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Docket Management System 

U.S. Department of Transportation

1200 New Jersey Avenue, SE

Washington, D.C. 20590

In re: Petition of Envision Virtual Tours, Inc. for Exemption Pursuant to Section 333 of 

the FAA Reform Act of 2012

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 

C.F.R. Part 11, Envision Virtual Tours, Inc., referred to hereafter as Envision, a real estate 

advertising company based out of Gainesville, GA is petitioning for an exemption from the 

Federal Aviation Regulations (FARs) pertaining to the following described unmanned aircraft 

systems (UAS). Stephen Hardman, an employee and representative of Envision and prospective 

pilot in command during commercial operations has been in contact with James Massey, Rob 

Pappas, and Mike Wilson of the FAA on several occasions in regards to filing a petition and the 

requirements thereof. The aforementioned FAA officials have provided helpful information in 

the form of specific petitions, grants, rules, and other resources to review. The information 

provided highlights the FAA has the authority to allow for the safe commercial operation of 

certain UAS within the national airspace. Envision respectfully submits the following petition 

for exemption from the listed FARs described in detail below as to allow for safe commercial 

operation of its UAS. Envision plans to use the small, safe, and commonly used DJI Phantom 2 

Vision +, DJI Phantom 3 Professional, and the DJI Inspire 1 for the purpose of producing 

videography and photography in order to market real estate. In the event that a grant is 

provided by the FAA, Envision is fully committed to abiding by the 31 conditions and limitations

(attached at the end of this document as “Conditions and Limitations”) expressed in Exemption 

No.’s 11213 (Aeryon Labs, Inc.) and 11341 Bob Sokoler (The Sokoler Medley Team RE/MAX), 

and other recent grants made for similar requests. 

Envision plans to use UAS in order to capture aerial video and photographs for the purpose of 

enhancing real estate listings. By allowing Envision to transition to utilizing UAS by way of 

exemption, the FAA will provide Envision with the capacity to transition to safer methods for 

capturing aerial photos that are more economically accessible to the communities we serve, 

more environmentally friendly, and safer because of their light weight, lack of combustible

fluids, and not having to carry human occupants. We believe that having the opportunity by 

way of a granted exemption to positively impact economic growth, the environment, as well as 

the overall safety of the communities we serve is in the public’s best interest. Our operations 

will undoubtedly inspire the public through opening economic opportunities in the 

communities we serve. By using UAS, we will be able to completely eliminate the possibility of 

a large airborne vehicle crash while conducting our operations. This makes our operations safer 

to people and property.

Envision provides real estate marketing solutions to thousands of clients throughout the 

southeast. Having been in business since 2001, Envision has a great deal of experience in the 
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segment it seeks to apply the use of UAS. We are fully capable of deploying UAS for 

commercial purposes in a safe and controlled manner in order to minimize risks. We will 

deploy UAS with complete cooperation and permission from property owners. 

The UAS we planned to use as mentioned above are the DJI Phantom 2 Vision +, DJI Phantom 3

Professional, and the DJI Inspire 1. All three devices are commonly used and have the most 

advanced safety features available. All three UAS are small and the design, operational 

characteristics, and specs for each type are attached as separate documents 

Stephen Hardman will be the PIC for Envision. Mr. Hardman has extensive experience 

operating UAS. Along with several other types of quadcopters, he has owned and operated DJI 

UAS and has accumulated many hours of flight time during recreational flights since the 

technology first became available. Mr. Hardman will be furthering his education by completing 

flight training in order to obtain a sport pilot certificate. All of his experience is in geographical 

areas similar to those he will be using UAS commercially. Mr. Hardman will be accompanied by 

Stuart Wade who will be acting as a visual observer (VO). As the owner of Envision and 

experienced operator of the exact models UAS to be used commercially, Mr. Wade is uniquely 

qualified to assist as a VO during flights to ensure safety of surrounding people and property. 

