Vantage Imaging Solutions, LLC

10021 Paseo Montril San Diego, CA 92129 February 17, 2016

Docket Operations, M-30 U.S. Department of Transportation (DOT) 1200 New Jersey Avenue, SE. Room W12-140 West Building Ground Floor Washington, DC 20590-0001

Re: Exemption Request Pursuant to Sect ion 333 of the FAA Modernization and Reform Act of 2012, 49 U.S.C. § 44701(f), and Pa rt 11 of the Federal Aviation Regulations

Dear Administrators,

Section 333, titled "Special Rules for Cert ain Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA authorizati on of safe civil UAS operations in the NAS. Section 333(a) states that the FAA "shall dete rmine if certain unmanned aircraft systems may operate safely in the national airspace system be fore completion of the (comprehensive) plan and rulemaking required by section 332( b)(1) of this Act or the guidance requi red by section 334 of this Act." In Section 332(b)(1), The Petitione r "Vantage Imaging Solutions, LLC", hereafter referred to as VIS, proposes the following exemp tions and meets all requirements to permit FAA approval of commercial UAS operations. The propos ed exemption, if granted, would allow the petitioner to conduct commercial operations of small unmanned aircraft systems ("sUAS") meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333 and covered by FAR Parts 61 and 91.

The following are examples of FAA issued grants of exemption in circumstances similar in all material respects to this petition. They are representative in natu re, and not comprehensive of all grants of exemption for aerial operations similar to those requested by VIS:

Nos. 11062 to Astraeus Aerial ( see Docket No. FAA

− 2014

− 0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No.

FAA

− 2014

− 0382), 11213 to Aeryon Labs, Inc. ( see Docket No. FAA

− 2014

− 0642), and 12645 to Allied Drones ( see Docket No. FAA-2014-0804), and Drone 6 LLC (see Docket No. FAA– 2015–5435).February 17, 2016 Page 2 of 10

Table of Contents

I. Terms of Reference ...........................................................................................3

II. Introduction and Interests of Petitioner ...............................................................3

III. Name and Address of Petitioner ......................................................................4

IV. Exemptions Requested ............................................................................................4

V. The Extent and Rationale for Relief Requested ..................................................................4

VI. Public Interest .............................................................................................7

VII. Safety and Operations ..................................................................................8

VIII. Summary ................................................................................................................10

IX. List of Attachments .....................................................................................10

Glossary of Terms and Acronyms

ATP Airline Transport Pilot

COA Certificate of Waiver or Authorization GPS Global Positioning System NAS National Airspace System

PIC Pilot In Command POH Pilot Operating Handbook, a.k.a. user manual

sUAS Small Unmanned Aerial Systems, a. k.a. UAS, ‘drones’ or UAV’s

UAV Unmanned Aerial Vehicles VFR Visual Flight Rules VIS Vantage Imaging Solutions, LLC, a.k.a ‘the petitioner’ VLOS Visual Line Of Sight

VO Visual ObserverFebruary 17, 2016 Page 3 of 10

I. Terms of Reference

Per FAA guidance for Petitions for Section 333 exemptions, the following terms are adopted in this petition:

a. Aircraft: any contrivance inve nted, used, or designed to na vigate, or fly in, the air (Title 49, United States Code (49 USC) § 40102)

b. National Airspace System (NAS): the common network of U.S. airspace; air navigation facilities, equipment and servic es, airports or landi ng areas; aeronautical charts, information and services; rules, regulations and procedures, technical information, and manpower and material

c. Operational Control: with respect to a fli ght, means the exercise of authority over initiating, conducting or terminating a flight (14 CFR § 1.1)

d. Pilot in Command (PIC): the person who has fi nal authority and responsibility for the operation and safety of the flight; has been designated as PIC be fore or during the flight; and holds the appropria te category class and type-ra ting, if appropriate, for the conduct of the flight (14 CFR § 1.1)

e. Unmanned aircraft (UA): any airc raft that is operated without the possibility of direct

human intervention from within or on the aircraft (P.L. 112-95, Section 331)

