Pursuant to 14CFR § 11.87

January 9, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave.

SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11

of the Federal Aviation Regulations from 14 C.F.R.

45.23(b); 14 CFR Part 21:14 CFR 61.113(a) & (b); 91.7(a): 91.9(b)

(2): 91.103(b): 91.109.119; 91.121; 91.151(a); 91.203(a) & (b)

91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a) & (b)

Dear Sir or Madam:

Pursuant of Section 333 of the FAA Modemization and Reform Act of 2012 (the Reform Act) and 14

C.F.R. Part 11, Multi-View Aerials, builder and operator of Small Unmanned Aircraft Systems (UASs”) equipped

to conduct, once granted would allow the petitioner to operate a small unmanned aerial vehicle (UAVs), to conduct bridge Inspections, flare stack inspections, utility-power generation system inspections, aerial inspection, photography and videography of residential and commercial real estate, aerial inspection, photography and videography of

utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline

inspection and patrolling, filmmaking, cinematography, and videography, aerial surveying, construction site

inspection and monitoring, public entity support operations, Aerial imaging for safety, monitoring and comparing

work efforts and completion percentages, and security of controlled environment of various sites, aerial video and

live video feed to assist with search and rescue and support operations under the authority and support of local

authority officials, motion picture production3, closed set filming4, disaster and catastrophe events, aerial video

and photography, and training to persons individually or belonging to both private and public organizations to

increase awareness and improve safety for current and future UAS operations within the NAS.

The name and address of the applicant is:

Multi-View Aerials (MVA)

Attn. Michael L. Massar

Address: 455 County Road 437

Thrall, Texas 76578

Ph. (512) 898-2034

Cell: (512) 517-2875

Email: mmassar64@gmail.com

Unmanned Aircraft System

Multi-View Aerials seeks exemption to operate small sUAS. Other sUAS types may be requested in future

amendments. The aircraft in our operation for which we seek exemption is VUL 1100 X-8, VUL 900 X8, VUL

900 Hexacopter and DJI Inspire 1 & Inspire 1 Pro. The UAV will be flown via a combination of RC control and

tablet GCS. This UAV type is a GPS equipped, multirotor helicopter. VUL 1100 & VUL 900 are X-8 quad-copter

type rotorcraft utilizing (8) eight motors, VUL 900 Hexacopter utilizing six (6) motors and the DJI Inspire 1 and

Inspire 1 Pro quad-copter utilizing four (4) motors . All platforms use Lithium-polymer batteries to power the

UAVs. All these crafts have GPS and full telemetry and redundancy for safe and reliable operation.

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 UASs operated by MVA weigh less than 55 pounds, including all payload. They operate at speeds of less than

45 knots, can hover, and can simultaneously move in multiple directions. MVA will only operate its UASs in line

of site and will operate only in sterile environment described in the FOPM. Such operations will ensure that the

UAS will not create a hazard to users of the NAS or public.

Given the small size of our UASs and the restricted area that they will be operated in, MVA’s UAS operations

adhere to the Reform Act’s safety requirements. Additionally, due to the size of the UASs and the limited

area in which they will operate, approval of this application presents no national safety concerns. Based

on the substantial level of safety surrounding the proprosed operations and the significant public benefit

(enhanced safety). Reduction in environmental impacts in the outdoor setting these UASs will operate

leaving no trace of activity behind, the grant of the requested exemption is in the public interest. Accordingly, MVA respectfully request that the FAA grant the requested exemption.

Aircraft And Equivalent Level of Safety:

The operating limitations proposed by MVA provide for a higher level of safety because operations

further enhance safety of movie and television filming operations using conventional aircraft.

As set fourth in the FOPM, the limitations and conditions include:

• The UASs will weigh less than 55 pounds

• Flights will be operated within line of sight of a pilot and observer

• Maximim flight time for each flight will be 30 minutes or at 25% or battery power

 reserve whichever comes first.

• Flights will be operated at an altitude of no more than 400 feet AGL as indicated by

 onboard GPS system.

• Minimum crew for each operation will consist of the UAS pilot, the observer and a

 camera operator.

• A UAS pilot will be Pilot in Command (PIC).

• A UAS pilot will be an FAA licensed airman with at least a private pilots license or a

 Sport Pilots license third class medical.

• The UAS will only operate within a confined “sterile area” as defined in the FOPM.

• The FOPM requires the establishment of a “Security Perimeter” for the flight operations

 area.

• A briefing will be conducted for Planned UAS operations prior to each day’s flight

 for all personnel.

• Performing duties within the boundaries of the safety perimeter are required to attend.

