FROM:

Vertical Limit Aviation LLC 7401 Atrisco Vista Blvd. #2 Albuquerque, NM 87120 Tel: 505-831-4354

TO:
DOCKET OPERATIONS ROOM W12-140 OF THEWEST BUILDING GROUND FLOOR 1200 NEWJERSEY AVENUE, SE. WASHINGTON, DC, 20590 Regulatory DocketNo.

_____ _

PETITIONFOREXEMPTION OF: Vertical LimitAviation LLC FORANEXEMPTION SEEKINGRELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERALREGULATIONS PART 21, SUBPARTHAND SECTIONS§§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & 

### (b) CONCERNING COMMERCIAL OPERATION OF A CUSTOM BUILD Quanum 680UC Pro Hexa-Copter UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAAMODERNIZATIONAND REFORMACT OF 2012 (PUBLIC LAW 112-95)

Submitted on 

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UAV Aerial Video for Exemption Page 1

### TABLE OF CONTENTS

GLOSSARY OFABBREVIATIONS

.........................................................................................3 SUMMAR¥

................................................................................................................................4 INTRODUCTIONAND INTERESTS OF PETITIONER

........................................................4 BACKGROUND

.........................................................................................................................4 BASIS FOR PETITION

..............................................................................................................5
NAMEAND ADDRESS OF PETITIONER

...............................................................................7
THE SPECIFIC SECTIONS OF 14 C.F.R FROM WIDCH Vertical Limit Aviation LLC SEEKS EXEMPTION

..............................................................................................................................8
THE EXTENT OFRELIEF Vertical Limit Aviation LLC SEEKS AND THE REASON Vertical Limit Aviation LLC SEEKS THE RELIEF

...................................................11
THE REASONS WHY GRANTING Vertical Limit Aviation LLC REQUEST WOULD BE IN THE PUBLIC INTEREST

........................................................................... 15
THE REASONS WHY GRANTING THE EXEMPTIONWOULD NOT ADVERSELY AFFECT SAFET¥

............................................................................................ 19 SUMMARYTHAT CAN BEPUBLISHED IN THE FEDERAL REGISTER

........................33 ANYADDITIONAL INFORMATION, VIEWS, ORARGUMENTS CONCLUSION

.........................................................................................................................33

UAV AerialVideo for Exemption Page 2AGL AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS NOTAM PIC Section 333 

## so SOP UA UAS 

### VFR VLOS VMC VTOL GLOSSARY OF ABBREVIATIONS

Above Ground Level Area ofInterest Air Traffic Control Air Traffic Organization Aerial Vehicle Code ofFederal Regulations Certificate ofAuthorization FederalAviation Administration Federal Aviation Regulation Ground Control Station Global Positioning System Loss ofLink National Airspace System Noticeto Airman Pilot In Command FAAModernization and Reform Act of2012 (FMRA) Section 333 Safety Observer Standard Operating Procedures Unmanned Aircraft Unmanned Aircraft System Visual Flight Rules Visual Line ofSite Visual Meteorological Conditions Vertical Takeoffand Landing

UAV Aerial Video for Exemption Page3

### SUMMARY Vertical Limit Aviation LLC seeks exemption from the requirements of 14 C.F.R 

### §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l)& (a) (2), and 91.417(a) & (b), to operate an UnmannedAircraft System pursuant to Section 333 ofthe FAAModernization and ReformAct of2012 (FMRA). This exemption will permit Vertical Limit Aviation LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose ofconducting aerial video and photography ofReal EstateProperties (for homeowners, realtors, home builders, home contractors and 

### I or home inspectors for real estatemarketing and inspection ofhome exteriors) as well as filming ofspecial events, film sets, scripted and unscripted television sets and landscape, conducting powerline inspection, aerial mapping, surveying and search andrescue over certain areas ofthe United States.


### INTRODUCTIONAND INTERESTS OFTHE PETITIONER Vertical Limit Aviation LLC is a Helicopter companybased in Albuquerque specializing in flight training, tours, part 135 operations, photography, special events, law enforcement and news gathering. Vertical LimitAviation's objective is to conduct aerial photography and videography in orderto provide high quality digital imaging and video content to its clients, in particularto homeowners, real estate agents, realtors, home builders, home contractors, and/or home inspectors for real estate marketing and inspections ofhome exteriors as well as filming ofspecial events, film sets, scripted and unscripted television sets and landscape, conducting powerline inspection, aerial mapping, and surveying. Vertical Limit AviationLLC will beutilizing a custom built Quanum 680UC ProHexa-Copter UAS. More specifically, Vertical Limit Aviation LLC aerial video and photography operations will serve in the following areas:

• Aerial photography ofhouses 

### I residential and commercial buildings and power lines
• Aerial videography ofhouses 

### I residential and commercial buildings and power lines
• Aerial event photography
• Aerial event filming
• Aerial Film & Television production
• Aerial Safety inspections
• Increase public knowledge ofUAS and promote safe UAS operations

UAV Aerial Video for Exemption Page4The proposed aerial filming will be conducted by a FAA commercial pilot license holder.