As the owner of Envision, he is also fully committed to ensuring safe and productive UAS 

operations articulated in the following section.

Envision will incorporate thorough safety policies and operating procedures. The three UAS 

listed above will be flown in adherence to supplemental information entitled “Conditions and 

Limitations” along with the following restrictions:

1. The PIC will obtain a sport pilot certificate along with 35 hours total flight time with each 

UAS used for commercial purposes

2. The PIC will maintain a valid U.S. driver’s license 

3. No flight will exceed 400 ft AGL

4. Airspeed of UAS will not exceed 20 knots

5. All flights will be restricted to 7 lbs gross weight

6. All flights conducted will have a pilot in command and a visual observer

7. UAS will be operated within visual line of site at all times

8. UAS will be operated over private property with the permission of the owner

9. UAS will not be operated over any groups of persons other than the PIC and VO

10. UAS will only be operated in daylight hours and clear weather conditions 

11. A thorough inspection of the UAS’s operational readiness will be conducted before each 

flight in accordance with manufacturer’s recommendations. All recommendations can 

be found in the documents attached speartely.

12. A flight plan will be drafted before each operation and reviewed by the PIC and VO

13. The PIC and VO will conduct an area sweep where each operation is to be conducted to 

ensure a safe environment

14. The PIC and VO will have on their persons the necessary documents needed to verify 

legality of operation
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15. The PIC will keep flight records in order to stay in line with manufacturer’s 

recommendations for maintenance and replacement standards

16. UAS will not be operated within 5 nautical miles of an airport

17. UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud 

18. PIC will abort any flight operation where conditions become unpredictable or in the case 

of an emergency

19. UAS will not operate without a clear connection to GPS stability 

20. All manuals for each UAS being operated will be available and on hand to the PIC and 

VO any time the UAS is operating

21. The PIC will operate the UAS from a stable position and will not operate from a moving 

vehicle or while traversing hazardous terrain

Contact Information:

Mr. Stuart Wade

Envision Virtual Tours, Inc.

P.O. Box 6939

Gainesville, GA 30504

770-540-0525

Stuart@getmytour.com

The specific section or sections of 14 CFR from which you seek an exemption;

14CFR: parts 21;

45.23(b);

45.29;

61.113(a);

91.7(a);

91.9(b)(2);

91.103;

91.109(a);

91.119;

91.121;

91.151(a);

91.203(a) and (b);

91.405(a);
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91.407(a)(1);

91.409(a)(2);

91.417(a) and (b).

The extent of relief you seek and the reason you seek the relief;

Envision respectfully submits this petition in accordance with Reform Act, 112 P.L. 95 §§ 331-

334, seeking relief from any currently applicable federal aviation regulations FARs pertaining to 

UAS and operating to prevent Envision from commercial photographic flight operations within 

the U.S. national airspace system. The Reform Act in § 332 provides for such integration of civil 

UAS into our national airspace system as it is in the public’s interest to do so. Envision’s small 

and light weight UAS, not exceeding 7 lbs, meet the definition of “small unmanned aircraft” as 

set forth in § 331. Envision’s light weight UAS are in line with the Reform Act and would be 

good candidates for exemption.

Envision requests exemption to use its UAS to capture videography and photography for real 

estate listings. We understand that the FAA is committed to safely integrating UAS into 

national airspace and believe that Envision would be a strong candidate for exemption because 

of our experience level, commitment to safe operating procedures, and desire to further 

educate the public about safe use of UAS by way of example. Safety is Envision’s primary focus 

and we requests you also consider the following: 

a. The size and weight of our UAS are under 7 lbs 

b. Our UAS travel at low speeds always less than 20 knots

c. Our UAS are outfitted with the most up to date safety and fail safe features

d. The PIC for Envision is a very experienced UAS operator 

e. Envision will strictly adhere to all 31 of the “Conditions and Limitations” applied to 

recent grants for similar petitions as outlined at the end of this petition

f. Envision will strictly adhere to the additional 22 stipulations as outlined above

