1

Karina D. Dodor, Esq.

35 Highland Circle

Needham, MA 02494

US DEPARTMENT OF TRANSPORTATION

1200 New Jersey Avenue

SE Room W-12-140

West Building Ground Floor

Washington, DC 20590-0001

December 30, 2014

Dear Administrator:

Enclosed please find the petition from Cambervision Inc. to the Federal Aviation 

Administration seeking an exemption from the requirements of Title 14 of the Code of 

Federal Regulations concerning the operation of an Unmanned Aircraft System for, 

commercial use and operation within the United States. The proposed exemption, if 

granted, will permit Cambervision’s commercial use of the Unmanned Aircraft System 

(“UAS”) for the purpose of research and development and aerial inspections of buildings 

and land within the United States. 

Very Truly Yours,

Karina D. Dodor Esq.

Attorney for Cambervision Inc.

35 Highland Circle

Needham, MA 02494

Tel: (617) 991-5677
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TABLE OF CONTENTS

SUMMARY FOR SEEKING EXEMPTION-------------------------------------------------- 3

COMPANY BACKGROUND------------------------------------------------------------------- 4

UNMANNED AIRCRAFT SYSTEM SPECIFICATIONS---------------------------------- 4

AIRCRAFT

GROUND CONTROL STATION 

BASIS FOR PETITION FOR EXEMPTION-------------------------------------------------- 6 

NAME AND ADDRESS OF CAMBERVISION, INC.

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH CAMBERVISION 

SEEKS EXEMPTIONS and THE EXTENT OF RELIEF CAMBERVISION,

INC. SEEKS AND THE REASON CAMBERVISION, INC. SEEKS THE 

RELIEF

REASONS IN THAT THE EXEMPTION IS IN THE PUBLIC INTEREST

A SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTRAR

ADDITONAL INFORMATION, VIEWS OR ARGUMENTS AVAILABLE 

TO SUPPORT THE REQUEST FOR AN EXEMPTION FOR 

CAMBERVISION, INC.

PRIVACY ISSUES DO NOT ARISE AT THE GRANT OF THE 

EXEMPTION------------------------------------------------------------------------------------- 19

CONCLUSION----------------------------------------------------------------------------------- 19

GLOSSARY/ABBREVIATIONS------------------------------------------------------------- 20
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SUMMARY FOR SEEKING EXEMPTION

CAMBERVISION, INC. (“Cambervision”), a Massachusetts Corporation, seeks 

an exemption from the requirements of Title 14 of the Code of Federal Regulations in 

particular an exemption from the following sections:

Part 21

14 C.F.R. §45.23(b) 

14 C.F.R. §61.113 (a) and (b)

14 C.F.R. §91.7(a)

14 C.F.R. §91.9(b) (2)

14 C.F.R. §91.103

14 C.F.R. §91.109(a)

14 C.F.R. §91.119(b)

14 C.F.R. §91.121

14 C.F.R. §91.151(a) (1)

14 C.F.R. §91.203(a) and (b)

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a) (1)

14 C.F.R. §91.409(a) (2)

14 C.F.R. §91.417(a) and (b)

Cambervision seeks commercially fly an Unmanned Aircraft System (UAS)

within the United States. The propose UAS is a small quadrocopter no more than 20 

pounds fully loaded with equipment to be flown at no more than 400 feet above ground 

level (“AGL”) and not within 5 miles of an airport. The exemption will have a positive 

impact on the public interest by providing services that are not available to the general 

public but are in high demand by both private and municipal parties. The exemption in 

particular will allow Cambervision to offer a spectrum of services using the UAS 

including community training workshops on the proper use and operation of UASs to 
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ensure safe operation by hobbyists and commercial users as well as to provide innovative 

and economically beneficial options of building/site inspections. 

The Petitioner is dedicated to following the conditions and limitations as imposed 

by the FAA regarding the flight of the UAS and including but not limited to avoid and 

yield right-of-way to all manned operations, file necessary notices and flight plans as well 

as adhere to the city and state imposed regulations to ensure the utmost safety for the 

general public and the operators. 

COMPANY BACKGROUND

CAMBERVISION, INC. is a Massachusetts Corporation with a primary place of 

Business in Needham, MA. Founded by two entrepreneurs with a background in aviation 

and a strong interest and desire to bring innovative services to the public using an UAS 

that are more practical, economical and useful than other avenues. One of the founders 

has an extensive background with commercial and government aviation as well as a 

Mechanic’s certificate from the Federal Aviation Administration issued for Airframe and 

Powerplant Mechanics. 

The company is interested in performing Research and Development for a unique 

platform of services to be utilized commercially by a variety of professionals from 

architects, builders, real estate companies and property managers to municipal service 

departments and first responders. 

