Thomas Woska

Avid Research Group Inc.

44 Sherman Drive

Syosset, NY, 11791

csdepot@gmail.com

Federal Aviation Administration:

I am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained 

within 14 C.F.R. 11, to request that AVID RESEARCH GROUP INC. be exempted from the Federal 

Aviation Regulations (“FARs”) listed below so that we may operate the DJI Phantom 2 Vision+ and DJI 

Inspire 1+ UAS's commercially in airspace regulated by the Federal Aviation Administration (“FAA”) in 

accordance with FAA UAS Regulations & Policies.

AVID RESEARCH GROUP INC. would like to formally submit for an exemption from the following 

Section 333 regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 

C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 

14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b). To 

operate DJI Phantom 2 Vision+ and DJI Inspire 1 along the guidelines of the DJI Phantom 2 Vision+ and

DJI Inspire 1 Operator’s manuals. 

About

I have flown small RC electric multirotors for over five (5) years, and have been flying RC aircraft for over 

thirty (30) years. I have also recently completed a 5 day Operator Course given by FlyAmericaFPV

located in State College PA. 

AVID RESEARCH GROUP INC.’s exemption request would permit Commercial operation of ultra light 

weight, unmanned (piloted by remote control) and comparatively inexpensive UAS(s) in tightly 

controlled and limited airspace. 

Commercial operation of an UAS, as described herein, would operate in the following manner: 

 Routine inspections of Power Electric Utility insulators.

 Right-of-Way inspections for Electric Power Utility and Natural and/or Gas petroleum pipeline 

inspection

 Power sub-station inspections.

 Natural Gas pump station inspection. 

 Crop and Agricultural monitoring. 

 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 and cell towers with help of F.L.I.R. (Forward 

Looking Infrared Camera) cameras. 

 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.

The DJI Phantom 2 Vision+ and DJI Inspire 1 were selected because they have proven reliable flying 

capabilities managed by gyro stabilized flight, GPS aided navigation, a compass, blinking LEDs, return to 

home failsafe mode and prop guards. AVID RESEARCH GROUP INC. updates the DJI on board software 

prior to every flight.

AVID RESEARCH GROUP INC. will record flight data and other information gained through permitted 

flight operations to share with the FAA through any required FAA reports to assists with future protocol 

and safety regulations.

Specific section or sections of 14 CFR which AVID RESEARCH GROUP INC. seeks relief and why: 

14 C.F.R. Part 21: Airworthiness Certificates

Given the size and limited operating area associated with the aircrafts to be utilized AVID RESEARCH 

GROUP INC. seeks an exemption from Part 21 meets the requirements of an equivalent level of safety 

under Part 11 and Section 333 of the reform Act. In all cases, an analysis of these criteria demonstrates 

that the UA operated without an airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than conventional aircraft operating with an 

airworthiness certificate without restrictions and conditions proposed.

14 C.F.R. 45.23: Display of marks: general

The UAs will not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to mark certain 

words or phrases. Further, the two inch lettering is difficult to place on such a small aircraft with 

dimensions smaller than the minimal lettering requirement.

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

The FAA has previously declared that additional manned airship experience of a commercially certified 

pilot would not correlate to the airmanship skills necessary for similarly proposed operations in 

previously issued exemptions to this regulation through Exemption Nos. 11062 and 11138.

14 C.F.R 91.7: Civil aircraft airworthiness

Currently, since there is no certificate applicable to the UAs in question, this regulation is inapplicable.

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements 
Requires an aircraft flight manual in the aircraft, however there are no pilots or passengers on board this 

aircraft and given its size, this regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining a safety/flight manual with the operator.

14 C.F.R. 91.119(c): Minimum safe altitudes

AVID RESEARCH GROUP INC. will ensure that UAS do not operate any higher than 200 feet at ground 

level. We will not fly over congested areas. We will plan operations before hand, for proper flight safety, 

and proper height analysis as to avoid any danger.

