### 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 W ashington Street Suite 260 We llesley 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 1 4 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) woul d provide safety enhancements to the already safe operations in the data collection, photo, and video industries presen tly 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

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**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 compl etion 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 d efined 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 th is 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.

### August	5,	2015 REVISION	TO	MARCH 8 LETTER	&	DOCUMENTS

**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 environm ental 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 model s of the proposed aircraft in this document , from th os e 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. We ig ht: 0.63 oz **2. For initial**  **V ideo,**  **Ae rial Photo and Data G**  **athering ,**  **VizTools will be using a Yuneec Q500 Ty** **phoon 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 1 4 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 und er 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 2 5 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 2 5 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 produ ction 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. 1 0 . Observer and pilot will at all times be able to communicate by voice and/or text. 1 1

. W ritten and/or oral permission from the relevant property holders will be obtained. 1 2 . 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. 1 3 . 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. 1 4 . The sUAS will have the capability to abort a flight in cas e of unpredicted obstacles or emergencies. **14 C.F.R. Part 21, Subpart H: A irw** **orthiness 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 s UAS 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 s UAS 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 lo cal 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 d egree 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 copy of 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) of the body of the aircraft. (W hichever yields is most readable.) **14 C.F.R. § 45.23 (b). Ma r** **king of the A ircraft**  The regulation requires: Wh en 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 ne ar 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 exem ption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on wh ich the word “Experimental” can be place. Give n the size of the sUAV, two

- inch lettering will be impossible. The word “Expe rimental” will be placed on the fuselage in compliance with §45.29 (f). Regardless of this, petitioner states that he will mark his 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

### August	5,	2015 REVISION	TO	MARCH 8 LETTER	&	DOCUMENTS

**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 p ilot’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 s UAS 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 with 14 CFR 61.51(b), at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. 

### CFR §61.3(a)(1): Requirement for certificates, ratings, and **authorizations** Applicant has held a Commercial Pilot’ s Certifi cate since 1996 and a Private Pilot’ s Certificate for SEL aircraft since 1974. Additionally, he holds an Instrument rating and has a Complex Airplane E ndorsement and he routinely participates in AOPA Safety Seminars. However, Petitioner requests to be perm itted 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 dete rmining 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 A** **ircraft Flight Manual in the A ircraft.**  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 th e 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 n eeded. 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 fligh t. **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.

**s** UASs 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 fo r 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. I t 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 b e 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 A ltimeter 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 n ot 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 fore cast 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 2 5 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 2 5 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 2 5 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its pla nned 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): Carry ing Civil A** **ircraft Certification and Regist ration**  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 o r 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 req uire 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 pa rt 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. Ma inte nance 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 th e 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 an d 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 ope rations, 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 h erein, 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 ea ch 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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**Page 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 hi ghways 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 prio r 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.

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**Page 12**  VizTools LLC , 396 Washington Street, Suite 260, Wellesley Hills, MA 02481

- 6209 **Ad ditional 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 th e Yuneec Q500 4K Aircraft Applicant holds Commercial Pilot’ s Certificate with Instrument Rating and is fully familiar with Communic ations 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, el evated 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 Sup plemental Documents Blade Nano QX Manual Insurance Quotation N number registration Aircraft registration