# HOVER VISIONS 6652 E. 46TH PLACE TULSA, OK 74145 918

- 798

- 2837

U.S. Department of Transportation Docket Management System July 27, 2015 1200 New Jersey Ave. SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam I am submitting this petition on my ow n, on the behalf of my company Hover Visions, of Tulsa, Oklahoma, without advice and/or aid of legal counsel. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Hover Visions, owned and operated by Dale Parrish, a sole proprietor, seeks an exemption from the Federal Aviation Regulations (FAR) listed below , to allow operation of our sUAS commercially in airspace regulated by the Federal Avia tion Administration (FAA) so long as such operations are conducted with in and under the conditions outlined herein or as may be established by the FAA as required by Section333. The requested exemption would permit Hover Visions to pursue its commercial in terests in providing services to companies interested in aerial data that can only be captured by using newly developed sUAS in the following areas:
* Surveying and 3D aerial mapping * Agriculture crop assessment and growth patterns * Construction site mo nitoring and land surveying * Public Utility Infrastructure Inspection * Special events * Aerial photo and video documentation of commercial and residential real estate * Aerial photo and video news gathering

Hover Visions assures all sUAS flights occur in g over private or controlled access property will be pursued with the property owner's consent and knowledge. Hover Visions will also assure thatonly those people with the authority to provide consent will be allow to accompany any PIC and

VO (visual obs erver) during the flight operation; being advised of the safety precautions and rules. The owner of Hover Visions, Dale Parrish, is a Private Pilot with single and multi

- engine land ratings and over 400 hours of flight time logged. I, Dale Parrish, am th e sole owner of the sUA S owned and operated as it relates to this petition. I have 30 years of professional firefighting experience acquiring the knowledge, skills and abilities to perform operations with safety being the most important segment of any of o ur operations. I have expert knowledge of the U.S Department of Homeland Security National Incident Management System. Hover Visions exemption request would permit us to operate lightweight, unmanned (remotely controlled in "line

- of

- sight") sUAS vehicles in tightly controlled and limited airspace. Predetermined, specifically outlined areas of operation in addition to GPS navigation maps which incorporate FAA restricted no fly zones (controlled and restricted airspace), will allow Hover Visions to operate within current safety guidelines and rules. The sUAS operated by Hover Visons is the DJI Inspire 1. The DJI Inspire 1 is equipped with a proprietary camera and gimbal system providing 12 MP images a nd up to 4K video resolution. The DJI Inspire 1 weighs less than 55 pounds, operates at speeds less than 42 mph and is limited to vertical speeds less than 15 mph. The system of the DJI Inspire 1 allows for computer updates to the system firmware and software. Within that system, the operator has the ability to limit height, distance from PIC, designation of emergency landing zones, battery and power monitoring and additional "NO FLY" zones around airports wherein the sUAV will not operate. The unit is equipped with a one button "return to home" feature in t he event of an emergency. Replacement of time sensitive components (props, batteries, etc.) are replaced by the owner and only OEM parts are used. As fully described below, the requested exemption would permit the ope ration of sUAS under conditions in th e National Airspace System that would be 1.) limited, 2.) controlled and 3.) predetermin ed and will provide a level of safety that meets and/or exceeds the safe operations currently followed by conventional aircraft and those who have received a Section 33 3 Exemption. Information data of the applicant is as follows:
Dale Parrish 6652 E. 46th Place Tulsa, OK 74145 918

- 798

- 2837 chiefdparrish@gmail.comRegulations from which an exemption is requested

14 CFR 61.113(a) 14 CFR 91.7(a) 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151(a) 14 CFR Subpart E (91.401

- 91.417)

Exemption Requests and Equivalent Level of Safety Hover Visions requests an exemption from the following regulations as well as any additional regulations found by the FAA to be necessary fo r safe and efficient sUAS flight operations. **14 CFR 61.113(a), Private pilot privileges and limitations: Pilot in command** This regulation states that no person holding 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 of an aircraft

. We believe that a PIC with a private pilot license has sufficient skill and knowledge to complete operations, especial ly after completing a sUAS knowledge and training course. We do not think that a commercial pilot license will significantly improve a PIC’s performance while operating a UAV. Therefore, we ask for an exemption from 14 CFR 61.113(a) in order to operate com mercially with the minimum of a private pilot license. **14 CFR 91.7(a), Civil aircraft airworthiness** As a sUAS will not require and airworthiness certificate, we believe that this regulations is not applicable, therefore, we request exemption from this reg ulation. **14 CFR 91.119(c) Minimum safe altitudes** This regulation states that no person may operate an aircraft below 500 feet above the surface as well as within 500 feet of any person, vessel, vehicle, or structure

. We believe that, because of the natur e of most UAS operations, an exemption is required in order to allow operation closer than 500 feet to vessels, vehicles, or structures as long as permission is granted from the owning/controlling parties and an assessment is made to assure that people and property are safe from undue harm. We also request that operations be allowed over congested areas as long as the operations stay within the following standards:
 Flight operations will remain 500 feet from all nonparticipating persons, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the event of an accident. b. Participating persons are made aware of the dangers of the UAS operation and the safety precautions that have been put into place. c. The aircraft is operated near vessel, vehicles, or structures only where the property owner/controller has granted permission a nd the PIC has made a safety assessment in regard to the close operation to these objects. d. Operations near the PIC or VO do not present an undue hazard to the PIC or VO per 91.119(a).e. All op erations will be conducted over private or controlled

