August	5,	2015 REVISION	TO	MARCH	8 LETTER	&	DOCUMENTS

Page 1 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

Roland J. Boucher, Jr.

396 Washington Street

Suite 260

Wellesley Hills, MA 02481-6209

U. S. Department of Transportation 

Docket Management System 

Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 

61.113 (a) & (b); 91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 

91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & 

(b). 

Dear Sir or Madam: 

VizTools wishes to amend its March 8, 2015 filing with this letter and attachments.

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

Reform Act) and 14 C.F.R. Part 11, VizTools LLC, operator of Small Unmanned Aircraft 

Systems (“sUASs”) equipped to conduct aerial photography, aerial data collection, and 

video recording, hereby submits a supplement to its previously submitted application for

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its sUASs, so 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

333.1

As described more fully below, the requested exemption would permit the 

operation of small, unmanned and relatively inexpensive sUAS under controlled 

conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 

4) would provide safety enhancements to the already safe operations in the data 

collection, photo, and video industries presently using conventional aircraft. Approval of 

this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s 

(the FAA Administrator’s) responsibilities to “...establish requirements for the safe 

operation of such aircraft systems in the national airspace system.” Section 333(c) of the 

Reform Act. (Note: VizTools has removed “Closed Set Filming” from this application.)

The name and address of the applicant is: 

VizTools LLC 

Attn: Roland J. Boucher, Jr.

Holder of Commercial Pilot Cert. # 2711520

Ph: 781-789-9026

Email: rboucher@viztools.tv

Address: 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

																																																							
August	5,	2015 REVISION	TO	MARCH	8 LETTER	&	DOCUMENTS

Page 2 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

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 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress’ goal in 

passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate 

safely in the national airspace system (NAS) before completion of the rulemaking 

required under Section 332 of the Reform Act. In making this determination, the 

Secretary is required to determine which types of UASs do not create a hazard to users 

of the NAS or the public or pose a threat to national security in light of the following: 

• The UAS’s size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may 

operate safely in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft in the national airspace system.” Id. 

§333(c) (emphasis added)2

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 of the Act,that includes sUASs, from the requirement that 

all civil aircraft must have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this 

title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) 

See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

																																																							

2

Applicant interprets this provision to place the duty on the Administrator to not only process applications for 

exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, 

if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for 

approval.
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Page 3 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

VizTools LLC’s sUASs are rotorcraft, weighting 55 or fewer lbs. including payload

(See bottom of page). They operate, under normal conditions at a speed of no more 

than 50 knots and have the capability to hover, and move in the vertical and horizontal 

plane simultaneously. They will operate only in line of sight and will operate only within a 

controlled area described in the VizTools Operations Manual, attached as Exhibit 1 

(hereinafter “the Manual”)3. Such operations will insure that the sUAS will “not create a 

hazard to users of the national airspace system or the public.”4

Given the small size of the sUASs involved and the restricted controlled

environment within which they will operate, the applicant falls squarely within that zone 

of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, 

by exemption, allow commercial operations of UASs to commence immediately. Also 

due to the size of the UASs and the controlled areas in which the relevant sUASs will 

operate, approval of the application presents no national security issue. Given the clear 

direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, including enhanced safety, reduction in 

environmental impacts, including reduced emissions associated with allowing UASs for 

data collection, movie and television operations, the grant of the requested exemptions 

is in the public interest. Accordingly, the applicant respectfully requests that the FAA 

grant the requested exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft 

that have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure because the proposed operations represent a 

safety enhancement to the already safe data collection, movie and television video and 

filming operations conducted with conventional aircraft. 

VizTools has also changed the manufacturer and models of the proposed aircraft

in this document, from those in the previously submitted document:

1.For training purposes VizTools makes use of a Blade Nano QX “Micro Quad 

Copter” which has a remote control device that functions similarly to the remote control 

of similar, but larger UAV devices. Weight: 0.63 oz

2. For initial Video, Aerial Photo and Data Gathering, VizTools will be using 

a Yuneec Q500 Typhoon 4K, 4 Blade Rotorcraft. Weight: 3.75 Pounds

Manuals for both of these aircraft are attached to this letter.