Envision request exemption from the following specific regulations:

14 C.F.R Part 21 Certification Procedures for Product and Parts, Airworthiness Certificates

The FAA is authorized to exempt UAS from the requirement for an airworthiness certificate 

upon consideration of the size, speed, weight, operational capability, proximity to airports and 

populated areas, and whether operation within visual line of sight does creates a hazard to 

users of the national airspace system or the public. Because Envision plans to use three small 

UAS (DJI Phantom 2 Vision +, DJI Phantom 3 Professional, and DJI Inspire 1) weighing no more 

than 7 lbs under extremely controlled circumstances, and intends to keep speeds at less than 

20 knots, we request an exemption from the above. By using these three safety oriented UAS, 

Envision will be able to create a safe operating environment. 
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14 C.F.R. 45.23 (b) Display of Marks: General and 45.29 Size of Marks 

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman

capital letter "N" (denoting United States registration) followed by the registration number of 

the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital 

letter.

The sizes of the UAS Envision plans to use are not large enough to accommodate the required 

size of the registration numbers. We request relief from the above requirement on the grounds 

that it is not applicable at this time. If registration numbers are issued for UAS, we will certainly 

add them in the largest format possible to ensure visibility. We would also like to point out that 

each UAS Envision plans to use is outfitted with green and red lights designed to communicate 

with the ground pilot. 

14 C.F.R. 61.113 (a) &(b) Private Pilot Privileges and Limitations: Pilot in Command

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as pilot in command of an aircraft that is carrying passengers 

or property for compensation or hire; nor may that person, for compensation or hire, act as 

pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in 

connection with any business or employment if:

(1)The flight is only incidental to that business or employment; and

(2)The aircraft does not carry passengers or property for compensation or hire.

Our UAS will not carry a pilot or passengers. We believe that we can achieve a higher level of 

safety by requiring the PIC to obtain a sport pilot certificate. Traditional operations in the past 

required a person or persons to elevate in a potentially combustible vehicle in order to carry 

out the same operations we plan to accomplish by way of UAS. Because we operate in a 

controlled environment, at low altitudes and speeds, with no persons on board, using light 

weight vehicles, the risks are substantially less than have been in the past. Envision also 

requests exemption regarding the limitations of compensation for hire since we will be charging 

clients for videography and photography in the real estate market. 

14 C.F.R. 91.7 Civil Aircraft Worthiness 

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

(b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft 

is in condition for safe flight. The pilot in command shall discontinue the flight when 

unairworthy mechanical, electrical, or structural conditions occur.
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In the event that an exemption is granted, there will be no airworthiness certificate issued for 

Envision’s UAS. Without an airworthiness certificate, no FAA regulatory standard will exist for 

determining airworthiness. As outlined above and in attached exhibits, Envision is committed 

to incorporating strict safety and operational procedures in order to create an adequate level of 

safety that should exceed current standards. 

C.F.R.91.9(b)(2) Civil Aircraft Flight Manual, marking and placard requirements

(b) No person may operate a U.S.-registered civil aircraft—

(1)For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter 

unless there is available in the aircraft a current, approved Airplane or Rotorcraft Flight 

Manual or the manual provided for in § 121.141(b); and

(2)For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight 

Manual, approved manual material, markings, and placards, or any combination thereof.

(c) No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter.

Since the UAS we plan to use are not large enough to carry documentation and do not have on 

board pilots, Envision does not have the ability to carry such documents. We can recreate the 

same standard of safety by having the required manuals on hand during each flight. 

C.F.R. 91.103 Pre-Flight Action

Each pilot in command shall, before beginning a flight, become familiar with all available

information concerning that flight. This information must include—

(a)For a flight under IFR or a flight not in the vicinity of an airport, weather reports and

forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, 

and any known traffic delays of which the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and

landing distance information:

(1)For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing

takeoff and landing distance data is required, the takeoff and landing distance data contained 

therein;

and

(2)For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable
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information appropriate to the aircraft, relating to aircraft performance under expected 

values of airport elevation and runway slope, aircraft gross weight, and wind and 

temperature.

