January	5,	2016

U.S.	Department	of	Transportation	

Docket	Management	System	

1200	New	Jersey	Ave,	SE	

Washington,	DC	20590	

Re:	Exemption	request	pursuant	to	Section	333	of	the	FAA Reform	Act	and	specified	parts	under	14	

CFR,	the	Federal	Aviation	Regulations	

To	Whom	It	May	Concern:

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

CFR	Part	11,	R.G.A.	Views,	an	"operator"	of	Unmanned	Aircraft	Systems	("UAS")	for	aerial	photography	

and	videography,	hereby	applies	for	an	exemption	{see	list	of	exemptions	below)	from	the	listed	

Federal	Aviation	Regulations	("FARs")	to	allow	commercial	operation	of	its	UAS	platforms	in	the	

National	Airspace	System	("NAS").	

This	application	is	submitted	by:

Company:	BuzzSloth,	LLC	DBA	R.G.A.	Views

Owner/Operators:	Grant	Austin,	Katelyn	Cook

Address:	2665	Burton	St,	Grand	Rapids,	MI,	49546

Email: Gaustin14@gmail.com

The	following	are	the	sections	of	14	CFR	from	which	we seek	an	exemption:

14	C.F.R.	21 14	C.F.R.	91.9(b)(2) 14	C.F.R.	91.203	(a)	and	(b)

14	C.F.R.	45.23(b) 14	C.F.R.	91.103	 14	C.F	.R.	91.205

14	C.F.R.	61.113(a)	and	(b) 14	C.F.R.	91.119 14	C.F.R.	91.215

14	C.F.R.6l.133(a)	and	(b) 14	C.F.R.	91.121 14	C.F.R.	91.405	(a);	407	(a)	

(1);	409	(a)	(2);	417(a)	&	(b)

14	C.F.R.	91.7(a) 14	C.F.R.	91.121

The	extent	of	relief	we	seek	and	the	reason	we	seek	the	relief:	

Commercial	operation	of	a	small	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	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.

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."	

How	our	request	would	benefit	the	public	as	a	whole:	

Granting	R.G.A.	Views our	request for	exemption	will	allow	for	local	services	such	as	real	estate	and	

marketing,	and	will	allow	growth	for	the	local	economy.	There	is	a	shortage	of	certified	individual(s)	

and	companies	that	provide	aerial	photography	and	videos	in	the	area,	thus	driving	up	the	cost	for	

such	services	- making	it	cost	prohibited.	The	UAS	platform	for	R.G.A.	Views provides	a	safe	and	cost	

effective	method	for	the	local	economy	to	showcase	its	greatest	assets.	

Reasons	why	the	exemption	would	not	adversely	affect	safety,	or	how	the	exemption	would	provide	

a	level	of	safety	at	least	equal	to	the	existing	rule:	

The	high	standards	and	regards	to	safety	of	R.G.A.	Views will	provide	the	benchmark	for	local	

competition	and	will	drive	for	safer	options	to	a	much-needed	service	in	this	geographical	area.	The	

selected	UAS	platform	has	many	safety	measures	in	place	that	will	significantly	lower	the	risk	of	safety	

related	incidents	- from	the	heightened	operator	awareness	to	the	engineered	safety	features.	

The	operating	limitations	proposed	by	R.G.A.	Views provide	for	a	higher	level	of	safety	because	UAS	

operations	further	enhance	safety	of	aerial	photography	operations	over	using	conventional	aircraft.	

These	limitations	and	conditions	to	which	R.G.A.	Views agrees	to	be	bound	when	conducting	

commercial	operations	under	an	FAA	issued	exemption	include:

o Operator	Awareness

o Pre-flight	Checklist

§ Ensure	that	you	are	using	only	genuine	parts	and	that	all	parts	are	in	mint	

condition.

§ Ensure	the	remote	controller,	Intelligent	Flight	Battery,	and mobile	device	

are	fully	charged.

§ Ensure	that	there	is	no	foreign	object	stuck	to	the	camera	lens,	the	micro-SD	

card	has	been	inserted	into

§ The	camera,	and	the	gimbal	can	rotate	freely	before	powering	it	on.