### UnmannedAircraft Systems: Quanum 680UC Pro Hexa-CopterUAS

Vertical Limit Aviation seeks an exemption to operate a custom Quanum 680UC Pro Hexa-Copter DRONE for compensation orhire within the NAS. The custom Quanum 680UC Pro Hexa-Copter is a vertical takeoffand landing (VTOL) Unmanned Aircraft (UAS) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The Quanum 680UC Pro Hexa-Copter has a maximum gross weight ofapproximately 15 pounds, while having a length of 36 inches width of36 inches, height of20 inches, and a maximum speed ofapproximately 35 knots. The Quanum 680UC ProHexa-CopterUAS is equipped with six main rotors; driven by Brushless Mulirotor battery powered electric motors.

The Quanum 680UC Pro Hexa-Copter that will be operatedby Vertical Limit Aviation LLC (trained professional) and will be registered in accordance with 49 U.S.C. 44103, Registration ofAircraft, as well as 14 C.F.R Part47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION Petitioner, Vertical Limit Aviation LLC, pursuant to the provisions of the 

### Federal Aviation Regulations (14 C.F.R. 

### § 11.61) and the 

### FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain UnmannedAircraftSystems, hereby petitions the Administrator to commercially operate a custom Quanum 680UC Pro Hexa-Copter UAS inthe National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R 

### §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b).

UAV Aerial Video for Exemption Page6In consideration ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Vertical Limit Aviation LLC operation ofa custom Quanum 680UC ProHexa-CopterUAS meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Vertical Limit Aviation LLC requests relieffrom Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) 

### & (a)(2), and 91.417(a) 

### & (b), as these sections set forth requirements for maintenancethat only apply to aircraft with an airworthiness certificate. Vertical Limit Aviation LLC submits that the requested reliefis proper since an equivalent
level of safety will be ensured. Vertical LimitAviation LLC will use trained personnel or
technicians to perform maintenance, alterations, or preventive maintenance onthe UAS's using the methods, techniques, and practices prescribed in the operating documents. Furthermore, Vertical Limit Aviation LLC will document and maintain all maintenance records for the Quanum 680UCProHexa-Copter UAS.

Relieffrom certain requirements ofSection 61.113(a) and 

### (b), entitled Privatepilotprivileges and limitations: Pilot In Command, is requested by Vertical Limit Aviation LLC to the extent necessary to allow a Pilot in Command (PIC) holding a Commercial Pilots License, and who has demonstrated, by meeting minimum flight- hour and currency requirements, thatthe PIC is able to safely operate the Quanum 680UC Pro Hexa-Copter UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Vertical Limit Aviation LLC seeks relieffrom Section 91.7(a), entitled Civil aircraft airworthiness, because the Quanum 680UC ProHexa-CopterUAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Vertical Limit Aviation LLC submits that itwill ensure thatthe Quanum 680UC ProHexa-CopterUAS are in an airworthy condition, prior to every flight, by determining that the UAS's are in compliance with the operating documents, and thatthe aircraft is in a condition for safe flight. Vertical Limit Aviation LLC also seeks an exemption from the requirements ofSection

UAV Aerial Video for Exemption Page791.121, entitledAltimeter Settings, as the Quanum 680UC Pro Hexa-Copter UAS will not have
a typical barometric altimeter onboard. However, altitude information ofthe Quanum 680UC ProHexa-CopterUAwill be providedto the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UAto the GCS for active monitoring ofthe flight path. This altitude information, combinedwith Vertical Limit Aviation LLC operation ofthe Quanum 680UCProHexa-CopterUAS within visual line ofsight, at or below 200 feet AGL, will ensure a level ofsafety equivalentto Section 91.121.
Additionally, Vertical Limit Aviation LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Vertical Limit Aviation LLC submitsthat safety will not be affected by operation ofthe Quanum 680UC Pro Hexa-Copter Professional UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery powerto fly for a total duration ofapproximately 15 minutesto the first point ofintended landing and, assuming normal cruising speed, to fly afterthat for at least 5 minutes.

In accordance with 14 C.F.R. 

### § 11.81, Vertical Limit Aviation LLC provides the following information in support ofits petition for exemption:

A. Name AndAddress OfThe Petitioner.

The name and address ofthePetitioner and point ofcontact is: Douglas Christian Vertical Limit Aviation 7401 Atrisco Vista Blvd #2 Albuquerque, 

### NM 87120 Tel: 505-831-4354 Email: DJ@verticallimitaviation.com

UAV Aerial Video for Exemption Page8B. The Specific Sections Of14 

### CF.R. From Which Vertical Limit Aviation Seeks Exemption. 1. (removed) 2. Vertical Limit Aviation LLC Seeks Exemption From The Requirements OfSection 91.7(a). Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Vertical Limit Aviation LLC Seeks ExemptionFrom The Requirements OfSection 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level ofthat aircraft, as the case may be, by reference to an altimeterthat is set, when operating--

(1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a)(l)(i) of this section, the current reported altimeter setting ofan appropriate available station; or (iii) Inthe case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure.

