104 West Jersey Avenue

Brandon, FL 33510

Docket Operations, M

- 30 U.S. Department of Transportation (DOT) 1200 New Jersey Avenue, SE

Room W12

- 140 West Building Ground Floor September 23 , 2015 Washington, D.C. 20590

- 0001

Reference: DroneVU Studios Peti tion for Section 333 Exemption

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), DroneVU

S tudios is petitioning for an exemption from the Federal A viation Regulations and other rules/statutes pertaining to unmanned aircraft systems. Section 333 of the FMRA addresses special rules for certain unmanned aircraft systems and grants the FAA authority to allow for the safe operation of certain unmanned aircraft systems (UAS) within the national airspace.

D roneVU S t udios can assist construction sites with ensuring the safety of the site adheres to current safety guid elines, assist real estate professionals with effectively mar keting their listings,

assist with inspections in difficult and hazardous location, and assist b usinesses throughout the Florida area with reaching their target audience using the latest cu tting edge aerial photography technology.

DroneVU S t udios is comprised of pilots, photographers, and videographers with years of photography and videography experience which can be used to help local b usinesses more effectively market their products, services, and capabilities to potential future cust omers.

DroneVU S t udios has safely created extensive complimentary aerial photography and aerial video footage throughout the Florida, Georgia, and North C arolin a areas for educational and recreational purposes. We have combined experience of over 1,000 hours operating remotely

cont rolled and remotely piloted terrestrial and aerial systems.

Obtaining an exemption would provide DroneVU S t udios with the ability to meet an urgent need

in the advertisin g community by creating aerial photography and aerial videography foota ge that

cu stomers could use to give them a marketing edge in a highly competitive environment. Currently, the FAA does not allow civil UAS operations (meaning operations other than public aircraft operations or model aircraft / “hobbyist” activities which include research andU.S. Department of Transportation

September 23 , 2015 Page 2 of 15

development); therefore DroneVU S t udios has not been able to commercialize it ’ s aerial photography services to real estate, construction

, and other Florida businesses. Approving this exemption would allow local American businesses to ca pitalize on the benefits that modern UASs can provide by giving DroneVU S t udios the approval it needs to begin commercial operations. 14 CFR 11.81 (a)

– Name and address of the Petitioner :

DroneVU Studios 104 West Jersey Avenue
Brandon, FL 33510

Phone: 727

- 403

- 1085

E

- mail: info@dronevustudios.com

14 CFR 11.81 (b)

– Exemptions Requested:

The FAA considers unmanned aircraft as “aircraft” flown by a “pilot” regardless of the location of the pilot. All aircraft a nd pilots must comply with applicable sections of Title 14 of the Code of Federal Regulations (14 CFR) and other rules/regulations to operate within the National Airspace. Unmanned aircraft are unable to comply with certain sections of 14 CFR as the regula tions were written prior to the consideration of small UAS integration within the national airspace. Therefore DroneVU Studios is requesting an exemption from certain parts of 14 CFR cited below, in addition to such further exemptions and relief as the FAA may determ ine is necessary to permit the operations described herein

.

14 CFR Part 21 Subpart H

– Airworthiness certification 14 CFR Part 45.23 (b)

– Display of marks; general 14 CFR Part 61.113 (a) and (b)

– Private pilot privileges and limitations: Pilot in command

14 CFR Part 91.7

– Civil Aircraft Airworthiness 14 CFR Part 91.9 (b)

– Civil aircraft flight manual, marking and placard requirements

14 CFR Part 91.109

– Flight Instruction

14 CFR Part 91.119

– Minimum safe altitudes

14 CFR Part 91.121

– Altimeter settings

14 CFR Part 91.151

– Fuel requirements for flight in VFR conditions 14 CFR Part 91.203 (a) and (b)

– Civil Aircraft; Certifications Required

14 CFR Part 9 1.405

– Maintenance required

14 CFR Part 91.407

– Operation after maintenance, preventive maintenance, rebuilding or

alteration

14 CFR Part 91.409

– Inspections

14 CFR Part 91.417

– Maintenance Records

U.S. DOT

- FAA

- Air Traffic Organization Policy Notice N JO 7210.873 (6.d)U.S. Department of Transportation

