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PETITION FOR EXEMPTION

I. SUMMARY

Petitioner, Helios Visions, Inc., seeks an exemption from the requirements of 14 C.F.R.

Part 21 Subpart H, 14 C.F.R. 91.7, 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121,

14 C.F.R. 91.151(b), 14 C.F.R. 91.203, 14 C.F.R. 91.405, 14 C.F.R. 91.407(a)(1), 14 C.F.R.

91.409 (a)(1) and (2), and 14 C.F.R. 91.417(a) and (b) to operate 4 small Unmanned Aircraft 

Systems (hereinafter “UAS”) for the commercial purpose of conducting aerial video 

photography, pursuant to Federal Aviation Administration Modernization and Reform Act of 

2012 § 333. Federal Aviation Administration (hereinafter “FAA”) authority for similar 

exemptions granted in 49 USC 106(f), 49 USC 40113, and 49 USC 44701. These activities 

include surveys and inspections of roads, buildings, bridges, roofs, gas and electric meters, 

agriculture along with data collection of the same. Also, assisting local law enforcement and fire 

departments with emergency matters including but not limited to search and rescue. All 

operations will be conducted with public safety and right to privacy safeguarded at all times as 

required in 49 USC 44701. This petition for exemption is filed in accordance with 14 C.F.R.

§11.81. 

II. INTRODUCTION

Petitioner’s background includes extensive expertise of information technology,

including but not limited to data collection, digital marketing, web design, graphic art, 

photography and videography. The three founders started Helios Visions, Inc. with the main 

objective to help local municipalities, government entities and business owners operate in a more 

efficient and cost effective manner. Therefore, Petitioner provides their clients with expertise 

and knowledge in advanced technology to increase efficiency. 

Further, to ensure safety, all the pilots in command operating Petitioner’s UAS have 

hundreds of hours of flying experience along with their pilot’s license. The pilots in command 

qualification flight hours and currency shall be logged in a manner consistent with 14 CFR 

§61.51(b). 
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Petitioner seeks an exemption to operate the following UAS commercially for 

compensation or hire. 

1. DJI Phantom 3 Professional

Petitioner will operate a DJI Phantom 3 Professional, with a total weight of 1280g or 2lbs 

13 oz. The dimensions are 40.36cm x 40.36cm x 19.05cm or 16inch x 16inch x 7.5inch. Under 

still air the maximum speed is no more than 16m/s or 35mph with a cruising speed of 11m/s or 

25mph. The DJI Phantom 3 Professional has the ability to hover and move along a vertical and 

horizontal plane simultaneously. The DJI Phantom 3 Professional has four motors, Motor Model 

DJI 3510, powered by a 4480mAh 4s LiPo Lithium Polymer battery. There are four propellers, 

Propeller Model DJI 1345, in use. The DJI Phantom 3 Professional will be controlled with the 

C3 remote controller with an operating frequency of 2.400GHz – 2.483GHz. The live video feed 

will have an operating frequency of 2.4GHz ISM with maximum range of 1.2 miles. The Radio 

Frequency spectrum will comply with Federal Communication Commission or other appropriate 

government oversight agency requirements.

(a) General Features.

• Ready to fly 

• 3-axis camera stabilization 

• Precision flight and stable hovering 

• GPS/GLONASS positioning & auto return home 

• Onscreen real-time flight parameters 

• High Definition 4k Camera

• Camera tilt control 

• Film straight down 

• Supports Adobe DNG RAW 

• Adobe lens profile support 

• Camera parameter settings 

• Album synchronization 

• FAA no-fly zones locked out via installed software

(b) Transmitter.

• Operating Frequency: 2.400 GHz – 2.483 GHz 

• Communication Distance(open area): CE: 2000m; FCC: 2000m 

• Receiver Sensitivity(1%PER): -101dBm +/- 2dBm

• Transmitter Power: CE: 16dBm; FCC: 20dBm

• Working Voltage: 1.2A @ 7.4V 

• Battery: 6000 mAh LiPo 2s

(c) Camera.
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• Operating Environment Temperature: 0°C-40°C

• Max Resolution: 4096 x 2162p @ 24/25fps

• FOV: 94°/ 85° 

• Sensor size: 1/2.3" 

• HD Recording: 4k p 24/25fps / 720p 60fps

(d) DJI Vision Application.

