John Parisoff

New View LLc PO Box 285 Helotes TX 78023 (210) 396

- 6224 jpdirtwork@live.com

I formall y petition the Federal Aviation Administration (FAA) for an exemption from part 21, subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.119 (c) 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). Outlined below are the descriptions of the parts, subparts and sections in which Irequest exemptions and my

reason for requesting the exemptions. Part 21 prescribes the procedural requirement s for issuing and changing design approvals, productions approvals, airworthiness certificates, and airworthiness approvals. Section 45.23(b) prescribes that when marks include only the Roman capital letter “N” and the registration number is display ed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable. Section 61.113(a) and (b) prescribes that

— (a) no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carry ing passengers or propert y for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) a private pilot may , for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only

incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire. Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy condition. Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (c) Over other than congested areas. An altitude of 400 feet above the surface, except over open water or sparsel y populated areas. In those cases, the aircraft may not be operated closer than 400 feet to an y person, vessel, vehicle, or structure.(1) A helicopter may be operated at less than the minimum s prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specificall y prescribed for helicopters b y the FAA; and (2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section. Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by r eference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” Section 91.151(a) prescribes that no person may begin a flight in an airplane under VFR conditions unless (c onsidering 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 [emphasis added]. Section 91.203(a) proh ibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the Unite d States, the second copy of the Aircraft registration Application as provided for in § 47.31(c). Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft unless the airworthiness certificate or a special flight authoriz ation issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in s ubpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of the chapter. Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for return to service b y a person authorized under § 43.7 of the same chapter. Section 91.409(a) (2) prescribes, in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. Section 91.417(a) and (b) prescr ibes, in pertinent part, that

— (a) Each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 10 0

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last o verhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required b y the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safet y directive involves recurring action, the time a nd date when the next action is required. (vi) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall reta in the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 ye ar after the work is performed. (2) The records specifi ed in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defect s are repaired and the aircraft is approved for return to service.

New View LLC ’s exemption requests from the above are detailed below: Unmanned Aircraft Sy stem: New View LLC plans to operate a DJ I, I nspire 1, which is comprised of an unmanned aircr aft . The Inspire 1 is a quad

- copter with a gross weight of about 6 pounds. It is equipped with four rotors that are driven b y electric motors which is powered b y batteries. The UA has a maximum airspeed of 50 mph. New View LLC plans to use this DJIin a erial cinematography and photography

on rural ranch sites, rural RV resorts, enhancing real

- estate listings and other such tasks for businesses in the greater San Antonio Texas area which could benefit from an aerial view for their planning of future expan sions and/or advertising of their products or business. For most businesses and realtors in the area, standard aerial photograph y has been very cost prohibitive. The economic impact of being able to assist your business using aerial photography would be substantial.The use of this DJ I in the above named applications greatl y reduces risk to the public and

propert y as there is no fuel carried b y the Inspire 1, aircraft noise is greatly reduced as opposed to a standard aircraft or rotorcraft both of which r equire numerous passes or extended lengths of hover time to accomplish the same task as the Inspire can in onl y a few minutes. The Inspire only weighs about 6 pounds and is by far a much smaller hazard to persons or propert y than a standard aircraft or hel icopter in the event of a catastrophic in

- flight failure. There is no higher priority for New View LLC other than the safet y of the public and propert y. New View LLC makes the following representations of its operation in which to abide b y to ensure these exemptions if granted, will provide a level of safety at least equal to existing rules: The Inspire 1 will onl y be operated b y, at a minimum, a private p ilot with at least a 3rd class airman medical certificate. The PIC will have completed at a minimum, 25 hours of documented flight time using the Inspire 1 with focus being: a) Collision avoidance b) L oss of C2 link procedures as outlined in the Operato rs manual for the Inspire 1 c) Identification of inflight hazards i.e. aerial wires, birds in the area, changing weather etc. d) Estimating distance from objects, persons, vehicles and vessels. e) Communication with the spotter(s) f) Completed the DJ I I nspire 1 pilot training guide maneuvers and skills. (PDF) attached. g) The ability

to recognize persons or objects that are not part of the intended and permitted part of the project that enter the 500 foot operational area unless such persons or objects are deemed permitted by

the owner or controller of the property or ar ea and the PIC makes a safety assessment of the risk of operating closer and it does not pose undue or significant risk. h) The ability

to quickl y and safel y land the DJ I Inspire 1 in the event of intrusion into the safe zone. 1.) A complete pre

