1200 New Jersey Ave. SE 

Washington, DC 20590 

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 

Dear Sir of Madam: 

The subject petition is being submitted without consulting or legal services as DA Aerial Vision is a startup small business. I also hold An Airline Transport Pilot Certificate Rating. 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012(the 

reform act), and 14 C.F.R. Part 11, DA Aerial Vision wishes to operate small 

Unmanned Aircraft System {UAS) equipped to conduct aerial photography and 

survey for various industries and hereby applies for an exemption from the Federal 

Aviation Regulations (FARs) listed below to allow of my UAS commercially in the National Airspace System {NA:S) so long as such operations 

are conducted with and under the conditions outlined herein or as may tie established by the FAA as required by Section 333. 

The request exemption would permit DA Aerial Vision to pursue its commercial interests in providing services to consumers interested in aerial photography using small, commercial-off the shelf (COTS) UAS in the following areas: 

• Real Estate Photography • Agricultural Land Surveys and monitoring 

• Land Development Surveys 

• UAS Operator Training 

• Promotmg the Safe and Effective Use of Small UAS Technology 
will be trained by to understand the proper roles of an observer, communication procedures, proper visual scan techriiques, operations at non towered airports, and appropriate sections of the Aeronautical Information Manual {AIM). Proper traming and safety will be of upmost importance. 

Regulations from which the exemption is requested: 

14 C.F.R. 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. 91.109 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) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401-91.417) 

Unmanned Aircraft System (UAS) 

DA Aerial Vision request to operate Dll Phantom 2 Vision Plus, Dll Phantom 3 Pro, and Dn Inspire 1 multi-rotor UAS equipped with a three axis gimbal mounted 

camera. The UAS's weighs less than 251bs, have built -in capability to limit height the UAS's flies above the ground, to limit the radius of the distance it flies from the operator and to exclude it from Class A, B, C and D airspace including a no fly 
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general public, livestock, pets, or wildlife. 

When conducting UAS flights within 5 run of an a41Jort, airport operators will be notified and the UAS operator will give the right of way to avoid flying in the proximity of full scale aircraft. All operations in these areas will be conducted at an attitude of less than 200 feet AGL. 

The maximum flight time for each operational flight will not exceed 60 minutes. 

Flights will be terminated at 25% battery power reserve should that occur prior to 

the 6o minute limit. 

The UAS will be programmed to limit flight altitude to 400 feet AGL. 

All UAS's will be maintained in accordance with the manufactures 

recommendations. 

Before each fligpt a thorough preflight inspection will be performed to validate the airworthiness of the UAS. No flight will be performed with an un- airworthy UAS under any circumstance. 

The UAS operator will be an FAA licensed airman holding at minimum an FAA Private Pilot Certificate The UAS's proposed by the petitioner weighs less than55 pounds, including all payloads (i.e. camera, lens, and gimbal). 

The UAS will operate at speeds less than 55 knots. 
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S Aerodynamics; Weather factors; Airmanship and Decision-making and safe 

operatmg procedures. 

DA Aerial Vision request exemption under Section 333 to enable to operate safe, low-risk commercial small UAS operations for the activities summarized in this 

request. 

Sincerely, 

Daniel K. Anderson 

President 

DA Aerial Vis ion 

824 Moss Cliff Circle 

McKinney TX 75071 

gxcaptain@yahoo.com 

(214) 886-5216 

Attachments: 

A. Exemption Request and Equivalent Level of Safety 

B. Maintenance Log 

C. Flight Log 
This part establishes the procedures for the issuance of an airworthiness certificate. While 

the FAA continues to work to develop airworthiness standards for Unmanned Aerial 

Systems. we request an experimental certificate be issued for the DJI Phantom 2 Vision 

Plus. Phantom and Inspire 1 UAS. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations prol<idc that each aircraft must display "N" and the 

registration number in letters at least 3 inches high. Additionally. the aircraft must display 

the word "EXPERIMENTAL" in letters at least 2 inches high ncar the entrance to the 

cabin. cockpit. or pilot station. The small UAS docs not have an entrance in which the 

word "EXPERIMENTAL" can be placed. and may not have a registration number 

assigned to it by the FAA. We propose to achieve an equivalent level of safety by 

including the word "EXPERIMENTAL" in the placard on the top of the UAS. 