UAV Aerial Video for Exemption Page94. Vertical Limit Aviation LLC Seeks Exemption From The Requirements OfSection 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. Vertical Limit Aviation LLC Seeks Exemption From The Requirement OfSection 91.405(a). Section 91.405, entitled Maintenancerequired, subsection (a), statesthe following: Each owner or operator ofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter[.]

6. Vertical Limit Aviation LLC Seeks ExemptionFrom The Requirements OfSection 91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-- (1) It has been approved for return to service by a person authorized under§ 43.7 ofthis chapter[.]

7. Vertical Limit Aviation LLC Seeks Exemption From The Requirements OfSections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had-- ( 1) An annual inspection in accordance with part 43 ofthis chapter and has

UAV Aerial Video for Exemption Page 10been approved for return to service by a person authorized by§ 43.7 of this chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance with part 2I ofthis chapter.

8. Vertical Limit Aviation LLC Seeks ExemptionFrom The Requirements Of Sections 91.4I7(a)And 91.4I7(b). Section 9I.4I7, entitled Maintenancerecords, subsections (a) and (b), state the following: (a) Except for work performed in accordance with§§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section: (I) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe I00-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and eachengine, propeller, rotor, and appliance ofan aircraft. The records must include-- (i) A description (orreferenceto data acceptable to theAdministrator) of the work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe person approvingthe aircraft for returnto service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor. (ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) Thetime since last overhaul ofall items installed onthe aircraft which
are required to be overhauled on a specified time basis. (iv) The current inspection status ofthe aircraft, including the time sincethe last inspection required by the inspection program under which the

UAV Aerial Video for Exemption Page 11aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, theAD or safety directive number and revision date. 

### IftheAD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§ 43.9(d) ofthis chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(l) ofthis section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft atthetime the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operatorunder§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. 

### C. The Extent Of ReliefVertical LimitAviationLLCSeeksAnd The Reason Vertical LimitAviation Seeks The Relief. 1. Extent OfReliefVertical Limit Aviation LLC Seeks And The Reason UA V Aerial Video Seeks ReliefFrom Section 61.113(a) And (b). Relieffrom Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested

### tothe extent necessaryto allow a PIC holding a Supplemental Pilot Certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conductthe proposed UAS flight operations for compensation or hire. This reliefis requested since the limitations set forth in Section 61.113(a) and (b) statethat a private pilot may, for compensation or hire, act as PIC ofan aircraft in connection with any business or employment if: (1) The flight is only

UAV Aerial Video for Exemption Page 12incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, Vertical Limit Aviation LLC submits that an equivalent level ofsafetywill be maintained because no PIC will be allowed to operatethe Quanum 680UC Pro Hexa-Copter UAunless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate eitherthe Quanum 680UCProHexa-CopterUAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Vertical Limit Aviation LLC submits that all flights ofthe Quanum 680UC ProHexa-Copter UAS, conductedbythe PIC pursuant to the grant ofthis Petition: (1) will be incidental to Vertical Limit Aviation LLC business; and (2) will not carry passengers or property for compensation orhire.
Vertical Limit Aviation LLC believes thatthough UAS are not traditional aircrafts, a PIC operating the UAmust have knowledge ofAirman rules, basic Airspace and comply with all the rules proposed bythe FAA. However, considering the fact that a UAis much smaller in both size and weight, the PIC may be except from obtaining a Private Pilot Certificate, a Sports Certificate, a Recreational Certificate considering these certificates require flight hours of actual full size aircrafts. Lastly, Vertical Limit Aviation LLC PICs will operate the UAS no higher than 200 feet, consequently causing no danger do any other aircraft in the NAS. However, Vertical Limit Aviation LLC Proposes PIC Certification as a Supplemental pilot and a minimum requirement ofsuccessfully completed private pilot ground school. Additionally, supplemental pilots without
a current FAAprivate pilot

UAV AerialVideo for Exemption Page 13certificate must have successfullypassed the private pilot, commercial pilot, or airline transport pilot knowledge test within the past 24 calendar months. 2. Extent OfReliefVertical Limit Aviation LLC Seeks And The Reason UA V Aerial Video Seeks ReliefFrom Section 91.7(a). Relieffrom Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Vertical Limit Aviation LLC to determinethatthe Quanum 680UC Pro Hexa-Copter UAS are in airworthy condition prior to every flight by ensuring thatthe UAS is in compliance with the operating documents. Vertical Limit Aviation LLC seeks the requested reliefbecausethe Quanum 680UC ProHexa-Copter UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Vertical Limit Aviation LLC will ensure that the Quanum 680UC Pro Hexa-CopterUAS are in airworthy conditionbased upon its compliance with the operating documents priorto every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below. 3. Extent OfReliefVertical Limit Aviation LLC SeeksAnd TheReason UAV Aerial Video Seeks ReliefFrom Section 91.121. Relieffrom Section 91.121, entitled Altimeter settings, may be required to allow flight operations ofthe Quanum 680UCProHexa-CopterUAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communicationstelemetry data link to downlink altitude information from the UAto the PIC at the ground control station (GCS). Since the FAArequires that any altitude information concerning UAS operations be reportedto air traffic control (ATC) in feet above ground level (AGL), Vertical Limit Aviation LLC seeks the requested reliefbecause the Quanum 680UC Pro Hexa-Copter UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field

UAV Aerial Video for Exemption Page 14altitude, before each flight.Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is sought to the extent necessaryto comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level ofsafety will be maintained since the Quanum 680UC ProHexa-CopterUAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensuresthat a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information ofthe UAon the heads-up display ofthe GCS.

