Albany 

Atlanta 

Brussels 

Denver 

McKenna Long &Aldridge.u· 

1676 International Drive • Penthouse 

Mclean. VA 22102 

Northern Virginia 

Orange County 

Rancho Santa Fe 

San Diego 

Los Angeles 

Tel: 703.336.8800 

mckennalong.com 

San Francisco 

Miami Seoul 

New York Washington, DC 

MARK E. MCKINNON 

703.336.8708 

EMAIL ADDRESS 

mmckinnonf@mckennalong.com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

October 14, 2014 

Re: Petition of Perfect View Aerial Media, LLC for an Exemption Pursuant to 

Section 333 of the FAA Modernization and Reform Act of2012 

Dear Gentlemen: 

Pursuant to Section 3 33 of the FAA Modernization and Reform Act of 2012 ("Reform 

Act") and 14 C.F.R. Part 11, Perfect View Aerial Media, LLC ("Perfect View"), hereby applies 

for an exemption from the Federal Aviation Regulations ("FARs") identified below, to allow 

commercial operations of small unmanned aerial vehicles (i.e., "small unmanned aircraft" or 

"UAS"). 

This exemption is made based on the information in this petition, as well as the 

accompanying Perfect View Operations and Safety Manual ("Operations Manual") and the DJI 

S-1 000 flight and maintenance manuals. Petitioner submits this supporting material as 

confidential documents under 14 C.F.R. § 11.35(b), as they contain confidential commercial and 

proprietary information that the Petitioner has not and will not share with others. Similarly, 

these documents contain operating conditions and procedures that are not available to the public 

and are protected from release under the Freedom oflnformation Act, 5 U.S.C. § 552 et seq., and 

any other requirements established by the FAA pursuant to Section 333 ofthe FAA Reform Act. 

For your convenience, the petition is organized as follows: 

I. Description of Petitioner 

II. Relevant Statutory Authority 

III. Perfect View Aerial Media's Proposed UAS Operations Meet The Requirements Of 

Section 333 Of The Reform Act 
U.S. Department of Transportation 

October 14, 2014 

Page 2 

IV. Regulations From Which Exemption is Requested 

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 

C.F.R. § 91.203 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category 

Rotorcraft 

C. 14 C.F.R. § § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and 

Identification Requirements 

D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and 

Registration 

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

F. 14 C.F.R. § 91.103: Preflight Action 

G. 14 C.F.R. § 91.109(a): Flight Instruction 

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

I. 14 C.F.R. § 91.121: Altimeter Settings 

J. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR 

Conditions 

K. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections 

L. 14 CFR § 61.113 

V. Drug and Alcohol Program 

VI. Public Interest 

VII. Privacy 

VIII. Federal Register Summary 

IX. Conclusion 

I. DESCRIPTION OF PETITIONER 

Perfect View seeks the requested exemptions to permit it to offer thermal and optical 

imaging and inspections of electric power infrastructure. In addition, Perfect View seeks 

authority to conduct flights for training and maintenance purposes in a sterile area free from 

hazards and persons. 

Perfect View has adopted a philosophy that recognizes that UAS operations are a part of 

the complex, interconnected systems that make up the national airspace (NAS). In addition, 

Perfect View personnel have longstanding experience in conducting electric power infrastructure 

inspections and are well aware of the special safety issues that arise from working in this 

environment. The Perfect View Team consists of Professional Electrical Engineers, Electrical 

Operations Managers, FAA Licensed Pilots, Certified Thermographers and professional 

photographers. 
U.S. Department of Transportation 

October 14, 2014 

Page 3 

The delivery of reliable electrical power and other utility services is essential in our 

demanding technological world. Manufacturers operating 24/7 depend on it to remain profitable, 

as do commercial enterprises at all levels. It is critical in everyday life, at home, on the road, in 

business and for public safety. That is why the most successful utility companies take every 

precaution to prevent sudden outages, and why thermal imaging has become a core predictive 

maintenance tool in their ongoing inspection programs. They depend on thermal imaging for 

intensive regular substation surveys as well as quick safety checks of energized equipment 

before beginning maintenance work. This helps utilities avoid costly service interruptions and 

exorbitant equipment losses. Deregulation in the electric utility industry in a number of states 

prompted utilities to become more cost-competitive, leading to the outsourcing of infrastructure 

work to contractors who could do the job more efficiently. Moreover, much of the transmission 

and distribution infrastructure in the United States is aging and in need of repair or replacement. 