§ Ensure	the	propellers	are	securely	mounted	on	to the	motors,	and	the	

motors	can	start	and	function	normally.
§ Follow	the	on-screen	instructions	to	calibrate	the	compass.

§ Ensure	the	DJI	Pilot	app	and	aircraft's	firmware	have	been	upgraded	to	the	

latest	version.

§ Ensure	that	your	flight	area	is	outside	the	No-Fly	Zones	and	flight	conditions	

are	suitable	for	flying	the	aircraft.

§ Be	sure	that	you	are	NOT	flying	under	the	influence	of	alcohol,	drugs	or	any	

substance	that	may	impair	your	cognitive	abilities.

§ Be	familiar	with	the	selected	flight	mode	and	understand	all	safety	functions	

and	warnings.

§ Be	sure	to	observe	all	local	regulations,	obtain	appropriate	authorizations,	

and	understand	the	risks.

o Fly	the	aircraft	only	within	line	of	sight;	pilot	in	command	(PIC)	and/or	visual	

observer	(VO)

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

times.

§ Respective	airports	will	be	contacted	if	operating	within	5	miles	of	an	airport	

to	be	granted	permission	to	enter	air	space.

§ Submission	to	the	controller's	safety	warnings	and	alarms.	(Such	as	power	

warnings,	calibration	needs	and	connection	errors)

§ Flights	will	be	operated	at	an	altitude	of	no	more	than	400	ft.	above	ground	

level.

§ Under	still	air	the	maximum	speed	is	no	more	than	3.5mph	with	a	cruising	

speed	of	25mph.

o The	DJI	Phantom	3	Professional's	Engineered	Safety	Features:	(The	following	is	from	the	

Phantom	3	Professional	User	Manual)

o Maximum	Speed	of	35mph

o Weight	of <	3	lbs.

o Maximum	flight	altitude	limit	capability.

o Maximum	flight	range	limit	capability.

§ If	you	fly	out	of	the	limit,	you can	still	control	the	Phantom	3,	but	cannot	fly	it	

any	farther.	If	the	Phantom	3	flies	out	of	the	max	radius	in	Ready	to	Fly	

(11011-GPS)	mode,	it	will	fly	back	within	range	automatically.

§ If	the	Phantom	3	flies	out	of	the	max	radius	in	Ready	to	Fly	(non-GPS)	mode,	

it	will	fly	back	within	range	automatically.

§ The	software	prohibits;	flight	in	"no-fly	zones".	Motors	will	not	start	and	

warning	will	notify	pilot	that	take	off	is	prohibited.

o Return	to	Home	(RTH)	function	- brings	the	aircraft	to	the	last	recorded	home	point.

§ Smart	RTH	- button	on	controller	to	bring	aircraft	home.

§ Low	Battery	RTH	- the	RTH	feature	is	automatically	triggered	when	the	D.H	

Intelligent	Flight	Battery	is	depleted	to	a	point	that	may	affect	the	safe	return	

of	the	aircraft.

§ Failsafe	RTH	- the	RTH	feature	is	automatically	activated	if	the	remote	

controller	signal	is	lost for	more	than	3	seconds.

o Vision	Positioning	System	(VPS)
§ With	the	use	of	ultrasound	and	image	data,	the	aircraft	is	able	to	maintain	its	

current	position.	This	will	allow	for	the	aircraft	to	hover	in	place	more	

precisely	where	a	GPS	signal	is	not	available.

