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 own, 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 Aviation

Administration (FAA) so long as such operations are conducted within and under the conditions

outlined herein or as may be established by the FAA as required by Section333. The requested 

exemption would permit Hover Visions to pursue its commercial interests 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 monitoring 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 occuring over private or controlled access property will be 

pursued with the property owner's consent and knowledge. Hover Visions will also assure that 
only those people with the authority to provide consent will be allow to accompany any PIC and 

VO (visual observer) 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 the sole owner of the sUAS 

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 our 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 and 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 the 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 operation of sUAS under 

conditions in the National Airspace System that would be 1.) limited, 2.) controlled and 3.) 

predetermined 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 333 Exemption.

Information data of the applicant is as follows:

Dale Parrish

6652 E. 46th Place

Tulsa, OK 74145

918-798-2837

chiefdparrish@gmail.com
Regulations 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 for 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, especially 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 commercially 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 regulation.

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 nature 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 and 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 operations 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 barometric 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 allow

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 fly 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 land

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 that 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 and preventive maintenance can be performed by the PIC. The

PIC 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 repairs 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 for 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 exemption 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. Minimum crew staffing for each operation shall consist of a designated PIC and a designated VO
6. 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 hours 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 yearly 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, equipment 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 as 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 the 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 Visions 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