August 15 , 2015

US Department of Transportation submitted electronically to : www.regulations.gov Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590



### Subject: Overview Solutions , MA

- Section 333 Exemption Petition ; Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 61.113(a)&(b);91.7(a);91.9(b)(2);91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 9 1.407(a)(1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam:

Overview Solutions (OS) , Inc. , seeks exemption pursuant to FAA Modernization and Reform Act of 2012 and the procedures contained within 14 Code of Federal Regulations ( CFR ) 11, from

the Federal Aviation Regulations (FARs) listed below so that OS may operate our small

ultra

- light weight unmanned aircraft system ( s UAS ) commercially in airspace regulated by the Federal Aviation Administrator (FAA). This petition is, in most regards, similar to

gran ted exemption No’s. 12444, 12389, 11569, 11544, 11327, and 11299 both in operation approach (closer than 500 feet ) and parallels to some of the equipment being us ed (3DR

Aero

- M ).

As described herein OS proposes to perform aerial still photography with the use of common professional s UAS equipment , presently a 3DR Aero

- M Fixed Wing aircraft, mostly for geologic al

, biological

, and botanical survey purposes and construction monitoring.

OS ’s exemption request would permit operation of ultra

- light weight, unm anned

, s UAS in small portions of semi

- rural airspace using tightly controlled and limited duration flight plan s

.

OS will provide a two

- person team during flight times , including an operator ; pilot in command

, and a visual observer ; ground station operator

.

• Harrison Hummel, OS ’s Photogrammetry Specialist and GIS Technician, will provide either

op erator or visual observer tasks pre mission planning and post mission GIS and aerial data analysis. Mr. Hummel is working toward obtaining his pilot license, and h as ground training completed and 10 hours of flight time accomplished.

• Ramiro Massa , will provide PIC duties will have final authority and responsibility for operation and safety of the flight. Will act as the primary flight mechanic to ensure all

airfra mes used are safe and airworthy.

OS respectfully requests the grant of an exemption allowing operation of ultra

- light weight, remote

controlled s UAS primarily to supplant existing aerial data such as ortho

- mosaic aerial imagery,
surface calculations, im age classifications and NDVI vegetation indexing.US Department of Transportation, Docket Man agement System

Overview Solutions , MA

- Section 333 Exemption Petition May 29, 2015 Page 2

OS understands that it is in the public interest of safety that operation s of sUAS ( small unmanned

aerial systems ) maintain maximum vigilance to prevent the potential for accidents or incidents. We

propo se to enhance safety in the local environment by applying sound risk

- evaluation and management principles to the operations

, including any limitations stated in the exemption. The PIC will have in depth knowledge of current airspace restrictions.

The spe cific sections of Title 14 of the CFR from which OS requests exemption are as follows:

• 14 CFR 21; 14 CFR 45.23(b)

• 14 CFR 61.113 (a) & (b)

• 14 CFR 91, et seq.

• 14 CFR 407 (a) (1)

• 14 CFR 409 (a) (2)

• CFR 417 (a) & (b). III

Contact Information:

Harrison Humme l

, Ramiro Massa

Overview Solutions , Inc. 3144 Broadway Ste.#4 #263
Eureka, CA 95501

- 2138

Ph. 707

- 845

- 0246 707

- 499

- 3129

email: hummelharrison@gmail.com / massalandscaping@gmail.com

web: overview.officerage.co m



### The Ex tent of Relie f Overview Solutions See ks and the Reason We Seek Such Relief:

OS submits this application in accordance with the Reform Act, 112 P.L. 95 & & 331

- 334, seeking relief from any currently applicable FARs operating to prevent commercial cinematic and other flight operation within the national airspace system. The Reform Act in Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace system as it is in the public’s interest to do so. OS ’s, ul tra

- light weight s UAS meets the definition of “small unmanned

aircraft” as defined in Section 331 and

, therefore

, the integration of our ultra

- light weight s UAS is expressly contemplated by the Reform Act. OS would like to operate its ultra

- light weight s UAS prior to the time by which the FAA is required the Reform Act requires to promulgate rules governing such craft. The Reform Act guides the Secretary in determining the types of s UAS s that may operate safely in our national airspace system.

