August 12, 2015
U.S. Department ofTransportation DocketManagement System I200 New Jersey Ave., SE Washington, DC 20590 Reference: Visualytics Group, LLC. Petition for Section 333 Exemption: Re: Research & DevelopmentofMethods to conductaerial data collection, photographyand videographyconsisting ofstructural inspections ofhomes and businesses (roofs), pipelines (oil and gas), realestateand golf course marketingand surveys and otherflight operations thatcould be performed safely and more cost effectivelywith the use ofsmallUAS.
Dear Sir orMadam:
In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under section 333 of the FAA Modernization and Reform Act of2012, Visualytics Group LLC. (Petitioner or Visualytics), is petitioning for an exemption from the Federal Aviation Regulations ("FARs") and otherrules/statutes pertaining to small Unmanned Aircraft Systems ("UAS") to conduct aerial data collection, photography and videography consistingofstructural inspections ofhomes and businesses (roofs), pipelines (oil and gas), real estate and golfcourse marketing and surveys and other flight operations that could be performed safely and more cost effectively with the use ofsmall UAS at low altitude within the U.S. national airspace system as compared to a manned aircraft. Operations will be perfonned only atthe request ofand with the authorization and permission ofclients ortheir authorized agents in orderto facilitate commerce and raise awareness ofthe beneficial uses ofUAS's. So long as such operations are conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333.
A. THEFAA'S LEGALAUTHORITYTO GRANTTHIS EXEMPTION REQUEST Visualytics shares Congress's vision ofintegrating small UAS for civil use in to ournational airspace and providing economic benefits and growth from this rapidly developing technology. Current law does not provide adequate authority to extend these research and development activities, and this application seeks interim authority from the FAA to allow Visualytics to pursue these activities it began researching in 2014.
In addition, the Federal AviationActexpressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under§ 40101 of the Act, that includes VAS, from the requirementthat all civil aircraft must have a current airworthiness certificate. TheAdministrator may grant an exemptionfrom a requirement ofa regulation prescribed under§§ 4470l{a) or (b) orin§§ 44702-44716 ofthe Act ifthe Administratorfinds the exemption in the public interest. Obtaining a Section 333 exemption would allow Visualytics the authority to do further research and development in a safe and efficient manner without burdeningthe FAA with additional requests for each ofourVAS platforms and operations. Currently, the FAA does not allow civil operations (meaning operations otherthan public aircraft operations or model aircraft 

### I "hobbyist" activities which include research and development); therefore Visualytics has not been able to fully develop its VAS flight research. Through this petition, Visualytics seeks an exemption to operate small VAS to further develop its research and development ofthis emerging technology.

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244Yisualytics small UAS are aircraft weighing significantly less than 55 lbs. (details are provided within). They operate at slow speeds (under45kts) aod within line ofsight within the areas described in this petition. Such operations will ensure that the small UAS operated by Yisualytics will not create a hazard to other aircraft operating in the national airspace, to the general public orpose a threatto national security as dictated by the Federal Aviation Regulations (FAR).
B. NAMEAND ADDRESS OF THEPETITIONER: Yisualytics Group LLC. 2864 Stackhouse St. FortWorth, Texas 76244 Phone: 214-316-6104 E-mail: david.rys@visualyticsgroupllc.com
C. EXEMPTIONS REQUESTED:
The FAA considers umnaoned aircraft as "aircraft" flown by a "pilot" regardless ofthe location ofthe pilot. All aircraft and pilots must comply with applicable sections ofTitle 14 ofthe Code ofFederal Regulations (14 CFR) to operate within theNational Airspace. Umnaoned aircraft are unable to comply with certain sections of 14 CFR as the regulations were written priorto the consideration ofsmall UAS operating within the national airspace. Therefore Yisualytics is requesting an exemption from certain parts of 14 CFR cited below in additionto such further exemptions and reliefas the FAA may determine is necessary to permitthe operations described herein.
14 CFRPart 61.113 (a) and (b)- Private pilotprivileges and limitations 14 CFRPart 91.119 (c) -Minimum safe altitudes over congested and other areas 14 CFRPart 91.121 -Altimetersettings 14 CFRPart 91.151 (a)- Fuel requirements for flight in YFR conditions 14 CFRPart 91.405 (a)- Maintenance required 14 CFRPart 91.407 (a)- Operation aftermaintenance, preventive maintenance, rebuilding or alteration 14 CFRPart 91.409 (a) (I) aod (2)- Inspections 14 CFRPart 91.417 (a) and (b)- Maintenance Records 61.113(a) & (b). Yisualytics request reliefin orderto facilitate the utilization ofpilots, who hold a private pilot (or greater) certificate. UAS operations will always be conducted by one ofthe two licensed commercial and private pilots. Combined, Yisualytics Pilots have 4000+ total flight hours, holding multiengine instrumented fixed wing ratings; one Pilot holds a current airline transport license as well as a Class I Medical certificate. Yisualytics exceeds the minimum requirements maodated thus ensuring compliance oftheNational Air Space (NAS). This positions Yisualytics to ensurethe safety ofthe public at large. Any pilots operating underthis exemption would berequired to comply with aoy conditions set forth and in similar fashion to the previously graoted exemptions.
All Pilot in command (PIC) operating under this exemption would berequired to comply with any conditions as setforth and in a similarfashion to the previously graoted exemptions. All UAS operations will utilize a visual observer (YO) at all times while underthis requested exemption. The PIC and YO must be able to communicate verbally at all times 91.119(c) Discussed in Exemption I I 138 (DOUGLAS TRUDEAU) (see reference 1), operations conducted closerthan 500 feet to the ground may require that the UA be operated closerthan 500 feet to essential persons, or objects that would not be possible without additional relief. Thepetitioner requests modification, waiver or exemption and clarification concerning the terms "congested areas" and "densely