September 23 , 2015 Page 3 of 15

14 CFR Part 11.81 (c)

– The extent of relief DroneVU St udios seeks, and the reason

DroneVU Studios seeks the relief:

DroneVU Studios seeks relief pursuant to this exemption from applicable parts of the Federal

A viation Regulations and other rules/regulations to the extent necessary to permit commercial civil flight operations within the national airspace. DroneVU Studios seeks authorization to conduct small UAS flight operations within the perimeters of this exemption request.

14 C FR Part 21 Subpart H (Airworthiness Certificates)

DroneVU Studios seeks to utilize the DJI Inspire 1

, and DJI Phantom 3, and the DJI Phantom 2 UAS platform s under this exemption request.

These UAS platform s have already been approved under previous Section 333 exemption
requests as evidenced by Sydor Aerial Photography LLC ’ s exemption approval (Exemption

Number 11930)

. These platforms have a proven safety record and have demonstrated that its operations would not adversely affect safety compared to similar aircraft that have been issued an airworthiness certificated under 14 CFR Part 21, Subpart H. Should the FAA approve this

ex emption request and determine that an airworthiness certificate is not required, noise certification and testing under 14 CFR Part 36 will also not be required for the se UAS platforms for the term of the exemption.

14 CFR Part 45.23 (b) (Display of Marks: General)

DroneVU Studios , as the petitioner seeks relief from Part 45.23 (b) requiring markings on certain sections of the aircraft and markings of a certain size. DroneVU Studios clearly identify the company, and provide contact information as large as pos sible on all UAS platforms approved in this exempti on due to the UAS small size.

14 CFR Part 61.113 (a) and (b) (Private Pilot Privileges and Limitations: Pilot in Command) Part 61.113 (a) states that no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command or an aircraft. Part 61.113 (b) states that a private pilot may, for compensation o r hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Within t he Grant of Exemption Regulatory Docket No. FAA

- 2014

- 0352, the FAA stated that it had to determine the level of pilot certificate appropriate for that proposed operation. The FAA said within the Grant that it considers the overriding safety factor to be th e airmanship skills acquired through UAS

- specific flight cycles, flight time, and specific make and model experience and UAS testing. DroneVU Studios agrees with this determination; however due to the expense and extensive time required to either obtain a private or sport pilot ’ s license

we reques t consideration of a 360 day temporary airman certificate in accordance with § 63.13

to allow DroneVU S t udios time to hire a private, sport or commercial pilot or time to obtain such

a designator by one of our existing employees.U.S. Department of Transportation

September 23 , 2015 Page 4 of 15

14 CFR Part 91.7 (Civil Aircraft Airworthiness) This regulation states that (a) No person may operate a civil aircraft unless it is in airworthy condition and (b) The pilot in command of a civil aircraft is re sponsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur. This exemption would not be necessary should the FAA approve the exemption for 14 CFR Part 21 Subpart H. If DroneVU

Studio ’ s UAS is not required to obtain an airworthiness certificate, then this would not apply;

however DroneVU Studios would maintain the UAS and the PIC would deem the UAS safe for flight operations and disconti nue any flight if any mechanical, electrical, or structural problem

arose.

14 CFR Part 91.9 (b) (Civil Aircraft Flight Manual, marking and placard requirements) and 14 CFR Part 91.203 (a) and (b) (Civil Aircraft; Certifications Required) This regulati on states that no person may operate a U.S. registered civil aircraft

- (1) For which an Airplane or Rotorcraft Flight Manual is required by Part 21.5 of 14 CFR unless there is available in the aircraft a current, approved Airplane or Rotorcraft Flight Manua l or the manual provided for in 14 CFR Part 121.141 (b); and (2) For which an Airplane or Rotorcraft Flight Manual is not required by 14 CFR Part 21.5, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, appro ved manual material, markings and placards or any combination thereof. Based on the FAA’s Memorandum titled, “Interpretation regarding whether certain required documents may be kept at an unmanned aircraft’s control station”, dated August 8. 2014, DroneVU Studios fee ls that requesting relief from these regulations may not be

necessary. DroneVU Studios will have in its possession, on site, the UAS manufacturer’s flight/operations manual and registration paperwork.

