July 31 , 2015

Federal Aviation Administration U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Petition of 360 CloudView

, LLC for Exemption Pursuant to Section 333 of the FAA Reform Act

Petitioner’s Name and Address:
360 CloudView

, LLC

Owner s : Neil Watson and James Sebastian Goebel 3127 Honeydew Dr. Carrollton, TX 75007

469

- 235

- 4018 Neil.Watson@360CloudView.com Sebastian.goebel@360cloudview.com

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Refo rm Act of 2012 (the Reform Act)
and 14 CFR Part 11, 360 CloudView

, LLC , operator of Small Unmanned Aircraft Systems (“ sUAS ”) equipped to conduct aerial photography and vid eography, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs” ) to allow commercial operation of its sUAS, so long as such operations are conducted within an d under the conditions outlined herein or as established by the FAA as required by Section 333.1

As described more fully below, the requested exemption would permit the operation of small,
unmanned sUAS under controlled conditions in a irspace that is 1) Limited 2) P redetermined and 3) C ontrolled. The proposed exe mption, if granted, would allow 360 CloudView

, LLC to conduct commercial operations of sUAS meeting or exceeding all of the operational and safety requirements set forth in Sect ion 333.

360 CloudView LLC is an aerial photography and cinematography company owned and operated by Neil Watson and James Sebastian Goebel.

360 CloudView LLC plans to use the capabilities of sUAS to offer a multitude of services, including:

- Construction site inspection and monitoring

- Event Photography/Videography

- Agriculture and Livestock monitoring

- Water level monitoring- Real Estate Photography and presentation

- Aerial nature photography Petitioner meets all requirements to permit FAA approval of commercial UAS operations.

The name and address of the applicant are:

Name: 360 CloudView LLC

Owner: Neil Watson and James Sebastian Goebel
Address: 3127 Honeydew Dr

. Carrollton, TX 75007
Phone: 469

- 235

- 4018
Email: Neil.Watson@360CloudView.com ; Sebastian.Goebel@360cloudview.com

Regulations from which the exemption is requested:

14 CFR 61.113(a) and (b) 14 CFR 61.23(a) and (c) 14 CFR 61.101 (e) (4) and (5) 14 CFR 61.315 (a)

14 CFR 91.7 (a)

14 CFR 91.9 (b)(2)

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151(a) and (b)

14 CFR 91.203 (a) & (b)

14 CFR 91.205 (b)

14 CFR 91.215

14 CFR (91.401

- 91.417)

In addition to providing cost savings and having little to no impact on the en vironment, sUAS provide enhanced safety. These factors are beneficial for, and in the best interest of, the public. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

Petitioner is requesting an exem ption to enable 360 CloudView

, LLC to operate a DJI Inspire 1 sUAS that is upgraded to latest version f irmware, equipped with a 3 axis Zenmuse camer a gimbal, which uses a High

- Def. video camera that can capture up to 4K (4096x2160p) video and 12M pixel photos. This sUAS has a built

- in capability to limit 1) the height it flies above the ground and 2) the radius of the distance it flies from the operator. The DJI Inspire 1 also has the
fail

- safe fu nction of the autopilot system , when communication between the Main Controller and the transmitter is disconnected, the system will automatically trigger Return to Home and will land safely.

The Inspire 1 weigh s 2935 grams or 6.47 pounds with battery.The PIC will conduct a pre

- flight safety check before all f lights, in accordance with the factory

instruction manual, as well as redundant checks to include the Internal Measurement Unit (IMU) to make sure that the compass, gyro and acceleration values are within specs, positive
GPS locks are secure, battery healt h in each individual LiPo cells are balanced, and radio signals
are locked in. The sUAS will be maintained in accordance with the manufacturer’s instruction
manual and only manufacturer's authorized replacement parts will be used.

FCC Information

The Inspire 1 transmitter used for controlling the sUAS complies with part 15 of the FCC rules. Operation is subject to the following two conditions: (1) this device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation. The Inspire1 radio transmitter used for controlling the sUAS is wireless technology which has been tested and found to be compliant with the applicable regulations governing a radio transmitter in the 2.400GHz to 2.4835GHz frequency

range.

