UNITED STATES OF AMERI CA DEPARTMENT OF TRANSPORTATION FEDERALAVIATION ADMINISTRATION

WASHI NGTON, DC

Regulator Docket No. ______________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF:**

**INSIGHT VIDEO SOLUTIONS,**  **Inc FOR**  **AN EXEMPTION SEEING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS**  **61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND**  **91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF UN MANNED**  **AIRCRAFT PURSUANT TO SECTION 333 OF**  **THE FAA MODERNIZAION AND REFORM ACT OF 2012**

**(PUBLIC LAW 112 -**  **95)**

Submitted on June 25, 2015 Insight Video Solutions 125 L akewood Drive Guy ton, GA 31312 Tel: ( 251 ) 599

- 7593

**GLOSSARY	OF ABBREVIATIONS**  **................................ ................................**  **........................... 3**  **SUMMARY ................................**  **................................ ................................**  **................................ ....**  **4**2

**INTRODUCTION	AND	INTEREST	OF	THE	PETITIONER ................................**  **................ 4**  **BACKGROUND ................................**  **................................ ................................**  **............................ 5**  **BASIS	FOR	PETITION ................................**  **................................ ................................**  **............... 5**  **CONCLUSION ................................**  **................................ ................................**  **............................ 26** 3 **GLOSSARY OF ABBREVIATIONS** AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle IVS Insight Video Solutions CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace Sy stem NOTAM Notice to Airman PI C Pilot In Command RPA Remotely Piloted Aircraft Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Visual Flight Rules VLOS Visual L ine of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 **SUMMARY** Insight Video Solutions (IV S ) seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem (UAS) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit IVS to operate a Remotel y Piloted Aircraft (RPA) or UAS for the commercial purpose of conducting aerial video and photography of construction sites, real estate property and the survey of buildings and structures for inspection purposes.

**INTRODUCTION AND INTEREST OF THE PETITIONER** IVS is owned and operated by William E. Strickland. Mr. Strickland has over 26 ye ars of service in the US military . He retired as a L ieutenant Commander in the US Coast Guard with over 3800 flight hours inMH65 A/B/C and D model Dolphin helicopter as well as the T3 4C Turbo Mentor fixed wing . He has over 10 years experience a s an Instructor Pilot (IP) and Flight Examiner (FE) . He holds a Commercial Pilots certificate (#3589455) in both fixed wing and rotary wing and holds a Commercial Flight Instructor rating with Instruments (rotary wing). He was a former fleet Standardizat ion Instructor for the Coast Guard and was the lead instructor for the Coast Guard’s Crew Resource Management (CRM) and Operational Ris k Management (ORM) programs. As a Coast Guard IP/FE one of his primary duties was giving upgrade and ye arly check ride f

lights to fleet pilots, ensuring strict adherence to , and knowledge of , FAA policies, procedures and directives. Mr. Strickland also has over 15 ye ars experience fl yi ng a variety of radio controlled aircraft , including helicopters, fixed wing and quad cop ters. If granted5

exemption, IVS will focus on commercial applications to include , but not limited to; real estate advertising, mapping, building survey s and inspection s , motion picture filming, marketing, and the training and support for law enforcement, fire/rescue and other public service organizations. Primary operations will be for commercial, for profit, events. However, as a civic

- minded company
– IVS will alway s look to give back to and support the community

by providing no cost services to approp riate events and organizations.

**BACKGROUND**
IVS seeks exemption to operate a Ty phoon Q500 UAS platform manufactured b y Yuneec for commercial purposes in the United States National Airspace System

. T he Q500 is a multirotor platform with Vertical Takeoff and Landing (VTOL) capabilities controlled by operators maintaining Visual Line of Sight (VLOS) using a full telemetry , GPS equipped, handheld ground station. The Q500 is 8.3 inches tall, and 16.5 inches long and 16.5 inches wide. It was a max takeoff weight with battery and camera in stalled on 1700 grams/3.8 lbs , while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 20 knots.