These limitations and conditions to which VizTools LLC agrees to be bound when 

																																																							

3

Applicant submits this manual as a Confidential document under 14 CFR 11.35 (b) as the entire manual 

contains proprietary information that the applicant has not and will not share with others. The manual 

contains operating conditions and procedures that are not available to the public and are protected from 

release under the Freedom of Information Act 5 USC 552 et.seq. 

4

Reform Act Section 333 (b).
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Page 4 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 25 minutes. Flights

will be terminated at 25% battery power reserve should that occur prior to the 25

minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not 

more than 200 feet above an elevated platform from which filming is planned. 

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual 

Observer, and/or the Camera Operator. 

6. sUAS pilot will be an FAA licensed airman with at least a private pilot’s 

certificate. 

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other 

than the sUAS Pilot, who possess the necessary PIC qualifications, is also 

present (i.e. the Aerial Coordinator), that person can also be designated as PIC. 

8. The UAS will only operate within a controlled area as defined in the Manual. 

The Manual requires the establishment of a “Controlled Area” for the flight 

operations area. 

9. A briefing will be conducted in regard to the planned sUAS operations prior to 

each day’s production activities. It will be mandatory that all personnel who will 

be performing duties within the boundaries of the Controlled Area be present for 

this briefing. 

10. Observer and pilot will at all times be able to communicate by voice and/or 

text. 

11. Written and/or oral permission from the relevant property holders will be 

obtained. 

12. All required permissions and permits will be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies. 

13. If the sUAS loses communications or loses its GPS signal, the UAS will have 

capability to return to a pre-determined location within the Controlled Area and 

land. 

14. The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR §91.203 

(a) (1). Given the size and limited operating area associated with the aircraft to be 

utilized by the applicant, an exemption from Part 21 Subpart H meets the requirements 

of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, 

upon consideration of the size, weight, speed, operation capability, and proximity to 

airports and populated area of the particular UAS. In all cases, an analysis of these 

criteria demonstrates that the sUAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries 
August	5,	2015 REVISION	TO	MARCH	8 LETTER	&	DOCUMENTS

Page 5 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, 

and operates exclusively within a secured area as set out in the Manual. Unlike other 

civil aircraft, operation under this exemption will be tightly controlled and monitored by 

both the operator, pursuant to the Manual’s requirements, and under the requirements 

and in compliance with local public safety requirements, to provide security for the area 

of operation. These safety enhancements, which already apply to civil aircraft operated 

in connection with aerial data collection, aerial photography and video production, 

provide a greater degree of safety to the public and property owners than conventional 

operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, 

Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UAS, due to its size, speed of operation, 

location of operation, lack of explosive materials or flammable liquid fuels, and inability to 

carry a substantial external load.

14 CFR, § 45.22(d) allows the UAS owner or operator to propose an alternative

marking procedure to the FAA. Alternate marking approvals may be issued to public 

aircraft by FAA UAS Integration Office (AFS-80). If alternative markings were required , 

a copyof the Alternative Marking approval letter should be attached to application in the

“Aircraft Registration” field.

The petitioner requests permission for 1 inch markings to be applied on the top 

or side surface(s) ofthe body of the aircraft. (Whichever yields is most 

readable.)

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot 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.

Even though the UAS will have no airworthiness certificates, an exemption may be 

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on 

which the word “Experimental” can be place. Given the size of the sUAV, two-inch

lettering will be impossible. The word “Experimental” will be placed on the fuselage in 

compliance with §45.29 (f). Regardless of this, petitioner states that he will markhis 

UAS in the largest possible lettering by placing assigned N number on its fuselage as

required by § 45.29(f) so that he or anyone assisting as a spotter will see the 

markings. The lettering will be 1 inch in height.