14 CFR Part 91.109 (Flight Instruction) This regulation relate s to civil aircraft with dual controls or throw over controls for flight training.

DroneVU Studios seeks relief from this regulation in that our UAS platforms do not have dual or throw over controls for flight instruction. DroneVU Studios has provided all training and operational docum ents for all of our UAS platform s , the DJI Inspire 1, DJI Phantom 2, and DJI

Phantom 3

. DroneVU Studios evaluates the qualification of our pilots based on their experience with the UAS to be operated and verifies this through manufacturer and DroneVU Studios ’

- supplemental training (from DroneVU Studios ’ lead PIC ).

14 CFR Part 91.119 (b) and (c) (Minimum Safe Altitudes: General) Per the regulation, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywhere. An al titude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those areas, the

airc raft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.U.S. Department of Transportation

September 23 , 2015 Page 5 of 15

DroneVU Studios does not request relief from (a) as we feel that our UAS can make an emergency landing without undue hazard to persons or property on the ground if its power unit fails due to its size and operating parameters. DroneVU Studios is seeking relief from (b) and (c)

because the focus of our flights will be objects on the ground. Properly framing, and filming properties on the ground will require us to fly significantly lower than 500 fee t , but we would not operate at an altitude that would create any undue hazard to persons or property on the surface.

14 CFR Part 91.121 (Altimeter Settings) This regulation states that:(a) Each person operating an aircraft shall maintain the cruising

altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

— (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft ; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the

elevation of the departure airport or an appropriate altimeter setting available before departure; or (2) At or above 18,000 feet MSL, to 29.92 ′′ Hg.(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the follow ing table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210
(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified below, according to the curr ent reported altimeter setting:

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500U.S. Department of Transportation

September 23 , 2015 Page 6 of 15

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000

Although DroneVU Stu dios will not have a typical aircraft barometric altimeter onboard the UAS, our intention is to operate within VLOS and at or below 400 feet AGL. This, in combination with our UAS’s capacity will provide altitude info rmation to both the PIC and mission specialist/planner via a telemetric data feed which downlinks from the UAS to a ground based display. Prior to each flight the UAS PIC and mission specialist/planner will confirm altitude accuracy prior to launch.

14 CFR Part 91.151

– Fuel Requirements for Flight in VFR Conditions According to this regulation, (a) 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 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. (b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.

DroneV U Studios seeks relief from Part 91.151 (a.1 ) and (b), as its UAS does not carry fuel onboard and is powered via battery. DroneVU Studio s ’ UAS platforms all weigh less than 7 lbs, operates at slow speeds and within VLOS in VMC conditions. DroneVU Studios intends to terminate flights after 20 minutes or with 20% remaining battery power (whicheve r occurs first).

DroneVU Studios does not seek an exemption from Part 91.151 (a)(2) as UAS operations will be conducted during the daytime VMC (visual meteorological conditions).

14 CFR Part 91.203 (a) and (b)

– Civil Aircraft; Certifications Required This regula tions states that (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. Each U.S. airworthiness certificate used to comply with this subpar agraph (except a special flight permit, a copy of the applicable operations specifications issued under §21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter containing that portion of the operations specifications issued under §21.197(c), or an authorization under §91.611) must have on it the registration number assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not have on it an assigned spe cial identification number before 10 days after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number, that has been affixed to an aircraft, may only be obtained upon applic ation to an FAA Flight Standards district office. (2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in §47.31(c), or a reg istration certification issued under the laws of a foreignU.S. Department of Transportation

September 23 , 2015 Page 7 of 15

country. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displaye d at the cabin or cockpit entrance so that it is legible to passengers or crew.

