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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),

equipped 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 enhancement

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 been involved in 

aviation for 35 years and radio controlled vehicles for over 5 years. Currently holds a 

Commercial Pilots Certificate with an Instrument rating received in 1980. Formally 

educated at Embry Riddle Aeronautical University in Aeronautical Science. Paul has an indepth understanding of the capabilities and safety concerns involved in this 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 2nd, 2015
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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 45.23(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 or 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 certificate 

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 area 

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 will 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 protocol (see attachment) to 

properly match the machine.
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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 has 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 

registration 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.
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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 before initiating each flight.

14 C.F.R. Part 91.407(a)(1) 

Operation after Maintenance 

Given this section only applies 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 applies 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 applies 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.

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 flight time of 25 minutes,. The UAS’s proposed to be 

used are listed below are all under 35 pounds. The 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 finds this exception to be reasonable with an equivalent, or 

greater, level of safety to be reached by the operator. 
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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 under 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 hazards 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/
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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 UAS loses communications or loses its GPS signal, it will return to a pre-determined 

location within the planned operating area and land or be recovered in accordance with the 

operating documents.

Altitude awareness will be maintained via a radio communications 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 will 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,

The PIC will:

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

At 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

Three take-offs and landings in the preceding 30 days.

Demonstrate DJI Pilot Training proficiency
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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 operated 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 will 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 require:

DJI Pilot / Flight Training Guide: (see attachment)

AVS 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 accomplished, 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. 
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The Ground Control Station will be included in the preflight inspection. 

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 UAS will be operated within visual line of sight (VLOS) of the PIC at all times.

The UAS 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 UAS 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 location 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 UAS with 25% 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 representative will be obtained for each flight to be conducted.

The UAS 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 UAS will not be flown at an indicated airspeed exceeding 30 knots.

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

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

activities at all times.

Operating characteristics and maintenance procedures are outlined in the attached operationsuser 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 requirements.

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.
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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 request.

Before conducting operations, the radio frequency spectrum used for 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 approve 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 least 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.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.8_en.pdf

DJI Inspire1 User Manual - http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

DJI Training Manual - http://download.djiinnovations.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_Guidelines_en.pdf

UAS Flight Log (sample)

AVS Protocols