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V1 Media, LLC. 

Kenneth R. Topham III 

3351 Walkers Ridge Rd. 

Dacula, Ga 30019 

Ktopham84@gmail.com

FAA 

Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

West Building, Ground Floor, Room W12-140 

Washington, DC 20590 

To whom it may concern: 

I am writing pursuant to the FAA Modernization and Reform Act of 2012 ( Reform Act), and the 

procedures contained in 14 C.F.R. 11, to request that, an owner and operator of small unmanned 

aircraft, be exempted from the Federal Aviation Regulations (FARs) listed above so that V1 Media may 

operate its small unmanned aircraft lightweight unmanned aircraft system (UAS) commercially in 

airspace regulated by the Federal Aviation Administration (FAA); as long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333. 

I am a FAA licensed private pilot with single engine rating with over 145 hours and 16 years of work 

experience in the aviation industry. Additionally, I have been flying Unmanned Aircraft recreationally 

since 1996. I have been a private pilot since 2001 and have a current 3rd class medical certificate. With 

my clear understanding of FAA rules, my awareness of operational and restricted airspace, my 

experience as a pilot license holder (even though The FAA is lowering the credential bar to include sport 

pilot certificates), and my attitude of safety first when it comes to flight operations, I believe I should be 

granted an exemption. 

My request for a waiver of the section is not for operations for the purpose of “closed-set motion 

picture and television filming” but are identified below. My request is to operate Unmanned Aerial 

Systems (UAS) for commercial purposes. Specifically, to “record digital video data and other aerial 

photography data of real estate, insurance and general aerial photography. Which will include 

residential, farms and land to assist an owner in the promotion of their improved/unimproved parcel of

land, and inspection of damaged property such as roofing systems and or timber survey, for ultimate 

disposition and sale or purchase or other promotional purposes, such as a business wanting to promote 

its facilities using aerial images.” 

I am currently seeking exemption from: 14CFR 91.7(a); 91.9(B)(2); 91.103; 9l.109; 91.119 (c); 91.121; 

91.J 51(a)(l); 91.203(a)(b); 91.405(a); 91.407(a)( l); 9l.409(a)(l)and(2); 91.417(a)&(b); 45.23(b); Part 21; 

61.l 13(a)(b) 

“The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS) under the new 

FAA “Summary Grant” approach, announced April 9th, 2015 

http://www.faa.gov/news/updates/?newsId=82485 that will help speed up Section 333 exemption 

approvals for many commercial UAS operators prior to finalizing the small UAS proposed rules published

this past February. It is my understanding that the FAA will still review each Section 333 petition 

individually. However, I am hoping that the agency will accept my particular petition, and include it in 
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the next summary grant, and issue me an exemption on the presumption that the FAA has “already 

granted a previous exemption similar to this request”. 

The new interim policy includes the granting of a Certificate of Waiver or Authorization (COA) for 

flights at or below 200 feet to any UAS operator with a Section 333 exemption for aircraft that weigh 

less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual 

line of sight (VLOS) of the pilots, and stay certain distances away from airports or heliports such as 5 

nautical miles (NM) from an airport having an operational control tower; or 3 NM from an airport with a 

published instrument flight procedure, but not an operational tower; or 2 NM from an airport without a

published instrument flight procedure or an operational tower; or 2 NM from a heliport with a published 

instrument flight procedure. It is also understood that the “blanket” 200- foot COA allows flights 

anywhere in the country except restricted airspace and other areas, such as major cities, where the FAA 

prohibits UAS operations. 

UAS Description: 

I am asking for an exemption for UAS up to 55 pounds because I will be using DJI Phantom Vision+ 

and/or DJI Phantom 2 Vision and/or DJI Phantom 3. The differences in these are camera options not 

flight systems. 

In the event a loss of communications occurs the craft will rise up vertically to a safe height before

beginning an automatic return to home function. The control signal may be reconnected in flight and 

the pilot can take over safe operations again if communication is reestablished. However in the case of a 

GPS failure the craft will be able to be manually flown to a safe landing by the pilot. The craft operates 

electrically, carries no flammable fuel, has an integrated GPS pilot system, provides location information 

along with height AGL, speed, battery life, has programmed no-fly zones for controlled airports, and 

provides direction of travel distance from the pilot. 