**BASIS FOR PETITION** Petitio ner, IV S , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereb y petitions the Administrator to co mmercially o perate the Ty

phoon Q500 UAS i n the NAS, and for an6

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, IVS ’s operation of Ty phoon Q500 UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingl y, IVS requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that onl y apply to aircraft with an airworthiness certificate. IVS submits that the requested relief is proper, as an equivalent level of safety will be ensured. IVS will ensure all safety and maintenance procedures outline by the UAS manufacture are complied with. Only authorized personnel or technicians will perform maintenance on the UASs using the methods, techniques, and practices prescribed in the operating docum ents provided b y the UAS manufacture. All maintenance will be logged in the UAS maintenance record maintained b y IVS

. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested b y IVS to the extent necessary to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, m eeting minimum flight

- hour and currency requirements, that the PI C is able to safel y operate the Ty

phoon Q500 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.7 IVS seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the Ty

phoon Q500 UAS do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, IVS submits that all maintenance and care will be conducted to will ensure the Ty phoon Q500 UAS is in an airworthy condition, prior to every

flight, by determining that the UASs are in compliance with the operating documents provided by the UAS manufacture , and that the aircraft are in a condition for safe flight. IVS seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the Ty phoon Q500 UA will not have a typical aircraft barometric altimeter onboard. Altitude is measured using barometric and G lobal Positioning Sy stem (GPS) sensors. The UA provides the information to the LOS operator via a GCS application for real time flight telematics

. The flight telematics aid the operator ensuring compliance and safe operation of the UA within visual line of sight, at or below 2 00 feet AGL , with the majority

of flights at or below 1 00 feel AGL , will ensure a level of safety equivalent to Section 91.121. Additionally , IVS seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. IV S submits that granting an exe mption is necessary due to the inherent limitations of electric UAS vehicles. Most if, not all small UAS’s are limited to a max imum of 20

- 25 minutes in total flight time

. O peratio n of the Ty phoon Q500 UAs will be conducted in daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR) will ensure the UA is operated in a safe manner compliant with applicable regulations

. In addition, a key

built in safety feature within the Q500’s software automatically reduces8

it’s maximum altitude based on decreasing battery levels, ultimately self

- landing the vehicle prior to total battery depletion. In accordance with 14 C.F.R. § 11.81, IVS provides the following in formation in support of its petition for exemption: **1) Name And Address Of The Petitioner.**  The name and address of the Petitioner and point of contact is: Insight Video Solutions 125 L akewood Drive Guy ton, GA 31312 ( 251 ) 599

- 7593 email: westrickland71@gmail.com 2) **The Specific Sections Of 14 C.F.R. From Which IVS**  **Seeks Exemption.** a) **IVS Seeks Exemption From The Requirements Of Section 61.113(a) And (b).**  Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: i) No person who holds a private pilot certificate may act as a pilot in command (PI C) of an aircraft that is carrying passengers or property for compensation or hire; nor may

that person, for compensation or hire, act as PIC of an aircraft. ii) A private pilot may , for compensation or hire, act as PI C of an aircraft in connection with any business or emplo ym ent if

— (1) The flight is onl y incidental to that business or employment; and (2) The aircraft does not carry passengers or property

for compensation or hire. b) **IVS Seeks Exemption From The Requirements Of Section 91.7(a).**  Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following:9 i) No person may

operate a civil aircraft unless it is in an airworthy condition. c) **IVS Seeks Exemption From The Requirements Of Section 91.121.**  Section 91.121, entitled Altimeter settings, subse ction (a), states the following, in part: i) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, b y reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL, to