4. Extent OfReliefVertical Limit Aviation LLC Seeks And The Reason UAV Aerial Video Seeks ReliefFrom Section 91.151(b). Relieffrom Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights ofthebattery powered Quanum 680UC ProHexa-CopterUAS during daylight hours in visual meteorological conditions (VMC), undervisual flight rules (VFR), for a total duration of 15 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. Vertical Limit Aviation LLC seeks the requested reliefbecause without an exemption from Section 91.151(b), the flight time duration ofthe batterypowered Quanum 680UC Pro Hexa-Copterwill severely constrain the practicality ofany aerial video or still photo flight operations that Vertical Limit Aviation LLC proposes to conduct pursuanttothis Petition. Significantly, as set forth below, the technical specifications ofthe Quanum 680UC ProHexa-CopterUAS operating documents, and Vertical Limit Aviation LLC proposed operating limitations, ensure that Vertical LimitAviation LLC will safely operate thebatterypowered Quanum 680UC ProHexa-CopterUAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery powerto fly for a total duration of 15 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

UAV Aerial Video for Exemption Page 155. Extent OfReliefVertical Limit Aviation LLC SeeksAndThe Reason Vertical Limit Aviation LLC Seeks ReliefFrom Section 91.405(a), 91.407(a)(l), 91.409(a) (1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only applyto aircraft with an airworthiness certificate, Vertical Limit Aviation LLC requests relieffrom these Sections because the Quanum 680UC Pro HexaCopter UAS do not require a airworthiness certificate. As set forth more fully below, the Quanum 680UCPro Hexa-CopterUAS meet the conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, Vertical Limit Aviation LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance onthe UAS using the methods, techniques, and practices prescribed in the UAS operating documents. Furthermore, Vertical Limit Aviation LLC will document and maintain all maintenance records for the Quanum 680UC Pro Hexa-Copter UAS.

D. The Reasons Why Granting Vertical LimitAviation LLCRequest WouldBeIn The PublicInterest; That Is, HowIt WouldBenefit The PublicAsA Whole. Granting the present Petition will further the public interest by allowing Vertical Limit Aviation LLC to safely, efficiently, and economicallyperformaerial video and photography ofreal estate, special events, film sets, and landscape over certain areas ofthe United States. Additionally, use ofthe Quanum680UCProHexa-CopterUAS will decrease congestion ofthe NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits ofVertical Limit Aviation's proposed operation ofthe Quanum 680UC Pro Hexa-Copter UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit FromDecreased Congestion OfThe NAS.

UAV Aerial Video for Exemption Page 16The Quanum 680UC Pro Hexa-CopterUAare battery powered and serve as a safe, efficient, and economical alternativeto the manned aircraft traditionally utilized to obtain aerial imagery. Byreducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa Quanum 680UC Pro Hexa-CopterUAS would reduce the amount ofmanned aircraft inthe NAS, reduce noise and air pollution, as well as increasethe safety oflife and property in the air and on the ground. Furthermore, byreducing the number ofmanned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The Quanum 680UC Pro Hexa-CopterUAdo not require an airport to takeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial video and photographymissions would result in fewer aircraft that must be handled by air traffic control duringthe ground, takeoff, departure, arrival, and landingphases offlight operations.

2. The Public Will Benefit From The SafetyAnd Efficiency OfThe Quanum 680UC Pro Hexa-Copter UAS. Conducting aerial acquisitions with the Quanum 680UC Pro Hexa-CopterUAS, instead ofmanned aircraft, will greatly benefit the public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. Byusing battery power and electric motors, the Quanum 680UC ProHexa-Copter UAS produce no air pollution, and is the most viable environmentally conscious alternativeto the cabin class, six cylinder internal combustion engine aircraft that are typicallyutilized for aerial video and photography, while burning approximately 20-30 gallons per hour ofleaded aviation fuel. The Quanum 680UC ProHexa-CopterUA, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, astheUAS
are propelled by battery powered electric motors, ratherthan an internal combustion engine. By using the Quanum 680UC Pro Hexa-CopterUAS to perform aerial acquisitions, the substantial risk to life and property in the air and