14 C.F.R. 91.121: Altimeter settings

The UAS utilize electronic GPS with a barometric sensor. An equivalent level of safety will be achieved by 

utilizing this built in feature.

14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions

The UAS that I will fly are powered by electricity, using lithium polymer batteries that currently have a 

flight limit of approximately no more than 20 minutes. Therefore, due to the limitations of the batteries, 

it is currently impossible to comply with part 91.151.

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required

Currently, there are no procedures for providing airworthiness certificates for the mentioned UAS. AVID 

RESEARCH GROUP INC. will always fly safely while having the manuals of the DJI Phantom 2 Vision+ and

DJI Inspire 1. Preflight safety checks are conducted prior to any flight to determine that the UAS is in a 

condition for safe flight (14 CFR § 91.7(b)) and that the planned operation can be completed safely.

14 C.F.R. 91.405(a): Maintenance Required,

14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or alteration,

14 C.F.R. 91.409(a)(1) and (2): Inspections &

14 C.F.R. 91.417 (a) and (b): Maintenance records

Maintenance inspections may be required and should be granted since they only apply to aircraft with 

an airworthiness certificate. However AVID RESEARCH GROUP INC. will perform preflight inspections of 

the UAS before each flight as outlined in the operating documents. AVID RESEARCH GROUP INC. will also 

follow manufacturer recommendations from operating documents.

Public Interest 

The the DJI Phantom 2 Vision+ and DJI Inspire 1+ UAs are battery powered and serve 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 the DJI Phantom 2 Vision+ and DJI Inspire 1 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. The the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography 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.

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Inspire 1 instead of manned 

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial video and still photography flight operations. By using battery power 

and electric motors, the DJI Phantom 2 Vision+ and DJI Inspire 1 produce no air pollution, and is the 

most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion 

engine aircraft that are typically utilized for aerial video and photography, while burning approximately 

20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 Vision+ and DJI Inspire 1 while 

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are 

propelled by battery powered electric motors, rather than an internal combustion engine.

AVID RESEARCH GROUP INC will adhere to the following for the safety of the public.

 Flying below 200 feet 

 Proper visual inspection of UAS before flights

 Preflight safety checks are conducted prior to any flight to determine that the UAS is in a 

condition for safe flight (14 CFR § 91.7(b)) and that the planned operation can be completed 

safely.

 Keeping mentioned UAS in visual sight at all times when in operation 

 Pilot and observer will have been trained in operation of UAS generally and received up-to date

Information on the particular UAS to be operated.

 Using an observer to assist 

 Remain well clear of and do not interfere with manned aircraft operations, and avoid other 

aircraft and obstacles at all times 

 Not intentionally fly over unprotected persons or moving vehicles 

 Contact the airport or control tower before flying within 5 miles of an airport 

 Not flying in adverse weather conditions such as high winds or reduced visibility

 Not flying under the influence of alcohol or drugs 

 Ensure the operating environment is safe 

 Not flying over sensitive infrastructure or property such as power stations, water treatment 

facilities, correctional facilities, etc. 

 Check and follow all local laws and ordinances

 Do not conduct surveillance or photograph persons in areas where there is an expectation of 

privacy without the individual's permission. 

CONCLUSION 
Satisfaction of the criteria provided in Section 333 of the Reform Act of2012 - size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of sight, 

and national security - provides more than adequate justification for the grant of the requested 

exemptions to permit Petitioner to operate the selected UAS vehicles and provide commercial 

photography and video of real estate, agriculture, inspection and artwork.

Granting the requested exemption will benefit the public interest as a whole in many ways, including 

improving safety and reducing risk by alleviating human exposure to danger, improving the quality of 

services and decreasing operating costs compared with conventional flight operations.

Respectfully, 

Thomas Woska

Avid Research Group Inc.

44 Sherman Drive

Syosset, NY, 11791