Garth M. Bruce

ONE VUE LLC

35714 SE 25th Street 

Fall City, WA 98024 

September 23rd, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE Washington DC 20590 

Re: Petition for Exemption Request to Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 61.113(a) and (b); 

14 CFR 91.7(a); 14 CFR; 14 CFR 91.121; 14 CFR 91.151(b); 14 CFR 91.405 (a); 14 

CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) 

To Department of Transportation, Federal Aviation Administration: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR

Part 11, Garth M. Bruce, operator of small Unmanned Aerial System (UAS), hereby 

applies for an exemption from the listed Federal Aviation Regulations to allow 

commercial operation of a small UAS, so long as such operations are conducted within 

and under the conditions outlined herein or as my be established by the FAA as required 

by Section 333. Garth M. Bruce has a private pilot license (single engine land), 

completed multiple UAV training courses, and has 2 years two years of experience 

building and flying UAVs. 

Commercial operation small UAS will have visible light cameras and multispectral 

sensors. They would be used for: 

1. Aerial photography and/or video for public and/or private use including agriculture, 

real estate, education, engineering, and other related professional needs. 

2. Aerial video and/or photography for search and rescue (SAR) operations as requested 

by county special services. 

Background 

The requested exemption would permit the operation of a DJI Phantom 2 Vision Plus, 

DJI Inspire I, and the senseFly eBee UAVs under controlled conditions in the NAS. Garth 

M. Bruce will use experienced technicians to perform maintenance on the UAVs using 

the methods, techniques, and practices stated in the operating documents for the DJI 

Phantom 2, and Inspire I, and senseFly eBee instruction manuals. Garth M. Bruce will 

also document and store all maintenance records for the UAVs listed above. 

The DJI and eBee products use a Ground Control Station (GCS) utilizing on an electronic 

tablet or smart phone system. All system are under 55lbs and in normal conditions they 

operate at speeds of no more than 56 Mph. All of the UAVs operate using Lithium 

Polymer batteries to power electric motors. They adhere to the Reform Act’s safety 

requirements. The approval of this application presents no national security issues. 
Granting the requested exemption is in the public interest given the potential reduction of 

environmental impact from reduced noise, emissions, energy, and increased efficiency. 

Name and Address of Petitioner 

Garth M Bruce 

35714 SE 25th Street 

Fall City, WA 98024 

425.466.8270 

garth@one-vue.com 

Regulations from which the exemption is requested 

14 CFR 61.113(a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.121 

14 CFR 91.151 (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (1) & (a) (2) 

14 CFR 91.417 (a) & (b) 

1. Extent of Relief Garth M Bruce seeks from 14 CFR 61.113(a) and (b) 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: 

Pilot in command, is requested to the extent necessary to allow a PIC holding a private 

pilot or higher level certificate, as well as a current and valid airman medical 

certificate, and who has met certain flight-hour and currency requirements, to conduct 

the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state 

that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. 

A pilots license is useful in understanding the airspace and commercial activities in 14 

CFR 61 but the operation and limitations set forth in the FOM will equate to the safe 

operation of the all flights of the DJI Phantom 2 Vision+, DJI Inspire 1, and senseFly 

eBee. Garth M Bruce submits that an equivalent level of safety will be maintained 

because no PIC will be allowed to operate the DJI Phantom 2 Vision+, Inspire I, or 

senseFly eBee UAS unless that PIC has met certain flight-hour and currency 

requirements, demonstrating the PIC is able to safely operate the UASs in a manner 

consistent with the operations specifications as described in this exemption, including 

evasive and emergency maneuvers, maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Written and/or verbal permission and permits will be obtained from territorial, state, 

county or city jurisdictions, including law enforcement or other appropriate 

governmental agencies when needed. 
2. Extent of Relief Garth M Bruce seeks from 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 are no airworthiness certificates issued for the UAVs no 

standard will exist for determining airworthiness. Given the size of the aircraft and 

use of safety checklists prior to each flight an equivalent level of safety will be 

provided. 

Garth M Bruce will ensure that the DJI Phantom 2 Vision+, Inspire 1, and senseFly 

eBee are in airworthy condition based upon the compliance with the Maintenance 

Logs and Instruction Manuals prior to each flight. 

3. Extent of Relief Garth M Bruce seeks from 14 C.F.R. §91.121 Altimeter Settings.

This requirement specifies an aircraft to maintain a cruising altitude by setting the 

altimeter to the elevation of the departure airport or an appropriate altimeter setting 

available before departure. An equivalent level of safety will be achieved by the 

operator referencing the barometric pressure sensor and GPS indicators which are 

provided to the ground station software via the data link. The UAVs flight data will 

be used to confirm the altitude of the launch site before flight. 

