July 30, 2015

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 of the Federal Aviation

Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a);

91.9(b) (2); 91.103(b); 91.109; 119.121; 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,

I, Stephen Bacchus, owner of newly formed Heliview Services LLC am writing pursuant to

the FAA Modernization and Reform Act of 2012 and the procedures contained within 

14 C.F.R. 11, to request that I, the owner and operator of small unmanned aircraft, be exempted 

from the Federal Aviation Regulations (“FARs”) listed below so that I may

operate my small ultra lightweight unmanned aircraft system (“UAS”) commercially in

airspace regulated by the Federal Aviation Administration (“FAA”).

As described herein I am experienced in flying hobby type helicopters for recreational purposes. I have 

added a hobby grade quad-copter UAS (DJI Phantom 3 Advanced) to my inventory equipped with 

an attached camera with intent for aerial videography/cinematography to augment real estate 

listings, land development, events, promotional videos; following exemption and approval by 

the FAA. The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, 11978

and 11213 also apply to the situation.

My exemption request would permit operation of ultra lightweight, unmanned (piloted by remote control) 

and comparatively inexpensive UAS(s) in tightly controlled and limited airspace.

Predetermined in areas away from general public, airports, heliports and vehicular traffic for

community videos, and within property boundaries for individual property owner real estate

videos/photos. Currently, unmonitored amateur hobbyists with no safety plan or

controls in place to prevent catastrophe legally operate similar lightweight, remote controlled

UAS’s in the National Airspace System.

I, Stephen Bacchus, have personally instilled safety protocols and controls to avoid

and prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to

further safety protocols exclusive to lightweight UAS's specific to real estate video and

photography usage as I record flight data and other information gained through permitted flight operations 

to share with the FAA through any required FAA reports to assist with future protocol and safety 

regulations.

Granting my request comports with the Secretary of Transportation’s (FAA Administrator’s) responsibilities

and authority to not only integrate UAS's into the, but to “...establish requirements for the safe operation of 

such aircraft systems[UAS's] in the ” under Section 333(c) of the Reform Act specific to the use of UAS's 

for real estate, photography and videography purposes. Further I, Stephen Bacchus, will

HELIVIEW SERVICES LLC. FAA EXEMPTION 333 REQUEST Page 1
conduct my operations in compliance with the protocols described herein or as otherwise

established by the FAA.

For the reasons stated below I respectfully request the grant of an exemption allowing me to operate ultra 

lightweight, remote controlled UAS’s to enhance real estate videos for property owners who cannot afford 

expensive manned aircraft. This will promote local economic growth through increased employment and 

increased tax base. This will keep public safety in mind by keeping heavier manned aircraft containing 

combustible fuel that poses potential public hazard.

I. Contact Information:

Stephen Bacchus

Heliview Services LLC

HC 70 Box 4531

Sahuarita, Az. 85629

Email: bbacchuss@aol.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From

Which Stephen Bacchus Requests Exemption are:

14 CFR 21;

14 C.F.R. 45.23(b);

14 CFR 61.113 (a) & (b);

14 C.F.R. 91, et seq.;

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and,

14 CFR 417 (a) & (b).

III. The Extent of relief Stephen Bacchus seeks and the Reason He Seeks Such

Relief:

I, Stephen Bacchus, submit this application in accordance with the Reform Act, 112

P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent

me, Stephen Bacchus, contemplated commercial cinematic, academic and other flight or flight 

operations within the National Airspace System. The Reform Act in Section 332 provides for

such integration of civil unmanned aircraft systems into our National Airspace System as it is

in the public’s interest to do so. My ultra lightweight UAS meets the definition of “small unmanned 

aircraft” as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly 

contemplated by the Reform Act. I would like to operate my ultra lightweight UAS prior to the time period 

by which the Reform Act requires the FAA to promulgate rules governing such craft.