• System Requirement of Mobile Device: iOS version 6.0 or above/ Android system 

version 4.0 or above 

• Mobile Device Support: Recommended: iPhone4s, iPhone5, iPhone5s, iPod Touch4, 

iPod Touch5. 

2. DJI Phantom 3 Advanced

Petitioner will operate a DJI Phantom 3 Advanced, with a total weight of 1280g or 2lbs 

13 oz. The dimensions are 40.36cm x 40.36cm x 19.05cm or 16inch x 16inch x 7.5inch. Under 

still air the maximum speed is no more than 16m/s or 35mph with a cruising speed of 11m/s or 

25mph. The DJI Phantom 3 Advanced has the ability to hover and move along a vertical and 

horizontal plane simultaneously. The DJI Phantom 3 Advanced has four motors, Motor Model 

DJI 3510, powered by a 4480mAh 4s LiPo Lithium Polymer battery. There are four propellers, 

Propeller Model DJI 1345, in use. The DJI Phantom 3 Advanced will be controlled with the C3 

remote controller with an operating frequency of 2.400GHz – 2.483GHz. The live video feed 

will have an operating frequency of 2.4GHz ISM with maximum range of 1.2 miles. The Radio 

Frequency spectrum will comply with Federal Communication Commission or other appropriate 

government oversight agency requirements.

(a) General Features.

• Ready to fly 

• 3-axis camera stabilization 

• Precision flight and stable hovering 

• GPS/GLONASS positioning & auto return home 

• Onscreen real-time flight parameters 

• High Definition 4k Camera

• Camera tilt control 

• Film straight down 

• Supports Adobe DNG RAW 

• Adobe lens profile support 

• Camera parameter settings 

• Album synchronization 

• FAA no-fly zones locked out via installed software
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(b) Transmitter.

• Operating Frequency: 2.400 GHz – 2.483 GHz 

• Communication Distance (open area): CE: 2000m; FCC: 2000m 

• Receiver Sensitivity(1%PER): -101dBm +/- 2dBm

• Transmitter Power: CE: 16dBm; FCC: 20dBm

• Working Voltage: 1.2A @ 7.4V 

• Battery: 6000 mAh LiPo 2s

(c) Camera.

• Operating Environment Temperature: 0°C-40°C

• Max Resolution: 1920x1080p @ 24/60fps

• FOV: 94°/ 85° 

• Sensor size: 1/2.3" 

• HD Recording: 1080p 24/60fps / 720p 60fps

(d) DJI Vision Application.

• System Requirement of Mobile Device: iOS version 6.0 or above/ Android system 

version 4.0 or above 

• Mobile Device Support: Recommended: iPhone4s, iPhone5, iPhone5s, iPod Touch4, 

iPod Touch5. 

3. DJI Inspire 1

Petitioner seeks an exemption to operate a UAS commercially for compensation or hire. 

Petitioner will operate a DJI Inspire 1, with a total weight of 2935g. Under still air the maximum 

speed is no more than 16m/s or 35mph with a cruising speed of 10m/s or 25mph. The DJI 

Inspire 1 has the ability to hover and move along a vertical and horizontal plane simultaneously. 

The DJI Inspire 1 has four motors, Motor Model DJI 3510, powered by a 5700mAh LiPo 

Lithium Polymer battery. There are four propellers, Propeller Model DJI 1345, in use. The DJI 

Inspire 1 will be controlled with the C1 remote controller with an operating frequency of 

2.400GHz – 2.483GHz & 5.725~5.825 GHz. The live video feed will have an operating 

frequency of 2.4GHz ISM with maximum range of 1.2 miles. The Radio Frequency spectrum 

will comply with Federal Communication Commission or other appropriate government 

oversight agency requirements.

