DronzView 423­506­7854

9 June 2015

Dear Sir or Madam,

Pursuant to § 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14

C.F.R. Part 11, DronzView, operator of Small Unmanned Aircraft Systems (sUAS)

equipped to conduct aerial filming and photographing to include: infrastructure inspections,

aerial acquisition (mapping), real estate, and other applicable areas for pre­planned, controlled

areas, hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to

allow commercial operation of its sUASs, so long as such operations are conducted within and

under the conditions outlined herein or as may be established by the Federal Aviation

Administration (FAA) as required by § 333. DronzView current operation of sUAS for

commercial purposes has been halted to comply with recently enacted federal aviation

regulations pertaining to sUAS. As described more fully below, the requested exemption would

permit the operation of small, unmanned and quad copter aircraft under controlled conditions in

airspace that is 1) contained 2) predetermined 3) has on­site safety personnel controlling

access, and 4) would provide increased safety and enhancements to clients' business

operations. We are prepared to modify or amend any part of this request to satisfy the need for

an equivalent level of safety. We look forward to working with your office. Please contact us at

any time if you require additional information or clarification.

The name and address of the applicant is:

DronzView,

Joseph I Cullen

CEO

Phone: 423­506­7854

Email: joseph.ian.cullen@gmail.com

Address: 380 Co Rd 252, Athens TN, 37303

MY BACKGROUND

DronzView, is a small company in operated by only me and father a real estate appraiser that

helped me see the potential in aerial photography. I have always been an avid RC operator and

video editor and never did i think the two could come together in such a way.

DronzView currently operates two DJI phantom 2 quad copters equipped with GoPro camera's.
HOW OUR COMPANY CAN BENEFIT THE PUBLIC

The exemption request will permit DronzView to operate sUASs commercially

for the purpose of aerial filming and photographing inspections of infrastructure, aerial

acquisition (mapping), real estate, and other applicable areas. DronzView will

provide a service that will change the way we view things, sUAS This will benefit the public

with the controlled operation of sUASs and increase integration into the National Airspace

System (NAS).

DronzView sUASs 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 sUAS 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.

PUBLIC SAFETY

DronzView's number one priority will be the safety of the public our operators will always have a

spotter to insure line of sight and only fly in the safest possible weather conditions. Our mission

is to use these devices for the greater good of everyone as a whole which includes making sure

the operation of these "drones" is safe.

PRIVACY

All flights will occur over private or controlled access property with the property owner’s or

controlling authority’s prior consent and knowledge. Aerial photography/filming will be of

people who have also consented to being photographed or otherwise have agreed to be in the

area where filming will take place.

CONDITIONS AND LIMITATIONS:

As set forth in the Flight Operations and Procedures Manual (FOPM) and Manufacturers Pilot

Training Guide (MPTG), the applicant proposes the following limitations and conditions:

1. UAS must weigh less than 55 pounds;

2. UAS airspeed not to exceed 50 knots;

3. UAS flights may not operate at more than 400 AGL and Altitudes reported to ATC must

be in feet AGL;

4. UAS must be operated within Visual Line of Sight (VLOS) of the PIC;

5. All operations will utilize a Visual Observer (VO). The VO may be utilized as long as the

PIC maintains VLOS capability and can communicate with the VO at all times;

6. The conditions and limitations will be added or amended in the operator’s manual;

7. The PIC will inspect the UAS to ensure it is safe for flight, along with the Ground Control

Station (GCS) if utilized. All maintenance and alterations must be properly documented.

8. A functional test flight must be performed for any UAS that has undergone maintenance

or alterations and be performed by the PIC and added to the operator’s manual;

9. The operator must follows the manufacturer’s UAS aircraft/component, maintenance,

overhaul, replacement inspection and life limit requirements.
The following must be included in the operator’s manual;

a. Actuators / Servos;

b. Transmission (single rotor);

c. Power plant (motors);

d. Propellers;

e. Electronic speed controller;

f. Batteries;

g. Mechanical or dynamic components (single rotor);

h. Remote command and control;

i. Ground control station (if used); and any other component(s) as determined by

THE OPERATOR.

