Dale Parrish, dba Hover Visions 6652 E. 46th Place Tulsa, OK 74145 US Department ofTransportation Federal Aviation Administration 800 Independence Ave, S.W. Washington D.C., 20591 Dear Sirs or Madam, I am re-submitting the following petition in reference to the FAA denying my original petition (Docket No
. FAA-2015-4751)

. I have only added to the original petition to explain further, my intention and reasons for my request for such exemption

. In relation to the denial letter from the FAA on December 31 , 2015 , ofmy original petition on July 27, 2015 , a five (5) month waiting period, I hope that I have answered all your concerns. I stand ready tojointhe 2800 plus exemption holders in making the skies safer for UAV operations across the United States
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**~** C(? '1')/V Dale ParrishJanuary 24, 2016 Hover Visions 6652 E. 46th Place Tulsa, OK 74145
U.S
. Department ofTransportation Docket Operations West Building Ground Floor Room Wl2-140 1200 New Jersey Avenue, SE. , Washington, DC 20590-0001
RE: Exemption Request Section 333 ofthe FAA Reform Act of2012 and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam; In accordance with the Public Guidance for Petitions for Exemption filed under Section 333 , Hover Visions requests exemption from the Federal Aviation Regulations to allow for commercial UAS operations ofa DJI S900, DJI Phantom 3 Professional, DJI Inspire 1, and DJI Matrice M 100 for the purpose ofaerial videography and photography, public utility inspection, real estate marketing, surveying, mapping ofland and construction sites, agricultural mapping, search and rescue, news gathering and other flight operations that could be performed safer, quicker, and more cost effectively than with traditional manned aircraft. Applicant: Hover Visions Dale Parrish, Owner 6652 E. 46th Place Tulsa, OK 74145 Attachments links to: Documents and manuals for:
DJI s900 http://dl.djicdn.com/downloads/s900/en/S900
_User

_Manual_en_ vl.4.pdf DJI phantom 3 professional http://www.dji.com /product/phantom-3/downloadDJI Inspire 1 http ://www.dji.com /product /inspire-l/download DJI Matrice M100 http://download.dji-innovations.com/downloads/dev/Matrice/en/M100_User_ Manual_ v 1. 4

_ en.pdf

Regulations from which the exemption is requested: 14 CFR 21 , Subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a) 14 CFR 91.7 (a) 14 CFR 91.9 (b)(2) 14 CFR 91.103 (b)(2) 14 CFR 91.1 09 14 CFR 91.119 (c) 14 CFR 91
. 121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a)(l) 14 CFR 91.409 (a)(l) & (a)(2) 14 CFR 91.417 (a) & (b)
14 CFR 21, Subpart H- In consideration ofthe size, weight, speed, and limited operating area associated with this U AS and its operation, HoverVisions request relieffrom 14 CFR part 21 , Subpart H, and any associated noise certification and testing requirements ofpart 36. The UAS will carry neither pilot, passenger, explosive materials or flammable liquids. 14 CFR 45.23 (b)- Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no cabin, cockpit, or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAS , two-inch lettering will be not be possible. The word "Experimental" will be placed on the fuselage in compliance with § 45.29 (f). The equivalent level ofsafety will be provided by having the UAS marked on its fuselage as required by § 45.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as"Experimental." 14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)- Since the UAS will not carry a pilot or passengers, Hover Visions request relieffrom these regulations. As a licensed private pilot I, Dale Parrish dba Hover Visions, will be the PIC and sole manipulator ofthe controls. A visual observer or (VO) will be utilized and required to communicate verbally with me at all times. The UAS will be limited to operations within visual distance ofboth the PIC and VO. All UAS operations will take place in a controlled area. The risks associated with the use ofa UAS are far less than similar commercial aircraft operations. 14 CFR 91.7 (a)- Since the UAS will not carry a pilot or passengers there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard exists for determining airworthiness

. Given the size ofthe aircraft, maintenance, and use ofsafety checklist prior to each flight, an equivalent level ofsafety will be provided
.All flights for each aircraft will be in accordance with the safety and maintenance recommendations found in the attached manufacturers' manuals. 14 CFR 91.9 (b)(2)- Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An equivalent level ofsafety will be maintained by keeping the flight manual at the ground station where the UAS pilot will have immediate access to it. 14 CFR 91.103 (b)(2) -As no FAA approved flight manuals will be provided for the aircraft listed, an exemption is needed. Alternate procedures including but not limited to reviewing airspace, weather conditions, checking flight battery requirements, checking takeoffand landing distances, along with checklists found in the manufacturers' manuals will be implemented