There is no pre-flight manual to refer to in regards to the UAS we plan to use. We will apply all 

pre-flight recommendations from the Manuals provided from the manufacturer along with our 

on safety measures as outlined above and in Exhibit A. Envision is committed to incorporated 

all of the safety measures illustrated throughout this petition as well as evolving our practices 

as needed to ensure a high level of safety. 

C.F.R. 91.109(a) Flight Instruction; Simulated Instrument flight and certain flight tests

(a) No person may operate a civil aircraft (except a manned free balloon) that is being used 

for flight instruction unless that aircraft has fully functioning dual controls. However, 

instrument flight instruction may be given in an airplane that is equipped with a single, 

functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, 

dual controls, when—

(1)The instructor has determined that the flight can be conducted safely; and

(2)The person manipulating the controls has at least a private pilot certificate with 

appropriate category and class ratings.

Because the UAS is radio controlled and operated, it does not have fully functional dual 

controls. It is on the other hand outfitted with very effective safety features that assist the 

craft in returning to a safe landing zone that is designated before flight if the PIC is no longer 

able to operate the UAS. Envision does not consider this regulation applicable and requests 

exemption. 

C.F.R. 91.119 Minimum Safe Altitudes

Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes:

(a)Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface.

(b)over congested areas. Over any congested area of a city, town, or settlement, or over any 

open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of 2,000 feet of the aircraft.

(c)Over other than congested areas. An altitude of 500 feet above the surface, except over 

open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure.
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(d)Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is 

conducted without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) 

of this section, provided each person operating the helicopter complies with any routes or 

altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the 

minimums prescribed in paragraph (c) of this section.

Envision asserts that the above is not applicable and believes it is in the interest of safety to 

maintain strict rules for maximum altitudes. We will not be operating our UAS above 400 feet 

AGL. Our UAS do not contain flammable or combustible fluids and therefore offer a safer 

circumstance compared to current standards. They are also small and light weight and are 

designed to automatically return to safe landing zones in the event of an emergency. Risks are 

minimized through operating in extremely controlled circumstances as outlined in this petition. 

C.F.R. 91.121 Altimeter Settings

Requires each person to reference an altimeter 

The UAS Envision plans to use utilizes GPS for altitude readings. Safety can be achieved by 

referencing the GPS data before and during each flight. We believe that an exemption for this 

regulation is necessary on the basis that an adequate level of safety and adherence to the 

purpose of the regulation can be achieved through the GPS readings. 

C.F.R. 91.151(a) Fuel requirements for flight in VFR conditions.

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to the first point of intended 

landing and, assuming normal cruising speed—

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

We request an exemption to the above regulation on the basis that the UAS we plan to use do 

not carry fuel and we will only be conducting operations during daylight hours. We also only 

conduct operations in clear and favorable conditions compared to traditional aircraft. Our UAS 

are also outfitted with automatic return home features when the battery life reaches a certain 

level. Because of the short amount of time required to accomplish our goals of capturing 

videography and photography, we plan to land the UAS before exceeding 70% battery life. 

 

C.F.R. 91.203 (a) &(b) Civil aircraft: Certifications required.
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(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it 

the following:

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate 

used to comply with this subparagraph (except a special flight permit, a copy of the 

applicable operations specifications issued under § 21.197 c of this chapter, appropriate 

sections of the air carrier manual required by parts 121 and 135 of this chapter containing 

that portion of the operations specifications issued under § 21.197 c or an authorization 

under § 91.611 ) must have on it the registration number assigned to the aircraft under part 

47 of this chapter . However, the airworthiness certificate need not have on it an assigned 

special identification number before 10 days after that number is first affixed to the aircraft. 