10. The PIC must possess a private pilot certificate, a current third­class medical certificate

and meet the flight review requirements specified in 14 CFR § 61.56;

11. A PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51

(b), a minimum of 200 flight hours and 25 hours as a UAS rotorcraft pilot and at least ten

hours logged as a UAS pilot with a similar sUASs type;

12. A PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51

(b), a minimum of five hours as a sUAS pilot operating the make and model of sUAS to

be utilized for operations under the exemption and three takeoffs and three landings in

the preceding 90 days. The PIC must operate the sUASs with appropriate distance from

nonparticipants in accordance with 14 CFR § 91.119;

13. The PIC and VO must have completed a qualification process;

14. A flight demonstration, administered by an operator approved and a qualified pilot must

be completed and documented in accordance with the operator’s manual;

15. The sUASs may not be operated directly over any person, except authorized and

consenting inspection personnel, below an altitude that is hazardous to persons or

property;

16. All participating persons must be essential and consent to the UAV operation which

should require no further FSDO or ASI approval;

17. The operator must ensure that no persons are allowed within 500 feet of the area

except those consenting to be involved and who are necessary for the on­going

operation of the entity being inspected;

18. If the UAS loses communications or loses its GPS signal, the UAS must return to a

predetermined

location within the security perimeter and land or be recovered in

accordance with the operator’s manual;

19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operator’s manual;

20. Each operation must be completed within 30 minutes flight time or with 25% battery

power remaining, whichever occurs first;

21. The operator must contain an Air Traffic Organization (ATO) issued Certificate of Waiver

or Authorization (COA) prior to conducting any operations under this 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 no less than 48 hours prior to the

operation;

22. All aircraft operated in accordance with this exemption must be identified by serial

number, registered in accordance with 14 CFR part 47and have identification (NNumber)

markings in accordance with 14 CFR part 45, Subpart C. Markings must be as

large as possible;

23. The operator must develop procedures to document and maintain a record of the UAS

maintenance, alterations, status of replacement/overhaul component parts, and the

total time in service of the UAS;

24. Each UAS operated under this exemption will comply with all manufacturing safety

bulletins;

25. The operator will develop UAS technician qualification criteria. And the criteria will be in

the operator’s manual;

26. The pre­flight inspections section of the operator’s manual will include the requirement

that the pre­flight inspection will account for all discrepancies, i.e. inoperable

components, items, or equipment;

27. Before conducting operations, the radio frequency spectrum used for operation and

control of the UA will comply with the FCC or other appropriate government oversight

agency requirements;

28. At least three days before a scheduled inspection the operator of the UAS affected by

this exemption will submit a written plan of activity to the local FSDO with jurisdiction

over the area of the proposed inspection. The 3­day notification may be waived with the

concurrence of the FSDO. The plan of activities will include the following:

a. Dates and times for all flights

b. Name and phone number of the operator for the sUASs inspection conducted

under this grant of exemption

c. Name and phone number of the person responsible for the on­site operation of

the UAS

d. Make, model, and serial or N­number of UAS to be used

e. Name and certificate number of UAS PIC s involved in the inspection process

f. A statement that the operator has obtained permission from property owners

and/or local officials to conduct the inspection; the list of those who gave

permission shall be made available to the inspector upon request

g. Signature of exemption­holder or representative

h. The description of the flight activity, including maps or diagrams of any area,

city, town, county, and/or state over which the inspection will be conducted and

the altitudes essential to accomplish the operation

i. The documents required under 14 CFR §§91.9 and 91.203 must be available to

the PIC at the ground control station of the sUASs any time the aircraft is

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

any law enforcement official upon request.
29. The UAS must remain clear and yield the right of way to all other manned operations

and activities at all times (including, but not limited to ultra­light vehicles, parachute

activities, parasailing activities, hand gliding, etc.);

30. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1 All

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

under special visual flight rules (SVFR) are not authorized;

