H500 UAS Ground Control Station must be

included in the preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

8) Any Tali H500 UAS maintenance or alterations that affect the UAS operation or flight

characteristics (e.g. replacement of a flight critical component), must undergo a

functional test flight. The PIC who conducts the functional test flight must make an entry

in the Tali H500 UAS aircraft record of the flight.

9) In addition to the pre-flight inspection section in the operating documents, the preflight

inspection must also account for all discrepancies, i.e. inoperable components, items, or

equipment, not already covered in the relevant sections of the operating documents.
27

10) The operator must follow the Tali H500 manufacturer’s UAS aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

11) The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance, inspection, and

alterations must be noted in the aircraft logbook, including total flight hours, description

of work accomplished, and the signature of the authorized Tali H500 maintenance

personnel or PIC returning the Tali H500 UAS to service.

12) The operator’s Tali H500 authorized maintenance personnel or PIC must make a

record entry in the UAS logbook or equivalent document of the corrective action taken

against discrepancies discovered between inspections.

13) The operator’s Tali H500 authorized maintenance personnel, PIC, and VO must

receive and document training referenced in the operating documents.

14) The UAS operated under the exemption must comply with all manufacturer System

and Safety Bulletins.

15) The PIC must possess at least a FAA-issued Commercial pilot certificate and a valid

FAA- issued 2

nd

 Class airman medical certificate. The PIC must also meet the flight

review requirements specified in 14 C.F.R. 61.56 in an aircraft in which the PIC is rated

on his or her pilot certificate.

16) Prior to operating for hire, the PIC, and VO must have successfully completed

AVS’s training syllabus as outlined in the operating documents. In addition, the PIC and

VO must also have successfully completed annual (recurrent) training in accordance

with the operating documents. A record of training must be documented and made

available upon request by the Administrator. Training, proficiency, and experiencebuilding flights for the purpose of training pilots and VOs to conduct flights authorized

by the exemption are permitted under the terms of the exemption.

17) If the Tali H500 UAS loses communications or loses its GPS signal, it must return

to a pre-determined location within the planned operating area and land, or be recovered

in accordance with the operating documents.

18) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents.

19) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations under the grant of

exemption. This COA will also require the operator to request a Notice to Airman

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the

operation.
28

20) The Tali H500 UAS operated in accordance with the exemption must be identified

by serial number, registered in accordance with 14 C.F.R. Part 47, and have identification

(N-Number) markings in accordance with 14 C.F.R Part 45, Subpart C.

21) Before conducting flight operations, the radio frequency spectrum used for operation

and control of the Tali H500 UAS. The Tali H500 UAS must comply with the Federal

Communications Commission (FCC) or other appropriate government oversight agency

requirements.

22) The documents required under 14 C.F.R §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the Tali H500 UAS any time the aircraft is

operating. These documents must be made available to the Administrator, or any law

enforcement official, upon request.

23) The Tali H500UAS must remain clear and yield the right of way to all other aircraft

operations and activities at all times.

24) If the Tali H500 UAS is operated from a moving device or vehicle, the operation

must be in accordance with the operating documents.

25) Tali H500 UAS operations may not be conducted during night, as defined in 14

C.F.R. § 1.1.

26) All operations must be conducted under visual meteorological conditions (VMC).

The Tali H500 UAS may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

27) During operations in the National Airspace System, the UAS may not operate within

5 nautical miles of the geographic center of an airport as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that airport’s management

is obtained, and the operation is conducted in accordance with a NOTAM as required by

the operator’s COA. The letter of agreement with the airport management must be made

available to the Administrator upon request.

28) The Tali H500 UAS may not be operated over congested or densely populated areas.

These areas include, but are not limited, to the yellow areas depicted on World

Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal

Area Charts (TAC). However, aeronautical charts may not reflect pertinent local

information. Ultimately, it is the PIC’s responsibility to maintain the minimum safe

altitudes required by 14 C.F.R. § 91.119.

29) Operation of the Tali H500 UAS must be conducted at least 500 feet from all

persons, vessels, vehicles, and structures not directly involved in the operation.

30) Operations of the UAS may be conducted at distances less than 500 feet from

participating persons, vessels, vehicles or structures that perform an essential function in

connection with the special purpose operations. Operations closer than 500 feet from the
29

PIC, VO, operator trainees and essential persons, are permitted when operationally

necessary; but never so close as to present an undue hazard, per 14 C.F.R. § 91.119(a).