-- (a) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (b) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an app ropriate available station; or (c) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. d) **IVS Seeks Exemption From The Requirements Of Section 91.151(b).**  S ection 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, exc ept as provided in paragraph10 of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] e) **Seeks Exemption From The Requirements Of Section 91.407(a)(1)** Section 91.407, entitled Operation after maintenance, preventive maintenance, rebu ilding, or alteration , subsection (a)(1), states the following: i) No person may

operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- ii) (1) It has been approved for return to service b y a person authorized under § 43.7 of this chapter[.] f) **IVS Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And**  **91.409(a)(2).** Section 91.409, entitled Inspections , subsection (a), states the fo llowing: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

– (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by

§ 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. g) **IVS Seeks Exemption From The Requirements Of Sections 91.417(a) And**  **91.417(b).** Se ction 91.417, entitled Maintenance records , subsections (a) and (b), state the11 following: i) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

— (2) A desc ription (or reference to data acceptable to the Administrator) of the work performed; and (3) The date of completion of the work performed; and (4) The signature, and certificate number of the person approving the aircraft for return to service. ii) Records contain ing the following information: (1) The total time in service of the airframe, each engine, each propeller, and each rotor. (2) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (3) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.12 (4) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (5) The current status of applicable A irworthiness D irectives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (6) Copies of the forms prescribed b y § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers , and appliances. iii) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this cha

pter shall be retained until the defects are repaired and the aircraft is approved for return to service. 3) **The Extent Of Relief IVS**  **Seeks And The Reason IVS**  **Seeks The Relief.** a) **Extent Of Relief IVS**  **Seeks And The Reason IVS**  **Seeks Relief From Section 91.7(a).** 13 Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow IVS personnel to determine that the Ty phoon Q500 UAS is in airworth y condition prior to every flight b y ensuring that the UAS is in compliance with the operating documents (i.e., the IVS Standard Operating Procedures (SOP) , Monthl y Maintenance Lo g , and Ty phoon Q500 documentation). IVS seeks the requested relief because the Ty phoon Q500 UASs do es not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, IVS personnel will ensure that the Ty phoon Q500 UAS is in airworth y condition based upon its compliance with the operating documents (i.e., Maintenance Lo g s , IVS SOP and manufacture documentation) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.
b) **Extent Of Relief IVS**  **Seeks And The Reason IVS**  **Seeks Relief From Section 91.121.** Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the Ty phoon Q500 which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude informati on from the UA to the PI C at the GCS. Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), IVS seeks the requested relief as the Ty phoon Q500 UA altimeter may be set on the ground to14 zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the Ty phoon Q500 is equipped with a barometric pressure sensor and GPS equipment, which automatically
ensure s that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of the GCS. c) **E xtent Of Relief**  **IVS Seeks And The Reason**  **IVS Seeks Relief From Section**  **91.151(b).** Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR). IVS seeks the requested relief as the UAS does not utilize traditional aircraft combustible fuel, rather the UAS is battery powered

. Significantl y, as set forth below, the technical specifications of the Ty p hoon Q500 UAS operating documents, and IV S proposed operating limitations, ensure that IVS will safely operate the battery

powered Ty

phoon Q500 UA during daylight hours in visual meteorological conditions (VMC),

under visual flight rules (VFR).15

d) **Extent Of R elief**  **IVS Seeks And The Reason**  **IVS Seeks Relief From Sections**  **91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).** Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only appl y to aircraft with an airworthiness c ertificate, IVS requests relief from these Sections because the Ty phoon Q500 UAS do not require airworthiness certificates. As set forth more fully below, the Ty

phoon Q500 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingl y, IVS will onl y use authorized technicians to perform maintenance on the UAS using authorized methods. IV S will document all maintenance activities and keep the maintenance activity records for the IV S UAS. e) **The Reasons Why Granting IVS**  **’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.**  Granting IVS ’s Petition will further the public interest b y allowing IVS to conduct training for IVS personnel as well as other parties interested in proper and safe recreational or commercially operating of UAS, employ ment of small UAS is efficient and more economical for certain type of activities such as construction site photography , land surveying, aerial video and photography of real estate, special events, film sets, and landscape over certain areas of the United States. Additionall y, use of the small battery powered UAS will decrease congestion of the NAS for certain activities , reduce po llution, and provide benefits to the econom y.16

f) **The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least**  **Equal To That Provided By The Rule From Which IVS**  **S eeks Exemption.**  i) **Reasons Why The Typhoon Q500**  **Meet s**  **The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333.**  In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its op eration, IV S ’s operation of the IVS UAS meet s the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (1) In General.