Additional Points: 

It is my hope that you find that the enhanced safety achieved using an unmanned aircraft with the 

specifications described by the petitioner which carries no passengers or crew, rather than a manned 

aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA 

good cause to find that the UAS operation enabled by this exemption is in the public interest. 

Flight Operations: 

I am well aware of conducting safe flight operations and planning flight paths that minimize any 

overflight of crowds. Flights will end when battery reserve reaches 25 percent. Operations will not occur 

under IFR conditions. In addition, preflight and post-flight checklists and UAS examinations will help

detect any abnormalities prior to flight and after flight. Any UAS unable to satisfy safety checklists will be 

removed from service until the issue can be resolved. 

Granting this request would not adversely affect safety since operations would be in accordance with 

current UAS rules. Section 333 Compliance and Appropriateness: Based on the size of the craft, 

experience of the pilot, and operational goals, this request appears to be well suited for approval using 

the current criteria outlined in Section 333 of the FAA Modernization and Reform Act of 2012 (including 

new interim policies). 

Safety is of paramount importance to V1 Media. We endeavor to help integrate UAS into the NAS 

(national air space) by performing our services with the utmost concern for the safety of our operators, 
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the general public and property. To achieve this, V1 Media, has instituted several flight parameters, 

conditions, guidelines and limitations to adhere to before, during and after flight operations - all of 

which are outlined in the DJI User Manual Operators Manual. These conditions are based off of Part 333

exemptions that have already been approved by the FAA and have been integrated into our operations: 

- The UAS will not exceed a ground speed of 50 knots. 

- All operations will remain below 400’ AGL. 

- The UAS will weigh less than 55 lbs. 

- All operations will remain in VLOS. 

- All operations will utilize a VO. This VO will always be able to communicate verbally with the PIC. 

- The operator must follow the procedures as outlined in its operator's manual. (listed herein as 

Protocols & Procedures & DJI User's Manual and Operators Manual). 

- Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. 

Any UAS that has undergone maintenance or alterations that would affect the UAS operation or flight 

characteristics must undergo a functional test flight in accordance with operators manual. 

- The operator must follow the manufacturer's UAS aircraft component, maintenance, overhaul, 

replacement, inspection and life limit requirements. 

- The PIC will must possess at least a private pilot certificate and at least a third-class medical 

certificate and also meet flight review requirements specified in the 14 CFR 61.56. 

- Prior to operations the PIC will undergo UAS specific training for type (multi-rotor), make and 

model aircraft and log hours appropriately. PIC will also maintain proficiency and currency 

(every 90 days) with UAS. Keeping with a manner consistent with 14 CFR 6l.51(b). 

- PIC & VO will have successfully completed a qualification process, as outlined in the operator’s 

manual. Completion of this qualification process will be documented. 

- The UAS will not be operated directly over any person, except authorized and consenting flight 

personnel. 

- The PIC & VO will ensure that no unauthorized persons are allowed within 200' (or a distance 

deemed safe and practical due to physical terrain constraints) of the flight area except those 

consenting flight personnel. 

- If UAS loses communication or loses it GPS signal, the UAS must return to a predetermined 

location within the security perimeter and land or be recovered in accordance with operator's 

manual. 

- The UAS must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with operators manual. 

- The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations. 

- All operators will comply with all manufacturers Safety Bulletins. 

- Before conducting operations, the radio frequency spectrum used for operation and control of 

UAS will comply with Federal Communications Commission (FCC). 

- Prior to the planned operation (3 days) the operator will contact the local Flight Standards 

District Office (FSDO) (that has jurisdiction of the area) in writing and cover the plan of activities

for the flight operation. 

- The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the ground 

station during all operations. 

- The UAS will remain clear and yield the right of way to all other manned operations and 

activities at all times. 
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- All operations will be conducted under VFR (visual flight rules) and no night operations during 

night as defined in 14 CFR 91.151 

- The UAS will not be operated by the PIC from any moving device or vehicle. 

- The UAS will not be operated less than 500’ below or less than 2,000’ horizontally from a cloud 

or when visibility is less than 3 statute miles from the PIC. 

- The UAS will not operate in Class B, C, or D airspace without written approval from the FAA. The 

UAS will not operate within 5 nautical miles of the geographic center of a non-towered airport. 

- Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA will be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. 

- Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB website. 