Should the FAA allow for the exemption of 14 CFR Part 21, DroneVU Studios would not need an exemption from this regulation, as an airworthiness certificate would not be required; howe ver since that exemption has not been received to date, DroneVU Studios seeks r elief from this regulation. DroneVU Studios ’ UAS will have the appropriate documentation available upon request.

14 CFR Part 91.405

– Maintenance required

Acc ording to this regulation, each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter; (b) Shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance records indicating the aircraft has been approved for return to service; (c) Shall have any inoperative ins trument or item of equipment, permitted to be inoperative by §91.213(d)(2) of this part, repaired, replaced, removed, or inspected at the next required inspection; and (d) When listed discrepancies include inoperative instruments or equipment,

shall ensure that a placard has been installed as required by §43.11 of this chapter. DroneVU

Studios seeks relief from this regulation because alternate UAS inspection requirements are

needed. DroneVU Studios will follow UAS manufacturer requirements regarding maintenance

via the manufacturer ’ s maintenance schedule. DroneVU Studios will document all maintenance, overhaul, replacement, and inspection requirements, as well as any preflight inspection procedures that account for discrepancies not already covered in the manufacturer’s manual;

docu mentation of maintenance records and will partner with the UAS manufacturer to develop UAS technician qualification criteria.

14 CFR Part 91.407

– Operation after maintenance, preventive maintenance, rebuilding or

alteration Per this regulation, (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service by a person authorized under §43.7 of this chapter; and (2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has been made. (b) No person may carry any person (other than crewmembers) in an aircraft that has been maintained, rebuilt, or altered in a manner that may have appr eciably changed its flight characteristics or substantially affected its operation in flight until an appropriately rated pilot with at least a private pilot certificate flies the aircraft, makes an operational check of the maintenance performed or

alterat ion made, and logs the flight in the aircraft records. (c) The aircraft does not have to be flown as required by paragraph (b) of this section if, prior to flight, ground tests, inspection, or both show conclusively that the maintenance, preventive mainten ance, rebuilding, or alteration has not appreciably changed the flight characteristics or substantially affected the flight operation of the aircraft

.U.S. Department of Transportation

September 23 , 2015 Page 8 of 15

DroneVU Studios seeks relief from this regulation, and requests that the FAA adopt an

alternative version that i s applicable to UAS operations. A DroneVU Studios

- approved UAS technician or the UAS manufacturer will approve the UAS to return to service/operation after it has undergone maintenance, rebuilding or alteration. The UAS PIC may approve the UAS for

return to service a fter performing any preventive maintenance. DroneVU Studios will keep UAS maintenance records that contain the following information: name of the person performing the maintenance, description of work performed, and date of work completion/returned to service.

14 CFR Part 91.409

– Inspections According to this regulation, (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

— (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or 2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No inspection performed

u nder paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records. (b ) Except as provided in paragraph (c) of this section, no person may operate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides, unless within the preceding 100 hours of time in service the aircraft

has received an annual or 100

- hour inspection and been approved for return to service in accordance with part 43 of this chapter or has received an inspection for the issuance of an

airworthiness certifi cate in accordance with part 21 of this chapter. The 100

- hour limitation may be exceeded by not more than 10 hours while en route to reach a place where the inspection can be done. The excess time used to reach a place where the inspection can be done must be included in computing the next 100 hours of time in service. (c) Paragraphs (a) and (b) of this section do not apply to

— (1) An aircraft that carries a special flight permit, a current experimental certificate, or a light

- sport or provisional airworthi ness certificate; (2) An aircraft inspected in accordance with an approved aircraft inspection program under part 125 or 135 of this chapter and so identified by the registration number in the operations specifications of the certificate holder having the approved inspection program; (3) An aircraft subject to the requirements of paragraph (d) or (e) of this section; or (4) Turbine

- powered rotorcraft when the operator elects to inspect that rotorcraft in accordance with paragraph (e) of this section.