Antenna Separation Distance

When operating the aircraft transmitter , the PIC will maintain a separation distance of at least 5 cm between his body (excluding fingers, hands, wrists, ankles and feet) and the antenna to meet RF exposure safety requirements as determined by FCC regulations.

Pilot in Command and Observer Qualifications and Duties

The PIC will maintain at least a Light Sport Pilot Certificate and a current State issued driver’s
l icense

.

The PIC is responsible for the safe and efficient operation of the ai rcraft. Specific duties include all preflight preparation and inspection, in flight operation, po st flight requirements, and all procedures including but not limited to:

 Safe in flight oper ations

 Risk evaluation

 Current weather conditions for safe flight

The Observer must have the visual acuity to observe the sUAS and be able to communicate clearly with the PIC.

The Observers duties are:

 Warning the PIC of any impending obstacles in t he flight path of the sUAS.

 Warning the PIC of any deviations in the planned flight path of the sUAS. Warning the PIC should any unauthorized personnel appear in the area of the planned

flight.

The Observer will have the authority to order the PIC to terminat e the flight should he or she
feel the flight cannot be conducted safely.

General Operating Standards

• 360 CloudView LLC will only operate its sUAS in line of sight of a pilot and/or observer

and will operate at sites that are a sufficient distance from populated areas.

• Such operations will insure that the sUAS will "not create a hazard to users of the national airspace sys tem or the public."

• Before an operation of a sUAS within 5NM of an airport with a control tower, the
control tower will be call ed to gain permission to operate the sUAS. The PIC will give the position, altitude and the times the sUAS will be operated. The sUAS will not be operated at an altitude of over 4 00 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling.

• Flights will be terminated at 30% battery power reserve

• The sUA S will be programmed so that it will not be operated at an altitude of no more
than 4 00 feet AGL, and not more than 4 00 feet above an elevated platform from which operations are plann ed.

• Minimum crew for each operation will consist of the sUAS Pilot, and Visual Observer.

• The sUA S operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimba l ).

• The sUAS will operate at speeds of no more than 25 knots, can hover, and can simultaneously move vertically and horizontally.

• Given the small size of the sUA S and the restricted sterile environment within which they will operate, our sUA S operations adhere to the Reform Act's safety requirements.

 The sU AS, powered by batteries, is smaller, lighter and more maneuverable than larger
aircraft running on combustible fuel. The sUAS operates at lower altitudes with no people on board and will thereby reduce current risk levels, enhance safety and
diminish the likelihood of death or serious bodily injury.

Low level oblique photos and video from several angles are far more effective than ground based imagery for displaying the characteristics of large, complex subjects . The benefits of
reduced cost and i mproved quality of production from the sUAS over manned aircraft will be
valuable t o many potential customers and the local economy

.

(a) No flight will be made with a Gross weight exceeding 55 pounds; (b) All operations must occur in FAA Cl ass G airspace at no more than 4 00 ft. AGL, at an airspeed of no more than 25 knots and no further than 1600 ft. , or 0.263 NM from the
PIC; (c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice or radio at all times during a flight operation;(d) Operations will be restricted to flights over private prop erty only with the expressed

permission of the property owner; (e) All required permits will be obtained from state and local government prior to operation; (f) 360 CloudView LLC will not operate over densely populated areas; (g) 360 CloudView LLC will not operate over any open

- air assembly of people; (h) 360 CloudView LLC will not operate over heavily trafficked roads; (i) 360 CloudView LLC will not operate at night.

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

360 CloudView LLC requests an exemption from the following regu lations as well as any additional regulations that may technically apply to the operation of the sUA S :

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 6 1.133 Commercial p ilot privileges and limitations

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Subparagraph (b ) allows a private pilot to act as pilot in command of an aircraft in connection with any bus iness or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposed operations require that the PIC must hold at least a Private Pilot Certificate with a Class III Medical issued by the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this applica tion is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 CFR 91.9 Civil air craft flight manual, marking, and placard requirements

This regulation provides that no person may operate an airc raft unless a current, approved flight manual is in the aircraft. We assume that the intent of thi s requirement is to ensure that flight manu al information is available to the aircrew while operat ing the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation; the documentation would not be available to the crew during flight operati ons. To obtain an equivalent level of safety and meet the intent of 91.9, we p ropose that a current, approved sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight, and ready for present ation for any governing official upon request.