The Perfect View team has developed a system that incorporates the better of two 

emerging technologies: remotely piloted aerial systems and thermal imaging. Perfect View has 

developed operating practices to provide customers with a safe, low cost, comprehensive aerial 

inspection program, including: 

Substation Aerial Thermal 

Overhead Power Line Video and photographic vegetation growth inspections 

Overhead Power Line components Thermal inspections 

Post Storm damage assessment 

Live video Streaming (Thermal and HD) 

The Perfect View team consists of individuals who have been active members of the 

UAS hobbyists community and have a combined experience of over 40 years operating small 

UAS. As a result, they have a keen awareness of issues affecting the safe use ofUAS and the 

importance of thorough planning for both normal operations and for contingencies that might 

affect the safety of flight. 

The contact information for Petitioner is as follows: 

Perfect View Aerial Media, LLC 

Attn: Ben Richardson 

7379 Lions Gate Rd. 

Suite 108 

Coconut Creek, FL 33073 

email:info@pvam.net 

II. RELEVANT STATUTORY AUTHORITY 
U.S. Department of Transportation 

October 14, 2014 

Page4 

This petition for exemption is submitted in accordance with the Section 333(a) through 

(c) ofthe FAA Modernization and Reform Act of2012. Congress has directed the FAA "to 

safely accelerate the integration of civil unmanned aircraft systems into the national airspace 

system." Pursuant to Section 333 ofthe Reform Act, the FAA Administrator is to permit 

unmanned aircraft systems to operate in the National Airspace System ("NAS") where it is safe 

to do so based on the following considerations: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within the visual line of sight of the operator. 1 

Additionally, the FAA Administrator has general authority to grant exemptions from its 

safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the 

Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a), (b) and§§ 

44702-44716, et seq.). A party requesting an exemption must explain the reasons why the 

exemption: ( 1) would benefit the public as a whole, and (2) would not adversely affect safety (or 

how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 

(petitions for exemption). 

III. PERFECT VIEW AERIAL MEDIA'S PROPOSED UAS OPERATIONS MEET 

THE REQUIREMENTS OF SECTION 333 OF THE REFORM ACT 

The proposed operations in this petition for exemption qualify for expedited approval 

under Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are 

satisfied. 

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and 

Operational Capability 

Perfect View will employ the DJI S-1 000 octo copter for its electric infrastructure 

inspection operations. This UAS has a maximum take-off weight of24 pounds. The UAS's 

flight speed will not exceed 30 miles per hour, and it will not be flown in controlled airspace or 

at an altitude that exceeds 400 feet AGL. All flights will be flown in such a way that they can be 

1 ld at§ 333(b)(1). 
U.S. Department of Transportation 

October 14, 2014 

Page 5 

safely terminated with a reserve battery power of25% maximum charge. The DJI S-1000 does 

not carry any flammable propellant or fuel. 

The :011 S-1 000 also has redundant motor capabilities, and the vehicle is still capable of 

flight in the event a motor fails unexpectedly. The vehicle is capable of compensating for an 

engine loss automatically, and action is not required by the PIC. 

The DJI S-1 000 also has features that can alert the PIC to the possibility of a lost link 

before it occurs. Because the video link is at a shorter wavelength than the control links, it is 

more susceptible to loss than the control link. Loss of the video signal warns the PIC that action 

should be taken to ensure continued control. In the event the control link is lost, the UAS is also 

equipped with a failsafe setting that permits the vehicle to return to a preselected home point. 

In the absence of a UAS, many of these inspections would have to be carried out by a 

helicopter or by sending someone up to perform the inspection manually. Utility inspections by 

helicopter are carried out at speed up to 70 knots, and the risk of a wire strike or other collision is 

much greater than with the UAS. See Helicopter Assoc. Int'l, Utilities, Patrol and Construction 

Safety Guide for Helicopter Operators at 2-1. Moreover, conducting helicopter inspections at 

certain locations, such as substations where several transmission lines converge, carry additional 

risks to helicopters. Id. at 3-3. It should also be kept in mind that, due to the low altitude of 

power line inspection flights, the ability of a helicopter pilot to successfully conduct an 

autorotation in the event of an engine failure may be limited or impossible. I d. at 2-3. For 

example, in 2009, the crew of a helicopter and a pedestrian on a sidewalk were killed when a 

helicopter conducting a power line inspection suffered an engine failure and could not autorotate 

successfully. http://www. tsb.gc.caleng/rappmts-reports/aviation/2008/a08p0 125/a08p0 125 .pdf. 