DroneVU Studios seeks relief from this regulation, in that DroneVU Studios will follow the guidance included in the UAS manufacturer’s maintenance schedule as attached.

14 CFR Part 91.417

– Maintenance Records According to this regulation, (a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenanc e, preventiveU.S. Department of Transportation

September 23 , 2015 Page 9 of 15

maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircra ft. The records must include

— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directiv e number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or s uperseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a regi stered owner or operator under §43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. (c) The owner or operator shall make all maintenance records required to be kept by this section avai lable for inspection by the Administrator or any authorized representative of the National Transportation Safety Board (NTSB). In addition, the owner or operator shall present Form 337 described in paragraph (d) of this section for inspection upon request of any law enforcement officer. (d) When a fuel tank is installed within the passenger compartment or a baggage compartment pursuant to part 43 of this chapter, a copy of FAA Form 337 shall be kept on board the modified aircraft by the owner
or operator.

DroneVU Studios seeks relief from this regulation and requests an exemption. All maintenance and alterations will be properly documented in the each UAS aircraft records. Dro neVU Studios will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement,

in spection and life limit requirements. All maintenance, preventive maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS will be

recorded and documented. DroneVU Studios will comply with all manufacturer saf ety bulletins.

U.S. DOT

- FAA

- Air Traffic Organization Policy Notice N JO 7210.873 (6.d) 6(d) Certificates of Waiver or Authorization (COA)

- Emergency and Urgent Applications: The FAA must ensure procedures are available to accommodate real

- time applicati ons that will directly support emergency and law enforcement

- type operations. UA Operations that reduce safety must not be approved in any case. (1) An emergency UAS COA may be consideredU.S. Department of Transportation

September 23 , 2015 Page 10 of 15

when all of the following conditions apply: (a) There is a situation of such distress or urgency that the possibility of loss of life is great. (b) Manned flight is not possible or practicable due to a hazard or the operation cannot be conducted safely with manned flight, or manned assets are not available. (c) The propose d proponent and UAS are operating under a current approved

COA. Note

- Requests for UAS COAs that fall outside of these perimeters must be processed through the normal online COA application process. (2) Emergency UAS COAs will not be considered for: (a) De monstration flights. (b) Flights to test capabilities. (c) Training. (d) Flights in Class B airspace. (e) Flights over populated areas.

DroneVU Studios seeks an exemption from the normal FAA UAS Civil COA Request mandated by a Section 333 Exemption filing and the current Emergency COA process. During a catastrophe event, the exact timeframe and location is not known ahead of time; therefore,

DroneVU Studios could not abide by the current COA process and would need an exemption from the normal COA process as well as the curre nt Emergency COA process. DroneVU

Studios would notify the local FSDO of the affected area immediately, apply for an amended Emergency COA (as granted by this exemption) and would notify any Incident Command or first responders for approval and coordination and would not interfere with first responders’ activities. Through this request, DroneVU Studios is seeking relief from U.S. DOT

- FAA

- Air Traffic Organization Policy Notice N JO 7210.873 (6.d)1(a), 1(c), 2(d) with ATO approval, and 2(e) of the COA process stated above.

1 4 CFR Part 11.81 (d)

– The reasons why granting DroneVU Studios ’ request would be in the public interest; that is, how it would benefit the public as a whole:

Granting the exemption for DroneVU Studios would allow the organization to safely and efficiently conduct small UAS flight operations to assist local businesses more effectively advertise their services, home owners to mo re quickly sell their homes, home buyers to better visual their potential future home, construction companies to more safely m anage their construction sites, and could more safely and effectively inspect cell phone towers, railroad tracks, pipelines, and other structures that could pose a risk to public sa fety in the event of a

failure

. Without this exemption, DroneVU Studios would be restricted to ground only operations which would not have the benefits of UAS efficiency in terms of s ervice

, safety , an d advertising appeal

.