• The operator will file a FAA Form 7711-1 or its equivalent, as modified in light of the

 requested exemption, with the appropriate Flight Standards District Office.

• The operator will obtain consent of all persons involved in the filming and ensure that

 only Consenting persons will be allowed within 100 feet of the flight operations.

• The operator will submit a written plan of Activities to the FSDO three days before the

 proposed shoot as required in the FPOM.

• The pilot and observer must be trained in UAS operations and received current information

 on the particular UAS to be operated as required by the FOPM.

• The pilot and observer will at all times be able to communicate by voice.

• Written and/or oral permissions and permits will be obtained from territorial, state, county,

 or city jurisdications, including local law enforcement, fire or other managing governmental

 agencies.

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• If the UAS loses communications or loses its GPS signal, the UAS will and does have the

 capability to return to a pre-determined LZ (Landing Zone) within the Security Perimeter and

 land safely.

• The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

Section 45.23 (b): Marking of the Aircraft

The regulation requires:

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.

Even though the UAS will have no airworthiness certificate, an exemption may be

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which

the word “Experimental” can be placed. Given the size of the UAVs, two-inch lettering

will be impossible. The word “Experimental will be placed on the fuselage in compliance

with §45.29 (f).

The equivalent level of safety will be provided by having the UAVs marked on its fuselage as

required by §45.29 (f) where the pilot, observer and others working with the UAVs will

see the identification of the UAS as “Experimental”. The FAA has issued the following

exemptions to this regulation to Exemption Nos. 10700, 8738, 10167 and 10167A.

Section 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command (PIC)

Multi-View Aerials is seeking relief from the regulation, as the requirement for a

Commercial Pilot License with a second class medical would be an unnecessary burden

on the operator with regard to obtaining and certifying UA pilots.

The UAS will not carry a pilot or passengers, and the proposed operations can achieve

the equivalent level of safety by requiring the pilot to posess a private pilot’s license

only, with a valid third class medical. This level of knowledge and skill combined with

the proposed operating procedures described in the Flight Operations Manual (VLOS

only, closed-set requirements, etc.) will more than adequately allow safe operation within

the national airspace system, and with regard to persons or property on the ground. The

additional knowledge and skill requirements for a Commercial Pilot’s license do not add

any level of safety with respect to closed-set small UAS operations in the same manner

they do with full scale, passenger-carrying aircraft.

An equivalent or greater level of safety is achieved by requiring UA pilots to have a

minimum number of hours logged, flight sequences, knowledge and experience testing,

etc. as described in the Flight Operations Manual.

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Section 91.119 (c): Minimum Safe Altitudes

Section 91.119 establishes safe altitude for operation of civil aircraft. Section 91.119 (d) allows

helicopters to be operated at less than the minimum prescribed, provided the person operating

the helicopter complies with any route or altitudes precribed for helicopters by the FAA. As this

exemption is for a UAVs that is a helicopter and the exemption requests authority to operate at

altitudes up to 400 feet Above Ground Level (AGL), or not more than 200 feet above an elevated

platform from which filming is planned, an exemption may be needed to allow such operations.

As set fourth herein, except for the limited conditions stated in the General Operating Manual,

the UAS will never operate at higher than 400 feet AGL. It will however be operated in a restricted

area with security perimeter, where buildings and people will not be exposed to operations

without their pre-obtained notification and consent when required.

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as

well as the location where it is operated. No flight will be taken without the permission of the

property owner or local officials. Because of the advance notice to the property owner and

participants in the filming activity, all affected individuals will be aware of the planned flight

operations as set forth in the GOM. Compared to flight operations with aircraft or rotorcraft

weighing far more than the maximum 55 lbs. proposed herein and the lack of flammable fuel,

any risk associated with these operations is far less than those presently presented with conventional

aircraft operating at or below 500 AGL in the movie industry. In addition, the low-altitude

operations of the UASs will ensure separation between these small-UAS operations and the

operations of conventional aircraft that must comply with Section 91.119.

Section 91.121: Altimeter Settings

Multi-View Aerials is seeking relief from this regulation, as the UA will not have a barometric

altimeter.

Section 91.121 requires each person operating an aircraft to maintain cruising altitude by reference

to an altimeter that is set “... to an elevation of the departure airport or an appropriate altimeter

setting available before departure”. As a UAS may not have a barometric altimeter, but instead a

GPS altitude data, an exemption is needed. An equivalent level of safety will be achieved by the

operator, pursuant to the FOPM and Safety Check List, confirming the altitude of the launch site

shown on the GPS altitude indicator before flight.

