Elevated Perspectives, LLC 300 Science Hill School Lane North Augusta, SC 29860 ‐‐‐ CONFIDENTIAL AND PROPRIETARY

Rodney Ashcraft, President, CEO

Elevated Perspectives, LLC

300 Science Hill School Lane

North Augusta, SC 29860

16October2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R.

45.23(b); 14 CFR part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(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); 91.417 (a) & (b).

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, Elevated Perspectives, LLC (“The Applicant”), developer and operator of Small Unmanned Aircraft Systems (“SUASs”)

equipped to conduct Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection,

Visual Inspection‐ Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar

arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings.  Real Estate, Golf

Courses, Orthographic Photography, Special Events, Construction Progress, Public Service‐ Primarily: Search & Rescue,

Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and

tornados.  Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious

gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and

development, traffic monitoring, and sporting events, hereby applies for an exemption from the listed Federal Aviation

Regulations (“FARs”) to allow commercial operation of its SUASs, so long as such operations are conducted within and

under the conditions outlined herein or as may be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of small, unmanned, and

relatively inexpensive sUAS under controlled conditions in airspace that is 1)limited, 2) predetermined, 3) controlled as

to access, and 4) would provide safety enhancements to the already safe operations in the infrastructure and business

operations industry presently using conventional aircraft.  Approval of this exemption would thereby enhance safety and

fulfill the Secretary of Transportation’s (The FAA Administrator’s) responsibilities to “...establish requirements for the

safe operation of such aircraft systems in the national airspace system.”  Section 333(c) of the Reform Act.

The name and address of the applicant is:

Elevated Perspectives, LLC

ATTN: Rodney Ashcraft

Ph: (803)215‐9000

Email: Rodneyashcraft@gmail.com   

Address: 300 Science Hill School Lane North Augusta, SC 29860  
Elevated Perspectives, LLC 300 Science Hill School Lane North Augusta, SC 29860 ‐‐‐ CONFIDENTIAL AND PROPRIETARY

Regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.405 (a)

14 C.F.R. 91.407 (a) (1)

14 C.F.R. 91.409 (a) (2)

14 C.F.R. 91.417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of

the Reform Act.  This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems

may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section

332 of the Reform Act.  In making this determination, the Secretary is required to determine which types of UASs do not

create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

 The UAS’s size, weight, speed, and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a).  Lastly, if the secretary determines that such vehicles “may operate safely in the national

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national

airspace system.”  Id. §333(C) (emphasis added).1

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions.  This statutory authority by

its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, which includes sUASs,

from the requirements that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a)

or (b) of this section or any sections 44702‐44716 of this title if the administrator finds the exemption in the public

interest.  49 U.S.C. §44701(f) See also 49 U.S.C. §44711 (a); 49 U.S.C. §44704; 14 C.F.R. §91.203 (a) (1).

Elevated Perspectives, LLC’s sUASs (Appendix 1) are rotorcraft, weighing 55 or fewer lbs. including payload.  

They operate under normal conditions at a speed of no more than 55 knots and have the capability to hover and

                                                            

1 Applicant interprets this provision to place the duty on the administrator to not only process applications for exemptions under

§333, but for the Administrator to craft conditions for the safe operation of the UAS, if it should be determined that the conditions

set forth herein do not fulfill the statutory requirements for approval.
Elevated Perspectives, LLC 300 Science Hill School Lane North Augusta, SC 29860 ‐‐‐ CONFIDENTIAL AND PROPRIETARY

move in the vertical and horizontal plane simultaneously.  They will operate only in line of sight and will operate only

within the sterile area described in the confidential Elevated Perspectives, LLC Unmanned Aircraft Systems

Operations Manual, attached as Appendix 2 (hereinafter “The Manual”)2

.  Such operations insure that the sUAS does

“not create a hazard to users of the national airspace system or the public.”3

Given the small size of the sUASs involved and the restricted sterile environment within which they will operate, the

applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that

the FAA must, by exemption, allow commercial operations of UASs to commence immediately.  Also due to the size

of the UASs and the restricted areas in which the relevant SUASs will operate, approval of the application presents

no national security issue.  Given the clear direction in Section 333 of the Reform Act, the authority contained in the

Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and

the significant public benefit, including enhanced safety, reduction in environmental  impacts, including reduced

emissions associated with allowing UASs for Precision Agriculture, 2D and 3D Mapping, Photography,

Cinematography, Aerial Data Collection, Visual Inspection‐ Primarily towers, poles, pipelines, power lines, cables,

bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash ponds,

absorbers, and buildings.  Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction

Progress, Public Service‐ Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief,

Wildfires, Floods, hurricanes, news broadcasting, and tornados.  Banner towing, Announcements, animal tracking,

Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments,

Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events, the

granting of the requested exemptions is in the public interest.  Accordingly, the applicant respectfully requests that

the FAA grant the requested exemption without delay.