The equivalent level of safety will be provided by having the sUAV marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working 

with the sUAV will see the identification of the UAS as “Experimental.” The FAA 

has issued the following exemptions to this regulation to Exemptions Nos. 10700, 

8738, 10167 and 10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

Because the UAS will not carry a pilot or passengers, the proposed operations 
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Page 6 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

can achieve the equivalent level of safety of current operations by requiring the 

PIC operating the aircraft to have a private pilot’s license rather than a 

commercial pilot’s license to operate this small UAS. Unlike a conventional 

aircraft that carries the pilot and passengers, the sUAS is remotely controlled 

with no living thing on board. The area of operation is typically controlled and 

restricted. The level of safety provided by the requirements included in the 

Manual exceeds that provided by a single individual holding a commercial pilot’s 

certificate operating a conventional aircraft. The risks associated with the 

operation of the sUAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing 

operations of the sUAS as requested with a private pilot as the PIC exceeds the 

present level of safety achieved by 14 C.F.R. §61.113 (a) & (b). 

Pilot in Command:

Petitioner requests to be permitted for commercial operation of a small UAS

PIC operating the UAS will have accumulated and logged, in a manner 

consistent with14 CFR 61.51(b), at least 10 hours logged as a UAS pilot with a 

multi-rotorUAS.

CFR §61.3(a)(1): Requirement for certificates, ratings, andauthorizations

Applicant has held a Commercial Pilot’s Certificate since 1996 and a Private 

Pilot’s Certificate for SEL aircraft since 1974. Additionally, he holds an 

Instrument rating and has a Complex Airplane Endorsement and he routinely 

participates in AOPA Safety Seminars. However, Petitioner requests to be 

permitted to use other certificated and trained Private Pilots as PIC in cases 

where that is necessary. Any such PIC will have had at least 10 hours of 

training prior to their first flight.

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the 

aircraft, should this exemption be granted, no FAA regulatory standard will exist 

for determining airworthiness. Given the size of the aircraft and the requirements 

contained in the Manual for maintenance and use of safety check lists prior to 

each flight, as set forth in Sections J, L and Q, an equivalent level of safety will 

be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

No person may 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 in the aircraft a current approved 

airplane or Rotorcraft Flight Manual, approved manual material, markings, and 

placards, or any combination thereof.
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Page 7 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

The	sUAS,	given	its	size	and	configuration	has	no	ability	or	place	to carry	

such	a	flight	manual	on	the	aircraft,	not	only	because	there	is	no	pilot	on	

board,	but	because	there	is	no	room	or	capacity	to	carry	such	an	item	on	the	

aircraft.	

The equivalent level of safety will be maintained by keeping the flight manual at 

the ground control point where the pilot flying the sUAS will have immediate 

access to it. The FAA has issued the following exemptions to this regulation: 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 

10602, 32827, and 10700. 

14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before 

flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will 

not be provided for the aircraft an exemption will be needed. An equivalent level 

of safety will be provided as set forth in the Manual. The PIC will take all actions 

including reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight instruction: 

Section 91.103 provides that no 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. 

sUASs and remotely piloted aircraft, by their design do not have fully functional 

dual controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of 

aircraft and for flight instruction in experimental aircraft. See Exemption 

Nos.5778K & 9862A. The equivalent level of safety provided by the fact that 

neither a pilot nor passengers will be carried in the aircraft and by the size and 

speed of the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d) allows helicopters to be operated at less than the minimums 

prescribed, provided the person operating the helicopter complies with any route 

or altitudes prescribed for helicopters by the FAA. As this exemption is for a 

sUAS that is a helicopter and the exemption requests authority to operate at 

altitudes up to 400 AGL, or not more than 200 above an elevated platform, an 

exemption may be needed to allow such operations. As set forth herein, except 

for the limited conditions stated in the Manual, the UAS will never operate at 

higher than 400 AGL. It will however be operated in a Controlled Area with 

security perimeter, where buildings and people will not be exposed to operations 

without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of 

the UAS as well as the location where it is operated. No flight will be taken 
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Page 8 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

without the permission of the property owner or local officials. Because of the 

advance notice to the property owner and participants in the activity, all affected 

individuals will be aware of the planned flight operations. Compared to flight 

operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. 

