Flite Video LLC 2267 Montecito Court Brentwood, CA 94513

Flite Video LLC

A Look From Above

United States Department of Transportation

Federal Aviation Administration

800 Independence Ave., SW

Washington, DC 20591

Petition for Exemption 

Parts of certain Title 14 CFRs in regards to Section 333 of the

FAA Modernization & Reform Act of 2012 

Concerning Unmanned Aerial Systems (UAS)
Flite Video LLC 2267 Montecito Court Brentwood, CA 94513

TO whom it may concern:

This letter is a request for exemption from a number of Title 14 CFRs that relate to the

commercial operation of “unmanned aerial systems” (UAS). The following will be

included in this request: Name & information of Petitioner; Executive Summary of

Petitioner summarizing the rules Petitioner seeks exemption from and the reasons the

exemptions would serve the public good; Specific Title 14 CFRs to which an exemption

is sought; the extent & reasons for the requested exemptions; reasons why safety would

not be compromised.

Personal Information:

Name:   Thomas Joseph Raniere (hereafter referred to as “Petitioner”)

Company: Flite Video LLC

Address: 2267 Montecito Court

    Brentwood, CA 94513

    (925) 262‐9306

    traniere@att.net

  

The Petitioner was born on February 8, 1947 in Chicago, IL and is a US citizen. He is the

owner/member of Flite Video LLC whose primary clients will be Real Estate Companies in

need of aerial photography and video in the area of Northern California. The Petitioner is a

licensed Air Transport Pilot (1705116) – Airplane Multiengine Land with ratings: B‐727; B‐737;

B‐747; B‐757; B‐767; DC‐9; IA‐Jet; L‐300 – Commercial Privileges: Airplane Single Engine Land

(attached). The Petitioner has owned a Phantom 2 Vision + UAS since 2014 and has flown

over 100 hours as a hobbyist to get proficient in this type aircraft.  

Petitioner is requesting an exemption from the current rules in Section 333 which govern the

uses of UASs for commercial purposes. The Petitioner seeks authorization to perform

commercial UAS operations for Real Estate Inspections, Sales and Advertising. This would

include residential, commercial and rural properties. Prospective customers and clients would

include Real Estate Agents and Brokers along with Insurance Companies, Banks and Private

Property Owners. There has also been interest shown from the Chief of Police in this area to

possibly be on standby if the need arises for my services. This is still being discussed at the

executive level of the department.

The Title 14 CFR exemptions that this request includes are: 61.113(a) & (b); 91.7(a); 91.119(a);

91.121; 91.151(a); 91.407(a)(1)&(2); 91.417(a) & (b). Reasons for each request are cited

below.

Public Good

Aerial videography for geographical awareness and for real estate marketing and

inspections has been around for a long time through manned fixed wing aircraft and

helicopters. But for small business owners, its expense has been cost‐prohibitive.
Flite Video LLC 2267 Montecito Court Brentwood, CA 94513

Granting this exemption to the Petitioner would allow him to provide this service at a

much lower cost. Further, the small UAS being utilized in this application will pose no

threat to the public given its small size and lack of combustible fuel when compared to

larger manned aircraft. The operation of this UAS will minimize ecological damage

and promote economic growth by providing information to businesses & individuals in

the Northern California Area..

Description of UAV to be deployed under requested exemptions.

Petitioner currently owns a DJI Phantom 2 Vision + V3 quad copter. The petitioner intends to

use the Phantom 2 as the primary UAV in commercial applications described herein. The

Phantom 2 is a quad copter that can take off and land vertically. It weighs approximately

3 lbs. and has a maximum airspeed of approximately 25 knots. This UAS uses lithium

polymer batteries which have approximately 20‐25 minutes of total charge time. This

gives this UAS approximately 12‐15 minutes of flight time with sufficient remaining

battery charge to land safely. The particular model of Phantom 2 being utilized under

this request for exemption has First Person View (FPV) which allows the PIC to visually

monitor certain telemetry data on a ground station monitor including altitude (AGL),

GPS signal strength, battery charge information, etc. This FPV also gives the PIC video

feed from the attached Hi‐Definition camera showing what images are being captured. This is

a significant safety feature as it shows the attitude of the UAS and its forward direction.

However, this FPV feature will never be used as a tool to deviate from VLOS operation

by the PIC.

Preflight

The petitioner will always follow procedures outlined in the UAS operator's manual as to

proper preflight inspection of all hardware, software, environment and any other factors

needed to ensure a safe flight. 

FCC Information 

The UAS being deployed here is a DJI Phantom 2 Vision + V 3.0. The Remote Control operates

on a frequency of  5.728 GHz – 5.85 GHz. Published FCC Range is 800 m (2624 ft.) with a

sensitivity of ‐93dbm. 