.These actions will provide an equivalent or higher level ofsafety. 14 CFR 91.109- UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use ofa control box that communicates with the aircraft via radio communications

.An equivalent level ofsafety will be achieved using the real time ground station data since the UAS will carry neither a pilot or passengers. 14 CFR 91.119 (c)- The UAS will never be operated at an altitude higher than 400 feet AGL. The UAS will operate in safe areas away from public and traffic and only with permission ofthe property and structure owners. The UAS will also be restricted by the flight controller to a maximum vertical height of400 feet AGL, and 1500 feet horizontal. Given the size, weight, maneuverability and speed ofthe UAS, an equivalent or higher level ofsafety will be achieved. 14 CFR 91.121- As the UAS may not have a barometric altimeter, but instead a GPS barometric sensor for altitude information an exemption may be required. An equivalent or increased level ofsafety will be achieved using a ground station which links to a telemetry data link
. This will provide the pilot with live flight data monitoring, confirming the altitude ofthe launch site shown on the GPS altitude indicator prior toflight. 14 CFR 91.151 (a)- The UAS has a limited range and will be limited to operations in a controlled environment. The battery power the UAS above provide approximately 22 minutes offlight time. The UAS is unable to meet the 30 minute reserve requirement and therefore requires an exemption
.An equivalent or increased level ofsafety will be achieved by monitoring the battery through the ground station and landing with a minimum of30 percent battery power remaining. 14 CFR 91.203 (a) & (b)- Given the size and configuration, the UAS does not have the ability to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to store a flight manual. An equivalent level ofsafety will be maintained by keeping the flight manual at the ground station where the UAS pilot will have immediate access to it. Given the following sections only apply to aircraft with an airworthiness certificate, these sections do not apply to this applicant. As a safety precaution, the operator will perform preflight inspections and ensure UAS is in working condition before initiating each flight: 14 CFR 91.405 (a) 14 CFR 91.407 (a)(1) 14 CFR 91.409 (a)(l) & (a)(2) 14 CFR 91.417 (a) & (b) Equivalent Level ofSafety In addition to the safety standards mentioned above the UAS will adhere to the following additional guidelines: 1. The U AS will not be operated within 5 miles ofan airport unless prior contact to Air Traffic Control has been established
. 2
. Flights will not exceed an airspeed of87 knots ( 100 mph) 3
. Flights will be operated at or below an altitude of400 feet AGL. 4. The PIC and VO will communicate verbally at all times. 5. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. 6. All operations will be conducted under VMC. 7. The UAS will land with a minimum 30 percent battery reserve remaining. 8. The UAS will only be piloted within visual line ofsight. 9. The UAS will utilize an internal flight safety feature that will return to a preprogrammed position and land ifcommunication with the remote control is lost. 10
. Preflight inspections and protocol will be followed prior to all operations
. 11. The UAS will abort flight in the event ofunpredictable obstacles or emergencies
. 12. Operated by the Applicant, a licensed private pilot. Public Interest I believe the use ofa sUAV to supplement manned aircraft will enhance safety and helpreduce the impact to the environment compared to similar operations conducted with a manned aircraft carrying a flight crew and flammable fuel. The inspections ofcellular communication towers or similar structures will eliminate the risks associated with persons climbing these structures. The photographs and videos collected can provide engineers with valuable information as to the needed maintenance ofthese structures for safety. The use ofa sUAV in the real estate industry helps provide a higher level ofmarketing and service for all parties involved. The sUAV is able to provide a view which can capture the entire property in a single photo or short video clip. When compared to similar operations, utilizing a UAS poses much less ofa safety concern for the general public with less fuel, time, noise and other resources. The use ofsUAV's in search and rescue make it possible to place resources where they need to be quicker which can help save lives and property. A sUAV can be deployed and provide a broader picture ofconditions to help the incident commander make a more informed decision. Any and all operations conducted by the petitioner will provide increased safety to life and property over manned aircraft in the event ofan unfortunate accident. Privacy All flights will occur over private or controlled areas with the owner's consent. Any person captured in a collected image will have consented prior to filming or otherwise have agreed to be in the area prior to the filming taking place. The right to privacy will always be respected and considered. In the case ofsearch and rescue, the standard operating procedure ofthe authority havingjurisdiction will serve as rule in the case of emergencies when consent cannot be obtained from each individual. Respectfully, Dale Parrish,



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