UAV Aerial Video for Exemption Page 17on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack offlight crew members located onboard the aircraft, the Quanum 680UC Pro Hexa-Copter UAS, has less physical potential for collateral damage to life and property onthe ground, and in the air, compared tothe manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The Quanum 680UC Pro Hexa-Copter UAS Will Benefit The Economy. In addition to being safe and efficient, the Quanum 680UC ProHexa-Copter is also
an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation ofthe Quanum 680UCProHexa-CopterUAS will allow United States based companies, like Vertical Limit Aviation LLC, to remain competitive and contributeto growth ofthe U.S. economy. Specifically, with the rising cost ofaviation fuel and the Environmental ProtectionAgency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in orderto remain competitive. Operating the battery powered Quanum 680UC ProHexa-CopterUAS is one such technology that not only allows companies greateroperational flexibility compared to manned aircraft, butprovides such flexibility without the high operational cost ofa traditional manned aircraft. Byoperating the Quanum 680UC ProHexa-CopterUAS, companies such as Vertical Limit Aviation LLC, can remain competitive and profitable, and therefore, provide greaterjob stabilityto employees and contractors, which will ultimately contributeto growth ofthe U.S. economy. Improved financial

UAV Aerial Video for Exemption Page 18performance ofU.S. companies, through commercial use ofthe Quanum 680UC ProHexa-CopterUAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companiesto invest in research and developmentin orderto remain competitive both inthe United States and abroad.

4. ThereAre No Privacy Issues. Similarto the manned aerial acquisition flight operations that have been conducted for decades, Vertical Limit Aviation LLC proposed operation ofthe Quanum 680UC Pro Hexa-CopterUAS will not implicate any privacy issues. Specifically, the Quanum 680UC ProHexa-CopterUAS will be operated only in compliance with operating documents, which requires property ownerinvolvement as well as local law enforcementnotification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. 

### § 91.119.



### E. The Reasons Why 

### Granting The Exemption Would Not AdverselyAffect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To ThatProvidedBy The Rule From Which Vertical LimitAviationLLCSeeks Exemption.
1. Reasons Why The Quanum 680UCProHexa-CopterUAS Meet The Conditions Of The FAA Modernization and Reform Act of2012 (FMRA) Section 333. In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Vertical Limit Aviation LLC operation ofthe Quanum 680UC Pro Hexa-Copter UAS meet the conditions ofFMRASection 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, SubpartH. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose a threatto national security.

UAV Aerial Video for Exemption Page 19Specifically, FMRA Section 333 statesthe following, in part: (a) In GeneraL--Notwithstanding any other requirement ofthis subtitle, and not laterthan 180 days afterthe date ofenactment ofthis Act, the Secretary of Transportation shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe plan and rule-making required by section 332 ofthis Act orthe guidance required by section 334 ofthis Act. (b) Assessment ofUnmanned Aircraft Systems.--In making the determination under subsection (a), the Secretary shall determine, at a minimum-- 

### (I) which types ofunmanned aircraft systems, ifany, as a result oftheir size, weight, speed, operational capability, proximityto airports and populated areas, and operation within visual line ofsight do not create
a hazard to users ofthe national airspace system orthe public or pose a threatto national security; and (2) whether a certificate ofwaiver, certificate ofauthorization, or airworthiness certificationunder section 44704 oftitle 49, United States Code, is required for the operation ofunmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.--Ifthe Secretary determines underthis section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation ofsuch aircraft systems in the national airspace system. In seeking this exemption, Vertical Limit Aviation LLC submitsthat the Quanum 680UC Pro Hexa-CopterUAS can operate safely intheNAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics ofthe Quanum 680UC Pro Hexa-CopterUAS; (b) the pilot certificationrequirement; and (c) the specific operating limitations.



### a. The Specifications Of

### The Quanum 680UC Pro Hexa-Copter UAS Demonstrate Its Safe Characteristics.

UAV AerialVideo for Exemption Page 20

### The Quanum 680UC Pro Hexa-CopterUAS does not create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications OfThe Quanum 680UC Pro Hexa-CopterUAS. The technical specifications ofthe Quanum 680UC Pro Hexa-Copter UAS is set forth by the Quanum 680UC Pro Hexa-Copter Specifications and Data Sheet, attached hereto as ExhibitA.



### ii. The Quanum 680UC Pro Hexa-CopterUAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area. The Quanum 680UC Pro Hexa-CopterUAS may be operated in both manual and fully autonomous flight modes.

iii. The Quanum 680UC Pro Hexa-CopterUAS Are DesignedFor Automatic Return To Home Point Or Hover In The Event OfLoss OfThe Control Link OrNavigation. When the Control Link is lost, the Quanum 680UC Pro Hexa-Copter UA will remains stationary, in flight, for 3 seconds or more. If, 

### after 3 

### seconds, the Quanum 680UC Pro Hexa-Copter UA does not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode}via GPS, and will descend to the takeoffposition and shutdown.

UAV Aerial Video for Exemption Page 21

### b. Flight Operations OfQuanum 680UC Pro Hexa-Copter UAS Are Limited To The Line Of

### Sight Of

### A Certificated Pilot in Command With A Safety Observer. Vertical Limit Aviation LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the Quanum 680UC Pro Hexa-Copter UAS. Additionally, a safety observerwill assist all pilots during flight time when determined nessisary by the PIC.