The petitioner will outline in this document: 

1. Request for exemptions by Part and Subpart 

2. Petitioners protocols and procedures for operations 

3. The Unmanned Aircraft System (UAS) 

4. The Public Interest 

 Requests for Exemption by Part and Subpart 

14 CFR 91.7(A) Airworthiness Certificate; 

Prohibits the operation of an aircraft without an airworthiness certificate. Petitioner requests exemption 

based on previous exemption no. 11138. The FAA has ruled that this make and model of aircraft (UAS) 

does not require an airworthiness certificate. 

14 CFR 91.9(B) (2) Aircraft Flight Manual 

Requires an aircraft flight manual in the aircraft. As there are no pilots or passengers aboard and given 

the size of the UAS, this regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining a manual at the flight operations center. The FAA has previously issued exemptions to this

regulation no. 10700 and 32827. 

14 CFR 91.103 Pre-flight; 

No approved Aircraft Flight Manual on board the aircraft. The petitioner asserts that an equivalent level 

of safety will be achieved by the PIC taking all pre-flight actions set forth in the operating documents 

including weather, flight battery requirements, landing and take-off distances and aircraft performance 

data before initiation of each flight. 

14 CFR 91.109 Flight Instruction; 

There are no dual controls available for flight instruction. 14 CFR 91.119 (C) Minimum Safe Altitudes;

States that no person may operate an aircraft below the following altitudes: over other than congested

areas, an altitude of 500' above the surface, except over open water or sparsely populated areas. In 

those cases, the aircraft may not be operated closer than 500' to any person, vessel, vehicle, or 

structure. 

The petitioner will not operate any UAS over an altitude of 400' AGL. The majority of the operations 

proposed will operate between 0 to 200' AGL as this usually provides the best angle of capture for the

type of photography and videography operations proposed. 
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The UAS utilized for this exemption is of exceptionally light weight and is not capable of speeds over 30 

knots. The UAS is equipped with GPS guided auto pilot with a return home function in case loss of 

control by the PIC and is powered by sealed batteries thereby reducing the chance of post impact fire to 

nearly zero. 

There will be cases when the 500' distance from structures will need to be exempted. (Example: Aerial 

Video of a 2 story home roof to determine and or document extent of storm damage.) In this type of 

operation every assurance will be made to keep persons outside of a reasonable, safe, clear area of 

operations and will only be conducted with the express permission of the property owner. See Protocols

and Procedures Section. 

The petitioner will implement procedures and policies to ensure that any person in the general vicinity 

of operations will be aware of such operations and ensure that all non-essential personnel are cleared of 

the area of operations to the extent possible. The petitioner therefore requests relief in part from 14CFR 

9 l .11 9(C) 

14 CFR 91.121 Altimeter Settings; 

The petitioner requests relief from 91.121 for the following reason. The UAS is equipped with GPS 

derived altitude capability, however due to the limited altitude requested in this exemption, the FAA has 

previously granted Exemption for these types of operations. Reference Exemption No. 11138 

14CFR 91.15l(a)(1) Fuel for Flight; 

No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast

weather conditions) unless there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruise speeds. (a)(l) During the day to fly for at least 30 minutes. 

The petitioner requests relief from 91.15l (a) due to the fact that the UAS is equipped with a battery and 

percentage indicator system. The UAS has a flight capability on full charge of approximately 25 minutes 

depending on camera usage and other variables. The petitioner has established that the maximum flight 

will be 15 minutes on a fully charged battery. This constitutes landing with approximately 25 percent 

fuel remaining. The petitioner believes that this follows the spirit and intent of the rule with a great 

margin of safety. 

No UAS operations will be conducted at night, as defined by Federal Aviation Regulations. 

14 CFR 91.203(a)(b) Carrying of civil aircraft Certifications and Registrations; 

Provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the 

same reasons described above. Operations manuals and Safety Procedures will be maintained at the V1 

Media home office with copies of same traveling with the PIC. 

14 CFR 91.405(a) Maintenance required; 

The petitioner requests relief in part from 91.405(a)(l) based on the Protocols and Procedures Section on 

Maintenance and Maintenance Records. Also reference Exemption No. ll138 

14 CFR 91.407(a)(l) 

Operation after maintenance, preventive maintenance, rebuilding, or alteration; The petitioner requests 

relief from 91.407(a)(l) based on the Protocols and Procedures Section on Maintenance, Return to 

service after maintenance, and Maintenance records. Reference Exemption No. 11138 
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14 CFR 91.409(a)(l)(2) Inspections; 

The petitioner requests relief from 9l.409(a)(1)(2) based on the Protocols and Procedures Section on 

Inspections. Reference Exemption No. 11138 

14 CFR 91.417(a)(b) Maintenance records; 

The petitioner requests relief from 91 .417(a)(b) based on the Protocols and Procedures Section on 

Maintenance records. 