Given the small size of the selected UAS and the restricted environment within which 

they will operate, this petition for exemption falls within the zone of safety, i.e., an equivalent 

level of safety, in which Congress directed the FAA to permit commercial UAS operations by 

exemption pending completion of formal rulemaking. 

B. Approval is Warranted Based on the Operational Restrictions Set Forth in 

the Operations Manual 

The Perfect View Operations Manual and manufacturer's maintenance and flight manuals 

contain all of the procedures and limitations necessary to successfully perform inspection of 

power infrastructure. To assist the FAA in its safety assessment of Perfect View's operations, 

below is a summary of operational limitations and conditions which will ensure an equivalent or 

higher level of safety for operations conducted under current regulatory guidelines: 
U.S. Department of Transportation 

October 14, 2014 

Page 6 

1. The UAS will weigh 24 pounds or less. 

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

3. Maximum total flight time for each operational flight will be limited to the 

amount oftime the UAS can be flown and still maintain a reserve battery power 

of no less than 25%. 

4. Flights will be operated at an altitude of no more than 400 feet AGL and will not 

be conducted within navigable airspace. 

5. Flights will be operated at a lateral distance ofleast 200 feet from any inhabited 

structures, buildings, vehicles or vessels, or from people not associated with the 

operation who have not given permission in advance of the operation. 

6. Minimum crew for each operation will consist of the UAS Pilot, one or more 

Visual Observers as necessary to safely conduct the mission, and a Sensor 

Operator if required. 

7. The Pilot will have a private pilot's license and is required to complete 64 hours of 

training and instruction prior to any flight in accordance with the training syllabus 

attached to the Operations Manual. 

8. The observer designated for any operation will be required to complete the 

training course as set forth in the Operations Manual before performing his duties 

on any flight. 

9. The UAS will operate in accordance with the safety and operational requirements 

of the Manual. 

10. Prior to the operation, a Mission Plan will be created setting forth the limitations 

for the flight as well as contact and hazard information provided by the utility. 

11. A NOT AM will be issued not more than 72 hours in advance of flight, but not 

less than 48 hours before flight. 

12. Pilot, Visual Observer and Sensor Operator will at all times be able to 

communicate by voice. 

13. A Certificate of Authorization will be obtained prior to flight. 
U.S. Department of Transportation 

October 14, 2014 

Page 7 

14. All required permissions and permits will be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire or other 

appropriate governmental agencies. 

15. The operator will coordinate all flights with the appropriate Flight Standards 

District Office. 

16. If the UAS loses communications or loses its GPS signal, the UAS will have the 

capability to return to a pre-determined location within the operational area and 

land. 

17. Contingency plans will be in place to safely terminate flight ifthere is a loss of 

communication between the pilot and the observer. 

18. The UAS will have the capability to abort a flight in case ofunpredicted 

obstacles or emergencies. 

IV. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined 

under§ 40101 of the Act, including UASs, from its safety regulations and minimum standards 

when the Administrator decides a requested exemption is in the public interest? 

Petitioner seeks an exemption from several interrelated provisions of 14 C.F .R. Parts 21, 

45, 61 and 91 for purposes of conducting the requested operations using a UAS. Listed below 

are (1) the specific sections of 14 C.F.R. for which exemption is sought, and (2) the operating 

procedures and safeguards that Petitioner has established which will ensure a level of safety 

better than or equal to the rules from which exemption is sought. 3 

2 See 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations 

prescribed pursuant to Sections 44701(a) and (b) and Sections 44702- 44716). 

3 See 14 C.F.R. § 11.81(e), which requires a petition for exemption to include: 

The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which you seek exemption. 
U.S. Department of Transportation 

October 14, 2014 

Page 8 

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 

91.203(a)(1) 

The FAA has stated that no exemption is needed from this section if a finding is made 

under the Reform Act that the UAS selected provides an equivalent level of safety over aircraft 

normally used for the same application. These criteria are met, and therefore, no exemption is 

needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA-2014-0352 at 13-14,22. 

If, however, the FAA determines that there are some characteristics ofthe chosen UAS that fail 

to meet the requirements of the Reform Act, an exemption is requested. 

Equivalent Level of Safety 

The UAS Perfect View will operate is safe taking into account its size, weight, speed, and 

operational capability. As set forth in Section II, Supra, the vehicle has a maximum take-off 

weight of 24 pounds, will be flown at less than 30 miles per hour and completely outside 

controlled airspace. 

