Vi sion It Now, Inc.

Bett y Henline 11 9 S Buf falo Street Warsaw, IN 46580 (574) 268

- 9800 betty @visionitnow .com Dear Sir or Madam: This petition is being submitted on my behalf without legal counsel or consulting services. Pursuant to Section 333 of the F A A Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F .R. Part 1 1, Betty

Henline, multimedia producer of Vi sion It Now, Inc, hereb y applies for an exemption from the Federal Av iation Regulations (F ARs) listed below to allow operation of our Unmanned Aircraft Sy stem (UAS) commercially in airspace regulated by

the Federal Av iation Administration (F

AA) so long as such operations are conducted with and under the conditions outlined herein or as may

be established by

the F AA as required by

Section 3 33. The requested exemption would permit Bett y Henline to pursue her commercial interests in providing services to clients using an UA V in the following areas: Photography , Vi deo and Special Events. Betty Henline states that all UAS flights will occur ove r private or controlled access property and will do so with the propert y owner's consent and knowledge and that only people who have consented or otherwise have agreed to be within the UAS’radius during filming and photography applications.
Bett y Henline has demonstrated the ability to safely and effectivel y fl y the UAS DJ I Phantom 3 Professional which will be used for all commercial and private purposes. Betty Henline complies with local ordinances and laws regarding the operation of the UAS, and adheres to all weather and environmental restrictions or limitations in reference to the operations of the UAS. All flights will occur in ordinance with an y state or local laws regarding privacy

. I, Bett y Henline, am seeking the exemption because I am committed to complying with all of the rules, guidelines, limitations, and future legislation set forth by the F AA. I agree to operate the UAS in the manner that I have described, and for the purposes that Ihave described. Wi thout the exemption request granted, I would be unable to safel y and ef fectively of fer these services to my

customers, and it is my intention to comply

with the F

AA and obtain an exemption of the following regulations. The following contains my list of regulations from which I am seeking exemp tion, and a complete list of responsibilities Iassume as operator; it also contains information regarding the aircraft, public benefit and safet y features, and similar petitions requests granted.Regulations from which exemption is requested:

14 C.F .R. Part 21 14 C.F .R. 45.23(b) 14 C.F .R. 61.1 13(a) & (b) 14 C.F .R. 91.7(a) 14 C.F .R. 91.9(b) (2) 14 C.F .R. 91.109 14 C.F .R. 91.1 19 14 C.F .R. 91.121 14 C.F .R. 91.151(a) 14 C.F .R. 91.203(a) & (b) 14 C.F .R. 91.205(b) 14 C.F .R. 91.215 14 C.F .R. 91.401

- 91.417
I , THE OPERA

TOR, ASSUME THE FOLLOWING RESPONSIBILITIES 1. Operations authorized by this grant of exemption are limited to the DJ I Phantom 3 Professional when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 2. Operations for the purpose of closed

- set motion picture and television filming are not permitted. 3. The UA

may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemptio n holder may

use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended b y the aircraft manufacturer

. 4. The UA

must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA

must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PI C to be able to use human vision unaided by any device other than corrective lenses, as specified on the PI C’ s F

AA

- issued airman medical certificate or U.S. driver ’s license.
6. All operations must utilize a visual observer (VO). The UA must be operated within the visua l line of sight (VLOS) of the PI C and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC alway s maintains VLOS capability . The VO and PI C must be able to communicate verball y at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.7. This exempti on and all documents needed to operate the UAS and conduct its operations in

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessibl e during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein tak e precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator ’s responsibility to track such revisions and present updated and revised documents to the Administrator or an y law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would af fect the basis upon which the F

AA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The F

AA ’s UAS Integration Office (AFS −80) may be contacted if questions arise regardi ng updates or revisions to the operating documents.
8. An y UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight p rior to conducting further operations under this exemption. Functional test flights may onl y be conducted b y a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pos e an undue hazard to persons and property

. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PI C must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that af fects the safe operation of the UAS, the aircr aft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.
11 . The operator must follow the UAS manufacturer ’s maintenance, overhaul, replacement, inspection, and life lim it requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safet y bulletins. 13. Under this grant of exemption, a PI C must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current F AA airman medical certificate or a valid U.S. driver ’s license issued b y a state, the District of Columbia, Puerto Rico, a territory , a possession, or the Federal government. The P IC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.14. The operator may not permit any PIC to operate unless the PI C demonstrates the abilit y to safel y

ope rate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PI C qualification flight hours and c urrency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator ’s PI Cs and VOs (training, proficiency

, and experience

- building) and determining the PIC’ s ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may onl y be conducted during dedicated training sessions. During training, proficiency , and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.1 19. 15. UAS operations may

not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA

may not operate within 5 nautical miles of an airport reference p oint (ARP) as denoted in the current F

AA A irport/Facilit y Directory (AFD) or for airports not denoted with an ARP , the center of the airport s ymbol as denoted on the current F AA

- published aeronautical chart, unless a letter of agreement with that airport’ s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or an y law enforcement official upon request. 17. The UA

may not be ope rated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility

is less than 3 statute miles from the PI C. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

- determined location within the private or controlled

- access property

. 19. The PI C must abort the flight in the event of unpredictable obstacles or emergencies. 20. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater

. 21. Air T raf fic Organization (A

TO) Certificate of W

aiver or Autho rization (COA). All operations shall be conducted in accordance with an AT O

- issued COA. The exemption holder may appl y for a new or amended COA

if it intends to conduct operations that cannot be conducted under the terms of the attached COA.
22. All aircr aft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N −Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practic able. 23. Documents used b y the operator to ensure the safe operation and flight of the UAS and an y documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the UAS any time the aircraft is operating . These documents must be made available to the Administrator or any law enforcement of

ficial upon request.24. The UA

must remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may not be operated b y the PI C from any moving device or vehicle.
26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that suf ficiently protect nonparticipatin g persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediatel y i n a manner ensuring the safet y of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permissio n for operating closer to those objects and the PIC has made a safet y assessment of the risk of operating closer to th ose objects and determined that it does not present an undue hazard. The PI C, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.
27. All oper ations shall be conducted over private or controlled

- access property wi th permission from the propert y owner/controller or authorized representative. Permission from propert y owner/controller or authorized representative will be obtained for each flight to be conducted.
28. An y incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA

must be reported to the F AA's UAS Integr ation Of fice (AFS −80) within 24 hours. Acc idents must be reported to the National Tr ansportation Safet y Board (N TSB) per instructions contained on the NTSB We b site: www .ntsb.gov

. S imilar E xemptions They are similar in all/or many material respects to relief previously requested in Grant of Exemp tion Nos. 1 1062, 111 09, 1 111 2, and 1 1213

. Public Benefit and Safety Unmanned Aircraft Sy stem UA Vs are often seen as superior to helicopters as an aerial video gathering platform due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safety

. Bett y Henline is petitioning for an exemption to operate a DJ I Phantom 3 Professional with a built

- in stabilized HD camera and GPS s afety features which limit the height it flies above ground level (AGL), to limit the radius of the distance it flies from the operator and to exclude it from operations within designated Class B, C and D airspace including a no

- fly zone feature. The DJ I Phantom 3 Professional also has a failsafe function that is triggered in the event co mmunication is lost between the UAS and the main controller transmitter

. At that time, the UAS will return to its point of takeof f and land safet y. I f the connection is re stored, the PI C can regain control of flight and land manually

. These specifications meet with the Model Aircraft Operating Standards as set below: The petitioner will only

operate its UAS in line

- of

- sight of a pilot and/or observer and will operate at sit es that are `suf

ficient distance' from populated areas within the sterile area described in the FO PM. Such operations will ensure that the UAS will "not create a hazard to users of the national airspace sy stem or the public."