PUREVISION

P.O. Box 54211, Irvine, California 92619 ● (949) 415-6704 ● purevisioncorp@gmail.com

October 12, 2015

U.S. Department of Transportation

Federal Aviation Administration

800 Independence Ave., S.W.

Washington, D.C. 20591

Re: Petition of PureVision, for an Exemption Pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform

Act") and 14 C.F.R. Part 11, PureVision hereby applies for an exemption (the “Petition”) from

the Federal Aviation Regulations identified below, to allow commercial operation of Unmanned

Aircraft System (i.e., "UAS") for conducting aerial video and photography, inspection and

surveys of construction sites, real property, including structures and facilities as part of exterior

building evaluations, special events and film sets.

This petition is made based on information outlined in this Petition, as well as the

accompanying PureVision UAS Flight Operation Manual (hereinafter "PureVision Flight

Operation Manual"), Phantom Pilot Training Guide, Phantom 3 Quick Start Guide, Inspire 1

User Manual v1.0, Inspire 1 Safety Guidelines, 1345 Propeller Locks Quick Start Guide,

Intelligent Flight Battery Safety Guidelines v1.4 (collectively referred to as "Manufacturer

Manuals"). A copy of the PureVision Flight Operation Manual and other supporting materials

are also attached hereto.

Sincerely,

Clayton T. Tanaka

PureVision
TABLE OF CONTENTS

1. Glossary of Abbreviations

2. Description of Petitioner

3. Description of Proposed Operations

A. Forensic Evaluation and Building Condition Assessments

B. Vehicular Accident Investigations

4. Relevant Statutory Authority

5. PureVision’s Proposed UAS Operations Meet the Requirements of Section 333 of the

Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational

Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the

Operations Manual

6. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.20

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

C. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

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

§ 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

E. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification

Requirements

F. 14 C.F.R. § 91.103: Preflight Action

G. 14 C.F.R. § 91.119: Minimum Safe Altitudes

H. 14 C.F.R. § 91.121: Altimeter Settings

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

J. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b):

Maintenance Inspections

K. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges

and Limitations

7. Privacy

8. Public Interest

9. Conclusion
1. GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

2. DESCRIPTION OF PETITIONER.

PureVision is a consulting firm with significant experience and expertise in real

property marketing and inspections, construction management, forensic investigations,

litigation support, civil engineering, environmental inspections, surveys and 3D mapping,

and aerial event filming and photography. PureVision provides its clients with the highest

quality digital content for use in its consulting activities.
3. DESCRIPTION OF PROPOSED OPERATIONS.

PureVision is seeking exemption pursuant to Section 333 of the Reform Act to use

small UAS’s weighing less than 6.7 pounds for conducting aerial inspections and surveys

during its forensic evaluations and building condition assessments. All UAS operations

will occur under controlled conditions. The proposed UAS operations will be conducted in

accordance with the conditions and limitations of this Petition for Exemption and

PureVision’s Flight Operation Manual. As detailed in the PureVision Flight Operation

Manual, the proposed UAS operations will be limited to daytime VFR conditions in

uncontrolled airspace, and will occur at least 5 miles away from an airport as detailed in

the Manufacturer’s Manuals. In addition, PureVision’s Flight Operation Manual

incorporates redundant safeguards to assure that the aircraft does not travel outside the

controlled area of UAS operations, including, but not limited to, GPS geo-fencing

technologies. The geo-fencing technology will be used to restrict which geographic

locations UAS operates within. All PureVision UAS operation will utilize geo-fencing

technology to set UAS limits of travel to a controlled area encompassing the building,

facility, vehicular accident site, or forensic evaluation location that is under assessment.

