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### U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE West Building Ground Floor Room W12

- 140 Washington, D.C. 20590

RE: Petition for Exemption Under Section 333 of the Federal Aviation Administration

Modernization and Reform Act of 2012 , public 112

- 95 Feb. 14, 2012, Section 333

Dear Sir or Madam,

Pursuant to Section 33 of the FAA Modernization Act of 2012 and 14 CFR Part 11, Aerial Video Solutions, Inc. ( AVS ) operator of Small Unmanned Aircraft Systems (UAS),

e quippe d to provide cost effective aerial imagery services , hereby applies for an Exemption from the listed Federal Aviation Regulations (FAR) to allow commercial Operations of it’s UAS, so long as such operations are conducted within and under

The conditions and limitations outlined herein or as may be established by the FAA As required by Section 333.

These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure specifically, a safety en hancement to aerial imagery and videography conducted by manned aviation operations

The use of UAS for aerial imagery and videography by AVS reduces the need for personnel to use manned aircraft activities to perform the same function.

Therefore it is in the best interest of the Public for the FAA to approve the Requested exemptions.

The applicant, Paul Craig Boutin, for Aerial Video Solutions, Inc., has be en involved in

aviation for 35 years and radio controlled vehicles for over 5 years. Currently h olds a Commercial Pilots Certificate with an Instrument rating received in 1980. Formally educated at Embry Riddle Aeronautical University in Aeronautical Science. Paul has an in

depth understanding of the capabilities and safety concerns involved in thi s technology and

that it has enormous potential benefit to the community.

Sincerely,

Paul Craig Boutin

President Aerial Video Solutions, Inc. ( AVS ) 2304 w. Eagle Feather Rd. Phoenix, AZ 85085

480

- 575

- 1156 pboutin321@msn.com

submitted: June 2 n d , 2015Page 2 of 9



### Requested Exemptions from Regulations :

14 C.F.R Part 21.185

Airworthiness Certificate

AVS recommends that in consideration of the size, weight, speed and limited operating area associated with these aircraft and their operation, the Secretary of Transportation determines

that these aircraft meet the conditions of Section 333.

14 C.F.R. Part 4 5.23(b) Display of marks

AVS UAS shall be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

14 C.F.R. Part 61.113(a) Private pilot privileges and limitations The FAA has found in previous grants of exemption that a PIC with a private pilot certificate operating a UAS would not adversely affect operations in the NAS or present a hazard to

persons o r property on the ground.

14 C.F.R. Part 61.133(b) Commercial pilot privileges and limitations The FAA has found in previous grants of exemption that a PIC with a private pilot ce rtificate operating a UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground.

14 C.F.R. Part 91.7(a)

Civil Aircraft Airworthiness

AVS recommends that in consideration of the size, weight, speed and limited operating are a associated with this aircraft and its operation, the Secretary of Transportation determines that

these aircraft meet the conditions of Section 333.

14 C.F.R. Part 91.9(b)(2) &(c) Civil Aircraft Flight Manual, Marking, and Placard Requirements

The FAA has previously determined that relief from these sections is not necessary. Relevant materials may be kept in a location accessible to the PIC in compliance with the regulations.

14 C.F.R. Part 91.103 Preflight Action As FAA approved flight manuals wi ll not be provided for the aircraft an exemption will be

needed. Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoff distances, along will all of those found in attachment "DJI Pilot Training" . An equivalent level of safety will be provided by preflight protoco l (see attachment) to properly match the machine.Page 3 of 9

14 C.F.R. Part 91.109(a) Flight Instruction

AVS will conduct all flight training through procedures specified in Training Instruction (see attachment) during dedicated training sessions. Based on previous decisions made by the FAA

for UAS petitions regarding this regulation,

14 CFR 91.109 UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is

achieved through the use of a control box that communicates with the aircraft via radio

communications. The equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft, and by the speed and size of the aircraft

.

14 CFR 91.113 (a) and (b)

AVS can achieve an equivalent level of safety as achieved by current regulations because the

UAS does not carry pilot nor passenger. While helpful, a pilots' license will not ensure remote control piloting skills.

14 C.F.R. Part 91.119(c)

Minimum Safe Altitude Aircraft will be operated below 400 AGL, but not over congested areas.

14 C.F.R. Part 121 Altimeter Settings The proposed aircraft have a barometric altimeter and GPS derived altitude capabilities. AVS recommends that the altimeter be set to zero feet AGL rather than local barometric pressure or field altitude before flight. Considering the limited altitude of the proposed operations.

14 C.F.R. Part 91.151(a) Fuel Requirements in VFR

Prior relief ha s been granted for manned and unmanned aircraft to operate at less than prescribed minimums.