Considera tions include t he weights, size, speed

, and overall capabilities of the s UAS s; the s UAS

will not be operated in heavily populated areas; and the s UAS will be operated by line of sight, 112 P.L. 95 &&333(a). Each of these items is in favor of an exemption f or OS

. OS ’s s UAS us e s onboard

inertial measurement unit ( IMU ) and global positioning system ( GPS ) for balance, control

, and stability. Our s UAS is equipped with GPS and auto

- return safety technology

, and weighs less than (10) pounds ( far below the maximu m 55

- pound limit), including the onboard camera.

OS operators do not have a current pilot license and therefore requests relief from 14 CFR part 61.113. The flights are only incidental to this business; the aircraft does not carry passengers or property f or compensation. To achieve an equivalent level of safety, the self

- imposed experienceUS Department of Transportation, Docket Man agement System

Overview Solutions , MA

- Section 333 Exemption Petition May 29, 2015 Page 3

and training requirements of the Pilot in Command (PIC) would more than offset any risk introduced by using private pilots to fly a s UAS in very restricted and controll ed areas. The PIC will be current on local and national airspace restrictions.



### Operational Considerations:

OS proposes to operate the s UAS in Humboldt and Del Norte Count ies, California, the Coos Bay and Netarts Bay region of Oregon , the Dungeness Bay and Willapa Bay region of Washington

. There is significant work is the se coastal

- bay areas that would warrant this method of reconnaissance. These areas are primarily served by :

• T he un

- towered airport at Arcata

- Eureka Airport ( K ACV), Murray Field (KEKA)

, and Samoa Airport (033) in Humboldt County, California

• Del Norte Count y Airport (KCEC) in Del Norte County

• Southwest Oregon Regional (KOTH) in Coos County, Oregon.

• Tillamook Airport (KTMK), in Tillamook County, Oregon

• Seattle

- Tacoma International (KSEA) in Clallam County, Washington

• Willapa Harbor Airport (K259) in Pacific County, Oregon

Other smaller non

- towered airports are also prevalent. Most of the flight operations will be
conducted on clear, visual flight rule (VFR) days, typically between the daylight hours of 7 a

. m

. and

8 p

. m. All operations will be conducted bel ow 500 feet in altitude . The ideal altitudes at which to conduct the operations typically are below 300 feet; however

, occasional f l ights may be required up to 400 feet. The duration of a single photo shoot typically is 1 hour or less

.

The PIC will have a minimum of 25 hours of total s UAS operation time. Prior to operational flight

activities the PIC will have accumulated at least 5 hours of 3DR Arrow

- M as the PIC. The PIC for any given mission will have to accomplished at least 3 flight activities in the past 90 days to remain in a current: status. The PIC will be proficient in evasive maneuvers and mitigate risk by accomplishing the proper standoff distances from all properties, people, structures and vehicles outside of the designated operating area.



### Operation Risk Management:

OS ’s proposed procedures for reducing operation risk include (but are not limited to) the following:

1) Contacting the local Air Traffic Control (ATC), at least one day prior to the operations and identifying the location of the flight operations with respect to local known landmarks, GPS

coordinates

, and/or location in relation to navigational aids ( such as

, VHF omni

- directional radio rang e devices [ VOR s ]

, non

- directional beacons [ NDBs ]

, or intersections )

2) Identifying the planned time, nature, and altitudes associated with the operations

3) Us ing a (very high frequency) VHF handheld transceiver (HT)

, such as

, the Vertex Standard

VXA

- 710, to monitor ATC communications with local air traffic, and to establish radio

-US Department of Transportation, Docket Man agement System

Overview Solutions , MA

- Section 333 Exemption Petition May 29, 2015 Page 4

com munication with AT C, if needed; or, i f in the vicinity of a non

- towered airport, monitoring air traffic flying in the vicinity using Unicom frequencies

4) Prior to the event, identify ing the runways in use at the time of the shoot and ascertain ing typical traffic flow patterns

5) Avoid ing the busiest air traffic time intervals as defined by local ATC

• B oth the Humboldt County and Coos County airports are surrounded by substantial open space and bodies of water.

• When operations are conducted in close proximity to an airport or its approach paths, ongoing communication with ATC or the local Unicom operator will be maintained.