PureVision will utilize the following UAS’s for conducting aerial inspections and

surveys during its forensic evaluations and building condition assessments (for

compensation or hire within NAS):

 DJI Phantom 3. The DJI Phantom 3 is comprised of a vertical takeoff and

landing (VTOL) Unmanned Aircraft (UA) and a transportable Ground

Control Station (GCS). The DJI Phantom 3 UA has a maximum gross weight

of approximately 2.8 pounds, while having a diagonal distance (motor to

motor) of approximately 24 inches, and maximum speed of 35 mph

(approximately 31 knots). The DJI Phantom 3 is equipped with four

propellers, each being driven by a Lithium Polymer battery powered electric

motor.

 DJI Inspire 1. The DJI Inspire 1 UAS is comprised of a vertical takeoff and

landing (VTOL) Unmanned Aircraft (UA) and a transportable Ground

Control Station (GCS). The DJI Inspire 1 UA has a maximum gross weight

of approximately 6.7 pounds, while having a diameter of 23 inches, and

maximum speed of 49 mph (approximately 42 knots). The DJI Inspire 1 UA

is equipped with four propellers, each being driven by a Lithium Polymer

battery powered electric motor.

A. Forensic Evaluation and Building Condition Assessments.

PureVision performs hundreds of forensic evaluations and various building

condition assessments every year. These evaluations include both distant and close

observation and photographic documentation. Close proximity inspections of building

elements include review and documentation of exterior roof coverings, exterior claddings,

windows, doors, exterior balconies, safety railing, etc. While most of the building

elements are easily accessible by ladder, some elements require the use of aerial work
platforms and various types of scaffolding. However, some building elements such as tall

roofs are at such a height, that conventional ladders cannot reach them, and the use of

other inspection methods may not be feasible due to site conditions and project logistics.

UAS assisted photography will aid in documenting the observable conditions of these

building components that are not accessible by any other safe or practical means. While

the use of ladders, aerial work platforms and suspended scaffolding are appropriate in

some cases, depending on inspection conditions, these methods may expose both the

inspecting engineers and the general public to unnecessary risk of harm or serious injury,

making their use impractical or impossible. UAS-assisted photography provides a safe and

effective alternative means for performing forensic evaluations and various building

condition assessments, while also minimizing the risk of harm to inspectors and the

general public. GPS "geo-fencing" technologies may be used to set UAS limits of travel to

a controlled area encompassing the building or facility that is under evaluation.

B. Vehicular Accident Investigations.

PureVision periodically evaluates vehicular accidents to determine causation

through state-of-the-art data collection, three-dimensional computer simulation, and

analysis software tools. PureVision analyzes single and multiple-vehicle accidents of all

types and investigates the roles of human, vehicle and environmental factors in such

accidents. Accident reconstruction engineers perform thorough analyses to develop a

reconstruction of the accident that is consistent with physical evidence. Our analytical

procedure consists of a series of systematic steps that includes reviewing documents,

identifying technical issues, documenting the accident site, and conducting vehicle and

component inspections. The site evaluations commonly involve examination of the

affected vehicle(s), as well as documenting conditions at the site where the accident

occurred. Site evaluations may require close examination to identify details such as skid

marks, grade variations, and roadway defects. Overall observation and distant

photographic documentation are necessary to assess the site conditions of the accident

location, but often cannot be feasibly obtained using traditional fixed-wing or rotorcraft

aircraft. Aerial images provided by UAS technology would aid in the analysis of vehicle

pathways, traffic behavior at intersections, and visualizing the general area of the

accident. Knowledge gained from vehicle accident investigations is used by the

transportation industry to improve public safety. When necessary, local law enforcement

shall be used to establish a secure zone around a traffic intersection to allow safe and

efficient UAS operation. GPS "geo-fencing" technologies may be used to set UAS limits

of travel to a controlled area encompassing the accident site.

4. RELEVANT STATUTORY AUTHORITY.

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of

the Reform Act. Congress has directed the FAA "to safely accelerate the integration of

civil unmanned aircraft systems into the national airspace system." Pursuant to Section

333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to

operate in the National Air Space ("NAS") where it is safe to do so based on the following

considerations:
 The UAS size, weight, speed, and operation capability;

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

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

In addition, the FAA Administrator has general authority to grant exemptions from

the agency's safety regulations and minimum standards when the Administrator decides a

requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the

authority of the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from §§

44701(a), (b) and §§ 44702 – 44716, et seq.). A party requesting an exemption must

explain the reasons why the exemption, (1) would benefit the public as a whole, and

(2) would not adversely affect safety (or how it would provide a level of safety at least equal to the

existing rules). See 14 C.F.R. § 11.81 (petitions for exemption).

5. PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF

SECTION 333.

The small UAS operations proposed by PureVision in this Petition for Exemption qualify

for expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria

and relevant factors are satisfied.

 Approval is Warranted Based on the UAS's Size, Weight, Speed, and

Operational Capability

PureVision will employ the DJI Phantom 3 quadcopter for the operations specified in this

Petition for Exemption. This is the same UAS model approved for use in the FAA's Grant of

Exemption to Douglas Trudeau, Docket No. FAA-2014-0481. This UAS has a maximum takeoff

weight of less than 3 pounds. The flight speed will not exceed 30 knots, and it will not be flown

in controlled airspace or at an altitude that exceeds 400 feet AGL without prior written

authorization and approval from the FAA. All flights will be flown in such a way that they can

be safely terminated once the operator receives the first low battery warning (approximately 30%

of the battery's maximum charge). The DJI Phantom 3 does not carry any flammable propellant

or fuel. The UAS also has an integrated GPS system that calculates the UAS's position and

height and relays that information via a secure connection to the operator. Additionally, as

acknowledged by the FAA in its prior grant of exemption to Douglas Trudeau, the DJI

Phantom "Has the capability to operate safely after experiencing certain in-flight contingencies

or failures and uses an auto-pilot system to maintain UAS stability and control. The UAS is also

able to respond to a loss of GPS or a lost- link event with pre-coordinated automated flight

maneuvers."

 Approval is Warranted Based on the Operational Restrictions Set Forth in the

Flight Operations Manual

The PureVision Flight Operations Manual and the Manufacturer's Manuals for the

selected UAS will contain all the procedures and limitations necessary to safely and successfully

perform the operations specified in this Petition for Exemption. To assist the FAA in making a

safety assessment of PureVision’s proposed operations, below is a summary of operational

limitations and conditions that will ensure an equivalent or higher level of safety to operations

conducted under current regulatory guidelines:
1. The DJI Phantom 3 weighs less than 3 pounds, fully loaded.

2. The DJI Inspire 1 weights less than 7 pounds, fully loaded.

3. The radio frequencies used for operations and control of the UAS (2.4GHz) will

comply with the Federal Communications Commission ("FCC") or other

appropriate government oversight agency requirements.

4. Minimum crew for each operation will consist of a pilot, who will be Pilot-in

Command ("PIC") of the UAS, and one or more Visual Observers ("Observer") as

necessary to safely conduct the mission.

5. The UAS shall be operated within Visual Line of Sight ("VLOS") of the PIC and

Observer at all times. The PIC will use human vision unaided by any device other

than corrective lenses.

6. The UAS shall be operated during daylight only. Operations shall occur during

daytime VFR Meteorological Conditions; flights under special visual flight rules

("SVFR") shall not be conducted. UAS operations under Instrument Flight Rules,

at night, or beyond VLOS are prohibited.

7. The Observer designated for any operation will be in constant voice contact with

the PIC.

8. The additional requirements identified in the exemption grant shall be added to

PureVision’s Flight Operations Manual. The Flight Operations Manual will be

maintained and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations in the granted

exemptions and the PureVision Flight Operations Manual, the conditions and

limitations in the granted exemptions will incorporated into the Flight Operations

Manual.

9. The UAS will be operated and maintained according to the Manufacturer's

Manuals and any required manufacturer Safety/Service Bulletins.

10. All aircraft operated in accordance with this exemption will be identified by serial

number, registered in accordance with 14 C.F.R part 47, and have identification

markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as

large as practicable.

11. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a

condition safe for flight. The PIC shall not operate the UAS if the inspection

reveals a condition that affects the safe operation of the UAS until the necessary

maintenance has been performed and the UAS is found to be in a condition for

safe flight. All maintenance and alternations must be properly documented in the

UAS records.

12. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics must undergo a functional test flight in

accordance with PureVision’s Flight Operations Manuals. The PIC who conducts
the functional test flight must make an entry in the UAS aircraft records of the

flight.

13. Prior to the operation, there will be a Flight Plan setting forth the operational

limitations and conditions for the flight operations, as well as key personnel

contact information and a description of any potential hazards on or in the vicinity

of the survey site.

14. The PIC is prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is enough power to fly at normal cruising speed

to the intended landing point and land the UAV once the low battery warning is

received (approximately 30% of the battery's maximum charge).

15. The UAV shall remain clear and yield the right of way to all other manned

operations and activities at all times (including, but not limited to, ultralight

vehicles, parachute activities, parasailing activities, hang gliders, etc.).

16. The UAS will not be operated by the PIC from any moving device or vehicle.

17. Flights will be operated at an altitude of no more than 400 feet AGL and will

never enter navigable controlled airspace.

18. Flights will be operated at a lateral distance of at least 200 feet from any

nonparticipating persons, unless that person is in a position where he or she is

shielded from the UAS and any possible debris resulting from UAS failure.

19. At no time will the UAS be operated so close to persons or objects to present an

undue hazard to the PIC or Observer, pursuant to § 91.119(a).

20. UAS operations will occur at least 200 feet away from non-participating vehicles

or structures unless the property owner/controller has granted permission, and the

PIC has made a safety assessment of the risk of operating closer to those objects.

At no time will the UAS be operated so close to structures or vehicles as to

present an undue hazard to the PIC or Observer, per § 91.119(a).

21. Flights will be limited to a speed of 30 knots and vertical ascent / decent will be

limited to 15 fps.

22. If the UAS loses communication with the PIC, the UAS has the capability to

return to a pre-determined location within the operational area and land safely.

23. Contingency plans will be in place to safely terminate flight if there is a loss of

communication between the PIC and the Observer.

24. The UAS will have the capability to safely abort flight in the case of unpredicted

obstacles or emergencies. The PIC will abort the flight in the event of unpredicted

obstacles or emergencies in accordance with the PureVision’s Flight Operations

Manuals.
6. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED.

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, including UAS’s, from its safety regulations and minimum standards

when the Administrator decides a requested exemption is in the public interest.

PureVision seeks an exemption from several interrelated provisions of Title 14 of the

Code of Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the

requested operations using a UAS. Listed below are the specific sections of 14 C.F.R for which

exemption is sought.

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. §

91.20

The FAA has stated that no exemption is needed from this section if a finding is made

under the Reform Act that the UAS selected provides an equivalent level of safety when

compared to aircraft normally used for the same application. These criteria are met, and therefore

no exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA-20140352

at 13-14, 22. If, however, the FAA determines that there are some characteristics of the chosen

UAS that fail to meet the requirements of the Reform Act, an exemption is requested.

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness

certification of normal category rotorcraft. To the extent that PureVision’s small UAS’s would

otherwise require certification under Part 27, Petitioner seeks an exemption from Part 27's

airworthiness standards for the same reasons identified in the request for exemption from 14

C.F.R. Part 21, Subpart H, supra.

C. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

PureVision seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil

aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is

required for 14 C.F.R. § 91.7(a) to the extent that the requirements of Part 21 are waived or

found inapplicable. See Docket No. FAA-2014-0352 at 13-14, 22. Accordingly, Petitioner

requests that the requirements for § 91.7(a) be treated in accordance with Section V(A), supra.

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

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and

Registration

PureVision seeks exemption from 14 C.F.R. § 91.9(b)(2). Given the small size and

configuration of the UAS, it would be impossible to keep airworthiness documents and other

aircraft manuals on board the UAS because there is simply no room and the UAS has no cabin or

cockpit.
E. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and

Identification Requirements

PureVision seeks an exemption from the aircraft marking and identification requirements

contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements,

provides that: No person may operate a U.S.-registered civil aircraft unless that aircraft is

identified in accordance with Part 45 of this chapter.

