1 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

December 12, 2014

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Petition of Micro Drone Vision, LLC for Exemption Pursuant to Section 333 of

the FAA Modernization and Reform Act of 2012.

To Whom It May Concern :

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR

Part 11, Micro Drone Vision, LLC (MDV ), hereby applies for an exemption from

Federal Aviation Regulations (FARs ) identified below, to allow commercial operations

of small unmanned aerial system ( i.e.

, sUAS ).

This exemption is in accordance with protocols outlined in this petition for exemption,

the enclosed MDV’s Op erations Manual 1

, MDV’s UAS Aircraft Training Manual 1

, the

DJI UAS manufacturer's operations and/or instructions manual , DJI UAS User’s

Manuals , DJI UAS Quick Start Guides, and any other requirements established by the

FAA pursuant to Section 333 of the Reform Act.

This exemption would permit commercial operation by MDV

, which uses DJI Phantom s

, 550S Flame Wheel s , Inspire 1, and S1000 to conduct s UAS flight training, education,

real estate photography

, and videography, film and movie production, and demonstration

flights. MDV’s o peration under the exemption will be subject to strict operating

requirements and conditions to ensure an equivalent level of safety to currently

authorized operations using manned aircraft and under conditions as may be modified by

the FAA as required by Section 333. 2

_______________________ 1 Micro Drone Vision submits the Operations Manual and Training Manual as a Confidential document under 14 CFR

§ 11.35(b), the entire content of both Manual s contain confidential commercial and proprietary information that MDV

has not and will not share with others. The se Manual s contain operating procedures and training procedures that are

not available to the public and are protected from release under the Freedom of Information Act, 5 USC § 552 (b) (4).

2 Micro Drone Vision is filing this exemption request on its own behalf; it anticipates that its customers, in the

future, will file exemption applications to allow them to operate the DJI UAS’s in commercial operations in their

own location

. Those filings will be substantially similar to this exemption application.2 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

MDV will be operated under controlled VFR conditions at low altitude in airspace that

is permitted in accordance with MDV’s approved Certificate of Authorization (COA).

They will operate t he sUAS’s with pilot s who are current and qualified with a FAA

Pilot Certificate and only after completing MDV’s training program

. Finally, the FAA

ATC will approve the airspace in which the sUAS will operate in advance.

Micro Drone Vision respectfully submits this request for an exemption because it

operates sUAS s . Currently, the operations of MDV will be conducting wil l be in lieu of

comparatively hazardous operations now conducted with fixed wing and rotary

conventional aircraft

. T he FAA can have confidence that the operations will be

conducted at an equivalent level or greater level of safety. Approval of this exemption

would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA

Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish

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

system.”

For your convenience, MDV has organized thi s Exemption request as follows:

I. Petitioner's Description

II. Relevant Statutory Authority

III. Qualifications for Approval Under Section 333 of the Reform Act

IV. Description of Proposed Operations

V. Regulations From Which Exemption is Requested

VI. Public Interest

VII. Privac y

VIII. Federal Registry Summary

IX. Conclusion

I. Petitioner's Description:

Micro Drone Vision, LLC, headquartered in Tampa

, Florida, is a company that

provides sUAS flight training , support to news services, real estate photography, film

and movie production, education, and demonstration flights in a compliant and safe

environment. MDV plans on providing a wide range of services as the sUAS market

expands

.3 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

The management at MDV has over 62 years experience in aviation and over 3 years

combined experience operating sUAS’s. The Director of Operations is a current Private

Pilot ASEL. The Chief Pilot has an ATP certificate, accumulated over 15,000 hours of

fligh t time, and is current in HS

- 125’s, LRJETs, King Air’s, and ASES’s. The Chief

Pilot is intimately familiar with operational control procedures and overseeing the safe

operations of an aviation event. The Manger has eight years working video production

and understands the requirements to integrate the sUAS into the movie sets.

MDV 's goal is to operate in an accident

- free environment by :

● Demonstrat ing a commitment by management and all employee’s to

operator in a compliant manner.

● Identify hazard and risk while eliminating or controlling all these risk.

They will use steps to intervene and report when unsafe work practices

appear to exist.

● Train all employees involved in flight operations to operate at the

highest standard level

.