Thereby, providing direct experience and valuable information for formal regulation that can

be administered uniformly to all real estate related UAS aerial video and photography. The

Reform Act guides the Secretary in determining the types of UAS's that may operate safely in

our National Airspace System. Considerations include: The weight, size, speed and overall

capabilities of the UAS's; Whether the UAS will be operated near airports or heavily

populated areas; and, whether the UAS will be operated by line of sight. Each of these items

reflects in favor of an exemption for me, Stephen Bacchus. My UAS utilizes four (4)

counter-rotating propellers for balance, control and stability. My UAS is equipped with GPS

and auto return safety technology. Weighing less than five (5) pounds (far below the

maximum 55-pound limit); including camera with gimbal.

I, Stephen Bacchus, consider safety as foremost with each flight. My small-unmanned

aircraft is designed to hover in place via GPS and operate in less than a 24-knot (15 mph)

wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 16 kph

(10 mph). Built in safety systems include a GPS mode that allows my UAS to hover in place

HELIVIEW SERVICES LLC. FAA EXEMPTION 333 REQUEST Page 2
when radio controls are released. With three modes to choose from, I utilize the Smart Mode

for aerial videography/photography. This is the safest, most reliable and stable mode to

prevent accident and hazard. When pilot communication is lost UAS is designed slowly

descend to point of take off. I do not operate my UAS near airports, Hospitals nor Police

heliports, and do not operate near areas where general public is within fifty to one hundred

(50-100) yards depending on location, conditions and weather. I am constantly on alert for

any manned aircraft and prepared to land/abort immediately to the nearest and safest ground

point should a manned aircraft approach my location or I suspect manned aircraft may

approach near my location.

My UAS is capable of vertical and horizontal operations, and are flown only within my line

of sight (LOS) of me, as the remote control pilot. Utilizing battery power rather than

combustible fuels, flights generally last between three (3) to fifteen (15) minutes, with an

altitude under four hundred (400) feet. I utilize a fresh fully charged battery with each flight as a safety 

precaution; full flight time limit for each battery is up to twenty-five (25) minutes. I do not operate my UAS

at or below manufacture recommend minimum charge levels for operation; preferring to remain well within

a safe operating range to insure adequate communication between radio control and UAS to

eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with

each exercise to insure replacement for sufficient safe level of operation. I do not believe in

taking risk that may cause a crash, which could create hazard to the public/property/manned

aircraft, and have no desire to lose an investment. I have clocked numerous practice flights in

remote areas as a hobbyist simulating flights for future commercial use to gain

familiarization with the characteristics of this specific UAS's performance under different

temperature and weather conditions.

I, Stephen Bacchus, am extremely cautious when operating of my UAS/ultra

lightweight unmanned aircraft and will not “create a hazard to users of the National Airspace

System or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it

falls well within Congress’s contemplated safety zone when it promulgated the Reform Act

and the corresponding directive to integrate UAS's into the National Airspace System.

My UAS, used in hobby flight, has a demonstrable safety record and

does not pose any threat to the general public or national security.

IV. Stephen Bacchus’s Request Will Benefit the Public As A Whole:

Aerial videography for geographical awareness and for real estate marketing has been around

for a long time through manned fixed-wing aircraft and helicopters. For small budget real

estate companies and average homeowners, the expense of such aerial videography is cost

prohibitive. Only large companies and high-end Realtors or luxury homeowners can afford to

absorb such expense. Depriving non-luxury homeowners and lower budget Realtors from a

valuable marketing tool. My UAS poses little to no threat since size and lack of combustible 

fuel alleviates any potential threat to the public. Congress has already proclaimed that it is in 

the public’s interest to integrate commercially flown UAS's into the National Airspace System, 

hence the passing of the Reform Act.

Granting my, Stephen Bacchus’s, exemption request furthers the public interest

through academic/visual awareness of the geographical benefits in and around southern Arizona.

My ultra lightweight UAS is battery powered and creates no emissions that can harm the environment. 

The consequence of my ultra lightweight UAS crashing is far less than a full size helicopter or fixed wing 

aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public.