Cambervision is dedicated to offering innovative and customized services to 

consumers using the UAS to better serve the community and the public interest by 

providing a safer alternative to current practices of building inspection and other services 

as well as by providing training workshops for UAS enthusiasts and commercial entities 

to ensure safer operations of the UAS in the National Airspace System (“NAS”). 

UNMANNED AIRCRAFT SYSTEM SPECIFICATIONS

I. AIRCRAFT: DJI

Cambervision seeks an exemption to operate a DJI, Model Phantom 2, version 2 

(“DJI”) for commercial use within the NAS. 
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The DJI is an X shaped quadrocopter equipped with an on-board flight computer with

constant communication with the ground station transmitting live data regarding speed, 

compass direction of flight, and altitude levels amongst its in-flight data. The UAS 

contains a Global Positioning System (“GPS”) tracking device and an on-board camera 

capable of capturing full color, high definition still photos and video. The UAS is also 

equipped with four sets of LED ‘status-lights’ which providing not only an enhanced 

visual from the ground but assisting the Pilot in Command (“PIC”) to confirm battery, 

GPS and other functionalities of the UAS based on the color and status of the lights..

a. Specifications

Figure 1: The DJI Phantom, Model 2, version 2.

II. GROUND CONTROL STATION

The ground control (“GCS”) station is the primary takeoff and landing point of the 

UAS and includes a setup, consisting of people and equipment, to promote the outmost 

safety for all persons involved in the operation including the operators, general public, 

and any objects or persons that may come into contact with the zone of operation 

(“Zone”). Specifically the ground station includes:

a. Pilot in Command: A designated pilot with a private pilot’s license, a current 

third-class medical certificate and a deep knowledge and thorough understanding 

of the UAS and its operation as well as numerous hours of experience in operating 

General Description A battery operated lightweight rotorcraft 

with additional onboard equipment and a 

separate ground station used for operation.

Weight (including battery) Approximately 2.2 lbs.

Flight path Vertical takeoff and landing

Hovering Accuracy (Ready to Fly) Vertical: 0.8m/ Horizontal: 2.5 m

Max. Ascent/Max. Descent Speed Ascent: 6m/s; Descent: 2m/s

Max. Flight Speed 15m/s

Number of copter blades Four

Color White with red and green stripes
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the DJI. PIC will operate the UAS within visual line of sight (VLOS) at all times 

using human vision unaided by any device other than corrective lenses. 

b. Flight Coordinator/Visual Observer (“FC”): A second person, other than the 

PIC, with a visual of the UAS at all times and the ability and knowledgeable to 

assist the PIC as needed including verbal as well as physical command of the 

controls. The UAS will always be within the VLOS of the FC. The PIC and the 

FC will have the ability to communicate verbally at all times. 

c. Equipment: 

a. A 100mW, 2.4GHz radio transmitter/controller operated by the PIC.

b. A portable receiver receiving transmitted live video and flight data from 

the UAS onboard camera and computer. This data is projected onto the 

controller used by the PIC to monitor during the flight.

d. Zone: a designated area cordoned off by brightly colored cones to put the 

surrounding public on notice of the operation. One sandwich board with the name 

of the company, contact information, and description of the operation in order to 

alert the general public of the event taking place and allowing anyone interested 

to contact Cambervision with questions.

e. Paperwork: The ground station will also include a designated area for the a copy 

of the pilot’s license, Operator’s Manual for the DJI (“Manual”) as amended with 

conditions or limitations scripted by the FAA, copy of the granted exemption, 

pursuant to the grant of this exemption by the FAA, copy of the insurance 

certificate, business cards and any other relevant paper work for the specific 

event. 

f. Other: Anything else that is required in order to be in full compliance with the 

regulations of the City and State where the event is taking place. 

BASIS FOR PETITION FOR EXEMPTION

Pursuant to the authority granted to the FAA under Federal Aviation Regulations, 

14 C.F.R. § 11.61(b) and the FAA Modernization and Reform Act of 2012, Section 333, 

Special Rules for Certain Unmanned Aircraft Systems, Cambervision respectfully 

requests to grant its petition for an exemption from the requirements of 14 C.F.R Part 21; 

14 C.F.R. §61.113 (a) and (b); 14 C.F.R. §91.7(a); 14 C.F.R. §91.9(b)(2); 14 C.F.R. 

§91.103; 14 C.F.R. §91.109; 14 C.F.R. §91.119; 14 C.F.R. §91.121; 14 C.F.R. 

§91.151(a); 14 C.F.R. §91.203(a) and (b); 14 C.F.R. §91.405(a); 14 C.F.R. §91.407(a)(1); 

14 C.F.R. §91.409(a)(2); and 14 C.F.R. §91.417(a) and (b). 

A. Name and Address of Petitioner: 

Cambervision, Inc. 