A revised airworthiness certificate having on it an assigned special identification number, that 

has been affixed to an aircraft, may only be obtained upon application to an FAA Flight

Standards district office.

(2) An effective U.S. registration certificate issued to its owner or, for operation within the 

United States, the second copy of the Aircraft registration Application as provided for in § 

47.31 c or a registration certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph

(a) of this section or a special flight authorization issued under § 91.715 is displayed at the 

cabin or cockpit entrance so that it is legible to passengers or crew.

Our UAS are not capable of carrying certification and registration documents and therefore 

believe this is inapplicable. There is no onboard pilot and such documents would need to be 

produced by the ground operator. We will ensure that all documentation required by the FAA 

is on hand at ground level during all flight operations. 

C.F.R. 91.405 (a) Maintenance Required

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, except as provided in paragraph (c) of this section, have

discrepancies repaired as prescribed in part 43 of this chapter;

Envision seeks exemption from the above on the basis that in the event of a grant, there will be 

no airworthiness certificate as to this applies. Though in the interest a assuring a high level of 

safety, we are committed to addressing any repairs replacements immediately. We will seek 

the assistance of the most qualified in the industry which would be the manufacturer. 

C.F.R. 91.407 (a) (1) Operation after Maintenance, Preventative Maintenance, Rebuilding, or

Alteration
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(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, (1) It has been approved for return to service by a person authorized 

under § 43.7 of this chapter

Envision points out that at this time there are no persons authorized to certify the models UAS 

we seek to use for commercial purposes. Although, as stated above, we will seek the assistance 

of the best qualified service technicians and help from the manufacturer. Because of the 

relatively simple nature of the flight components, the light weight, and low speeds and altitude, 

we believe we can offer a high standard of safety while operating and maintaining our UAS. We 

are also located within 30 minutes of one of the largest distributors of DJI products, Atlanta 

Hobby. 

C.F.R. 91.409(a)(2) Inspections

(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—

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of 

this chapter.

In the event of an exemption being granted, we believe that this is inapplicable and therefore 

request relief. 

14 C.F.R. 91.417(a) Maintenance Records

(a) 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—

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to 

service.

(2) Records containing the following information:
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(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be

overhauled on a specified time basis.

(iv) 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.

(v) The current status of applicable airworthiness directives (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.

(vi)Copies of the forms prescribed by § 43.9 d of this chapter for each major alteration to the

airframe and currently installed engines, rotors, propellers, and appliances.

Envision requests relief from the above on the basis that at this time, those regulations are 

inapplicable to the small and relatively simple UAS we plan to use. Because of the limited 

payloads of the small UAS we plan to use can handle, modifications are limited. The only 

possible modifications we plan to use are for safety purposes in the form of prop guards 

designed by the manufacturer. In addition, we plan to utilize the most detailed records 

possible relative to the operating nature of the simple UAS incorporated at Envision. 

How your request would benefit the public as a whole;

The impact of an exemption for Envision to use UAS will reach far beyond the company and the 

clients we serve. Granting an exemption for Envision would allow the company to immediately 

transition into providing services that are safer, more environmentally friendly, and 

economically accessible. 

As highlighted throughout this petition, Envision believes the substitution of small UAS in place 

of traditional aircraft to accomplish the same objectives provides a host a safety benefits. The 

UAS are considerably safer because of their size, weight, and power source. They are operated 

at low altitudes under extremely controlled circumstances and do not require onboard pilots. 

