Dale Parrish, dba 

Hover Visions 

6652 E. 46th Place 

Tulsa, OK 74145 

US Department of Transportation 

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, of my original 

petition on July 27, 2015, a five (5) month waiting period, I hope that I have answered all 

your concerns. I stand ready to join the 2800 plus exemption holders in making the 

skies safer for UAV operations across the United States. 

_ _ R;:ctfully, . 9 L ~ ' c__A.A. L ~ C(? '1')/V 

Dale Parrish 
January 24, 2016 

Hover Visions 

6652 E. 46th Place 

Tulsa, OK 74145 

U.S. Department of Transportation 

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 of a DJI S900, DJI Phantom 3 Professional, DJI Inspire 1, 

and DJI Matrice M 100 for the purpose of aerial videography and photography, public 

utility inspection, real estate marketing, surveying, mapping of land 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/download 
DJI Inspire 1 

http://www.dji.com/product/inspire-l /download 

DJI Matrice M100 

http://download.dji-innovations.com/downloads/dev/Matrice/en/M1 00 _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 91.11 9 (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 of the size, weight, speed, and limited operating 

area associated with this U AS and its operation, Hover Visions request relief from 14 

CFR part 21 , Subpart H, and any associated noise certification and testing requirements 

of part 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 of the 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 of safety 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 of the 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 relief from these regulations. As a licensed private 

pilot I, Dale Parrish dba Hover Visions, will be the PIC and sole manipulator of the 

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 of a 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 of the aircraft, 

maintenance, and use of safety checklist prior to each flight, an equivalent level of safety 

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 of safety 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 

takeoff and landing distances, along with checklists found in the manufacturers' manuals 

will be implemented. These actions will provide an equivalent or higher level of safety. 

14 CFR 91.109- UAS and remotely piloted aircraft do not have fully functional dual 

controls. Flight control is achieved through the use of a control box that communicates 

with the aircraft via radio communications. An equivalent level of safety 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 of the 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 of safety 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 of safety 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 of the launch site shown on the GPS altitude indicator prior to 
flight. 

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 of flight time. The UAS is unable to meet the 30 minute reserve requirement and 

therefore requires an exemption. An equivalent or increased level of safety will be 

achieved by monitoring the battery through the ground station and landing with a 

minimum of 30 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 of safety will be maintained by 

keeping the flight manual at the ground station where the U AS 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 of Safety 

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 of an airport unless prior contact to Air 

Traffic Control has been established. 

2. Flights will not exceed an airspeed of 87 knots ( 100 mph) 

3. Flights will be operated at or below an altitude of 400 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 of sight. 

9. The UAS will utilize an internal flight safety feature that will return to a 

preprogrammed position and land if communication 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 of unpredictable obstacles or emergencies. 

12. Operated by the Applicant, a licensed private pilot. 

Public Interest 

I believe the use of a sUAV to supplement manned aircraft will enhance safety and help 
reduce the impact to the environment compared to similar operations conducted with a 

manned aircraft carrying a flight crew and flammable fuel. 

The inspections of cellular 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 

of these structures for safety. 

The use of a s U AV in the real estate industry helps provide a higher level of marketing 

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 of a safety concern for the general 

public with less fuel, time, noise and other resources. 

The use of sUAV'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 of conditions 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 of an 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 of search and rescue, the standard 

operating procedure of the authority having jurisdiction will serve as rule in the case of 

emergencies when consent cannot be obtained from each individual. 

Respectfully, 

Dale Parrish, Own~ , " },L 

_) (~'L_ \ C. try f/ 

Hover Visions 

6652 E. 46th Place 

Tulsa, OK 74145