35 Highland Circle

Needham, MA 02494
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B. Specific Sections of 14 C.F.R. From Which Cambervision Seeks 

Exemptions and the Extent of Relief Cambervision Seeks; The Reason 

Cambervision Seeks The Relief and Reasons why the Exemptions 

Would not Affect Public Safety

1. Cambervision seeks an exemption from 14. C.F.R. Part 21

14 C.F.R. Part 21- Airworthiness Certificate

14 C.F.R. Part 21 along with 14 C.F.R. §91.203(a) (1) establishes the necessary 

procedures in order to obtain an airworthiness certificate for a manned aircraft. The 

general purpose of an airworthiness certificate for an aircraft is to ensure the aircraft’s 

safe functionality, good working order and to ensure the safety of those onboard as well 

as anyone in proximity to the aircraft at any time. The Federal Aviation Act, 49 U.S.C. 

§44701(f) and Section 333 of the Reform Act statutorily authorize the FAA to issue an 

exemption from the airworthiness requirements upon consideration of the aircraft’s size, 

weight, speed and operational capability. Such considerations should be applied to 

Petitioner’s UAS in determining that Cambervision should be exempt from the 

airworthiness requirement for its UAS.

The UAS to be operated by Cambervision is less than 55 lbs. fully loaded 

(inclusive of additional equipment such as GPS tracker, camera, etc.) and does not carry a 

pilot or passengers. Furthermore, the UAS does not contain explosives, fuel or any other 

flammable materials. The operation of the UAS will be strictly confined to a designated 

area and under full control of the PIC and FC. 

Safety Standard: The UAS is equipped with several safety features, which will 

further serve as a reason to exempt it from an airworthiness certificate. The UAS is 

equipped with a “Fail-Safe Feature which allows it to self-correct a failure that is beyond 

control of the PIC. Once a “Failure” is detected the UAS’s automatic safety feature is 

triggered which prompts it to return to its GPS point of origin of takeoff. This along with 

the other safety features such as a proposed parachute (in early stages of development)

provide an enhanced safety feature to the operator and the general public compared to 

manned aircraft that hold an airworthiness certificate and are used to perform the tasks 

proposed to be performed by the UAS.

Cambervision would like to refer to Exemptions No.11062 and11067 in which the 

FAA previously determined that based on the [Petitioner’s] UAS “limited size, weight, 

operating conditions, design safety features and the imposed conditions and limitations 

... the [Petitioner] has demonstrated that the operations would not adversely affect safety 

compared to similar operations conducted with aircraft that have been issued an 

airworthiness certificate under 14 C.F.R. Part 21, Subpart H”. 

In the alternative Petitioner respectfully requests that the Administrator finds that 

the exemption from 14 C.F.R. Part 21 is not necessary because the regulation is not 

applicable to the UAS to be used by the Petitioner. 
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2. Cambervision seeks an exemption from 14 C.F.R. §45. 23(b) 

14 C. F. R. §45.23(b) - Display of Marks; General

(b) When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near 

each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches 

nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” 

“experimental,” or “provisional,” as applicable.

Provided that the exemption from Part 21 is granted and the UAS will not need an 

airworthiness certificate, Petitioner seeks an exemption from the requirement that the 

word “EXPERIMENTAL” be displayed on the DJI near each entrance to the cabin, 

cockpit or pilot station. The DJI Phantom is a small UAS and subsequently does not have 

a cabin, cockpit, pilot station or any other type of entrance. The size of the UAS does not 

permit any markings to be above one inch (1”) in height and be longer than eight inches 

(8”). 

Safety Standard: In order to achieve an equivalent level of safety and to most 

closely comply with the FAA regulations, Cambervision proposes to display the word

“EXPERIMENTAL” on top of the UAS with the dimensions of the signage being one 

inch by eight inches (1”x8”) in compliance with 14 F.C.R. §45.29 (f) (See Figure 2 

below). This type of signage will allow the PIC, FC and others in close proximity to see 

the designation of the UAS. 

Figure 2: The DJI Phantom with the proposed wording on top.

The FAA should grant Cambervision the exemption from the regulation regarding 

the requirement for signage. As the FAA decided in Exemptions No. 11062 and 11067 

that an exemption from such requirements is warranted given that the aircraft obtains an 

N-number in accord with 14 C.F.R. Part 47, have identification (N-markings) in accord 

with 14 C.F.R. 45, Subpart C. and the markings must be as large as practicable the FAA 

Administrator should decide similarly in this instance. Cambervision will display 
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markings as large as practicable on the top of the UAS in the interest of safety and

compliance. See also Exemptions Nos. 10700, 8738, 10167, and 10167A.

3. Cambervision seeks an exemption from 14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §61.113- Private pilot privileges and limitations: Pilot in command.

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

holds a private pilot certificate may act as pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, 

for compensation or hire, act as pilot in command of an aircraft.