We believe that this strongly supports the position that the risks to person or property are 

dramatically lower with UAS. It is undoubtedly in the public’s interest to reduce the 

occurrences of catastrophic or fatal crashes by way of integrating newer and safer technologies 

to accomplish the same goals. We appreciate the cautious nature of integrating UAS and are 

committed to serving as an example of safe operations. 
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The environmental impact of granting an exemption for Envision as well as any other 

responsible petitioner is significant. In a time when society is highly conscious of their 

environmental footprint, switching to battery operated UAS is a logical step for society as a 

whole. Traditional aircraft will always have a role in the national airspace. With that said, 

Envision believes that by obtaining an exemption to carry out its objectives, it will be 

empowered to replace the wasteful use of traditional aircraft and the emissions expelled from 

the fuel they burn. It is commonly accepted that becoming more efficient and less wasteful 

whether it be in regards to trash disposal, gas, food, and other resources is in the public’s best 

interest. Throughout history, society has eagerly adopted new ways to conserve the resources 

available to everybody. An exemption for Envision and companies alike, will allow us to 

continue those efforts and impact the environment we all share as a society. 

The economic benefits of the exemption Envision seeks are far reaching. This exemption will 

not only benefit our clients and Envision but also the communities in general that we serve. 

Through the use of UAS, we will be able offer economically accessible options to homeowners 

and realtors that were completely out of reach accept for a limited group. Our country’s 

continuous efforts to create equal opportunity constitute the framework of our economic 

system. Creating accessible options for entrepreneurs, leveling the playing field, discouraging 

monopolies, and creating a vibrant atmosphere of competition has been accepted as America’s

path towards an elevation of society as a whole since the country was founded. UAS are a 

prime example of what makes new technologies so valuable to society. It has the potential to 

help people of all circumstances that are exposed. An exemption for Envision will allow us to 

share in that positive impact on society as a whole. 

Another tremendous public benefit an exemption for Envision would offer is to help promote 

cooperation and trust with regulatory organizations. By providing us with an exemption, it will 

provide a concrete example for other companies and people looking to conduct business 

responsibly and lawfully. Envision’s experience in dealing with the FAA in regards to using UAS 

has been positive. They have highlighted that the FAA is committed to providing a path 

through the exemption process for businesses to incorporate the technology. Clear rules have 

been outlined and Envision is committed to abiding by those rules. Each exemption granted to 

responsible companies like Envision help the public understand the process and create a 

positive outlook for anyone looking to engage with this new technology. 

Reasons why the exemption would not adversely affect safety, or how the exemption would 

provide a level of safety at least equal to the existing rule;

As stated and supported throughout this petition, Envision Virtual Tours, Inc. is fully capable of 

integrating UAS in a manner that will not adversely affect safety. We have also put forth that 

integrating UAS for the purpose of obtaining real estate photos and videography not only meets 

but exceeds the current level of safety offered through traditional manned aircraft. 
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A summary we can publish in the Federal Register

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register:

Envision Virtual Tours, Inc. seeks an exemption from the following:

14CFR: parts 21; 

45.23(b);

45.29; 

61.113(a); 

91.7(a);

91.9(b)(2);

91.103;

91.109(a); 

91.119; 

91.121; 

91.151(a); 

91.203(a) and (b); 

91.405(a);

91.407(a)(1); 

91.409(a)(2); 

91.417(a) and (b). 

An exemption for Envision Virtual Tours, Inc. will allow commercial operations of UAS under 

strictly controlled conditions for the purpose of real estate photography, videography, and 

marketing. The pilot in command will obtain a sport pilot certificate and will be accompanied 

by a visual observer. The PIC for Envision Virtual Tours, Inc. plans to use the DJI Phantom 2 

Vision +, DJI Phantom 3 Professional, and the DJI Inspire 1. All three UAS are outfitted with 

numerous safety features and are commonly used. They are all small, lightweight, and pose 

minimal risks to property and people. The UAS’s physical characteristics and fail safe features 

combined with Envision’s commitment to safe operating procedures and policies meets or 

exceeds the level of safety commonly accepted with traditional manned aircraft. 
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An exemption as requested in this petition should be granted and will allow Envision Virtual 

Tours, Inc. the ability to impact safety, the environment, and the economy of society as a 

whole. 

If you want to exercise the privileges of your exemption outside the United States, you must 

state the reason.

We do not seek to exercise the privileges of an exemption outside the United States. 