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244populated". Visualytics requests waiver for this condition to allow reasonable and responsible operations with safety as our main concern in areas ofsubdivisions and neighborhoods ifrequired.
91.121 Discussed in Exemption 11138 (DOUGLAS TRUDEAU) (see reference I) is inapplicable since the UAS does not have an altimeterand instead utilizes electronic GPS with a barometric sensor for altitude infonnation. 91.151(a) Discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) (see reference 2), prior reliefhas been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and I0650. In addition, similar UAS specific reliefhas been granted in Exemption Nos. 881 I, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percentto the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operatingdocuments discusses procedures regarding remaining battery powermanagement. Those documents contain a condition in which the PIC will initiate a landing procedure when battery remainingreaches a specified level. Given the limitations on proposed operations and the location ofthose proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable. 91.405(a). 91.407(a)(1). 91.409 (a)(1) & (2). 91.417(a) & (b) Discussed in Exemption 11138 (DOUGLAS TRUDEAU) (see reference I), Visualytics proposes to inspect and ensure thatthe UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner's operating documents and the conditions and limitations specified, describingthe requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would not be adversely affected.
D. SPECIFIC SECTIONS OF 14 C.F.R. FROMWHICH PETITIONERS SEEKAN EXEMPTION: Visualytics also requests exemption from such other FARs as the FAA deems appropriate to enable the requested operations. If, duringthe effective dates ofany Grant ofExemption issued pursuantto this Petition, the FAA issues interim orfinal rules for small UAS, Visualytics requests that it be relieved of the requirements ofany conditions and limitations ofsaid exemption and allowed to comply with any less burdensome applicable regulations that may have become effective.
E. THEUAS Visualytics specifically proposes to conduct UAS operations using small UAS includingthe OJ! Phantom 2 Vision+, the 30Robotics Solo and the 30Robotics X-SM.
The OJ! Phantom 2+ is a multi-rotor aircraft. The Phantom 2+ has a 1284gtake-offweight (battery and propellers included). The Phantom 2+carries a 5200mAh LiPo battery, which facilitates up to 25 minutes offlight time. It can be flown with either a radio ortablet and carries a 3-axis Camera Stabilization Gimbal with a 14 Megapixel/1080p integrated camerasystem. The Phantom 2+has a maximum cruise speed of 15 m/s. Itfeatures auto-takeoffand landing, auto go home and landing, GPS waypoint navigation, direction lock, and GIS mapping. A remote controllerand Wi-Fi Communications system; 5.8 GHzremote control receiver, flight control system and a 2.4 GHz Wi-Fi module.
The 30Robotics Solo is a multi-rotor aircraft. The Solo has a flight time of25 minutes; 20 minutes with payload, a range of.5 miles (.8 km), max speed: 55 mph (89 km/h), max ascent speed ofI0 m/s in stabilize mode; 5 m/s in "fly" mode, max payload: 420 g, max altitude: 400 feet per FAA regulation, user adjustable (122m), motors: 880 kV, propellers: I0" diameter4.5" pitch self-tightening (24 em diameter