(a) General Features.

• Ready to fly 

• 3-axis camera stabilization 

• Precision flight and stable hovering 

• GPS/GLONASS positioning & auto return home 

• Onscreen real-time flight parameters 
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• High Definition 4k Camera

• Camera tilt control 

• Film straight down 

• Supports Adobe DNG RAW 

• Adobe lens profile support 

• Camera parameter settings 

• Album synchronization 

• FAA no-fly zones locked out via installed software

• Max Ascent Speed: 5 m/s

• Max Descent Speed: 4 m/s

(b) Transmitter.

• Operating Frequency: 2.400 GHz – 2.483 GHz 

• Communication Distance:(open area): CE: 2000m; FCC: 2000m 

• Receiver Sensitivity:(1%PER): -101dBm +/- 2dBm

• Transmitter Power: CE: 16dBm; FCC: 20dBm

• Working Voltage: 1.2A @ 7.4V 

• Battery: 6000 mAh LiPo 2s

• Max Flight Time: Approximately 18 minutes. 

(c) Camera.

• Operating Environment Temperature: 0°C-40°C

• Max Resolution: 4096 x 2162p @ 24/25fps

• FOV: 94°/ 85° 

• Sensor size: 1/2.3" 

• HD Recording: 4k p 24/25fps / 720p 60fps

(d) DJI Vision Application.

• System Requirement of Mobile Device: iOS version 6.0 or above/ Android system 

version 4.0 or above 

• Mobile Device Support: Recommended: iPhone4s, iPhone5, iPhone5s, iPod Touch4, 

iPod Touch5. 

4. DJI Matrice 100

Petitioner seeks an exemption to operate a UAS commercially for compensation or hire. 

Petitioner will operate a Matrice 100, with a total weight of 2431g or 5lbs 3oz. Under still air the 

maximum speed is no more than 22m/s or 49mph with a cruising speed of 11m/s or 25mph. The 

DJI Matrice 100 has the ability to hover and move along a vertical and horizontal plane 

simultaneously. The Matrice 100 has four motors, Motor Model DJI 3510, powered by a 

5700mAh 6S LiPo Lithium Polymer battery. There are four propellers, Propeller Model DJI 

1345, in use. The Matrice 100 will be controlled with the C1 remote controller with an operating 
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frequency of 2.400GHz – 2.483GHz & 5.725~5.825 GHz. The live video feed will have an 

operating frequency of 2.4GHz ISM with maximum range of 1.2 miles. The Radio Frequency 

spectrum will comply with Federal Communication Commission or other appropriate 

government oversight agency requirements.

(a) General Features.

• Ready to fly 

• 3-axis camera stabilization 

• Precision flight and stable hovering 

• GPS/GLONASS positioning & auto return home 

• Onscreen real-time flight parameters 

• High Definition 4k Camera

• Camera tilt control 

• Film straight down 

• Supports Adobe DNG RAW 

• Adobe lens profile support 

• Camera parameter settings 

• Album synchronization 

• FAA no-fly zones locked out via installed software

(b) Transmitter.

• Operating Frequency:2.400 GHz – 2.483 GHz & 2.400GHz – 2.483GHz & 5.725~5.825 

GHz

• Communication Distance(open area): CE: 2000m; FCC: 2000m 

• Receiver Sensitivity(1%PER): -101dBm +/- 2dBm

• Transmitter Power: CE: 16dBm; FCC: 20dBm

• Working Voltage: 1.2A @ 7.4V 

• Battery: 6000 mAh LiPo 2s

(c) Camera.

• Operating Environment Temperature: 0°C-40°C

• Max Resolution: 4096 x 2162p @ 24/25fps

• FOV: 94°/ 85° 

• Sensor size: 1/2.3" 

• HD Recording: 4k 24/25fps / 720p 60fps

(d) DJI Vision Application.

• System Requirement of Mobile Device: iOS version 6.0 or above/ Android system 

version 4.0 or above 

• Mobile Device Support: Recommended: iPhone4s, iPhone5, iPhone5s, iPod Touch4, 

iPod Touch5. 
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III. BASIS FOR PETITION

(a) Name and address of the petitioner.