--Not

withstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace syste m before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. ii) Assessment of Unmanned Aircraft Systems.

--In making the determination under subsection (a), the Secretary shall determine, at a minimum

--17 (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, p roximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). iii) Requirements for Safe Op eration.

--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national a irspace system. In seeking this exemption, IVS submits the Ty phoon Q500 UAS can be operate d safel y in the NAS pursuant to FMRA Section 333, as demonstrated by: (A ) the characteristics of the Ty phoon Q500 UAS; ( B ) the pilot certification requirement; and ( C ) the specific operating limitations.

A. **The Specifications Of The Typhoon Q500**  **UAS Demonstrate Its Safe Characteristics.**  The Ty phoon Q500 UAS do es not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security consi dering its size, weight, speed, and operational capability

. IVS UAS utilizes four counter

- rotating propellers for18 extreme balance, control and stability that is aided by GPS and other on board sensors

. In the event of an unexpected loss of communication w ith the UAS it will return to a pre

- defined location at a pre

- determined altitude AGL. If the UAS has returned to the pre

- defined location and altitude with a low battery the UAS will safely

land at the pre

- determined location. In addition the Q500 has fa ctory

installed firmware that prevent it from being activated or flown in close proximity to an y ai rport in the US. *Note: Yuneec customer support has an available firmware download that is only

released to customers that meet their screening process that does allow operation in proximity to airports. B. **Technical Specifications O f The**  **Typhoon Q500 UAS.**  The technical specifications of the Ty phoon Q500 UAS is set forth by the Ty phoon Q500 manufacturer is as follows: **Battery :**  5 4 00mAh L iPo **Weight (Battery & Propellers Included)**  **:** 1 700 g **Max Yaw Rotational**  **Velocity :**  65 °/s **Max Tilt /Bank**  **Angle :**  35 ° **Max Ascent / Descent Speed :**  Ascent: 3 m/s; Descent: 2m/s **Max Flight Speed :**  15mph, approximate. **Diagonal Length (without propellers)**  **:** 565 mm19 C. **Flights Of the**  **Typhoon Q5 00**  **Will Be Conducted Pursuant To Specific Operating Limitations.** 
a. IVS UASs weigh less than 55 pounds; b. IVS onl y operates its UASs below 400 feet;
c. IVS UASs only

operate for 5

- 2 0 minutes per flight; d. IVS remote control pilots operate IVS UASs by visual line of sight (VLOS) at all times.
e. IVS remote control pilots have downlink video backup via ground station, should they lose sight of the UAS; f. IVS UASs have GPS flight modes whereb y the y hover and then slowly

land if communication with the remote contro l pilot i s lost or battery

power is low; g. IVS activel y anal ys es electronic flight data and other sources of information to constantly update and enhance safety protocols; h. IVS alway s obtains all necessary permissions and permits prior to operation; and, IVS has procedures in place to abort flights in the event of safety breaches or potential danger. i. The pre

- flight inspection by IVS personnel must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.20 j. If the UA loses communications for a pre

- defined period of time or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in acco rdance with the operating documents. k. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) w ithin 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. g) **Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Sa**  **fety.** IVS submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the UAS unless that PI C has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safely

operate the UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering IVS ’s proposed area of op erations, and the operating limitations set forth