14 CFR Part 11.81 (e)

– The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least eq ual to that provided by the rule from which DroneVU Studios seeks the exemption:

DroneVU Studios requests that the exemption be granted with the following limitations and operational conditions. These limitations and conditions will provide an enhanced level of safety

and wi ll be the guiding principles when DroneVU Studios is conducting operations under this exemption:U.S. Department of Transportation

September 23 , 2015 Page 11 of 15

A. The small unmanned aircraft systems maximum take

- off weight will be less than 55 lbs.

DroneVU Studios is willing to hav e its authorization restricted below the 55 lb. threshold to the operating weight of the unmanned aircraft identified. The UAS platform s that

DroneVU Studios is seeking to utilize through this exemption is currently operating safely

within the national a irspace pursuant to several COAs granted by the FAA to Tierra Antigua Realty, Sydor Aerial Photography, and other public entities. One these COAs

was for the use of the DJI Phantom 2

- to provide aerial imagery for real estate properties

in the Arizona area . Other COAs have been approved for this particular platform through other public entities, which demonstrates the confidence that the FAA has for this manufacturer’s operational and safety protocol. DroneVU Studios would operate in

accordance with the manufacturer’s flight manuals, maintenance schedules, and training

documents

.

B. All pilot in command (PIC) and visual observers (VO) will possess an FAA certified private pilot ’ s license or operate the craft under a temporary airman certificate if so granted in accordance with § 63.13 . This ensures that all PIC and VO have the knowledge regarding the Federal Aviati on Regulations, Airspace, and other pertinent knowledge to conduct safe operations of small unmanned aircraft systems

. All PIC and

VO will be trained in detail for each of the unmanned aircraft system platform’s operations, systems and emergency procedures and passed every level of training on the platform and pass the manufacturer’s test if so provided which would be administered by the DroneVU Studio s PIC . Training records will be kept at DroneVU

Studios for every PIC and VO and will be available for review. Every PIC and VO will

obtain an FAA Clas s 3 medical certificate or hold a valid driver ’ s license

.

C. Prior to conducting operations for a commercial cu stomer , the PIC will have accumulated and logg ed, in a manner consistent with 14 CFR Part 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a UAS pilot and at least 10 hours logged as a UAS pilot with a similar UAS type. The PIC will have accumulated and logged a minim um of 5 hours as a UAS pilot operating the make and model of the UAS to be utilized for operations and 3 take off and landings in the preceding 90 days.

All flight op erations will be coordinated and approved by the homeowner, construct ion site authorized representative, commercial property authorized representative , or any authorized repr esentative for the structure to be filmed in advance of DroneVU Studios ’

arrival at the filming site via email or written authorization. T he U AS will not be operated directly over any person, except authorized and consenting personnel at the site or unless the UAS is at sufficient altitude not to create a hazard to other people or property on the ground.U.S. Department of Transportation

September 23 , 2015 Page 12 of 15

D. All flight operations will be operated at an altitude of no more than 400 ft above the ground (AGL) within daylight VFR conditions and within visual line of sight (VLOS). The UAS will be operated within VLOS of the PIC at all times. The UAS will remain clear and yield the right of way to all o ther manned operations and activities at all times. All operations will utilize at least one visual observer (VO) and the PIC and VO will be able to communicate verbally at all times

. The UAS will not operate within 5 nm of any airport unless a letter of agreement with that airport’s management is obtained and the operation is conducted in accordance with a NOTAM, as required by a C OA. All flights will be communicated to FAA Flight Service with posted NOTAMS prior to the flight(s).

E. All flight operations will be conducted within line of sight of the pilot in command and visual observer(s). Maximum total fligh t time for each flight will be 20 minutes or less in duration. All flight operations will be terminated when the aircraft has le ss than 20% battery life remaining.

F. Flight operations and safety briefings will be conducted prior to all planned small unmanned aircraft system flights and will be mandatory for PIC and VO. Briefings will include weather reviews, take off, landing and aircraft performance data for those real time conditions, and full pre

- and post

- flight inspections/checklists and briefings for each specific unmanned aircraft system, including the ground control station being operated and account for any discrepancies (i.e. inoperable components, items or equipment that are not covered in the relevant preflight inspection sections of the operations manual.) Before conducting any flight, the radio frequency spectrum used for the operation and control of the UAS will comp ly with the FCC or other appropriate government oversight agency requirements.