14 C.F.R. § 45.23(b), Markings of the Aircraft, states: When marks include only the

Roman capital letter "N" and the registration number is displayed on limited, restricted or lightsport 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.

14 C.F.R. § 45.27(a), Rotorcraft, states: Each operator of a rotorcraft must display on that

rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required

by § 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these

requirements was warranted provided that the aircraft "have identification (N-Number) markings

in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable." FAA

Docket No. FAA-2014-0352.

F. 14 C.F.R. § 91.103: Preflight Action

PureVision seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become

familiar with specific information before each flight, including information contained in the

FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all

information necessary to safely conduct the flight, an exemption is requested to the extent that an

FAA-approved Flight Manual is required.

G. 14 C.F.R. § 91.119: Minimum Safe Altitudes

PureVision seeks an exemption from the minimum safe altitude requirements of 14

C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may

not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or

structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a

helicopter to operate at less than those minimum altitudes when it can be operated "without

hazard to persons or property on the surface," provided that "each person operating the helicopter

complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

An exemption is required because the proposed UAS operations will occur below 400

feet AGL. Additionally, due the nature of the proposed operations, the Pilot and/or Observers(s)

may need to be less than 500 feet away from the UAS.
H. 14 C.F.R. § 91.121: Altimeter Settings

PureVision seeks an exemption from 14 C.F.R. § 91.121, which requires a person

operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that

is set to the elevation of the departure airport or barometric pressure. An exemption is required to

the extent that the UAS’s do not have a barometric altimeter, but rather GPS altitude display.

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

PureVision seeks an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight

in VFR conditions. The technological limitations on UAS battery power means that no

meaningful flight operations can be conducted while still maintaining a 30-minute battery

reserve. An exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

Additional information: Individual PureVision Flight operations will be limited 15 minutes or

less.

J. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b):

Maintenance Inspections

PureVision seeks an exemption from the maintenance inspection requirements contained

in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations

specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14

C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft

inspected as prescribed in subpart E of this part and shall between required inspections ...have

discrepancies repaired as prescribed in part 43 of this chapter"). An exemption from these

regulations is needed because Part 43 and these sections only apply to aircraft with an

airworthiness certificate, which the UAS to be operated under this grant of exemption will not

have.

K. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot

Privileges and Limitations

61.113: subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor

may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC 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.

PureVision seeks exemption from 14 CFR § 61.113, which restricts private pilot

certificate holders from flying aircraft for compensation or hire, and would also require a second

class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any

PIC matches the airspace in which the PIC will be operating, as well as requiring certifications if

the private pilot is carrying passengers or cargo for hire. In this case, while the UAS’s will be
operated as part of a commercial operation, it carries neither passengers nor cargo. In the Grant of

Exemption to Astraeus Aerial17, the FAA determined that the unique characteristics of UAS

operation outside of controlled airspace did not warrant the addition cost and restrictions attendant

with requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical Certificate.

The fulfillment of the additional requirements for a private pilot to become qualified as a

commercial pilot would not lead to any additional safety benefits when UAS operations are

involved. Furthermore, while helpful, a pilot license will not ensure remote control piloting skills.

The risks associated with the operation of small UAS is far less than the risks associated with the

commercial activities outlined in 14 CFR § 61.113 (a) & (b).

7. PRIVACY.

All PureVision UAS operations will be conducted in accordance with applicable federal,

state, or local laws regarding privacy. All operations shall be conducted over private or

controlled-access property with permission from the land/building owner/controller or authorized

representative. Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted. Notification of inspection activities (including UAS

operations) will be delivered via land/building owner/controller or authorized representative a

minimum of 24 hours prior to inspection day/UAS operations.

8. PUBLIC INTEREST.

The public interest will be served by granting PureVision’s Petition for Exemption.