PIC Qualifications 

As stated above, the petitioner holds a FAA Air Transport Pilot's License with ratings in

multiple commercial/military jet aircraft. Along with the extensive flight experience, the

petitioner was also a FAA Flight Inspection Pilot at NAFEC in New Jersey and an Air Traffic

Controller at both Oakland and Kansas City Centers. The Petitioner was also an Air Carrier

Inspector at the Kansas City ACDO.

Petitioner has owned the UAS described above since 2014 and has over 100 hours in this type

of UAS as a hobbyist. The petitioner envisions being the PIC in all operations that will be

performed under the requested rule exemptions and the subsequent COA request. However,

if another PIC is used for these operations, petitioner agrees that any PIC of the UAS in the

envisioned operations will hold at least a FAA Private pilots’ certificate have no less than 25
Flite Video LLC 2267 Montecito Court Brentwood, CA 94513

hours of PIC time in the UAS being deployed before beginning any type of commercial for hire

operations and conform to all safety protocols.

Description of Intended Commercial Operations 

Petitioner intends to solicit work for aerial real estate inspections from real estate agents

& brokers, insurance companies & related vendors, banks and private property owners

to provide photography and videography of residential, commercial and rural real

estate. This work will always be conducted with the permission of the property owner or

their respective agent. Flight operations will be restricted to flights directly over the

property that has granted permission. Safety will always be the primary concern regarding

any flight at any time.

Petitioner agrees to place a sign during any flight operation that says: CAUTION UNMANNED

AERIAL VEHICLE IN OPERATION. STAY BACK 100 FEET FROM AIRCRAFT.

UAS Operating Parameters

The UAS being deployed in these exemption request can fly at a speed of approximately

25 knots. However, given the intended use describe here, this speed will never be

necessary. Much slower speeds are preferred to collect the photographic material

needed.

Petitioner agrees never to fly UAS outside of VLOS and also agrees to only fly UAS during the

day in VMC conditions at altitudes below 400 feet AGL, clear of clouds.

The UAS will not be operated within 5 nautical miles of an airport reference point as denoted

on a current FAA published aeronautical chart.

The UAS being deployed with these exemption requests has the capability of using GPS

signals to return to its initial point of takeoff if connection with the radio control link is lost.

The Petitioner agrees to yield right of way to all manned aviation activities at all times.

Exemption Requests 

The following are a list of Title 14 CFRs which the petitioner seeks exemption. Please

note that the Petitioner has used Exemption No. 11138 to Douglas Trudeau (Regulatory

Docket No. FAA‐2014‐0481) as a reference. Given that the petitioner and Mr. Trudeau

intend to use the exemptions in similar manners and both use similar equipment, it

seemed prudent not to burden the reviewer in this matter with exemption requests that

have been previously deemed that relief was not necessary. These rules are Part 21,

45.23(b). 91.9(b)(2), 91.103(b), 91.109 and 91.203(a) & (b). If the reviewer believes that

these rules need to be addressed in this request, the petitioner will make a supplemental

request including these additional rule exemptions.

Rule 61.113 - Private Pilot Privileges and Limitations 
Flite Video LLC 2267 Montecito Court Brentwood, CA 94513

The Petitioner hold an ATP with aircraft rating (a copy included in supplemental material).

The Petitioner does not have the need to keep the qualifications of this license current with a

1st. or 2nd. Class medical, but would be willing to keep a 3rd. Class medical certificate current.

This would reduce the limitation of the ATP to be equal to that of a Private Pilot with

appropriate limitations. As to the Private Pilot Limitations concerning operations for hire or

compensation, it seems that Exemption No. 11062 to Astraecus has allowed this exemption

previously and was noted in the Trudeau Exemption No. 11138.

As to airmanship skills, the Petitioner has been operating his UAS since 2014 and has

over 100 hours of flight time. Petitioner currently fly's this UAS several hours a month

as a hobby and is very proficient and has the skills to maintain altitude, maintain VLOS,

navigate, avoid obstacles, avoid air traffic and respond to loss of control link. Petitioner

understands that he must make at least 3 takeoffs and landings within a 90 day period

for currency purposes.

Rule 91.7(a) Civil Aircraft Airworthiness 

There is no current FAA regulatory standard for determining airworthiness of UAS and

there is no certificate currently available for UAS airworthiness. Petitioner seeks an

exemption from this rule by ensuring that the UAS is in an airworthy condition based on

compliance with the operating documents prior to every flight. Flight manuals and other

important documents will be kept in a location readily accessible to the PIC at all times. 