Helios Visions, Inc.

Incorporated in the State of Illinois

Ted Parisot, Registered Agent

401 W. Bridge Street

Streator, IL 61364

tedsaccount@gmail.com

(b) The specific section of 14 C.F.R. from which 

Helios Visions, Inc. is seeking an exemption.

Helios Visions, Inc. respectfully requests the grant of an exemption to the following 

specific sections of the Federal Regulations allowing it to operate 4 lightweight UAS for 

commercial use by a licensed pilot.

1. 14 C.F.R. Part 21 Subpart H: Certification procedures for products and parts,

Airworthiness Certificates.

2. 14 C.F.R. 91.7 (a) Civil aircraft airworthiness.

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

3. 14 C.F.R. 91.9(b)(2) Civil aircraft flight manual. 

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

(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.

4. 14 C.F.R. 91.119 (c) Minimum safe altitudes. 

(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.

5. 14 C.F.R. 91.121 Altimeter settings.

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating— (1) Below 

18,000 feet MSL, to—
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(i) The current reported altimeter setting of a station along the route and within 100 nautical 

miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the 

current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or 

an appropriate altimeter setting available before departure; or (2) At or above 18,000 feet MSL, 

to 29.92′′ Hg. 

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of 

operation as shown in the following table: Current altimeter setting Lowest usable flight level 

29.92 (or higher) ...................................................... 

180 29.91 through 29.42 ................................................ 

185 29.41 through 28.92 ................................................ 

190 28.91 through 28.42 ................................................ 

195 28.41 through 27.92 ................................................ 

200 27.91 through 27.42 ................................................ 

205 27.41 through 26.92 ................................................ 

210 (c) 

To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, 

the pilot shall take the flight level equivalent of the minimum altitude in feet and add the 

appropriate number of feet specified below, according to the current reported altimeter setting: 

Current altimeter setting Adjustment factor 

29.92 (or higher) ...................................................... 

None 29.91 through 29.42 ................................................ 

500 29.41 through 28.92 ................................................ 

1,000 28.91 through 28.42 ................................................ 

1,500 28.41 through 27.92 ................................................ 

2,000 27.91 through 27.42 ................................................ 

2,500 27.41 through 26.92 ................................................ 

3,000

6. 14 C.F.R. 91.151(b) Fuel requirements for flights 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. 

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.

7. 14 C.F.R. 91.203 (a), (b) Civil aircraft; certification 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.

8. 14 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;

(b) Shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance 

records indicating the aircraft has been approved for return to service;

(c) Shall have any inoperative instrument or item of equipment, permitted to be inoperative 

by§ 91.213(d)(2) of this part, repaired, replaced, removed, or inspected at the next required 

inspection; and

(d) When listed discrepancies include inoperative instruments or equipment, shall ensure that a 

placard has been installed as required by§ 43.11 of this chapter.

9. 14 C.F.R. 91.407(a)(1) Operation after maintenance. 

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

rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under§ 43.7 of this chapter; 

and
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(2) The maintenance record entry required by§ 43.9 or § 43.11, as applicable, of this chapter has 

been made.

(b) No person may carry any person (other than crewmembers) in an aircraft that has been 

maintained, rebuilt, or altered in a manner that may have appreciably changed its flight 

characteristics or substantially affected its operation in flight until an appropriately rated pilot 

with at least a private pilot certificate flies the aircraft, makes an operational check of the 

maintenance performed or alteration made, and logs the flight in the aircraft records.

(c) The aircraft does not have to be flown as required by paragraph (b) of this section if, prior to 

flight, ground tests, inspection, or both show conclusively that the maintenance, preventive 

maintenance, rebuilding, or alteration has not appreciably changed the flight characteristics or 

substantially affected the flight operation of the aircraft.

10. 14 C.F.R. 91.409(a)(1), (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—

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by § 43.7 of this chapter; or

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

this chapter.

