787-643-3234 www.wilfredobatista.com

1 wilfredophotography@gmail.com| 787-643-3234 | V-17 Calle Alaska Urb. Parkville Guaynabo PR 00969 Julio 12, 2015 Wilfredo Pérez Batista Wilfredo Batista Photography V-17 Calle Alaska Urb. Parkville Guaynabo PR 00969 Emial: wilfredophotography@gmail.com United States Department of Transportation Docket Management System 1200 New Jersey Ave., SE West Building Ground Floor Room W12-140 Washington, DC 20590 RE: Visual Advantage’s Petition for Exemption to Operate Unmanned Aircraft Systems for Aerial Photography and Videography Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. Part 11, Visual Advantage hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed herein and any other necessary to allow its operation of small Unmanned Aircraft Systems (UAS) to support its professional photo and video production services to include the use of small unmanned aircraft systems (UAS) to include aerial photo and video services. The requested exemption would permit the operation of DJI Inspire 1 and DJI Phantom3 to obtain aerial photographs and video for photography services and sales. The areas of use will include both photo and video in the Utilities, communications industry, real estate industry, surveying industry, construction industry, agricultural industry, motion picture and television industry. Exemption request to section 333 of the FAA Reform Act Plan 11 Specific to UAS operations. 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) & (b); 14 CFR 91.103;14 CFR 91.105; 14 CFR 91.109: 14 CFR 91.119(c);14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.401(a)(1) & (2); 14 CFR 91.417(a) 7 (b). BACKGROUND Wilfredo Batista provides photo and video production services to support professional photography services in Puerto Rico. Traditional photography and videography is current used for interior and exterior jobs. Visual Advantage would like to support its services and include aerial photography and videography through the use of small UAS.787-643-3234 www.wilfredobatista.com

2 wilfredophotography@gmail.com| 787-643-3234 | V-17 Calle Alaska Urb. Parkville Guaynabo PR 00969 The Unmanned Aircraft (UA) described herein is smaller, lighter and more maneuverable than conventional aircraft running on combustible fuel, operates at lower altitudes with no people on board and will thereby reduce current risk levels and enhance safety. With a small payload and maximum flight time of only 22 minutes, this offers little or no risk to national security. Experience with RC Airplane models More than 20 years as a pilot RC models, also have insurance with "AMA" Academy of Aeronautics, member #578481 open until 12-31-2015. THE UNMANNED AIRCRAFT (UA) DJI Inspire1 (primary system) o (Model: T600)  professional aerial filmmaking and photography platform  Under 20 pounds takeoff weight  4 motors  18 to 22 minute flight time depending on battery size o DJI Flight Master and Slave Controllers with GPS  Provides Fail Safe features that allow the aircraft to return to the launch point and land automatically in the event the command and control signal is lost or the battery has reached a pre-determined threshold. If battery reaches a critical level, the aircraft will descend and land at the current location. Control of the aircraft is maintained during descent to allow the PIC to guide it to a safe landing.  Home Lock function allows safe return of the aircraft in the event of a motor failure

 Contains a database of airports and restricted airspace and automatically prevents operation in these areas.  DJI Vision Positioning is a positioning system that uses ultrasonic and image data to help the aircraft identify its current position. With the help of Vision Positioning, your Inspire 1 can hover in place more precisely and fly indoors or in other environments where there is no GPS signal available. Note: The Inspire 1's flight controller is based on DJI flight controller with several enhancements such as new flight mode and new safe mode. Three safe modes are available: Failsafe, Return Home and Dynamic Home Point. These features ensure the safe return of your aircraft if the control signal is lost. A flight recorder stores crucial flight data for each flight.

o DJI 5.8 GHz Video Downlink Transmitter – FCC Licensed. o DJI - On Screen Display of Telemetry.The superimposes telemetry data on the video downlink to provide the pilot with heading, speed, height, distance, GPS information, and current battery voltage as well as indicating proximity to airports and restricted airspace. Direction back to launch point is also indicated.

Note: DJI's Lightbridge technology which can transmit video from up to 2km away. Lightbridge technology which can transmit video from up to 2km away787-643-3234 www.wilfredobatista.com

3 wilfredophotography@gmail.com| 787-643-3234 | V-17 Calle Alaska Urb. Parkville Guaynabo PR 00969 DJI Phantom3 Professional (Backup System) o Phantom3 Professional  Professional Grade  Under 13 pounds takeoff weight  4 motors  Up to 23 minute flight time depending on battery size.