proposed herein and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with conventional aircraft 

operating at or below 500 AGL in the data collection, data gathering, aerial photo 

and video industries. In addition, the low-altitude operations of the sUAS will 

ensure separation between these small-UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure 

airport or an appropriate altimeter setting available before departure.” As the 

sUAS may not have a barometric altimeter, but instead a GPS altitude read out, 

an exemption may be needed. An equivalent level of safety will be achieved by 

the operator, pursuant to the Manual and Safety Check list, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “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 of intended landing, and, assuming 

normal cruising speed – (1) During the day, to fly after that for at least 30 

minutes; or (2) At night, to fly after that for at least 45 minutes.” 

The battery powering the sUAS provides approximately 25 minutes of powered 

flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS 

flights would not be possible. Given the limitations on the UAS’s proposed flight 

area and the location of its proposed operations within a predetermined area, a 

longer time frame for flight in daylight VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the 

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin 

Corporation to operate without compliance with FAR 91.151 (a)). Operating the 

small UAS, in a tightly controlled area, with less than 25 minutes of reserve fuel, 

does not engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the small UAS. Additionally, grounding

sUAS flights which do not have sufficient reserves, would greatly reduce the 

utility for which the exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting 

flights to 25 minutes or 25% of battery power whichever happens first. This 

restriction would be more than adequate to return the sUAS to its planned 

landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 

2689F, 5745, 10673, and 10808. 
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Page 9 VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(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 person may operate a civil aircraft unless the airworthiness 

certificate required by paragraph (a) of this section or a special flight 

authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 55 lbs and is operated without 

an onboard pilot. As such, there is no ability or place to carry certification and 

registration documents or to display them on the sUAS. 

An equivalent level of safety will be achieved by keeping these 

documents at the ground control point where the pilot flying the sUAS will have 

immediate access to them, to the extent they are applicable to the sUAS. The 

FAA has issued numerous exemptions to this regulation. A representative 

sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9797A, 9816A, and 10700. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner “shall have 

that aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter...,” and others 

shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an 

airworthiness certificate, these sections will not apply to the applicant. 

Maintenance will be accomplished by the operator pursuant to the flight manual 

and operating handbook as referenced in the Manual.(See Sections L and Q) An 

equivalent level of safety will be achieved because these small UASs are very 

limited in size and will carry a small payload and operate only in restricted areas 

for limited periods of time. If mechanical issues arise the UAS can land 

immediately and will be operating from no higher than 400 feet AGL. As provided 

in the Manual, the operator will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with 

the aircraft and best suited to maintain the aircraft in an airworthy condition to 

provide the equivalent level of safety.

*********

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication 

in the Federal Register, should it be determined that publication is needed: 
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Page 

10

VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

Applicant seeks an exemption from the following rules: 

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) &

(b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) 

and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & 

(b) to operate commercially a small unmanned vehicle (55lbs or less) in motion 

picture and television operations. 

Approval of exemptions allowing commercial operations of sUASs in the data 

gathering, aerial photography and video industry will enhance safety by reducing risk. 

Conventional aerial data gathering, aerial photograhy and video operations, using jet or 

piston power aircraft, operate at extremely low altitudes just feet from the subjects being 

recorded and in extreme proximity to people and structures; and present the risks 

associated with vehicles that weigh in the neighborhood of 4,000 lbs., carrying large 

amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to 

and from the subject location. In contrast, a sUAS weighing fewer than 55 lbs. and 

powered by batteries eliminates virtually all of that risk given the reduced mass and lack 

of combustible fuel carried on board. The sUAS is carried to the subject data gather

point, video subject or film set and not flown to it. The sUAS will carry no passengers or 

crew and, therefore, will not expose them to the risks associated with manned aircraft 

flights. 