4. Extent of Relief Garth M Bruce seeks from 14 C.F.R. § 91.151(b): Fuel 

Requirements for Flight in VFR Conditions 

Section 91.151 (b) 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 LiPo batteries powering the UASs provide a minimum of 18 minutes of 

consistent flight time, 13 minutes to the first intended landing area, and 5 minutes 

following. Given the limitations of the UASs, the flight area and flight time are 

restricted. Garth M Bruce will safely operate the UAVs during daylight hours in 

visual meteorological conditions and under visual flight rules with enough battery 

power to fly to a designated area and allow for a return to the intended landing point 

at a normal cruising speed. 

5. Extent of Relief Garth M Bruce seeks from 14 C.F.R. §91.405 (a); 407 (a) (1); 409 

(a) (1) and (a) (2); 417(a) & (b): Maintenance Inspections. 

Since these sections only apply to aircraft with an airworthiness certificate, Garth M 

Bruce requests relief from these Sections given the DJI Phantom 2 Vision+, Inspire 1, 

and senseFly eBee do not require airworthiness certificates. Accordingly, Garth M 

Bruce will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs as outlined in the Operations Manuals, Maintenance Logs, 

and Instruction Manuals. Garth M Bruce will document and maintain all maintenance 

records for the UAVs listed above to provide the equivalent level of safety.
UAS Information 

Small UASs to be used are as follows but not limited to providing they are within the

scope of the exemption granted by the FAA: 

1. DJI Phantom 2 Vision Plus 

• Weight (Battery & Propellers Included) – 2.74 lbs. 

• Hover Accuracy (Ready to Fly) –Vertical: 24 ft; Horizontal: 7.5 ft 

• Max Yaw Angular Velocity – 2000/s 

• Max Tilt Angel – 350 

• Max Ascent Speed – 18 ft/s 

• Max Descent Speed – 6 ft/s 

• Max Flight Speed – 45 ft/s 

• Battery 

 DJI 5200mAH LiPo 

 Current – Static: 750mA; Dynamic: 900mA 

• Transmitter Frequency – 5.728GHz –5.85GHz 

• Communication Distance (unobstructed) – FCC Compliance: 800m 

• Transmitter Power – FCC Compliance: 100mW 

• Working Voltage – 120mA@3.7V 

• Range Extender Frequency – 2412-2462MHz 

• User Manual - http://www.dji.com/product/phantom-2-vision/download 

2. DJI Inspire I 

• Weight (Battery Included) – 6lbs 7.5291oz (2935g) 

• Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m 

• Max Tilt Angle - 350 

• Max Ascent Speed – 5m/s 

• Max Descent Speed – 4m/s 

• Max Speed – 22m/s 

• Max Flight Altitude – 4500m 

• Max Flight Time – Approximately 18 minutes 

• Operating Temperature Range – 140F to 1040F (-100C to 400C) 

• Dimensions – 17 1⁄4” x 17 3⁄4” x 12” 

• Transmitter Frequency – 5.728-5.850GHz; 2.400-2.483GHz 

• Communicating Distance (unobstructed) – 2000m 

• Output Power – 9W 

• Operating Temperature Range - 140F to 1040F (-100C to 400C) 2.2.4.6 

• User Manual - http://www.dji.com/product/inspire-1/download 

3. senseFly eBee 

• Weight (includes camera) - Approx. 0.71 kg (1.56 lbs) 

• Wingspan - 96 cm (38 in) 

• Material - EPP foam, carbon structure & composite parts 

• Propulsion - Electric pusher propeller, 160 W brushless DC motor 

• Battery - 11.1 V, 2150 mAh 

• Maximum flight time - 45 minutes 

• Nominal cruise speed - 40-90 km/h (11-25 m/s or 25-56 mph) 

• Radio link range - Up to 3 km (1.86 miles) 
• Wind resistance - Up to 45 km/h (12m/s or 28 mph) 

• Transmitter Frequency - 2.4 GHz 

• Communicating Distance - approx. 1 km (Certification: CE, FCC) 

• Multi-drone operation - Yes (inc. mid-air collision avoidance) 

• Automatic 3D flight planning 

• Linear landing accuracy - Approx. 5 m (16.4 ft) 

• Flight planning & control – eMotion 

• User Manual - 

https://www.sensefly.com/fileadmin/user_upload/sensefly/documents/manuals/Ext

ended_User_Manual_eBee_and_eBee_Ag_v16.pdf 

Maintenance Log 

Maintenance Log 

UAV: Description of Inspections, Tests, Repairs, 

Alterations 

By: Date 

Date Time 

 

Conclusion 

Thank you for the consideration of these exemptions. 

Sincerely, 

Garth M. Bruce