14 C.F.R. Part 91.203(a) and (b) Certifications Required Original intent of these regulations was to display an aircraft’s airworthiness, certification and

reg istration documents so they would be easily available to inspectors and passengers. Based

on the FAA Section 333 of the Reform Act, authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.Page 4 of 9

14 C.F.R. Part 91.405(a) Maintenance Required Given these section only apply to aircraft with an airworthiness certificate, theses sections do not apply to this applicant. As a safety precaution, operator will perform preflight inspections and

ensure UAS is in working condition b efore initiating each flight.

14 C.F.R. Part 91.407(a)(1) Operation after Maintenance

Given this section only appl ies to aircraft with an airworthiness certificate, theses sections do not apply

to this applicant. As a safety precaution, operator will perform preflight inspections and ensure

UAS is in working condition before initiating each flight.

14 C.F.R. Part 91.409(a)(1) and (2) Inspections

Given this section only appl ies to aircraft with an airworthiness certificate, theses sections do not apply to this applicant. As a safety precaution, operator will perform preflight inspections and

ensure UAS is in working condition before initiating each flight.

14 C.F.R. Part 91.417 (a) and (b)

Maintenance Records

Given this section only appl ies to aircraft with an airworthiness certificate, theses sections do not apply to this applicant. As a safety precaution, operator will perform preflight inspections and

ensure UAS is in workin g condition before initiating each flight.

Aerial Video Solutions, Inc. (AVS) is seeking relief from all FARs above preventing applicant from conducting cost effective aerial imagery services taken at levels less than 400ft, at a speed less than 33.5 mph , and with a maximum fligh t time of 25 minutes,. The UAS’s proposed to be

used are listed below are all under 35 pounds. T he UAS meets the definition of "small

unmanned aircraft system " found in section 333 "The Reform Act". In order to obtain high quality photography and video the UAS will be used at speeds much less than it's top speed of 33.5 mph. Due to the UAS being battery powered there are no combustible fuels onboard. Maximum flight time for this particular UAS is 25 minutes battery life, flights to be terminated with 25% battery life remaining. Given the size, weight, speed, and limited operating area associated with

the aircraft to be utilized

. AVS find s this exception to be reasonable with an equivalent, or greater, level of safety to be reached by the operator.Page 5 of 9



### Public Interest :

Removal of human risk from flight operations.

AVS operations of UAS to perform aerial imagery and videography will reduce risk to life and
property by decreasing the requirements of personnel to operate manned aircraft to perform

these tasks.

AVS will use battery

- powered UAS that serve as safe and efficient alternatives to the manned
aircraft commonly utilized to conduct aerial imagery and videography.

Also, the flight data, inspection results, recorded observations and lessons learned from these
operations will be compiled to further enhance its current safety program.

AVS proposes that the exemptions requested herein apply to civil aircraft that have the
characteristics and that operate with the limitations listed herein. These limitations provide for at
least an equivalent or even higher level of safety to operations unde r the current regulatory
structure because the proposed operations represent a safety enhancement to aerial imagery
and videography conducted by manned aircraft.

Reduction in gas emissions associated with powered flight.

Improvement upon cost efficiencies associated with manned flight.

National policy set by Congress favors early integration of UAS into the NAS in controlled, safe,
working environments such as those proposed in this petition. In addition, the public also has
an interest in reducing the haz ards and emissions associated with alternate use of helicopters to
conduct similar operations.



### PRIVACY :

All flights will be conducted in accordance with any and ALL federal, state and local laws
regarding privacy

AVS will voluntarily participate in the “NoFlyZone” registry and proactively stay current with

updates

- https://www.noflyzone.org/Page 6 of 9



### Aircraft and Equipment requested to be used for compensation or hire :

All aircraft weigh less then 55 pounds

AVS proposes to use Four unmanned aircraft systems (UAS) for aerial video & still photography

DJI Phantom 2 Vision+ V2.0 Quad

- Rotor

- PIC will operate UAS in safe manner that will not
pose threat to person or property and with assistance from a visual observer (VO)

DJI Phantom 2 Vision+ V3.0

- PIC will operate UAS in safe manner that will not pose threat to

person or property and with assistance from a visual observer (VO)

DJI Inspire 1

- PIC will operate UAS in safe manner that will not pose threat to person or

property and with assistance from a visual observer (VO)

Tarot 680PRO Six

- Axis Hexacopter

– Equipped with the DJI NAZ

- M V2 Control, GPS and
Navigation (same system as other DJI UAS). PIC will operate UAS in safe manner that will not
pose threat to person or property and with assistance from a visual observer (VO)

AVS will use the following ground support equipment :

DJI laptop Ground Control Station (DJI aircraft)

DJI iPad Ground Control Station (DJI aircraft)

If the UA S loses communications or loses its GPS signal, it will return to a pre

- determined

l ocation within the planned operating area and land or be recovered in accordance with the
operating documents.