14 CFR 45.23(b) Marking of the Aircraft; 

Applicable codes of Federal Regulation require aircraft to be marked according to certain specifications. 

V1 Media UAS's are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot 

station on which to mark certain words or phrases. Further, two inch lettering is difficult to place on 

such small aircraft. Regardless, V1 Media will, if required, mark its UAS's in the largest possible lettering 

by placing the ”N "number on its fuselage as required by 14CFR 45.29 (f) so that the pilot, technician, 

spotter and others working with the UAV will see the markings. The FAA has previously issued 

exemptions to this regulation through Exemption No 10167 and 10700 

14 CFR 21, Sub Part H Airworthiness Certificates; 

Entitled Airworthiness Certificates, set forth requirements for procurement of necessary airworthiness

certificates in relation to FAR 91.203(a)(l). The size, weight and enclosed operational area of V1 Media 

UAS permits exemption from Part 21 because V1 Media UAS meet an equivalent level of safety pursuant 

to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both the Act (49 USC 44701(f)) and Section 333 of the Reform Act. Both 

pieces of the legislation permit the FAA to exempt UAS from the airworthiness certificate requirement in 

consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and 

dense populations. V1 Media’s UAS meet or exceed each of the elements. 

14 CFR 61.l 13(a)(b) Private Pilot Privileges and Limitations PIC; 

Private pilots are limited to non-commercial operations. V1 Media can achieve an equivalent level of 

safety as achieved by current Regulations because V1 Media UASs do not carry any pilots or passengers.

Further, while helpful, a pilot license will not ensure remote control piloting skills, though V1 Media pilot 

vetting and training program will. Further, private pilot licensees will operate V1 Media UASs with the 

same skill. Further the risk attendant to the operation of V1 Media UAS is far less than the risk levels 

inherent in the commercial activities outlined in CFR 61. Thus, allowing V1 Media to operate its UAS with 

a private pilot as the pilot in control will exceed current safety levels in relation to CFR 61.l 13(a)(b). 
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PROTOCOLS AND PROCEDURES FOR UAS OPERATIONS 

A. Preflight 

B. Area Security 

C. Limitations of Operations 

D. Airworthiness 

E. Maintenance and Records 

F. Pilot in Command Requirements 

G. Visual Observer and Requirements 

H. Reporting of Incidents and Accidents 

A. Preflight Inspection of UAS 

( I ). Preflight of the Unmanned Aerial System will follow the instructions in the DJI instruction and User 

Manual. The Pilot in Command will certify that a preflight inspection has been accomplished with the 

date and time and signature in the UAS logbook. The preflight shall include the aircraft, transmitter, and 

batteries, motors, rotors, landing gear, camera and gimbal mount. As a part of the preflight the Pilot in 

Command will assure that weather conditions, area security, and any other information essential to safe 

operation has been obtained. 

B. Area Security 

( 1 ). The PIC of the UAS will ensure that the operational area for the purposes of UAS flight shall be 

cleared of all nonessential persons at all times the UAS is in flight. Additionally all nonessential persons 

shall be required to remain clear of the operations area by a minimum distance of 200' (or by as much as 

practical) during operations. PIC shall ensure that cones and clearly marked signs are posted at all 

ingress \ egress points to the operations areas. These signs will be of white background with red 

lettering stating the following: "Unmanned aircraft operations underway. Please remain clear." 

(2). In the event of a breach by nonessential persons into the operations area during the flight of UAS, 

the PIC shall immediately terminate flight operations until such time as the area can be cleared of these 

persons. 

(3). The UAS area of operation is defined as the horizontal flight path(s) of the UAS as well as the Vertical 

flight path and Maximum altitude to be reached. Additionally, the area between the UASs current 

position and its Home location is also considered operational area as it will proceed direct to its home 

location in the event of loss of ground control. 

C. Limitations of Operations 

(1) The UAS shall be operated i n Day time only, as defined by 14 CFR 

(2) UAS night operations are prohibited. 