Power line inspection is currently carried out using helicopters that can weigh in excess 

of6,000 pounds and carry a large load offuel. Given the low altitude, helicopters cannot fly 

these missions as safely as a UAS, and there is a history of accidents that have killed not only 

flight crews but innocent bystanders on the ground due the inability to successfully autorotate in 

the event of an engine failure. 4 Similarly, the damage to critical infrastructure that results from a 

helicopter striking a transmission line or substation is far greater than if a small UAS has the 

same accident. As a result, national security is enhanced by substituting a UAS for a manned 

helicopter. 

In all cases, an analysis ofthese 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 as, or safer than, a conventional rotorcraft operating with an airworthiness 

certificate without the restrictions and conditions of the proposed UAS operations. 

The aircraft itself does not need a means to communicate with other aircraft or ATC, 

because those capabilities will be with the pilot and observer who are not onboard. See Grant of 

Exemption, Docket FAA-2014-0352 at 13. In addition, no sense and avoid technology is 

necessary on the UAS because it will be operated at all times by visual line-of-sight. Id. The 

device has onboard capabilities to autonomously handle lost link situations. 

4 http://www. t b.gc.caleng/rapports-reports/aviation/2008/a08p0 125/a08p0 125 .pdf. 
U.S. Department of Transportation 

October 14, 2014 

Page 9 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category 

Rotorcraft 

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of 

normal category rotorcraft. To the extent the Petitioner's UAS would otherwise require 

certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards 

for the same reasons identified in the exemption request from 14 C.F.R. Part 21, Subpart H. 

C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and 

Identification Requirements 

Petitioner seeks an exemption from the aircraft marking and identification requirements 

contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 

• 14 C.P.R.§ 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, 

provides that: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is 

identified in accordance with Part 45 of this chapter. 

• 14 C.F.R. § 45.23(b), Markings ofthe Aircraft, states: 

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. 

• 14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces ofthe cabin, fuselage, boom, or tail the marks required by§ 45.23. 

In its previous Grant of Exemption, the FAA determined that exemption from these 

requirements was warranted provided that the aircraft "have identification (N-Number) markings 

in accordance with 14 CFR part 45, Subpart C if the markings are as large as practicable." FAA 

Docket No. FAA-2014-0352. 

Equivalent Level of Safety 

Perfect View will mark all aircraft with their N-Number in a prominent spot on the 

fuselage with markings that are as large as practicable. 
U.S. Department of Transportation 

October 14, 2014 

Page 10 

D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and 

Registration 

Pursuant to 14 C.F.R. § 91.9(b)(2): 

(b) No person may operate a U.S.-registered civil aircraft-

(2) For which an Airplane or Rotorcraft Flight Manual is not required by§ 21.5 of 

this chapter, unless there is available in the aircraft a current approved airplane or 

Rotorcraft Flight Manual, approved manual material, markings and placards, or 

any combination thereof. 

Pursuant to 14 C.F.R. § 91.203(a) and (b): 

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

has within it the following: 

(1) An appropriate and current airworthiness certificate ... 

(b) 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 or crew. 

Perfect View does not request an exemption from this section but instead notifies the 

FAA that, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, the 

UAS flight manual, registration certificate and other documentation will be kept at the control 

station with the PIC during flight. The Chief Counsel's Office has held that for all UAS 

operations, this alternate method constitutes full compliance with the regulations. 

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil 

aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is 

required to the extent that the requirements of Part 21 are waived or found inapplicable. 

Accordingly, Petitioner request that the requirements for Section 91.7 are treated in accordance 

with Section V(A), supra. 
U.S. Department of Transportation 

October 14, 2014 

Page 11 

F. 14 C.F.R. § 91.103: Preflight Action 

Petitioner seeks an exemption from 14 C.F .R. § 91.103, which requires a PIC to become 

familiar with specific information before each flight, including information contained in the 

FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all 

information necessary to safely conduct the flight, an exemption is requested to the extent that an 

FAA-approved Flight manual is required. 

Equivalent Level of Safety 

An equivalent level of safety will be provided by following the Aircraft Operations 

Manual and flight manual provided by the manufacturer. The PIC will take all required preflight 

actions- including performing all required checklists and reviewing weather, flight battery 

requirements, landing and takeoff distance, aircraft performance data, and contingency landing 

areas - before initiation of flight. The Aircraft Operations Manual and manufacturer's flight 

manual will be kept at the ground station with the operator at all times. 