Congress has established a national policy that favors early integration of UAS into the NAS in

controlled, safe working environments such as those proposed in this Petition. Granting this

Petition for Exemption helps fulfill Congress' goal in passing Section 333(a) through (c) of the

Reform Act—the FAA Administrator's assessment of whether certain UAS may operate safely in

the NAS before completion of the statutorily required rulemaking. The proposed UAS operations

in this Petition for Exemption significantly improve safety and reduce risk by alleviating the

public's exposure to danger associated with traditional aerial survey and inspection methods,

namely, full size fixed-wing aircraft and rotorcraft as well as the use of inherently dangerous

equipment use such as scaffolding and aerial work platforms. The UAS’s that PureVision intends

to use weight less than 3 pounds (DJI Phantom 3) and less than 7 pounds (DJI Inspire 1), are

battery powered, and create no emissions. Moreover, in the unlikely event that one of Petitioner's

UAS’s crash, there is no fuel to ignite and explode. Any accident involving Petitioner's

lightweight UAS’s will present significantly less danger to the pilot and other individuals on the

ground than one involving a full size aircraft or significantly larger UAS. Furthermore,

PureVision’s UAS’s will be capable of documenting conditions that may have been otherwise

inaccessible using traditional inspection and survey methods. UAS-assisted photography will

also reduce the risk of harm to inspecting engineers and consultants by not exposing them to

hazards associated with inspection of dangerous or unsafe physical conditions often present in

buildings and structures that have been damaged.

9. SUMMARY AND CONCLUSION.

PureVision seeks exemption from the following rules in Title 14 of the Code of Federal

Regulations: 14 C.F.R. 21, subpart H; 14 C.P.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(b); 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) and (b); 14 C.F.R.

§ 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.P.R. § 91.409 (a)(2); 14 C.P.R. § 91.409 (a)(2);
and, 14 C.P.R. §§ 91.417 (a) & (b) to commercially operate lightweight unmanned UAS during

forensic evaluations and building condition assessments.

Granting PureVision request for exemption will reduce current risk levels and thereby

enhance safety. UAS technologies applied to building inspection services will provide higher

level of efficiency and safer services for our clients. Forensic evaluations and building condition

assessments performed by PureVision often involve the physical inspection of outdoor structures

and facilities for the assessment of current element condition, damage, defects and accidents.

Obtaining images of certain physical features may not be feasible due to dangerous conditions,

limited access on the structure or the excessive height of the required viewing angle.

The use of UAS-assisted photography will provide a practical means to perform forensic

evaluations and building condition assessments that would be otherwise unsafe to the employees

of PureVision and the general public. UAS-assisted photography also offers a safer and more

efficient means to perform forensic evaluations and building condition assessments. The use of

this technology will better serve clients and improve public safety.

PureVision respectfully requests that the FAA grant its exemption request without delay.

The FAA has the authority to issue the exemption sought by PureVision pursuant to the Federal

Aviation Act, 85 P.L. 726 (1958), as amended (the “Act”).

Respectfully submitted,

Clayton T. Tanaka

PureVision

P.O. Box 54211

Irvine, CA 92620

65 Clocktower

Irvine, CA 92620

(949) 415-6704
The following attached items contain proprietary and commercial information exempt from

disclosure under the Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a

separate file pursuant to 14 C.F.R. § 11.35(b).

Attachments:

1. PureVision

a. PureVision Flight Operations Manual (2015-1001)

2. DJI Phantom 3:

a. Phantom 3 User Manual v1.2

b. Phantom 3 Quick Start Guide v.1.0

c. Phantom 3 Intelligent Flight Battery Safety Guidelines v.1.0

d. Phantom 3 Safety Guidelines v1.2

3. DJI Inspire 1:

a. Inspire 1 Quick Start Guide v.1.4

b. Inspire 1 User Manual v.1.4

c. Inspire 1 Safety Guidelines v1.0

d. Intelligent Flight Battery Safety Guidelines v.1.4

e. Inspire 1 1345s Quick-Release Propellers Quick Start Guide

f. Inspire 1 Maintenance Manual v.1.0
PureVision Flight Operations Manual (2015-1001)