### c. Flights OfQuanum 680UC ProHexa-CopterUAS Will Be Conducted PursuantTo Specific Operating Limitations. In seeking this exemption, proposes to commercially operate Quanum 680UC Pro Hexa-CopterUAS for the special purpose ofconducting aerial video and photography over certain areas ofUnited States, pursuantto the following specific operating limitations:

1. Operations authorized by this grant ofexemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 

### 55 pounds maximum gross weight: Quanum 680UC Pro Hexa-CopterUnmanned Aircraft System. Proposed operations ofany other aircraft will require a new petition ora

.petition to amend this grant.


### UAV Aerial Video for Exemption Page 222. UAS operations under this exemption will be limited to conducting operations for the purpose ofaerial video and photography for homeowners, Realtors, home builders, contractors, home inspectors for use in real estate marketing and real estate inspections. Additionally, aerial video and photography may be conducted on occasional basis for film and television sets, special events and landscape photography, conducting power line inspection, aerial mapping, surveying as deemed necessary.

3. The UAS may not beflown at an indicated airspeed exceeding 35mph.

4. The UAS must be operated at an altitude ofno morethan 200 feet above ground level (AGL), as indicatedbythe procedures specified in the operating documents unless a special request is made and approved byATC. All altitudes reported toATC must be in feet AGL.

5. The UAS must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device otherthan corrective lenses, as specified on the PIC's FAA-issued airman medical certificate.

6. The use offirst person view (FPV) by thePIC or safety observer (SO) is not permitted.

7. PIC will determine what operations will utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicateverbally at all times. Electronic messaging ortexting is not permitted during flight operations. ThePIC must be designated before the flight and cannottransfer his orher designation for the duration ofthe flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents,

UAV Aerial Video for Exemption Page 238. The SO must not petform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operatethe camera or other instruments.

9. The operating documents and the grant ofexemption must be accessible during 

### VAS operations and made availableto theAdministrator upon request. Ifa discrepancy exists between the conditions and limitations contained in the grant ofexemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemptiontake precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update orrevise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administratorupon request. The operator must also present updated and revised documents ifit petitions for extension or amendment to the grant ofexemption. 

### Ifthe operator determines that any update orrevision would affect the basis upon which the FAAgranted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates orrevisions tothe operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. 

### Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa flight critical component, must undergo a functional test flight. The PIC who conductsthe



### UAV Aerial Video for Exemption Page 24functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections ofthe operating documents.

13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul component parts must be noted in the aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service.

15. Each UAS operatedunderthis exemption must comply with all manufacturer SafetyBulletins.

16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a Suplemental Pilot certificate and at least a current third- class medical certificate. Supplemental pilots must have, at a minimum, successfully completed private pilot ground school. Additionally, supplemental pilots without a current FAAprivate pilot certificate must have successfully passed the private pilot, commercial pilot, or airline transport pilot knowledge test within the past 24 calendar months.

18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate

UAV Aerial Video for Exemption Page 25the UAS in a manner consistent with howthe UAS will be operated underthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. 

### § 61.51(b). Flights for the purposes oftraining the operator's PICs are permitted underthe terms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-buildingflights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operatethe UA with appropriate distance from nonparticipants in accordancewith 14 C.F.R. 

### § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. 

### § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Ifflight at night is required, a special request will be made at the local flight standard district office to proposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UAmay not operate within 5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport's management is obtained, andthe operation is conducted in accordance with a NOTAM as required bythe operator's CO A. The letter ofagreement with the airport management must be made available to the Administrator upon request.

21. The UA may not be operated 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 thePIC.

22. 

### Ifthe UAloses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered

UAV AerialVideo for Exemption Page 26in accordance with the operating documents.

23. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough powerto fly at normal cruising speed to the intended landing point and land the UAwith 25% battery power remaining.

25. The operator must obtain anAir Traffic Organization (ATO) issued Certificate ofWaiver orAuthorization (COA) prior to conducting any operations under the grant ofexemption. This COAwill also require the operatorto request a Notice toAirman (NOTAM) not more than 72 hours in advance, but not less than 48 hours priorto the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class ofairspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in accordancewith 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station ofthe UAS any timethe UAS is operating. These documents must be made availableto theAdministrator or any**~aw** enforcement official upon request.
UAV Aerial Video for Exemption Page 2729. The UAS must remain clear and yield the right ofway to all manned aviation operations and activities at all times.

30. The UAS may not be operated bythePIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons otherthanthe PIC, SO, operatortrainees or essential persons), vessels, vehicles, and structures unless:
a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UAand/or debris in the event ofan accident. The operatormust
ensure that nonparticipatingpersons remain under such protection. 

### Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or;

, b. The aircraft is operated near vessels, vehicles or structures wherethe owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does not present an undue hazard, and;
c. Operations nearer to thePIC, SO, operatortrainees or essential persons do not present an undue hazard tothose persons per 

### § 91.119(a).

32. All operations shall be conducted over private orcontrolled-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representativewill be obtained for each flight to be conducted.



