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); 91.407(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 (sUAS) commercially in airspace regulated by 

the Federal Aviation Administrator (FAA). This petition is, in most regards, similar to 

granted 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 used (3DR 

Aero-M).

As described herein OS proposes to perform aerial still photography with the use of common 

professional sUAS equipment, presently a 3DR Aero-M Fixed Wing aircraft, mostly for geological, 

biological, and botanical survey purposes and construction monitoring. 

OS’s exemption request would permit operation of ultra-light weight, unmanned, sUAS in small 

portions of semi-rural airspace using tightly controlled and limited duration flight plans.

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 

operator 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 has 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 

airframes used are safe and airworthy. 

OS respectfully requests the grant of an exemption allowing operation of ultra-light weight, remote 

controlled sUAS primarily to supplant existing aerial data such as ortho-mosaic aerial imagery, 

surface calculations, image classifications and NDVI vegetation indexing.
US Department of Transportation, Docket Management System

Overview Solutions, MA- Section 333 Exemption Petition

May 29, 2015

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

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

propose 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 specific 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 Hummel, 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.com

The Extent of Relief Overview Solutions Seeks 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, ultra-light weight sUAS meets the definition of “small unmanned 

aircraft” as defined in Section 331 and, therefore, the integration of our ultra-light weight sUAS is 

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

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 sUASs that 

may operate safely in our national airspace system. 

Considerations include the weights, size, speed, and overall capabilities of the sUASs; the sUAS

will not be operated in heavily populated areas; and the sUAS will be operated by line of sight, 112 

P.L. 95 &&333(a). Each of these items is in favor of an exemption for OS. OS’s sUAS uses onboard

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

stability. Our sUAS is equipped with GPS and auto-return safety technology, and weighs less than 

(10) pounds (far below the maximum 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 for compensation. To achieve an equivalent level of safety, the self-imposed experience 
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Overview Solutions, MA- Section 333 Exemption Petition

May 29, 2015

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and training requirements of the Pilot in Command (PIC) would more than offset any risk 

introduced by using private pilots to fly a sUAS in very restricted and controlled areas. The PIC 

will be current on local and national airspace restrictions. 

Operational Considerations:

OS proposes to operate the sUAS in Humboldt and Del Norte Counties, California, the Coos Bay

and Netarts Bay region of Oregon, the Dungeness Bay and Willapa Bay region of Washington. 

There is significant work is these coastal-bay areas that would warrant this method of 

reconnaissance. These areas are primarily served by:

• The un-towered airport at Arcata-Eureka Airport (KACV), Murray Field (KEKA), and 

Samoa Airport (033) in Humboldt County, California

• Del Norte County 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 below 500 feet in altitude. The ideal altitudes at which to 

conduct the operations typically are below 300 feet; however, occasional flights 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 sUAS 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 range devices [VORs], non-directional beacons [NDBs], or intersections)

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

3) Using 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 Management System

Overview Solutions, MA- Section 333 Exemption Petition

May 29, 2015

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communication with ATC, if needed; or, if in the vicinity of a non-towered airport, 

monitoring air traffic flying in the vicinity using Unicom frequencies

4) Prior to the event, identifying the runways in use at the time of the shoot and ascertaining 

typical traffic flow patterns

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

• Both 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) Maintaining detailed flight and maintenance logs

7) Performing robust pre- and post-flight inspections on the airframe, power plant(s), and any 

electronics that are important for safe operations of the sUAS

Reasons Why Approval of OS’s Application will Serve the Public Benefit:

1) Operations will be conducted by an experienced operator, aircraft owner, and PIC, who are 

intimately familiar with the local airspace, local 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 to Part 91 operations on a 

flight-by-flight basis.

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

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

non-towered airports.

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

7) Maintained HT will be used for communications.

8) The sUAS to be used (3DR Aero-M) has “first-person-view” (FPV) capability. However, all 

operations of the sUAS 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 use 

for aircraft control beyond line-of-site. Therefore, all operations 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 Operational Risk Management Procedure:

1) Pre-operation: at least 24 hours prior to operations:
US Department of Transportation, Docket Management System

Overview Solutions, MA- Section 333 Exemption Petition

May 29, 2015

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a) Contact local airport operator, as well as ATC tower and Settle ARCC manager and 

identify: location of shoot with respect to local known ATC landmarks, timeframe of 

shoot, identification of sUAS, 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 operation 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 patterns in area; monitor ATC frequency at all times.

d) Use operations checklist for sUAS.

e) Conduct safety inspection of sUAS.

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

g) Use safety observer.

h) While monitoring ATC, in the unlikely event that the operation 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 409(a) (2); and 14 CFR 417(a) & (b)., for the purpose of 

conducting safe operation of a 3DR Aero-M sUAS in the general areas of Humboldt and Del Norte 

Counties, California and Coos County, Oregon. OS proposes to maximize safety through 

operational risk management 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

Photography or survey operations using a 3DR Aero-M sUAS 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 sUAS are available at:

http://3drobotics.com/wp-content/uploads/2015/04/AeroM-Operation-Manual-v3.pdf

Please issue a flight exemption for our sUAS as soon as possible, so that we can use it for 

documenting species of interest during this blooming and nesting season.

Respectfully submitted,

Overview Solutions
US Department of Transportation, Docket Management 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