February 20, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act. 

Dear Sir or Madam: 

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

Act"), AviTronics Integrated Solutions, LLC ("AviTronics"), the operator, David A. Akers 

(the applicant), planned operator of Unmanned Aircraft Systems (UASs) equipped to 

conduct aerial photography and digital point cloud surveys for various industries hereby 

applies for an exemption from Federal Aviation Regulations (FARs) to allow commercial 

operation of our UASs, 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. 

As described more fully in Appendix A, the requested exemption would permit the 

operation of UASs by the operator for commercial use that would provide the following 

benefits: 

1. Operations would be performed in an area of operation limited in size suitable to the 

specific use, in advance of flight. 

2. The flight would be planned in advance to minimize hazards to persons and property 

in the air and on the ground. 

3. The operator would reasonably limit or control access to provide safety to those not 

involved in the operation. 

4. Operation of a UAS would provide significant safety, environmental and other 

enhancements not possible by larger sized aircraft. 

5. An FAA licensed airman with a Commercial Pilot Certificate would operate the UAS 

or directly supervise the operation. 

6. Provide a beneficial and currently unavailable service to government organizations 

and the general public that would serve the public interest. 
Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA Administrators) responsibilities to " ... establish requirements 

for the safe operation of such aircraft systems in the national airspace system. "Section 

333(c) of the Reform Act. 

It is possible to operate an UAS so to not create a hazard to users of the National 

Airspace System (NAS), the public or pose a threat to national security if done so safely 

and responsibly. The applicant has demonstrated their willingness to act safely and 

responsibly by not engaging in commercial UAS operations. The applicant has worked 

within FAA guidelines to obtain a legal authorization to conduct commercial operations. 

Additionally, the fact that the applicant currently holds a FAA Commercial Pilot 

Certificate demonstrates that the applicant has a high regard to safe operations, as well 

as a necessary high-level understanding of the NAS and FARs. The experience of a 

FAA certificate serves to add significantly to the level of safety in any operation 

performed by the applicant or the applicant's employees. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

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

have the characteristics of UAS and that operate with the limitations listed herein. 

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

under the current regulatory structure as the proposed operations represent a safety 

enhancement to the already safe aerial commercial photography and survey operations 

conducted with conventional aircraft. 

The UASs planned to be operated are the OJI Phantom 2 Vision, DJI Phantom 2 Vision 

Plus, and the 30 Robotics IRIS Plus rotorcraft. Each unmanned aircraft (UA) is 

equipped with four rotors that are driven by electric motors, powered by batteries, and 

weigh less than 4 pounds, including payload. The UA would have a maximum airspeed 

of 30 knots. The principal construction material of these UA is plastic. Operations will 

be performed by a qualified UAS Pilot in Command (PIC), as outlined below, to insure 

that the UAS will "not create a hazard to users of the national airspace system or the 

public." Given the small size of the UAS involved and the pre-planned environment 

within which they will operate, the applicant believes that these operations fall 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 UAS to commence 

immediately. Also, operation in a researched (to include applicable NOTAMs), predefined area will prevent the possibility of a national security issue. The operation of 

UASs by knowledgeable professionals with experience in the NAS will serve to enhance 

safety, add to the public benefit and reduce environmental impacts related to current 

methods of aerial photography and survey. 

These limitations and conditions to which the operator, or its employees, acting as an 

UAS PIC, agrees to be bound when conducting commercial operations under an FAA 

issued exemption: 

1. Safety will be the first and foremost consideration in any UAS operation. 
2. The UAS pilot will be an FAA licensed airman with at least a Commercial Pilot 

Certificate or the UAS pilot will be directly supervised by an FAA licensed airman with at 

least a Commercial Pilot Certificate. 

3. The UAS Pilot, and observer will hold at least a Second Class Medical Certificate. 

4. The UAS FAA licensed airman will be considered PIC, whether flying or supervising, 

and will be responsible for safe operation of the flight. 

5. Flights will be conducted within line of sight of the PIC and an observer. 

6. Flights will be conducted in Class G airspace whenever possible. If an operation in 

another airspace is required, the relevant controlling agency will be notified at least 

24 hours prior to the operation and, if required, any necessary permission obtained. 

7. Flights will be conducted under visibility and cloud clearance requirements equivalent 

to Visual Flight Rules (VFR). 

8. The UAS will at all times give way to any aircraft, object, or persons. 

9. Minimum crew for each operation will consist of the UAS PIC and an observer. The 

observer and PIC will at all times maintain visual line of site to the UA, and be able to 

communicate by voice. 

10. Prior to a UAS flight, an area of operation will be established. This area of operation 

will include a defined lateral and vertical area, where the UAS will operate (Appendix J). 

Safety procedures will be established for persons, property and applicable airspace 

within the area of operation. 

11. Flight planning will include flight completion with at least 20% battery power 

remaining as measured by the UAS or appropriate timing. 

12. The UAS will utilize GPS navigation, failsafe, return-to-home (RTH) and/or flight 

abort safety features. 

13. A briefing will be conducted in regard to the planned UAS operations prior to 

operation at each new location (Appendix I through K). All personnel who will be 

performing duties within the boundaries of the area of operation will be present for this 

briefing. 

14. All required permissions and permits will be obtained from appropriate state, county 

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

governmental agencies. 

15. Written, to include electronic, and/or oral permission from the relevant property 

owners will be obtained prior to an operation. 
16. The UAS pilot will be trained in advance for the safe operation of the UAS to be 

operated. This will include operation of the UAS both in normal and emergency modes 

of operation as applicable, and will include familiarization with the operation manual (or 

similar) if published by the UAS manufacturer. Training will also include types of 

maneuvers to be performed and the safe operation in relation to persons, property and 

applicable airspace. 

Attached Appendix B, please find a letter from Technical Applications & Consulting, LLC 

requesting a UAS operation in Orange, Texas that will document a current landfill 

project. This operation serves as an excellent example of the benefits of using a UAS. 

It represents an enhancement in safety as well as benefiting the public interest. It is 

respectfully requested that the FAA grant an exemption as soon as possible to enable 

TAC's project to be documented within their time constraints. 

It is the applicant's belief that the size, speed, operating environment, limitations, and 

level of applicant's experience in the NAS outlined provides an "equivalent level of 

safety" or better when operating a UAS for the public interest as outlined in Section 333 

in the FAA Modernization and Reform Act of 2012. It is requested that the FAA issue 

an exemption to permit safe, legal, commercial UAS operation by the applicant as soon 

as possible. 

Sincerely, 

David Akers, President 

AviTronics Integrated Solutions, LLC 

P.O. Box 1644 

Rockwall, TX 75087 

972-708-1535 

Appendix A 

Appendix B 

Appendix C 

Appendix D 

Appendix E 

Appendix F 

Appendix G 

Appendix H 

Appendix I 

Appendix J 

Appendix K 

Exemption Requests and Equivalent Level of Safety 

Letter from Technical Applications & Consulting 

DJI Phantom 2 Vision User Manual 

DJI Phantom 2 Vision Plus User Manual 

3D Robotics IRIS Plus Operation Manual 

3D Robotics IRIS Plus Flight Checklist 

3D Robotics Gimbal User Guide 

AviTronics Flight Log Form 

AviTronics Project Risk Assessment Form 

AviTronics Project Concept Sheet 

AviTronics Project Brief/Debrief Form