The contact in formation for Petitioner is as follows:

Micro Drone Vision, LLC

20125 Heron Crossing Drive

Tampa, FL 33647

Member Managers:

Bonnie Edwards

Office: 813

- 449

- 2454

Cell: 321

- 505

- 2920

Justin W. Newcomb

Cell: 30

- 270

- 8665

II. Relevant Statutory Authority :

This petition for exemption is submitted to fulfill Congress' goal in passing Section

333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely

accelerate the integration of civil unmanned aircraft systems into the national airspace

system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to

consider whether certain unmanned aircraft systems may operate safely in the National

Airspace ("NAS") before completion of the formal UAS rulemaki ng, based on the4 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

following considerations:

• The UAS's size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas;

and

• Operation of the UAS within the visual line of sight of the operator. 3

If the Secretary determines that such vehicles "may operate safely in the National

Airspace System, the Secretary shall establish requirements for the safe operation of

such aircraft in the National Airspace System".

Additionally, the FAA Administrator has general authority to grant exemptions from its

safety regulations and minimum standards when the Administrator decides a requested

exemption is in the public interest. A party requesting an exemption must explain the

reasons why the exemption: (1) would benefit the public as a whole, and (2) would not

adversely affect safety (or how it would provide a level of safety at least equal to the

existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions.

This statutory authority, by its terms, includes exempting civil aircraft, as the term is

defined under 40101 of the Act, from the requirement that all civil aircraft must have a

current airworthiness certificate and those regulations requiring commercial pilot s to

operate aircraft in commercial service:

The Administrator may grant an exemption from a requirement

of a regulation prescribed under subsection (a) or (b) of this

section or any of sections

.

III. Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for expedited approval

under Section 333 of the Reform Act. Each of the statutory criteria and other relevant

factors are satisfied.

The proposed operations would perm it MDV the use of small UAS under controlled

conditions in airspace that is: (1) predetermined; ( 2 ) controlled as to access; and that

(3 ) provides an increased level of safety beyond that existing when fixed or rotor wing

aircraft are used to accomplish the same purpose.

_________________________

3 MDV ’s submission places a duty on the Administrator to not only process applications for exemptions under

Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order to

allow approval, to supply conditions for the safe operation of the s UAS. MDV welcomes the opportunity to consult

with FAA staff in order to address any issues or concerns that this proposal may raise that they believe may require

modification.5 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

MDV uses UAS s that are multirotor

, weighing less than 25 pounds including payload.

They operate, under normal conditions, at speed s not to exceed 45 mph and have the

capability to hover, and move in the vertical and horizontal plane. MDV ’s UASs wil l

operate in line of sight , during daylight hours, and will only operate within a sterile

area described in the enclosed Operations Manual. MDV will operate at or below 400

feet AGL and will file a NOTAM for each flight operated in controlled airspace. All

required permissions and permits would be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate

governmental agencies prior to operating a s UAS.

Given the small size of the sUAS ’ s involved and the restricted sterile environment

within which they will operate, this MDV’s exemption falls within the zone of safety

and demonstrate an equivalent level of safety, in which Congress desired the FAA to

permit commercial UAS operations by exemption pending completion of formal

rulemaking. Also, due to the size of the sUAS ’ s and the confined area in which the

sUAS ’ s will operate, approval of the application presents no hazard in the NAS.

Considering the clear direction in Sect ion 333 of the Reform Act, the authority

contained in the Federal Aviation Act, as amended, the equivalent level of safety

surrounding the proposed operations, and the significant public benefit, the grant of

the requested exemptions is also in the public interest.

IV. Description of Proposed Operations

The enclosed Operations Manual describes, in detail, the policies and procedures for

MDV 's proposed sUAS operations. To assist the FAA in its safety assessment of

MDV 's proposed sUAS operations, below is a summary of operational limitations and

conditions that will ensure an equivalent or higher level of safety to operations

conducted under current regulatory guidelines:

1. The sUAS will weigh less than 25 pounds.

2. Flights will be operated within line of sight of the PIC and observer.

3. Maximum total flight time for each operational flight will be limited

to the amount of time the sUAS can be flown and still maintain a

reserve battery power of no less than 25%.

4. Flights will be oper ated at an altitude of no more than 400 feet AGL

.

5. Flights will be operated at a lateral distance of least 100 feet from any

inhabited structures, buildings, vehicles, vessels, people not associated

with the operation or who have not signed a waiver in advance of the

operation.6 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

6. Minimum crew for each operation will consist of the sUAS

Pilot in Command and a Visual Observer . Additional

crewmembers consist of a Pilot and a Camera Operator.