No inspection performed under paragraph (b) of this section may be substituted for any 

inspection required by this paragraph unless it is performed by a person authorized to perform 

annual inspections and is entered as an “annual” inspection in the required maintenance records.

(b) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

carrying any person (other than a crewmember) for hire, and no person may give flight 

instruction for hire in an aircraft which that person provides, unless within the preceding 100 

hours of time in service the aircraft has received an annual or 100-hour inspection and been 

approved for return to service in accordance with part 43 of this chapter or has received an 

inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter. The 100-hour limitation may be exceeded by not more than 10 hours while en route to 

reach a place where the inspection can be done. The excess time used to reach a place where the 

inspection can be done must be included in computing the next 100 hours of time in service.

(c) Paragraphs (a) and (b) of this section do not apply to—

(1) An aircraft that carries a special flight permit, a current experimental certificate, or a lightsport or provisional airworthiness certificate;
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(2) An aircraft inspected in accordance with an approved aircraft inspection program under 

part 125 or 135 of this chapter and so identified by the registration number in the operations 

specifications of the certificate holder having the approved inspection program;

(3) An aircraft subject to the requirements of paragraph (d) or (e) of this section; or

(4) Turbine-powered rotorcraft when the operator elects to inspect that rotorcraft in accordance 

with paragraph (e) of this section.

(d) Progressive inspection. Each registered owner or operator of an aircraft desiring to use a 

progressive inspection program must submit a written request to the FAA Flight Standards 

district office having jurisdiction over the area in which the applicant is located, and shall 

provide—

(1) A certificated mechanic holding an inspection authorization, a certificated airframe repair 

station, or the manufacturer of the aircraft to supervise or conduct the progressive inspection;

(2) A current inspection procedures manual available and readily understandable to pilot and 

maintenance personnel containing, in detail—

(i) An explanation of the progressive inspection, including the continuity of inspection 

responsibility, the making of reports, and the keeping of records and technical reference material;

(ii) An inspection schedule, specifying the intervals in hours or days when routine and detailed 

inspections will be performed and including instructions for exceeding an inspection interval by 

not more than 10 hours while en route and for changing an inspection interval because of service 

experience;

(iii) Sample routine and detailed inspection forms and instructions for their use; and

(iv) Sample reports and records and instructions for their use;

(3) Enough housing and equipment for necessary disassembly and proper inspection of the 

aircraft; and

(4) Appropriate current technical information for the aircraft. The frequency and detail of the 

progressive inspection shall provide for the complete inspection of the aircraft within each 12 

calendar months and be consistent with the manufacturer's recommendations, field service 

experience, and the kind of operation in which the aircraft is engaged. The progressive inspection 

schedule must ensure that the aircraft, at all times, will be airworthy and will conform to all 

applicable FAA aircraft specifications, type certificate data sheets, airworthiness directives, and 

other approved data. If the progressive inspection is discontinued, the owner or operator shall 

immediately notify the local FAA Flight Standards district office, in writing, of the 

discontinuance. After the discontinuance, the first annual inspection under § 91.409(a)(1) is due 

within 12 calendar months after the last complete inspection of the aircraft under the progressive 

inspection. The 100-hour inspection under § 91.409(b) is due within 100 hours after that 

complete inspection. A complete inspection of the aircraft, for the purpose of determining when 

the annual and 100-hour inspections are due, requires a detailed inspection of the aircraft and all 
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its components in accordance with the progressive inspection. A routine inspection of the aircraft 

and a detailed inspection of several components is not considered to be a complete inspection.

(e) Large airplanes (to which part 125 is not applicable), turbojet multiengine airplanes, 

turbopropeller-powered multiengine airplanes, and turbine-powered rotorcraft. No person may 

operate a large airplane, turbojet multiengine airplane, turbopropeller-powered multiengine 

airplane, or turbine-powered rotorcraft unless the replacement times for life-limited parts 

specified in the aircraft specifications, type data sheets, or other documents approved by the 

Administrator are complied with and the airplane or turbine-powered rotorcraft, including the 

airframe, engines, propellers, rotors, appliances, survival equipment, and emergency equipment, 

is inspected in accordance with an inspection program selected under the provisions of paragraph 

(f) of this section, except that, the owner or operator of a turbine-powered rotorcraft may elect to 

use the inspection provisions of § 91.409(a), (b), (c), or (d) in lieu of an inspection option of 

§ 91.409(f).

