UAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request 

UAVProducts - Birdseyemedia LLC 

10027 Fair Oaks 

Goodrich, Ml 48438 

517-862-1386 

robert@birdseyemedia.com 

Federal Aviation Administration 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. 

SE Washington, DC 20590 

Dear Sir or Madam: 

Tuesday, October 6, 2015 

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

UAVProducts (dba: Birdseyemedia, LLC) and owner Robert Remund hereby apply for an exemption from 

Federal Aviation Regulations (FARs) detailed below to allow for commercial operations of small 

unmanned aerial systems for the primary purpose of aerial photography and video. 

Birdseyemedia will offer safe, low altitude, and cost effective aerial imaging to the communities we serve. 

A variety of industries will benefit; Home Real Estate, Commercial Real Estate, Marketing, Land 

Development, Construction, and Property Inspections. 

Birdseyemedia will operate a DJI Inspire 1, a small unmanned aerial system (sUAS) equipped with 

advanced flight control systems, high definition camera and gimbal, and advanced safety features. The 

sUAV will be operated by a responsible PIC (pilot in command) and VO (visual operator), in turn offering a 

safe and valuable experience to our clients. 

UAVProducts is the original North American Distributor for OJI Innovations since 2008. From 2008-2012 

UAVProducts was the only North American Distributor for OJI Innovations. Owner Robert Remund knows 

the owners of OJI Innovations on a personal basis. Owner Robert Remund is constantly testing new 

products and advancing the drone industry on safety and advancements. 

BirdsEyeMedia, LLC and owner Robert Remund have been doing Aerial Photography from Remote 

Aircraft safely since 2006. The experience in aerial photography and the vast background of autopilot 

systems should also be noted for exemption of FARs. 

1. The OJI Inspire 1 has a maximum takeoff weight of less than 6.5 pounds and thus offers a 

lightweight, small and compact video platform compared to manned aircraft. 

2. The OJI Inspire 1 offers significant safety, noise, emission, security and environmental benefits 

not available to larger manned aircraft. 

3. The OJI Inspire 1 has numerous safety features such as failsafe mode, automatic landing 

should signal between PIG and UAS be interrupted, GPS based altitude and distance locks, flight 

limiting features and low battery warnings. 

4. The OJI Inspire 1 also has obstacle and avoidance feature that was just recently added as of 

09-07-2015. 
UAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request Tuesday, October 6, 20i 5 

5. Dual controllers provide the PIC (pilot in command) to focus on operating the sUAS while a 

second individual operates the camera. Two man operation is the safest setup. 

6. Inspire 1 safety features are addressed in more detail in the attached Inspire 1 user manual. 

The safe operation of the UAS will be the first priority before, during and after every operation. 

1. All sUAS operations will be conducted at Visual Line Of Sight (VLOS) at no more than 200 

feet AGL. 

2. No sUAS operations will be conducted within 5 NM of an airport and will be in FAA class G 

airspace. 

3. No sUAS operations will occur directly over densely populated areas, un-approved 

government buildings, power lines, or major roads. 

4. All sUAS operations will take place during daylight hours under conditions equivalent to Visual 

Flight Rules (VFR) with the UAS no more than 1000 ft from the PIC. 

5. All sUAS operations will have a PIC and VO present and all operations will be within visual line 

of sight (VLOS) of both the PIC and VO. 

6. PIC and VO will be able to verbally communicate at all times. 

7. The UAS will yield to all manned aircraft at all times. 

8. All required permits and permissions will be obtained from local and state government should 

they be required. 

9. A pre-flight inspection by the PI_C will be performed prior to each flight to assure that the UAS 

is safe for flight. A post-flight inspection will also be performed as an added level of safety. 

iO.Full aircraft inspections will be completed in accordance with manufactures instructions. 

;; . At no time shall the UAS be operated with missing or manufacturer unapproved parts, or in 

any condition that could pose a hazard to any other aircraft or structure or person on the 

gmund. 