 DJI Phantom3 – Flight Controller (similar as Inspire 1)  DJI 5.8 GHz Video Downlink (similar as Inspire 1)  DJI Telemetry (similar as Inspire 1) GROUND STATION EQUIPMENT The ground station equipment is comprised of a dual control system o Primary controller is for the Pilot in Command (PIC)  2.4 GHz radio control unit (FCC Licensed)  5.8 GHz video receiver (FCC Licensed)  Display of video and telemetry o Camera Controller operates the camera gimbal and does not affect aircraft control  2.4 GHz radio control unit. (FCC Licensed)  5.8 GHz video receiver (both PIC and Cameraman receive the same signal)  Display of video and telemetry  Two directional antenna for improved video reception Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner:

o Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, engineering and other related professional activities. o Aerial video and/or photography of for public and/or private use including television, public events, cinematography and news gatherings. o Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority. o Aerial inspection/photography of residential/commercial utility infrastructure included but not limited to electrical power lines, wind turbines and cell towers. o Aerial video/photography or providing live video feed to assist with rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contract and/or donation. o The ability to offer training to persons or individuals belonging to both private and/or public organizations that have interests in the use and application of UAS for the purpose of the safe operation of a UAS to enhance the safety of national aerospace system (NAS) as well as for protection of the persons and property. As described fully below, and to be used as FOM(exibit#1), the requested exemptions would permit the operation of a UAS under controlled conditions in the NAS that would be a) limited,787-643-3234 www.wilfredobatista.com

4 wilfredophotography@gmail.com| 787-643-3234 | V-17 Calle Alaska Urb. Parkville Guaynabo PR 00969 b) controlled, c) predetermined, and d) will provide safety enhancements such as limited exposure to flight crew, climbing crews, weight of vehicles, speeds of usage, non-use of volatile fuels, ect. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportations (the FAA administrators) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national airspace system.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The primary vehicle to be used will be the DJI Inspire1 and DJI Phantom3. While vehicles may be upgraded as new technological and safety advanced occur the bar for operation and safety will be set by DJI and any new vehicles or versions will exceed the current safety and operational standards. No vehicle operated by BUNGEE LLC will be modified from the manufacturers design unless specifically directed by the same manufacturer. The operation limitations proposed for an equivalent or higher level of safety because perations will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as set forth in the flight operations manual include: Exhibit #1 o The UAS will weigh less than 55 lbs o The UAS will have a maximum operating speed of no more than 100 mph o Flights will be operated within line of sight of the pilot in command and/or visual observer o Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs first o Flights will be operated at altitude of no more than 200feet above ground level and no more than 200 feet above an equivalent platform from which filming is planned. o UAS will NOT operate. o 5 nautical miles (NM) from an airport having an operational control tower; or o 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or o 2 NM from an airport without a published instrument flight procedure or an operational tower; or o 2 NM from a heliport with a published instrument flight procedure o Minimum crew for each operation will consist of the UAS pilot(PIC), the visual observer (VO) and may include but not limited to a camera operator o The UAS pilot will be designated pilot in command and hold a private pilot’s license along with a Current State Drivers License. If the PIC feels another operator to be qualified with the necessary skills to be pilot in command and possesses a private pilot’s license along with, Current credentials, that person may be designated PIC provided they have a minimum of 20 hours of flight time with the UAS. o A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of all days production activities o All flights will occur under visual flight rules meteorological conditions (VFR only).787-643-3234 www.wilfredobatista.com

5 wilfredophotography@gmail.com| 787-643-3234 | V-17 Calle Alaska Urb. Parkville Guaynabo PR 00969 o The operator will obtain verbal/written consent of all persons involved with the planned operations and ensure only consenting persons will be allowed within 100 feet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as required under the FOM. With the advance permission of the FFDO, operations at closer range may be approved. o The PIC and VO will have been trained in operation of UAS and receive up-to-date information for the particular UAS to be operated. o The PIC and VO will be able to communicate by voice, radio, and/or text at all times. o Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate governmental agencies. o If the UAS loses communications with the remote controller or losses GPS signal, the UAS will have the capability to return to a pre-determined location within a designated location and land autonomously. o The UAS will have the capability to abort a flight and return to designated landing area in case of unpredicted obstacles, weather, or emergencies. o VO or PIC instructed to switch UAS to automatically return home in event either are incapacitated. https://www.faa.gov/uas/legislative_programs/section_333/how_to_file_a_petition/media/ section333_public_guidance.pdf As of March 23, 2015, the FAA will automatically grant a "blanket" COA for flights at or below 200 feet to any UAS operator with a Section 333 exemption, provided the aircraft weighs less than 55 pounds, operations are conducted during daytime Visual Flight Rules (VFR) conditions and within visual line of sight (VLOS) of the pilots, and stay certain distances away from airports or heliports. In seeking authorization, petitioners will require exemptions from regulations with which they cannot fully comply. The table below provides guidance regarding regulations from which a petitioner may require exemption. However, some proposed operations may require exemption from regulations not listed here, while others may not require exemption from all regulations listed here. 14 CFR PART 21, Subpart H Certification procedures for products and parts, Airworthiness Certificates 91.103(b)(2) Preflight action 91.105 Flight crewmembers at stations 91.109 Flight instruction 91.119 Minimum safe altitudes 91.121 Altimeter settings 91.151 Fuel requirements for flights in VFR conditions 91.405 Maintenance required 91.407 Operation after maintenance 91.409 Inspections 91.417 Maintenance787-643-3234 www.wilfredobatista.com