- flight sy stematic check b y the PI C of the Inspire 1’s phy sical condition, i.e. props, prop guards, landing gear, position indicator lights, battery capacity and overall airframe condition. I f any

of the above are not within the manufacturers minimum standards no flight will take place until such time as the issue(s) is repaired to manufacturers standards. 2.) Written documentation of each ph ys ical inspection and repairs if any , by the PIC (pilot in command) will be kept with the Inspire and will be on

- site and available for review. 3.) Software in relation to the Inspire operation will be checked for proper function. The most current DJ I vision APP and the current firmware will be installed to assure the most up to date safet y features. 4.) Prior to every

fligh t, the compass on the DJ I In spire 1 will be calibrated as to ensure precision location. 5.) New View LLC will ensure the altimeter setting on the DJ I Inspire 1 is that of AGL (above ground level) rather than GPS or barometric pressure derived settings. 6 .) Every safet y feature offered through the DJ I vision APP will be enabled for every flight, every time. (6) Enable ground station (7) Compass calibration (8) Low battery

auto go home(9) Dy

namic home point (10) Current RTH (return to home) altitude (AGL) (14) Low battery

alarm
Of particular interest are the following: [3] Flight attitude and radar function [4] Flight parameters

- RTH (return to home) altitude, horizontal distance from home point, altitude

- vertical distance from home point, speed

- horizontal flying speed. [6] Flight Battery

L evel indication [7} There is a built in preflight checklist within the DJ I vision APP which is completed prior to each flight. [8] Aircraft GPS Status

- New View LLC’s Inspire 1 will not fly with less than (7) GPS Satellites available. [14] Hide or show flight parameters

- New View LLC’s Inspire 1 will ALWAYS fly with parameters display ed in order to assist in maintaining safe distances from persons and objects and to adhere to the flight plan. 8.) New View LL C will operate with a minimum of (1) one, trained spotter for every flight. “Trained” meaning familiarization with the DJI I nspire 1, its abilities according to the operators’ manual as well as the abilities of PI C. Spotters will participate in documented training developed in

- house prior to being allowed on the flight line. Training will consist of, at a minimum the following: a) The ability

to roughl y identify

minimum distance from objects b) The ability

to quickl y recognize unusual flight maneuvers/att itudes of the Inspire 1 c) The ability

to communicate with the PI C the visual limitations and to never let the Inspire 1 out of the visual capabilities of the PI C and the spotter(s). d) The ability

to recognize persons or objects that are not part of the intended and permitted part of the project that enter the 500 foot operational area unless such persons and objects are deemed permitted by

the owner or controller of the property or area and the PIC makes a safety assessment of the risk of operating at a closer range and it does not pose undue or significant risk to those persons or objects. “ e) The ability

to accurately

describe to the PIC, the orientation of the Inspire in relation to the pre - set home point as well as the direction of travel. f) The training will take place under strict, safe conditions away from persons or large obstacles. I. e. large open fields. 9.) Prior to each flight, the PI C and the Spotter(s) will perform a pre - flight briefing detailing the estimated flight distance, estimated flight level AGLand the goal of the particular flight. Each preflight briefing will be documented b y the PIC to include flight details, pilot name, spotter(s) name, weather details, time and date. Written and/or verbal consent will be obtained from the person/business requesting the flight. A post

- flight briefing will also be conducted and documented with the PI C and theThe Documented Pre

- flight, the raw pictures and/or the raw video footage as well as the post

flight brief and written consent will be kept by New View LLC for a period of at least (2) y ears. New View LLC believes that given the size, weight, speed, and limited operating area associated with the Inspire 1, reque sts an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safet y under 14 CFR part 11 and Section 333 of P.L . 112

- 95 (Section 333). New View LLC requests exemption from § 45.23 Marking of the aircraft. The Inspire 1 does not have a cabin, does not have a cockpit or a pilot station. Minimum sized lettering and wording are di fficult to place on the Inspire 1. New View LLC will however affix a sticker on the unit which will contain contact information for the compan y i n case of aircraft loss. New View LLC requests an exemption from §§ 91.405(a), 91.407(a) (1), 91.409(a) (2) and 91.417(a) and (b) Maintenance inspections and feel it should be granted since they onl y appl y to aircraft with an airworthiness certificate. New View LLC has developed m aintenance inspections and documentation methods for the DJ I Inspire 1 from personal experience as well as the manufacturer’s user manual.
DJIPilot in Command (PIC) Under § 61.113 (a) and (b) private pilots are limited to non