The public’s interest is furthered by, minimizing ecological and crash threat by permitting

aerial video/photo capture through my battery operated ultra lightweight UAS's. Permitting

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me, to immediately fly within national air space furthers economic growth. Granting my exemption 

request substantially furthers the economic impact for the community and companies in southern Arizona.

V. Reasons Why Stephen Bacchus’s Exemption Will Not Adversely Affect Safety

Or How The Exemption Will Provide a Level of Safety At Least Equal To 

Existing

Rule:

My, Stephen Bacchus’s, exemption will not adversely affect safety. Quite the contrary, for the 

reasons stated permitting me to log more flight time in FAA controlled airspace, with communication 

with the FAA, will allow me to contribute to the innovation and implementation of new and novel, 

as of yet undiscovered safety protocols for other individuals and development in cooperation with 

the FAA. 

In addition I, Stephen Bacchus, submit the following representations of enhancements to current 

aerial videography and photography for real estate and other opportunities, which may present itself:

My UAS weighs less than 5 pounds complete with a small ultra lightweight high quality

built-in camera; I only operate my UAS below 400 feet ceiling set by the FAA Modernization and 

Reform Act of 2012); my UAS only operates for 3-15 minutes per flight; I will land my UAS prior to 

manufacturer recommended minimum level of battery power; I pilot my UAS through remote control 

only by visual line of sight (VLOS); My UAS has GPS a flight safety feature whereby it hovers and then 

slowly lands if communication with the remote control pilot is lost; I actively analyze flight data and 

other sources of information to constantly update and enhance safety protocols; I only operate in

reasonably safe environment that are strictly controlled, are away from power lines, elevated

lights, airports and actively populated areas; I conduct extensive pre-flight inspections and

protocol, during which safety carries primary importance; I always obtain all necessary

permissions prior to operation; and, I have procedures in place to abort flights in the event of

safety breaches or potential danger.

My safety protocols provide a level of safety equal to or exceeding existing rules. It is important to 

note that absent the integration of commercial UAS into our, helicopters are the primary means of aerial 

video and photography for community awareness and real estate.

First, the potential loss of life is diminished because UAS's carry no people on board and I

only operate my UAS in specific areas away from mass populations. Second, there is no fuel

on board a UAS and thus the potential for fire or explosions is greatly diminished. Third, the

small size and extreme maneuverability of my UAS allow me to remotely pilot away from

and avoid hazards quickly and safely. Lastly, given its small size and weight, even when

close enough to capture amazing images, my UAS need not be so close to the objects they are

focused on through the technology and use of post editing software allowing pan and zoom.

Accordingly, my UAS has been experimentally operated for familiarization/competency and

will continue to operate at and above current safety levels.

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14

C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The

size, weight and enclosed operational area of my UAS permits

exemption from Part 21 because my UAS meets (and exceeds) an equivalent level of safety

pursuant to Section 333 of the Reform Act.

The FAA is authorized to exempt aircraft from the airworthiness certificate requirement

under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces

of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement

HELIVIEW SERVICES LLC. FAA EXEMPTION 333 REQUEST Page 4
in consideration of the weight, size, speed, maneuverability and proximity to areas such as

airports and dense populations.

My, Stephen Bacchus’s, current and projected UAS's meet or exceed each of the

elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness

certificate. As no such certificate will be applicable in the form contemplated by the FARs,

this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on

board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable.

An equivalent level of safety will be achieved by maintaining a safety/flight manual

delineating areas of where safety can be defined.

The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737,

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700, 32827 and many others.

14 C.F.R. § 91.121 regarding altimeter settings are inapplicable in so far as my UAS utilizes

electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and

registrations. They are inapplicable for the same reasons described above. The equivalent

level of safety will be achieved by maintaining any such required certifications and

registrations by me, Stephen Bacchus.

B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation

require aircraft to be marked according to certain specifications. My UAS is, by definition,

unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark

certain words or phrases. Further, two-inch lettering is difficult to place on such small aircraft

with dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs

in the largest possible lettering by placing the word “EXPERIMENTAL”,or FAA recomended lettering on 

its fuselage as

required by 14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with

the UAV will see the markings. The FAA has previously issued exemptions to this regulation

through Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R.