G. 14 C.F.R. § 91.109(a): Flight Instruction 

Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "[n]o 

person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted 

aircraft, by their design, do not have functional dual controls. Instead, flight control is 

accomplished through the use of a device that communicates with the aircraft via radio 

communications. 

Equivalent Level of Safety 

Given the size and speed of the UAS, an equivalent level of safe training can still be 

performed without dual controls because no pilot or passengers are aboard the UAS, and all 

persons will be a safe distance away in the event that the UAS experiences any difficulties during 

flight instruction. 

In addition, Petitioner has established a flight training program that will be administered 

by a certified flight instructor. That training program includes both classroom instruction as well 

as supervised flight training employing the same aircraft that will be used operationally to 

conduct power infrastructure inspections. Accordingly, Perfect View's proposed method of 

operation provides superior levels of safety. 

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

Petitioner requests an exemption from the minimum safe altitude requirements of 14 

C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may 
U.S. Department of Transportation 

October 14, 2014 

Page 12 

not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or 

structure in non-congested areas. See 14 C.F .R. § 91.119( c). Section 91.119( d) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated "without 

hazard to persons or property on the surface," provided that "each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA." 

Equivalent Level of Safety 

Compared to flight operations with rotorcraft weighing far more than the maximum UAS 

weight proposed herein, and given the lack of flammable fuel, any risk associated with these 

operations is far less than those that presently exist with conventional aircraft. An 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. In order to avoid any risk to aircraft, flight operations will be 

restricted to 400' AGL or below. As set forth in the Manual, the UAS will be operated in a 

restricted area, away from persons or structures not involved in the operation. 

I. 14 C.F.R. § 91.121: Altimeter Settings 

This petition seeks an exemption from 14 C.P.R.§ 91.121, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that 

is set to the elevation of the departure airport or barometric pressure. An exemption is required 

to the extent that the UAS does not have a barometric altimeter, but rather a GPS altitude read 

out. 

Equivalent Level of Safety 

The FAA has stated that an equivalent level of safety can be achieved ifthe UAS will be 

operated at 400' or below and within visual line-of-sight in addition to GPS based altitude 

information relayed in real time to the operator. See Grant of Exemption to Astraeus Aerial, 

Docket No. FAA-2014-0352. As the attached Operations Manual indicates, the chosen UAS 

meets these requirements, and a zero altitude initiation point will be obtained prior to flight. 

J. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR 

Conditions 

Petitioner requests an exemption from 14 C.P.R.§ 91.151(a)'s fuel requirements for flight 

in VFR conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing and, assuming normal cruising speed -

(1) During the day, to fly after that for at least 30 minutes; or 
U.S. Department of Transportation 

October 14, 2014 

Page 13 

(2) At night, to fly after that for at least 45 minutes. 

Here, the technological limitations on UAS battery power means that no meaningful 

flight operations can be conducted while still maintaining a 30 minute reserve. Perfect View 

proposes that all flights comply with this requirement by mandating that the aircraft be safely 

landed with no less than 25% of battery life remaining. 

Equivalent Level of Safety 

The FAA has stated that an equivalent level of safety is provided ifthe UAS flight is 

terminated with at least 25% reserve battery power still available. See Grant of Exemption to 

Astraeus Aerial, Docket No. FAA-2014-0352. The Operations Manual conforms to this limit, 

providing an equivalent level of safety. 

K. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections 

Petitioner seeks an exemption from the maintenance inspection requirements contained in 

14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 

91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ... have discrepancies 

repaired as prescribed in part 43 of this chapter"). An exemption to these regulations is needed 

because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which 

the UAS will not have. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because maintenance and inspections will 

be performed in accordance with the UAS Manufacturer's Manual, as referenced in the 

Operations Manual. As provided in the Operat ons Manual, flights will not be conducted unless 

a flight operations checklist is performed that includes all of the aircraft's components. The 

Operations Manual also sets requirements for maintenance log books and record keeping as well 

as routine and post-flight maintenance. The Manual sets requirements for both annual 

maintenance and preventative maintenance based on hours of flight. 

