VideoGuy.com

Russell J. Maiorana

39 Pretoria Ln.

Palm Coast Fl 32164

Cell: 516

- 287

- 7714

email: Russ@VideoGuy.com

Date: December 18, 2015

U. S. Department of Transportation,

Docket Management System

1200 New Jersey Ave. SE

Washington, DC 20590

RE: Petition of Utility Aerial Services, Inc. for Exemption Pursuant to Section 333

of the FAA Reform Act

Dear Exemption Manager,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act)

and 14 C.F.R. Part 11, VideoGuy.com, operator of Small Unmanned Aircraft Systems

(“sUASs”) equipped to conduct aerial photography and videography, hereby applies for an

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commerci al 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 FAA as required by Section 333.1

As described more fully below, the requested exemption would permit the ope ration of small,

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1)

limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow

VideoGuy.com to conduct commercial operations of small unmanned aircraft systems (“UAS”)

meeting or exceeding all of the operational and safety requirements Congress has set forth in

Section 333.

VideoGuy.com is a media/technology company that plans to exploit the capabilities of

Unmanned Aerial Systems to of fer a multitude of services, including:

- Aerial surveying

- Remote sensing

- Event Photography/Videography

- Agriculture purposes

- Real Estate Photography

- Aerial filmmaking and photography

- Construction site inspections and monitoring

- Wildlife and forestry monitori ng

- Educational and research operationsStatutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil

UAS operations in the NAS. Section 333(a) sta tes that the FAA “shall determine if

certain unmanned aircraft systems may operate safely in the national airspace system

before completion of the (comprehensive) plan and rulemaking required by section

332(b)(1) of this Act or the guidance required by sec tion 334 of this Act.” In Section

332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited

operation authorization” if several factors are met. Petitioner meets all requirements to

permit FAA approval of commercial UAS operati ons.

The Petitioner Requests Relief From the Following:

Regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F .R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 - 91.417)

Unmanned Aircraft System sUAVs are oftentimes seen as superior to helicopters due to the

smaller devices cheaper equipment and pers onnel cost, reduced noise and as such, a much

smaller environmental impact which promotes public safety.

We are petitioning for exemption to enable VideoGuy.com to operate a DJI Phantom 2 vision

and the Phantom 2 are equipped with a three-axis gimbals and using High-Def cameras. This

SUAV has a built- in capability to limit the height it flies above the ground, to limit the radius of

the distance it flies from the operator and to exclude it from Class B, C and D airspace including

a no fly zone feature. The Phantom also has the failsafe function of the Naza-M autopilot

system which means when the communication between the Main Controller and the transmitter

is disconnected, the outputs of all command sticks from controller will go to the center position.

If the GPS signal is good enough, the system will automatically trigger Return to Home and will

land safely.

The above specifications meet with the Model Aircraft Operating Standards as set

below:

• VideoGuy.com will only operate its sUAS in line of sight of a pilot and/or observerand will operate at sites that are a 'sufficient distance' from populated areas within the sterile

area described in the FOPM. Such operations will insure that the sUAS will "not create a hazard

to users of the national airspace sys tem or the public."

• When flying sUAV within 3 miles of an airport, airport operators will be notified and the

operator will give the right of way to avoid flying in the proximity of full-scale aircraft.

• Maximum flight time for each operational flight will be 30 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the

30 minute limit.

• The sUAV will be programmed so that it will not be operated at an altitude of no more

than 400 feet AGL, and not more than 200 feet above an elevated platform from

which filming is planned.

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

• The sUAS operated by the petitioner weighs less than 55 pounds, including the

payload (i.e. camera, lens, and gimbal).

• The sUAV will operate at speeds of no more than 50 knots, can hover, and can

simultaneously move vertically and horizontally.

• Given the small size of the sUAS and the restricted sterile environment within which

they will operate, our sUAS operations adher e to the Reform Act's safety

requirements.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft

running on combustible fuel, it operates at lower altitudes with no people on board and will

thereby reduce current ris k levels and thereby enhance safety and diminish the likelihood of

death or serious bodily injury. With a small payload and maximum flight time of only 20

minutes, this is offers little or no risk to national security.

Low level oblique photos and video fr om several angles are far more effective than ground

based imagery for displaying the characteristics of large, complex properties with several

buildings and large trees. The applicants in the past have chartered 2-seat full-sized

helicopters for this purp ose, which has proven more costly than many potential clients have

been able to afford. The benefits of reduced cost and improved quality of presentation from

the UA will be valuable to and benefit many buyers and sellers of real property.

Additionally, w e request that we be allowed to use our system to benefit first responders

nearby who might require assistance, including fire fighters, the police, the sheriff, et al.,

while remaining subject to all limitations cited in this application as we do so.

(a) No f light will be made with a Gross weight exceeding 55 pounds;

(b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at

an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC;

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able

to communicate by voice at all times during a flight operation;

(d) Operations will be restricted to flights over private property with the permission of

the property owner;

(e) All required permits will be obtained from state and local government prior to operation;(f) VideoGuy.com will not be operate over densely populated areas;

(g) VideoGuy.com will not be operating over any open-air assembly of people;

(h) VideoGuy.com will not be operating over heavily trafficked roads;

(i) VideoG uy.com will not be operating within 5 NM of an airport or heliport;

We respectfully request exemption under Section 333 to enable VideoGuy.com to operate

efficient, limited, low-risk commercial sUAV operations for the activities

stated respecting at all t imes the space and privacy of citizens and property whilst keeping

our skies safe.

Sincerely

Russell J. Maiorana

VideoGuy.com

Russ@VideoGuy.com

516

- 287

- 7714