§§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. I, Stephen Bacchus

can achieve an equivalent level of safety as achieved by current Regulations because my UAS 

does not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure

remote control piloting skills. The risks attended to the operation of my UAS is far less than

the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, 

allowing me to operate my UAS, meet and exceed current safety levels in relation to 

14 C.F.R. §61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes

for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in

certain conditions. My UAS will operate at an altitude safely below the standard of 400 AGL.

I, Stephen Bacchus, will however operate my UAS in safe areas away from and traffic,

providing a level of safety at least equivalent to or below those in relation to minimum safe

altitudes. Given the size, weight, maneuverability and speed of my UAS, an

equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

Inspections.

The above-cited Regulations require, amongst other things, aircraft owners and operators to

“have [the] aircraft inspected as prescribed in subpart E of this part and shall between

HELIVIEW SERVICES LLC. FAA EXEMPTION 333 REQUEST Page 5
required inspections, except as provided in paragraph (c) of this section, have discrepancies

repaired as prescribed in part 43 of this chapter . . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not,

therefore, apply to my, Stephen Bacchus's, UAS. However, as a safety precaution I inspect my UAS 

before and after each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R.

91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled

Airworthiness Certificates, sets forth requirements for procurement of necessary

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed

operational area of my UAS permits exemption from Part 21 because my, Stephen Bacchus's

UAS meets an equivalent level of safety pursuant to Section 333 of the Reform

Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement

under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces

of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement

in consideration of the weight, size, speed, maneuverability and proximity to areas such as

airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R.

91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such

certificate will be applicable in the form contemplated by the FARs, this Regulation is

inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As

there are no pilots or passengers, and given the size of the UAS's, this Regulation is

inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The

FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737,

8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular

software updates and curative measures for any damaged hardware. Therefore, an equivalent

level of safety will be achieved.

In summary, Stephen Bacchus, seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §

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

91.409 (a) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Stephen Bacchus's,

small unmanned vehicle/lightweight unmanned aircraft vehicle in community

awareness, real estate operations and other opportunities which may present itself. Currently,

area awareness and real estate aerial videography/photography relies primarily on the use of

larger aircraft running on combustible fuel. Posing potential risk to the public.

Granting my, request for exemption will reduce current risk levels and thereby enhance 

safety. My UAS aircraft does not contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional real estate video and photographic aircraft with much less 

flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential 

public risk flying to and from established airfields.

I, Stephen Bacchus, have been informally analyzing flight information and will compile safety 

protocols and the implementation of a flight operations manual for real estate usage that exceeds 

currently accepted means and methods for safe flight. Formal collection of

information shared with the FAA will enhance the FAA's internal efforts to establish

protocols for complying with the FAA Modernization and Reform Act of 2012.

There are no personnel on board my, Stephen Bacchus’s, UAS and therefore the

likelihood of death or serious bodily injury is significantly diminished. My operation of my 

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UAS, weighing less than 5 pounds and travelling at lower speeds within limited areas will 

provide an equivalent level of safety as that achieved under current FARs. 

Accordingly

I, Stephen Bacchus, respectfully request that the FAA grant my exemption request and am 

willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, 

and the general public at large.

Respectfully submitted,

Stephen Bacchus

Heliveiw Services LLC

HC 70 Box 4531

Sahuarita, Az 85629

Attached: Preflight Form and Checklist:

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HELIVIEW SERVICES 

PREFLIGHT CHECKLIST

 Preparation before going flying.... 

1: Visually inspect the Phantom 3 aircraft for body damage taking greater attention to the landing gear and 

camera/gimbal. 

2: Check the propellers you will use during a flying session for damage like chips, cracks, bending and hub 

wear. 

3: Check your batteries for damage/signs of swelling. Swollen batteries should really not be used for flying. 

4: Spin the motors with your fingers and make sure none feel/sound different.

