U.S. Department of Transportation July 20, 2015

Docket Management System

1200 New Jersey Ave., SE

Washington DC 20590

Focus Aero, LLC

Section 333 Petition to Operate

Small Unmanned Aerial Systems

Prepared by:

Paul Bartlett

President, Focus Aero, LLC

2953 Walsh Drive

Rochester Hills, MI 48309

248.766.3007

paul@focusaero.com
Petition Summary

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub L. 

N0. 112.85 (2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation 

Administration's (“FAA”) general exemption authority under 49 U.S. C. section 

44701(f), Focus Aero, LLC (“Petitioner”) hereby petitions for exemptions from 14 

C.F.R. Part 21, Subpart H (Airworthiness Certificates), 14 C.F.R. Part 27 

(Airworthiness Standards, Normal Category Rotorcraft), 14 C.F.R. sections 61.101(e)

(4)(5), 61.113(a)(b), 61.315(a), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a)

(1), 91.409(a)(1)(2) and 91.417(a)(b), and 97.1(a), .

The proposed exemption, if granted, would allow Petitioner to conduct commercial 

operations of small unmanned aircraft systems (“UAS”) also known as unmanned 

aerial vehicles (“UAV”) meeting or exceeding all of the operational and safety 

requirements Congress has set forth in Section 333.

Petitioner is a marketing and digital media company with experience in data 

collection, video recording and photography previously using ground and motor 

vehicle mounted camera systems. 

This has included but is not restricted to low and high elevation imaging of 

• Construction Projects

• Real Estate Marketing

• Event and Attraction Marketing (Golf Courses, Amusement Parks, etc.)

• Automotive Performance and Feature Videos

• Industrial Plant Operations (Exterior and Interior)

• Energy Use Surveying

• Pipeline/Powerline Inspection

• Agricultural Inspection

• Land Survey Measurement

The exemption would facilitate the use of Unmanned Aerial Systems to allow more 

efficient and safer capture of data and images at higher altitudes (not to exceed 400 

feet AGL) and operations over more rugged and remote locations than are currently 

possible with ground based systems.

Other proposed operations under consideration for the petitioner include community 

liaison and educational demonstrations for groups such as law enforcement, schools, 

business organizations and others.

The President and main officer of the Petitioner has held a Private Pilot Certificate – 

Airplane Single Engine Land since 2004, and will utilize that certificate along 

applicable medical certification and flight review requirements to act as the chief pilot

and flight operations manager for the Petitioning company. He will be examining 

qualifications and operating training programs for various roles in the Petitioner's 

flight operations. He also has over 200 hours in self-administered flight training and 

maneuvers testing in unmanned light multi-rotorcraft of many varieties.
At this time, the Petitioner will be operating two types of unmanned vehicles, the DJI

Phantom 3, and the DJI Inspire 1, utilizing qualified pilots and observers as required.

These vehicles will be flown at no more than 55 pounds total weight, and at speeds 

of no more than 87 knots (100 miles per hour). Energized by batteries with a flight 

time of up to 22 minutes, they are connected to four electric motors and four rotor 

blades per vehicle. The vehicles use GPS and physical data based sensors to detect 

their own location as well as designating critical operational areas and providing 

automatic return to base processes in case of loss of signal or low energy 

circumstances.

Petitioner's vehicles will be identified by serial number, registered with the FAA in 

accordance with 14 C.F.R. Part 47, and have identification markings as large as 

practicable, in accordance with 14 C.F.R. Part 45, Subpart C.

Pre-Flight Inspection

The following inspection steps have been designed and tested for use by our flight 

department before every flight in a manner similar to manned aircraft flights.

1. Inspect all rotor blades for free and clear rotation. Check for any cracks or 

deformities. Replace blades that show signs of damage

2. Check camera for gimbal range of motion, bent parts, or loose wires

3. Check battery in use for structural damage or other deformities

4. Check the entire frame for cracks including the landing gear

5. Check every motor to make sure they are seated properly and not loose 

(including all the screws)

6. Boot up the drone on a flat surface and let it go through start-up

7. Calibrate the compass and any other systems depending on drone model.

8. Bring UAV to a hover slightly above eye-level and check for and strange 

movement/shaking

9. While recording video, do basic maneuvers (forward, backward, left, right, yaw

left, yaw right, up, down).

10. Review video to confirm no abnormal vibrations are detected.

Flight Operations

Our current survey and video capture operations are typically conducted in areas 

completely cleared of persons or property that would be in peril from accident other 

than those specific to the project, and we would continue to emphasize these 

procedures even more with UAVs.

Weather considerations including wind limits, humidity, and precipitation will be 

analyzed and applied toward every flight, as the type of aircraft being utilized need 

optimal conditions for safe and effective operations.

Any vehicle that cannot pass its pre-flight inspection will be pulled from service until 

repaired to satisfactory condition.

Mission operations will be flown within visual line of sight of the pilot at all times, and
a designated observer will maintain constant visual contact with the aircraft and 

verbal contact with the pilot in command. UAVs will remain 100 feet away from any 

inhabited structures or vehicles, but may approach closer to uninhabited elements 

for detailed surveying or imagery.

For UAS operations within 5 nautical miles of non-towered airports, petitioner will 

contact airport management to obtain any necessary permissions and to submit 

requested notifications such as “NOTAMs”.

Benefits derived from this specific petitioner.

Petitioner has maintained close business relationships for many decades with 

automotive companies, event management companies, and advertising agencies in 

the United States and other countries. Many of these companies are headquartered 

in the State of Michigan, and we will be leading communication in this state on the 

positive uses of UAS operations, as well as obtaining a lot of feedback from these 

companies as to their requirements and questions regarding these operations.

We plan to continue involvement in local and national UAS advocacy groups as well, 

along with publishing white papers and other reports regarding our experiences and 

recommendations.

Another major concern of petitioner is recognizing and respecting citizen's right to 

privacy in their homes and helping develop operational standards that will foster 

positive attitudes toward UAV operations as the industry expands in the future.

Conclusion

For the reasons listed herein, we believe it would be a positive decision to grant the 

exemptions requested and allow the Petitioner to initiate UAS operations in 

accordance with safe operational documents provided by the vehicle manufacturers, 

the petitioner's own flight department, and operating parameters deemed necessary 

and appropriate by the FAA and other applicable governmental agencies moving 

forward.

Sincerely,

Paul Bartlett

President, Focus Aero, LLC