6) Maintain ing detailed flight and maintenance logs

7) Perform ing robust pre

- and post

- flight inspections on the airframe, power plant(s)

, and any

electronics that ar e important for safe operations of the s UAS



### Reasons Why Approv al of OS ’s Applic ation will Se rve the Public Ben efit:

1) Operations will be conducted by an experienced operator, aircraft owner

, and PIC, who are intimately familiar with the local airspace, loca l flight operations considerations, landmarks, and ATC procedures.

2) Use of the industry

- standard 3DR Aero

- M with features that have been tested and proven for safe operation characteristics

. 3) Applications of operations

- risk methods similar to those applied t o Part 91 operations on a flight

- by

- flight basis.

4) Operation almost entirely in very clear day VFR weather.

5) Operational location s of sites typically are along the waterfront or away from towered and

non

- towered airports.

6) Operation will be almost entirely be low 400 aboveground level ( AGL )

. 7) Maint ained HT will be used for communication s

. 8) The s UAS to be used ( 3DR Aero

- M ) has “first

- person

- view” (FPV) capability. However, all operations of the s UAS will be conducted using line

- of

- sight. FPV is useful in framing and evaluating position with respect to the desired photographs. However, use of FPV for flight control rarely offers sufficient image quality, particularly on a very bright VFR day, to us e for aircraft control beyond line

- of

- site

. Therefore, all operatio ns will be conducted strictly using line

- of

- sight.

9) This application, if approved, will help ensure safety by ensuring that the operations are conducted in accordance with FAA regulations overseen by an experienced FAA certificated pilot.



### Sample Operationa l Risk Management Procedure:

1) Pre

- operation: at least 24 h ou rs prior to operations :US Department of Transportation, Docket Man agement System

Overview Solutions , MA

- Section 333 Exemption Petition May 29, 2015 Page 5

a) Contact local airport operator, as well as ATC tower and Settle ARCC manager and identify : location of shoot with respe ct to local known ATC landmarks, timeframe of
shoot, i dentification of s UAS , and communications capability of pilot (i.e.

, radio, cell phone).

b) Obtain complete weather briefing from an approved weather information provider, as one would for a commercial Part 91 flight.

2) Day of operation:

a) Examine site of operati on using online mapping, such as

, the town GIS map applications, Google Earth

, or Flash Earth.

b) Ascertain runway in use and traffic patterns being used using Flightaware.com, by monitoring ATC tower frequency, etc.

c) Upon arrival at site, observe traffic patt erns in area ; monitor ATC frequency at all times.

d) Us e operations checklist for s UAS

. e) Conduct safety inspection of s UAS

. f) Test s UAS and obtain good GPS signal prior to flight

. g) Use safety observer

. h) While monitoring ATC, in the unlikely event that the operatio n is perceived to be in conflict with any air traffic, immediately avoid traffic and cease operation.



### Summary

Overview Solutions requests exemption from 14 CFR 21; 14 CFR 45.23(b); 14 CFR 61.113 (a) &(b); 14 C/F/R 91, et seq.; 14 CFR 407 (a) 1; 14 CFG 4 09(a) (2); and 14 CFR 417(a) & (b)., for the purpose of conducting safe operation of a 3DR Aero

- M s UAS in the general area s of Humboldt and Del Norte Counties, California and Coos County, Oregon. OS proposes to maximize safety through operational risk mana gement procedures comparable to those applied to Part 91 operations in

which OS is experienced and familiar.

This application is similar to other approved or pending applications centered on Aerial

Ph otography or survey operations us ing a 3DR Aero

- M s UAS system. The applicant believes the FAA is familiar with the aircraft capability

, so the flight manual for the aircraft is not included herewith, but can be provided on request. The manuals for the s UAS are available at:

http://3drobotics.com/wp

- content/uploads/2015/04/AeroM

- Operation

- Manual

- v3.pdf

Please issue a flight exemption for our s UAS as soon as possible, so that we can use it for documenting species o f interest during this blooming and nesting season.

Respectfully submitted,



### Overview SolutionsUS Department of Transportation, Docket Man agement System

Overview Solutions , MA

- Section 333 Exemption Petition May 29, 2015 Page 6

Harrison Hummel Ramiro Massa Photogrammetry Specialist / GIS Technician Pilot

- in

- Charge

HCH:RF:lms