1 

### PETITION FOR EXEMPTION

I. SUMMARY

Petitioner, Helios Visions, Inc., seeks an exemption from the requirement s 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. 91.20 3, 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 System s ( hereinaft er “ UAS ” ) for the commercial purpose of conducting aerial video photography , pursuant to Fe deral 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 activitie s include surveys an d inspections of road s , building s , bridge s , roof s , gas and electric meter s , agriculture along w ith data collection of the same . Also, assist ing local law enforcement and fire departments with emergency matters including but n ot limited to search and rescu e

. All operations wi ll be conducted with public safety and right to pr ivacy safe guarded at all times as required in 49 USC 44701. This petition for exemption is filed in accordance with 14 C.F.R. § 11.81.

I I. INTRODUCTION

Petitioner’s background includ es extensive expertise of information t echnology , including but not limited to data collection , digital marketing, web design, graphic art , photography and videography

. The three founders started Helios Visions, Inc. with th e 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 co mmand operating Petitioner’s UAS have hundreds of hours of flying experience along with their pilot’ s license

. The pilot s in command qualification flight hours and currency shall be logged in a manner consistent with 14 CFR § 61 .51(b).2 Petitioner s eeks an exemption to operate the following UAS commercially for compensation or h ire

. 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 ar e 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
ho rizontal 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 b e 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 ra nge of 1.2 miles. The Radio Frequency spectrum will comply with Federal Commu nication 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

.

• Opera ting 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.3 • Ope rating 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 dimensio ns 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
h orizontal 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 contr olled 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 Communicatio n 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 parame ters

• 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 software4 (b) Transmitter.

• Operating Fr equency: 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: 1920x1080 p @ 24/ 60 fps

• FOV: 94°/ 85°

• Sensor size: 1/2.3"

• HD Recording: 1080 p 24/ 60 fps / 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 Inspir e 1 , with a total weight of 2935 g. Under still air the maximum speed is no more than 16m/s or 35mph with a cruising speed of 1 0 m/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 frequen cy 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 governmen t 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 parameters5 • 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.

• Operat ing 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 Mob ile 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 comp ensation or hire.
Petitioner will operate a Matrice 100 , with a total weight of 2431 g or 5 lbs 3oz. Under still air the maximum speed is no more than 22 m/s or 49 mph 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
5700 mAh 6S LiPo Lithium Polymer battery. There are four propellers, Propeller Model DJI 1345, in use. The Matrice 100 will be controlled with the C 1 remote controller with an operating6 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 wi th 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) Tr ansmitter.

• 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 Touch5.7 III. BASIS FOR PETITION

(a) Name and address of the petitioner.

Helios Visions , Inc. Incorporate d 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. f rom which Helios Visions, Inc. is seek ing 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 l ightweight UAS for

com mercial use by a licensed pilot

.

1. 14 C.F.R. Part 21 Subpart H : Certification pro cedures 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) C ivil aircraft flight manual.

(b) No person m ay 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 s urface, 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 sh all 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

—8 (i) The current reported altimeter setting of a station along the route and w ithin 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 e quipped 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 c onvert 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 repo rted 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 win d 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 m inutes.
(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 t hat for at least 20 minutes.

7

. 14 C.F.R. 91.203 (a), (b) Civil aircraft; certification required.9 (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 manu al 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 cha pter. 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 identificatio n 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 ha ve 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 inopera tive 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 inspe ction; and

(d) When listed discrepancies include inoperative instrument s 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; and10 (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 c hanged 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, re building, 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 approv ed 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 authori zed 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 hi re, 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 light

sp ort or provisional airworthiness certificate;11 (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 inspec tion 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 per sonnel 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, specifyi ng 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

ex perience; (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 aircra ft; 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 spe cifications, 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 d iscontinuance. 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 all12 its components in accordance with the progressive inspection. A routine inspection of the aircraft and a detai led 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 p aragraph (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 th e 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 unde r 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 maintain ing 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 part 135 of this chapter

. (3) A current inspect ion 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 addres s 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 unde r 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 S tandards 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:13 (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 emerg ency 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 (incl uding 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 perfo rmed; 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 curr ent 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:14 (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 pre sent 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. seek s ; (c)(2) T he reason Helios Visions, Inc. seek s the relief; and (c)(3) T he 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 capabili ty, 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, P etitioner seeks the following ex emptions 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 t he size, weight, and defined area of operation s 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 O perations Manual ; along with the operation limitations pr oposed by the FAA for a higher level of safety and to further enha nce the safety of persons and property. Petitioner agree s to the following limitations under the “blanket” exemption to ensure safety :15 (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: Identifica tion and Re gistration Marking , before any commercial operations take place ;

(b ) Fli ghts will only occur in the day time 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 deteriorate s to “unsafe
for flight” by manufacturer recommendations;

(e ) The UAS weigh s less than 55 lbs. ;

(f

) Fli ghts will be operated at 4 00 feet AGl or less;

(g ) Pilot in command will hold a n airline transport, commercial, private, recreatio nal, 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 governm ent;

(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 capabilitie s to
further reduce the chance of violating someone’s privacy;16 (n ) All required FAA clearances, will be obtained and distances f rom a irports 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 wa ter the UAS will be equipped with a flotation
devise ; and

(t ) The UAS wil l 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 sma ll 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 UA S 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 t hese 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

accor dance with 14 C.F.R. Part 21, Subpart H

. Therefore, t he pilot in command before each flight will use a safety check list to p rovide an equal level of safety, and further, determine that the UAS is in a condition for safe flight.17 3

. 14 C.F.R. 91.9(b)(2) C ivil 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 a n UAS
manual with the operator and/or pilo t 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. Fina lly, all precautions in paragraph 1 w ill 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 instea d a
GPS altitude read ; which will create an equivalen t 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 req uired to allow flights of batte ry powered UAS for approximately 2 0

– 30 minutes ; since the battery life is 3 5 minutes. The technical speci fications of the UAS and the proposed operating limitations, ensure that petitioner will safely operate the battery po wered 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 b y keeping tho se doc uments 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

.18 This relie f is requested since these section s only apply to aircraft with a n 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 w ill document and maintain all
maintenance records. (d) P etitioner’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 road s , building s , bridge s , roof s , met ers 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 n ot limited to search and rescue

. Petitioner’s request would be in the public interest , because the use of P etitioner’s UAS is a much safer, qui et er and
economical alternative to the traditional means of aerial photography , which normally would be an airplane or helicopter

. First, a n UAS is a much safer alternative , because t raditional 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 ba ttery power instead of flammable fuel

. Also, t he size of the UAS a llow s for better maneuverability than traditional means. For the same reasons , the UAS is also the qui eter 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 s ize and lack of maneuverability. Lastly, Petitioner’s UAS will be a more efficient and cost effective alternative to the t raditional means ; since the UAS can fly lower to the ground to collect data within a grid format regarding w h ere the UAS has search ed

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

manner , no matter wh at industry

. Petitioner is opening doors to all new types of information and
data that ca n be collected and provided to their client. Similar relief has been granted in exemption nos. 11062,11109, 11112, 11213, 12645,
and 13223

.19 IV. CONCLUSION

All of Petitioner’s operat ions will be conducted with public s afety 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 L aw 3215 E. 1969 th Road, Suite 7 Ottawa, IL 61350 815

- 993

- 0529 h.emmettlaw@gmail.com