Albany Atlanta Brussels Denver 

# McKenna Long 

# &Aldridge. u·

1676 International Drive • Penthouse Mclean. VA 22102 Northern Virgin ia Orange County Rancho Santa Fe San Diego Los Angeles Tel: 703.336.8800 mckennalong.com San Francisco Miami Seoul NewYork Washington, DC

MARK E. MCKINNON 703.336

.8708 EMAIL ADDRESS mmckinnonf@mckennalong.com

U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 October 14, 2014

Re: Petition ofPerfect View Aerial Media, LLC for an Exemption Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 Dear Gentlemen: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 ("Reform Act") and 14 C.F.R. Part 11, PerfectView Aerial Media, LLC ("Perfect View"), hereby applies for anexemption from the Federal Aviation Regulations ("FARs") identified below, to allow commercial operations ofsmall unmanned aerial vehicles (i.e., "small unmanned aircraft" or "UAS"). This exemption is made based on the information inthis petition, as well as the accompanying Perfect View Operations and Safety Manual ("Operations Manual") and the DJI S-1000 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 informationthat the Petitionerhas 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 oflnformationAct, 5 U.S.C. § 552 

### et seq., and any other requirements established by the FAApursuantto Section 333 oftheFAA Reform Act. For your convenience, the petition is organized as follows: 

### I. Description ofPetitioner II. Relevant Statutory Authority III. Perfect View Aerial Media's Proposed UAS Operations Meet The Requirements Of Section 333 OfThe Reform ActU.S. Department ofTransportation October 14, 2014 Page 2



### IV. Regulations From Which Exemption is Requested A. 14 C.F.R. Part21, SubpartH- Airworthiness Certificates and 14 C.F.R. 

### § 91.203 B. 14 C.F.R. Part27 Airworthiness Standards: Normal Category Rotorcraft C. 14 C.F.R. 

### § § 91.9(c), 45.23(b) and 45.27(a): AircraftMarking and Identification Requirements D. 14 C.F.R. 

### § 91.9(b)(2): Civil Aircraft FlightManual 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 AircraftAirworthiness F. 14 C.F.R. 

### § 91.103: PreflightAction G. 14 C.F.R. 

### § 91.109(a): FlightInstruction H. 14 C.F.R. 

### § 91.119: Minimum SafeAltitudes I. 14 C.F.R. 

### § 91.121: Altimeter Settings 

### J. 14 C.F.R. 

### § 91.151(a): FuelRequirements 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): MaintenanceInspections L. 14 CFR 

### § 61.113 V. Drug and Alcohol Program VI. Public Interest VII. Privacy VIII. FederalRegister Summary IX. Conclusion I. DESCRIPTION OF PETITIONER Perfect View seeks the requested exemptions to permit itto offer thermal and optical imaging and inspections ofelectric power infrastructure. In addition, PerfectView seeks authority to conduct flights for training and maintenance purposes in a sterile area free from hazards andpersons. Perfect Viewhas 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 Viewpersonnel have longstanding experience in conducting electric power infrastructure inspections and are well aware ofthe special safety issues that arise from working inthis environment. The Perfect View Team consists ofProfessional Electrical Engineers, Electrical Operations Managers, FAALicensed Pilots, Certified Thermographers and professional photographers.U.S. Department ofTransportation October 14, 2014 Page 3

The delivery ofreliable 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. Itis critical in everyday life, at home, on the road, in business and for public safety. That is whythe most successful utility companies take every precautionto 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 ofenergized 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 ofstates prompted utilities to become more cost-competitive, leadingto the outsourcing ofinfrastructure work to contractors who could do thejob more efficiently. Moreover, much ofthe transmission and distribution infrastructure inthe United States is aging and in need ofrepair or replacement. The PerfectView team has developed a system that incorporates the better oftwo emerging technologies: remotelypiloted aerial systems and thermal imaging. PerfectViewhas developed operating practices to provide customers with a safe, low cost, comprehensive aerial inspectionprogram, including: SubstationAerial Thermal Overhead PowerLine Video andphotographic vegetation growth inspections Overhead Power Line components Thermal inspections Post Storm damage assessment Live video Streaming (Thermal and HD) The Perfect Viewteamconsists ofindividuals who have been active members ofthe UAS hobbyists community andhave a combined experience ofover 40 years operating small UAS. As aresult, they have a keen awareness ofissues affecting the safe use ofUAS and the importance ofthorough planning for bothnormal operations and for contingencies that might affect the safety offlight. The contact information for Petitioner is as follows: Perfect ViewAerial Media, LLC Attn: Ben Richardson 