7. The sUAS Pilot in Command will be an FAA licensed airman

with at least a private pilot's certificate , third class medical , and a

current check required by 14 CFR Part 61.56 in an aircraft in

which the PIC is rated on his or her pilot certificate

.

8. MDV will designate a Pilot in Command ("PIC") for each mission

.

9. The sUAS will operate only within a confined "Sterile Area" as

defined in the Operations Manual.

10. Prior to the operation s at a particular location, a site inspection will

have been conducted

. O n the day of the mission the management

person with operational control and the PIC will concur on

dispatching of the mission.

11. In accordance with Operations Manual a briefing will be conducted in

regard to the planned sUAS operations prior to each day's missions. It

will be mandatory that all personnel who will be performing duties

within the boundaries of the sterile area be present for this briefing.

12. MDV crew will use the checklist and callouts required in the

Operations Manual.

13. All sUAS’s will be maintained in accordance with inspection pr ogram specified in the MDV’s Operations Manual and in compliance with the

manufacture r’ s guidelines.

14. In the event of an accident involving an MDV sUAS, they will cease

operations and report the accident to the NTSB and AFS

- 80.

15. Pilot in Command and Visual Observer will at all times be

able to communicate by voice.

16. Pilot in Command, Pilot, Camera Operator, Visual Observer, and

Operational Personnel will have been trained and tested in accordance

to MDV’s UAS Aircraft Training Manual

.7 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

17. All required permissions and permits would be obtained from

territorial, state, county or city jurisdictions, including local law

enforcement, fire or other appropriate governmental agencies.

18. In compliance with approved Waiver, MDV management will submit

a written “ P lan of Activities ” to the local Flight Standards District

Office ( FSDO) having jurisdiction over the area of proposed filming

three day s in advanced of operations during film or movie

productions

.

19. If the sUAS loses communications signal, the sUAS will have the

capability to return to a pre

- determined location within the Sterile Area

and land.

20. Contingency plans will be in place to safely terminate flight if there

is a loss of communication between the pilot and the observer.

21. The sUAS has the capability to abort a flight in case of

unpredicted obstacles or emergencies.

22. MDV, by following procedures listed in the Operations Manual will

assure no individuals’ privacy is violated

.

23. Procedures have been established in MDV’s Operations Manual to

contact ATC prior to operating in airspace other than G.

V. Regulations From Which Exemption is Requested

A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and

Limitations; Pilot in Command

B. 14 CFR § 91.103: Preflight Action

C. 14 CFR § 91.113 : Right

- of

- Way Rules

D. 14 CFR § 91.119 (c): Minimum Safe Altitudes

E. 14 CFR § 91.121: Altimeter Settings

F. 14 CFR § 91.151(b ): Fuel Requirements for Flight in VFR

Conditions

G. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b):

Maintenance Inspections8 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations ;

Pilot in Command

Section 61.113(a) & (b) limit private pilots to non

- commercial operations. Unlike

a conventional aircraft that carries a pilot, passengers, and cargo, the DJI sUAS’s

are remotely controlled with no passengers or property of others on board. MDV

respectfully proposes that the FAA should take into account the characteristics

and procedures of the particular UAS.

Micro Drone Vision proposes that the actual operation of the DJI sUAS does

not require the Pilot to hold a private pilot certificate

. Instead, the actual site

operation requires a private pilot certificate. MDV proposes the following

requirements :

• Pilot in Command Requirements:

1. The PIC must possess a Private Pilot’s Certificate and a valid third

- class

medical certificate;

2. The PIC must have accumulated and logged a minimum of 200 flight cycles

and 25 hours of total time as a UAS pilot and at least 10 hours logged as a

UAS pilot with a similar UAS type (single blade or multirotor) and 5 hours in

type of UAS aircraft

.

3. The PIC must have accumulated and logged a minimum of five hours as

UAS pilot with the make and model of UAS to be utilized for operations

under the exe mption and three takeoffs and landings in the preceding 90 days.

4. The PIC must have successfully completed the qualification process as

specified in the MDV Operations Manual and MDV Training Program, to

include a knowledge and skill test.

5. The PIC must al so meet the flight review requirements specified in 14 CFR

Part 61.56 in an aircraft in which the PIC is rated on his or her pilot

certificate.