31) Operations of the UAS may be conducted at distances less than 500 feet from

unoccupied vessels, vehicles or structures owned by the land owner/controller when the

land owner/controller grants such permission and the PIC makes a safety assessment of

the risk from operations closer to these objects.

32) All operations shall be conducted with permission from the land owner/controller or

authorized representative. Permission from land owner/controller or authorized

representative will be obtained for each flight to be conducted.

33) Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be reported to

the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents meeting the

requirements of 49 C.F.R. Part 830 must be reported to the National Transportation

Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.
30

1. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The level of safety established by Section 91.7(a) will be maintained because prior to

every flight, AVS will ensure that the Tali H500 UAS is in an airworthy condition and safe for

flight based upon the Tali H500 UAS’s compliance with its operating documents (i.e., the Tali 

H500 UAS Operator Manual and the Tali H500 UAS Maintenance Manual) and as stated in the 

conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a), specific to

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138).
31

2. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because

the Tali H500 UAS is equipped with a digitally encoded barometric altimeter and GPS

triangulation equipment, with a zero altitude initiation point being established prior to each

flight. As such, the PIC on the Tali H500 UAS is provided the altitude of the UAS above

ground level (AGL) via a heads-up display of the ground control station (GCS). Specifically, the

PIC of the Tali H500 UAS is provided three different types of altitude information:

(1) Desired Altitude, indicating the commanded altitude, located at the top right corner of HUD

as well as above the HUD; (2) Altitude Above Ground Level (AGL), indicating actual altitude

relative to height above launch level on the ground, located in the center of the right side of the

HUD; and (3) Climb Rate, indicating the current rate of climb, located in the center of the right

side of the HUD. Accordingly, the PIC of the Tali H500 UAS will be provided with all of the

necessary altitude information necessary to maintain safe operation of the UAS in the NAS.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138).

3. Reasons Why An Exemption From The Requirements Of Section

91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure the equivalent level of safety established by 14

C.F.R. Section 91.151(b) because the technical specifications of the Tali H500 UAS, the Walkera

Operations Manual, and AVS’s proposed operating limitations will ensure that AVS may safely

operate the battery powered Tali H500 UAS during daylight hours in VFR conditions for a total

flight duration of 15 minutes, which will ensure a landing with five minutes (i.e., 25
32

percent) battery power remaining. Furthermore, previous exemptions granted by the FAA

concerning Section 91.151(b) establish that safety is not adversely affected when the technical

characteristics and operating limitations of a UAS are considered.

The Tali H500 UAS is powered by one Lithium Ion 11 Amp hour, 22.2V batteries, and

is protected by two low battery failsafe’s. The ground control station (GCS) provides a battery

indicator on the heads-up display, which indicates the Tali H500 UAS’s current remaining

battery power measured in volts, and a 30% Buzz of the CU. This provides the PIC with constant

awareness of the real-time battery voltage during a flight.

The two low battery fail safes that protect the Tali H500 UAS are a “Low AV battery”

failsafe and a “Critically low AV battery” failsafe. The “Low AV battery” failsafe flies the UA

to the location of the ground control station (GCS), or identified Rally point, when the UA

batteries reach a certain threshold of time as configured by the operator, or 22.2V. The

“Critically low AV battery” failsafe lands the UA at its current location. This failsafe is triggered

if a battery drops below the critical battery voltage as configured by the operator, or 21.2V.

Furthermore, an exemption from the requirements of Section 91.151(b) would not

adversely affect safety because AVS will only conduct flights during daylight hours in VMC,

with the duration of each flight not to exceed 15 minutes, with five minutes (i.e., 25 percent)

battery power remaining.

Likewise, as set forth above, AVS has proposed specific operating limitations in this

Petition that will maintain the equivalent level of safety established by Section 91.151(b),

including the following: (1) the Tali H500 UAS will only be operated during daylight hours (i.e.

between the end of morning civil twilight and the beginning of evening civil twilight, as
33

published in the American Air Almanac, converted to local time); (2) The Tali H500 UAS will 

only be operated pursuant to visual flight rules (VFR) in visual meteorological conditions 

(VMC); and

(3) the duration of each flight shall not exceed 15 minutes.

Significantly, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristics and operating

limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at

less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and

10650. Moreover, the FAA has previously granted relief from Section 91.151, specific to UAS

in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11136, 11138).

4. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not

Adversely Affect Safety.