1. GENERAL PROTOCOL:

a. Review and consult the UAS manufacturers manuals:

i. 1.1.1. DJI Phantom 3:

1) Phantom 3 User Manual v1.2

2) Phantom 3 Quick Start Guide v.1.0

3) Phantom 3 Intelligent Flight Battery Safety Guidelines v.1.0

4) Phantom 3 Safety Guidelines v1.2

ii. DJI Inspire 1:

1) Inspire 1 Quick Start Guide v.1.4

2) Inspire 1 User Manual v.1.4

3) Inspire 1 Safety Guidelines v1.0

4) Intelligent Flight Battery Safety Guidelines v.1.4

5) Inspire 1 1345s Quick-Release Propellers Quick Start Guide

6) Inspire 1 Maintenance Manual v.1.0

b. Minimum crew for each operation shall consist of a pilot, who will be Pilotin Command ("PIC") of the UAS, and one or more Visual Observers ("VO")

as necessary to safely conduct the mission.

c. The UAS shall be operated within Visual Line of Sight ("VLOS") of the PIC

and VO at all times. The PIC will use human vision unaided by any device

other than corrective lenses.

d. The UAS shall be operated during daylight only. Operations shall occur

during daytime VFR Meteorological Conditions; flights under special visual

flight rules ("SVFR") shall not be conducted. UAS operations under

Instrument Flight Rules, at night, or beyond VLOS are prohibited

e. The Observer designated for any operation will be in constant voice contact

with the PIC

f. Prior to operation, PIC and VO are to prepare a Flight Plan setting forth the

operational limitations and conditions for the flight operations and a

description of any potential hazards on or in the vicinity of the survey site
g. The PIC is prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is enough power to fly at normal cruising

speed to the intended landing point and land the UAV once the low battery

warning is received (approximately 30% of the battery's maximum charge)

h. The UAV shall remain clear and yield the right of way to all other manned

operations and activities at all times (including, but not limited to, ultralight

vehicles, parachute activities, parasailing activities, hang gliders, etc.)

i. The UAS shall not be operated by the PIC from any moving device or

vehicle

j. Flights will be operated at an altitude of no more than 400 feet AGL and

will never enter navigable controlled airspace

k. Flights will be operated at a lateral distance of at least 200 feet from any

nonparticipating persons, unless that person is in a position where he or she

is shielded from the UAS and any possible debris resulting from UAS

failure

l. Warning signage shall be placed within 150 feet of UAV operations.

m. At no time shall the UAS be operated so close to persons or objects to

present an undue hazard to the PIC or Observer

n. UAS operations shall occur at least 200 feet away from non-participating vehicles

or structures unless the property owner/controller has granted permission, and the

PIC has made a safety assessment of the risk of operating closer to those objects.

At no time shall the UAS be operated so close to structures or vehicles as to

present an undue hazard to the PIC or Observer

o. Flights shall be limited to a speed of 30 knots and vertical ascent / decent will be

limited to 15 fps

p. Contingency plan must be in place to safely terminate flight if there is a loss of

communication between the PIC and the Observer

q. The PIC shall abort flight in the case of unpredicted obstacles or emergencies.

Refer to section four below
2. PRE-FLIGHT PROTOCOL:

a. Review local weather forecast

b. Inspect surroundings

i. Visually review the flight location and surroundings

ii. Identify potential risks and challenges

1) Vicinity of public safety helipads/heliports

2) Vicinity of medical helipads/heliports

3) Vicinity of airport(s)

4) Vicinity of light poles

5) Vicinity of utility poles/towers/lines

6) Vicinity of trees

7) Vicinity of elevated obstructions

8) Vicinity of roadways with moderate to heavy traffic

9) Flocks of birds that may cause interference and potentially impact

flight

10) Public gatherings that may attract viewer

11) Identify optimal point of control to maintain direct line of sight at

all times

12) Identify optimal point of home position and launch/land location

iii. Place warning signage in appropriate locations

1) Place sign(s) that warn potential observes or bystanders in public

spaces

2) Warning signs should state the following

“WARNING! AERIAL PHOTOGRAPHY IN PROGRESS.

