November 1, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam:

This document constitutes an exemption Request under Section 333 of the FAA Modernization and 

Reform Act of 2012 for Aviation Unmanned to perform Aerial Photography & Videography by/for

John Besancon Jr and 360TourVision LLC. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and

14 C.F.R. Part 11, John Besancon Jr and 360TourVision LLC, (360TourVision LLC is a design and 

photography/video company), hereby applies for an exemption from the Federal Aviation Regulations

(FARs) listed below to allow operation of our Small Unmanned Aircraft System (sUAS) commercially in 

airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with 

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

The requested exemption would permit John Besancon Jr and 360TourVision LLC to pursue its commercial

interests in providing services to clients using a small advanced sUAV in the following areas:

•Real Estate

•Marketing and Advertising

•Special Events

John Besancon Jr and 360TourVision LLC states that all sUAS flights will occur over private or controlled 

access property and will do so with the property owner’s consent and knowledge and that only people 

who have consented or otherwise agreed to be in the area where videography will take place.

Regulations from which exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23

14 C.F.R. 61.113 (a) & (b)

14 C.F.R. 91.7

14 C.F.R. 91.9

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151

14 C.F.R. 91.203

14 C.F.R. subpart E 91.401 - 91.417

14 C.F.R. 91.9 (b) (2)

Unmanned Aircraft Systems UAVS are often as seen as superior to helicopters as an aerial gathering platform 

due to the smaller devices, cheaper equipment and personnel cost, reduced noise, and much smaller 

environmental impact which promotes public safety. John Besancon Jr and 360TourVision LLC is petitioning

for an exemption to operate a DJI Phantom 3 Advanced with a built in stabilized HD camera and GPS 

safety features which limit it’s ability to limit the height it flies above ground level (AGL)., to limit the radius 

of the distance it flies from the operator and to exclude it from operations within designated Class B, C, 

and D airspace including a no fly zone feature. The DJI Phantom 3 Advanced also has a failsafe function

that is triggered in the event communication is lost between the sUAS and the main controller transmitter. 

At that time, the sUAS will return to its point of takeoff and land safety. If the connection is restored, the PIC 

can regain control of flight and land manually. These specifications meet with the Model Aircraft Operating 

Standards as set below:
The petitioner will only operate its sUAS in line – of-sight of a pilot and will operate at sites that are 

sufficient distance from populated areas within a sterile area described in the FOPM. Such operations will 

ensure that the sUAS will “not create a hazard to users of the national airspace system or the public.”

When flying the sUAS within five (5) miles of an airport, airport operators will be notified and the 

operator will give the right of way to avoid flying in the proximity of full-scale aircraft. Maximum flight time 

for each operation will be 30 minutes. Flights will be terminated when battery levels reach 25%, allowing

sufficient reserve flight time to safely land the sUAS. The sUAS will be programmed so that it will not be 

operated at an altitude that exceeds 400 fee AGL, and not more than 200 feet above an elevated platform 

from which videography is planned. Minimum crew for each operation will consist of: sUAS pilot

The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (ie: camera, lens, and

stabilized gimbal).

The sUAS will operate at speeds no more than 50 knots, can hover, and can simultaneously move vertically 

and horizontally. Given the small size of the sUAS and the restricted sterile environment within which 

it will operate, John Besancon Jr and 360TourVision 

LLC’s operations adhere to the Reform Act’s safety requirements. 

We respectively request exemption under Section 333 to enable John Besancon Jr and 360TourVision 

LLC to operate efficient, limited, low-risk commercial sUAS operations for the activities stated respecting 

at all times the space and privacy of citizens and property while keeping airspace safe.

As a competent photographer the need to offer photography from a UAS is something that will help my business and clients. 

I am in hopes that this exemption is granted so that I can assist in the ground floor education and lead by good example for 

the good of the people. 

Sincerely,

John Besancon Jr

John Besancon Jr

360TourVision LLC

PO BOX 66266

St Pete Beach, FL 33736

407-495-9398

info@360tourvision.com