### 7379 Lions Gate 

### Rd. Suite 108 Coconut Creek, FL 33073 email:info@pvam.net



### II. RELEVANT STATUTORY AUTHORITYU.S. Department ofTransportation October 14, 2014 Page4

This petition for exemption is submitted in accordance withthe Section 333(a) through (c) ofthe FAA Modernization and Reform Act of2012. Congress has directed the FAA "to safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system." Pursuantto 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 ofthe UAS in close proximityto airports andpopulated areas; and

• Operation ofthe UAS within the visual line ofsight ofthe operator. 1 Additionally, the FAAAdministrator has general authority to grant exemptions from its safety regulations and minimum standards whenthe Administrator decides a requested exemptionis inthe public interest. See 49 U.S.C. § 106(f) (defining the authority ofthe Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a), (b) and§§ 44702-44716, 

### etseq.). A party requesting an exemptionmust explainthe reasons why the exemption: (1) would benefit thepublic as a whole, and (2) would not adversely affect safety (or howit wouldprovide a level ofsafety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption).



### III. PERFECTVIEW AERIAL MEDIA'S PROPOSED UAS OPERATIONSMEET THE REQUIREMENTS OF SECTION 333 OF THE REFORMACT The proposed operations inthis petition for exemption qualify for expedited approval under Section 333 ofthe Reform Act. Each ofthe statutory criteria and other relevant factors are satisfied. 

### A. Approvalis Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability PerfectView will employ the DJI S-1000 octocopter for its electric infrastructure inspection operations. This UAS has a maximum take-offweight of24pounds. 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 ofTransportation 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-1000 also has redundant motor capabilities, and the vehicle is still capable of flight inthe event a motor fails unexpectedly. The vehicle is capable ofcompensating for an engine loss automatically, and action is not required bythe PIC. The DJI S-1000 also has features that can alert the PIC to the possibility ofa 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 ofthe 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 preselectedhome point. In the absence ofa UAS, many ofthese inspections would have to be carried out by a helicopter orby sending someone up to performthe inspectionmanually. Utility inspections by helicopter are carried out at speedup to 70 knots, and the risk ofa wire strike or other collision is much greaterthanwith 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 inmind that, due to the low altitude of power line inspection flights, the ability ofa helicopterpilotto successfully conduct an autorotation in the event ofan engine failure may be limited or impossible. Id. at 2-3. For example, in 2009, the crew ofa helicopter and a pedestrian on a sidewalkwere 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/a08p0125/a08p0 125.pdf. Given the small size ofthe selected UAS and the restricted environment within which they will operate, this petitionfor exemption falls withinthe zone ofsafety, i.e., an equivalent level ofsafety, in which Congress directed the FAAto permit commercial UAS operations by exemptionpending completion offormal 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 oftheprocedures and limitations necessary to successfully perform inspection of power infrastructure. To assist the FAA in its safety assessment ofPerfect View's operations, below is a summary ofoperational limitations and conditions whichwill ensure an equivalent or higher level ofsafety for operations conducted under current regulatory guidelines:

### U.S. Department ofTransportation October 14, 2014 Page 6

1. The UAS will weigh 24 pounds or less. 2. Flights will be operated within line ofsight ofa pilot and observer. 3. Maximumtotal flight time for each operational flight will be limited to the amount oftimethe UAS can be flown and still maintain a reserve battery power ofno less than 25%. 4. Flights will be operated at an altitude ofno more than 400 feet AGL and will not be conducted within navigable airspace. 5. Flights will be operated at a lateral distance ofleast200 feet from any inhabited structures, buildings, vehicles or vessels, or from people not associated with the operation who have not givenpermission in advance ofthe operation. 6. Minimum crewfor each operationwill consist ofthe UAS Pilot, one or more Visual Observers as necessary to safely conductthe mission, and a Sensor Operator ifrequired. 7. The Pilot will have a private pilot's license and is required to complete 64 hours of training and instructionprior to any flight in accordance withthe 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 inthe Operations Manual before performinghis duties on any flight. 9. The UAS will operate in accordance with the safety and operational requirements ofthe Manual. 10. Priorto the operation, a Mission Plan will be created setting forth the limitations for the flight as well as contact and hazard informationprovided bythe utility. 11. A NOTAM will be issued not more than 72 hours in advance offlight, 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 ofAuthorization will be obtained priorto flight.U.S. Department ofTransportation October 14, 2014 Page 7

14. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 15. The operator will coordinate all flights withthe appropriate Flight Standards District Office. 16. Ifthe 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. Contingencyplans will be inplace to safelyterminate flight ifthere is a loss of communication betweenthe pilot and the observer. 18. The UAS will have the capabilityto abort a flight in case ofunpredicted obstacles or emergencies.



### IV. REGULATIONS FROMWHICHEXEMPTIONIS 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 ofthe Act, including UASs, from its safety regulations and minimum standards whenthe Administrator decides a requested exemption is inthe public interest? Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61 and 91 for purposes ofconducting 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 ofsafety betterthan or equal to the rules from which exemptionis sought.3

2 See 49 U.S.C. § 44701(f) (authorizingthe grant ofexemptions from requirements ofregulations prescribed pursuant to Sections 44701(a) and (b) and Sections 44702- 44716). 3 See 14 C.F.R. § 11.81(e), which requires apetition for exemptionto include: The reasons why grantingthe exemption would not adversely affect safety, or how the exemption would provide a level ofsafety at least equal to that provided by the rule from whichyou seek exemption.U.S. Department ofTransportation 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 FAAhas stated that no exemption is needed from this section ifa finding is made under the Reform Actthatthe UAS selected provides an equivalent level ofsafety over aircraft normally used for the same application. These criteria are met, and therefore, no exemption is needed. See Grant ofExemptionto Astraeus Aerial, DocketNo. FAA-2014-0352 at 13-14,22. If, however, the FAA determines thatthere are some characteristics ofthe chosenUAS that fail to meet the requirements ofthe Reform Act, an exemption is requested. 

### Equivalent Level ofSafety 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 of24 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. Giventhe low altitude, helicopters cannot fly these missions as safely as a UAS, andthere is a history ofaccidents that have killed not only flight crews but innocent bystanders onthe ground due the inability to successfully autorotate in the event ofan engine failure. 4 Similarly, the damage to critical infrastructure that results from a helicopter striking a transmissionline or substation is far greater than ifa 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, inthe 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 withoutthe restrictions and conditions ofthe proposed UAS operations. The aircraft itselfdoes 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 onthe UAS because it will be operated at all times byvisual 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/a08p0125/a08p0 125.pdf.U.S. Department ofTransportation 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 identificationrequirements 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 Placardrequirements, provides that: No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with Part 45 ofthis chapter.

• 14 C.F.R. § 45.23(b), Markings ofthe Aircraft, states: Whenmarks include onlythe Roman capital letter "N" and the registration number is displayed onlimited, restricted or light-sport category aircraft or experimental orprovisionally certificated aircraft, the operatormust also display on that aircraft near each entrance to the cabin, cockpit, orpilot 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 ofa rotorcraft must display onthatrotorcrafthorizontally on both surfaces ofthe cabin, fuselage, boom, ortail the marks required by§ 45.23. Inits previous Grant ofExemption, the FAA determined that exemption from these requirements was warrantedprovided that the aircraft "have identification (N-Number) markings in accordance with 14 CFRpart45, Subpart C ifthe markings are as large as practicable." FAA DocketNo. FAA-2014-0352. EquivalentLevel ofSafety 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 ofTransportation 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 Pursuantto 14 C.F.R. § 91.9(b)(2): (b) No personmay 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 inthe aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings and placards, or any combinationthereof. Pursuantto 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 personmay operate a civil aircraft unless the airworthiness certificate required byparagraph (a) ofthis section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpitentrance so that it is legible to passengers or crew. Perfect View does not request an exemption from this sectionbutinstead notifies the FAAthat, in accordance with FAA Office ofChiefCounsel'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 ChiefCounsel'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 aircraftbe in airworthy conditionto be operated. The FAA has stated that no exemption is required to the extentthat the requirements ofPart 21 are waived or found inapplicable. Accordingly, Petitioner request thatthe requirements for Section 91.7 are treated in accordance with Section V(A), supra.U.S. Department ofTransportation 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 informationbefore each flight, including information contained in the FAA-approved Flight Manual onboard the aircraft. While the PIC will be familiar with all information necessary to safely conduct the flight, an exemption is requested to the extentthat an FAA-approved Flight manual is required. Equivalent Level ofSafety An equivalent level ofsafety will be providedby 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 takeoffdistance, aircraft performance data, and contingency landing areas - before initiation offlight. The Aircraft Operations Manual and manufacturer's flight manual will be kept atthe 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), whichprovides 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 accomplishedthroughthe use ofa device that communicates withthe aircraft viaradio communications. Equivalent Level ofSafety Giventhe size and speed ofthe UAS, an equivalent level ofsafe 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 eventthatthe UAS experiences any difficulties during flight instruction. In addition, Petitionerhas established a flight training programthatwill be administered by a certified flight instructor. Thattraining program includes both classroom instruction as well as supervised flight training employing the same aircraft that will be used operationally to conductpower infrastructure inspections. Accordingly, Perfect View's proposedmethod of operationprovides superior levels ofsafety. H. 14 C.F.R. § 91.119: Minimum Safe Altitudes Petitioner requests an exemptionfrom the minimum safe altitude requirements of 14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft mayU.S. Department ofTransportation 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 helicopterto operate at less than those minimum altitudes when it can be operated "without hazard to persons orproperty on the surface," provided that "eachperson operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." Equivalent Level ofSafety Compared to flight operations with rotorcraft weighing far more than the maximum UAS weight proposed herein, and giventhe lack offlammable fuel, any risk associated with these operations is far less than those that presently exist with conventional aircraft. An equivalent level ofsafety will be achieved given the size, weight, and speed ofthe 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 orbelow. As set forth inthe 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, whichrequires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is setto the elevation ofthe departure airport orbarometric pressure. An exemption is required to the extent that the UAS does not have a barometric altimeter, butrather a GPS altitude read out. EquivalentLevelof Safety The FAA has stated that an equivalent level ofsafety can be achieved ifthe UAS will be operated at 400' orbelow and within visual line-of-sight in addition to GPS based altitude informationrelayed in real time to the operator. See Grant ofExemptionto Astraeus Aerial, Docket No. FAA-2014-0352. As the attached Operations Manual indicates, the chosen UAS meets these requirements, and a zero altitude initiationpointwill be obtained prior to flight. J. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Petitionerrequests 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 ofintended landing and, assuming normal cruising speed

- (1) During the day, to fly after that for at least 30 minutes; orU.S. Department ofTransportation October 14, 2014 Page 13 (2) At night, to fly after that for at least 45 minutes. Here, the technological limitations onUAS battery powermeans that no meaningful flight operations canbe conducted while still maintaining a 30 minute reserve. PerfectView proposes that all flights comply with this requirement by mandating that the aircraft be safely landed with no less than 25% ofbattery life remaining. Equivalent Level ofSafety The FAA has stated that an equivalent level ofsafety is provided ifthe UAS flight is terminated with at least 25% reserve battery power still available. See Grant ofExemptionto Astraeus Aerial, DocketNo. FAA-2014-0352. The Operations Manual conforms to this limit, providing an equivalent level ofsafety. K. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): MaintenanceInspections Petitioner seeks anexemption 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 inreference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. 

### § 91.405(a) (statingthat each owner or operator ofan aircraft "[s]hall have the aircraft inspected as prescribed in subpart E ofthis part and shall betweenrequired inspections

...have discrepancies repaired as prescribed inpart 43 ofthis chapter"). Anexemption to these regulations is needed because Part43 and these sections only apply to aircraft with an airworthiness certificate, which the UAS will not have. Equivalent Level ofSafety An equivalent level ofsafety will be achieved because maintenance and inspections will beperformed in accordance withthe UAS Manufact urer's Manual, as referenced inthe Operations Manual. As provided inthe Operat onsManual, flights will not be conducted unless a flight operations checklist is performed that includes all ofthe 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 onhours offlight. 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 orhire, and would also require a second class medical certificate. The purpose ofPart 61 is to ensure the skill and competency ofany PIC matches the airspace in which the PIC will be operating, as well as requiring certifications ifthe private pilot as carrying passengers or cargo for hire. Inthis case, while the UAS will beU.S. Department ofTransportation October 14, 2014 Page 14 operated as part ofa commercial operation, it carries neitherpassengers nor cargo. In the Grant ofExemption inFAA DocketNo. FAA-2014-0352, the FAA determined thatthe unique characteristics ofUAS operation outside ofcontrolled airspace did not warrant the addition cost and restrictions attendant withrequiring a the PIC to have a commercial pilot certificate and class II medical certificate. PerfectView will employ licensedprivate 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 DocketNo. FAA-2014-0352. Perfect View will operate in a sterile area way from persons and property not involved inthe inspection. Itwill be flown based onVLOS and below 400' AGL. A NOT AM will be issued between48 and 72 hours before the flight is to occur, andthe flight will be coordinated with the applicable FSDO. Equivalent Level ofSafety 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 inthe Operations Manual, Perfect Viewhas created specific training programs for both pilots and observers to meetthis need. The course syllabus is attached to the Operations Manual. All training will beprovided by an FAA-certified Flight Instructor. Petitioner believes that this system will provide a higher level ofcompetency andproficiency 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 inthe Manual, Perfect View is committedto a drug-free work place and the right ofthe 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 ifthey have alcohol or a prohibited drug intheir system. VI. PUBLIC INTEREST Granting Perfect View's exemptionrequest 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 ofstate and local governments for decades. Bytheir nature, each ofthe proposed uses ofa UAS offer superior safety to performing the same tasks with conventional aircraft orrotorcraft. In addition, the public also has an interest inreducingthe hazards and emissions associated with alternate use ofhelicopters to conduct similar inspection operations. The UAS in.· U.S. Department ofTransportation 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 Pursuantto 14 C;F.R. Part 11, the following summary is provided for publication inthe Federal Register, should it be determined thatpublication is needed: PerfectView seeks an exemption from the following rules: 14 CFRPart 21, Subpart H; 14 CFRPart 27; 14 CFR45.23(b); 14 CFR § 61.113; 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR91.109(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 CFR91.417 (a) & (b). Approval ofthese exemptions will allow Perfect View to offerthermal and photographic inspection ofpower infrastructure, includingpower lines and substations. The exemptions will enhance safety byreducing riskto the general public and property owners from the substantial hazards associated with performing equivalent work with conventional rotorcraft. IX. 

### CONCLUSION Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Act of2012-size, weight, speed, operating capabilities, proximityto airports andpopulated areas, operation within visual line ofsight, and national security-provides more than adequatejustification for the grant ofthe requested exemptions to permitPerfect Viewto operate the selected UAS and provide inspection services for power infrastructure. Granting the requested exemption will benefitthe public interest as a whole inmany ways, including (1) significantly improving safety and reducing riskby alleviating human exposure to danger, and (2) improving the quality ofservices and decreasing operating costs compared with conventional flight operations. Ifyouhave any questions or require any additional information, please do nothesitate to call.U.S. Department ofTranspottation October 14, 20 14 Page 16 

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

Attachments: 

### PVAM OperationsManual (submitted as a Confidential Document under 14 C.F.R. 

### § 1 1.35(b) and exempt from disclosure underthe Freedom ofInformation Act, 5 U.S.C. 

### § 552 

### et seq., and any other requirements established by theFAA pursuantto Section 333 ofthe Reform Act).