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 preplanned, 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 operations 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 conditions 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 Regulations:

• 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 and 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 the 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 combined 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 features, 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 persons: 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) Subpart 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 11 and 

§333 of the Reform Act. 111e Federal Aviation Act (49 U.S.C.§4470 1 (f)) and §333 of the 
Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness 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 secondary 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, which 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 these 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 carry 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 "Experimental" 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 Privileges 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 operations 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 that 
carries the pilot and passengers, the sUAS is remotely controlled with no persons on board. 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 contemplated 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, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

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 provided.

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 chapter, 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 physical 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 adhered to.

14 C.P.R. §91.109: Flight instruction:

§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 remotely 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 training 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 utilizing 
digital communications which is paired to the sUAS making it nearly impossible to 

unintentionally or intentionally 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, provided 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 line of sight, whichever is closer. It will however be operated in a 

restricted area with security 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. Because 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 with aircraft or rotorcraft 

weighting far more than the maximum 11kg of Vertical Visions's sUASs 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 lowaltitude 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 with 

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 45 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 91.151(a) was intended to alleviate 

given the size and speed of the small UAS. Vertical Visions APV believes that an equivalent level 
of 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 passengers 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 will 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 representative 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 owner "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 

operator 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 arise 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. 

Moreover, 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 lightweight, 

unmanned, remotely controlled, sUASs in a tightly controlled environment with limited 

airspace. Vertical Visions APV utilizes local business' safety officers in specifically determined 

areas (designated flight zone) to mitigate injury and property damage 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 Transportation. 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 

indicates 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 economic growth by 

providing information to companies looking 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 size 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) 

undergoing 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 elevated 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 local 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, would 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 inconvenience 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 flight zone 

with the requirement that it be safe from casual intrusions and 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 Vertical Visions APV on the quality of the natural and social 

environments:

Utilizing sUASs minimizes the requirement for conventional aircraft. This eliminates the need 
for an onboard pilot, time consuming adherence to regulations surrounding bookkeeping and 

submission 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. Flight 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 conditions. 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 client'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 allowing 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 controls 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 sUAS 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 contends 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 and intimate 

knowledge of the behavior of the sUAS platform in many weather conditions. This safety record 

and implemented operational practices

demonstrate an awareness of public safety.Vertical Visions APV operations routinely provide a 

level of safety at 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 also continues to work closely with organizations to identify and mitigate 

sUAS platform risk due to their expertise in several industries 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 fulfill 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 access to non-essential persons,

• Operation by unaided VLOS operation only, 

• Operation to minimal 25% battery power,

• Operation in phases 10 minutes in length, 

• Operation of device to GPS aided readout to 400ft at maximum,

• Our pre-programmed fail-safes that ensure specific behavior per issue, 

• Three main roles supplemented by on-site 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 choose data collection instruments and accessories to minimize flight requirements 

or expertise,

Vertical Visions APV has experience in similar fields and has adapted this experience in its use of 

UASs to increase safety. In combination to the ever expanding knowledge repositories from 

hobbyists and experts alike, Vertical Visions APV is constantly evolving its 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 is 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 sUASs in the the media industry will 

enhance safety by reducing risk associated with conventional aircraft operations and other 

means of elevated remote sensing involving persons. The public benefit served by approval of 

this petition is increased awareness of characteristics of difficult imaging targets. A sUAS 

weighing fewer than 11kg and powered by sealed batteries eliminates virtually all associated 

risk inherent in 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 conditions 

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 media 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 pursuant 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) related to operation

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 same 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 satellites, manual mode can be activated or the flight package can be programmed to 

perform a controlled landing to the home base waypoint. 

-Ground based height ranging is performed 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 normal 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 

perform a safe landing or attempt operation to home base waypoint.  

- Note: Behavior of the landing location is 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.