; 2. The sUAS will not be operated at a battery level below 20%. This is a safety setting in the DJI 

Inspire software. 

i 3. Prior to all UAS operations a pre-flight meeting will be held by the PIG to determine the 

parameters of flight in a given location, any hazards present, weather conditions, safety 

procedures at the specific location and approximate duration and route of flight. 

14.The PIC will have a minimum of 10hrs flying time and operated at least 50 individual flights of 

similar sUAS multi-rotor aircrafts. 

It is my belief that small unmanned aerial systems, used by experienced and responsible operators, 

following the policies outlined above, qperating in privacy conscious way; will in turn offer aerial imaging 
UAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request Tuesday, October 6, 2015 

to the general public in ways that are more cost effective, safe, and efficient than the traditional methods 

of manned aircraft. 

I respectfully request the FAA to grant an exemption to Birdseyemedia LLC, for commercial UAS aerial 

photography operations under the Reform Act of 2012. 

If any of procedures, policies, or content of this request do not meet the requirements of an exemption, it 

is Birdseyemedia's intention to adjust its policies in accordance to the FAA's requirements outlined in the 

granted exemption. 

Robert Remund - Owner of Birds emedia LLC I UAVProducts.com 

10027 Fair Oaks 

Goodrich, Mi 48438 

517-862-1386 

robert@birdseyemedia.com 
UAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request Tuesday, October 6, 2015 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Birdseyemedia LLC, requests an exemption from the following regulations as well as any additional 

regulations that apply to the operation of OJI Inspire 1 or similar sUAS's for the purpose of aerial 

photography and video. 

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

Birdseyemedia will use specially trained staff to conduct the sUAS operations. While these individuals will 

not hold commercial pilot licenses, they will have at least 1 Ohrs of flying time, have conducted at least 50 

individual flights and read sUAS manufactures manuals and operating procedures. In addition each PIC 

and VO will be required to sign a document confirming the understanding of Birdseyemedia operating and 

safety policies and the granted Birdseyemedia exemption. The sUAS will not carry property for 

compensation or hire since they will be used solely to provide our clients with aerial imaging. Without an 

exemption, the pilot would be required to hold a commercial pilot certificate under §61.133. However, the 

risk associated with the contemplated operations is less than the risk posed by a traditional aircraft. The 

sUAS will fly at altitudes well below the permissible limits for other civil aircraft, eliminating the risk to 

other aircraft, and within a geographical envelope under the sole control of Birdseyemedia clients. · 

Requiring a commercial pilot certificate would provide no appreciable safety benefit and would needlessly 

impose additional cost on Birdseyemedia. Because the contemplated operations would not comply with 

§61.113(b)(1) and none of the other exceptions to paragraph (a) apply, relief is needed from both 

paragraphs (a) and (b). 

14 CFR Part2i, Subpart H: Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness certificate. 

While the FAA continues to work to develop airworthiness standards for UAS, we request an experimental 

certificate be issued for the UAS operated by the applicant under either or both of the following 

provisions: 

21 .191 Experimental certificates . . 

Exp~rimental certificates are issued for the following purposes: 

Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft 

installations, new aircraft operating techniques, or new uses for aircraft. 

Showing compliance with regulations. Conducting flight tests and other operations to show compliance 

with the airworthiness regulations including flights to show compliance for issuance of type and 

supplemental type certificates, flights to substantiate major design changes, and flights to show 

compliance with the function and reliability requirements of the regulations. 

Since the experimental certificate can be used for commercial purposes such as market surveys; sales 

demonstrations, and customer crew training, we would expect that an experimental certificate would 

permit our commercial purpose as well. 

The_ aircraft will not carry persons or property and will only fly under strict operational requirements. As · 

Birdsyeymedia's sUAS also carries no combustible fuel , weighs less than 6.5 pounds and is constructed 

primarily of plastics and composites, we propose the UAS is at least as safe, if not significantly safer than 

conventionally certified aircraft used within similar parameters. 

