AVIASYS 

AVIATION SYSTEMS 

2906 E Lee Street, Pensacola, FL 32503 1 +1 (850) 549 7519 llucas@aviasys.com · 

October 14, 2015 

u.s. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., 

SE Washington, DC 20590 

,r- ,. "" 

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

Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 CFR Part 11, 

Lucas Alan Bardsley dba AVIASYS LLC, operator of Unmanned Aircraft Systems (UASs), hereby applies for an 

exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its UASs, so long as 

such operations are conducted within and under the conditions outlined herein or as may be established by the FAA 

as required by Section 333. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, 

would operate in the following manner: 

• Aerial photography and/or video for public and/or private use including real estate, architecture, land 

surveying, engineering and other related professional activities. 

Aerial video and/or photography for public and/or private use including television, public events, 

cinematography and news gathering. 

Aerial inspection/photography of residential/commercial structures under contract with the owners or local 

government authority. 

Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to 

electrical power lines, wind turbines, offshore oil and gas installations and cell towers. 

Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of 

an emergency or natural disaster only when the local authorities or government has requested it by contract 

or donation. 

The ability to offer training to persons individually or belonging to both private and/or public organizations 

that have interests in the use and application of a UAS for the purpose of the safe operation of a UAS to 

enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and 

property. 
As described fully below, the requested exemption would permit the operation of a UAS under controlled conditions 

in the NAS that would be 

a) limited 

b) controlled 

c) predetermined and 

d) will provide safety enhancements to the already safe operations in the industry presently using 

conventional aircraft. 

Approval of this exemption would thereby enhance safety 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." 

The name and address of the applicant is: 

AVIASYS, LLC 

EIN: 47-3081370 

Attn: Lucas Bardsley 

Phone: 850 549 7519 

Email: lucas@aviasys.com 

Address: 2906 E Lee Street, Pensacola, Florida 32503 

The regulations from which the exemption is requested are as follows: 

14 C.F.R. Part 21; 

14 C.F.R. 45.23(b); 

14 C.F.R. 61.113(a) & (b); 

14 C.F.R. 61.133 {a); 

14 C.F.R. 91.7(b); 

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

14 CFR 91.103; 

14C.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 C.F.R. 91.405(a); 

14 C.F.R. 91.407(a){l); 

14 C.F.R. 91.409(a)(2}; 

14 C.F.R. 91.417(a) & {b). 

Page2 
Equipment List 

AVIASYS, LLC, seeks an exemption to legally operate the following UASs for compensation or hire: 

• DJI Phantom 3 Professional 

Total weight: 1280g 

Diagonal Size (Including Propellers): 590mm 

Max Ascent Speed: 5 m/s 

Max Descent Speed: 3 m/s 

Under stiff air the maximum speed is about 16 m/s (about 36 mph) 

Max altitude above sea level: 6000 m 

Operating Temperature: 0°C to 40°C 

Max flight time: approximately 23 minutes 

GPS Mode: GPS/GLONASS 

The DJI Phantom 3 has the ability to hover and move along a vertical and horizontal 

plane simultaneously. 

Four motors, four propellers 

Intelligent Flight Battery: PH3·4480 mAh-15.2 V, Lithium Polymer 4S battery. 

The DJI Phantom 3 remote controller has an operating frequency of 2.400 GHz-2.483 GHz including live 

video downlink and telemetry data. 

Maximum transmission distance: 2000m (outdoors and unobstructed) 

User Manual: 

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professionai_User_Manual_v1.4_en.pdf 

3DR Iris Plus 

Total weight (with battery): 1282 g 

Dimensions: Height 100mm, Motor-to-motor 550mm 

Under still air the maximum speed is about 40mph (17.9 m/s) 

Max flight time: 16·22 minutes* (*depending on payload) 

Payload max capacity: 400g (.81bs) 

GPS Mode: 3DR uBiox GPS with compass (LEA·6H module, 5Hz update) 

The 3DR Iris+ has the ability to hover and move along a vertical and horizontal plane simultaneously. 

Four 950 kV motors, four 9.5 x 4.5 T-Motor multi-rotor self-tightening propellers 

Intelligent Flight Battery: 3S 5.1 Ah 8C lithium polymer 

The 3DR Iris+ remote controller has an operating frequency of 915 mHz for telemetry, 2.4 GHz for 

control. 

