John Parisoff NewViewLLc POBox285 Helotes TX 78023 (210) 396-6224 jpdirtwork@live.com 

# • t**~-** \. : t./

I formally petitionthe Federal Aviation Administration (FAA) for an exemption :from part 21, subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.119 (c) 91.121, 91.151(a), 91.203(a) and {b), 91.405(a), 91.407(aX1), 91.409(aX2), and 91.417(a) and (b) ofTitle 14, Code ofFederal Regulations (14 CFR).

Outlined below are the descriptions ofthe parts, subparts and sections in which I request exemptions and my reason for requesting the exemptions.

Part 21 prescribes the procedural requirements for issuing and changing design approvals, productions approvals, airworthiness certificates, and airworthiness approvals.

Section 45.23(b) prescribes that whenmarks include only the Roman capital letter 

### ''N'' and the registration number is displayed on limited, restricted orlight-sport category aircraft orexperimental orprovisionally certificated aircraft, the operator must also display onthat aircraft near each entrance 

### to the cabin, cockpit, orpilot station, in letters not less

### than 2 inches nor more 

### than 6 inches high, the words "limited," ''restricted," "light-sport," "experimental," or ''provisional," as applicable.

Section 61.113(a) and (b) prescribes that- (a) no person who holds a private pilot certificate may act as a pilot in command ofan aircraft that is carrying passengers or property for compensation orhire; normaythatperson, for compensation orhire, 

### act as pilot in command ofan aircraft. (b) a private pilot may, for compensation orhire, act as pilot in command ofan aircraft in connection with anybusiness or employment if:
(1) The flight is only incidental 

### to that business or employment; and (2) The aircraft does not 

### carry passengers orproperty for compensation or

### hire.

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy condition.

Section 91.119 prescribes that, except when 

### necessary fortakeofforlanding, no person may operate an aircraft belowthe following altitudes:
(c) Over other

### than congested areas. An altitude of400 feet above the surface, except
overopenwater or sparsely populated areas. Inthose cases, the aircraft maynot be operated closer

### than 400 feet to any person, vessel, vehicle, or structure.
{l) A helicopter maybe operated atless than the minimums prescribed inparagraph (b) 1or (c) ofthis section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and
(2) A powered parachute orweight-shift-control aircraft may be operated 

### at less than the minimums prescribed inparagraph (c) ofthis section. Section 91.121 requires, in pertinent part, eachperson operating an aircraft to maintain cruising altitude byreference to an altimeter that is set "

...to the elevation ofthe departure 

### airport or an appropriate altimeter setting available before departure."

Section 91.151(a) prescribes that no person may begin a flight in an airplane 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, (1) during the day, to fly after that for atleast 30 minutes [emphasis 

### added]. Section 91.203(a) prohibits, inpertinent

### part, any person from operating a civil 

### aircraft unless it

### has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy ofthe Aircraft registration Application as provided for in § 47.31(c). Section 91.203(b) prescribes, inpertinentpart, 

### that no person may operate a civil 

### aircraft unless the airworthiness certificate or a special flight authorization issued under § 91.715 is displayed 

### at the cabin orcockpit entrance so 

### that it is legible to passengers or crew.

Section 91.405( a) requires, inpertinentpart, that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart 

### E ofthe same part and shall, between required inspections, except as provided inparagraph (c) ofthe same section, have discrepancies repaired as prescribed inpart 43 ofthe chapter.

Section 91.407(aX1) prohibits, inpertinentpart, any person from operating an 

### aircraft thathas undergone maintenance, preventive maintenance, rebuilding, or alteration unless it 

### has 

### been approved for return to service by a person authorized under§ 43.7 ofthe same chapter.

Section 91.409(a) (2) prescribes, inpertinent 

### part, that no person may operate an 

### aircraft unless, within the 

### preceding 12 calendarmonths, it 

### has had an inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter.

Section 91.417( a) and (b) prescribes, in pertinent

### part, that- (a) Each registered owner or operator shall keep the following records for the periods specified inparagraph (b) ofthis section:
(1) Records ofthe maintenance, preventive maintenance, and alteration and records-ofthe 1

00-hour, 

### annual, progressive, and other required or approved inspections, as appropriate, for each 

### aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan 

### aircraft. The records must include--
(i) A description (orreference to 

### data acceptable to the Administrator) ofthe work 2

### performed; and
(ii) 

### The date ofcompletion ofthe work performed; and (iii) 

### The signature, and certificate number ofthe person approving the aircraft for return to service.
(2) Records containing the following information:
(i) The total time in service ofthe airframe, each engine, eachpropeller, and eachrotor. (ii) 

### The current status 

### oflife-limited parts 

### ofeach airframe, engine, propeller, rotor, and appliance. (iii) 

### The time since last overhaul of

### all 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 since the last inspection required 

### bythe inspection program under which the aircraft and its appliances

are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. 