The operation of small UASs, weighting less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight aircraft 

operate at slow speeds, close to the ground, and in a controlled environment and, as a 

result, are far safer than conventional operations conducted with turbine helicopters 

operating in close proximity to the ground and people. 

Safety

Applicant has maintained a flight and maintenance log for all aircraft from start

of ownership.

Applicant maintains current firmware and software updates for all aircraft.

Applicant has accrued over 10 hours of logged UAS rotorcraft flight evidenced

by flight and maintenance log

Applicant has obtained "N" numbers and registration for each of the aircraft to

be operated under the exemption that is being requested

Yuneec Aircraft firmware for the models being used includes systems for:

Blocking take-off in restricted areas around airports

Automatic Return-To-Launch-Site and land upon loss of control

signal (see document provided)

Automatic remote monitoring and warning of low battery condition (25%)

Launch Operations Flight Kit contains:

Operation safety procedures (document provided)

Aircraft registration documents
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11

VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

First Aid Kit

Sectional Charts for proposed areas of operation (paper and electronic)

Anemometer to measure local wind and temperature

ICom IC-A21 Aircraft Navicom radio/VOR to monitor and scan

aircraft frequencies where necessary or required by ATC.

Safety cones bearing a warning sticker to mark Controlled Area around

launch operating location when operating in public areas.

An "observer/spotter" for all but remote practice flight operations. 

Observer/spotter will be required to read and acknowledge (sign) a safety 

procedures manual and to enhance situational awareness for the PIC

(operator)

Mobile applications to monitor TFRs, NOTAMS, Aircraft Weather data 

(AviationWX, AeroPlus), GPS position application and other programs to

identify proximity to restricted areas (RCFlyMaps and HOVER), ADS-B/in

signals (FlightRadar24), VOR distance and heading data, (SkyRadar).

Safety Operations and Procedures Manual outlining specific procedures and

restrictions, which specifies no flights within 50 feet of or over active highways

or railroads, no spectators or communication with spectators within 50 feet

(marked with warning cones) of flight operation area preceding or during flight

operations.

Operation Manuals for aircraft being used.

Repair parts and tools.

Privacy

All flights will occur over private or primarily over controlled access property with 

the property owner’s prior consent and knowledge.

All flights are to be conducted during daylight hours.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--

size, weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of 

applicant’s UAS in the data gathering, aerial photography and video industries pursuant 

to the Manual appended hereto. 
August	5,	2015 REVISION	TO	MARCH	8 LETTER	&	DOCUMENTS

Page 

12

VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481- 6209

Additional Information in Support of this Request:

Applicant has obtained N numbers (NV102, NV104)

Applicant has accrued in excess of 10 hours practical experience and

practice with the Blade Nano QX Training Aircraft and the Yuneec Q500 4K 

Aircraft

Applicant holds Commercial Pilot’s Certificate with Instrument Rating and is 

fully familiar with Communications and Navigation Processes and Procedures.

Applicant is involved in ongoing aviation safety training through the AOPA, 

FAA and EAA.

Applicant will only operate in reasonably safe environments that are

strictly controlled, are away from power lines, elevated lights, airports and

actively populated areas; and

Applicant will conduct preflight inspections and protocols, during which

safety carries primary importance.

Sincerely, 

Roland J. Boucher, Jr.

Member

VizTools LLC. 

Enclosures:

Petitioner Supports this request with the following additional documents, which are to be 

considered proprietary documents and are not to be published in the Federal Record.

Exhibit 1 - VizTools Operations Manual (Revised)

Yuneec Q500 4K Manual

Yuneec Supplemental Documents

Blade Nano QX Manual

Insurance Quotation

N number registration

Aircraft registration