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

aircraft in connection with any business or employment if:

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

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

Cambervision seeks an exemption from the restriction outlined in parts (a) and (b) of 

the regulation prohibiting a holder of a private pilot’s certificate to act as a pilot for an 

aircraft carrying property for compensation or hire. The UAS to be used by 

Cambervision will be used for commercial operation for compensation or for hire, 

however, will not be carrying any passengers or cargo allowing Cambervision to achieve 

the same level of safety of current operations by requiring the PIC to obtain a private 

pilot’s license instead of a commercial pilot license. Unlike an aircraft that carries cargo 

or passengers, the UAS is remote controlled by an experienced PIC. 

Safety Standard: Pursuant to obtaining a grant of the exemption to operate the UAS 

for compensation, Cambervision will ensure that the PIC holds a private pilot’s license, 

has a significant number of flying hours and follows the instructions as set forth in the 

Manual for the UAS. Since there are no persons on board and the UAS will be operated

within the safety procedures outlined by the FAA regulations, the operation of the UAS

by remote control with a private pilot’s license by the PIC will exceed the present level of 

safety meant to be achieved by the requirements of 14 C.F.R. §61.113 (a) and (b). 

As the FAA Administrator previously outlined in Exemption Nos. 11062 and 11067 

“[a]nother consideration supporting the certificate requirement is that pilots holding a 

private pilot certificate are subject to security screening by the Department of Homeland 

Security” and this type of screening should overrule “security concerns over the UAS 

operations” that would be granted under this exemption. Additionally as the FAA 

concluded in the analysis of the areas of knowledge specified in 14 C.F.R. part 61 for that 

of a commercial pilot versus a private pilot, the results show that “the required areas of 

knowledge for a commercial versus private pilot cover the same fundamental principles”. 

Granting Cambervision the exemption based on the safety outlines and requirements 

outlined by the FAA and the experience and expertise of the PIC, would not adversely 

affect the safety of the NAS. 

Cambervision would like to refer to Exemptions No.11062 and11067 in which the 

FAA previously determined that a commercial pilot’s license is not required to operate an 

UAS.
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4. Cambervision seeks an exemption from 14 C.F.R. §91.7(a)

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.

Cambervision requests an exemption from the regulation, pursuant to 

Cambervision obtaining of an exemption to 14 C.F.R. Part 21, there will be no 

airworthiness certificate issued for the UAS and consequently a standard for 

airworthiness is not applicable. 

Safety Standard: Cambervision’ s compliance with an established pre-flight 

safety checklist, standard of operation as described in the Manual and outlined in the 

maintenance requirements prior to each flight ensures that an equivalent level of safety 

will be provided during all times of operation . The PIC will be in compliance with the 

requirements of 14 C.F.R. §91.7(b) when determining whether the aircraft is in a 

condition for safe flight. 

As the FAA determined in Exemption Nos. 11062 and 11067 that a requirement 

of airworthiness does not need to be met if a certificate of airworthiness is not required, 

the FAA should determine similarly in favor of Cambervision that if they are granted the 

exemption from a certificate of airworthiness, the provision of 14 C.F.R. §91.7(a) and (b) 

is not necessary.

5. Cambervision seeks an exemption from 14 C.F.R. §91.9(b)(2)

14 C.F.R. §91.9(b) (2) - Civil Aircraft Manual Requirements

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.

Cambervision seeks an exemption from maintaining a flight manual aboard the 

UAS. 

Safety Standard: Given the size and design of the UAS it is not possible to carry 

the manual onboard during operation. To ensure full compliance with safety requirements 

the manual will be available at the ground station and immediately accessible by the PIC 

and FC at all times during operation. 

Petitioner would like to refer to Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 

9565, 9565B, 10167, 10167A, 10602, 32827, 10700 and 11067 where the Administrator 

issued a similar exemption as requested here. In the alternative, Petitioner requests that 

the Administrator finds that the exemption is not necessary based on the FAA 
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Memorandum subject “Interpretation regarding whether certain required documents may 

be kept at an unmanned aircraft’s control station” dated August 8, 2014. 

6. Cambervision seeks an exemption from 14 C.F.R. §91.103

14 C.F.R. §91.103- Preflight Action

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

available information concerning that flight. This information must include—

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

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

completed, and any known traffic delays of which the pilot in command has been advised 

by ATC;

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

and landing distance information:

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

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

data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, 

other reliable information appropriate to the aircraft, relating to aircraft performance 

under expected values of airport elevation and runway slope, aircraft gross weight, and 

wind and temperature.

Cambervision seeks an exemption from the Preflight Action requirements as 

prescribed in 14 C.F.R. §91.103 which requires the PIC to take certain actions before 

flights to ensure safety. 