If an experimental airworthiness certificate is not appropriate for this application, then we request an 

exemption of ; 4 CFR Part2i, Subpart H, and the requirement for an airworthiness certificate in general, 

citing the equivalent level of safety outlined in the previous paragraph. 
lJAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request Tuesday, October 6, 2015 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew." 

As the sUAS is too small to carry documentation, does not have an entrance and does not carry a crew, 

we propose the following in order to meet the intent of 91.203 and provide an equivalent level of safety. All 

documents deemed appropriate by the FAA for this aircraft will be located at the operational ground 

station for each flight in proximity to the PIC and VO and will be available for inspection on request. In 

order to identify the aircraft, we propose to use the manufacturer's model and production codes located 

on the aircraft as well as a Birdseyemedia logo affixed to the aircraft as well. 

14 CFR 91 .9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved flight manual 

is in the aircraft. The intent of this requirement is to ensure that flight manual information is available to 

the aircrew while operating the aircraft. 

Birdseyemedia requests an exemption to this requirement as the UAS cannot, given its size, carry the 

flight manual. To meet an equivalent level of safety, we propose to have the current manufacturer's flight ·· 

manual and the Birdseyemedia flight manual at the operational ground station of each flight, available to 

both the PIC and VO. 

14 CFR 91.119 Minimum safe altitudes: General. 

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 

500 feet to any person, vessel, system, or structure. Since the UAS will be operating at a maximum 200 

feet AGL, we. cannot comply with this requirement and thus ask for an exemption. In order to provide an 

equivalent level of safety, we propose the following . 

The UAS will only be operated within VLOS of the PIC and VO at a maximum range of 1000 feet from the. 

ground station. 

A preflight safety risk assessment will be completed prior to each flight to ensure the UAS is in a condition 

for safe flight and that the planned operation can be completed safely. Birdseyemedia's Flight Manual and 

Pre~Flight Checklist is included as Appendix A and Appendix B. 

The UAS will not be operated within 5 NM of any airport and will only be operated with the consent of 

property manager and/or owner. 

i 4 CFR 91.121 Altimeter settings. 

The. regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter setting 

available within 100 nautical miles of the aircraft. 

The UAV will always be flying below 200 feet AGL within VLOS of the PIC and VO that will provide 

separation from terrain, structures and other aircraft. Also, the UAS will continually transmit an AGL 

reading back to the controller at the ground station and the AGL lock in the UAS's software will be set to 

400 feet, providing an equivalent level of safety. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flightin an airplane under day-VFR conditions unless 

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. 

The UAS is smart battery powered and continually transmits battery charge information back to the 

ground station to be evaluated by the PIC who will return the UAS back to the ground station prior to the 
UAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request Tuesday, October 6, 2015 

battery showing 20% remaining capacity. We feel that this combined with the fact that the UAS will have a 

maximum range of 1000 feet from the ground station provides an equivalent level of safety. 

14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b) 

Maintenance, Preventive Maintenance, and Alterations. 

We propose that the PIC perform maintenance and inspection and "be authorized to approve the aircraft 

for return to service." As provided for in Appendix A, the PIC will inspect the aircraft prior to every flight to 

ensure it is in airworthy condition. A maintenance check will also be performed at intervals instructed by 

the manufacturer, OJI. Any general maintenance and repair or replacement of components will be 

completed by the PIC following the manufacturer's recommendations and documented in accordance 

with 91.417. In any case where the UAS cannot be returned to service by the PIC, or is suspected to be 

unsafe, the UAS will not be operated until returned to all manufacturer specifications. We feel that due to 

the simplicity, size, robustness and construction of the aircraft, the PIC can assure an equivalent level of 

safety. 

8900.227 Paragraph 16(cXa) PIG Medical. and Paragraph 16(eX1) Observer Medical 

This policy provides that both the PIG and observer must have a valid FAA second-class medical . 

certificate issued under part 67 in order to perform as a pilot or observer. We feel that requiring the PIC 

and VO to meet the same medical requirements as a commercial pilot carrying passengers in a large 

aircraft is an unnecessary burden. 