(f) Selection of inspection program under paragraph (e) of this section. The registered owner or 

operator of each airplane or turbine-powered rotorcraft described in paragraph (e) of this section 

must select, identify in the aircraft maintenance records, and use one of the following programs 

for the inspection of the aircraft:

(1) A continuous airworthiness inspection program that is part of a continuous airworthiness 

maintenance program currently in use by a person holding an air carrier operating certificate or 

an operating certificate issued under part 121 or 135 of this chapter and operating that make and 

model aircraft under part 121 of this chapter or operating that make and model under part 135 of 

this chapter and maintaining it under § 135.411(a)(2) of this chapter.

(2) An approved aircraft inspection program approved under§ 135.419 of this chapter and 

currently in use by a person holding an operating certificate issued under part135 of this chapter.

(3) A current inspection program recommended by the manufacturer.

(4) Any other inspection program established by the registered owner or operator of that airplane 

or turbine-powered rotorcraft and approved by the Administrator under paragraph (g) of this 

section. However, the Administrator may require revision of this inspection program in 

accordance with the provisions of§ 91.415.

Each operator shall include in the selected program the name and address of the person 

responsible for scheduling the inspections required by the program and make a copy of that 

program available to the person performing inspections on the aircraft and, upon request, to the 

Administrator.

(g) Inspection program approved under paragraph (e) of this section. Each operator of an 

airplane or turbine-powered rotorcraft desiring to establish or change an approved inspection 

program under paragraph (f)(4) of this section must submit the program for approval to the local 

FAA Flight Standards district office having jurisdiction over the area in which the aircraft is 

based. The program must be in writing and include at least the following information:
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(1) Instructions and procedures for the conduct of inspections for the particular make and model 

airplane or turbine-powered rotorcraft, including necessary tests and checks. The instructions and 

procedures must set forth in detail the parts and areas of the airframe, engines, propellers, rotors, 

and appliances, including survival and emergency equipment required to be inspected.

(2) A schedule for performing the inspections that must be performed under the program 

expressed in terms of the time in service, calendar time, number of system operations, or any 

combination of these.

(h) Changes from one inspection program to another. When an operator changes from one 

inspection program under paragraph (f) of this section to another, the time in service, calendar 

times, or cycles of operation accumulated under the previous program must be applied in 

determining inspection due times under the new program.

11. 14 C.F.R. 91.417(a), (b) 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:

(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.

(b) The owner or operator shall retain the following records for the periods prescribed:
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(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with 

the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall 

be retained until the defects are repaired and the aircraft is approved for return to service.

(c) The owner or operator shall make all maintenance records required to be kept by this section 

available for inspection by the Administrator or any authorized representative of the National 

Transportation Safety Board (NTSB). In addition, the owner or operator shall present Form 337 

described in paragraph (d) of this section for inspection upon request of any law enforcement 

officer.

(d) When a fuel tank is installed within the passenger compartment or a baggage compartment 

pursuant to part 43 of this chapter, a copy of FAA Form 337 shall be kept on board the modified 

aircraft by the owner or operator.

(c)(1)The extent of relief Helios Visions, Inc. seeks; 

(c)(2) The reason Helios Visions, Inc. seeks the relief; and

(c)(3) The reasons why granting the exemption would not adversely affect safety.

The FAA is authorized under 49 USC 4470(f) and § 333 of the FAA Modernization and 

Reform Act of 2012 to exempt aircraft from the airworthiness certificate requirement in 

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

areas, and operation within visual line of sight that does not create a hazard to users of the 

national airspace system, public or pose a threat to national security. In accordance, Petitioner 

seeks the following exemptions to operate 4 UAS commercially for compensation or hire:

1. 14 C.F.R. Part 21 Subpart H: Certification procedures for products and parts, 

Airworthiness Certificates. 