### 33. Any incident,**accid~nt,** orflight operationthattransgresses the lateral or vertical boundaries ofthe operational area as defined bythe applicable COAmust be reportedto the FAA's UAS Integration Office (AFS-80) within 

### 24 hours. Accidents must be reportedto theNational Transportation Safety Board (NTSB) perinstructions contained on the NTSB Web site: www.ntsb.gov.

UAV Aerial Video for Exemption Page 28

### 2. Reasons WhyAn Exemption From The Requirements OfSection 61.113(a) And (b) Would Not AdverselyAffect Safety.
Vertical Limit Aviation LLC submits thatthe equivalent level ofsafety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operatethe Quanum 680UC Pro Hexa-CopterUAS unless that PIC has demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operatethe Quanum 680UC ProHexaCopterUAS in a manner consistent with the exemption, including evasive and emergency
maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Vertical Limit Aviation LLC proposed area ofoperations, and the operating limitations set forth-above; the parallel nature ofprivatepilot aeronautical knowledge requirementsto those ofcommercial pilot requirements (See ExemptionNo. 11062); and the airmanship skills necessary to safely operatethe Quanum 680UC ProHexa-CopterUAS, Vertical Limit Aviation LLC submits that the additional manned airmanship experience ofa commercially certificated pilot would not correlateto the airmanship skills necessaryfor Vertical Limit Aviation LLC specific proposed flight operations. The 

### FAAhas previously granted relieffrom Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159,11160, 11161).


### 3. Reasons Why An Exemption FromThe Requirements Of

### Section 91.7(a) Would Not AdverselyAffect Safety. The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every flight, Vertical Limit Aviation LLC will ensure that the Quanum 680UC Pro Hexa-Copter UAS is in an airworthy condition based upon the UAS's compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the 

### FAAhas previously granted relieffrom Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

### UAV Aerial Video for Exemtion 

### Page 29Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
4. Reasons Why An Exemption From The Requirements OfSection 91.121 Would NotAdverselyAffect Safety. The equivalent level ofsafety established by Section 91.121 will be maintained because the altitude information ofthe Quanum 680UC Pro Hexa-Copter UAwill be provided to thePIC via GPS equipment and a radio communicationstelemetry data link, which downlinks from theUAtothe GCS for active monitoring oftheflight path and altitude. This altitude information, combined with Vertical Limit Aviation's operation ofthe Quanum 680UC Pro Hexa-CopterUAS within visual line ofsight, at orbelow 200 feet AGL, will ensure a level ofsafety equivalentto Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Priorto each flight, a zero altitude initiationpoint is automatically established bythe UASs at ground level.
The FAAhas previously granted relieffrom Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11062,11063,11064,11065,11066,11067,11080, 11109,11112,11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
5. Reasons Why An Exemption From The Requirements OfSection 91.15l(b) Would NotAdverselyAffect Safety.
A grant ofthis exemptionwould ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b) as a result of(1) the technical specifications ofthe Quanum 680UC Pro Hexa-Copter UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Vertical Limit Aviation LLC will
ensure that 

### itwill safely operatethe battery powered Quanum 680UC ProHexa-CopterUA during daylight hours in VFR conditions, with enough battery powerto fly for a total duration of 15 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. Here, as in ExemptionNo. 11109, the technical specifications ofthe

UAV Aerial Video for Exemption Page 30Quanum 680UC ProHexa-Copter UAS; the limitations on theproposed flight operations; and the location ofthe proposed operations, will ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the Quanum 680UCProHexaCopterUAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low batteryvoltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. Atthe critically low battery level, the Quanum 680UC Pro Hexa-Copter UAS will descend and land automatically. Significantly, previous exemptions granted bythe FAAconcerning Section 91.151 establish that safety is not adversely affected when thetechnical characteristics and operating limitations oftheUAS are considered. Reliefhas been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including ExemptionNos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).


### 6. Reasons Why 

### An Exemption From The Requirements Of

### Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) & 

### (b) Would Not Adversely Affect Safety. In seekingthis exemption, Vertical Limit Aviation LLC submits that the equivalent level of safetywith regard to the regulatory maintenanceand alteration requirements establishedby Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be metbecause Vertical Limit Aviation LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents. Furthermore, Vertical Limit Aviation LLC will document and maintain all maintenancerecords for the Quanum 680UC ProHexa-CopterUAS. Sincethe Quanum 680UC ProHexa-CopterUAS will be inspected as prescribed by the operating documents, Vertical Limit Aviation LLC will maintain the equivalent level ofsafety



### UAV Aerial Video for Exemption Page 31established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy ofthe Quanum 680UC ProHexa-Copter UserManual is attached hereto as Exhibit A; a copy ofthe Quanum 680UC Pro Hexa-Copter UAS MaintenanceLOG is attached hereto as Exhibit 

### B. Likewise, the exemption sought will not adversely affect safetybecause Vertical Limit Aviation LLC will use trained technicians to perform maintenance, alterations orpreventive maintenance
on theUAS using the methods, techniques, and practices prescribed bythe operating documents. Furthermore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe Quanum 680UCProHexa-CopterUAS will be performed bytrained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(l)& (a)(2), and 91.417(a)& (b) establish that safetyis not adversely affected when thetechnical characteristics and operating limitations ofthe UAS are considered. In consideration ofVertical Limit Aviation LLC proposed operating limitations, the operating documents, and the technical aspects ofthe Quanum 680UC ProHexa-CopterUAS, Vertical Limit Aviation LLC submits that safety will not be adversely affected by granting exemption from 14 C.P.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAAhas previously granted reliefspecific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,. 11153, 11156, 11157, 11158, 11159, 11160, 11161).