f. Unmanned Aircraft System (UAS): an unma nned aircraft and associated elements, including communication links and the components that control the unmanned aircraft, that are required for the pilot in command to operate safely and efficiently in the national airspace system (P.L. 112-95, Section 331)

g. UAS Certificate of Waiver or Authoriza tion (COA): an authoriz ation issued by the Air Traffic Organization to an operator fo r a specific unmanned aircraft activity

h. Visual Line of Sight (VLOS): unaided (cor rective lenses and/or sunglasses excepted) visual contact between a pilot in comma nd and an unmanned aircraft sufficient to maintain safe operational contro l of the aircraft, k now its location, and be able to scan the airspace in which it is operating to se e and avoid other air tr affic or objects aloft or on the ground

II. Introduction and Interests of Petitioner

The Petitioner, VIS is a professi onal consulting firm that specializ es in surveying, construction analysis, and civil engineering services. Additionally, VIS also provides services to unique industries and projects that pert ain to the scope of services lis ted below. VIS plans to use the unique capabilities of Unmanned Aerial Systems to mo re safely and efficien tly offer a variety of services, including:

o Aerial Data Collection

o Mapping and survey operations

o Construction inspections and monitoring

o Volumetric surveying

o Historical and Ar chaeology services

o Agricultural monitoring

o Landscaping servicesFebruary 17, 2016 Page 4 of 10

o Structural 3D modeling services

o Wildlife and forestry monitoring

o Scientific and Envi ronmental studies

o Natural disaster services

o Advertisement services

o Crime scene investigative services

o Real estate photography and videography

o Cinematic Services

A large portion of our work depends on topog raphic data and analys is. Current topographic surveys are performed by small manned aircraft using aerial photogramme try, which is costly and can have lead times of up to several mont hs. Using a small, unma nned aircraft system (sUAS), VIS would be able to quickly, safely and affordably provide our clients with the topography and analysis of their projects. By granting this reque st, flights consisting of small manned aircraft would be replaced by sUAS, resultin g in less intrusive air traffic and would have a minimal impact on the NAS and environment comp ared to the aircraft currently used for similar services. The increased safety of professionally flown UAS’s with multiple imbedded safety features is significant.

III. Name and Address of Petitioner Vantage Imaging Solutions, LLC

10021 Paseo Montril San Diego, CA 92129 Point of Contact: Werner Pieters, P.E.

Email: wpieters@vantageis.com

IV. Exemptions Requested

The specific section or sections of 14 CFR from which exemption is sought:

 14 CFR 21 Subpart H

 14 CFR 36

 14 CFR 45.23 / 29

 14 CFR 61.23 (2) (ii)

 14 CFR 61.113

 14 CFR 91.9

 14 CFR 91.103

 14 CFR 91.119

 14CFR91.151

 14 CFR 91.203

 14 CFR 91.405, 91.407, 91.409, 91.417

V. The Extent and Rationale for Relief Requested

The extent of relief sought is for the duration of the Grant of Exemption, unless otherwise specified. A Section 333 Grant of Exemption provides a blanket COA with the following stipulations:February 17, 2016 Page 5 of 10

FAA will grant a Certificat e of Waiver or Authorization (COA) for flights at or below 200 feet to any UAS operator with a Section 333 exempti on for aircraft that weigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) c onditions, operate within visual line of sight (VLOS) of the pilots, and st ay certain distances away fr om airports or heliports:

o 5 nautical miles (NM) from an airport having an operational control tower; or

o 3 NM from an airport with a published in strument flight pro cedure, but not an operational tower; or

o 2 NM from an airport without a publishe d instrument flight procedure or an operational tower; or

o 2 NM from a heliport with a publis hed instrument flight procedure.