This relief is requested because the size, weight, and defined area of operations for flights

permits an exception from Part 21 since Petitioner agrees when conducting commercial 

operations under the FAA issued exemption, to adhere to safety measures as set forth in the 

Flight Operations Manual; along with the operation limitations proposed by the FAA for a higher 

level of safety and to further enhance the safety of persons and property. Petitioner agrees to the 

following limitations under the “blanket” exemption to ensure safety:
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(a) The UAS operated by Petitioner will be registered in accordance with 49 USC 

44103: Registration of Aircraft as well as 14 C.F.R. 45: Identification and Registration 

Marking, before any commercial operations take place; 

(b) Flights will only occur in the daytime hours; 

(c) Flights will be operated in the line of sight of the pilot in command and/or a visual 

observer;

(d) Flights will be terminated at any time weather and wind deteriorates to “unsafe 

for flight” by manufacturer recommendations;

(e) The UAS weighs less than 55 lbs.; 

(f) Flights will be operated at 400 feet AGl or less;

(g) Pilot in command will hold an airline transport, commercial, private, recreational, 

or sport pilot certificate; 

(h) Pilot in command will 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;

(i) Pilot in command will meet the flight review requirements for their pilot 

designation;

(j) Pilot in command will do a thorough preflight inspection before every flight;

(k) Operator and Pilot in Command will remain in contact during flight;

(l) The operator and/or pilot in command will perform a check of the flight area, 

make operation borders and make certain of the safety of all person in the area;

(m) Consent from property owners will be obtained within the video capabilities to 

further reduce the chance of violating someone’s privacy;
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(n) All required FAA clearances, will be obtained and distances from airports strictly 

observed;

(o) The UAS will have the capability to return automatically to the pilot in command 

in a safe manner with the auto return function checked and working;

(p) Flights will only operate in visual flight rule conditions;

(q) UAS has a function to tell the pilot in command the distance away and its battery 

power remaining;

(r) Flight team will communicate by a two-way radio when working with a pilot in 

command and visual observer, as needed;

(s) When operating near or over water the UAS will be equipped with a flotation 

devise; and

(t) The UAS will not operate at a speed exceeding 100 miles per hour and to never 

operate greater than the maximum UAS operating airspeed recommended by the aircraft 

manufacturer.

The very small nature of the UAS combined with the safe guards presented above, will 

allow for the safe operation greater than that envisioned by Congress for the FAA to establish an 

exemption allowing commercial operations. Furthermore, because of the size of the UAS and 

altitude the UAS will be flying, approval presents no security issues and minimal safety 

concerns. The economic impact of reducing the cost of aerial photography benefits public 

interest and these operations will not create a hazard to users, public nor the environment. 

Similar relief has been granted in exemption nos. 11062, 11109, 11112, 11213, and 12645.

2. 14 C.F.R. 91.7 (a) Civil aircraft airworthiness.

This relief is requested because the UAS does not require an airworthy certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, the pilot in command before each

flight will use a safety checklist to provide an equal level of safety, and further, determine that 

the UAS is in a condition for safe flight. 
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3. 14 C.F.R. 91.9(b)(2) Civil aircraft flight manual. 

This relief is requested since there are no passengers and given the size of the UAS this 

regulation is inapplicable. An equivalent level of safety will be achieved by maintaining an UAS

manual with the operator and/or pilot in command on the ground.

4. 14 C.F.R. 91.119 (c) Minimum safe altitudes. 

This relief is requested since the equivalent level of safety will be achieved given the 

size, weight, speed and location of operation of the UAS. Compared to flight operations of 

traditional aircraft or rotorcraft, that weigh far more than the UAS; operations of the UAS fewer 

than 500 feet presents smaller risks to the public and property. Furthermore, no flight will be 

taken without the permission of the property owner. Finally, all precautions in paragraph 1 will 

provide an equal level of safety.

