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 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 FAA as required by Section 333.1

As described more fully below, the requested exemption would permit the operation 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 offer a multitude of services, including:

- Aerial surveying

- Remote sensing

- EventPhotography/Videography

- Agriculture purposes

- Real Estate Photography

- Aerial filmmaking and photography

- Construction site inspections andmonitoring

- Wildlife and forestry monitoring

- Educational and research operations
Statutory 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) states 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 section 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 UASoperations.

The Petitioner Requests Relief From the Following: 

Regulations from which the exemption isrequested: 

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 personnel 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 observer
and 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 system 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, andgimbal).

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

simultaneously move vertically andhorizontally.

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

they will operate, our sUAS operations adhere 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 risk 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 from 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 purpose, 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, we 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 flight 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) VideoGuy.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 times 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