Background Information

Elevated Perspectives, LLC is in the business of consulting on, building, and maintaining mission specific sUAS for

Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection‐ 

Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind

generators, power stations and substations, coal ash ponds, absorbers, and buildings.  Real Estate, Golf Courses,

Orthographic Photography, Special Events, Construction Progress, Public Service‐ Primarily: Search & Rescue, Law

Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and

tornados.  Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection,

Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research

and development, traffic monitoring, and sporting events.  Elevated Perspectives, LLCs’ clients look to us for safe

operations of sUAS.  We have developed specific safe UAV operational procedures.  Increasingly, we have clients

looking to operate sUAS for Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data

Collection, Visual Inspection‐ Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical

structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings.  

Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service‐ 

Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods,

hurricanes, news broadcasting, and tornados.  Banner towing, Announcements, animal tracking, Alzheimer patient

tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining,

volumetric Analysis, Research and development, traffic monitoring, and sporting events.

                                                            

2 Applicant submits this manual as a Confidential document under 14CFR 11.35 (b) as the entire manual contains proprietary

information that the applicant has not and will not share with others.  The manual contains operating conditions and procedures

that are not available to the public and are protected from release under the Freedom of Information Act 5 U.S.C. 552 et. Seq. 3 Reform Act Section 333(b).
Elevated Perspectives, LLC 300 Science Hill School Lane North Augusta, SC 29860 ‐‐‐ CONFIDENTIAL AND PROPRIETARY

Operations performed by Elevated Perspectives, LLC include:

Precision Agriculture

2D and 3D Mapping

Photography

Cinematography

Aerial Data Collection

Visual Inspection‐ Primarily:

Towers

Poles

Pipelines

power lines

cables

bridges

chimneys

vertical structures

solar arrays

wind generators

power stations and substations

coal ash ponds

absorbers

buildings

Real Estate

Golf Courses

Orthographic Photography

Special Events

Construction Progress

Public Service‐ Primarily:

Search & Rescue

Law Enforcement

Fire

Security

Disaster Management & Relief

Wildfires

Floods

Hurricanes

news broadcasting

tornados

Banner towing

Announcements

animal tracking

Alzheimer patient tracking

Radiation detection

Noxious gas detection

Forestry & logging

Insurance Assessments

Surveys

Mining

volumetric Analysis

Research and development
Elevated Perspectives, LLC 300 Science Hill School Lane North Augusta, SC 29860 ‐‐‐ CONFIDENTIAL AND PROPRIETARY

traffic monitoring

sporting events

As part of this Elevated Perspectives, LLC is requesting FAA Exemption for sUAS operations for safety, inspection and video

capture

Usage.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics

and that operate within the limitations listed herein.  These limitations provide for at least an equivalent or even higher

level of safety to operations under the current regulatory structure because the proposed operations represent a safety

enhancement to the already safe Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data

Collection, Visual Inspection‐ Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical

structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings.  Real

Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service‐ Primarily: Search

& Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news

broadcasting, and tornados.  Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation

detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis,

Research and development, traffic monitoring, and sporting events.  Elevated Perspectives, LLCs’ clients look to us for

safe operations of sUAS.  We have developed specific safe UAV operational procedures.  Increasingly, we have clients

looking to operate sUAS for Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data

Collection, Visual Inspection‐ Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical

structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings.  Real

Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service‐ Primarily: Search

& Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news

broadcasting, and tornados.  Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation

detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis,

Research and development, traffic monitoring, and sporting events operations conducted with conventional aircraft.

These limitations and conditions to which Elevated Perspectives, LLC agrees to be bound when conducting

commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55lbs.

2. Flights will be operated within line of sight, unless an addendum is released or other appropriate FAA guidelines

supersede.

3. Maximum total flight time for each operational flight will be 60 minutes.  Flights will be terminated at 25%

battery power reserve; should that occur prior to the 60 minute time limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL (Above Ground Level) or, not more than 200

feet above an elevated platform from which the flight is planned.