FOR YOUR SAFETY PLEASE REMAIN 150 FEET BACK”

iv. Inspect UAS:

1) Verify that all batteries are in proper working condition

a) Visually inspect batteries for swelling, damage, or leakage

b) Verify that all batteries are fully charged

2) Verify that the UAV is in proper working condition

a) Visually inspect the propellers for warps, chips, and cracks

b) Visually inspect the UAV arms and body for

damage/loose connections
3. FLIGHT PROTOCOL:

a. Install propellers and propeller locks (if applicable)

b. Install battery

c. Power on radio then power on UAV

d. Set geo-fence that limits UAV flight path to the inspection location only

e. Visually inspect immediate and adjacent surroundings

f. Lift UAV approximately 4 feet off of ground and allow to hover in place

g. Verify that all system inputs are responding normally

h. Maneuver UAV in a slow controlled manner at all times

i. Restrict flight altitude to a minimum elevation sufficient to acquire data

j. Remain alert to surroundings including the following:

k. Approaching people and vehicles.

i. VO shall deflect all distraction from PIC

ii. Birds

iii. Manned aircraft

iv. Changes in wind speed and direction

v. Location of the sun

vi. Changes in cloud coverage

vii. Land UAV in same location as take off

4. UNPREDICTED OBSTACLES OR EMERGENCIES

a. If at any time the PIC or VO observes or encounters an unpredicted obstacle, the

PIC shall immediately land the UAV in a safe location

b. The PIC may increase or decrease altitude based on the location of the

unpredicted obstacle to avoid the obstacle
c. If an unpredicted obstacle is identified during normal flight, the PIC shall return

the UAV to its home position to further identify the challenge and create a new

flight plan 4.4. If the UAV begins to act in an unpredictable manner then the PIC

shall land the UAV immediately

5. POST-FLIGHT PROTOCOL

a. Shut down UAS

b. Remove propellers

c. Allow all batteries and UAV to cool down

d. Place batteries, transmitter(s), propellers, and accessories into carrying case

e. Log flight time and any conditions that changed during flight

f. Charge batteries pursuant to manufacturers recommendations

g. Ensure that all systems have the most current version of firmware/software

installed

6. FLIGHT LOGS:

a. The PIC must maintain flight and maintenance logs using the forms below:
PureVision Flight Operations Flight Log (2015-1001)

Pilot in Charge:

Visual Observer:

Date:

Project Name:

Project Number:

Location:

Weather Conditions:

UAS:

Flight Plan:

Challenges:

Flight Notes:

Pre-Flight Checklist: Inspect surroundings 

Note flight plan 

Inspect/tighten all connections 

Review flight plan 

Place warning signage 

Set geo-fence (if applicable) 

Test control inputs 
PureVision Flight Operations Flight Log (2015-1001)

Maintenance Performed by:

UAS: DJI Inspire 1 Identification Number

Date:

Checklist: Inspect UAS 

Inspect camera 

Inspect batteries 

Inspect cables 

Inspect charger 

Tighten all connections 

Inspect propellers 

Update software 

Update firmware 

Calibrate IMU 

Calibrate compass 

Test control inputs 

Charge batteries 

Additional Notes:
PureVision Flight Operations Flight Log (2015-1001)

Maintenance Performed by:

UAS: DJI Phantom 3 Identification Number

Date:

Checklist: Inspect UAS 

Inspect camera 

Inspect batteries 

Inspect cables 

Inspect charger 

Tighten all connections 

Inspect propellers 

Update software 

Update firmware 

Calibrate IMU 

Calibrate compass 

Test control inputs 

Charge batteries 

Additional Notes: