### U.S. Department ofTransportation Docket Management System 1200 New JerseyAve. SE Washington, DC 20590 Re: Exemption Request Section 333 ofthe FAA Reform Act Dear Sir/Madam, This petition is being submitted on ourown behalfwithout legal counsel orconsulting services. Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act), and 14 C.F.R. Part 11 , ParrottVision Productions (PVP) operating a Small Unmanned Aircraft System (sUAS) equipped to conduct aerial photography and survey forvarious industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed belowto allow operation ofoursUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and underthe conditions outlined herein oras may be established by the FAA as required by Section 333. The requested exemption would permit ParrottVision Productions to pursue its commercial interests in providing services to consumers interested aerial data capture using a small advanced sUAS in the following areas: 

# • • • • • • Agricultural Surveying sUAS OperatorTraining Real Estate Photography Product Demonstrations Research and Development Aerial 3D Renderings PVP states that all sUAS flights thatwill occurover private orcontrolled access property will do so with the property owner's priorconsent and knowledge and that only people who have consented or otherwise have agreed to be inthe area where photography and videographywill take place will be captured. PVP understandsthe proper roles ofan observer, communication procedures, propervisual scan techniques, operations at non-towered airports, and appropriate sections ofthe Aeronautical Information Manual.April 11lh 2015 Regulations from which the exemption is requested: 14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) 

### & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401 - 91.417) Unmanned Aircraft System sUAS are a feasible method to obtain information ofagricultural cropland to determine optimum inputsthat result in cost savings to farmers, yield security, and reduce environmental impact ofexcess fertilizers and chemicals in the soil. We are petitioning for exemption to enable PVP to operate a multi-rotorequipped with a three-axis gimbaled camera, a OJI Inspire 1 multi-rotorequipped with a three-axis gimbaled camera, a OJI S-900 multirotor equipped with a three-axis gimbaled camera. These sUAS all weigh lessthan 25 lbs, have a built- in capability to limitthe height itflies above the ground, to limitthe radius ofthe distance itflies from the operatorand to exclude itfrom Class B, C and D airspace including a no fly zone feature. Each system also hasthe failsafe function ofthe autopilot system, which means when the communication between the Main Controllerand the transmitter is lost, the system will automatically trigger Return to Home and will land safely. The above specifications meet standards listed below, some derived in accordance with the Model Aircraft Operating Standards: 

## 0 The petitionerwill only operate its sUAS in line ofsight ofa pilot and/orobserverand will operate at sites that are a 'sufficient distance' from populated areas within the sterile area described inthe operators manual. Such operations will insure thatthe sUAS will "not create a hazard to users ofthe national airspace system orthe public." 

## 0 When flying sUAVwithin 3 miles ofan airport, airport operators will be notified and the operatorwill give the right ofway to avoid flying in the proximity offull-scale aircraft. 

## 0 Maximum flight time for each operational flight will be 60 minutes.

**~** Flightswill be terminated at 25% battery power reserve should that occur priorto the 60 minute limit.

• The sUAVwill be programmed so that itwill not be operated at an altitude of no more than 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned. • Minimum crewfor each operation will consist ofthe sUAS Pilot and the Visual Observer. • The sUAS operated by the petitionerweighs less than 55 pounds, including the payload {i.e. camera, lens, and gimbal). • The sUAS will operate at speeds of no more than 55 knots. • Given the small size ofthe sUAS and the restricted sterile environmentwithin which they will operate, our sUAS operations adhere tothe Reform Act's safety requirements. Underthe requested exemption PVP ensures that all operators have completed a small unmanned aircraft systems {UAS) education and training program including all applicable regulations and guidance documents; including aeronautical background information such as charts, NOTAMS and Aircraft Circulars; Radio Communications Procedures; Human Factors and Crew Resource Management; Basic Small UAS Aerodynamics; Weatherfactors; Airmanship and Decision-making and Safe Operating Procedures. We respectfully request exemption under Section 333 to enable PVP to operate safe, low-risk commercial sUAV operations forthe activities stated. PVP at all times will respect the space and privacy ofcitizens and propertywhilst keeping ourskies safe. Sincerely Mark Parrott, President- ParrottVision Productions LLC 561-389-2415 Mark@ParrottVision.com 1551 North Flagler Drive, West Palm Beach, Florida 33401



