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• 

February 1, 2016 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Central Virginia Aerial Solutions, LLC 

4132 Richmond Hwy 

lynchburg, VA 24501 

Kyle Falwell: {434} 851-1992 

Kyle@bonairbrokerage.com 

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Additional Services Request to Exemption No. 12781, Regulatory Docket No. FAA-2015-1450 

Dated September 8, 2015, granted to Central Virginia Aerial Solutions, LLC. 

Dear Sir or Madam: 

Central Virginia Aerial Solutions (CVAS) was granted exemption from several provisions ofthe 

Federal Aviation Regulations (FAR) in accordance with Section 333 of the FAA Modernization 

and Reform Act of 2012 on September 8, 2015, under Exemption No. 12781 (Regulatory Docket 

FAA 2015-1450). CVAS was authorized to operate small lightweight DJI unmanned aircraft 

systems (UASs) (detailed below) commercially for the purpose of private property mapping and 

surveys in airspace regulated by the Federal Aviation Administration (FAA). CVAS was granted 

this exemption under Part 21; §§ 45.23(b); 61.113(a) and (b); 61.133(a); 91.7(a); 91.9(b)(2); 

91.109{a); 91.119; 91.15l{a); 91.203(a) and (b); 91.319(a)(l); 91.405(a); 91.407(a)(1); 

91.409(a)(2); and 91.417(a) of Title 14, Code of Federal Regulations (14 CFR part 11). 

The purpose of this letter is to request two additional services to be added to our 

exemption: 

Search and Rescue 

Emergency Services 

The public interest in granting this exemption request is served by, among others, the 

following: 

• The use of UASs improves public safety and reduces risk by alleviating the public's 

exposure to danger and emissions associated with conventional aerial methods that are 

very heavy, fast, and carry passengers, flammable fuel and cargo. 

• Since UASs being operated are very small and contain no flammable fuel; in the remote 

event of an accident, will cause no damage or injuries. 

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• Given that the cost to conduct an inspection using a UAS is considerably less than 

available alternatives, this important task can be accomplished which will benefit 

everyone. 

• CVAS use of UAS's in lieu of comparatively hazardous operations now conducted with 

fixed wing and rotary conventional aircraft, the FAA can have confidence that the 

operations will achieve at least an equivalent level or greater level of safety. Approval of 

this exemption would thereby enhance safety and fulfil the Secretary of 

Transportation's responsibilities under Section333(c) of the Reform Act to "establish 

requirements for the safe operation of such aircraft systems in the national airspace 

system." 

CVAS will also work closely with the local FSDO to monitor and report drone operators that are 

not compliant with the FAA exemptions required. 

The OJI UASs systems consist of lightweight battery operated aircrafts, an integrated state of 

the art ground station system and communications equipment. The aircrafts carry an onboard 

high resolution camera (with first person view) that allows us to conduct precision aerial 

photography and video. This technology will assist the Pilot in Commands (PIC) in providing the 

upmost safety procedures and the public will benefit from these services. CVAS services will 

help the commercial industry and not bring harm to any person in the air or on the ground. 

Kyle Falwell, The co-owner of CVAS is an ATP pilot with Type ratings in the CE 500 and CE525 

aircraft. Kyle will personally oversee all operations of safety. His extensive aviation background 

will on aid in the safety of all CVAS operations. 

The aircrafts of CVAS will be operated in the field of view with both a PIC and a ground-based 

Visual Observer (VO) in accordance with FAA Policy N 8900.227 Section 14 "Operational 

Requirements for UAS" with the following additional restrictions: 

• All operations will occur in Class G airspace (below 400' AGL) 

• Operations will be operated over private property, commercial property, or property 

(not federal or state) with permission of the land owner 

• The aircraft will not operate within SNM of any airport or heliport (unless wellcoordinated with the FAA and airport/heliport (detailed flight plans)) 

• Operations will be limited to day, visual meteorological conditions 

• Aircraft will remain within Visual Line of Sign at no greater than Y2 NM of the PIC at all 

times 

• While the aircraft is airborne, the VO will be positioned within voice distance to the PIC 

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 

Personnel Qualifications. Additionally, the PIC and VO will perform maintenance on the system 

and will complete all necessary maintenance set forth by the FAA or manufacturer. 

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We submit that the combination of the aircrafts light weight, historically demonstrated flight 

performance, fully qualified flight crew and strict operation under the guidelines established in 

8900.227, the FAA can have confidence that the operation will have an equivalent or greater 

level of safety of manned aircraft performing similar operations. CVAS is dedicated to safety 

and believes the company will not bring any harm to the public (air or ground). 