Rule 91.119© Minimum Safe Altitudes 

91.119 prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters

to be operated at lower altitudes in certain conditions. Petitioner seeks an exemption

from this rule as Petitioner will only operate the UAS in a range from ground level up to

but not exceeding 400 feet (AGL) and will only operate in safe areas away from the

public thus providing a level of safety not available to manned aircraft. The petitioner

asserts that given the size, weight, maneuverability and speed of the UAS, an equivalent

or higher level of safety will be achieved that from conventional manned helicopters.

Petitioner will avoid actively populated areas. These areas will be interpreted to include

areas on a FVR chart depicted in yellow and will be supplemented with information

from a F1ights Standard District Office (FSDO). Petitioner intends to operate the UAS

over real estate for inspection purposes.  

Per the exemption granted in No. 11138 concerning 91.119(c), Petitioner agrees to act in

strict accordance to that exemption. However, Petitioner seeks an exemption from the

rule stipulating that a UAS cannot be operated within 500 feet of a structure without

permission of the owner. Given the intended use Petitioner will use these exemptions

for, which is for photography and videography of real estate for marketing & inspection

purposes, agreement from the engaging property owner or their agent is an absolute

necessity. The UAS will only be flown over properties with this permission. However,
Flite Video LLC 2267 Montecito Court Brentwood, CA 94513

given the housing density in the Northern California area, maintaining a 500 foot distance

from other structures even while strictly flying over a permission granting owner's property is

impossible in many instances. The Petitioner seeks an exemption to this rule which

would allow a 50' stand‐off from other structures as long as the UAS is operated

completely over and within the property boundary lines of a permission granting

property owner. Petitioner agrees to always keep privacy rights of other property owners

in mind.

Rule 91.121 Altimeter Settings 

Petitioners' UAS has GPS derived altitude capabilities with a barometric sensor. The

petitioner believes this rule in not applicable to the UAS operations intended.

Rule 91.151(a) Fuel Requirements For Flight in VFR Conditions. 

Petitioner seeks relief from this rule due to the UAS being deployed is battery operated

and the requirements under this rule are not applicable. The UAV in question has First

Person Vision (FPV) capabilities which transmits certain telemetry to a monitor where the PIC

can monitor certain aspects of the flight including battery level. A typical battery for a

Phantom 2 Vision + UAS will last approximately 20‐25 minutes before total exhaustion.

Certain battery level warnings are set where the PIC will know when the battery state is at

30% and 15% remaining charge levels. This will normally allow a flight of 12 ‐ 15 minutes

with sufficient battery charge to make a safe landing. Petitioner will never begin a flight

unless a fully charged battery is used.

Rule 91.405(a) Maintenance Required, 91.407(a) Operation After 

Maintenance, Preventative Maintenance, Rebuilding or Alteration; 

91.409(a)(2) Inspections; 91.417(a)(b) Maintenance Records 

Petitioner seeks relief from these rules due to it being an alternate inspection requirement of

91.409(a)(2). The Petitioner will inspect and ensure UAS is in a condition for safe flight and

adhere to all operating documents.

Supplemental Information 

The Petitioner has provided the following information to support these requests for rule

exemptions and personal identification:

1) Copy of Petitioner’s FAA ATP License, 2) Phantom 2 Vision + Manual V1.4, 3) Petitioner’s

California Driver’s License

Closing

The Petitioner believes that exemption from the above listed Title 14 CFRs is warranted

given Petitioner's background as an Air Transport Pilot, Air Traffic Controller, Air Carrier

Inspector, the nature of the type of UAS flights that will be undertaken, the size & weight of

the UAS being deployed, the safety precautions to the general public and the NAS the

Petitioner intends to adhere to, the positive environmental impact the flight operations
would have compared to manned fuel consuming missions and the economic benefit the 

Petitioner's business would have in this new area of aviation. 

As it appears that this class of flying is and will be getting more popular as the cost of these 

units comes down even further, I would like to also put my name, qualifications and 

experience in the running for a FAA UAS Designee to assist in the certification of new UAS 

operators. I feel that this certification could be accomplished with short NAS written exam 

and short operational hands on flight check with direction from the Certification Division. I 

have discussed this with an Inspector at the Oakland FSDO and said that I would follow up 

when/if I am given the Exemption to operate this as a commercial venture. 

Thank you for your review of this matter. Please feel free to contact me at any time with 

With requests for additional information regarding this matter. 

Thomas J. Raniere 

Flite Video, LLC 

Brentwood, CA 

(925) 917-0641 

Flite Video LLC 2267 Montecito Court Brentwood, CA 94513