Visualytics Group LLC 2864Stackhouse Street Fort Worth, TX 76244144 em pitch); glass-reinforced nylon, autopilot: Pixhawk 2, software: APM Copter, communication: 3DRLink secure WiFi network, frequency: 2.4 GHz, weight: 3.3 lbs. (1.5 kg) I 3.9 lbs. (1.8 kg) with cameraand Solo Gimbal, dimensions: 10 in. tall (25 em), 18 in. (46 em) motor-to-motor, flight battery: Lithium polymer 5200 mAh 14.8 Vdc, battery charge time: -1.5 hours, controller battery: 2600 mAh 7.2 Vdc rechargeable lithium ion. (Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style and pilot skill. Listed flight time applies to elevations less than 2,000 feet above sea level).
The 3D Robotics X8-M is a multi-rotor aircraft. Itweighs (with battery) 7.7 lbs. (3.5 kg), dimensions: 13.7 in x 20.1 in x 11.8 in (35 em x 51 em x 30 em), payload capacity of.4 lbs. (200 g). Radio range of.6 miles (I (km), flight time of 14 minutes, maximum operational wind speed of25 mph (II m/s), a Pixhawk autopilot system, 4S I0000 mAh IOC lithium polymerbattery.
F. RISKMITIGATION Visualytics has reviewed FAA exemptions reference's 13 Conditions and Limitations section and believe thatthe procedures specified therein are reasonable and will be utilized in orderto manage and mitigate risk and ensure public safety.
A preflightchecklist will be developed and employed to ensure thatthe UAS's airworthiness will be verified before launch. Airworthiness will be maintained by performance ofroutine inspections before each flight, maintaining flight and maintenance logs to record time on failure prone components. Visualytics request that in a manner similarto reference 13, be allowed to operatewithin 5 miles ofan airport provided that:
"TheUA may notoperatein Class B, C, orD airspacewithoutwritten approvalfrom the FAA. The UA may notoperatewithin 5 nauticalmiles ofthegeographic centerofa non-towered airport as denoted on a currentFAA published aeronautical chart unless a letterofagreementwith that airport's managementis obtained, and the operation is conducted in accordancewith a NOT AM as required by the operator's COA. Theletterofagreementwith the airportmanagementmustbe made availableto theAdministratorupon request." Operations within 5 miles ofan airport are not anticipated to be routine but Visualytics is requesting a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the need arise. Operations within class B airspace are not requested due to the lack ofmode C transponder.
G. PUBLIC INTEREST
Use ofthe UAS in lieu ofa manned aircraft would enhance safety and reduce the environmental impact as compared to similaroperations conducted with manned aircraft ofgreater proportions, carrying a crew and flammable fuel.
In regards to performing inspections ofhomes and businesses (roofs) and pipelines (oil and gas) the UAS will minimize the riskto persons attempting to climb these structures and photograph problem areas. Safe, roofinspections conducted by human beings carries with it certain risks. Currently, inspectors need to physically climb onto the roofusing ladders and other safety gearto conduct inspections. Sometimes, a two story/steep team is used, requiring two representatives and special safety harnesses. The dangers of inspecting any roofinclude losing one's footing, having a ladder slip, and being blown offa rooffrom wind shear. In addition to safety concerns, inspectinga roofby physically climbing on it has the potential to damage the roof. Using UAS for roofinspections avoids all ofthese risks. By utilizing UAS,
Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244Visualytics representatives will be able to reduce their exposure to hazards and rapidly obtain accurate assessments ofthe roofwhile remaining safety on the ground. Many ofthe pipelines (oil and gas) in our areatravel in areas that are hard to reach by vehicle orfoot and ifan area is suspected ofhaving problems the UAS can reach itto make an assessment easier and safer.
The use ofthe UAS in order to facilitate commerce could lead to economic growth. Operations for this petition will enable service for property owners or their designees seeking an enhanced perspective for characteristics, amenities, and benefits oftheirdesired photographic subjects that cannot be displayed through ground level photography. Aerial photography and videography is a valuable marketingtool that can lead to increased commerce. The VO will be utilized at all times thatthe UAS is perfonning duties for compensation and the PIC will hold, as a minimum, a Private Pilot license. Flight data including UAS flight time, Control Unit operation time, incident, and details will be recorded for each flight and made available to the FAA at any time needed. Any deviations from normal operations will also berecorded and made available to FAA.