6 wilfredophotography@gmail.com| 787-643-3234 | V-17 Calle Alaska Urb. Parkville Guaynabo PR 00969 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. Sec 91.203(a)(1) The UAS will operate @ 55lbs or less (Gross), carries neither a pilot or passenger*, carries no explosive materials or flammable liquid fuels*, and operates in within a secured and pre-determined designated area, at altitudes not to exceed 200 ft ALT or speeds in access of 100 MPH. 14 C.F.R. Sec 91.105 Flight crew members at station Exemption may be required, the PIC may not leave his station nor shall VO leave station . In event that PIC or VO become incapacitated, UAS is to automatically return to designated landing area, as outlined in FOM 14 CFR Sec 91.109 Flight Instruction (Dual Controls) Requiring that no person shall operate a civil aircraft for flight instruction unless the aircraft has fully functioning dual controls.UAS and Remote controlled aircraft by design do not have dual controls, to do so on a radio controlled aircraft would lower the ability to safely operate the UAS. This section cannot reasonably apply 14 C.F.R. Sec 45.23(b). Marking of the Aircraft Although exemption from said section cannot benefit nor exceed current stipulations, physical limitations of UAV are reality, such as cabins, letter size, ect. The UAV will operate under my control with registration lettering sized to fit fuselage in compliance of said section 45.23(b) under conditions and or limitations deemed mandatory by FAA . I and my colleges must be held responsible for compliancy, on behalf of Public’s safety and shared air space, as well as its need to indentify and Enforce the accountability and of this growing industry. 14 C.F.R. Sec 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command By current regulations because the applicants UAS does not carry passengers, or property. The use of UAS is far less dangerous (weight, speed, Fuel) than the inherent usage of commercial activities outlined in 14 CFR.16. The pilot in command shall have a current Private pilots license as well as a Current state drivers licsence which will equal if not exceed safety regulations outlined in 14 CFR 16.113.(a) & (b). 14 C.F.R. Sec. 91.103: Preflight Action: Exemption is requested due to fact that FAA rotor flight manuals are not available for UAV. The PIC will take all actions as stated in FOM, under normal procedures included but not limited to review of weather, examination of batteries for flight time analysis, landing and takeoff distances as well as flight and aircraft performance in flight. 14 C.F.R. Sec 91.119; Minimum Safe Altitudes Mandates safe altitude for operation of civil aircraft and allow helicopter to operates less then minimums prescribed, providing the person operating helicopter complies with any route with and or altitudes prescribed for Helicopter’s by FAA. Being that UAV is of Helicopters standards and operation a request for exemption to operate at altitude’s not to exceed 200 AGL or not more than 200 ft above any elevated platform from which take off is necessary to achieved filming. In the event of such particular flight plan, property owners, filming crews and other personnel would all be briefed as to787-643-3234 www.wilfredobatista.com

7 wilfredophotography@gmail.com| 787-643-3234 | V-17 Calle Alaska Urb. Parkville Guaynabo PR 00969 safety and conduct procedures during flight. FOB or ATC having jurisdiction in such area would have notification and briefing as mandated. 14 C.F.R. Sec 91.121 Altimeter Settings The requirement of PIC is to use altimeter as means to navigate aircraft to cruise altitudes to and from corresponding airports as predetermined in flight plan, unless ordered otherwise. As the UAS has no barometric altimeter, but instead uses GPS altitude read out, an exemption would need be applied. Per a pre flight check list and live flight data monitoring, the altitude of launch site will be predetermined and therefore calculated into the UAS- GPS indicator before flight. 14 C.F.R. Sec 91.151(a): Fuel Requirements for Flight in VFR Co Fuel requirements for flight. The maximum flight time under ideal conditions is 30 minutes with the current manufacturers battery pack. The proposed rule under this exemption would require the UAS to return to its point of launch if its battery reaches less than 25% provides a higher standard of safety when applied to UAS. 14 C.F.R. Sec 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections Referring to maintenance, preventive maintenance, and alterations to the UAS. The operator will provide minor maintenance and inspection to the UAS, documented as outlined in the operational and safety guidelines. Given the size and simplicity of the UAS combined with the operational and safety guidelines outlined in this petition the operator can maintain or exceed the required level of safety.

Respectfully Submitted,

Wilfredo Pérez Batista Wilfredo Batista Photography V-17 Calle Alaska Urb. Parkville Guaynabo PR 00969 787-643-3234