Michael Ude 

South Bay Custom Video Productions, Inc. 

707 Torrance Blvd. #105 

Redondo Beach, CA 90277 

31 0-543-4901 

http://www .customvideo.tv/ 

Docket Operations, M-30 

U.S. Department of Transportation 

Room W12-140, West Building Ground Floor 

1200 New Jersey Avenue, SE. 

Washington, DC 20590-0001 

Re: Exemption Request under SeGtion 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations 

Dear Sir or Madam: 

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

"Reform Act") and 14 C.F.R. Part 11, Vertical Approach Aerial Solutions, LLC 

(Operator) seeks an exemption from Federal Aviation Regulations (FARs) to 

allow commercial operations of their UASs (Unmanned Aerial Systems) for the 

purpose of conducting aerial photography, video, and survey for various 

industries. 

Regarding the Unmanned Aircraft Systems 

The requested exemption would support an application for a commercial 

Certificate of Authorization (GOA) to use the below described UAS, so long as 

operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333. Like the FAA, it is 

the Operator's mission to provide the safest and most efficient means of Civil 

Commercial implementation into the National Airspace System (NAS). 

Furthermore, the Operator is comprised of members with the equivalent of a FAA 

Commercial Certificate or higher adding an additional layer of high regard for 

safe operations as well as the necessary high-level of understanding of the NAS 

and FARs. 

Petition for Part 21; and 45.23(b); 61.113(a) & (b); 91.7(a); 91.9(b)(2); 91.1 03(b); 

91.109; 91.119; 91.121, 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 

91.409(a)(2); and 91.417(a) & (b) of Title 14, Code of Federal Regulations I plan 

to operate a UAS, the PHANTOM 2 Vision+, Blade 350QX & similar units which 

each are comprised of an unmanned aircraft (UA or PHANTOM, Blade) and a 

transportable ground station. The PHANTOM and Blade are referred to as quadcopters with a maximum gross weight of around 5 pounds each. They are 

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

Each of the UA's have a maximum airspeed of around 20 knots. The UAS will 

have a small ultra-6 lightweight GoPro 3+ camera or equivalent to the UAS and 
operate either of the UA's over various areas to record video for personal and 

marketing uses, aerial photography/videography for public and/or private use 

including real estate, wedding/event documentation, news gathering, architecture, 

lots, land surveying, engineering and other related professional activities. The 

UAS will also provide communities with new and picturesque representations of 

their city, businesses and their surroundings. Aerial videography for geographical 

awareness, real estate marketing, business advertising, and personal 

photography has been around for a long time through manned fixed wing aircraft 

and helicopters, but for small business owners, its expense has been costprohibitive. Granting this exemption would allow me to provide this service at a 

much lower cost. Furthermore, my small UAS will pose no threat to the public 

given its small size and lack of combustible fuel when compared to larger 

manned aircraft. The operation of his UAS will minimize ecological damage and 

promote economic growth by providing new opportunities to individuals and 

businesses throughout the United States. 

The Pilot, Michael Ude, will provide the following levels of safety: 

I will only operate in reasonably safe environments that are strictly controlled, are 

away from power lines, elevated lights, airports and densely populated areas; 

I will conduct extensive preflight inspections and protocols, during which safety 

carries primary importance. I will operate the UAS below 300 feet and within a 

radius distance of 1 000 feet from the controller to both aid in direct line of sight 

visual observation; I will operate the UAS for 5-15 minutes per flight; 

I will land his UAS prior to the manufacturers recommended minimum level of 

battery power; I will operate his UAS only within visual line of sight (VLOS); 

I will use the UAS global positioning system (GPS) flight safety feature whereby it 

hovers and then slowly lands if communication with the remote control pilot is lost; 

I will conduct all operations under my own personal and flight safety protocols 

(including posting a warning sign reading: Attention Aerial Photography in 

Progress Remain Back 150 feet) contained in the operating documents and will 

actively analyze flight data and other sources of information to constantly update 

and enhance the safety protocols; I will contact respective airports if operations 

will be within 5 miles to advise them of my estimated flight time, flight duration, 

elevation of flight and other pertinent information; I will always obtain all 

necessary permissions prior to operation; I will have procedures in place to abort 

flights in the event of safety breaches or potential danger. 

Respectfully, 

.~<~ .. ~ ~. 

~i~~de 6-18-2015 

President 

Custom Video Productions 

707 Torrance Blvd. #105 

Redondo Beach, CA 90277 

31 0-543-49 0 1