### Ifthe AD 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 oroperator 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 orfor 1 year afterthe work is performed. (2) The records specified in paragraph (aX2) ofthis section shall be retained and transferred with the aircraft 

### at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operator under§ 43.11 ofthis chapter shall beretained until the defects are repaired and the aircraft is approved for return to service.

New View LLC's exemptionrequests from the above are detailed below:

Unmanned Aircraft System:

NewView LLC plans to operate a 

## on, the Inspire 1, which is comprised ofan unmanned aircraft. The INSPIRE 1 is a quad-copter with a gross weight ofabout 6 pounds. It

### is equipped 

### with four rotors that are driven by electric motors which is powered by batteries. The UA 

### has a maximum 

### airspeed ofapprox. 50 mph.

New View LLC plans to use this DR in aerial cinematography and photography on rural 

### ranch sites, rural RV resorts, enhancing real-estate listings and other suchtasks 

### for businesses inthe greater San Antonio Texas area which could benefit from an aerial view 

### 3for their planning offuture expansions and/or advertising oftheirproducts orbusiness. For most businesses and realtors in the area, standard aerial photography 

### has been very cost prohibitive. The economic impact ofbeing able to assist your business using aerial photography would be substantial.

The use ofthis 

## on in the above named applications greatly reduces risk to the public and property as there is no fuel carried by the Inspire 1, aircraft noise is greatly reduced as opposed to a standard aircraft orrotorcraft both ofwhich require numerous passes or extended lengths ofhover time to accomplish the same task as the Inspire I can in only a few minutes. The Inspire only weighs about 6 pounds and is by far a much smaller hazard to persons orproperty than a standard aircraft orhelicopter in the event ofa catastrophic in-flight failure.

There is no higher priority for New View LLC otherthan the safety ofthe public and property.

New View LLC makes the following representations ofits operation in which to abide by to ensure these exemptions 

### ifgranted, will provide a level ofsafety at least equal to existing rules: The Inspire I will only be operated by, at a minimum, a private pilot with at least a 3rd class airman medical certificate. The PIC will have completed at a minimum, 25 hours ofdocumented flight time using the Inspire I with focus being:
a) Collision avoidance b) Loss ofC2 link procedures as outlined in the Operators manual for the Inspire 1 c) Identification ofintlight hazards i.e. aerial wires, birds in the area, changing weather etc. d) Estimating distance from objects, persons, vehicles and vessels. e) Communication with the spotter(s) 

### f) Completed the 

## on Inspire 1 pilot training guide maneuvers and skills. (PDF) attached. g) The ability to recognize persons or objects that are not part ofthe intended and permitted part ofthe project that enter the 500 foot operational areaunless suchpersons
or objects are deemed permitted by the owner or controller ofthe

### property or area and the PIC makes a safety assessment ofthe risk ofoperating closer and it does not pose undue
or significant risk. h) The ability to quickly and safely land the 

## on Inspire 1 inthe event ofintrusion into the safe zone.
1.) A complete pre-flight systematic check by the PIC ofthe Inspire I physical condition, i.e. props, prop guards, landing gear, position indicator lights, battery capacity and overall airframe condition. Ifany ofthe above are not within the manufacturers minimum standards no flight will take place until suchtime as the issue(s) is repaired to manufacturers standards. *Although prop guards are not required on the 

## on Inspire 1' New View LLC will not operate without them. 2.) Written documentation ofeachphysical inspection and repairs ifany, bythe PIC (pilot in command) will be kept with the Inspire and will be on-site and available for review. 3.) Software inrelation to the Inspire I operation will be checked for proper function. The
4most current

# on vision APP and the current firmware will be installed to assure the most up to date safety features. 4.) Priorto every flight, the compass on the

# on Inspire 1 will be calibrated as to ensure precision location. 5.) New ViewLLC will ensure the altimeter setting onthe

# on Inspire 1 is that ofAGL (above ground level) rather than GPS orbarometric pressure derived settings. 6.) Every safety feature offered through the

# on vision APP will be enabled for every flight, every time. (6) Enable ground station (7) Compass calibration (8) Lowbattery auto go home (9) Dynamic home point (10) Current RTH (return to home) altitude (AGL) (14) Lowbattery alarm

