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 withi n 14 C.F.R. 11, to request that AVID RESEARCH GROUP INC. be exempted from the Federal Aviation Regulations (“FARs”) listed be low so that we may operate the DJI Phantom 2 Vision+ and DJI Inspire 1 + UAS's commercially in airspace regulated by the Federal Aviation Administrat ion (“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+ a nd 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 inexpe nsive UAS(s) in tightly controlled and limited airspace. Commercial operation of an UAS, as described herein, would ope rate in the following manner:

 Routine inspections of Power Electric Utility insulators.
 Right-of-Way inspections for Electric Power Uti lity 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, architect ure, land surveying, engineering and other rel ated professional activities.
 Aerial video and/or photography for public and/or private use including television, public events, cinem atography and news gathering. Aerial inspection/photography of residential/commercial structures under contract with the

owners o r 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 Loo king 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 re quested. The DJI Phantom 2 Vision+ and DJI Inspire 1 were selected because they have proven reliable flying capabilities manage d by gyro stabilized flight, GPS aided navigation, a compass, blinking LEDs, return to home failsafe mode and prop guards. AVID R ESEARCH 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 secti on 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 restri ctions 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 dimens ions 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, t his regulation is inapplicable. 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirementsRequires an aircraft flight manual in the aircraft, however there are no pilots or passengers on boa rd 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 t hat UAS do not operate any higher than 2 00 feet at ground level . We will not fly over congested areas. We will plan operations before hand, for proper flight safety, and proper height a nalysis 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 Requiremen ts for flight in VFR conditions The UAS that I will fly are powered by electr icity, 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 impossi ble 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
. P reflight 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. 91.4 09(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 onl y apply to aircraft with an airworthiness certificate. However AVID RESEARCH GROUP INC. will perform preflight inspections of the UAS before each flight as outlined i n the operating documents. AVID RESEARCH GROUP INC. will also follow manufacturer recommen dations 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 wel l 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 theNAS, 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 durin g 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 leve ls 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 enviro nmentally 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 adh ere to the following for the safety of the public.

 Flying below 200 feet
 Proper visual inspection of UAS before flights
 P reflight 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 i s an expectation of privacy without the individual's permission. CONCLUSIONSatisfaction 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, agric ulture, 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