### H. SUMMARY TO BE PUBLISHED IN FEDERAL REGISTER
Petitioner: Visualytics Group LLC
Sections of 14 C.F.R. Affected: Part§§ 61.1 13(a) and (b); § 91.119(c); § 91.121; § 91.151(a); § 9!.405(a); § 91.407(a)(l); §§ 91.409(a)(l) and (2); §§ 91.417(a) and (b). Description of Relief Sought: Petitioner seeksrelieffrom the requirements of 14 C.F .R. Part 14 C.F.R. §§ 61.1 13(a) and (b); 14 C.F.R. § 91.1!9(c); 14 C.F.R. § 91.121; 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. §§ 91.409(a)(l) and (2); 14 C.F.R. §§ 91.417(a) and (b) to conduct aerial data collection, photography and videography consisting ofstructural inspections ofhomes and businesses (roofs), pipelines (oil and gas), real estate and golfcourse marketing and surveys and other flight operations subjectto operating procedures that meet orexceed those thatthe FAA requires for similar operations for internal Visualytics Group Research & Development purposes. 

### I. CONCLUSION
Satisfaction ofthe criteria provided in Section 333 ofthe FMRA regarding size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line ofsight, and national security, provide more than adequatejustificationforthe grant ofthe requested exemption allowing operation ofPetitioner's use ofsmall UAS for roofinsurance inspections, oil and gas pipeline inspections, aerial photography, cinematography and videography pursuantto the Operations Manual. Allowing Visualytics this exemption would give Visualytics the ability to continue research and development beyond the limits imposed today. Additional testingwould benefit not only Visualytics and its clients, but would serve as a partnership with the FAA and others within the UAS community to advancethis new and emergingtechnology in a safe and controlled environment.
The FAA has issued grants ofexemption in circumstances similar in all material respects to those presented herein. In Grants ofExemption Nos. II062 to Astraeus Aerial (see DocketNo. FAA-2014-0352), 11109 to Clayco, Inc. (see DocketNo. FAA-2014-0507), 11112 to VDOS Global, LLC (see DocketNo. FAA-2014-0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA-2014-0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitionerand carrying no passengers orcrew, rather than a manned aircraft ofsignificantly greater proportions, carrying crew in addition to flammable fuel, givesthe FAA good cause to find thatthe UAS operation enabled by this exemption is in the public interest.

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244Visualytics does not seekto exercise the privileges ofthis exemption, should it be granted, outside the United States. Ourrequest is strictly to be granted authority for civil UAS R&D operations at specified locations within the national airspace system.

# Da~&·r;r President I Managing Partner Visualytics Group LLC.

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244References I) FAA ExemptionNo. I I 138, Regulatory DocketNo. FAA20140481 in the matter ofthe petition of DOUGLAS TRUDEAU 2) FAA ExemptionNo. II 136, Regulatory DocketNo. FAA-2014-0508 in the matter ofthe petition of ADVANCED AVIATION SOLUTIONS LLC 3) FAA Exemption No. I 1080 Regulatory DocketNo. FAA20140355 in the matter ofthe petition of FLYING CAM INC


### URL Links for attachmentfiles over

### 30MB: I) Phantom 2 Vision+ User Manual http://download.djiinnovations.com/downloads/phantom 2 vision plus/en/Phantom 2 Vision Plus Use r Manual v1.8 en.pdf 2) Phantom Quick Start Manual http://download.djiinnovations.com/downloads/phantom/en/PHANTOM Quick Sta1i Manual v1.7 en.p df 3) Phantom 2 Vision Pilot Training Guide http://download.djiinnovations.com/downloads/phantom 2 vision plus/en/Phantom 2 Vision Plus Pilo t Training Guide vi.I en.pdf 4)Phantom 2 Vision Release Notes http://download.djiinnovations.com/downloads/phantom 2 vision plus/en/Phantom 2 Vision Plus Rei ease Notes en.pdf 5) Phantom 2 Vision Battery Safety Guidelines http://download.djiinnovations.com/downloads/phantom ? vision plus/Sma11 Flight Batterv Safetv G uidelines.pdf 6) 3D Robotics SoloUser Manual http://3drobotics.com/wp-content/uploads/2015/08/v5 09 06 15.pdf 7) 3D Robotics Solo Preflight Checklist http://3drobotics.com/kb/preflio:ht-checklist-solo/ 8) 3D Robotics Solo Battery Safety http://3drobotics.com/kb/batterv-safetv-solo/ 9) 3D Robotics X8+ Operation Manual http:/ 

### 13drobotics.com/wp-content/uploads/2015/04/XS-Operation-Manual-vC.pdf I0) 3D Robotics X8+Flight Checklists http:/ /3drobotics.com/wp-content/up1 oads/20 15/04/XS-Checklist-vB.pdf I I) 3D Robotics X8+ Safety Checklist http://3drobotics.com/kb/safetv/

Visualytics Group LLC 2864 Stackhouse Street Fort Worth, TX 76244