Ofparticular interest are the following: [3] Flight attitude and 

### radar function [4] Flight parameters-RTH (return to home) altitude, horizontal distance from home point, altitude-vertical distance from homepoint, speed-horizontal flying speed. [6] Flight Battery Level indication 

### [7} There is a built in preflight checklist within the

# on vision APP which is completed priorto each flight. [8] Aircraft GPS Status-NewView LLC's Inspire 1 will not fly with less than (7) GPS Satellites available. [14] Hide or show flight parameters- New ViewLLC's Inspire 1 will ALWAYS fly with parameters displayed in orderto assist in maintaining safe distances from persons and objects and to adhere to the flight plan.
8.) New View LLC will operate with a minimum of(1) one, trained spotter for every flight. "Trained" meaning familiarization withthe

# on Inspire 1, its abilities according to the operators' manual as well as the abilities ofPIC. Spotters will participate in documented 

### training developed in-house priorto being allowed onthe flight line. Training will consist of, at a minimum the following: a) The abilityto roughly identify minimum distance from objects b) The ability to quickly recognize unusual flight maneuvers/attitudes ofthe Inspire 1 c) The ability to communicate withthe PIC the visual limitations and to never let the Inspire 1 out ofthe visual capabilities ofthe PIC andthe spotter(s). d) The ability to recognize persons or objects that are not part ofthe intended and permitted 

### part ofthe projectthat enterthe 500 foot operational area unless suchpersons and objects are deemed permitted bythe owner orcontroller oftheproperty or area and the PIC makes a safety assessment ofthe risk ofoperating at a closer range and it does not pose undue or significant risk to those persons or objects. " e) The ability to accurately describe to the PIC, the orientation ofthe Inspire inrelation to the pre-sethome point as well as the direction oftravel. f) The 

### training will take place under strict, safe conditions away from persons orlarge obstacles. I.e. large open fields. 5

### 9.) Prior to each flight, the PIC and the Spotter(s) will perform a pre-flight briefing detailing the estimated flight distance, estimated flight level AGL and the goal ofthe particular flight. Eachpreflight briefing 

### will be documented by the PIC 

### to include flight details, pilot name, spotter(s) name, weather details, time and date.

Written and/or verbal consent will 

### be obtained from the person/business requesting the flight.

A post-flight briefing will also 

### be conducted and documented with the PIC and the

The Documented Pre-flight, the rawpictures and/or the rawvideo footage as well as the post-flight briefand 

### written consent will be kept by New View LLC for a period ofat least 

### (2) years.

New View LLC believes that given the size, weight, speed, and limited operating area associated with the Inspire 1, requests an exemption from 14 CFR

### part 21, Subpart H (Airworthiness Certificates) and§ 91.203 (a) and 

### (b) (Certifications required}, subject

### to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of

### safety under 14 CFR

### part 11 

### and Section 333 ofP.L. 112-95 (Section 333).

NewView LLC requests exemption from§ 45.23 Marking ofthe aircraft. The Inspire 1 does nothave a 

### cabin, does not have a cockpit or a pilot station. Minimum sized lettering and wording are difficult to place onthe Inspire 1. NewView LLC will however affix a sticker onthe unit which will contain contact information for the company in case of aircraft loss.

New View LLC requests an exemption from§§ 91.405(a), 91.407(a) 

### (1), 91.409(a) (2) and 91.417(a) and 

### (b) Maintenance inspections and feel it should be granted since they only apply 

### to aircraft with an airworthiness certificate. NewViewLLC 

### has developed maintenance inspections and documentation methods for the Inspire 1 from personal experience as well as the manufacturer's user manual.



# on Pilot in Command {PIC} Under§ 61.113 (a) and (b) private pilots are limited to non-commercial operations. New ViewLLC will only use, at a minimum a pilot with a private pilot license, current 3rd class airmen medical certificate. Under current regulations, civil operations for compensation or hire 

### require a PIC holding
a commercial pilot certificate per 14 CFRpart 61. Based onthe private pilot limitations in accordance with pertinent parts 