• Pilot Requirements:

1. The Pilot must have accumulated and logged a minimum of 200 flight cycles

and 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours

logged as a UAS pilot with a similar UAS type (single blade or multirotor).

2. The Pilot must have accumulated and logged a minimum of five hours as

UAS pilot with the make and model of UAS to be uti lized for operations

under the exemption and three takeoffs and landings in the preceding 90 days.

3. The Pilot must have successfully completed the qualification process as

specified in the MDV Operations Manual and MDV Training Program , to

include a knowle dge and skill test.

4. The Pilot must have successfully completed the recurrent requirements as

specified in MDV Training Program within the last 12 calendar mon ths.9 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

Equivalent Level of Safety

Micro Drone Vi sion utilizes both a PIC and a P ilot to increase safety during flight

operations. While the Pilot is concentrating on flying the UAS the PIC has the ability

oversee safety of the entire operations. The PIC will always remain within 10 feet of the

Pilot when the UAS is airborne to assist or take over if an emergency should happen.

Procedures developed by Micro Drone Vision far exceed the current safety requirements

established by the FAA. Micro Drone Vision respectfully requests the option to use a

two pilot crew and the second crewmembe r not having to possess a private pilot

certificate.

B. 14 CFR § 91.103: Preflight Action

MDV requests an exemption from the preflight actions requirements of 14

CFR 91.113 that prescribes the preflight actions under which aircraft may operate:

Each pilot in command shall, before beginning a flight, become familiar with all

available information concerning that flight.

(a) F light under IFR or a flight not in the vicinity of an airport, weather reports and

forecasts, fuel requirements, al ternatives available if the planned flight cannot

be completed, and any known traffic delays of which the pilot in command has

been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following

takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight

Manual containing takeoff and landing distance data is required, the

takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those sp ecified in paragraph (b)(1) of this

section, other reliable information appropriate to the aircraft, relating to

aircraft performance under expected values of airport elevation and

runway slope, aircraft gross weight, and wind and temperature.

MDV will no t operate sUAS’s under IFR conditions or when the ceilings are below

1000 feet and the visibility is below 3 statute miles. DJI’s sUAS’s do not have published

approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance

data

.

Eq uivalent Level of Safety

Located in MDV Operations Manual are procedures describing steps the PIC along with

the person having operational control must follow to assure that the weather will be

adequate to complete the mission in VFR condition. Since MDV operates in Florida10 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

where the density altitude is never usually above 2000 feet, UAS performance is not

affected. When MDV is allowed to operate in other parts of the United States the UAS

used in those locations will be test flown at gross weigh t to test performance limitations

prior to conducting commercial operations.

C. 14 CFR 91.113: Right

- of

- Way Rules

MDV request an exemption from 14 CFR 91.113 Right

- of

- way rules, requiring

vigilance by each person operating an aircraft so as to see and av oid other aircraft. When

a rule of this section gives another aircraft the right

- of

- way, the pilot shall give way to

that aircraft and may not pass over, under, or ahead of it unless well clear.

Micro Drone Visions operates small pilotless UAS’s and canno t comply with these rules

as they have been written.

Equivalent Level of Safety

MDV operates sUAS’s at or below an altitude of 400 feet AGL, well below the normal

operating altitude of other aircraft. MDV Operations Manual specifies that a Pilot in

Command with experience will oversee each mission and has knowledge of the avoid

rules . A Visual Observer will assist the PIC in look ing for aircraft entering the operations

area. It’s the responsibility of the PIC to cease operations and land the UAS imme diately

whenever and aircraft comes in to the vicinity creating a potential threat

. Operations

cannot recommence until the threat is clear.

D

. 14 CFR. § 91.119: Minimum Safe Altitudes

MDV requests an exemption from the minimum safe altitude requirements of 14

CFR 91.119 that prescribes the minimum safe altitudes under which aircraft may

operate :

• Over any congested area of a city, town, or settlement, or over any open air

assembly of persons, an altitude of 1,000 feet above the highest obsta cle within

a horizontal radius of 2,000 feet of the aircraft.

• Over other than congested areas at a n altitude of 500 feet above the surface,

except over open water or sparsely populated areas. In those cases, the aircraft

may not be operated closer than 50 0 feet to any person, vessel, vehicle, or

structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum

altitudes when it can be operated "without hazard to persons or property on the

surface," provided that "each person operating the helicopter complies with any routes

or altitudes specifically prescribed for helicopters by the FAA."