L. 14 CFR § 61.113: Private Pilot Privileges And Limitations 

Petitioner seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate 

holders from flying aircraft for compensation or hire, and would also require a second class 

medical certificate. The purpose of Part 61 is to ensure the skill and competency of any PIC 

matches the airspace in which the PIC will be operating, as well as requiring certifications if the 

private pilot as carrying passengers or cargo for hire. In this case, while the UAS will be 
U.S. Department of Transportation 

October 14, 2014 

Page 14 

operated as part of a commercial operation, it carries neither passengers nor cargo. In the Grant 

of Exemption in FAA Docket No. FAA-2014-0352, the FAA determined that the unique 

characteristics ofUAS operation outside of controlled airspace did not warrant the addition cost 

and restrictions attendant with requiring a the PIC to have a commercial pilot certificate and 

class II medical certificate. 

Perfect View will employ licensed private pilots as PIC for their operation. The 

restrictions Perfect View has placed on its UAS operations meet or exceed the restrictions 

similarly imposed on Astraeus Aerial in FAA Docket No. F AA-2014-0352. Perfect View will 

operate in a sterile area way from persons and property not involved in the inspection. It will be 

flown based on VLOS and below 400' AGL. A NOT AM will be issued between 48 and 72 hours 

before the flight is to occur, and the flight will be coordinated with the applicable FSDO. 

Equivalent Level of Safety 

In addition to these flight restrictions, Perfect View will further ensure safe operation by 

requiring that any PIC be thoroughly versed not only in airspace and communication issues 

pertaining to all aircraft operators but also in the unique aspects ofUAS flight. Accordingly, as 

set forth in the Operations Manual, Perfect View has created specific training programs for both 

pilots and observers to meet this need. The course syllabus is attached to the Operations Manual. 

All training will be provided by an FAA-certified Flight Instructor. Petitioner believes that this 

system will provide a higher level of competency and proficiency for its pilots than simply 

permitting those with either a private pilot license to act as PIC by default. In addition, all 

observers and PIC will have a class III medical certificate. 

V. DRUG AND ALCOHOL PROGRAM 

As set forth in the Manual, Perfect View is committed to a drug-free work place and the 

right of the flying public it serves to safe and efficient air transportation. All employees of 

Perfect View who perform safety sensitive and/or security related functions are prohibited from 

performing work if they have alcohol or a prohibited drug in their system. 

VI. PUBLIC INTEREST 

Granting Perfect View's exemption request furthers the public interest. National policy 

set by Congress favors early integration ofUAS into the NAS in controlled, safe working 

environments such as those proposed in this petition. In addition, maintaining industrial safety 

has been a priority of state and local governments for decades. By their nature, each of the 

proposed uses of a UAS offer superior safety to performing the same tasks with conventional 

aircraft or rotorcraft. 

In addition, the public also has an interest in reducing the hazards and emissions 

associated with alternate use of helicopters to conduct similar inspection operations. The UAS in 
.· 

U.S. Department of Transportation 

October 14, 2014 

Page 15 

question is very light weight and does not carry any flammable fuel, further reducing the risk 

from any potential accident. 

VII. PRIVACY 

All flights will be conducted in accordance with any federal, state or local laws regarding 

pnvacy. 

VIII. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C;F .R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Perfect View seeks an exemption from the following rules: 

14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 CFR § 61.113; 14 

CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR 

91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 

14 CFR 91.409(a)(2); 14 CFR 91.417 (a) & (b). 

Approval of these exemptions will allow Perfect View to offer thermal and photographic 

inspection of power infrastructure, including power lines and substations. The exemptions will 

enhance safety by reducing risk to the general public and property owners from the substantial 

hazards associated with performing equivalent work with conventional rotorcraft. 

IX. CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012-size, 

weight, speed, operating capabilities, proximity to airports and populated areas, operation within 

visual line of sight, and national security-provides more than adequate justification for the grant 

of the requested exemptions to permit Perfect View to operate the selected UAS and provide 

inspection services for power infrastructure. 

Granting the requested exemption will benefit the public interest as a whole in many 

ways, including (1) significantly improving safety and reducing risk by alleviating human 

exposure to danger, and (2) improving the quality of services and decreasing operating costs 

compared with conventional flight operations. 

If you have any questions or require any additional information, please do not hesitate to 

call. 
U.S. Department ofTranspottation 

October 14, 2014 

Page 16 

It:::. :.:.LDRIDGE, LLP 

Attachments: PVAM Operations Manual (submitted as a Confidential Document under 14 

C.F.R. § 11.35(b) and exempt from disclosure under the Freedom of Information Act, 5 U.S.C. 

§ 552 et seq., and any other requirements established by the FAA pursuant to Section 333 of the 

Reform Act).