# ~~EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY ParrottVision Productions requests an exemption from the following regulations as well as any additional regulations that may technically applyto the operation ofthe sUAV System: 14 CFR Part 21, Airworthiness Certificates This part establishes the procedures forthe issuance ofan airworthiness certificate. While the FAA continues towork to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued forthe DJI Phantom 2 Vision plus, DJI S-900, DJIInspire, and RF-70 sUAS undereitheror both ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued forthe following purposes: (a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests and otheroperations to show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate majordesign changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expectthat an experimental certificate would permit ourcommercial purpose as well. The aircraftwill not carry persons or property, will not carry fuel, and will onlyfly under strict operational requirements. Combined with the UA's lightweight, being constructed primarily offoam, carbon fiber, and/or plastic, we propose thatthe UAwill be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. Ifan experimental airworthiness certificate is not appropriate forthis application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level ofsafety outlined in the previous paragraph. 14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must displaythe word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance to the cabin, cockpit, or pilot station. The sUAV does not have anentrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level ofsafety by including the word "EXPERIMENTAL" in the placard on the top ofthe aircraft, as shown above, where the PIC,VO and others in the vicinity ofthe aircraftwhile it is preparing for launch will be able to see the designation. Additionally, wefeel thatthe permanent placard discussed in the previous paragraph will provide the aircraft's registration information atthe ground station. Finally, we will display atthe ground station a high contrast flag or bannerthat containsthe words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraftwill operate within 3/4 NM ofthe ground station,the bannershould be visible to anyone that observes the aircraft and chooses to investigate its point oforigin. 14 CFR 61 .113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraftforcompensation or hire. Subparagraph (b) allows a private pilotto act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business oremployment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposed operations require that the PIC must hold at least a Private Pilot Certificate issued by the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of61.113 Subparagraph (b) even though the intent ofthis application is to conduct a business. 14 CFR 91.7 Prohibits the Operation ofan aircraftwithout an airworthiness certificate. As no such certificatewill be applicable in the form contemplated bythe FARs, this Regulation is inapplicable. 14 CFR 91.9 Civil aircraftflight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent ofthis requirement is to ensure that flight manual information is available to the aircrewwhile operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation,the documentation would not be available to the crew during flight operations. To obtain an equivalent level ofsafety and meet the intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew atthe ground station anytime the aircraft is in, or preparing for, flight. 14 CFR 91.109 Flight Instruction; Simulated instrumentflight and certain flighttestsThe regulation states that "No person may operate a civil aircraftthat is being used for flight instruction unless that aircraft has fully functioning dual controls." The sUAS System ground-based control station consists ofa small hand-held radio transmitter and while it does not offer a second set of "controls" , both the student and instructorcan, and will , operate the single set ofcontrols simultaneously. With both student and instructor having "hands-on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level ofsafety. 14 CFR 91 .119 Minimum safe altitudes: General. The regulation states that oversparsely populated areas the aircraft cannot be operated closerthan 500 feet to any person,vessel, vehicle, orstructure. Since the typical mission ofthe sUAS would be photography orsurvey of persons, vessels, vehicles orstructures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained and careful pre-planned has been performed. The aircraftwill be operated at a low altitude allowing, ifa power unitfails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due tothe small size ofthe UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption. 14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft. The sUAS will always fly below 600 feet AGL and will not need to maintain cruising altitudes in orderto prevent conflictwith otheraircraft. An Above Ground Level altimeter measurement above the takeoff point istransmitted via radio from the sUAS on-board computerto the display screen held by the PIC, providing a constantly updated AGL readout. 14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly afterthatfor at least 30 minutes. We feel the intention ofthis paragraph isto provide an energy reserve as a safety bufferfor delays to landing. The sUAS are battery operated and the maximum duration offlight from a single battery charge is 12-45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraftwill neverfly morethan 1/2 NM from the point of intended landing, a full battery charge at launch will ensure thatwe meetthe reserve energy requirement ofthis paragraph. We request an exemption to theword "fuel" and ask for anequivalent interpretation with the word "energy". We also request exemption from the 30 min reserve and ask that our reserve will beto fly the mission tothe point of intended landing and have at least a 20% battery reserve afterthat. 14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration numberassigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides thatthe airworthiness certificate be "displayed atthe cabin orcockpit entrance so that it is legible to passengers orcrew." With our largestvehicle, the RF-70, at a maximum gross weight of 13 pounds, the sUAS istoo small to carry documentation, does not have an entrance, and is not capable ofcarrying passengers orcrew. To obtain an equivalent level ofsafety and meetthe intent of91.203, we propose that documents deemed appropriate for this aircraft bythe FAAwill be co- located with the crew atthe ground control station and available for inspection upon request. In orderto identifythe aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23. 14CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations The regulation provides thatthe operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service by a person authorized under43.7" after maintenance and inspection. It is our intentionthatthe PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraftfor return to service." The PIC will ensure thatthe aircraft is in an airworthy condition priorto every flight and in addition, conduct detailed inspections after every two hours offlight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware forthe on-board computer. All other maintenance will be performed bythe manufacturer ortheir designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level of safety.