Since the UAV is of small size, unmanned, has an auto return home feature, will be operating at low .. 

altitudes, will not operate over a densely populated area, and required to be in VLOS of the IC and VO at 

all times, we feel both the PIC and VO requiring vision corrected to 20/20 and a valid state issued driver's 

license supports medical requirements. 
UAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request Tuesday, October 6, 2015 

APPENDIX A 

Birdseyemedia Flight Parameters and Restrictions 

1. All flights will occur in FAA Class G airspace at no more than 200 feet AGL and no further than 1 OOOft 

from the PIC. 

2. The sUAS will not be flown faster than 40mph or as limited by FAA regulations. 

3. All operations will utilize a PIC and VO with the PIC and VO able to communicate verbally at all 

times. 

4. All operations will occur only during daylight hours and in weather conditions equivalent to VFR. 

5. All operations will occur at VLOS from the PIC and VO. 

6. The PIC and VO will have a pre-flight meeting at the site of the operation just prior to the flight 

to assess weather, area of operation, topography, flight time, route, hazard mitigation and overall 

operational and safety parameters. Also during this meeting, the pre-flight aircraft checklist (see 

Appendix B) will be implemented. 

7. PIC is responsible for maintaining an established safe emergency landing plan if at any time during 

the operation conditions become unfavorable due to unforeseen hazards, safety concerns, or weather. 

8. All operations will be reviewed prior to flight and conducted with the full permission of the property 

owner or manger. 

9. Flight planning will include the termination of the flight with 20% battery remaining, as determined by 

the data link between the UAS and ground station. 

10. The UAV will at all times give way to manned aircraft. 

11. Prior to every flight, a highly visible launch banner will be placed at the site of the ground station 

to allow an outside observer to determine the location of the UAS's origin and command point. 

12. All permits required by state and local governments will be obtained prior to any operations. 

13. No flight operations will occur without a successful pre-flight inspection by the PIC before each 

flight to determine that the UAS is in a condition for safe flight. 

14. At the conclusion of each flight a post-flight inspection will be done to assess the condition of. 

the UAS. 

15. A full aircraft check will be performed in accordance with manufactures instructions. 

16. Replacement of parts shall only be done according to manufacturer's instructions. 

17. All flight operations will be logged in a flight logbook. 

18. All maintenance done and inspections performed will be lodged in a maintenance log. 

19. Check for software updates weekly and upload to UAS as needed to continually keep the UAS 

software. as current as possible. · 
UAVProducts - Birdseyemedia, LLC FAA 333 Exemption Request Tuesday, October 6, 2015 

APPENDIX B 

Birdseyemedia Pre-Flight Checklist 

1. Ensure the area identified for flight is considered FAA Class G airspace, winds conditions are less 

than 

15mph, and weather conditions are favorable. 

2. Identify all potential obstructions and safety hazards in or near the area planned for flight. 

3. Inspect all propellers for proper tightness and that they are free of cracks, dings, chips and 

excessive wear. 

4. Inspect all wiring and motors. 

5. Inspect the airframe for cracks or damage. 

6. Inspect battery voltage of UAS on-board battery and Remote Controller!Transmitter battery to 

ensure there is sufficient energy in both systems for safe flight. 

7. Turn off wifi wireless on all devices·located the person or within 10ft of the PIC and VO. 

8. Recalibrate compass according to manufacturer's instructions. 

9. Always turn on Remote Controller!Transmitter before turning on UAS battery. 

10. Ensure that a link between Transmitter and UAS is established and that GPS link is established. 

11. Engage throttle, lift aircraft off the ground and verify the aircraft responds properly to all inputs 

and hovers accurately. 

APPENDIXC 

DJI Inspire 1 User manual: http://www.d ji .com/product/inspire-1/ download