5. Minimum crew for each operation will consist of the sUAS pilot and the Visual Observer.

6. The sUAS pilot will be a specially trained staff member of Elevated Perspectives, LLC.  Knowledgable of the

airspace within which the operation will take place and how that airspace fits into the NAS.

7. The sUAS pilot will be the Pilot in Command (PIC).  If a pilot certificate holder other than the sUAS Pilot, who

possess the necessary PIC qualifications, is also present on site, that person can also be designated as PIC.

8. The sUAS will only operate within defined boundaries as outlined in Section 8.4 of the manual.

9. A briefing will be conducted in regard to the planned sUAS operations prior to each mission.  It will be

mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter be

present for this briefing.
Elevated Perspectives, LLC 300 Science Hill School Lane North Augusta, SC 29860 ‐‐‐ CONFIDENTIAL AND PROPRIETARY

10. The operator will file a FAA form 7711‐1, or its equivalent, as modified in light of the requested exemption, with

the appropriate Flight Standards District Office (FSDO).

11. The operator will obtain the consent of all persons involved in the mission and ensure that only consenting

persons will be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based

upon an equivalent level of safety determination, as required by section 8.4 of the manual.  With the advanced

permission of the relevant FSDO, operations at closer range can be approved.

12. The operator will submit a written Plan of Activities to the FSDO three days before the proposed mission as

required in Section 8.1 of the Manual.  Items will include:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS mission conducted under this petition of

exemption;

c. Make, Model, and serial or N‐number of UAS to be used;

d. Name and certificate numbers of UAS PICs involved in the mission;

e. A Statement that the operator has obtained permission from property owners or property owners’

representatives and/or local officials to conduct the mission;

f. The list of those who gave permission made available to the inspector upon request;

g. Signature of exemption‐holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or

state over which the mission will be conducted and the altitudes essential to accomplish the operation.

13. Pilot and observer will have been trained in operation of UAS generally and received up to date information on

the particular UAS to be operated as required in Sections 7.4 and 7.5 of the manual.

14. Observer and pilot will at all times be able to communicate by voice.

15. Written and/or oral permission from the relevant property holders will be obtained.

16. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions,

including local law enforcement, fire, or other appropriate governmental agencies.

17. If the sUAS loses communications or loses its GPS signal, the UAS will have the capability to return to a pre‐

determined location within the security Perimeter and land.

18. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of

airworthiness certificates as required by FAR §91.203 (a)(1).  Given the size and limited operating area associated

with the aircraft to be utilized by the applicant, an exemption from Part 21 Subpart H meets the requirements of an

equivalent level of safety under Part 11 and Section 333 of the Reform Act.  The Federal Aviation Act (49U.S.C.

§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for

an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to

airports and populated areas of the particular UAS.  In all cases, an analysis of these criteria demonstrates that the

UAS operated without an airworthiness certificate,  in the restricted environment and under the conditions

proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airwrothiness certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55lbs. fully loaded, carries neither a pilot nor passenger, carries

no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the

manual.  Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both

the operator and observer, pursuant to the Manual’s policies, and under and in compliance with local public safety

requirements, to provide security for the area of operations as is now done with conventional Precision Agriculture,
Elevated Perspectives, LLC 300 Science Hill School Lane North Augusta, SC 29860 ‐‐‐ CONFIDENTIAL AND PROPRIETARY

2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection‐ Primarily towers,

poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power

stations and substations, coal ash ponds, absorbers, and buildings.  Real Estate, Golf Courses, Orthographic

Photography, Special Events, Construction Progress, Public Service‐ Primarily: Search & Rescue, Law Enforcement,

Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados.  

Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas

detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and

development, traffic monitoring, and sporting events.  The FAA will have advanced notice of all of these operations.  

These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture,

2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection‐ Primarily towers,

poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power

stations and substations, coal ash ponds, absorbers, and buildings.  Real Estate, Golf Courses, Orthographic

Photography, Special Events, Construction Progress, Public Service‐ Primarily: Search & Rescue, Law Enforcement,

Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados.  

Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas

detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and

development, traffic monitoring, and sporting events, provide a greater degree of safety to the public and property

owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. part 21,

Subpart H.  Lastly, application of these same criteria demonstrates that there is no credible threat to national

security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or

flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. §45.23 (b). Marking of the Aircraft

The regulation requires:

    

    When marks include only the Roman capital letter “N” and the registration number is displayed on

limited, restricted or light‐sport category aircraft or experimental or provisionally certificated aircraft, the operator

must also display on that aircraft near each entrance to the cabin, cockpit, or pilot 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.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have

no entrance to a cabin, cockpit, or pilot station on which the word “Experimental” can be placed.  Given the size of

the sUAV, two‐inch lettering will be impossible.  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 sUAV marked on its fuselage as required by §45.29

(f) where the pilot, observer and others working with the sUAV will see the identification of the UAS as

“Experimental.”  The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738,

10167 and 10167A.