Safety Standard: The PIC will be familiar with all of the manual requirements 

and recommendations as well as perform a “Cross-Check Quadrant TM “a customized preflight check list of actions to be performed prior to operation of the UAS. Combined, the 

PIC will take actions such as inspection of the UAS, the weather elements, and physical

inspection of the area of operation and aircraft performance data prior to the initiation of 

every single flight. The Operator’s Manual and Operational limitations will be kept at the 

ground station within reach of the PIC at all times. The information collected at the time 

of the pre-flight check will be compiled into a report and kept in Petitioner’s office for 

record keeping. The pre-flight procedures will allow an equivalent if not higher level of 

safety to be reached. The PIC will also take into account visibility and distance from 

clouds as well as sun glare and the ability to see other traffic when conducting the preflight inspections. 

In the alternative Petitioner requests the Administrator to find that the exemption 

is not necessary, as the FAA administrator found in Exemption Nos. 11062 and 11067, 

that with conditions and limitations the exemption is not necessary. 
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7. Cambervision seeks an exemption from 14 C.F.R. §91.109(a)

14 C.F.R. §91.109(a) - Flight Instruction

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

used for flight instruction unless that aircraft has fully functional dual controls...

Petitioner requests an exemption from the regulation because the UAS and other 

remotely piloted aircraft, by design, do not have functional dual controls. Flight control 

of the UAS is accomplished by the PIC’s use of a control box which communicates with 

the aircraft via radio signal communication. 

Safety Standard: Since the UAS is not carrying a pilot or passengers the 

equivalent level of safety will be achieved with the remote control of the UAS and 

without dual controls. The PIC is in full control of the UAS at all times. Because the

flight will be performed in a cordoned off area, any trouble that the UAS might 

experience will be rectified in a safe manner by the PIC and the FC without any 

interference or danger to the public. 

Petitioner would like to refer Exemption Nos. 11062 and 11067 where the 

Administrator found that UAS may be operated without dual controls. See also 5778K 

and 9862A. 

In the alternative the Petitioner would like to request the Administrator to 

determine that the 14 C.F.R. §91.109(a) regulation is not applicable to Cambervision 

since Cambervision does not plan to use the UAS in an environment where dual controls 

are necessary such as instrument flight instruction and the PIC will be the only controller

in operation of the UAS at all times. 

8. Cambervision seeks an exemption from 14 C.F.R. §91.119(b)

14 C.F.R. §91.119(b) - Minimum Safe Altitudes: General

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

the following altitudes:

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

over any open air assembly of persons, an altitude of 1,000 feet above the highest 

obstacle within a horizontal radius of 2,000 feet of the aircraft.

Cambervision seeks an exemption from the requirement of a subsection (b) and relies 

on subsection (d) for an exemption. Subsection (d) permits the operation of a helicopter 

at less than the prescribed minimums, given that the operator is in compliance with any 

route or altitudes prescribed for helicopters by the FAA. 

Cambervision requests an exemption to operate the UAS at 400 feet AGL. Except

for the limited conditions stated in the Manual the UAS will not operate above 400 feet 

AGL. The equivalent level of safety will be achieved provided the size, weight and 

speed of the UAS. 
13

Safety Standard: Cambervision’s operation will provide at least an equivalent 

level of safety if not higher at 400 feet AGL to those in relation to the minimum safe 

altitudes as outlined in regulation 91.119. Most civil airplanes operate at 500 feet AGL 

or above therefore the operation of the UAS by petitioner will not be in direct 

interference with manned aircraft in the NAS. 1 The operation of the UAS will be in a 

cordoned off area with security perimeters set up by the PIC. All property owners and 

abutters who may be affected will receive advanced notice of the operation and the 

propose flight operations as set forth in Section K of the Manual. The PIC will be in the 

ground control station equipped with the set up as described in detail above in the 

“Unmanned Aircraft Specifications”. Cambervision will ensure a “safe zone” around the 

area of PIC operation as large as is allowable in an urban setting. At all times anyone 

interested in the operation criteria of the UAS can contact Petitioner to obtain the 

necessary information. 

Cambervision plans to design and equip a parachute landing system for the UAS 

in order to ensure a high level of safety for those involved and around the operational 

area. The UAS is equipped with an automatic system that detects “trouble” such as low 

battery or connection loss and automatically triggers the UAS to land safely back at its 

point of lift off based on the GPS coordinates of the take off. 

Compared to flight operations with aircraft or rotorcraft weighing far more than 

the UAS proposed to be used by Cambervision and lack of flammable fuel and a pilot or 

passengers on board any risk associated with these operations is far less as compared 

manned aircraft operated in accord with the minimum altitude requirements as outline in 

the regulation. 

9. Cambervision seeks an exemption from 14 C.F.R. §91.121

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—

...

Cambervision requests an exemption from the Altimeter Settings requirement 

because the UAS does not have a barometric altimeter, but is instead equipped with a 

GPS altitude reading device. 

