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 Refor m 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 Fede ral 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 su ch operations are conducted with

and under t he 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 commerci al

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 ove r private or con trolled

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 wi ll 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, cheap er equipment and personnel cost, reduced noise, and much smaller

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

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

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

of the distance it flie s 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 fu nction

that is triggered in the even t communication is lost between the sUAS and the ma in controller transmitter.

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

can regain control of flight and land manually. These specifications me et 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 ster ile area described in the F OPM. 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 not ified and the

operator will give the right of way to av oid flying in the proximity of full

- scale aircraft. Maximum flight time

for each operation will be 30 minutes. Flights will be ter minated when ba ttery levels reach 25%, allowing

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

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

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

The sUAS operated by the petitioner weighs less than 25 pounds, including all pa yload (ie: camera, lens, a nd

stabilized gimbal).

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

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

it will operate, John Besancon Jr and 360TourVision

LL C’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