Best Regards,

Stuart Wade, Owner

Envision Virtual Tours, Inc. 
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Conditions and Limitations

Failure to comply with any of the conditions and limitations of this grant of exemption will be

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom

2 when weighing less than 55 pounds including payload. Proposed operations of any

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The

exemption holder may use either groundspeed or calibrated airspeed to determine

compliance with the 87 knot speed restriction. In no case will the UA be operated at

airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used

to satisfy the VLOS requirement as long as the PIC always maintains VLOS

capability. The VO and PIC must be able to communicate verbally at all times;

electronic messaging or texting is not permitted during flight operations. The PIC

must be designated before the flight and cannot transfer his or her designation for the

duration of the flight. The PIC must ensure that the VO can perform the duties

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its

operations in accordance with the conditions and limitations stated in this grant of

exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the

Administrator upon request. If a discrepancy exists between the conditions and

limitations in this exemption and the procedures outlined in the operating documents,

the conditions and limitations herein take precedence and must be followed.

Otherwise, the operator must follow the procedures as outlined in its operating

documents. The operator may update or revise its operating documents. It is the

operator’s responsibility to track such revisions and present updated and revised

documents to the Administrator or any law enforcement official upon request. The
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operator must also present updated and revised documents if it petitions for extension

or amendment to this grant of exemption. If the operator determines that any update

or revision would affect the basis upon which the FAA granted this exemption, then

the operator must petition for an amendment to its grant of exemption. The FAA’s

UAS Integration Office (AFS−80) may be contacted if questions arise regarding

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation

or flight characteristics, e.g., replacement of a flight critical component, must undergo

a functional test flight prior to conducting further operations under this exemption.

Functional test flights may only be conducted by a PIC with a VO and must remain at

least 500 feet from other people. The functional test flight must be conducted in such

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the

UAS is in a condition for safe flight. The pre-flight inspection must account for all

potential discrepancies, e.g., inoperable components, items, or equipment. If the

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is

prohibited from operating until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the aircraft and

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport,

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal

government. The PIC must also meet the flight review requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the

ability to safely operate the UAS in a manner consistent with how the UAS will be

operated under this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs

(training, proficiency, and experience-building) and determining the PIC’s ability to

safely operate the UAS in a manner consistent with how the UAS will be operated
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under this exemption are permitted under the terms of this exemption. However,

training operations may only be conducted during dedicated training sessions. During

training, proficiency, and experience-building flights, all persons not essential for

flight operations are considered nonparticipants, and the PIC must operate the UA

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not

denoted with an ARP, the center of the airport symbol as denoted on the current

FAA-published aeronautical chart, unless a letter of agreement with that airport’s

management is obtained or otherwise permitted by a COA issued to the exemption

holder. The letter of agreement with the airport management must be made available

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast

weather conditions) there is enough available power for the UA to conduct the

intended operation and to operate after that for at least five minutes or with the reserve

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All

operations shall be conducted in accordance with an ATO-issued COA. The

exemption holder may apply for a new or amended COA if it intends to conduct

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial

number, registered in accordance with 14 CFR part 47, and have identification

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law enforcement

official upon request.
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24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. The operator must ensure

that nonparticipating persons remain under such protection. If a situation arises

where nonparticipating persons leave such protection and are within 500 feet of

the UA, flight operations must cease immediately in a manner ensuring the safety

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission

for operating closer to those objects and the PIC has made a safety assessment of

the risk of operating closer to those objects and determined that it does not

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with

permission from the property owner/controller or authorized representative.

Permission from property owner/controller or authorized representative will be

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be reported

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be

reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM)

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day

notification may be waived with the concurrence of the FSDO. The plan of activities

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of

the UAS;
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d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners

and/or local officials to conduct the filming production event; the list of those

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city,

town, county, and/or state over which filming will be conducted and the altitudes

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons

consenting to be involved and necessary for the filming production, as specified in the

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS

operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 

45, 47, 61, and 91.