(May

15, 2015) U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations
Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Visual Aerial Pros, seeks an exemption from Federal Aviation Regulations (“FARs”) detailed below for (1) DJI Inspire 1, and (1) DJI Phantom3 quadcopters manufactured by DJI Innovations. The requested exemption would support an application for a commercial Certificate of Authorization to use the system to support aerial photography and videography. The DJI Inspire 1 (6.5lb) and DJI Phantom3 (3 lb) consist of a battery operated aircraft, a tablet
- based ground control station and/ a RC Controller, and associated communications equipment. Both aircrafts carry an onboard geo
- referenced gimbaled camera that allows it to obtain photography and videography. The Unmanned Aircraft System will be operated in the field with a PIC in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS". Visual Aerial Pros respectfully requests the grant of exemption allowing to operate lig htweight , remote controlled UAS's lawfully and safely. Visual Aerial Pros also respectfully requests Exemption Request Section 333 from (but not limited to) the Specific Sections of Title 14 of the Code of Federal Regulations and part ll of the Federal Aviation. Regulations listed below.14 C.F.R.45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9

(b) (2); 91.103(b); 91.109; 91.119; 91.121~ 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b)
The extent of relief Visual Aerial Pros seeks and the reason why: Visual Aerial Pros is seeking relief from any applicable FARs operating to prevent Visual Aerial Pros from conducting aerial shots of real estate and other possible legal flight operations. The weig ht of the UAS meets the definition of ''small unmanned aircraft” found in section 331 "The Reform Act”

. Visual Aerial Pros seeks to operate legally as a small business that cater mostly to real estate agents. Realtors are not allowed to use UAS's or hire u nless they or the person they hire, is al lowed by the FAA to fly a UAS. Visual Aerial Pros would satisfy the need for safe and affordable aerial shots. At less than 7 pounds, Visual Aerial Pros uses UAS that is considerably less than 55 pounds including the camera that is attached. The UAS will be used at speeds under 35 mph because of the nature of the business and the limited physical capabilities of the UAS. It is designed to hover and take pictures. The UAS will be in accordance with flying well below 400ft. The UAS in which Visual Aerial Pros would be using only utilizes battery power for its operations. There are no combustible fuels used in the UAS that Visual Aerial Pros uses. The maximum flight t ime for our particular UAS is 20 minutes battery l ife. It will fly no more than 15 minutes maximum at one time at one location. The amount of time the UAS will be in the air, less than 400ft, is very minimal. A Safety system in place for Visual Aerial Pros UAS includes a GPS mode that allows the UAS to return home if communication is lost. Further, the GPS onboard allows the UAS to return back to its launched position if the battery life of the UAS is low.THE GROUND STATION PART OF THE SYSTEM:

A Pilot in Command (PIC) in operational control of a flight operation from beginni ng to end and who controls the UAS while in the air. Additionally, the line of site of the UAS will not leave the sight of the PIC. A 2.4GHz radio transmitter/controller operated by the PIC to control the U.AS while in fl ight; A radi o receiver receiving live video, and flight data from the on
- board camera and computer. It projects it all in one screen to the Pilot in Command The UAS, weighing less than 7lbs fully loaded, is powered by batteries and operates with no peo ple on board which lowers the likelihood of death or serious bodily injury. With a small payload consisting of harmless electronics such as a camera and GPS, the UASs only purpose is to be used as a tool to take pictures and videos. Low level aerial photo s and video from several angles are far more effective than ground based photos. Low level aerial video and pictures show the layout of properties with the advantage of seeing more in one photo or short video. Current applicants have used helicopters and small planes for this purpose but the cost of fuel, time, and emissions of such aircraft is not efficient enough for most customers to afford. The benefits of reduced cost and improved efficiency of the UAS allows future customers to afford this service with a faster turnaround time at a lesser cost. Additionally, I respectfully request that VISUAL AERIAL PROS be allowed to use the UAS to benefit possible first responders our local area for actions that could benefit the public. Such as, fires and search and rescue.Visual Aerial Pros will not operate a UAS near airports and generally does

not fly over crowds. Situational awareness is most important . The areas where Visual Aerial Pros conducts aerial photography is predetermined which allows for a co ntrolled environment to operate safely. With allowing Visual Aerial Pros to conduct business with a light weight UAS, it could very well help the economy and benefit people in first response situations. Further, Visual Aerial Pros UAS is considerably lighter than the alternative which is a helicopter or small plane. Currently, Visual Aerial Pros has 2 UAS which only operates off 20 minutes of battery power. Therefore, the UAS used by Visual Aerial Pros would only have a flight time of 5
- 15 minutes at one time. The likelihood of injury or even death with such a small unmanned aircraft, compared to an aircraft flown by a person loaded with combustible fuel, is considerably low
SUMMARY: Visual Aerial Pros is more than willing to follow the safety guideli nes of the FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS'1 with the appropriate exemptions for flying a small UAS. A

- No flight will be made with a UA Gross weight exceeding 55lbs B
- All operations must occur in FAA Class G airspace at no more than 400 ft. AGL, at an airspeed of not more than 25 knots and no further than 3/4 NM from the Pilot In Charge C
- Operations will be restricted to flights over private property with the p ermission of the property owner D
- All requ ired permits will be obtained from state and local government prior to operation E
- The UAS will not be operat ed over densely populated areas F
- The UAS will not be operated at air shows G
- The UAS will not be operated over any open - air assemb ly of people H
- The UAS will not be operated ove r heavily trafficked roadsI
- The UAS will not be operated within 5 N M of an airport or heliport

J
- Operations will be rest ricted to day only an d weather conditions equivalent to VFR K
- The PIC will notify property owner about the operation and risk before the first flight at each new location; L
- No flight may be made without a Pre
- Flight Inspection by the PIC before each operati on to ascertain that the UAS is in a condition safe for flight (see Appendix A). My operations above are the bare minimum safety guidelines Visual Aerial Pros will follow. Visual Aerial Pros is also more than willing to follow any additional safety requirements if not listed above.
Visual Aerial Pros believes flying its UAS a s a small business within th e safety parameters of the FAA, can help people and promote the economy. The name and contact information of the applicant is: Visual Aerial Pros Attn; Adrey Arrojo Phone: 305
-431
- 3777 Email: VISUALAERIALPROS@GMAIL.COM Visual Aerial Pros respectfully requests that the FAA grant its exemption request without delay. I very much look forward working together with you guys. Thank you for your time. Respectfully,
Adrey Arrojo Visual Aerial Pros 305
-431
- 3777