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## AirVidz, LLC 4232 N. Cambridge Way Pace, FL 32571 850.292.2693 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 RE: Exemption Request u nder Section 333 of the FAA Modernization and Reform Act of 20 12 and Title 14 of the Code of Federal Regulations ( C F R ), Part 11 .81 Dear Madam or Sir: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11 .81 , AirVidz, LLC seeks an exemption from the Federal Aviation Regulation s detailed below for the DJI S900 Unmanned Aircraft System ( UAS ) . This UAS is a multi
- rotor aircraft with electric propulsion, and is a commercial platform with a proven track record. DJI UAS platforms have been approved for flights in the National Airspace system under multiple FAA Certificates of Authorization (COA). The requested exemption would allow AirVidz, LLC to pursue commercial interests in aerial data collection, cinematography, photography, and visual inspections using small unmanned aircraft systems. The proposed UAS will be used to conduct data gathering for agricultural applications, aerial inspections, mapping, surveying, R&D , search and rescue, video productions, and product demonstratio ns. AirVidz, LLC will operate its UAS aircraft in accordance with FAA N 8900.227 and utilize both a Pilot in Command (PIC) and a ground
- based visual observer. AirVidz, LLC will also utilize emergency, lost link, and lost communication procedures. All flights under these exemptions will be conducted with the following restrictions: 1. The Pilot in Command (PIC) of all UAS operations will hold a minimum of a Private Pilot’s License issued by the U.S. Department of Transportation, Federal Aviation Administration. 2. The PIC will hold a current Amateur Radio License issue by the U.S. Federal Communications Commission, Call Sign KM4GXX. 3. The PIC will also hold a current SECRET Clearance issue by the U.S. Department of Defense. 4. UAS operations will be conducted in C lass G airspace . For flights in other than Class G airspace, the controlling agency will be notified at least 24 hours in advance, and if required, any necessary permission will be acquired. 5. UAS operations will be conducted at no more than 400’ AGL. 6. The P IC of the UAS will ensure that the UAS remains clear of and yields the right of way to all manned operations and activities at all times (including but not limited to ultra
- light aircraft, skydiving activities, parasailing activities, hang gliders, and hot air balloons). 7. The UAS will be operated over private property ONLY with the prior written permission of the property owner. 8. The UAS will not be operated over densely populated areas. 9. The UAS will not be operated within 5 NM of an airport without an approved COA prior to operations . ( See #4 above for flights outside of Class G airspace. ) 10. Flights will be limited to daytime operations under visual meteorological conditions; the UAS will remain clear of clouds at all times.**AirVidz, LLC** Request for Section 333 Exemption

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________________________________ ________________________________ ________________________________ ________ Page 2 of 8 11. The aircraft will remain within visual line of sight of the observer at no more than a 1 NM range. 12. The UAS will have a maximum GTOW of less than 55 lbs. 13. The aircraft will be registered with the FAA and will have the appropriate N - number markings prominently displayed . 14. The PIC wil l possess the certifications required under N 8900.227. 15. No operator or observer will engage in, nor may an operator or observer permit, any activity during a critical phase of flight which could distract any operator or observer from the performance of his/her duties or interfere in any way with the proper conduct of his/her duties. 16. The PIC will conduct a pre
-flight inspection prior to each flight so as to ensure that the UAS and associated systems are in a condition for safe operation. 17. The PIC and o bservers will maintain two
-way communications with each other during all operations; if unable to maintain two
-way communications, or if any condition occurs that may otherwise cause the operation to be unsafe, the operator will immediately conclude the operation. 18. The aircraft will automatically return to point of take off if the communications link is lost. 19. All flights will be conducted at airspeeds below 5 0 mph. **Appendix 1** lists the Title 14 regulations that AirVidz, LLC seeks relief from. It also add resses each regulation relative to how AirVidz, LLC will provide an equivalent level of safe operations and compliance. **Appendix 2** details the specific characteristics of the DJI S900 UAS for which AirVidz, LLC will be using in its flight operations. **Appendix 3** details the radio frequencies utilized in flight operations conducted by AirVidz, LLC. **Contact Information** AirVidz, LLC ATTN : Mark A. Olivet, President 4232 N. Cambridge Way Pace, FL 32571 Phone: 850.292.2693 E mail: molivet@hotmail.com AirVidz, LLC requests exemption under Section 333 to enable safe commercial UAS operations for the activities stated. By approving these exemptions the FAA will create benefits to the areas mentioned that is ultimately in the public interest, both for consumers of the services provided and for the commercial pursuit of companies such as AirVidz, LLC in a new and developing industry. Please contact me at your earliest convenience if you require additional information or clarification. Very Respectfully, Mark A. Olivet, President AirVidz, LLC

Attachments:

 DJI S900 User Manual  DJI iOSD Mark II User Manual  DJI A2 Flight Controller User Manual  DJI Zenmuse H3 3D User Manual  AirVidz, LLC Pilot’s Operating Handbook (POH)**AirVidz, LLC** Request for Section 333 Exemption

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## Appendix 1
- Specific Exemption Requests and Equ ivalent Level of Safety

**14 CFR Part Summary of Regulation**  Part 21 – Airw orthiness Certification 21, Subpart H Certification procedures for products and parts, Airworthiness Certificates Part 45 – Identification and Registration Marking 45.23(b) Display of Marks, General Part 61 – Certification: Pilots, Light Instructors, and Ground Instructors 61.23(a) Operations requiring a medical certificate 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in Command 61.133(a) Commercial Pilot Privileges and Limitations Part 91 – General Operating and Flight Rules 91.7(a) Civil aircraft airworthiness 91.9 (b) Civil aircraft flight manual, marking, and placard requirements 91.109(a) Flight instruction; Simulated instrument flight and certain flight tests 91.119 Minimum safe altitudes: General 91.121 Altimeter settings 91.151(a) Fuel requirements for flight in VFR conditions 91.203(a) and (b) Civil aircraft: Certifications required 91.401 Maintenance, Preventive Maintenance, and Alterations: Applicability 91.403 Maintenance, Preventive Maintenance, and Alterations: General 91.405 Maintenance, Preventive Maintenance, and Alterations: Maintenance required 91.407 Maintenance, Preventive Maintenance, and Alterations: Operation after maintenance, preventive

maintenance, rebuilding, or alteration 91.409 Maintenance, Preventive Maintenance, and Alterations: Inspections 91.411 Maintenance, Preventive Maintenance, and Alterations: Altimeter system and altitude reporting

equipment test and inspections 91.413 Maintenance, Preventive Maintenance, and Alterations: ATC transponder tests and inspections 91.415 Maintenance, Preventive Maintenance, and Alterations: Changes to aircraft inspection programs 91.417 Maintenance, Preventive Maintenance, and Alterations: Maintenance records



### Table 1 – List of Title 14 Regulations for Which Exemption is Requested **14 C.F.R. Part 21, Subpart H: Airworthiness Certificates**  **14 C.F.R. §91.203(a) and (b) -**  **Civil aircraft: Certifications required.** Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural req uirements for the issuance of airworthiness certificates as required by FAR §91.203(a). AirVidz, LLC requests an exemption from these rules and will utilize an internal airworthiness process based on MIL
- HDBK 516B for an equivalent level of safety. Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthi ness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the UAS involved. **14 C.F.R. §45.23(b) -**  **Display of marks; general.** These regulations provide that each aircraft must display "N" and the aircraft’s registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. Given the size of the UAS (fuselage length of 6’), this**AirVidz, LLC** Request for Section 333 Exemption

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________________________________ ________________________________ ________________________________ ________ Page 4 of 8 requirement is impossible to match. The equivalent level of safety will be achieved by having the registered N
number in 1 inch lettering on the side of the fuselage and/or on both vertical arms of the landing gear
. **14 C.F.R. §61.23(a) -**  **Medical certificates: Requirement and duration.** Regulations provide that a person must hold at least a second class medical certificate when exercising:

 Second
- in - command privileges of an airline transport pilot certificate in part 121 of this chapter (other than operations specified in paragraph (a)(1)(ii) of this section); or  Privileges of a commercial pilot certificate Given the size of the UAS in this petition and the limited flight area and the safety features integrated in the autopilot, AirVidz, LLC believes that an Equivalent Level of Safety can be reached if the operator has a valid driver’ s license and Private Pilot’s license . **14 C.F.R. §61.113(a) and (b), §61.133 (a)**  **- Pr**  **ivate Pilot Privileges and Limitations: Pilot in Command; Commercial Pilot Privileges and Limitations** **.** Subsections (a) and (b) of §61.113 prohibit private pilots from operating aircraft in commercial operations, and §61.133(a) requires an individual operat ing an aircraft for compensation or hire to hold a commercial pilot certificate. AirVidz, LLC requests an exemption from 14 C.F.R. §61.113(a) and (b) and 14 C.F.R. §61.133(a) so that the above mentioned UAS may be operated by individuals who have a private pilot certificate. Based upon the design features of the UAS, its autopilot system, and safety factors, the FAA should permit operation of UAS by operators with a private pilot certificate when the conditions described above have been satisfied. The above described conditions are in line with those set forth in Volume 16, Chapter 4, S ection 1 of FAA Order 8900.1. AirVidz, LLC proposes to conduct operations in accordance with these restri ctions. Given these conditions and restrictions, an equivalent level of safety to manned operations will be achieved through operation with a private pilot certificate. The risks associated with the operation of the DJI multi
- rotor aircraft (given the size, speed, operational capabilities, and lack of combustible fuel) are so much less than the level of risk associated with fixed wing and rotorcraft operations, both private and commercial, as contemplated by Part 61, that allowing operations of these UAS, a s set forth above, meets or exceeds the present level of safety provided under 14 C.F.R. §61.113(a) and (b) and §61.133(a). **14 C.F.R. §91.7(a) -**  **Civil aircraft flight manual, marking, and placard requirements .**  This regulation requires that no person may o perate a civil aircraft unless it is in airworthy condition. AirVidz, LLC requests that an exemption be granted allowing commercial operation without an airworthiness certificate. Given the size of the aircraft, self
- certification utilizing MIL
- HDBK 516B will provide an equivalent level of safety. **14 C.F.R. §91.9(b) -**  **Civil aircraft flight manual, marking, and placard requirements.** This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. AirVidz, LLC assumes that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. AirVidz, LLC requests an exemption to this requirement since the aircraft is not only too small to carry documentation, but the documentation would not be available to the crew. The equivalent level of safety will be achieved by keeping a hard copy of the DJI user manual and the AirVidz, LLC Pilot’s Operating Handbook (POH) with the ground crew. **14 C.F.R. §91.109(a)**  **- Flight instruction; Simulated instrument flight and certain flight tests** **.** Sections 91.109(a) provides that no person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls. The UAS in this exemption are remotely piloted aircraft, and, by design, not equipped with fully functional dual controls. Flight control is accomplished through th e use of a radio transmitter that communicates with the aircraft via radio comm unications. Utilizing a pilot skilled in remote piloting will provide an equivalent level of safety.**AirVidz, LLC** Request for Section 333 Exemption

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________________________________ ________________________________ ________________________________ ________ Page 5 of 8 **14 C.F.R. §91.119 -**  **Minimum safe altitudes: General.** The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the UAS in this exemption will be operating at a maximum of 400 feet AGL, this requirement cannot be followed. To provide an equivalent level of safety , AirVidz, LLC will only fly over priva te property with the permission of the land owner. The land owner will be briefed of the expected route of flight and the associated risks to persons and property on the ground. We maintain that due to the small size of the UAS, the hazard to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be considered in granting the exemption. Furthermore, AirVidz, LLC will not operate over congested areas nor over any open air assembly of persons. **14 C.F.R. §91.121 -**  **Altim eter settings.**  The regulation states that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 nautical miles of the aircraft. The UAS will fly below 400 feet AGL and will not need to maintain hemispherical c ruising altitudes in order to de
- conflict with other aircraft. To provide an equivalent level of safety, the autopilot calculates the reference altitude (ground level) with the on
- board GPS during the pre
-flight tests. The GPS and barometer data are then u s ed to calculate the altitude in flight. **14 C.F.R. §91.151(a) -**  **Fuel requirements for flight in VFR conditions.** The regulation states that no person may begin a flight in an airplane under day
-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. As the aircraft in this request are electric
- powered, th is requirement is inapplicable. An equivalent level of safety is achieved through a low battery powe r warning. The DJI UAS is designed to automatically return to base and land safely when the battery voltage falls below a predetermined voltage. **14 C.F.R. Subpart E (§91.401 -**  **§91.417) -**  **Maintenance, Preventive Maintenance, and 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. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7 " after maintenance and inspection. AirVidz, LLC will have 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 condition pri or to flight and conduct detailed inspectio ns after every 10 flight hours. Additionally, checklists will be utilized with all of the necessary pre -flight procedures p rior to every flight operation. The PIC will document work perfo rmed 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.**AirVidz, LLC** Request for Section 333 Exemption