### of 14 CFR 61.113(a) and 

### (b), a pilotholding a private pilot certificate cannot act as a PIC ofan 

### aircraft for compensation or hire 

### unless the flight is only incidental 

### to a business or employment. "However, in Grant ofExemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private 

### pilot certificate operating the Astraeus 

# on would not adversely affect operations inthe NAS orpresent a hazard 

### to persons orproperty onthe ground." New View LLC requests 

### 6

### .. '

that an exemption allowing a private pilot employed byNewViewLLC be allowed 

### to be the PIC ofthe Inspire 1 for compensation similar

### to the grant ofexemptionNo.11602 to Astraeus Aerial.

New View LLC requests relieffrom§ 91.119(c) because the aircraft will be operated at altitudes below400 feet AGL. Section 91.119( c) states that no person may operate an 

### aircraft belowthe following altitudes: over other

### than congested areas, an altitude of400 feet above the surface, except over open water or sparselypopulated areas. Inthose cases, the aircraft maynot be operated closer

### than 500 feet 

### to anyperson, vessel, vehicle, or structure. NewViewLLC will operate pursuantto the following restrictions related to § 91.119: -Operate inreasonably safe environments that are closely monitored by ground assistants and signage placed in locations that would be considered reasonable locations for pedestrians, vehicles or vessels to enterthe 

### area. -Within 6 miles of

### airports and congested areas. Congested areas 

### will be defined byVFR charts as well as by contacting the local FSDO (flight standards 

### district office)

- Conduct all operations underNew View LLC's guidelines contained inthe operating documents and will analyze flight data and other sources ofinformation such as the manufacturer's website to constantlyupdate and enhance safety. -Contactrespective 

### airports ifoperations will be within 6 miles 

### to advise them of estimated flight time, flight duration, elevation offlight and otherpertinent information deemed important bythe 

### airport.

- Always obtain all necessary permissions priorto operation. Permissions include but are not limited to a (COA) and a request for a (NOT AM) as well as permission from the property owner orperson in control ofthe property and whenpractical 

### will be in writing and kept on file for 2 years for review. Ifit's notpossible to obtain written permission, the PIC will document in writing howpermission was obtained i.e. phone call with date, time andparty information.

New View LLC requests relieffrom 14 CFR 91.121 Altimeter Settings. NewView LLC's Inspire 1 

### has a barometric altimeter 

### and GPS derived altitude capabilities. The FAArequires any altitude reported to ATC to be in feet AGL. NewView LLC 

### will set the altimeter on the Inspire 1 to zero feet AGL rather 

### than local barometric pressure or field altitude before flight.

New ViewLLC requests relieffrom§ 91.151(a) Fuel requirements for flight in VFR conditions based onthe following:

No fuel is used in the Inspire 1 but itis battery operated. Batteries have, 

### in ourexperience have about 15 minutes ofquality flying time. Inthe interest ofsafety, New ViewLLC generally lands with 35% ofbatteryremaining which gives about 9 minutes offlying time per battery. The Inspire 1 

### has an audible battery state warning system. New View LLC 

### will always follow the manufactures minimum battery warning which is 300/o remaining. There is also an onscreen warning ofnot enough battery to return to home message if flight distance 

### has exceeded battery capacity. Inthis event, an emergency 

### landing would be made as soon as safe andpractical. The Inspire 1 also 

### has an automated function which 

### 7·- •. ,.. «'-

results in immediate landing when a low 

### battery is detected. Researching previous relief requests, reliefhas beengranted for manned aircraft to operate at less 

### than prescribed minimums, including Exemption Nos. 2689, 5745, and 10650.1n addition, similar

# onspecific reliefhas been granted in exemptionNos. 8811, 10808, 

### and 10673 for daytime, VFR conditions. NewViewLLC will adhere

### to all VFRminimums as well as VMC conditions whenplanning and/or executing any flights. There is little purpose for aerial video orpictures ifthe weather is less 

### than desirable. FollowingVFRminimum standards will at least ensure a safe flight. Wind and forecast weather 

### will be a keyin deciding suitable conditions. Local weather can 

### be attained from the nearest airport byusing AWOS. No 

### flight will take place in any condition that wouldpotentially 

### be outside ofthe Inspire I capabilities in wind. New View LLC will always fly 

### within its 30% minimum remaining 

### battery life at its 

### first intended landing point.

New View LLC will obtain an 

### AirTraffic Organization (ATO) issued Certificate of Waiver orAuthorization (COA) prior

### to conducting any operations. NewViewLLC will also request a Notice to Airman (NOT 

### AM) notmore

### than 72 hours in advance, but not less 

### than 48 hours priorto the operation.

Ifthere are any areas that have not been addressed, please contact me for supplemental information.
Sincerely, John Parisoff NewViewLLC POBox285 Helotes, TX 78023 (210) 396-6224 jpdirtwork@live.com



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