14 C.F.R. §61.113 (a) & (b):  Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61.113 (a) & (b) limit private pilots to non‐commercial operations.  Because the UAS will not carry a

pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by

requiring the PIC operating the aircraft to have specially trained staff operate this small UAS.  Unlike a conventional
Elevated Perspectives, LLC 300 Science Hill School Lane North Augusta, SC 29860 ‐‐‐ CONFIDENTIAL AND PROPRIETARY

aircraft that carries the pilot and passengers, the sUAS is remotely controlled and restricted, and all flights are

planned and coordinated in advance as set forth in the Manual.  The level of safety provided by the requirements

included in the Manual exceeds that provided by a single individual holding a commercial pilots certificate operating

a conventional aircraft.  The risks associated with the operation of the sUAS are so diminished from the level of risk

associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS

as requested by specially trained staff as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113

(a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition.  As there

will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory

standard will exist for determining airworthiness.  Given the size of the aircraft and the requirements contained in

the Manual for maintenance and use of safety checklists prior to each flight, as set forth in Sections 9.1 and 9.6, an

equivalent level of safety will be provided.

14 C.F.R. §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides:

    No person may operate a U.S.‐ registered civil aircraft ... (2) For which an airplane or rotorcraft Flight

    Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current

    Approved airplane or rotorcraft Flight Manual, approved manual material, markings, and placards,

    Or any combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not

only because there is no pilot on board, but because there is no room or capacity to carry such an item on the

aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where

the pilot flying the sUAS will have immediate access to it.

The FAA has issued the following exemptions to this regulation:  Exemption Nos. 8607 8737, 8738, 9299, 9299A,

9565, 9565B, 10167A, 10602, 32827, and 10700.

14 C.F.R. §91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight.  

As FAA approved rotorcraft flight manuals will not be provided for the aircraft, an exemption will be needed.  An

equivalent level of safety will be provided as set forth in Sections 8 and 9 of the Manual.  The PIC will take all actions

including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance

data before initiation of flight.

14 C.F.R. §91.109: Flight Instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being

used for flight instruction unless that aircraft has fully functional dual controls.
Elevated Perspectives, LLC 300 Science Hill School Lane North Augusta, SC 29860 ‐‐‐ CONFIDENTIAL AND PROPRIETARY

sUASs and remotely piloted aircraft, by their deisgn do not have fully functional dual controls.  Flight control is

accomplished through the use of a control box that communicates with the aircraft via radio communications.  The

FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and

for flight instruction in experimental aircraft.  See Exemption Nos. 5778K & 9862A.  The equivalent level of safety is

provided by the fact that neither the pilot nor passengers will be carried in the aircraft and by the size and speed of

the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft.  Section 91.119(d) allows helicopters to be

operated at less than the minimums prescribed, provided the person operating the helicopter complies with any

route or altitudes prescribed for helicopters by the FAA.  As this exemption is for a sUAS that is a helicopter and the

exemption requests authority to operate at altitudes up to 400AGL, or not more than 200 feet above an elevated

platform from which operation is planned, an exemption may be needed to allow such operations.  As set forth

herein, except for the limited conditions stated in the Manual the UAS will never operate at higher than 400 AGL.  It

will, however, be operated in a restricted area with a security perimeter, where buildings and people will not be

exposed to operations without their pre‐obtained consent.

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the

location where it is operated.  No flight will be taken without the permission of the property owner, representatives

of the property owner or local officials.  Because of the advanced notice to the property owners and participants in

the mission, all affected individuals will be aware of the planned flight operations as set forth in Section 6.2, 8.1 and

8.2 of the Manual.  Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum

55lbs.  proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than

those presently presented with conventional aircraft operating at or below 500 AGL in the Precision Agriculture, 2D

and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection‐ Primarily towers, poles,

pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations

and substations, coal ash ponds, absorbers, and buildings.  Real Estate, Golf Courses, Orthographic Photography,

Special Events, Construction Progress, Public Service‐ Primarily: Search & Rescue, Law Enforcement, Fire, Security,

Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados.  Banner towing,

Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry &

logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic

monitoring, and sporting events.  The FAA will have advanced notice of all of these operations.  These safety

enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D and 3D

Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection‐ Primarily towers, poles, pipelines,

power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and

substations, coal ash ponds, absorbers, and buildings.  Real Estate, Golf Courses, Orthographic Photography, Special

Events, Construction Progress, Public Service‐ Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster

Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados.  Banner towing,

Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry &

logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic

monitoring, and sporting events industries.  In addition, the low‐altitude operations of the sUAS will ensure

separation between these small UAS operations and the operations of conventional aircraft that must comply with

Section 91.119.