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## Appendix **2** – Description of UAS used in Flight Operations
UAS Overview AirVidz, LLC is submitting this request for exemption for the DJI S900. This commercially available system from DJI has been shown to be reliable and is a popular platform utilized by both hobbyists and professionals. AirVidz, LLC has extensive expertise and knowledge in the operations of this platform, and will utilize training and operational procedures that follow the guidelines presented in N 8900.227. UAS Specifications The DJI S900 is a six (6 ) rotor UAS with a maximum take
- off weight of 18 .1 pounds. Specifications are listed in **Table 2** below. **DJI S900 Specifications** Frame Diagonal Wheel Base 900 mm Frame Arm Length 358 mm Frame Arm Weight (with Motor, ESC, Propeller) 316 g (0.7 lbs.) Center Frame Diameter 272 mm Center Frame Weight (with Landing Gear, Mounting Base, Servos) 1,185 g (2.6 lbs.) Landing Gear Size 460 mm (Length) x 450 mm (Width) x 360 mm (Height) Motors Stator Size 41 mm x 14 mm KiloVolts (KV) 400 rpm/V Maximum Power 500 Watts Weight (with Cooling Fan) 158 g (0.35 lbs.) Electronic Speed Controllers (ESC) Working Current 40 Amps Working Voltage 6S LiPo Signal Frequency 30 Hz – 450 Hz Drive PWM Frequency 8 KHz Weight (with Radiators) 35 g (0.08 lbs.) Foldable Propellers Material High strength performance engineered plastics Size 15 in x 5.2 in Weight 13 g (0.03 lbs.) Flight Parameters Take
- off Weight 4.7 Kg (10.2 lbs.) – 8.2 Kg (18.1 lbs.) Total Weight 3.3 Kg (7.3 lbs.) Flight Battery LiPo (6S, 16000 mAh, 25C) Maximum Power Consumption 3000 Watts Hovering Power Consumption 1000 Watts (@6.8 Kg Take
- off Weight) Hovering Time 22 minutes (@ 12000 mAh & 6.8 Kg Take
- off Weight) Working Environment Temperature
- 10 C (14 F) – 40 C (104 F)



### Table 2 – Specifications for the DJI S900 Multirotor UAS The DJI S900 UAS utilized by AirVidz, LLC will be configured with the following components: Aircraft Components**AirVidz, LLC** Request for Section 333 Exemption

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________________________________ ________________________________ ________________________________ ________ Page 7 of 8  **DJI A2 Flight Controller** – Includes a Power Management Unit (PMU), Inertia Measurement Unit (IMU), Main Controller, LED indicator, and a GPS/Compass unit.  **DJI iOSD Mark II** – Provides telemetry information to the ground station, including horizontal air speed, vertical air speed, altitude (AGL), pitch and roll attitude, distance from home station, direction to home station, flight mode, audio visual channel, number of GPS Satellites locked, and on
- board battery voltage.  **DJI Zenmuse H3 3D Gimbal** – Integrated with the DJI A2 flight controller to provide smooth video capabilities regardless of the aircraft attitude.  **GoPro Hero 3 Plus Silver Edition Camera** – High Definition (HD) camera that provides real time video to the ground station while also recording video to a storage card.  **Iftron Technologies 800 mw Video Transmitter** – T ransmits video signal from aircraft to ground station.  **IBCrazy BlueBeam Antenna** – Circularly Polarized Omni - Directional antenna that works with the video transmitter to provide enhanced range and quality.  **FrSky L9R Radio Receiver** – Long range receiver that receives radio frequency instructions from the ground station radio transmitter. Ground Components

 **Taranis X9D Plus Radio Transmitter** – Fully programmable 32 channel radio transmitter that sends instructions to the UAS.  **Iftron Technologies Yellowjacket RPV Video Receiver** – Receives video signal transmitted from the UAS and contains two outputs for conne ction to two video display devices. Also contains “diversity” technology (two antennae) to provide greater signal quality and reliability.  **IBCrazy BlueBeam Antenna** – Circularly Polarized Omni
- Directional antenna that works with the video receiver to provi de enhanced range and quality.  **ReadyMadeRC 12” LCD Monitor** – Displays signal transmitted from the UAS video transmitter to the ground station video receiver .**AirVidz, LLC** Request for Section 333 Exemption

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## Appendix **3** – Radio Frequency Spectrum Utilized in Flight Operations The radio frequencies utilized by the UAS proposed by AirVidz, LLC are described in **Table 3** below. AirVidz, LLC pilots will deploy a spectrum analyzer prior to each flight to identify any possible radio frequency interference. If the interference cannot be mitigated or avoided, then the flight will be not be executed. **Radio Frequencies** Current Configuration Radio Transmitter/Receiver 2.4 GHz On Board GPS (receive only) 1575.42 MHz Video Transmitter/Receiver 1.2 GHz (1258 MHz and/or 1280 MHz)
– Used in conjunction with a “high pass” filter on the video transmitter to eliminate harmonic interference with the 2.4 GHz frequency used by the radio transmitter/receiver Future Use Radio Transmitter/Receiver 433 MHz Video Transmitter/Receiver 5.8 GHz 

### Table **3** – Radio Frequencies The “Future Use” frequencies are listed as frequencies that may be used by the proposed UAS in future upgrades in order to provide more flexibility and reliability in environments with high levels of interference.