Safety Standard: With an exemption from the regulation, an equivalent level of 

safety will be achieved by the operator, pursuant to the Manual and pre-flight check lists 

and by confirming the altitude of the launch site as shown on the GPS altitude indicator 

before flight. To ensure that the exemption from the regulation does not adversely affect 

safety the petitioner proposes to operate the UAS at or below 400 feet AGL, provide 

altitude information to the PIC via a digitally encoded telemetric data feed, which 

downlinks from the ground-base on-screen display. Prior to each flight, a zero altitude 

 

1 Dershowitz, Adam Dr. , PhD., P.E. , CFEI, “UAS Safety Analysis Exponent Project”, 

December 2014, page 4. 
14

initiation point will be established and confirmed for accuracy buy the UAS PIC and the 

altitude information will be generated by equipment installed onboard the aircraft, as 

specified using GPS triangulation. 

Petitioner would like to refer to Exemption Nos. 11062 and 11067 where the 

Administrator found that UAS is permitted to be operated with a digitally encoded 

telemetric data feed instead of an onboard barometric altimeter. See also Exemption Nos. 

5778K and 9862A.

10. Cambervision seeks an exemption from 14 C.F.R. §91.151(a)(1)

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

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

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

intended landing and, assuming normal cruising speed—

Cambervision seeks an exemption from the fuel requirement regulation because 

the Battery Life of the UAS, as outlined in the Operating Manual, is 25 minutes when 

flown without additional equipment and 15 minutes fully loaded with a camera and GPS 

tracking unit. The UAS battery life does not fit within the requirement of (a) (1) and 

Cambervision is not planning on flying the UAS in the nighttime, 

Safety Standard: Cambervision proposes to limit the flight to 10 minutes total 

time after takeoff. Petitioner believes that an equivalent level of safety will be achieved 

by limiting flights to 10 minutes or 25% of battery power, which ever happens first which 

is well within the limits of the Manual. This proposed restriction will allow an adequate 

amount of time for the UAS to return to its intended landing zone during the operation. 

As the FAA granted relief for manned aircraft to operate at less than the 

minimums prescribed in 14 C.F.R. §91.151(a)(1) the FAA should grant a similar 

exemption to Petitioner in that the UAS can operate 10 minute flights or within 25% of 

battery life reserve. See similar rulings in Exemption Nos. 2689, 5745, 10650, 11062 and

11067. See also similar UAS-specific relief granted in Exemption Nos. 8811, 10808, and

10673 for daytime, Visual Flight Rules (VFR) conditions. 

11. Cambervision seeks an exemption from 14 C.F.R. §91.203(a) and (b)

14 C.F.R. §91.203(a) and (b)-Civil Aircraft: Certifications Required

(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 
15

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.

Cambervision requests an exemption from sections (a) and (b) of the regulation 

because the Administrator grants the earlier requested exemption from Chapter 14 Part 21 

the UAS will not be required to obtain an airworthiness certificate. Additionally the UAS 

is less than 55 lbs. when fully loaded and does not contain an onboard pilot therefore 

there is no ability or place to carry the certification and registration documents as 

prescribed. 

Safety Standard: Cambervision proposes to achieve the equivalent level of safety 

that is premised by the regulation by keeping the necessary and required documents at the 

ground control station within immediate reach by the PIC at all times and will be made 

available to the Administrator and law enforcement immediately upon request. 

For similar exemptions to this regulation granted by the FAA see Exemption Nos. 

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 10700, 11062 and 11067. In the 

alternative, Petitioner requests that the Administrator finds that the exemption is not 

necessary based on the FAA Memorandum subject “Interpretation regarding whether 

certain required documents may be kept at an unmanned aircraft’s control station” dated 

August 8, 2014. 

12. Cambervision seeks an exemption from 14 C.F.R. §91.405(a), 91.407(a)(1), 

91.409(a)(2) and 91.417(a) and (b)

14 C.F.R. §91.405(a), 91.407(a) (1), 91.409(a) (2) and 91.417(a) and (b) - Maintenance 

Exceptions

Cambervision seeks an exemption from the above outlined regulations governing 

the maintenance requirements, because these section along with Part 43 apply only to 

aircraft with an airworthiness certificate, which if the petition is granted by the 

Administrator, will not apply to the Petitioner

Safety Standard: With the grant of the exemption, an equivalent or higher level of 

safety will be achieved during the operation of the UAS. The Petitioner will inspect the 

UAS regularly and address all mechanical issues immediately. The PIC will ensure that 
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the UAS is in proper working order prior to every flight, perform required maintenance 

and keep a record log of any maintenance issues and their respective resolutions. In the 

instance that the UAS is dormant for a prolonged period of time, the operator will inspect 

the UAS bi-weekly to ensure its working order. All maintenance and inspections will be 

performed in accordance with the Operator’s Manual and flights will not be conducted 

until the Cross-Check Quadron TM is performed prior to each flight. 

C. Reasons Why the Exemption Would Not Adversely Affect Public

Safety And How the Exemption Would Provide a Level of Safety 

at least Equal to The Existing Rule

Taking into consideration the safety standards outlined above granting 

Cambervision an exemption to permit commercial operation of the UAS will not 

adversely affect public safety and would provide a level of safety at least equal to the 

existing rule and in several cases provide a higher level of safety. The UAS is a battery 

operated unmanned aircraft with no flammable fuel, pilot or passengers on board and 

operated by an operator with at least a private pilot’s license. The UAS will in several 

instances replace a manned aircraft hired to perform the same task or serve as an 

alternative to using persons climbing to high elevations and eliminating the risk of 

incident of injury or fall. 

The UAS will be operated by an experienced PIC who will be in full control of 

the UAS at all times with a FC who will provide another visual and keep the UAS in a 

VLOS at all times. . PIC will have access to all necessary up to date equipment, 

machinery and mechanicals necessary for the proper and airworthy operation of the UAS. 

Furthermore, Cambervision will carry liability insurance for the operation of the UAS in 

excess of $1,000,000 and provide the insurance certificates upon request. Cambervision 

proposes to operate the UAS with the utmost diligence, care and responsibility as 

outlined in the exemptions, regulations and additional restrictions and guidelines as 

proposed by the FAA. 

With following the safety provisions as outlined in the Manual and being in strict 

compliance with FAA regulations, restrictions and conditions the operation of the UAS 

will not adversely affect public safety and the exemption will provide a level of safety at 

a level greater than the existing rule by providing alternative ways to inspect areas of 

high elevation instead of using physical man power to do so, thus preventing injuries and 

other hazards. 

D. The Exemption is in the Public Interest

Granting Cambervision’s request for a petition for the exemption from the 

regulations outlined above will further the public interest by allowing Cambervision to 

provide commercial services and thus expanding the stream of commerce. Providing such 

services the public holds many benefits because these options are much more economical 

and safer than current available options, create safe and useful options for first responders 

to use in emergency situations and allows Cambervision to conduct research and 

development for other uses of the UAS with future hopes of providing a positive 
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economic impact on the community as a whole while not implicating privacy and 

ensuring all equivalent safety levels and standards. 

Cambervision proposes to use the UAS system to perform citywide, implemented 

by the City of Boston, mandatory building inspections providing a more economical and 

safe alternative than the current inspection method in place. These inspections are 

applicable to low and high rise buildings as well as all appurtenant building parts. 

Currently the inspections are performed by a visual evaluation through a telescope on the 

ground or a physical escalation of the building itself. Cambervision will provide a service 

to inspect the buildings using the UAS operated by a licensed PIC adhering to all 

applicable FAA regulations as outlined by the Administrator as well as the 

recommendations set forth in the Manual. Use of the UAS will ensure a higher level of 

safety for the public and provide more accurate reporting including areas of the building 

such as overhangs and awnings which are not easily accessible.

This exemption will also further the public interest by providing the option of 

having access to aerial photography and videography. The use of the UAS will provide 

government and private reporting agencies, real estate and development firms as well as 

architects the option to use a UAS to obtain aerial views, replacing the use of a manned 

aircraft. Use of the UAS is both more economical and safer and decreases congestion of 

the NAS. The use of the UAS versus a manned aircraft will also create a reduction in 

noise and air pollution, an increase in safety and a better economic alternative for the 

public.

Finally, the public will benefit from the use of the UAS by Cambervision because 

Cambervision proposes to perform research and development for other uses of the UAS 

which although not yet fully developed are proposed to benefit the first responders by 

using the UAS to investigate areas of high activity and danger zones creating a safer 

alternative than utilizing a person to perform the same investigation. The possibility of 

UAS utilization creates a safer, economical and indispensable alternative to current 

options. 

The enhanced safety achieved by using a UAS with a licensed PIC and the added 

safety gear to be used strictly in compliance with the uses outlined above while carrying 

no passengers or crew is in the public interest to replace the use of a manned aircraft of 

significantly greater proportions , carrying crew and flammable fuel. This use provides an 

alternative use with more accuracy and a higher level of safety 

E. A Summary to be Published in the Federal Registrar

Applicant, Cambervision Inc., seeks an exemption from the following regulations 

Part 21; 14 C.F.R. §45.23(b); 14 C.F.R. §61.113 (a) and (b); 14 C.F.R. §91.7(a); 14 

C.F.R. §91.9(b)(2);14 C.F.R. §91.103; 14 C.F.R. §91.109(a); 14 C.F.R. §91.119(b);14 

C.F.R. §91.121; 14 C.F.R. §91.151(a)(1); 14 C.F.R. §91.203(a) and (b); 14 C.F.R. 

