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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 under Section 333 of the FAA Modernization and Reform Act of 2012 and Title 14 of the 

Code of Federal Regulations (CFR), 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 Regulations 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 demonstrations.

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 Class 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 PIC 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.
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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 will 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 observers 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 50 mph.

Appendix 1 lists the Title 14 regulations that AirVidz, LLC seeks relief from. It also addresses 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

Email: 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)
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Appendix 1 - Specific Exemption Requests and Equivalent Level of Safety

14 CFR Part Summary of Regulation

Part 21 – Airworthiness 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 requirements 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 airworthiness 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 
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requirement is impossible to match. The equivalent level of safety will be achieved by having the registered Nnumber 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) - Private 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 operating 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 ofUAS 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, Section 1 of FAA Order 8900.1.

AirVidz, LLC proposes to conduct operations in accordance with these restrictions. 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, as 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 operate 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 isin 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 the use of 

a radio transmitter that communicates with the aircraft via radio communications. Utilizing a pilot skilled in 

remote piloting will provide an equivalent level of safety.
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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 private 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 - Altimeter 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 cruising 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 used 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, this requirement is inapplicable. An equivalent level of safety is achieved 

through a low battery power 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 prior to flight and conduct 

detailed inspections after every 10 flight hours. Additionally, checklists will be utilized with all of the necessary 

pre-flight procedures prior to every flight operation. The PIC will 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.
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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
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 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 – Transmits 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 connection 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 provide enhanced range and quality.

 ReadyMadeRC 12” LCD Monitor – Displays signal transmitted from the UAS video transmitter to the 

ground station video receiver.
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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.