- commercial operations. Ne w View LLC will only use, at a minimum a pilot with a private pilot license, current 3rd class airmen medical certificate. Under current regulations, civil operations for compensation or hire require a PI C holding a commercial pilot certificate per 14 CFR part 61. Based on the private pilot limitations in accordance with pertinent parts of 14 CFR 61.113(a) and (b), a pilot holding a private pilot certificate cannot act as a PI C of an aircraft for compensation or hire unless the flight is only incidental to a business or employ ment. “However, in Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PI C with a private pilot certificate operating the Astraeus DJIwould not adversel y affect operations in the NAS or present a hazard to persons or property

on the ground.” New View LLC requests that an exemption allowing a private pilot employ ed by New View LL C be allowed to be the PIC of the Inspire 1 for compensation similar to the grant of exemption No.11602 to Astraeus Aerial. New View LLC requests relief from § 91.119(c) because the aircraft will be operated at altitudes below 400 feet AGL. Section 91.119(c) states that no person may operate an aircraft below the following altitudes: over other than congested areas, an altitude of 400 feet above the surface, except over open water or sparsel y populated areas. In those cases, the aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle, or structure. New View LLC will operate pursuant to the following restrictions related to § 91.119:

- Operate in reasonabl y safe environments that are closely monitored b y ground assistants and signage placed in locations that would be considered reasonable locations for pedestrians, vehicles or vessels to enter the area.

- Within 6 miles of airports and congested areas. Congested areas will be defined by VFR charts as well as b y contacting the local FSDO (flight standards district office)- Conduct all operations under New View LLC’s guidelines contained in the operating

do cuments and will analyze flight data and other sources of information such as the manufacturer’s website to constantly update and enhance safet y.

- Contact respective airports if operations will be within 6 miles to advise them of estimated flight time, fl ight duration, elevation of flight and other pertinent information deemed important by the airport.

- Alway s obtain all necessary permissions prior to operation. Permissions include but are not limited to a (COA) and a request for a (NOTAM) as well as permission from the propert y owner or person in control of the propert y and when practical will be in wr iting and kept on file for 2 ye ars for review. If it’s not possible to obtain written permission, the PI C will document in writing how permission was obtained i.e. phone call with date, time and party information. New View LLC requests relief from 14 CFR 91.121 Altimeter Settings. New View LLC’s Inspire 1 has a barometric altimeter and GPS derived altitude capabilities. The FAA requires an y altitude reported to ATC to be in feet AGL. New View LLC will set the altimeter on the Inspire 1 to zero feet AGL rather than local barometric pressure or field altitude before flight. New View LLC requests relief from § 91.151(a) Fuel requirements for flight in VFR conditions based on the following: No fuel is used in the Inspire 1 but it is battery operated. Batte ries have, in our experience have about 15 minutes of quality fl yi ng time. In the interest of safety , New View LLC generall y lands with 35% of battery

remaining which gives about 9 minutes of flying time per battery . The Inspire 1 has an audible battery st ate warning s ys tem. New View LLC will alway s follow the manufactures minimum battery warning which is 30% remaining. There is also an onscreen warning of not enough battery to return to home message if flight distance has exceeded battery capacity . In this event, an emergency landing would be made as soon as safe and practical. The Inspire 1 also has an automated function which results in immediate landing when a low battery is detected. Researching previous relief requests, relief has been granted for mann ed aircraft to operate at less than prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar DJI

- specific relief has been granted in exemption Nos. 8811, 10808, and 10673 for day time, VFR conditions. New View LLC will adher e to all VFR minimums as well as VMC conditions when planning and/or executing an y flights. There is little purpose for aerial video or pictures if the weather is less than desirable. Following VFR minimum standards will at least ensure a safe flight. Wind and forecast weather will be a key in deciding suitable conditions. Local weather can be attained from the nearest airport by using AWOS. No flight will take place in any condition that would potentially be outside of the Inspire 1 capabilities in wind. N ew View LLC will alway s fly within its 30% minimum remaining battery life at its first intended landing point. New View LLC will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting an y operatio ns. New View LLC will also request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.If there are an y areas that have not been addressed, please contact me for supplemental

information. Sin cerel y, John Parisoff New View LLC PO Box 285 Helotes, TX 78023 (210) 396

- 6224 jpdirtwork@live.com