§91.405(a); 14 C.F.R. §91.407(a)(1); 14 C.F.R. §91.409(a)(2); 14 C.F.R. §91.417(a) and 

(b), as established by the FAA, in order to commercially operate an unmanned aerial 

system weighing less than 20 lbs. and operating at a maximum altitude of 400 feet AGL 

for aerial imagery and research and development for other commercial uses including but 

not limited to building inspections. 
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The grant of the exemption allowing for commercial operation will maintain an 

equivalent if not higher level of safety than the one proposed by the FAA regulations, 

benefit the public interest and create a positive impact on the stream of commerce. 

Currently, the only way to obtain aerial imagery is to employ a manned aircraft system 

which often weights more than 4,000lbs, carries a pilot and flammable fuel and requires a 

designed large area landing pad or airport in order to get into the air. The other option to 

obtain aerial imagery is to physically scale a building in order to achieve a higher altitude

for the imagery needed. The UAS, which is powered by battery and remote operated from 

a ground control station, provides a much safer and easier alternative eliminating

eliminate most of the risk associated with accidents of a manned aircraft or injuries and 

accidents of climbing heights.

The operation of the UAS conducted with strict accord of the FAA regulations 

and within the conditions outlined above will provide an equivalent if not higher level of 

safety supporting the grant of the exemption request by Cambervision, including the 

exemption from the requirements of Part 21 and allowing commercial operations. 

F. Additional Information, Views or Arguments Available 

to Support the Request For an Exemption For CAMBERVISION, 

INC.

A recent “UAS Safety Analysis Exponent Project” conducted by Dr. Adam 

Dershowitz , PhD., P.E. , CFEI, a managing Engineer in Exponent’s Thermal Science 

practice, at the request of UAS America Fund , LLC and Kramer Levin Naftalis and 

Frankel, LLP concludes “that there is no significant added risk to other airspace users 

posed by this type of commercial drone operation” that is proposed to be used by 

Cambervision. 

The study is based on an analysis of 25 years of safety data involving small and 

medium sized birds, representing a simulated drone flight, and the rate of collisions with 

manned aircrafts. The study further concludes that using the proposed regulations of a 

maximum altitude of 400 feet AGL and a radius of 5 miles from airports there is no 

indication of imposed significant risk in allowing the operation of small UAS at or below 

400 feet AGL and at least 5 miles or further from airports.

Cambervision further requests that the FAA recommend special condition, 

limitations and guidelines for the operation of the DJI, which contain safety standards 

that the Administrator finds necessary to establish a level of safety equivalent to the level

established by Chapter 14 and the applicable subsections. 

NO PRIVACY ISSUES ARISE AT THE GRANT OF THE EXEMPTION

If Cambervision is granted an exemption there are no privacy issues with regard

to the operation of the UAS. Any privacy concerns, which might arise, can be alleviated 

by providing advanced notice to the possible affected persons. 

The UAS will be operated at the request of a client. At the inception of the 

agreement Cambervision will provide the client a Notice at least a few days in advance 
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outlining the operation which the client will need to distribute to foreseeable person that 

might be affected. This advanced notice will permit the client to field any concerns that 

might arise ahead of time and if necessary allow possible affected persons to vacate the 

area for the time of the flight operation. 

This type of action is no different than if a building inspection is done manually 

by an “inspector” positioning themselves on the fire escape with the same access to the 

window of a person’s apartment. 

Once the UAS is ready for takeoff, the ground station will be clearly marked with 

orange cones and a good sized sign noting the exact procedure in place and creating a 

chance for people to avoid the area if they do not wish to be caught on the film. This type 

of procedure can be equated with a movie production in a public area where people are 

notified in the same manner in order to have the option to avoid the area altogether. 

When the UAS is rising up into its flight the main focus of the camera is the 

building itself, if there are faces of persons who did not provide consent to be filmed 

which are caught in the frame, following proper protocol Cambervision will use 

specifically designated software to blur out the faces before turning the finished product 

over to the client whether it is an architect who will further use the video to generate an 

analysis report or submit it over to their respective client. 

CONCLUSION

For the reasons outlined above and with authority granted to the FAA by 14 

C.F.R. §11.61 and Section 333 of the FAA Modernization and Reform Act of 2012, 

Cambervision requests and Exemption to commercially operate the UAS, DJI Phantom, 

without an airworthiness certificate for experimental uses. The grant of this exemption 

will advance the public interest, provide an economic benefit to the public and allow 

Cambervision to develop new and innovative uses for UASs in a safe and compliant 

manner. 
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GLOSSARY /ABBREVIATIONS

UAS- Unmanned Aerial System

PIC- Pilot in Command

FC-Flight Coordinator

VC-Visual Controller

GPS- Global Positioning System

VLOS- Visual Line of Sight