Altitude awareness will be maintained via a radio communicati ons telemetry data link, which downlinks from the aircraft to the PIC for active monitoring of the flight path. The altitude information will be generated by GPS equipment installed on the aircraft. Prior to each flight, a

zero altitude initiation point wi ll be established and confirmed for accuracy by the UAS PIC.

Pilot In Command : Prior to commercial operations conducted for the purpose of aerial imagery and videography

,

T he PIC will :

Have a minimum of twenty hours of total time as a UAS pilot

A t least ten hours logged as a UAS pilot with similar UAS type (quad or hex rotor)

Have a minimum of five hours as a UAS PIC operating the make and model of the UAS

T hree take

- offs and landings in the preceding 3 0 days.

Demonstrate DJI Pilot Training profici encyPage 7 of 9

AVS will not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be opera ted under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures.

PIC qualification flight hours will be logged

. The VO w ill also be required to complete the operator’s training requirements. A record of training will be documented and made available upon request by the Administrator



### Visual Observer : All operations will utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC will be able

to communicate verbally at all times. Electronic messaging or texting will not be permitted during flight operations. The PIC will be designated before the flight. The PIC will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the

functions prescribed in the operating documents. The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based

obstacles/obstructions and is not permitted to operate the camera or other instruments.



### Training :
Will Include and re q uire:

DJI Pilot / Flight Training Guide: (see attachment)

AV S Training guide ( available upon request )



### Maintenance : AVS will carry out its maintenance, inspections, and record keeping requirements, in

accordance with the manufacturer operating documents and manuals . Maintenance, inspection, alterations, and status of replacement/overhaul component parts will be noted in the aircraft records, including total time in service, description of work accomp lished, and the signature of

an authorized AVS person before returning the UAS to service.



### Flight Operations :

All flights will occur under Visual Flight Rules Meteorological Conditions (VFR) only.

All operations must utilize a VO. The VO may be used to satisfy the Visual Line of Sight (VLOS) requirement

.

The PIC and VO will have been trained in operation of UAS and receive up

- to

- date information for the particular UAS to be operated.

Mission planning will be accomplished prior to flight. A preflight briefing will be conducted by the PIC and VO, as well as with any other observers (company representatives, licensed inspectors, etc.) prior to commencement of operations.

PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight.Page 8 of 9

The Ground Control Station will be included in the preflight ins pection.

All maintenance and alterations will be properly documented in the aircraft records. to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight

The UA S will be operated within visual line of sight (VLOS) of the P IC at all times.

The UA S will be operated at an altitude of no more than 400 feet above ground level (AGL),

UAS operations will not be conducted during night,

UAS will be operated with all manufacturer safety bulletins.

The UA S will not operate within 5 miles of an airport

The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined l ocation within a designated location and land autonomously.

The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point

and land the UA S wit h 2 5 % battery power remaining.

All operations shall be conducted over private or controlled

- access property with permission

from the land owner/controller or authorized representative. Permission from land

owner/controller or authorized re presentative will be obtained for each flight to be conducted.

The UA S may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

The UA S will not be flown a t an indicated airspeed exceeding 30 knots.

The UAS may not be operated by the PIC from any moving device or vehicle.

The UA S must remain clear and give way to all manned aviation operations and

activities at all times.

Operating characteristics and mainte nance procedures are outlined in the attached operations

user manuals. The radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requi rements.

AVS shall obtain all necessary consent and permissions prior to operation of those being filmed or an agreement to be in the designated filming area prior to filming taking place.Page 9 of 9

Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required, will be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon reque st.

Before conducting operations, the radio frequency spectrum used fo r operation and control of

the UAS shall comply with the Federal Communications Commission (FCC) or other appropriate
government oversight agency requirements.



### Conclusion : AVS requests a review of the aforementioned relief request at the earliest date practicable. We believe we have addressed all the requests and requirements set forth by Section 333 relief guidance and that our request is in line with previously approved relief requests. It is our

recommendation that the Secretary of Transportation and FAA a pprove the exemption for Aerial Video Solutions, Inc.

, due to the favorability of the public interest and the ability of the exemption to provide a level of safety at l east equal to that provided by the rules from which exception is being sought.

Sincerely,



### Paul Craig Boutin

President Aerial Video Solutions, Inc. ( AVS ) 2304 w. Eagle Feather Rd. Phoenix, AZ 85085

480

- 575

- 1156 pboutin321@msn.com



### ATTACHMENTS:

DJI Phanton2 User Manual

- http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.8_en.pdf 

### DJI Inspire1 User Manual

- http://download.dji

i nnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en. pdf 

### DJI Training Manual

- http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_Pilot_Training_Guide_v1.1_en.pdf 

### DJI Safety Guidelines

- http://download.dji

- innovations.com/downloads/inspire_1/en/Inspire_1_Safety_Guid elines_en.pdf 

### UAS Flight Log (sample)

AVS Protocols