**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, 201 5

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 b ased 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 Moder nization 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. 91.407ix. 91.409

x. 91.417

2. Rel i e f 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 bec ause 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 Professio nal

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

use of manned flight or manual meth ods:

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 t he 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 a nd 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 personnel s uch 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 wil l 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 In c. (or equivalent).

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

fixed

- wing in the case of fixed

- wing flight operations under this exemption). Such cycles and hours may be gained during flights under this exemption if a safe distance is maintained from persons in accor dance with 14 CFR 91.119.

6. At least 5 hours of flight experience and 3 takeoffs and landings in make and model being flown in the prior 90 days. Such cycles and hours may be gained during flights under this exemption if a safe distance is maintained fro m 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

Authorization e. All flight operations will comply with the following:

i. The manufacturers' Aircraft Flig ht Manuals and operation guidelines

ii. MVI flight operations policies including lost communication and

other emergency and safety procedures.

iii. Conducted in VMC conditions during daylight hours

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

v. Pre

- flight inspection s (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

on the ground without their prior permissionx. 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. A ny 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