14 CFR 61.113 Pri,•ate pUot prilileaes and Umitations: PUot in Command and 

61.133 Commercial pllot pril-Deges and llmltations. 

The regulation provides that no person that holds a Private Pilot certificate may act as 

Pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a 

private pilot to 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 docs not cany passengers or property for compensation or hire. Our proposed 

operations require that the PIC must hold at least a Private Pilot Certificate issued by the 

FAA and since the aircraft cannot cany passengers or property. we feel we meet the 

intent of61 .113 Subparagraph (b) even though the intent of this application is to conduct 

a business. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness 

certificate. 

As no such certificate will be applicable in the fonn contemplated by the F ARs. this 

Regulation is inapplicable. 
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operations. To obtain an equivalent level of safety and meet the intent of 91. 9, we 

propose that a cUITellt. approved UAS Flight Manual must be available to the crew at the 

ground station at all times. 

14 CFR 91.109 FU1ht Simulated instrument m1ht and m1ht 

tests 

The regulation states ''No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." The UAS System 

ground-based control station consists of a small hand-held radio transmitter and while it 

does not offer a second set of"controlsu. both the student and instructor can. and will. 

operate the single set of controls simultaneously. With both student and instructor ha"-ing 

"hands-on'* the controls during flight. we feel that this technique meets the intent 91.109 

and provides an equivalent level of safety. 

14 CFR 91.1191\IIDfmum safe altitudes: 

The regulation states that over sparsely populated areas the aircraft cannot be operated 

closer than 500 feet to any person. vessel. vchic:le. or structure. Since the typical mission 

of the UAS would be photography or survey of persons. '\·essels. vehicles or structures it 

would be necessary to operate closer than 500 feet to the items listed. Operations will 

only be flown over property or persons where pennission has been obtained either 

verbally or in writing. The aircraft will be operated at a low altitude allowing. if there is a 

loss of propulsion. an emergency landing without undue hazard to persons or property on 

the surface. Therefore we maintain that due to the small size of the UAS. the hazard to 

persons. vehicles and structures is minimal compared to manned aircraft. which should be 

considered in granting the exemption. 

14 CFR 91.121 Altimeter settin1s. 

The regulation requires that aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft. The UAS will always fly below 

600 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict 

with other aircraft. An AGL altimeter measurement above the takeoff point is transmitted 

via radio from the UAS on-board computer to the display screen held by the UAS 

operator. providing a constantly updated AGL readout. 
and the maximum duration of flight from a single battery charge is 12-45 (depending on 

which UAS) minutes with a 20% resetV"e. Since the aircraft will never fly more than 112 

NM from the point of intended landing. a full battery charge at launch will ensure that we 

meet the resetV"e energy requirement of this paragraph. We also request exemption from 

the 30 min reserve and ask that our reserve will be to fly the mission to the point of 

intended landing and ha\·e at least a 20% battery reserve after that. 

14 CFR 91.203(a) & (b) Chil required. 

The regulation pro,.ides that an airworthiness certificate. with the registration number 

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Additionally. subparagraph (b) provides that the ainvorthiness certificate be .. displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew." A small UAS is 

too small to cany documentation. does not ha\·e an entrance. and is not capable of 

c811}'ing passengers or crew. To obtain an equivalent level of safety and meet the intent 

of 91.203. we propose that documents deemed appropriate for this aircraft by the FAA 

will be collocated with the crew at the ground control station and available for inspection 

upon request. In order to identify the aircraft. we propose that the information found on 

airworthiness and registration certificates be permanently affixed to the aircraft \ia 

placard containing the following information plus the word 0 EXPERIMENTAV• to 

satisfy the requirement of 14 CFR 45.23. 

14 CFR Subpart E (91.401- 91.417)- :Maintenance, Pre\·entil·e Maintenance, 

Alterations 

The regulation pro'\ides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition. including compliance with part 39 and 43. Paragraphs 

91.407 and 91.409 require that the aircraft be "approved for return to service by a person 

authorized under 43. 7" after maintenance and inspection. It is our intention that the PIC 

perfonn maintenance and inspection of the aircraft and 111be authorized to approve the 

aircraft for return to set\ice.'' The UAS operator will ensure that the aircraft is in an 

ainvorthy condition prior to every flight and in addition. conduct detailed inspections after every two hours of flight. Maintenance perfonned by the UAS operator is limited to 

repairing small replacing a propeller? checking electrical and updating software 

and finnware for the on-board computer. All other mainteoance will be perfonned by the 

manufacturer or their designated repair facility. The UAS operator will document work 

performed in accordance with 91.417 in the attached Maintenance Log. 

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