31. The UAS cannot be operated by the PIC from any moving device or vehicle;

32. The UAS may not be operated less than 500 feet below or less than 2000 feet

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

33. The UAS may not be operated in class B, C, or D airspace without written approval from

the FAA. The UAS may not operate within 5 nautical miles of the geographic center of a

non­towered airport as denoted on a current FAA­ published aeronautical chart unless a

letter of agreement with the 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;

34. Any I) Incident, 2) Accident, or 3) Flight operation that transgresses the lateral or vertical

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

to the Federal Aviation Administration's (FAA) UAS Integration Office (AFS­80) within 24

hour. Accidents must be reported to the National Transportation Safety Board (NTSB)

per instruction contained on the NTSB 'web site: www.ntsb.gov. Further flight

operations may not be conducted until the incident, accident, or transgression is

reviewed by the A FS­80 and authorized to resume operations is provided;

35. The UAS, PIC and operator will comply with all applicable parts of 14 CFR including, but

not limited to, parts 45, 47, 61, and 91.

REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED:

14 CFR Part 21

14 CFR 61.113 (a) & (b)

14 CFR 61.133 (a)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.109 (a)

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

14 C.F.R. 21: Certification Procedures for Products and Parts
This section outlines requirements for the issue of design and production

approvals, airworthiness certificates, and other airworthiness approvals. DronzView

is aware that if an exemption is granted as per Section 333, an

airworthiness certificate would be issued and a request for exemption from Part 21 is

unnecessary. However, as outlined in the List of Limitations and Conditions in this

application, as well as all of the Attachments to this application, including the FOPM,

DronzView seeks to uphold the same level or exceeded level of safety

as described in Part 21 of 14 C.F.R.

14 C.F.R. § 61.113 (a) & (b), 61.133 (a): Private Pilot Privileges and Limitations: Pilot in

Command. Commercial Pilot Privileges and Limitations.

Sections 61.113 (a) & (b) limit private pilots to non­commercial operations.

Because the UAS will not carry a pilot or passengers, the proposed operations can

achieve the equivalent level of safety of current operations by requiring the PIC

operating the aircraft to have a private pilot’s license rather than a commercial pilot’s

license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and

passengers, the sUAS is remotely controlled with no living thing on board. The area of

operation is controlled and restricted, and all flights are planned and coordinated in

advance as set forth in the FOPM. The level of safety provided by the requirements

included in the FOPM exceeds that provided by a single individual holding a commercial

pilot’s certificate operating a conventional aircraft. The risks associated with the

operation of the sUAS are so diminished from the level of risk associated with

commercial operations contemplated by Part 61 when drafted, that allowing operations

of the sUAS as requested with a private pilot as the PIC exceeds the present level of

safety achieved by 14 C.F.R. §61.113 (a) & (b).

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 and the requirements contained in the

FOPM 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 sUAS, 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.

14 C.F.R. § 91.109 (a): FLIGHT INSTRUCTION

Section 91.109 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.

14 C.F.R. § 91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section

91.119 (d) allows helicopters to be operated at less than the minimums prescribed,

provided the person operating the helicopter complies with any route or altitudes

prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter

and the exemption requests authority to operate at altitudes up to 400 AGL, or not

more than 200 above an elevated platform from which filming is planned, an exemption

may be needed to allow such operations. As set forth herein, except for the limited

conditions stated in the Manual, the UAS will never operate at higher than 400 AGL. It

will however be operated in a restricted area with security perimeter, where buildings

and people will not be exposed to operations without their pre­obtained consent. The

equivalent level of safety will be achieved given the size, weight, speed of the sUASs as

well as the location where it is operated. 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 activity, all affected individuals will be aware of the

planned flight operations as set forth in the FOPM.

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 sUAS may

not have a barometric altimeter, but instead a GPS altitude read out, an exemption is

needed. An equivalent level of safety will be achieved by the operator, pursuant to the

FOPM and Safety Check list, confirming the altitude of the launch site shown on the GPS

altitude indicator before flight.

14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions

This regulation 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 sUAS provides approximately 40 minutes of powered flight. To

meet the 30 minute reserve requirement in 14 CFR § 91.151, sUASs 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 night VFR conditions is reasonable.