Maximum transmission distance: up to 1 km (.6 miles) (outdoors and unobstructed) 

User Manual: 

http://3drobotics.com/wp-content/uploads/2015/02/IRIS·Pius-Operatlon-Manual-vH-web.pdf 

Page3 
DJIInspire 1 (Model T600) 

Total weight (including battery): 2935g 

Diagonal Size (Including Propellers): 559 to 581 mm 

Dimensions: 438x451x301 mm 

Max Ascent Speed: 5 m/s 

Max Descent Speed: 4 m/s 

Under still air the maximum speed is about 22 m/s (about 49 mph) 

Max altitude above sea level: 4500 m 

Operating Temperature: -10°C to 40°C 

Max flight time: approximately 18 minutes 

The DJI Inspire 1 has the ability to hover and move along a vertical and horizontal plane 

simultaneously. 

Four DJI 3510 motors, four DJI 1345 propellers 

Intelligent Flight Battery: LiPo 6S High voltage battery, model TB47, 4500mAh, 22.2 v 

The DJI Inspire Cl remote controller has an operating frequency of 5.725"'5.825 GHz;2.400tv2.483 

GHz including live video downlink and telemetry data. 

Maximum transmission distance: 2000m (outdoors and unobstructed) 

User Manual: 

htto:fldownload.djHnnovations.com/downloads/jnspire 1/en/Inspire 1 User Mjlnual v1.4 en.pgf 

3DRSolo 

Total weight (with battery): 3.3 lbs. 

Dimensions: Height 10.2 in, Motor-to-motor 18.1 in 

Max Ascent Speed: 5 m/s (11 mph) 

Max Descent Speed: 2.5 m/s (5 mph) 

Under still air the maximum speed is about 55 mph (24.5 m/s) 

Max altitude: 400 ft. 

Max altitude above sea level: 10,000 ft. 

Operating Temperature: 32°F to 113°F 

Max flight time: 25 minutes 

Payload max capacity: 1.11bs. 

GPS Mode: 3DR uBiox GPS with compass (LEA-6H module, 5 Hz update) 

The 3DR Iris+ has the ability to hover and move along a vertical and horizontal plane simultaneously. 

Four 880 kV motors, four 10 x 4.5in self-tightening propellers 

Intelligent Flight Battery: lithium polymer, 5200 mAh, 14.8 Vdc 

The 3DR Solo remote controller has an operating frequency of 2.4 GHz for telemetry and control. 

Maximum transmission distance: up to 2,500 ft (outdoors and unobstructed) 

User Manual Location: 

http://3drobotics.com/wp-content/uploads/2015/08/v5_08_21_15.pdf 

Page4 
Given the small size of the UAS and the controlled environment provided the proposed operations will 

adhere to the Reform Act's safety requirements. The approval of this application presents no national 

security issues. Regarding the level of safety surrounding the proposed operations and the public 

benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, 

the grant of the requested exemption is in the public interest. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance 

the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which 

Aviasys, LLC agrees to adhere to when conducting commercial operations under the FAA issued exemption as set 

forth in the company Flight Operations Manual (FOM) include: 

• The UAS will weigh less than 55 lbs. 

The UAS will have a maximum operating speed of no more than 87 knots or 100m ph, or the maximum 

airspeed recommended by the manufacturer (whichever is lowest). 

Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). 

Maximum flight time for each operational flight will be 30 minutes. 

• Flights will be terminated at 20% battery power reserve or 30 minutes of flight time whichever occurs 

first. 

Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not 

more than 200 feet above the highest point on the structure being filmed. 

Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may 

include but not limited to a Camera Operator. 

The UAS pilot/operator will have been trained in operation of sUAS generally and received up to-date 

information on the particular sUAS to be operated. 

• The UAS pilot/operator will have at least a class 2 medical certificate. 

• If the PIC feels another operator to be qualified with the necessary skills to be PIC, that person may be 

designated PIC provided they have a minimum of 20 hours of flight time with the UAS. 

A briefing will be performed regarding the planned UAS operations prior to each day's flight consisting 

of all the days' production activities. All flights will occur under Visual Flight Rules Meteorological 

Conditions (VFR) only. 

• The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport. 

If operations will be within a 5 mile radius of the geographic center/ Airport Reference Point (ARP) of a 

tower controlled or uncontrolled airport the respective airports will be contacted advising them of the 

estimated flight time, flight duration, elevation of flight and other pertinent information. 

• The operator will obtain verbal/written consent of all persons involved with the planned operation and 

ensure that 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 advanced permission of the FSDO, operations at closer range may be 

approved. 