To provide the intended operations , the sUAS is normally operated below 400 feet11 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

AGL. Additionally, due to the nature of the proposed operations, the sUAS will

maintain a lateral distance of at least 100 feet from inhabited structures, buildings,

vehicles, and vessels, and from people not associated with the operation.

Equivalent Level of Safety

Compared to flight normal aircraft, MDV’s multi

- rotor air craft weigh a maximum of

25 pounds

, and given the lack of flammable fuel, any risk associated with these

operations is far less than those that presently exist with conventional aircraft. An

equivalent level of safety will b e achieved given the size, weight, and speed of the

UAS, as well as the location where it is operated. As set forth in the Operations

Manual, the sUAS will be operated in a sterile area, where buildings and people will

not be exposed to operations without their pre

- obtained consent. Because of the

advance notice to the property owners and participants, all affected individuals will be

well aware of the planned flight operations as set forth in the Operations Manual.

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with

aircraft that are subject to the minimum safe altitude regulations. Finally, the

successful safety record of the DJI sUAS’s demonstrates that the sUAS can be safely

used at these lower altitudes and c loser operating environments.

E. 14 C.F.R. § 91.121: Altimeter Settings

MDV seeks an exemption from 14 CFR 91.121, which requires a person operating an

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is

set to the elevation of the departure airport or barometric pressure. An exemption is

required because the sUAS does not have a barometric altimeter, but rather a GPS

altitude read out.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in

the Operations Manual. MDV will confirm the altitude of the launch site shown on

the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude

indicator to constantly monitor the sUAS's height, thus ensuring operation at safe

altitudes.

F . 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

MDV requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in

VFR conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions

unless (considering wind and forecast weather conditions) there is

enough fuel to fly to the first point of intended landing

, and

assuming normal cruising speed

–12 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

(1) During the day, to fly after that for at least 25 minutes; or

(2) At night, to fly after that for at least 45 minutes.

The batteries powering MDV’s UAS’s provide approximately 10

- 1 8 minutes of

powered flight. To meet the 30 minutes reserve requirement in 14 CFR 91.151, sUAS

flights could not be conducted. Given the limitations on the sUAS's proposed flight

area and the location of its proposed operations within a predetermined area, a safety

margin based on a reserve amount of battery life is needed.

MDV will not be conducting any sUAS flights at night.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be conducted

on

- site without significant transit time by the sUAS. All flights will be planned to

terminate with no less than 25% reserve battery power still available. This restriction

would be more than adequate to return the sUAS safely to its planned landing zone

from anywhere in its confined area of operation even in the event of an unexpected

occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel does not

include the type of risks that Section 91.151(a) was intended to alleviate given the size

and speed of the small UAS, and the proximity of the flight operation to the landing

zone. Moreover, operation will be limited to controlled areas where only people and

property owners, or official representatives who have signed waivers will be allowed

.

G . 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b):

Maintenance Inspections

MDV also seeks an exemption from the maintenance inspection requirements contained

in 14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2)

, 91.417(a) and (b). These regulations

specify maintenance and inspection standards in re ference to 14 CFR Part 43. 14 CFR

91.405(a) (stating that each owner or operator of an aircraft "shall have the aircraft

inspected as prescribed in subpart E of this part and shall between required inspections

...have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption

to these regulations is needed because Part 43 and these sections only apply to aircraft

with an airworthiness certificate, which the sUAS will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections

will be performed in accordance with the MDV Operations Manual and DJI User’s

Manuals

. As provided in the Operations Manual, the operator will ensure that the

sUAS is in working order prior to initiating flight, perform required maintenance, and

keep a log of any maintenance performed. The operator is the person most familiar

with the aircraft and best suited to maintain the aircraft in an airworthy condition to

provide the equivalent level of safety.13 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight

operations will only take place in restricted areas for limited periods of time during

daylight hours, creates less risk than that associated with conventional rotorcraft

performing the same operation.

VI. PUBLIC INTEREST

Granting Micro Drone Vision , LLC an exemption furthers the public interest. National

policy set by Congress favors early integration of UAS into the national airspace in

controlled, safe working environments such as those propose in this petition. The one

vision of MDV is to help facilitate safe integration of sUAS’s into mainstream USA

in the following areas:

• Movies and Videography

Whether the shot requires unique views and expansive panning or extreme

altitude with radical views, the UAS is designed to hold up under demanding

conditions. Because of the autopilot feature with pre

- designed mission

management and R/C control interrupt, the pilot and camera operator can easily

create the ultimate shot with HD video or HD still photos. When working close

in on a closed set the hazards to the actors are greatly reduced due to the size of

the sUAS.

• News Gathering

Similar to movies and videography, each news assignment may require a

completely different shot or view of a scene. With budgets for traditional

helicopter use being greatly reduced, the UAS is the perfect solution to allow for

easy news gathering for a fraction of the cost. The sUAS can and will be

operated in a sterile area away from the public, while the traditional helicopter

must hovers over persons and property increasing the danger to individuals.

• Real Estate

The s UAS can be used in all areas of real estate, including commercial,

residential and industrial properties. Using a s UAS, real estate professionals can

create promotional videos, photos and unique shots that normal camera aspects

cannot capture. MDV’s easy

- to

- use video and photo platform enables properties

to stand out, providing dazzling views that are typically shown v ia expensive

computer animation or costly helicopter rentals. Imagine shooting a view from a

high

- rise condo in stunning high definition that shows your potential customer

the actual view from the residence. The remote platform is great for new

planning, z oning and large developments. Simple and easy

- to

- use video and

photos allow for multiple height pictures and elevation views.14 Page

- MDV Exemption Request 

## MICRO DR ONE VISION

LLC

• Fire and Rescue

MDV would introduce and demonstrate to f ire and rescue personnel t he sUAS’s

reliability and the capability to perform in extreme situations. The ability to offer

real time HD and IR video facilitates placing personnel and equipment in the

right places. Also, with modern FLIR cameras, areas can be identified for

potential ‘hot spots’ and addition al focus without pu tting personne l at risk.

MDV ’s mission is to assist governmental agencies safely into the NAS.

• Law Enforcement and SWAT

MDV would introduce and demonstrate to Law enforcement officers that s UAS

excel in rapid deployment and chal lenging situations

. Most s UAS ’s deploy in

less than 5 minute s

. MDV is working with a manufacture r that has developed a

sUAS that will deploy in 1 minute

. With a video package, the s UAS provides

law enforcement with seamless incident situational awareness, tactical support

and a ccident photography. Using the s UAS, police and SWAT can quickly

assess potential threats; take HD photos of a crime scene or FLIR video of an

area to find hidden threats.

• Agriculture and Conservation

MD V would introduce and demonstrate to farmers of all types that t he s UAS can

aid commercial agriculture, land management and conservation efforts by

assessing crops, mapping flood zones, measuring snow pack and more. The

s UAS can fly pre

- saved missions via the fully automated ground station, which

allows for time

- lapse photos of fields, crops and known land tracts. It also can

accurately recreate the same pattern during all seasons, providing invaluable data

for land and soil management. Using HD video, HD photos

, and IR cameras

allows for d etailed analysis and recording. With photo rendering software, 3D

maps and topography can be used in conjunction with time

- lapse photos to create

highly detailed maps for erosion, flood mapping and other critical aspects of l and

management



### .

VII. Privacy

Micro Drone Vision has established a chapter in their Operations Manual to protect the

public privacy. MDV knows that many individual have concerns about privacy from

the operations of s UAS’s. MDV has created a privacy notice that informs residents,

commercia l property owners, churches, schools, and governmental organizations of

our intent to conduct commercial drone operations in proximity to their property.

### M I 

### C R 

### O D R 

### O 

### N E V I 

### S I 

### O 

### N

L L C

V I I I

. F

e d

e r a l R

e g i

s t r y S

u m m a r y

P u r s u a n t t o 1 4 C F R P

a r t 1 1

, t h

e f

o l l

o w i

n g s u m m a r y i

s p r o v i d

e d f

o r p u b l i

c a t i

o n i n t h

e

F

e d

e r a l R

e g i

s t e r

, s h

o u l d i t b

e d

e t e r m i

n e d t h

a t p u b l i

c a t i

o n i

s n e e d

e d

: ' i

M i

c r o D

r o n e V i

s i

o n

, L L C

s e e k

s a n e x e m p t i

o n f

r o m t h

e f

o U

o w m g r u l

e s : * '

1 4 C F R P a r t 6 1

. 1 1 3 ( a ) a n d ( b ) ; 1 4 C F R 9 1

. 1 0 3 ; 1 4 C F R 9 1

. 1 1 3 ; 1 4 C F R 9 1

. 1 1 9

- 1 4

^ C F R 9 1

. 1 2 1 ; 1 4 C F R 9 1

. 1 5 1 ( a ) ; 1 4 C F R 9 1

. 4 0 5 ( a ) ; 1 4 C F R 9 1

. 4 0 7 ( a ) ( 1 ) ; 1 4 C F R ;

9 1

. 4 0 9 ( a ) ( 2 ) ; 1 4 C F R 9 1

. 4 1 7 ( a ) & ( b )

.

A p p r o v a l

o f t h i

s e x e m p t i

o n r e q u e s t a l l

o w s M D V t o c o n d

u c t c o m m e r c i

a l

o p e r a t i

o n s

w i t h

s m a l l

a n d l i g h t w e i g h t u n m a n n e d

a e r i

a l

s y s t e m s

. M D V O

n e V i

s i

o n i

s t o

e n h

a n c e s a f

e t y o f

s U A S

o p e r a t i

o n s i

n t h

e N A S w h i l

e r e d

u c i

n g r i

s k t o t h

e g e n e r a l

p u b l i

c a n d p r o p e r t y o w n e r s

.

T h

e D J I s U A S

, w e i g h i

n g l

e s s t h

a n 2 5 p o u n d

s a n d p o w e r e d b y b

a t t e r i

e s

, e l i m i

n a t e s

v i

r t u a l l y a l l

o f t h

a t r i

s k g i

v e n t h

e r e d

u c e d m a s s a n d l

a c k

o f

c o m b u s t i b l

e f u e l

c a r r i

e d

o n b

o a r d

. T h

e s U A S i

s t r a n s p o r t e d t o t h

e d

e s i g n a t e d m i

s s i

o n a r e a a n d

s e t u p t h

e r e

. i

T h

e s U A S w i l l

c a r r y n o p a s s e n g e r s o r c r e w a n d

, t h

e r e f

o r e

, w i l l n o t e x p o s e t h

e m t o

t h

e r i

s k

s a s s o c i

a t e d w i t h m a n n e d a i

r c r a f t f l i g h t s

.

T h

e o p e r a t i

o n o f t h i

s s m a l l U A S w i l l p r o v i d

e a n e q u i

v a l

e n t l

e v e l

o f

s a f

e t y

, s u p p o r t i

n g

t h

e g r a n t o f t h

e e x e m p t i

o n s r e q u e s t e d h

e r e i

n

, i

n c l

u d i

n g e x e m p t i

n g t h

e a p p l i

c a n t f

r o m

t h

e r e q u i

r e m e n t s o f

s e v e r a l

r e g u l

a t i

o n s a n d

a l l

o w m g c o m m e r c i

a l

o p e r a t i

o n s

. T h

e s e

l i g h t w e i g h t s U A S '

s o p e r a t e a t s l

o w s p e e d

s

, c l

o s e t o t h

e g r o u n d

, a n d i n a s t e r i l

e

e n v i

r o n m e n t

. A

s a r e s u l t

, t h

e y a r e f

a r s a f

e r t h

a n c o n v e n t i

o n a l

a e r i

a l

s u r v e y a n d

i

n s p e c t i

o n o p e r a t i

o n s c o n d

u c t e d w i t h f i

x e d w i

n g a n - c r a f t o r h

e l i

c o p t e r s

. C

I f

a d d i t i

o n a l i n f

o r m a t i

o n i s r e q u i

r e d

, o r i f y o u h

a v e a n y q u e s t i

o n s r e g a r d i n g t h i s

P e t i t i

o n f

o r E

x e m p t i

o n

, p l

e a s e c o n t a c t t h

e u n d

e r s i g n e d

a t : %

V

e r y t r u l y y o u r s

,

B

o n n i

e L

. E d w a r d

s

, M

a n a g e r

M i

c r o D

r o n e V i

s i

o n

, L L C

C

e l l P h

o n e : 3 2 1

- 5 0 5

- 2 9 2 0

E m a i l

: b

o n n i e @ m i c r o d

r o n e v i

s i

o n

. c o m

1 5 P

a g e - M D V E

x e m p t i

o n R

e q u e s t