o DJI	Intelligent	Flight	Battery	Functions

§ Battery	level	display

§ Battery	life	display

o DJI	Phantom	3	Professional	(same	UAS	as	in	Granted	Exception	No.	11911)

o General	Features

§ Ready	to	fly

§ 3-axis	camera	stabilization

§ Precision	flight	and	stable	hovering

§ GPS/GLONASS	positioning	&	auto	return	home	Onscreen	real-time	flight	

parameters

§ High	Definition	4k	Camera

§ Camera	tilt	control	

§ Film	straight	down	

§ Supports	Adobe	DNG	RAW

§ Adobe	lens	profile	support

§ Camera	parameter	settings

§ Album	synchronization

§ FAA	no-fly	zones	locked	out	via	installed	software

o Transmitter

§ Operating	Frequency:	2.400	GHz	- 2.483	GHz

§ Communication	Distance	(open	area):	CE:	2000m;	FCC:	2000m

§ Receiver	Sensitivity	(1%PER):	-101dBm	+/- 2dBm

§ Transmitter	Power:	CE:	16dBm;	FCC:	20dBm	

§ Working	Voltage:	1.2A@	7.4V	

§ Battery:	6000	mAh	LiPo	2s

o Camera

§ Operating	Environment	Temperature:	0°C-40°C

§ Max	Resolution:	4096	x	2162p	@	24/25fps

§ Sensor	size:	1/2.3"

§ HD	Recording:	4k	p	24/25fps	/	720p	60fps

o DJI	Vision	App

§ System	Requirement	of	Mobile	Device:	iOS	version	6.0	or	above/	Android	

system	version	4.0	or	above

§ Mobile	Device	Support:	Recommended:	iPhone4s,	iPhone5,	iPhone5s,	iPod	

Touch4,	iPod	Touch;

Given	the	specifications	of	the	UAS	platform,	engineered	safety	features	and	operator	awareness	

check	list,	the	approval	of	this	application	presents	no	national	security	issues.	Regarding	the	impact	to	

the	public	and	the	safety	protocols	in-place,	R.G.A.	Views requests	your	approval	with	minimum	delay.	

Explanations	of	Requested	Exemptions
• 14	C.F.R.	21:	Certification	Procedures	for	Products	and	Parts.

o This	regulation	is	designed	for	manned	aircraft.	It	is	not	suitable	for	the	UAS	Platform	of	

R.G.A.	Views.	This	regulation	is designed	for	manned	aircraft.	It	is	not	suitable	for	offthe-shelf	or	production	UAS.	All	parts	come	from	the	manufacturer.	Substantive	

replacement	parts	(i.e.	motors,	propeller	blades,	radio	transmitters,	etc.)	also	come	

from	the	manufacturer	or	an	authorized	vendor	with	approved	after-market	

components	and	will	ensure	correct	equipment	is	used	to	replace	substantive	parts	of	

the	UAS	craft.

• 14	C.F.R.	45.23(b):	Display	of	Marks;	general.

o Even	though	the	UAS	will	have	no	airworthiness	certificate,	an	exemption	will	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,	two-inch	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."

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

o R.G.A.	Views can	achieve	an	equivalent	level	of	safety	as	achieved	by	current	regulations	

because	our	UAS	does	not	carry	any	pilots	or	passengers.	Further,	while	helpful,	a	pilot	

license	will	not	ensure	remote	control	piloting	skills.	The	risks	attended	to	the	operation	

of	our UAS	is	far	less	than	the	risk	levels	inherent	in	the	commercial	activities	outlined	in	

14	C.F.R.	61,	et	seq.	Thus,	allowing	us	to	operate	our	UAS	to	meet	and	exceed	current	

safety	levels	in	relation	to	14	C.F.R.	61.113	(a)	&	(b).

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

o R.G.A.	Views can	achieve	an	equivalent	level	of	safety	as	achieved	by	current	regulations	

because	our	small	UAS	does	not	carry	any	pilots	or	passengers.	Further,	while	helpful,	a	

pilot	license	will	not	ensure	remote	control	piloting	skills.	The	risks	attended	to	the	

operation	of	my	small UAS	is	far	less	than	the	risk	levels	inherent	in	the commercial	

activities	outlined	in	14	C.F.R. 61,	et	seq.	Thus,	allowing	us	to	operate	our	small	UAS	to	

meet	and	exceed	current	safety	levels	in	relation	to	14	C.F.R.	61.133	(a)	&	(b).