The specific rationale for relief fr om specific CFR’s is as follows:

 14 CFR 21 Subpart H a. The petitioner requests relief from 14 CFR Part 21. The UAV is a small quadcopter

less than 20 inches in diameter a nd weighing less than 10 pounds. The UAV maximum speed is 40 mph (35knots). b. The aircraft will not carry persons or pr operty, will not carry fuel, and will only fly under strict operational require ments. Combined with the UAS's light weight, being constructed primarily of carbon fiber and plastic. We propose that the UAS will be certainly at least as safe, if not safer, than a conventionally certificated aircraft, including helicopters, perf orming the same mission.

 14 CFR 36 a. The Petitioner requests reli ef from any associated no ise certification and testing requirements of part 36. As a note, accordi ng to the manufacturer's specifications, the UAV operates below 40db within 50 meters.

 14 CFR 45.23 / 29 a. The Petitioner request relief from the size and placing requirements for registration markings under this section due to the size limitations of the UAV. We propose to use marks as large as practicable on the UAV, as well as maintaining pertinent registration information with the PIC during flight operations. Additionally, a digital copy of all UAV registration information will be available from VIS upon request.

 14 CFR 61.23 a. The Petitioner requests relief from this section because the PIC and the VO will be operating the UAV with no passengers and no pa yload on board and therefore should

not be held to the same medical standard as a commercial pilot.

 14CFR61.3(a)(1) / (c) a. The Chief Pilot for VIS is a current commercially licensed pilot with ATP privileges. All future pilots with VIS will be current, rated pilots with at least a Sport

Pilot license.February 17, 2016 Page 6 of 10

b. A current medical certificate commensurate with all pilot’s rating will be required for all flight operations.

 14CFR91.9 a. Relevant materials, including any flight manuals, certificates a nd placards, shall be kept in a location immediately accessible to the PIC during all commercial flight operations in compliance with the regula tions. A digital copy of all necessary materials shall be maintained by VIS.

 14 CFR 91.103 (b) a. The pilot in command shall, before be ginning a flight, become familiar with all

available information concerning any flight. b. The VIS UAS does not use runways, so 91.103(b) does not apply. c. The petitioner expects all fu ture commercial flight operations to be within Class G airspace, below 400 AGL at all times. If th ere is a requirement to fly in any other than G airspace, specific COA’s, letters of agreement and any other required permissions and documentation to perform su ch flight operations will be obtained prior to such operations. In regards to 91.103(b), the UAV w ill not be operated within any Class B, C, or D airspace. The UAS’s will be used for business purposes in Class G airspace (unless otherwise described by an ATO-issued COA). The PIC will follow all other applicable pre-flight actions in cluding reviewing weather, flight battery status, landings, and takeoff clearances and ai rcraft performance data before initiation of any flight. d. The PIC will use the FAA B4UFly mobile app to assist in verifying airspace

concerns are satisfied.

 4CFR91.105

UAS’s have no crew station or restraint systems, so this rule does not apply.

 14CFR91.109 The Petitioner will operate only unmanned UAS’s and will not be providing any flight instruction.

 14CFR91.119(c) a. The Petitioner will not be flying above 400ft AGL, and thus requests relief from

this section.

 14C 91.121 a. The Petitioner requests relief from this section because the UAS uses GPS for

altitude control instead of an altimeter. A dditionally, its operation will be in a highly controlled airspace that will be deconflicted fr om any other aircraft. All flights will

be below 400ft AGL.

 14CFR91.151 a. The Petitioner requests exemption from this section due to the maximum flight time available from this battery powered, unfueled UAS. The UAS total flight time isFebruary 17, 2016 Page 7 of 10

limited to 20 minutes per battery and therefor e the PIC would not be able to meet the minimum flight reserve standards and s till conduct flight operations. The UAS is equipped with a visual battery level indica tor for the aircraft and controller that provide the pilot real time battery state. b. Additionally, the UAV has a visual and aura l alarm that indicates when the battery reaches a state of 30 and 20 percent battery lif e. These indicators, coupled with pilot awareness and the emergency return to hom e point settings, provide ample time to land the aircraft safely whenever the batter y level is low. At 20 percent, the UAS automatically aborts and return s to the designa ted home point.

 14CFR91.203 a. The Petitioner requests relief from this section as the appr opriate airworthiness

certificate does not exist for this UAS. Additionally, the certificate cannot be displayed in the aircraft due to the size and physical structure of the UAV.

 14 CFR 91.405,407, 409, 417a. The Petitioner requests relief from 14 CFR 91.405, 407, 409, and 417 The abovecited regulations require, in general, airc raft owners and opera tors to inspect the aircraft " ... 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." These regulations apply to aircraft with an Airworthiness Certificate. Therefore, these sections are not applicable to this UAS. Operators will adhere to requirements located with in the operations manual and the checklists and procedures commensurate with safe aviation practices.

VI. Public Interest

The reasons why granting this re quest would be in the public interest; that is, how it would benefit the public as a whole:

o Personal Safety The use of UAS technology provide personnel with alternative methods to collect data and travel in high risk areas. W ith the help of UAS more complete site inspections can be performed while minimizi ng the risk to the life and safety of employees.

o Improve Project Accessibility

UAS’s will increase safe access to remote or impassable area projects that are not practical for aerial data colle ction by conventional means.

o Cost Effectiveness The UAS will be used in a variety of app lications that generally require expensive full-size manned aircraft to complete. Sma ll, light, unmanned aerial vehicles offer many benefits over the use of full-sized manned aircraft for construction and surveying operations, archaeology servic es, agricultural mon itoring, wildlife and forestry services, and natural disaster support services, among others mentioned within the scope. UAS inspections for selected projects are more time efficient, safer and more practical than the conventiona l methods for conducting these inspections.February 17, 2016 Page 8 of 10

The reduction in overhead cost afforded by UAS operations will lead to end-user savings and more economica lly feasible projects.

o Innovative Project Analysis The UAS technology is creating a modern appro ach to project analysis as a result of improved accessibility, cost effectiveness and personnel safety. Innovative project analysis will help improve research and development systems and in turn provide better products and serv ices to the public.

o Environmental Impact Our all-electric UAS’s produce no air pollu tion, and are the most environmentally friendly alternative to the curr ent use of a manned aircraft.

VII. Safety and Operations

Granting an exemption would not adversely affect safety for the following reasons:

a. The petitioner states that the unmanned aircra ft (UA) to be operated under this request is less than 10 lbs. fully loade d, flies at a speed of no more than 40 mph (35 knots), carries neither a pilot nor passenger, carries no explos ive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the POH. The aircraft is the Inspire 1 Pro, manufactured by DJI. The aircraft itself, it s fully gimbaled and stabilized video camera, and sophisticated control systems include a GPS navigation and reference system, full autonomous and programmable autopilot capabili ties, telemetry recording and data logging and robust manual and automatic safety features . In addition, the DJI Inspire 1 Pro aircraft has integrated safety features built into the de sign of the UAV, as described in the POH, to ensure the safety of persons and property w ithin and surrounding the limited operating area.

In the event of an aircraft and controller communication loss, the UAS switches to GPS

control and returns to its takeoff coordinates at a pre-set safe altitude to perform a "Fail Safe Landing" within the Security Perimeter. The sa fe return altitude is set for each mission during the mission planning phase. At any time a mission abort is required or desired, the pilot has a single Return To Home (RTH) but ton located within i mmediate reach on the controller. When pushed, the aircraft will imme diately stop, climb or descend to the safe return altitude, and then return to the designate d return point. Pilot intervention / override is always available in any mode of flight. Due to the short range of flights that must remain within visual line of sight by the pilot and VO, even 10 percent battery life provides a safe margin for return at any point in a mission. VIS standard procedures call for return to landing at no lower than 30 percent battery life. Another key safety attribute is that this UAV

will enter a GPS stabilized hover whenever the pilot releases the controls while flying. b. Petitioner has reviewed Section 333 requirements and exemptions that have been granted, and has incorporated those operating standard s into its proposed flight operations. For instance, there is a commercia lly rated PIC, a VO with continuous voice communications with the PIC, no flights beyond VLOS, no speeds above 40kts, no altitu de greater than 400ft AGL, return to home at 30 percent battery life and rigorous pre-flight planning and UAS preflight prior to operations. c. Petitioner's UAS's will be identified by se rial numbers, which will be as large as practicable.February 17, 2016 Page 9 of 10

d. Operational Requirements for UAS flight operations: All commercial flights by VIS will be executed according to a preflight plan th at includes full mission planning, appropriate notification of any private or commercial property owners / managers, required notification or letters of agreement / COA’s pertinent to ai rspace or property concerns, such as proximity to an airport, and pre-flight inspection of the aircraft and its systems. Flight data will be logged, and post-flight inspections performed afte r each flight. Operatio ns will be conducted in Class G airspace. If in remote or inacces sible regions that are privately owned, the permission of the land owner or manager and all required permits will be obtained before flight operations. The UAV will not be operated within 500 feet of occupied vehicles or structures in open areas unless ba rriers or structures are presen t that can sufficiently protect non-participating persons from the UAS or debris in the event of an accident. e. The aircraft will not be operated over urban or populated areas. Before each flight the PIC will perform a series of pref light and takeoff checks as defined by the POH supplied. After each 60 minutes of airtime, the craft will undergo a maintenance checkup. Thorough inspection of all aircraft component s, including, but not limited to:

1. Basic structural integrity

2. Motors, wiring and connectors

3. Propellers, smooth, no chips

4. Electronic speed controller, wiring and conn ectors e. batteries, wiring and connectors

5. Remote command and control

6. Ground control station

7. Camera mount and gimbal assembly

UAS Operating Parameters:

Besides operating constraints already noted, the petitioner’s UAS will remain clear and yield the right of way to all manned operations and any other users of the NAS, which may include but are not limited to; fixed wing, helicopters, ultralight vehicles, parachute activities, parasailing activities, and hangliders. Pet itioner will not conduct UAS operations within 5 nautical miles of the geographic center of a non-towered airport with an operating control tower unless a letter of agreement with that airport's management is obtained and the operation is conducted in accordance with any required Notice to Airmen ("NOTAM"). The

UAS will remain under 400ft AGL a nd conform to the constraints of the Section 333 COA at

all times.

Pilot in Command (PIC):

The PIC has developed safe techniques and app lications providing for a level of safety at least equivalent to or higher than manned aircraft operations. UAV operations will be conducted in a safe and professional manner with a heavy emphasis on public and personnel safety. Regarding Petitioner's requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will comply with the other applicable procedures and requirements stated in § 91.103(a) and (b). Specifically, the PIC will take all actions in cluding reviewing weather, flight battery requirements and status, aircraft performance da ta, and landing and takeoff constraints beforeFebruary 17, 2016 Page 10 of 10

initiation of a flight. The PIC will also account fo r all relevant site-specific conditions in their preflight procedures.

Radio Frequencies:

Radio frequencies used will be those allotted by the FCC for data transmission and vehicle control in unlicensed frequency bands. All devi ces used will comply with FCC usage and emissions regulations. The POH contains specifics (Appendix A).

VIII. Summary

Pursuant to Section 333 of PL 112-95 co mmonly known as the “FAA Modernization and Reform Act of 2012”, VIS, hereby applies for authorization to conduct commercial small unmanned aerial systems (UAS) operations for the pur poses of surveying, construction analysis, and civil engineering services. A dditionally, VIS also provides se rvices to unique industries and projects they pertain to the scope of serv ices listed for which exemption is sought:

 14 CFR 21 Subpart H

 14 CFR 36

 14 CFR 45.23 / 29

 14 CFR 61.23 (2) (ii)

 14 CFR 61.113

 14 CFR 91.9

 14 CFR 91.103

 14 CFR 91.119

 14CFR91.151

 14 CFR 91.203

 14 CFR 91.405, 91.407, 91.409, 91.417

IX. List of Attachments

Appendix (A): Inspire 1 Pr o User Manual (a.k.a. POH)

Very truly yours,

Vantage Imaging Solutions, LLC

Werner Pieters, P.E.

Co-Founder wpieters@vantageis.com