(3) The UAS shall be operated by VLOS at all times 

(4) A Visual Observer shall be utilized at all times and must maintain VLOS at all times. 

(5) The UAS shall remain within 1 000' horizontal distance of the PIC at all times. 

(6) The UAS to be utilized is the DJI Inspire Unmanned Aircraft System. No other systems will be 

operated. 
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(7) The UAS will have an altitude restriction of 400ft AGL. 

(8) The UAS will not be operated at a speed exceeding 30 Knots. 

(9) Operations Documents will be accessible to the PIC at all times and must be accessible during UAS 

operations and made available to the Administrator on request. 

(10) PIC must inspect and ensure that UAS and ground control station is in airworthy condition prior to 

each operation; if determined un-airworthy, all operations will be suspended until such time as 

necessary maintenance has been performed and the UAS is determined to be in a safe condition for 

flight. 

(11) An operational flight test is required after any maintenance or alterations that may affect UAS 

operation or flight. 

(12) UAS maintenance must follow manufactures aircraft and component, maintenance overhaul, and 

replacement, inspection, and life limit requirements. 

(13) The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance and inspection, and alterations must be noted 

in the aircraft records including total flight hours, description of work performed, and the signature of 

the authorized person returning the UAS to service.

(14) UAS must comply with all Manufacturers' Safety Bulletins. 

(15) An authorized person must make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections. 

(16) UAS must by operated by a PIC possessing at least a Private Pilot Certificate, with most appropriate 

Class and Category and at least a current Third Class Medical. 

(17) PIC must meet the flight review requirements of 14 CFR 61.56 in an aircraft in which the PIC is 

rated. 

(18)Prior to operations for which exemption is requested the PIC must have accumulated and logged ,in 

a manner consistent with 14 CFR 61.5l(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot 

including at least 10 hours of UAS multi-rotor. 

(19) Prior to operations the PIC must have accumulated and logged a minimum of 5 hours as a UAS pilot 

in make and model listed in exemption. PIC must log at a minimum 3 takeoffs and landings in the 

preceding 90 days to meet currency requirements. 

(20) PIC is required to operate the UAS in accordance with 14CFR 91.119. 

(21) No UAS operation within 5 nautical miles of a controlled airport reference point as denoted on a 

current FAA chart. 

(22) No operations are allowed in the surface areas of Class B, C, and D airspace or in restricted airspace. 

(23) No operations are allowed if the return home function and\or auto pilot are, or are suspected to be 

malfunctioning. 

(24) UAS shall not be operated from a moving platform of any type. 
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(25) No operations shall be conducted without an appropriate Certificate of Authority issued by the 

Administrator. 

(26) A Visual Observer shall be utilized at all times when operating the UAS. 

(27) Should the PIC or Visual Observer detect that a manned aircraft is being operated in close proximity 

to the operations area, the UAS shall give right of way to the manned aircraft, and the PIC shall cease 

operations and land until such time as the manned aircraft has cleared the area. 

(28) UAS will not be operated any closer than 100' to any structure without the express permission of 

the structure I building I property owner. 

(29) The UAS will be limited to 18 minutes of flight or 25% of battery power, whichever occurs first. 

D. UAS Airworthiness 

(1). The PIC shall ensure that the UAS is in an airworthy condition before each flight. Airworthiness shall 

be determined by a preflight inspection in accordance with DJI operating documents and any and all 

applicable Federal Aviation Regulations, and any additional requirements as defined by the 

Administrator. PIC shall document each preflight inspection by date, Aircraft total Flight time to date, 

any discrepancies noted ,and signature and certificate number. Any discrepancy noted shall be 

addressed before UAS operation. 

E. UAS Maintenance and Records 

(l). The operator shall maintain aircraft maintenance logbooks. Each V AS shall have its own and 

separate maintenance log book. DJI documents, handbooks, user manuals, supplements, Safety 

Bulletins, etc., shall be the only approved documents for performing repairs, maintenance, inspections, 

overhauls, or replacement of life limited components. A record of each preflight inspection will 

additionally be recorded in these logbooks. The preflight inspection must be conducted by the PIC for 

that operation. Preflight sign-off shall include at least the following information: date of operation, 

Aircraft Total time , aircraft serial or operating number, PIC signature and certificate number. 