- above; combined with the Owner/operator’s extensive training and experience,21

including holding both a private and commercial fixed and rotor wing certifications ensures that all IVS’s operations will be con ducted in a safe manner. The FAA has previously

granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 1108 0, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). IVS will not all ow an y P IC to operate the UAS unless that PI C has demonstrated, by meeting minimum flight

- hour requirements or UAS training and currency requirements, that the PIC is able to safel y operate the UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specificall y, the PI C must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency

purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in complianc e with applicable regulations will ensure an equivalent level of safety during IVS ’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:22 In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b ), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot
o perating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 day s (for currency

purposes). The FAA finds that at a minimum, the flight

hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency

in the skills necessary

to safel y conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency , and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, p roficiency , and experience

- building flights the PI C is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingl y, IVS will ensure safe operations by not allowing any P IC23

to operate the UAS unless that PI C has demonstrated, by meeting minimum flight

- hour and currency

requirements, that the PI C is able to safel y operate the UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. h) **Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.**  The equivalent level of safety established b y Section 91.7(a) will be maintained utilizing pre flight SOP , IV S wi ll ensure that the UAS is in an airworth y condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally , the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11 159, 11160, 11161). i) **Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.**  The equivalent level of safety established b y Section 91.121 will be maintained because the altitude information of the UA will be pro vided to the PI C via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with IVS ’s operation of the UA within visual line of sight, at or below 400 feet AGL, will ensure a level of safety24 equivalent to Section 91.121. The altitude information will be generated b y GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is aut omatically established b y the UAS at ground level. The FAA has previously

granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11 066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). j) **Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.**  A grant of this exemption would ensure an equiv alent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingl y, IVS wil l ensure that it will safel y operate the battery powered UA during daylight hours in VFR conditions. Here, as in Exemption No. 11109, the technical specifications of the UAS ; the limitations on the proposed flight operations; and the location of the propos ed operations, will ensure an equivalent level of safety established b y 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the UAS provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage. At the critically

low battery

level, the UAS will descend and land automatically

.25 Significantl y, previous exemptions granted b y the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previousl y granted relief from Secti on 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157 , 11158, 11159, 11160, 11161). k) **Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely**  **Affect Safety.** In seeking this exemption, IVS submits that the equivalent le vel of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91. 417(a) & (b) will be met as IVS will use only authorized technicians to perform maintenance
o n the UASs using the authorized methods, techniques, and practices

. Furthermore, IVS will document and maintain all maintenance records for the DJ I UAS

. T he UAS will be inspected as prescribed b y the operating documents, IVS will maintain the equivalent l evel of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2).26 Likewise, the exemption sought will not adversel y affect safety as IVS will only use authorized technicians to preform maintenance on the UAS using the authorized methods, techniques, and practices Furthermore, the exemption sought would maintain an equivalent level of safety established b y Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the UAS will be performed b y authorized technicians. Mai ntenance will be documented and maintained utilizing the maintenance log. Significantl y, previous exemptions granted b y the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversel y affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of IVS ’s proposed operating limitations, the operating documents, and the technical aspects of the Ty phoon Q500 UAS , IVS submits that safety will not be adversel y affected b y granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously

granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

**CONCLUSION** As set forth herein, IVS seeks an e xemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Ty phoo Q500 + UAS commerciall y, without an airworthin ess27

certificate, for the purpose of conducting aerial video and photography over certain areas of the United States. By

granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public , by allowing IVS to safel y, efficiently , and
e conomicall y operate the UAS commerciall y within the NAS. **WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, IVS respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit IV S to operate the UAS
comm erciall y for the purpose of conducting aerial video and photography over certain areas of the United States. IVS respectfully requests that FAA exercise its authority to issue the exemption sought by IVS pursuant to the Federal Aviation Act, 85 P.L . 726 ( 1958), as amended (the "Act") without delay

.

Sincerel y,

William E. Strickland InSight Video Solutions 125 L akewood Drive Guy ton GA 31312 251 599

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