U.S. Department of Transportation, Docket Operations West Building Ground 

Floor, Room w12-140

1200 New Jersey Avenue, S.E.Washington, DC 20590

Petition for Exemption Under 14 CFR § 11.81 to Allow Commercial Use of Unmanned 

Aircraft Systems

September 8, 2015

Petitioner:

Marvel Vision Industries

Pablo I. Marvel - Owner

25 Willow Place, Brooklyn, NY, 11201

Phone: (646) 240 0216

Email: mymarvelvision@gmail.com

Greetings,

This application is substantially based on the FAA's findings in Exemption No. 11062 

granted to Astraeus Aerial on September 25, 2014, and in reliance on the analysis 

provided therein.1. Sections from which exemptions are sought: Application is hereby 

made for exemption from:

a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 333

b. 14 CFR Part 21, subpart H

c. 14 CFR Part 61.113(a) and (b)

d. 14 CFT Part 91:

2. Relief sought:

i. 91.103(b)(2) 

ii. 91.105

iii. 91.109 

iv. 91.119

v. 91.121 

vi. 91.151 

vii. 91.405 

viii. 91.407 
ix. 91.409 

x. 91.417

2. Relief sought:

Marvel Vision Industries (MVI) wishes to operate Unmanned Aircraft Systems for 

commercial purposes to include (but not limited to) videography, photography, 

inspections and analyses. This relief is sought because commercial use of UAS is 

currently prohibited by law unless performed under an exemption.

b. This exemption will cover use of the following airframes, all of which will weigh less 

than 55 pounds including payload and energy sources: 

1. DJI models

a. DJI Phantom 3 Professional

b. DJI Inspire 1

c. DJI Spreading Wings s900

Other models to be added by future amendment to this exemption.

3. Public benefit:

a. Use of UAS technology to obtain imagery, information and data currently obtained by 

useof manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g.,powerline 

inspections) and due to other dangerous activities that can be avoided (e.g., 

scaffolding/rigging failures during stack or bridge inspections)

ii. Reduces the cost of obtaining such information, which benefits consumers and the 

economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from 

manned aircraft.

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and 

Part 47 and Part 45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the 

manufacturer.All repair and maintenance work will be conducted or approved by 

qualified personnelsuch as those authorized by DJI Los Angeles (or an east coast 

equivalent) after such work. Records of all maintenance and repair work will be kept in a 

maintenance log for each aircraft.
c. All flight operations will be conducted by two individuals who will maintain 

verbal communication capability with each other at all times during the flight, and who 

will remain stationary on the ground during the flight operations:

i. A Pilot In Command (PIC) who possess the following credentials:

1. An Airman Certificate issued under 14 CFR 61 (private pilot license)screened by the 

TSA

a. MVI may change PIC credentials when and if the FAA makes a change to (PIC)

credentials under current proposed framework and regulations changes dated September 

8, 2015.

2. A Third Class medical certificate issued under 14 CFR 67.

3. A Bi-annual flight review under 14 CFR 61.56

4. A completion of a course of instruction in safe UAS flying conducted by Unmanned 

Experts Inc. (or equivalent).

5. At least 200 cycles and 25 hours of flight experience in a UAS rotorcraft(or UAS 

fixed-wing in the case of fixed-wing flight operations under thisexemption). Such cycles 

and hours may be gained during flights under this exemption if a safe distance is 

maintained from persons inaccordance with 14 CFR 91.119.

6. At least 5 hours of flight experience and 3 takeoffs and landings in makeand model 

being flown in the prior 90 days. Such cycles and hours maybe gained during flights 

under this exemption if a safe distance ismaintained from persons in accordance with 14 

CFR 91.119.

ii. A Visual Observer.

d. All flight operations will be conducted in accordance with valid Certificates of 

Authorizatione. All flight operations will comply with the following:

i. The manufacturers' Aircraft Flight Manuals and operation guidelines

ii. MVI flight operations policies including lost communication and 

otheremergency and safety procedures.

iii. Conducted in VMC conditions during daylight hours

iv. PIC and VO will maintain VLOS at all times.

v. Pre-flight inspections (including ground control station, if any) and safety risk 

assessments will be conducted prior to each flight 

vi. Flight altitudes will remain below 400 feet above ground level

vii. Flight ground speeds will not exceed 50 knots. 

viii. Not intrude into Class B, C or D airspace, or published approach, SID or 

STAR, or take place within 5 miles of an airport

ix. Not be made near persons as required in 14 CFR 91.119 and not over persons 

onthe ground without their prior permission
x. Each flight will be logged in both the PIC's logbook and the aircraft logbook

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 

minutes,whichever occurs first.

xii. Any incidents will be reported within 24 hours of occurrence.

xiii. MVI will maintain liability insurance of at least $1,000,000 issued by USAA 

Insurance or equivalent insurer.

xiv. Any applicable local FSDO requirements.

xv. All other applicable regulations concerned with the operation of aircraft.

f. Aircraft will use 2.4 GHz for control of the aircraft, and 5.8 GHz for sending data.

Please advise us of any additional information or changes that are required.

Sincerely,

Pablo Marvel

Owner – Marvel Vision Industries (MVI)

(646) 240 0216

mymarvelvision@gmail.com