Example: Preflight inspection completed, No defects noted. 1-1-15, AC FIT 50.l hours, VAS number 1, 

(2). Any required maintenance, inspection, alteration or repair must be completed by an approved 

person. At the completion of this work the approved person must make an entry in the aircraft log book

that at least includes: Date, Aircraft serial or operating number, brief description of the discrepancy, 

inspection, alteration or repair, the reference material used as guidance for the repair, statement 

approving the aircraft for return to service, and signature of person who completed the work. 

Example: 1-1-15 UAS #XXX, 50. hours, replaced number 3 rotor with new rotor, in accordance with DJI 

Inspire User Manual. Flight or ops check completed. Aircraft is approved for return to service. PIC 

signature and certificate number. 

(3).Maintenance records shall be kept with the UAS at all times and shall be made available to any 

authorized agency or the Administrator upon request. 

F. Pilot in Command Requirements 

(1).The Pilot in Command shall hold at least a Private Pilot Certificate and a current Third Class Medical 

whenever conducting operations. Operator prefers that the Certificate be in the most appropriate Class

and Category to the UAS being operated. 
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(2). The Pilot in Command shall have accumulated and logged a minimum of 200 flight cycles and 25 

hours of rotorcraft UAS flight time before performing any operation for which exemption is requested. 

(3). The Pilot in Command shall have at least 5 hours in make and model before performing any 

operation for which exemption has been requested. 

(4).The Pilot in Command shall perform a pre-flight inspection before each flight is conducted, 

(5).The Pilot in Command shall observe all Federal Aviation Regulations at all times with the exceptions 

of the exemptions requested by the operator. In those cases the Pilot in Command shall adhere to 

company operating standards or Federal Aviation Administration Limitations placed upon exemptions, 

whichever is more stringent. 

(6). The Pilot in Command will not operate the UAS without a Visual Observer present. 

(7). The Pilot in Command must have 3 takeoff and landings within the preceding 90 days. 

(8). The Pilot in Command must maintain a record of flight information to establish currency and that he 

or she meets the requirements of this section. 

(9). The Pilot in Command will utilize eye protection in the event that sun glare would reduce YLOS 

operations. 

G. Visual Observers: Responsibilities and Requirements 

(1). A Visual Observer shall be used during any and all operations of the UAS System. 

(2). The Visual Observer shall maintain verbal communication with the PIC at all times during UAS 

operation. 

(3). The Visual Observer shall maintain Visual Contact with the UAS at all times. In the event that Visual 

Contact is lost the VO will notify the PIC who will immediately cease operations and land the aircraft. 

(4). The Visual Observer shall also help the PIC maintain area of operations security and ensure that all 

non-essential persons remain clear of the area of operations. In the event of a breach by unauthorized

person(s) the VO shall notify the PIC and operations will cease immediately. 

(5).The Visual Observer shall also assist the PIC in looking for manned aircraft traffic near the operations 

area. If manned aircraft traffic is observed near the operations area, the VO will notify the PIC who will 

immediately cease operations and land the UAS. 

(6). The VO will utilize eye protection in the event that sun glare would reduce VLOS operations. 

H. Reporting of Incidents and or Accidents 

Any incident or accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA will be reported within 24 hours to: FAA UAS 

Integration Office (AFS-80) Accidents: National Transportation Safety Board (www.ntsb.gov.) 
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The Public Interest 

The request for this exemption is in the Public Interest as it is safe to assume that there are many 

consumer applications for the services that can be provided by UAS. It is clear that the Congress of the 

United States, the business sector, and the consumer want to integrate UAS into the NAS and utilize 

their unique and cost effective capabilities. It is also in the Public Interest that many of the low level 

flight operations now conducted by manned aircraft could be accomplished with these light, fire 

resistant and environmentally friendly unmanned aircraft that can operate at a fraction of the cost to

both the operator and consumer. These aircraft can be operated without risk of loss to life or limb, and 

without significant financial impact to the operator or any person or property on the ground in the event 

of the loss of an aircraft. Utilizing these UAS will create a safer more productive work environment, 

reduce environmental pollution and have a positive impact on the local community which is in the Public 

Interest. Finally, the petitioner believes that granting this exemption would help to further by 

Administrative process the integration of UAS systems and the possibility to help create additional 

regulations and guidance to be used as these systems become more widely utilized. 

Please forward any comments or questions you may have to ktopham84@gmail.com. 

Sincerely, 

V1 Media 

Kenneth R. Topham III, 

President