• 14	C.F.R.	91.7(a):	Civil	Aircraft	Airworthiness.

o 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.

o Given	the	size	of	the	aircraft	for	maintenance	and	use	of	safety	checklists	prior	to	each	

flight	an	equivalent	level	of	safety	will	be	provided.
• 14.F.R.	91.9	(b)	(2):	Civil	Aircraft	Flight	Manual	in	the	Aircraft.

o The	need	to	have	an	aircraft	manual	on	board	does	not	apply.	UAS	aircraft	information	

manuals	will	be	kept	by	the	operator.

• 14	C.F.R.	91.103:	Preflight	action.

o 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	manufacturer	FOM	in	the	pre-flight	inspection	section,	including	but	not	

limited	to	reviewing	weather,	flight	battery	requirements,	landing	and	takeoff	distances	

and	aircraft	performance	data	before	initiation	of	flight.

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

o 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	UAS	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,	the	UAS	will	never	operate	at	

higher	than	400	AGL	with	the	exception	that	in	circumstances	where	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.

• 14	C.F.R.	91.121:	

o 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.

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

o 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	...	"

o The	battery	powering	the	DJI	Phantom	3	Professional	UAS	provides	approximately	20	

minutes	of	powered	flight.	Operations	would	be	impossible	to	conduct	in	order	to	meet	

the	30-minute	reserve	requirement	in	14	CFR	91.151.	Given	the	limitations	on	the	UAS's	

proposed	flight	area,	its	proposed	flight	time,	and	proposed	operations	within	a	

predetermined	location,	14	CFR	91.151	is	inapplicable. Furthermore,	operating	the	UASs	

in	a	tightly	controlled	area	where	only	people,	property	owners,	and/or	official	
representatives	will	be	allowed,	less	than	30	minutes	of	reserve	fuel	does	not	endanger	

the	type	of	risk	that	91.151	was	intended	to	address.

o The	owner/operator	of	R.G.A.	Views affirms	that	safety	can	be	achieved	by	limiting	

flights	to	end	with	a	25%	battery reserve	as	indicated	on	the	PIC's	controller	mounted	

monitor.	This	restriction	would	be	more	than	adequate	to	return	the	UAS	to	its	

predetermined	landing	area.

• 14	C.F.R.	91.203	(a)	and	(b):	Carrying	Civil	Aircraft	Certification	and	Registration.

o The	UAS	fully	loaded	weighs	no	more	than	55	lbs.	and	is	operated	without	an	on	board	

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.	91.205:	Powered	civil	aircraft	with	standard	category	U.S.	airworthiness	certificates:	

Instrument	and	equipment	requirements.

o Section	91.205	pertains	to	cockpit	instruments	for	manned	aircraft	occupied	by	at	least	

one	pilot.	This	is	not	applicable	to	UAS.	However,	to	ensure	an	equivalent	level	of	safety	

and	information,	transmitted	telemetry	will	be	sent	to	the	PIC	and	displayed	on	a	video	

screen	indicating	various	parameters	including,	but	not	limited	to,	GPS	altitude,	GPS	

signal,	battery	power	remaining,	time	in	flight,	UAS	ground	speed,	etc.

• 14	C.F.R.	91.215:	ATC	transponder	and	altitude	reporting	equipment	and	use.	

o The	UAS	craft	will	have	insufficient	useful	load	and	power	supply	to	operate	a	

transponder.	Furthermore,	operations	offered	by	the	blanket	COA	will	occur	below	ATC	

radar	coverage.	To	ensure	an	equivalent	level	of	safety,	when	operations	exist	near	a	

public	airport,	the	operator	will	notify	the	local	airport	or	ATC	facility	to	advise	them	of	

the	operation.	If	operations	exist	in	an	area	not	covered	by	the	blanket	COA,	then	a	

specific	COA	for	that	operation	will	be	obtained	by	the	local	FSDO	and	specific	case-bycase	coordination	with	ATC	will	be	made	for	the	UAS	flight.

• 14	C.F.R.	91.405	(a);	407	(a)	(1);	409	(a) (2);	417(a)	&	(b):	Maintenance	Inspections.

o 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.

o Given	that	these	section	and	Part	43	apply	only	to	aircraft	with	an airworthiness	

certificate,	these	sections	will	not	apply	to	the	applicants. 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	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.