14 C.F.R. §91.121 Altimeter Settings
Elevated Perspectives, LLC 300 Science Hill School Lane North Augusta, SC 29860 ‐‐‐ CONFIDENTIAL AND PROPRIETARY

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an

altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before

departure.”  As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption

may be needed.  An equivalent level of safety will be achieved by the operator, pursuant to the Manual and safety

checklist, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. §91.151 (a):  Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “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 of intended landing,

and, assuming normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; or (2) at night, to

fly after that for at least 45 minutes.”

The battery powering the sUAS provides approximately 30‐37 minutes of powered flight.  To meet the 30‐

minute reserve requirement in 14 C.F.R. §91.151, sUAS flights would be limited to approximately 20 minutes in

length.  Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a

predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 C.F.R. §91.151 (a) falls within the scope of prior exemptions.  See

Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)).  

Operating the small UAS, in a tightly controlled area where only people and property owners or official

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not

engender the type of risks that Section 91.151 (a) was intended to alleviate given the size and speed of the small

UAS.  Additionally, limiting sUAS flights to 20 minutes would greatly reduce the utility for which the exemption will

be granted.   

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of

battery power whichever happens first.  This restriction would be more than adequate to return the sUAS to its

planned landing zone from anywhere in its limited operating area.

   

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808.

14 C.F.R. §91.202 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the

following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate require by paragraph (a)

of this section or a special flight authorization issues under §91.715 is displayed at the cabin or

cockpit entrance so that it is legible to passengers and crew.
Elevated Perspectives, LLC 300 Science Hill School Lane North Augusta, SC 29860 ‐‐‐ CONFIDENTIAL AND PROPRIETARY

The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot.  As such, there is no

ability or place to carry certification and registration documents or to display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point

where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the

sUAS.  The FAA has issued numerous exemptions to this regulation.  A representative sample of other

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

       14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance Inspections

       These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in

subpart E of this part and shall between required inspections, except as provided in paragraph © of this section, have

discrepancies repaired as prescribed in Part 43 of this chapter...,” and others shall inspect or maintain the aircraft in

compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will

not apply to the applicant.  Maintenance will be accomplished by the operator pursuant to the flight manual and

operating handbook as references in the Manual (See Sections 8.6 and 9).  An equivalent level of safety will be achieved

because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for

limited periods of time.  If mechanical issues arise the UAS can land immediately and will be operating from no higher

than 400 ft AGL.  As provided in the Manual, the operator will ensure that the UAS is in working order prior to initiating

flight, perform required maintenance, and keep a log of any maintenance performed.  Moreover, the operator is the

person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the

equivalent level of safety.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it

be determined that publication is needed:

Applicant seeks an exemption from the following rules:

    14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113 (a) & (b), 14 C.F.R. 91.7 (a), 14 C.F.R. 91.9 (b) (2), 14

C.F.R. 91.103, 14 C.F.R. 91.109, 14 C.F.R. 91.119, 14 C.F.R. 91.121, 14 C.F.R. 91.151(a), 14 C.F.R. 91.203(a) & (b), 14 C.F.R.

91.405 (a), 14 C.F.R. 91.407 (a) (1), 14 C.F.R. 91.409 (a) (2), 14 C.F.R. 91.417 (a) & (b). to operate commercially a small

unmanned vehicle (55lbs or less) in motion picture and television operations.