Page 5 
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. 

The PIC and VO will be able to communicate by voice, radio, and/or text at all times. 

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. 

If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the 

capability to return to a pre-determined location within a designated location and land autonomously. 

• The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies. 

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

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. The UAS to be 

operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive 

materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil 

aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the 

requirements and in compliance with local public safety requirements. These safety enhancements provide a greater 

degree of safety to the public and property owners than conventional operations conducted with airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that 

there is no credible threat to national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load. 

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 

6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even 

though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance 

to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size of the UAS, twoinch 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 UAS marked on its fuselage as required by §45.29(f) 

where the pilot, observer and others working with the UAS will see the identification of the UAS as "Experimental." 

Page 6 
14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command. 

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a pilot in 

command of an aircraft that is carrying passengers or property for compensation or hire. The FAA has 

found in previous grants of exemption that a PIC with a private pilot certificate operating a sUAS would 

not adversely affect operations in the NAS or present a hazard to persons or property on the ground. 

Request relief with limitations and conditions specified in this petition. 

14 C.F.R. § 61.133 (b): Commercial pilot privileges and limitations. 

The FAA has found in previous grants of exemption that a PIC with a private pilot certificate operating a 

sUAS would not adversely affect operations in the NAS or present a hazard to persons or property on 

the ground. Request relief with limitations and conditions specified in this petition. 

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 for 

maintenance and use of safety check lists prior to each flight 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 ... (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. The UAS, 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 UAS will have immediate access to it. 

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. The PIC will take all actions as stated in the Aviasys Flight Operations Manual (FOM) 

including but not limited to reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight. 

Page 7 
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 dual controls. UAS 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. 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. 

AVIASYS, LLC has two (2) FAA Airline Transport (ATP) rated Rotorcraft Pilots on staff with current FAA Certified Flight 

Instructor {CFI) ratings who will conduct all flight training through procedures specified in the AVIASYS Flight 

Operations Manual. 

Based on previous decisions made by the FAA for sUAS petitions regarding this regulation, relief is not necessary. 

14 C.F.R. §91.119: Minimum Safe Altitudes. 

As set forth herein, the UAS will never operate at higher than 400 AGL with the exception that in circumstances here 

the UAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be 

operated more than 200 feet above the highest point on the structure. 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. 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 551bs. 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 400ft AGL. In addition, the lowaltitude operations of the UAS will ensure separation between these UAS 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 UAS 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 safety check list and live flight data 

monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 

Page 8 
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." The battery powering the UAS provides approximately 30 minutes of powered 

flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, UAS 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 twilight VFR conditions is 

reasonable. Applicant believes that an exemption from 14 CFR §91.151{a) falls within the scope of prior exemptions. 

Operating the UAS, in a 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 UAS 

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 20% of battery power-whichever 

happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from 

anywhere in its limited operating area. 

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 UAS. An equivalent level 

of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will 

have immediate access to them, to the extent they are applicable to the UAS. 

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 

equivalent level of safety will be achieved because the UAS is very limited in size and will carry a small payload and 

operate only in restricted areas for a limited period 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 

Page 9 
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. An equivalent level of safety will be achieved because maintenance and 

inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the AVIASYS 

UAS Flight Operations Manual; Section 3- Normal Procedures., the operator will ensure that the UAS is in working 

order prior to initiating flight and perform required maintenance needed. 

Additional Information 

The principle directors of Aviasys, LLC are FAA Airline Transport Rated Helicopter Pilots and Certified Flight 

Instructors (CFI) with type ratings on the Sikorsky S-92. Each company director has logged in excess of 4000 

accident and incident free hours of actual flight time and in excess of 1000 hours of Level D simulator experience as 

FAA approved Part 135 check airmen. 

All operations will be conducted I.A.W the AVIASYS Flight Operations Manual which is attached to support this 

application but is considered the intellectual property of Aviasys, LLC and is not for upload, reproduction or 

dissemination without the express permission of Aviasys, LLC. 

Aviasys, LLC shall comply will all criteria provided in Section 333 of the Reform Act of 2012 and trusts that this is 

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

applicant's UAS. 

Thank you for your time and consideration. 

Sincerely, 

Lucas Bardsley 

AVIASYS, LLC 

FAA ATPL(H), FAA CFI, NZCAA CPL(H), CASA CPL(H) 

Page 10