In seeking this exemption, AVS submits that an equivalent level of safety with regard to 

the regulatory maintenance and alteration requirements established by Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because AVS, will use its 

trained Pilots as technicians to perform maintenance, alterations, or preventive maintenance on 

the unmanned aircraft system using the methods, techniques, and practices prescribed in the

manufacturer’s maintenance manual. Furthermore, AVS will document and maintain all

maintenance records for the Tali H500 UAS.

Since the Tali H500 UAS will be inspected as prescribed by the manufacturer’s

maintenance manual, AVS will maintain the equivalent level of safety established by Sections

91.405(a), 91.409(a)(1), and 91.409(a)(2). The Tali H500 UAS Maintenance Manual sets
34

forth Scheduled Maintenance Inspection Procedures for each system and component. Inspection

intervals for the Tali H500 UAS include preflight and post flight inspections, as well as

scheduled inspections every 25 hours, 50 hours, 75 hours, and 100 hours of operation.

Likewise, the exemption sought will not adversely affect safety because AVS will

perform maintenance, alterations or preventive maintenance on the UAS using the methods,

techniques, and practices prescribed by the manufacturer’s maintenance manual.

Furthermore, the exemption sought would maintain an equivalent level of safety

established by Sections 91.407, 91.417(a) and 91.417(b) because all maintenance of the Tali 

H500 UAS will be performed by trained Pilots as technicians to perform maintenance, who will

document and maintain maintenance records for the Tali H500 UAS.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), 91.417(a) & (b) establish that safety is not adversely

affected when the technical characteristics and operating limitations of a UAS are considered.

The FAA has previously granted relief specific to UAS in circumstances similar, in all material

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11112, 11136, 11138).
35

5. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, AVS requests that the FAA

prescribe special conditions for the intended operation of the Significantly, previous exemptions 

granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics

and operating limitations of a UAS are considered. The FAA has previously granted relief

specific to UAS in circumstances similar, in all material respects, to those presented herein

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11112, 11136, 11138).

, which contain such safety standards that the Administrator finds necessary to establish a 

level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b).

Such special conditions will permit safe operation of the UAS for the limited commercial

purpose of conducting aerial video/filmmaking, photography, aerial inspections 

(energy/utilities) and acquisitions over certain areas of the United States and Gulf of Mexico.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and

further, provides the authority for such UAS to operate without airworthiness certification in 

accordance with any requirements that must be established for the safe operation of the UAS in 

the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.
36

§ 21.16, for operation of the Tali H500 UAS, since the airworthiness regulations of 14 C.F.R.

Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual

design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller,

he prescribes special conditions and amendments thereto for the product. The special

conditions are issued in accordance with Part 11 of this chapter and contain such safety

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to

establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may

prescribe special conditions for AVS’s intended operation of the Tali H500 UAS, which contain

such safety standards that the Administrator finds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a)

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a)

& (b).

F. A Summary That Can Be Published In The Federal Register, stating:

The Rules From Which AVS Seeks Exemption:

AVS, Inc. seeks exemption from the requirements of 14 C.F.R Sections 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption AVS Seeks:

This exemption will permit AVS, to commercially operate an Unmanned Aircraft System

(UAS) for the purpose of conducting aerial video/filmmaking, photography, aerial inspections 

(energy/utilities) and acquisitions over certain areas of the United States and Gulf of Mexico.
37

G. Any Additional Information, Views, Or Arguments Available To Support

AVS’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS

may operate safely in the NAS. As such, AVS’s request for exemption may be granted

pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create

a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and

further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, AVS will operate the Tali H500 UAS safely in the NAS

without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to

national security.

CONCLUSION

 As set forth herein, AVS seeks an exemption pursuant to 14 C.F.R. § 11.61

and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA),

which will permit safe operation of the Tali H500 UAS commercially, without 

an airworthiness certificate, for the limited purpose of conducting aerial

video/filmmaking, photography, aerial inspections (energy/utilities) and 

acquisitions over certain areas of the United States and Gulf of Mexico.
38

.

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of

the FAA Modernization and Reform Act of 2012, while also advancing the interests of the

public, by allowing AVS to safely, efficiently, and economically operate the Walkera Tali H500

UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, AVS respectfully requests that the

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections

 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b), and permit AVS to operate the Walkera Tali H500 UAS for the purpose of

conducting aerial video/filmmaking, photography, aerial inspections (energy/utilities) and 

acquisitions over certain areas of the United States and Gulf of Mexico.

Respectfully submitted

Joseph R. Pascal Jr.

September 8, 2015

Aerial Video Systems

921 West Lakeshore Dr.

Carriere, MS. 39426

(601)347-8222

joe.pascal@yahoo.com
39