5. 14 C.F.R. 91.121 Altimeter settings.

This relief is requested since the UAS will not have a barometric altimeter; but instead a 

GPS altitude read; which will create an equivalent level of safety by confirming the altitude of 

the launch site and live flight data monitoring in feet rather than barometric pressure. 

6. 14 C.F.R. 91.151(a)(1) Fuel requirements for flights in VFR conditions.

This relief is requested to the extent required to allow flights of battery powered UAS for

approximately 20 – 30 minutes; since the battery life is 35 minutes. The technical specifications 

of the UAS and the proposed operating limitations, ensure that petitioner will safely operate the 

battery powered UAS.

7. 14 C.F.R. 91.203 (a), (b) Civil aircraft; certification required.

This relief is requested since the size of the UAS does not have the ability to carry such 

documentation. An equivalent level of safety will be achieved by keeping those documents with 

the operator and/or pilot in command on the ground.

8-11. 14 C.F.R. 91.405(a) Maintenance required, 14 C.F.R. 91.407(a)(1) Operation after 

maintenance, 14 C.F.R. 91.409(a)(1), (2) Inspections, 14 CFR417(a), (b) Maintenance Records. 
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This relief is requested since these sections only apply to aircraft with an airworthiness 

certificate. Petitioner requests relief because the UAS does not require an airworthy certificate;

since Petitioner’s UAS meets the conditions of § 333 for operation without an airworthy 

certificate. Furthermore, Petitioner will use trained technicians to perform maintenance, 

alterations, or preventative maintenance on the UAS using the methods, techniques and practices 

prescribed in the UAS operating documents. Petitioner will document and maintain all 

maintenance records. 

(d) Petitioner’s request would be in the public interest.

Petitioner is requesting an exemption to fly 4 UAS for surveys and inspections including 

but not limited to roads, buildings, bridges, roofs, meters for gas and electric, agriculture along 

with data collection of the same; and assisting local law enforcement and fire departments in 

emergency matters including but not limited to search and rescue. Petitioner’s request would be 

in the public interest, because the use of Petitioner’s UAS is a much safer, quieter and 

economical alternative to the traditional means of aerial photography, which normally would be 

an airplane or helicopter.

First, an UAS is a much safer alternative, because traditional means of aerial photography 

for surveying and inspection have required a large airplane or helicopter with flammable fuel to 

fly in close proximity of populated areas. An UAS is a much safer option based on its size and

the fact that it uses battery power instead of flammable fuel. Also, the size of the UAS allows 

for better maneuverability than traditional means. For the same reasons, the UAS is also the 

quieter option. Further, Petitioner’s UAS would allow a new perspective to their clients; since 

UAS are able to fly in areas of cities were traditional aircraft are normally not allowed, because 

of traditional aircraft size and lack of maneuverability. Lastly, Petitioner’s UAS will be a more 

efficient and cost effective alternative to the traditional means; since the UAS can fly lower to 

the ground to collect data within a grid format regarding where the UAS has searched. 

Economically the data collected will be able to help Petitioner’s clients work in a more efficient 

manner, no matter what industry. Petitioner is opening doors to all new types of information and 

data that can be collected and provided to their client. 

Similar relief has been granted in exemption nos. 11062,11109, 11112, 11213, 12645, 

and 13223.
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IV. CONCLUSION

All of Petitioner’s operations will be conducted with public safety and right to privacy 

safeguarded at all times. Petitioner will ensure safety by providing operational borders during 

flights along with the operator monitoring those borders during every flight; along with the pilot 

in command keeping a visual line of sight of the UAS within those borders. The level of safety 

for each activity would provide a level of safety greater than that provided by the rule from 

which the exemption is sought.

Petitioner respectfully requests the FAA to grant the above exemptions and whatever 

other relief they see fit.

Submitted by:

 /s/ Heidi Emmett

Attorney for Helios Visions, Inc.

Contact Information:

Emmett Law

3215 E. 1969th Road, Suite 7

Ottawa, IL 61350

815-993-0529

h.emmettlaw@gmail.com