CVAS proposes to operate the DJI UASs Phantom 2, Phantom 2+, and the Inspire 1. The 

petitioner states that given the size, weight, speed and limited operating area associated with 

the aircraft to be utilized by the applicant, an exemption from 14 CFR Part 21, Subpart H 

(Airworthiness Certificates), subject to certain conditions and limitations, is warranted and 

meets the requirements for an equivalent level of safety under 14 CFR Part 11 and Section 333 

of P.L. 112-95 (Section 333}. The petitioner further states that UAS operated without an 

airworthiness certificate in the limited environment and under the conditions and limitations 

proposed by the petitioner will be at least as safe, or safer, than a conventional aircraft (fixed 

wing or rotorcraft) operating with an airworthiness certificated issued under 14 CFR Part 21, 

Subpart H and not subject to the proposed conditions and limitations. 

The petitioner states that the unmanned aircraft (UA} to be operated under this request is a 

rotary-wing aircraft, with the smallest aircraft weighing 2.5 lbs (largest weighing 7.6 lbs) fully 

loaded, flies at a maximum speed of 29 knots (not recommended), carries neither a pilot nor 

passengers, carries no flammable fuels, and operates exclusively within a pre-disclosed area. 

Operations under this exemption will be tightly controlled and monitored by both the operator, 

spotter, and local public safety requirements. 

DJI Aircraft Specs: CVAS operates the following UAS 

Phantom 2(1): Serial Number: PH645195943 

Weight: 2.5 pounds 

Max Speed: 29 knots 

Flight Time: 25 minutes 

Battery: 3S LiPo, 5200mAh, 11.1V 

Operating Frequency: 2.4GHz ISM (range 1000 meters) Note: We only operate with 100% line of 

sight to the Aircraft (we do not lose visual of the aircraft) 

First Person View: Yes 

Phantom 2 Vision + (2): Serial Number: PH645199878 Serial Number: PH645240161 

Weight: 2. 7 pounds 

Max Speed: 29 knots 

Flight Time: 25 minutes 

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Battery: 3S LiPo, 5200mAh, 11.1V 

Operating Frequency: 5.728-5.85 GHz 

First Person View: Yes 

Inspire (1): Serial Number: W13DCJ28050067, W13DCA18020091, W13DCB16020084 

Weight: 7.6 pounds 

Max Speed: 31 knots 

Flight Time: 18 minutes 

Battery: LiPo(6S, 10000mAh"'15000mAh, 15C(Min)) 

Operating Frequency: 2.4GHz ISM (range 1000 meters) Note: We only operate with 100% line of 

sight to the Aircraft (we do not lose visual of the aircraft) 

First Person View: Yes 

Phantom 3 Advance: Serial Number: P77DCH17010801 

Weight: 1280g 

Max Speed: 16 m/s 

Flight Time: 21 minutes 

Battery: Lipo (2s, 6000 mah) 

Operating Frequency: 2.4 GHz- 2.482 GHz Note: We only operate with 100% line of sight to the 

Aircraft (we do not Jose visual of the aircraft) 

First Person View: Yes 

UAS Pilot In Command 

The petitioner asserts that operations of the OJI should not be required to hold a commercial or 

private pilot certificate. However I Chief Safety Officer does. The petitioner notes that unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the OJI UASs are remotely 

controlled with no passengers or property of others on board. The petitioner proposes that 

operator requirements should take into account the characteristics of the particular UAS. The 

petitioner states that the OJI UASs have high degree of pre-programmed control and various 

built-in technical capabilities that strictly limit the potential for operation outside of the 

operating conditions set forth in its petition for exemption. 

CVAS will not allow the PIC to fly any aircraft without at least 40 hours of training flight time 

with the exact aircraft used for the business. The company has several private testing areas 

that are in a remote location with no vertical obstructions. This allows the PICs for CVAS to test 

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all the systems and understand fail safe features to the fullest extent before conducting 

business with the UAS. 

CVAS's PICs are well versed in all the safety features on the DJI aircrafts. They have spent 

countless hours perfecting the pre-flight, flight, and post flight procedures. CVAS's PICs can 

perform all necessary maintenance on the DJI aircrafts and if for some reason they are not able 

to fix aircraft to safety specifications, they will seek assistance with the strict parameters of the 

FAA and the DJI Flight Operational Manuals. 

The name and contact information of the applicants are: 

Central Virginia Aerial Solutions, LLC 

4132 Richmond Hwy 

Lynchburg, VA 24501 

Kyle Falwell: (434) 851-1992 

Kyle@bonairbrokerage.com 

CVAS is prepared to modify or amend any part of this request to satisfy the need for an 

equivalent level of safety. We look forward to working with your office. Please contact us any 

time if you require additional information or clarification. 

Sincerely, 

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