G. The UA S will not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Direc tory (AFD) or for airports not denote d
with an ARP, the center of the airport symbo l as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder.

The letter of agree ment with the airport management will be made available to the Administrator or any law enforcement official upon request.

H. Any UAS that has undergone maintenance or alterations that affects the UAS operation or flight characteristics must undergo a functional test flight in accordance with the manufacturer’s recommendations. The PIC who conducts the test flight will make an entry in the UAS aircraft records of the flight. All maintenance and alterations will be properly documented in the aircraft records. DroneVU Studios will follow the UAS

manuf acturer’s aircraft/component, maintenance, overhaul, replacement, inspection and life limit requirements. All maintenance, preventive maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS will beU.S. Department of Transportation

September 23 , 2015 Page 13 of 15

recorded and documented. DroneVU Studios will comply with all manufacturer safety

bulletins.

I. In the event of a communication lost link, the UAS will return to a specific predetermined location and once the UAS is safely recovered, all flight operations will cease until any communication/data link issues are properly resolved. The UAS will abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s

manual.

J. Any incident, accident or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24hrs. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB

Web site: www.ntsb.com

. DroneVU Studios will suspend all flight operations until the incident, accident, or transgress ion is reviewed by AFS

- 80 and authorization to resume operations is provided.

14 CFR Part 11.81 (f) A summary the FAA can publish in the Federal Register, stating:

(1) The rule from which you seek the exemption

Petitioner: DroneVU Studios

Sections of 14 CFR and FAA regulations that DroneVU Studios seeks an exemption:

14 CFR Part 21 Subpart H 14 CFR Part 45.23 (b) 14 CFR Part 61.113 (a) and (b)

14 CFR Part 91.7 14 CFR Part 91.9 (b)

14 CFR Part 91.109

14 CFR Part 91.119

14 CFR Part 91.121

14 CFR Part 91.151 14 CFR Part 91.203 (a) and (b)

14 CFR Part 91.405

14 CFR Part 91.407

14 CFR Part 91.409

14 CFR Part 91.417

U.S. DOT

- FAA

- Air Traffic Organization Policy Notice N JO 7210.873 (6.d)U.S. Department of Transportation

September 23 , 2015 Page 14 of 15

(2) A brief description of the nature of the exemption you seek:

DroneVU Studios seeks relief from the applicable parts of 14 CFR 21, 45, 61, 91 and U.S. DOT

FAA

- Air Traffic Organization Policy Notice N JO 7210.873 (6.d) as requested within this petition

to allow DroneVU Studios to safely and efficiently conduct civil UAS flight operations to assist business owners, real estate professionals, construction site owners, in advertising their services, safely conducting construction operations, and saf ely inspecting in areas that coul d be

hazardous or difficult for humans to inspect.

14 CFR Part 11.81 (g)

– Any additional information, views or arguments available to
support DroneVU Studio s request:

Granting this exemption for DroneVU Studios would allow the organization to safely and efficiently conduct small UAS flight operations to assist local businesses more effectively
advertise their services, home owners to mo re quickly sell their homes, home buyers to better visual their potential future home, construction companies to more safely m anage their construction sites, and could more safely and effectively inspect cell phone towers, railroad tracks, pipelines, and other structures that could pose a risk to public sa fety in the event of a

failure

.

14 CFR Part 11.81 (h)

– Request to exercise the privileges of the exemption outside the United States, the reason why the petitioner needs to do so:

DroneVU Studios does not seek to exercise the privileges of this exemption, should it be granted, outside of the United States. Our request is strictly to be granted authority for civil UAS operations at locations within the national airspace system.

Sincerely,



# Robert Ashe

Robert Ashe

Owner

– DroneVU Studio s