Limiting sUAS flights to 10 minutes would greatly reduce the utility for which the

exemption will be granted.
An equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of

battery power whichever happens first. This restriction would be more than adequate to

return the sUAS 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 sUAS 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 sUAS. An equivalent level of safety will be

achieved by keeping these documents at the ground control point where the pilot flying

the sUAS will have immediate access to them, to the extent they are applicable to the

sUAS.

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 FOPM. An equivalent level of

safety will be achieved because these small UASs are very limited in size and will carry a small

payload and operate only in restricted areas for limited periods of time. If mechanical

issues arise the sUAS can land immediately and will be operating from no higher than

400 feet AGL. As provided in the FOPM, the operator will ensure that the sUAS is in

working order prior to initiating flight, perform required maintenance, and keep a log of

any maintenance performed. Moreover, the 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.

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

DronzView submits that grant of this exemption application advances the

Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of UASs

into the NAS if it can be accomplished safely. This law directs the Secretary of Transportation to

consider whether certain UASs may operate safely in the NAS before completion of the

rulemaking required under Section 332 of the Reform Act. In making this determination, the

Secretary is required to determine which types of UASs do not create a hazard to users of the

NAS, the public, or pose a threat to national security in light of the following:

● The UAS’s size, weight, speed, and operational capability;
● Operation of the UAS in close proximity to airports and populated areas; and

● Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a) (1). If the Secretary determines that such vehicles “may operate safely in

the national airspace system, the Secretary shall establish requirements for the safe operation

of such aircraft in the national airspace system.” Id. § 333 (c).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §

40101 of the Act, from the requirement that all civil aircraft must have current airworthiness

certificate and those regulations requiring commercial pilots to operate aircraft in commercial

service:

The Administrator may grant an exemption from a requirement of a regulation

prescribed under subsection (a) or (b) of this section or any of sections 4470244716 of

this title if the Administrator finds the exemption is in the public interest.

The grant of the requested exemption is in the public interest based on the clear direction in

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended;

the strong equivalent level of safety surrounding the proposed operations; and the significant

public benefit, including enhanced safety and cost savings associated with use of UASs for

aerial

videography/photography, the reduction or elimination of unregulated operators, and the safe

integration of UASs. Accordingly, the applicant respectfully requests that the FAA grant the

requested exemption without delay.

CONCLUSION

As set forth herein, DronzView seeks an exemption pursuant to 14

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 from the

requirements of 14 CFR § 21; 61.113 (a) & (b); 61.133 (a); 91.7 (a); 91.9 (b); 91.109 (a); 91.119

(c); 91.121; 91.151 (a); 91.203; 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.417 (a) & (b), which

will permit safe operation of the sUASs commercially, without an airworthiness certificate, for

the limited purpose of conducting aerial imagery over small, defined operational areas of the

United States.

Approval of the exemption allowing commercial operations of DronzView

sUASs will increase safety by permitting an operator to conduct a service safely by adhering

to the prescribed guidelines. The exemption will also encourage the education of sUAS

operators and the adoption of FAA guidelines and approval for commercial sUAS operations as

pertains to DronzView employees and contractors. It will allow DronzView to provide a service

that

benefits the public and local businesses. It benefits the public through a higher level of safety of

sUAS

operations and through a smooth integration of sUASs into the NAS. Having a pilot owned

business bridges the

gap between the advancement of sUAS technology and the current practices and operations in

the NAS and with the
FAA. This assists the FAA with its mission of promoting aviation while preserving safety of

aviators, the

public, and property. The sUASs operated by DronzView satisfies the criteria set

forth in § 333 of the Reform Act–size, weight, speed, operating capabilities, operation within

visual line of sight, and national security–and showing an equivalent level of safety to manned

aircraft flights through appropriate pilot certification and safety focused standards of operation,

providing more than adequate justification for the grant of the requested exemptions allowing

commercial operations.

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 DronzView to safely, efficiently, and economically

operate the sUASs commercially within the NAS.

Kind Regards,

Joseph I Cullen

CEO