### 7. The FAA May Prescribe Any OtherConditions ForSafe Operation. In accordance with Section 333 ofthe FAAModernization and Reform Act of2012 (FMRA) and 14 C.P.R.§ 21.16 entitled Special Conditions, Vertical Limit Aviation LLC requests that the FAAprescribe special conditions for the intended operation ofthe Quanum 680UC Pro Hexa-Copter UAS, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalentto that established by 14 C.P.R. Part 21, Subpart H, and 14 C.F.R 

### §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe



### UAV Aerial Video for Exemption Page 33operation ofthe UAS for the limited purpose ofconducting aerial video and photography
overcertain areas ofthe United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation ofthe UAS in the NAS. Likewise, theAdministrator may prescribe special conditions pursuant to 14 C.F.R. 

### § 21.16, for operation ofthe Quanum 680UC ProHexa-Copter UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features ofthe aircraft. Section 21.16, entitled Special Conditions, states the following: Ifthe FAA finds that the airworthiness regulations ofthis subchapter do not contain adequate
or appropriate safety standards for an aircraft, aircraft engine, orpropeller because ofa novel orunusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 ofthis chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessaryto establish a level ofsafety equivalentto that established in the regulations. See 14 C.F.R. 

### § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. 

### § 21.16, the FAA may prescribe special conditions for Vertical Limit Aviation's intended operation ofthe Quanum 680UC Pro Hexa-Copter UAS, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalentto that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1)& (a)(2), and 91.417(a)& (b).



### R A Summary That Can Be Published In The Federal Register, stating: The Rules FromWhich Vertical LimitAviation LLC Seeks Exemption: Vertical Limit Aviation LLC seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

UAV Aeriai Video for Exemption Page34ABriefDescription OfThe Nature OfThe Exemption Vertical Limit Aviation LLC Seeks: This exemption will permit Vertical Limit Aviation LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose ofconducting aerial video and photography over certain areas ofthe United States.



### G. AnyAdditional Information, Views, OrArgumentsAvailable To Support UAV Aerial Video Request. This Petition is made pursuant to the FAAModernization and ReformAct of2012 (FMRA) Section 333, which directs the Secretary ofTransportationto determine ifcertain UAS may operate safely in the NAS. As such, Vertical Limit Aviation LLC request for exemption may be granted pursuant to the authority ofFMRA Section 333 and 14 C.F.R Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwisepose athreatto national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Vertical Limit Aviation LLC will operatethe Quanum 680UC ProHexa-CopterUAS safely inthe NAS, without creating a hazard to users oftheNAS, orthe public, or otherwisepose a threat to national security.



### CONCLUSION

As set forth herein, Vertical Limit Aviation LLC seeks an exemptionpursuant to 14 C.F.R. 

### § 11.61 and Section 333 ofthe FAAModernization and ReformAct of2012 (FMRA), whichwill permit safe operation ofthe Quanum 680UCProHexa-CopterUAS commercially, without an airworthiness certificate, for the limited purpose ofconducting aerial video and photography over certain areas oftheUnited States. Bygranting this Petition, the FAA Administratorwill be fulfilling the Congressional mandate ofthe FAAModernization and Reform Act of2012, while also advancing the interests ofthe public, by allowingUAV Aerial Video to safely, efficiently, and economically operatethe Quanum 680UC Pro HexaCopter UAS commerciallywithin the NAS.
WHEREFORE, in accordance with the FederalAviation Regulations and the FAA

UAV Aerial Video for Exemption Page35Modernization and ReformAct of2012, Section 333, Vertical Limit Aviation LLC respectfully requests that theAdministrator grantthis Petition for an exemptionfrom the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit Vertical Limit Aviation LLC to operate a custom Quanum 680UC ProHexa-CopterUAS commercially for the purpose ofconducting aerial video and photography of Real EstateProperties (for homeowners, realtors, home builders, home contractors and 

### I orhome inspectors for real estate marketing and inspection ofhome exteriors) as well as filming ofspecial events, film sets, scripted and unscripted television sets and landscape as well as conducting powerline inspection, aerial mapping, surveying over certain areas ofthe United States.

Respectfully submitted by, Douglas Christian Douglas Christian Vertical Limit Aviation 7401 Atrisco Vista Blvd #2 Albuquerque, NM 87120 505-831-4354 DJ@verticallimitaviation.com

Appendixes: Exibit A: User Manual Exibit 8: Maintance Log

Page 36Software Updates Airframe Engines Propellers Camera Gimbal Landing Gear Vibration Dampening Other: 

### Exibit-B MONTHLYMAINTENANCE LOG

Vertical Limit Aviation LLC petition for Exemption 42