14 CFR 91.119 Minimum safe altitudesThe regulation states that over sparsely populat ed areas the aircraft cannot be operated closer

than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the ite ms listed. Operations will only be flown over property or persons where permission has been obtained and careful preplanned flight path has been performed. The aircraft will be opera ted at a low altitude allowing, if a power unit fails, an emergency landing without undue hazar d to person s or property on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft , which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 4 00 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other
aircraft. An Above Ground Level altimeter measurement above t he takeoff point is transmitted

v ia radio from the sUAS on

- board computer to the display scre en held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions

The regulation provides that no person may begin a flig ht in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of in tended landing and to fly after
that for at least 30 minutes. We feel the intention of this pa ragraph is to provide an energy reserve as a safety buffer for delays to landing. T he aircraft will never fly more than 0.263 NM from the point of intended landing, a full battery charge at launch wi ll ensure that we meet the

reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equ ivalent interpretation with the word "energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required

The regulation provides that an airworthiness certificate, with t he registration number assigned to the aircraft and a registration certificate must be abo ard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificat e be "displaye d at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of 6.47 pounds, the sUAS is too small to carry documentation, does n ot have an entrance, and is not capable of carrying passengers or crew. To obtain an equivale nt level of safety and meet the intent of 91.203, we propose that documents deemed appropria te for this aircraft by the FAA will be with the crew at the ground control station and available for inspection upon request . In order to identify the aircraft, we propose that the informa tion found on airworthiness and registration certificates be permanently affixed to the airc raft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR

45.23.14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance,

Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Parag raphs 91.407 and 91.409 require that the aircraft be "approved for return to servi ce by a person authorized under 43.7" after maintenance and inspection. It is our intention t hat the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy conditi on prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limi ted to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for t he on

- board computer. All other maintenance will be performed by the manufacturer or their designated r epair facility. The PIC
wil l document work performed in accordance with 91.417 . We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

Safety and Benefits of the UAS

360 CloudView LLC will be using the UAS in a variety of appl ications that generally require expensive full

- size manned aircraft to complete. Small, light, unmanned aerial vehicles offer
more efficient and safer benefits over the use of full

- s ized manned aircraft for aerial photography, advanced agriculture monitoring, film and still photography, real estate marketing, (see attachment 4), and water supply monitoring. D ue to drought conditions in the area over the past few years, this would greatly supply safer, faster, and mo re efficient
information to our local officials who need this information abou t the lake levels and our water supply.

Replacing significantly larger manned aircraft carrying crew an d flammable fuel with small UAS carrying no passengers or crew creates a much greater margin of safety for the pilots and crew. By granting 360 CloudView LLC ‘s requested exemptions, the FAA will help drive development of safe and successful commercial UAS operations and will advanc e the public knowledge base for such operation s. 360 CloudView LLC is committed to promot ing the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by s haring data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAA ha s good cause to grant this Petition.

Conclusion As pointed out in this application, the DJI Inspire1 whi ch our company would use, under authorization by the US DOT

- FAA, is a small, light

- weight dev ice operated within the line of sight of the Pil ot

- in

- Command (PIC), less than 4 00 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, or other loc ation with aviation activities, unless the air traffic control authorities (ATC) have been no tified and have authorized each flight within a radius of this distance.The DJI Inspire1 has been proven capable for controlled flight. It is a UAS offered for general

sale on the market around the world and have often been used as Model Aircraft in the USA.
FAA studies , about Section 332, Public Law 112

- 95, 2014, have already provided necessary assurances of the airworthiness of the same or similar sUAS

.

For the foregoing reasons, the exemptions requested herein should be granted and 360
CloudView LLC s hould be permitted to conduct small UAS operations in accordance with its
manuals and all other operating parameters deemed necessary and appropriate by the FAA.

Signed

,

Neil Watson
President
360 CloudView

, LLC Neil.Watson@360CloudView.com James Sebastian Goebel Chief Operating Officer 360 CloudView, LLC
Sebastian.Goebel @360CloudView.com