- access property with prior permission from the property owner/controller or authorized representative. **14 CFR 91.121 Altimeter settings** As our UAS does not utilize a standard barometri c altimeter, we request exemption from 91.121 to the extent necessary to comply with applicable conditions and limitations. The altimeter reading for our UAS is calculated by GPS. The accurate and continuous readings that we receive from this GPS system al low us to operate our drone below set minimums at all times. **14 CFR 91.151(a) Fuel requirements for flight in VFR conditions** This regulation states that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fl y to the first point of intended landing and, after that, fly for an additional 30 minutes. This regulation is intended to create a safe flying environment by creating sufficient fuel reserves. Therefore, we do not request an exemption from this regulation but, instead, request that the term “fuel” be changed to “battery power.” We also request that our battery power reserve for our UAS operations be 30%. Our UAS has capabilities that allow the PIC to monitor battery power levels as well as a return to lan d feature that will engage when battery levels reach a critical level, therefore returning the UAS automatically to the point of takeoff. **14 CFR Subpart E (91.401**

**– 91.417)**  Hover Visions requests an exemption from the stringent maintenance regulations th at are designed to increase the safety of the flying environment by ensuring adequate inspections and servicing of aircraft. We are requesting exemption from these regulations because we believe that, due to the simplicity and the ease of repair, general a nd preventive maintenance can be performed by the PIC. The PI C is required to make a thorough preflight inspection before each operation. In the case of a discovery of faulty equipment, most replacement and repair can simply be done on site as long as repa irs are of an airworthy manner. Major repair will still have to be performed by a licensed repair facility which will be logged in the UAS records. We believe that our comprehensive preflight inspection, the simplicity of the UAS itself, the nature of the UAS’s operations, and the fact that no passengers are on board the aircraft make our operations eligible for exemption from CFR Subpart E (91.401

– 91.417). Standard Operational Procedures The applicant shall adhere to operation limitations providing fo r an equivalent or higher level of safety for persons and property as is required for conventional aircraft. The limitations and conditions to which the applicant agrees to adhere when conducting commercial operations under the requested FAA issue of exem ption include: 1. The sUas shall weigh less than 55 pounds. 2. All flights will be performed within line of sight of the PIC and VO (visual observer) 3. Maximum flight time for each operational flight shall be 30 minutes. Flights will be terminated at 30% battery power reserve or 30 minutes time elapse whichever event occurs first. 4. Operational flights shall not exceed an altitude of 400 ft. AGL and not more than 200 feet above an elevated platform from which filming is planned. 5. Min imum crew staffing for each operation shall consist of a designated PIC and a designated VO6. Designated PIC's shall possess or at one time possessed a Private Pilot's license that shall be

officially documented in addition to documented flight hou rs exceeding 100 hours. All PIC's shall possess a current driver's license issued by the State in which the pilot resides. All PIC's shall possess an FAA 3rd Class Medical or shall prove, by legal documentation, they have passed a ye arly physical exam from their primary care physician, that meets or exceeds the requirements of an FAA 3rd Class Medical. 7. Designated VO's (visual observer) shall be 25 years of age or older and shall have 20 or more hours of flying, equipm ent and safety training conducted by a Hover Visions PIC. 8. The PIC and VO will be able to communicate by voice or radio. There shall be no texting or cell phone communications allowed during a flight. 9. The operator shall obtain written and/or verbal consent of all persons involved with a planned operation and shall ensure that only persons consenting be allowed within 100 ft. of the flight operation. Landing zones shall be marked and shall be, at a minimum, 20x20 ft. No person is approved to be within the LZ during an operation. 10. Written and/or verbal permission shall be obtained from the authority having jurisdiction or Incident Commander when assisting city, county or state authorities. Requests for assistance to provide donated services to emergency response agencies must come from the onsite Incident Commander. Upon reaching the scene of the incident location, all PICs and VO's shall be under the direct command of the Incident Commander a s required by the National Incident Management System from the Department of Homeland Security. 11. If the sUAS looses communications with the remote controller commanded by the PIC or looses GPS signal, the sUAS will automatically return to the pre

- determined take off point/LZ. 12. Operations shall operate under the FAA regulated VFR guidelines. Operations shall not take begin or be allowed to continue when winds are gusting or sustained about 22mph.
Hover Visions is confident that t he stricter standards for PIC qualifications, the strict safety operational standards set by Hover Visions, the FAA and the safety properties of the sUAS, will allow safe and effective operations.

Hover V isions hereby respectfully requests exemption under Section 333 in order to pursue commercial sUAS applications and operations. Respectfully, Dale Parrish, Owner/Operator

HOVER VISIONS 6652 E. 46th Place Tulsa, OK 74145