Brian Love

830 Flaxmill Rd. Huntington, IN 46750 Phone: (260)224

- 3323 Email: brian@baileylove.com
U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
RE: Exemption Request Section 333 of the FAA Reform Act of 2012
Dear Sir or Madam, Pursuant to §333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Vertical Visions APV, operator of Small Unmanned Aircraft Systems (sUASs) equipped to conduct aerial photography for the media and advertising industries for pre

planned, controlled area, photographic and surveying services, hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the Federal Aviation Administration (FAA) as required by §333. Vertical Visions APV’s current operation s of sUASs for commercial purposes has been halted to comply with recently enacted federal aviation regulations pertaining to sUASs.
As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive multi

- rotor aircraft under controlled conditi ons in airspace that is 1) contained 2) predetermined 3) has on

- site safety personnel controlling access, and 4) would provide increased safety and enhancements to clients' business operations. The name and address of the applicant is:

Vertical Visions APV Attn: Brian Love Ph: (260)224

- 3323 Email: verticalvisionsapv@gmail.com Address: 830 Flaxmill Rd., Huntington, IN 46750
Vertical Visions APV respectfully requests a grant of an exemption of the following sections of Title 14 of the Code of Federal Regul ations:

• 14 CFR 21;

• 14 CFR 91, et seq.;

• 14 CFR 45.23 (b); • 14 CFR 61.113 (a)& (b); • 14 CFR 407 (a) (1 ); • 14 CFR 409 (a) (2);

• 14 CFR 417(a)&(b).Vertical Visions APV also respectfully requests an Exemption from Section 333 of the FAA

Reform Act a nd Part 11 of the Federal Aviation Regulations from:

• 14 CFR 45.23(b) ;

• 14 CFR 61 .1 (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);

I. The Extent of Relief Vertical Visions APV Seeks and the Reason It Seeks Such Relief: Vertical Visions APV submits this application in accordance with th e Reform Act, 112 P.L. 95 §§331

- 334, seeking relief from any currently applicable federal aviation regulations PARs pertaining to UASs (unmanned aircraft systems) and operating to prevent Vertical Visions APV contemplated commercial photography, photographic mapping, and other flight operations within the U.S. national airspace system. The Reform Act in §332 provides for such integration of civil UASs into our national airspace system as it is in the public's interest to do so. Vertical Visions APV’s lightweight UAS meets the definition of "small unmanned aircraft" as set forth in §331 and comb ined with a sterling safety record in similar industries, Vertical Visions APV's light duty UAS are ideal recipients of exemption by the intent of the Reform Act. Considerations for relief include a combination of sUAS physical characteristics, safety feat ures, and safe practices identified in §333:

• sUAS weight,

• sUAS overall size,

• sUAS speed over ground, • sUAS flight zone characteristics,

- Non

-operation near airports (civilian or military)

- Tightly controlled operation in populated areas
• Operation of the UAS by VLOS,

• Coordination by a minimum of 2 p ersons: 2 members of Vertical Visions APV and one safety official from the business it’s pertaining to.
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates : 14 C.F.R. §91.203 (a) (1) S ubpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated sUASs, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 1 1 and §333 of the Reform Act. 11 1e Federal Aviation Act (49 U.S.C.§4470 1 (f)) and §333 of theReform Act both authorize the FAA to exempt aircraft from the requirement for an

ai rworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The sUAS to be operated by Vertical Visions APV is less than 11kg. with maximum payload consisting of remote sensing instrumentation, carries neither no persons, carries no explosive or flammable materials including combustible fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the pilot (PIC), 'spotter' role designated to act as both the remote sensing controller and second ary monitor for safety issues, and a technician, which assists in matters related to maintaining the sUAS and also monitors for safety concerns and liaisons to the on

-site safety officials. These enhancements to current safety practices and regulations, wh ich already apply to civil aircraft, provide a greater degree of safety to the public and property owners than conventional aircraft operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of thes e same criteria demonstrates that there is no intrinsic credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of intrinsic explosive materials or flammable liquid fuels, and inability to car ry a substantial external load.
14 C.F.R. §45. 23 (b). Marking of the Aircraft: The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed 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. Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experi mental" can be placed. Given the size of the sUAS, two

- inch lettering will be impossible. The word "Experimental" will be placed on the frame in compliance with §45.29 (f) at a size suitable for the available space. The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification of the UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. Further markings include the use of flashing green LED illumination on the underside of the sUAS frame which stands at contrast against a blue or white sky.

14 C.P.R. §61.113 (a) & (b): Private Pilot P rivilege s and Limitations: Pilot in Command: §61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operatio ns by requiring a ground crew member to have a private pilot’s license rather than a commercial pilot’s license to operate this sUAS. Unlike a conventional aircraft thatcarries the pilot and passengers, the sUAS is remotely controlled with no persons on b oard. The

area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplate d by Part 61 when drafted, that allowing operations as requested with a private pilot in the ground crew exceeds the present level of safety achieved by 14 C.P.R. §61.1 13 (a) & (b).
14 C.P.R. §91.7(a): Civil aircraft airworthiness: The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, shoul d this exemption be granted, no FAA regulatory standard will exist for determining airwort hiness. Given the size of the aircraft and the requirements contained in the manual for maintenance and use of safety checklists prior to each flight, a subset of which are provided in enclosed Supplemental material, an equivalent level of safety will be p rovided.
14 C.F.R. §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft: §91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this cha pter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The sUAS, given its size and configuration has no ability to carry a phys ical flight manual on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,8737,8738,9299, 9299A, 9565,95658, 10167, 10167A, 10602,32827, and 10700.

14 C. F.R. §91.103: Preflight action: This regulation requires each PIC to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data before initiation of flight. Further, we have proprietary manuals created with the help of sUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and continue to work with these organizations to ensure best safe practices are a dhered to.
14 C.P.R. §91.109: Flight instruct ion: §91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. sUASs and rem otely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight tra ining without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft. Enhancing this safety is the technology inherent in the remote controls utilizingdigital communications which is paired to the sUAS making it nearly impossible to

unintentionally or intent ionally have the control communications interrupted.

14 C.F.R. §91.119: Minimum safe altitudes: §91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provide d the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that closely mimics the behavior of a helicopter, and the exemption requests authority to operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL or beyond unaided visual lin e of sight, whichever is closer. It will however be operated in a restricted area with s ecurity officials tasked with ensuring public safety, and where buildings and people will not be exposed to operations without their pre

- obtained consent and training. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight operation will be taken without the permission of the property owner in the case of private property or local officials in the case of public property or private property with public interests. Becau se of the advance notice to the property owner and participants in the remote sensing activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations wi th aircraft or rotorcraft weight ing far more than the m aximum 11kg of Vertical Visions's sUAS s proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

alti tude operations of the sUASs will ensure separation between these small

- UAS operations and the operations of conventional aircraft that must comply with §91.119.
14 C.F.R. §91. 121 Altimeter Settings: §91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "...to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. The PIC and Technician will also ensure effective pairing wi th multiple GPS sources to guarantee accurate detection of height.
14 C.F.R. §9 1.15l (a): Fuel Requirements for Flight in VFR Conditions: §91.151 (a) prohibits an individual from beginning "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

- (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 4 5 minutes:' The battery powering the sUAS provides approximately 20 minutes of powered flight in hover mode with out payload. Vertical Visions APV's sUAS will not be able to meet the 30 minute reserve requirement in 14 CPR §91.151. Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve power, does not engender the type of risks that Section 91.1 51(a) was intended to alleviate given the size and speed of the small UAS. Vertical Visions APV believes that an equivalent levelof safety can be achieved by limiting flights to » 10 minutes or 25% of battery power whichever

happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.
14 C.P.R. §91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration: The regulation provides in pertinent part: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate..

. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passen gers or crew. The sUAS fully loaded weighs no more than 11kg and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. An equivalent level of safety wi ll be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representa tive sample of other exceptions includes Exemption Nos. 9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700.
14 C.P.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections: These regulations require that an aircraft operator or ow ner "shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...;' and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the ope rator pursuant to the flight manual. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues aris e the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreove r, 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.
An exemption granted to Vertical Visions APV would permit its operation of lightwei ght, unmanned, remotely controlled, sUASs in a tightly controlled environment with limited airspace. Vertical Visions APV utilizes local business' safety officers in specifically determined areas (design at ed flight zone) to mitigate injury and property dam age while fulfilling clients' goals. Technical enhancements to current safety controls will allow Vertical Visions APV to operate exceeding current safety specifications, and stay ahead of, or meet, new ones being implemented by the FAA and Department of T ransportation. Further, Vertical Visions APV conducts its operations in compliance with protocols described herein or as otherwise established by the FAA.II. Commercial and Public Benefits

We at Vertical Visions APV believe that granting this exemption request furthers the public interest by providing safe (by way of an unmanned system) and efficient means to meet technical problems solvable by elevated data collection instruments. Vertical Visions APV 's client base are typically small to medium sized business' looking to increase their awareness of structures or landscape on their respective properties through data collection , other Public Interest, aerial videography for geographical awareness, and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has been cost

- prohibitive. Granting this exemption to the petitioner would allow him to provide this service at a much lower cost. Further, the petitioner i ndicates his small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. The petitioner also states that the operation of his UAS will minimize ecological damage and promote economi c growth by providing information to companies loo king to relocate or build in Northeast Indiana area by photographic, video graphic or lidar based surveying. By moving these functions onto sUAS based aircraft, the potential for loss of life or property is diminished due to the greater control in a smaller and safer aircraft that holds no persons. Second, there are no reactive or combustible materials on board the sUAS and thus the potential for fire or explosions is greatly diminished. Third, the small siz e and extreme maneuverability of Vertical Visions APV UASs allow the PIC to avoid hazards. Lastly, due to the nature of the remote sensing instrumentation onboard, the sUAS can maintain quite a safe distance between the aircraft and the object(s) undergoin g scrutiny. Accordingly, Vertical Visions APV 's UASs have operated and will continue to operate at and above current safety levels.

A. The costs and benefits of your proposed action to society in general and specific groups within society : As described above, Vertical Visions APV 's past customers have been small to medium business seeking a remote sensing solution to specific issues before a larger effort on their part would come underway. Examples include construction efforts that sought el evated photographic imagery of specific landforms to minimize cost of efforts to develop, a regional park service that wanted to quantify the changing lifecycle of it's flora by way of measuring leaf health through gradual chlorophyll depletion, and a loca l cities' Dept. Fish and wildlife that sought to collect images and wooded area data by way of photographic means of it's trees to serve as a supplement to it's routine repair and planning documentation. The impact to society, financial and otherwise, woul d be extremely minimal. Indeed, it's been demonstrated that sUASs have the ability to drastically increase the information available to policymakers at a fraction of the cost of measuring this data by terrestrial means. One such impact would be inconvenien ce to directly proximal and non

- essential personnel that would be displaced from public or business owned property if it is deemed to be unsafe. In this case we relay our needs for a fl ight zone with the requirement that it be safe from casual intrusions a nd allow the business time to shift operations in order to minimize potential safety issues. This is best performed with the aid of safety personnel that actively steer non

- essential persons around the flight zone.
1. The effect of an exemption for Verti cal Visions APV on the quality of the natural and social environments : Utilizing sUASs minimizes the requirement for conventional aircraft. This eliminates the needfor an onboard pilot, time consuming adherence to regulations surrounding bookkeeping and

s ubmission of flight paths to local civilian or military airports, and detrimental effects to the environment caused by operating a combustible fuel based, large scale aircraft, with restrictions on the proximity to the target for remote sensing.

III . Fli ght Capabilities and Characteristics of Vertical Visions APV 's UASs Persuant to 112 P.L. 95 §333 (a), concerns for public safety are mitigated by the overall capabilities and characteristics of the sUAS. Vertical Visions APV sUASs have four (4) counter

- rotating propellers paired oppositely to each other for balance, control and stability. The total span of the sUAS is less than 1.2m allowing for stable flight or landing even with the sudden onset of detrimental environmental condi tions. The sUAS's have a maximum unit + payload mass of 11kg, including cinematic/photographic or other surveying equipment. Vertical Visions APV 's sUAS is designed to primarily hover in place to capture photographic data and then operate at less than a 35 knot maximum speed to the next point of interest. They are capable of vertical and horizontal operations but, in practice, is operated only within unaided VLOS of the PIC. In addition to the PIC, Vertical Visions APV employs a spotter (VOS role) and a technician (secondary VOS and on

- site personnel liaison) which are within unaided verbal communication range. These personnel are supplemented by safety officials provided by the client who are instructed to cordon off and otherwise pedestrian access in the flight zone of the clien t's grounds. In the event of a loss of visual of the UAS, the PIC can change flight controls from cartesian (X,Y,Z) based controls to radial (r,a,h) based controls which allows the PIC to utilize one controller axis to recall the VAS to the PIC's position without concern to the current heading of the sUAS. In the event of loss of sight of the sUAS into an area containing hazards or possible hazards, the spotter has a heads

- up
- display containing a live video feed which can be used to locate the UAS while it maintains it's position in hover mode. The sUAS has demonstrated it's ability to maintain it's position by GPS coordinates in hover mode in 25kph wind gusts as an extreme environmental condition beyond the range of conditions within the scope for sUAS operation. All of Vertical Visions APV's sUASs utilize LiPo (lithium polymer) battery based power sources, decreasing safety risks from more easily combustible, fuel based, power sources. Flight times generally last between eight (8) to ten (10) minutes allow ing the staff to work with small flight areas per phase. The maximum flight time without payload is 20 minutes, however practical safe operation limits this to 10 to give ample time to control the sUAS to a safe landing zone. Vertical Visions APV further restricts flight time by not operating its sUASs with less than twenty five percent battery capacity. Further safety management systems in place include a GPS mode that allows Vertical Visions APV sUASs to hover in place if communication with the PIC is lost and optionally follow a set of waypoints at a set speed and height to a 'home base' predesignated safe landing zone. In the event of UN

-foreseen motor(s) failure, the system will enter into a controlled descent while allowing full use of all UAS flight c ontrols by the PIC. All commands sent via remote controller received during a controlled descent are translated to an 'as meant' paradigm meaning the flight control package will use it's real

-time 3 dimensional position and compensate rotors to control the sU AS regardless of spin velocity. This assures that if one system is compensated a safe and successful landing can still occur.IV. Reasons Why an Exemption to Vertical Visions APV Will Not Adversely Affect Safety

Standards Vertical Visions APV 's conten ds that operation of it's sUASs will not "create a hazard to users of the national airspace system or the public:' as stated in 112 P.L. 95 §333 (b). Given the diminutive size and weight of Vertical Visions APV 's sUASs, combined with their operation in
cordoned off and well

- controlled areas, Vertical Visions APV 's sUASs falls within Congress's contemplated safety zone. Vertical Visions APV sUASs have an established safety record bolstered by multi

- point preflight checklist, awareness of their surroundings a nd intimate knowledge of the behavior of the sUAS platform in many weather conditions. T his safety record and implemented operational practices demonstrate an awareness of public safety. Vertical Visions APV operations routinely provide a level of safety a t least equal to existing rules, and in nearly every instance, exceeds existing rules. Vertical Visions APV has worked very closely with the regional vendors and support for this unit to create a tightly integrated and highly tolerant platform that has been tested thoroughly by a vendor with a proven record for safety and solid designs

. Vertical Visions APV als o continues to work closely with organization s to identify and mitigate sUAS platform risk due to their expertise in several i ndustries closely related to aviation and transportation. Vertical Visions APV does not operate its UASs on or near airports and generally has only operated its fleet on private grounds with cordoned off areas or areas under the control of the property owner/client with assistance by safety officials employed by the business. Vertical Visions APV determines the areas needed to fulfil l the clients' goals and only operates its UASs in these flight zones and only in compliance with well regarded safety protocols set forth initially by the RC UAS trade and hobby groups and recently codified by relevant FARs.

Vertical Visions APV standardized on the following practices to ensure safe operation of it's UASs: • Work with on

- site personnel to plan the flight goals,

• Work with on

- site personnel to restrict a ccess to non

- essential persons, • Operation by unaided VLOS operation only, • Operat ion to minimal 25% battery power, • Operation in phases 10 minutes in length,
• Operation of device to GPS aid ed readout to 400ft at maximum, • O ur pre
- programmed fail

- safes that ensure specific behavior per issue,
• Three main roles supplemente d by on

- s ite safety personnel,
• Employ controlled lifecycle management of components to guard against multiple failures, • Perform a site check day(s) before flight to identify potential issues, • Subscribe to relevant local weather and safety alerts, • Expertly c hoose data collection instruments and accessories to minimize flight requirements or expertise,

Vertical Visions APV has experience in similar fields and ha s adapted this experience in it s use of UASs to increase safety. In combination to the ever expandi ng knowledge repositories from hobbyists and experts alike, Vertical Visions APV is constantly evolving it s practices when there is a clear benefit to operations or increased safety element.Summary:

Pursuant to 14 C.F.R. Part 11, the following summary i s provided for publication in the Federal Register, should it be determined that publication is needed: Vertical Visions APV {applicant) seeks an exemption from the following rules: 14 C.P.R. §21, subpart H; 14 C.F.R 45.23(b); 14 C.P.R. §§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); 91.409 (a) {2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (11kg or less) in elevated photographic and remote sensing operations. Approval of exemptions allowing commercial operations of s UASs in the the media industry will enhance safety by reducing risk associated with conventional aircraft operations and other means of elevated remote sensing invol ving persons. The public benefit served by approval of this petition is increased awareness of characteristics of difficult imaging target s. A sUAS weighing fewer than 11 kg and powered by sealed batteries eliminates virtually all associated risk inherent i n operating conventional aircraft in close proximity to buildings or persons or otherwise elevating persons to a position they would be able to collect needed data. The operation of small UASs, weighting less than 55lbs., conducted in the strict condition s outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations.
As identified and described herein, Brian Love, and his company Vertical Visions APV, is an experienced, recognized media services professional in the various photographic industries. Mr. Love and his companies have been producing and delivering media and technical solutions for the m edia service industry for ten (10 ) years with a spotless safety record. The FAA has been given the authority to issue the exemption to Vertical Visions APV pursuan t to the Federal Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek your consideration and approval of this petition.

encl: Supplement A: Physical characteristics of UAS encl: Supplement B: Flight Operation and Procedures Manual (FOPM) relate d to ope ration
Supplement B : Summary Sections of Flight Operations and Procedure Manual (FOPM)
• All regular and irregular operations are noted with timestamps, relevant UAS metrics and corrective action procedures (CAP) that are performed.

- Note: All irregular behavior have root cause analysis performed before UAS operation is resumed.
Emergency Procedures • Loss of Remote Signal

- The flight package features an optional enhanced fail

- safe which returns the UAS to the home base waypoint via the s ame path taken to point of lost signal.

- The UAS will then preform a hover over this waypoint and then a controlled landing. • Loss of GPS signal- The system will operate in GPS assisted mode with three (3) satellites.

-At a loss of three (3)

GPS sat ellites, manual mode can be activated or the flight package can be programmed to p e rform a controlled landing to the home base waypoint.

- Ground based height ranging is p e rformed by a separate system and so loss of GPS will not impact controlled landing in a safe manner. • Loss of Engine Power

- In the event of one (1) (or to two oppositely positioned) rotor or motor failure the system will enter into controlled spin where all controls are translated based on current orientation and will behave as nor mal operation to the PIC to ensure a safe landing,

- In the event of multiple rotor or motor failures the flight package can be configured to p e rform a safe landing or attempt operation to home base waypoint.

- Note : Behavior of the landing location i s highly dependent on the position and number of rotors/motors that are affected. • Loss of Ground Control Software

-This will not affect operation of the flight. The unit will be piloted to a safe landing area and then landed so that examination of the link can be made. http://www.steadidrone.com/support/QU4DQuickstartGuide.pdf https://pixhawk.org/users/first_steps http://www.steadidrone.com/support/check.jpg http://www.steadidrone.com/support/PeriodicMaintenanceChecklist.pdf http://www.steadidrone.com/support/QU4DAirframeAssemblyGuide.pdf
More characteristics have been outlined in the enclosed supplemental materials.