Approval of exemptions allowing commercial operations of sUASs in the Precision Agriculture, 2D and 3D Mapping,

Photography, Cinematography, Aerial Data Collection, Visual Inspection‐ Primarily towers, poles, pipelines, power lines,

cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and substations, coal ash

ponds, absorbers, and buildings.  Real Estate, Golf Courses, Orthographic Photography, Special Events, Construction

Progress, Public Service‐ Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief,

Wildfires, Floods, hurricanes, news broadcasting, and tornados.  Banner towing, Announcements, animal tracking,

Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance Assessments,

Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events.  The FAA will

have advanced notice of all of these operations.  These safety enhancements, which already apply to civil aircraft

operated in connection with Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data

Collection, Visual Inspection‐ Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical

structures, solar arrays, wind generators, power stations and substations, coal ash ponds, absorbers, and buildings.  Real
Elevated Perspectives, LLC 300 Science Hill School Lane North Augusta, SC 29860 ‐‐‐ CONFIDENTIAL AND PROPRIETARY

Estate, Golf Courses, Orthographic Photography, Special Events, Construction Progress, Public Service‐ Primarily: Search

& Rescue, Law Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news

broadcasting, and tornados.  Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation

detection, Noxious gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis,

Research and development, traffic monitoring, and sporting events, using jet or piston powered aircraft, operate at

extremely low altitudes just feet from the infrastructure being inspected and in extreme proximity to people and

structures; and present the risks associated with vehicles that weigh in the neighborhood of 4,000lbs, carrying large

amounts of jet A or other fuel.  Such aircraft must fly to and from the work location.  In contrast, a sUAS weighing fewer

than 55lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible

fuel carried on board.  The sUAS is carried to the worksite and not flown.  The sUAS will carry no passengers or crew and,

therefore, will not expose them to the risks associated with manned aircraft flights.

   

The operation of small UASs, weighing less than 55lbs., conducted in the strict conditions outlines above, will

provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the

applicant from the requirements of Part 21 and allowing commercial operations.  These lightweight aircraft operate at

slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional

operations conducted with turbine helicopters operating in close proximity to the ground and people.

Privacy

All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge.  

Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection‐ 

Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind

generators, power stations and substations, coal ash ponds, absorbers, and buildings.  Real Estate, Golf Courses,

Orthographic Photography, Special Events, Construction Progress, Public Service‐ Primarily: Search & Rescue, Law

Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and

tornados.  Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious

gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and

development, traffic monitoring, and sporting events.  The FAA will have advanced notice of all of these operations.  

These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D

and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection‐ Primarily towers, poles,

pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and

substations, coal ash ponds, absorbers, and buildings.  Real Estate, Golf Courses, Orthographic Photography, Special

Events, Construction Progress, Public Service‐ Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster

Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados.  Banner towing, Announcements,

animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance

Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events

operations will be performed for people who have also consented for work to be performed or otherwise have agreed

to be in the area where UAS flight will take place.   

Conclusion

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012‐ size, weight, speed, operating capabilities,

proximity to airports and populated areas and operation within visual line of sight and national security – provide more

than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant’s UAS

in the Precision Agriculture, 2D and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual

Inspection‐ Primarily towers, poles, pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays,
Elevated Perspectives, LLC 300 Science Hill School Lane North Augusta, SC 29860 ‐‐‐ CONFIDENTIAL AND PROPRIETARY

wind generators, power stations and substations, coal ash ponds, absorbers, and buildings.  Real Estate, Golf Courses,

Orthographic Photography, Special Events, Construction Progress, Public Service‐ Primarily: Search & Rescue, Law

Enforcement, Fire, Security, Disaster Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and

tornados.  Banner towing, Announcements, animal tracking, Alzheimer patient tracking, Radiation detection, Noxious

gas detection, Forestry & logging, Insurance Assessments, Surveys, Mining, volumetric Analysis, Research and

development, traffic monitoring, and sporting events.  The FAA will have advanced notice of all of these operations.  

These safety enhancements, which already apply to civil aircraft operated in connection with Precision Agriculture, 2D

and 3D Mapping, Photography, Cinematography, Aerial Data Collection, Visual Inspection‐ Primarily towers, poles,

pipelines, power lines, cables, bridges, chimneys, vertical structures, solar arrays, wind generators, power stations and

substations, coal ash ponds, absorbers, and buildings.  Real Estate, Golf Courses, Orthographic Photography, Special

Events, Construction Progress, Public Service‐ Primarily: Search & Rescue, Law Enforcement, Fire, Security, Disaster

Management & Relief, Wildfires, Floods, hurricanes, news broadcasting, and tornados.  Banner towing, Announcements,

animal tracking, Alzheimer patient tracking, Radiation detection, Noxious gas detection, Forestry & logging, Insurance

Assessments, Surveys, Mining, volumetric Analysis, Research and development, traffic monitoring, and sporting events

industries pursuant to the Manual appended hereto.

Sincerely,

Rodney Ashcraft

President & CEO

Elevated Perspectives, LLC

C: Justin Sellers