Section 91.151(a): Fuel Requirements for Flight in VFR Conditions

Multi-View Aerials is seeking relief from the fuel requirements of this FAR as current battery

technology allows the UAV to fly for approximately 15-30 minutes in normal conditions. As

91.151 (a) requires a 30-minute reserve AFTER reaching the point of intended landing, there is

no practical flight possible under this regulation.

An equivalent or greater level of safety exist as the exact battery level remaining is transmitted to

the pilot radio via telemetry, and given that the operating area for the UAV is in close proximity

to the pilot (VLOS), an unsafe condition where the UAV is unable to return for landing due to

low battery condition is easily avoidable.

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Additionally, should a defective battery prematurely depletes, the UAV is configured to auto

land above the point at which the flight controller detects low voltage. And as part of the MultiView Aerials Operations Manual, it is a requirement that any flight be terminated if telementery is

lost. Otherwise, a flight limit of 30 minutes or 25% battery capacity remaining is prescribed.

Section 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

a) Except as provided in §91.715, no person may operate a civil aircraft unless it has

 within it the following:

b) An appropriate and current airworthiness certificate ...

c) 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 and or

 crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As

such, there is no ability or place to carry certification and registration documents or to display

them on the sUAS. Each sUAS operated by Fly Habana will be registered with the FAA and all

documentation carried by the PIC.

An equivalent level of safety will be achieved by keeping these document at the ground control

point where the pilot flying the sUAS will have immediate access to them, to the extent they are

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative

sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9816A and

10700.

Section 91.405 (a), 91.407 (a) (1), 91.409 (a) (2); 91.417 (a) and (b): Maintenance Inspections

Multi-View Aerials is seeking relief from the above stated FAR’s as the UAV will not have an

airworthiness certificate. Therefore there is no requirement to perform an inspection in order to

maintain airworthiness as stated in Appendix D to Part 43 for 100hr. and annual inspections.

An equivalent or greater level of safety exists as the Multi-View Aerials Flight Operations

Manual does prescribe regular maintenance and inspections, compliance with manufacturer’s

service bulletins, test flights after maintenance, technician training, and so forth, in the spirit of

the scope and detail of Appendix D to Part 43. In addition, while mechanical failures are not out

of the question, a crash resulting from a catastrophic failure has a very small amount of risk of

injury when compared to a failure in a passenger carrying full size aircraft, for which this regulation

was intended.

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4. Public Interest:

Multi-View Aerials believes that allowing commercial use of small-unmanned aircraft will

enhance the safety of filming and inspection operations by reducing the risk associated with low

altitude full size aircraft operations. A manned, turbined powered helicopter operating is close

proximity to production personal and company employees on the ground has a far greater risk

of injury than a small, lightweight UAV carrying no combustible fuel, especially when amanned,

turbined powered helicopter operating is close proximity to production personal and company

employees on the ground has a far greater risk of injury than a small, light weight UAV carrying

no combustible fuel, especially when the UAV is operating within the parameters of the

Multi-View Aerials Operations Manual. Additionally, the safe integration of sUAS within the

national airspace is a growing concern among pilots, the FAA and general public. This exemption

would provide safe integration to share the airspace safely and to a more robust set of future

sUAS rules.

5. Level of Safety:

As outlined in each of the FAR’s above for which relief is sought (underlined).

6. Summary:

Multi-View Aerials seeks exemption from the following rules for the commercial operation of a

small unmanned aerial system in order to conduct filming and photography operations below an

altitude of 400’ AGL and within a limited operating area: 14 C.P.R. Part 21, Subpart H;

61.113(a) & (b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a)

& (b). This exemption will enhance the level of safety not currently able to be obtained by using

full sized manned helicopters and aircraft for the same type of work.

7. Privacy:

All flights will occur over private or controlled access property with the property owner’s prior

consent and knowledge. Filming will be of people who have also consented to being filmed,

property and infostructure with permission of owners or otherwise agreed to be in the area where

filming and photography will take place.

8. Additional Information:

The applicant, Michael L. Massar, is a safety conscious member of the AMA for over 20 plus years.

Have served as safety officer in local clubs and charter clubs and aided in safety rules for the

safety of everyone in the club. I was a sponsored RC Heli Pilot for over 8 years and flew

competitively in sanction events hosted by the AMA. Also help in the local events and helping

the event grow in number of pilots while maintaining a high degree of safety for people involved

as well as helping new comers to the sport and get them started right. I have been been in

filming and building the sUAV for the aerial industry for over 14 yrs. I take this very serious and

expect others to do the same and will not have anything to do with dangerous actions or people

that do.

If you have any other questions or need farther info, please contact at (512) 517-2875 or mmassar64@gmail.com

Regards,

Michael L. Massar

Owner, Multi-View Aerials

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