5: Charge all required flight batteries. Run the battery self check feature. 

6: Charge the Phantom 3 controller and power on/off to verify it works. 

7: Charge your mobile device. Close all running apps then test the Pilot App to make sure it opens. 

8: Make sure you have MicroSD card(s) available empty/formatted. Slot one inside the Phantom ready. 

9: Power on the controller then Phantom 3 and quickly check that IMU readings are within range. It should 

normally be OK. Power everything back off. 

10.Cache maps in the DJI Pilot App is needed.

11: Make sure Gimbal guard is fitted before transport. You can use the one that came with the Phantom or 

another 3rd party one you might have purchased.

 12: Pack the Phantom 3 in your chosen transport method making sure it’s secure. Many cases and 

backpacks available. 

13:Check Weather, Solar Radiation/Storm Levels, Wind speed/direction and is the location you will fly in is

within a No Fly Zone or not.

 Pre-Flight...

1: Make sure the area you are going to fly in is safe not only for you and your phantom but members of the 

public, animals and other aircraft too. A big wide open field would be best for the first few flights. 

2: Carefully unpack the Phantom 3 and the controller, tablet, batteries and propellers onto a clean surface. If

you transport in a case you can place them on top or take a small plywood board with you for this purpose. 

Check the Phantom to make sure it’s OK. Also remember to remove any lens cap and check the lens is clean

on the camera. 

3: Mount your tablet/phone onto the Phantom 3 controller and attach the USB cable from the device to it. 

4: Put the battery into the Phantom 3 making sure it is seated correctly ( should be almost no gap between 

the Phantom's shell and the battery ). 

5: Attach a set of propellers to each motor. Make sure to mount the Black headed hubs to the black tipped 

motors and the Gray headed hubs to the silver tipped motors. Make sure to snugly tighten the propellers by 

hand. 

6: Place the Phantom 3 on clean level ground. Use a small square sheet of plywood or a transport case if 

needed. 

7: Remove the Gimbal Guard. 

8: Power on the controller and then the Phantom 3. Open the Pilot App on your tablet/phone and verify you 

can see a live feed from the aircraft. Allow it to set a "Home Point". Monitor the aircraft's status lights to 

confirm this as well as the Pilot App. Have the antennas setup like Rabbit Ears ( Looking at the controller 

form the side _| - Looking at the controller form the front \_/ ). 

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9: Turn the volume UP on the tablet with the Pilot App Open.

10: Calibrate the compass. Keep the Phantom about 10 feet from the controller and any metal objects when 

doing compass calibration. If the calibration fails, move the Phantom from its current location and try again.

11: Don't get distracted by the pretty people looking at you. 

12: Check that the PAF switch is in the desired position. P mode is best to start with.

13: Move about 10 feet from the Phantom making sure the back of it is facing you. Arm the motors using 

the CSC ( Combination Stick Command ). The Pilot App will confirm the aircraft is ready to fly. 

14: Slowly increase the throttle and lift the Phantom 3 about 15 feet off the ground. Do a slow 

left/right/forward/back movement and YAW to confirm its stable and working as expected. You can now 

enjoy flying the DJI Phantom 3. 

 Post-Flight... 

1: Land or hand catch the Phantom 3 and power it off (it will take a few seconds before the aircraft switched

off, don't do anything until its OFF ). Power off the controller. 

2: With the Phantom 3 on a clean surface, give it a quick check for damage, dirt and dead flies. Refit the 

3: Remove the propellers, use the provided prop tool to loosen them if needed. Give them a quick look over 

for damage before storing them. 

4: Remove the battery. It might be a little warm after flight, this is normal. Check it for damage/swelling 

and if all is OK, place it to one side to cool a little whilst you do everything else. 

5: Remove the phone/tablet from the holder and store it and the controller. 

6: Refit the Gimbal Guard. 

7: Put the Phantom 3 back in its case/backpack. 

8: Put the battery back in the case/backpack. 

9: Make sure you haven't left anything behind before going home to check the video/photos out. 

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