January 9, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

,

___ :: Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b)

(2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 91.409

(a) (2);91.417 (a) & (b).

To whom it may concern,

In pursuant with Section 333 of the FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11,

Voler UAV LLC (Voler), an operator of a small Unmanned Aircraft System (sUAS) for the

motion picture and television industry, seeks an exemption from the Federal Aviation Regulations

(FARs) to all ow commercial operations of its sUAS. Regulations ("FARs") to allow commercial

operation of its sUASs, 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 Section 333.

As described more fully below, the requested exemption would permit the operation of small,

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is limited,

predetermined, controlled as to access and would provide safety e nhancements to the already safe

operations in the film and television industry presently using conventional aircraft. Approval of this

exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA

Administrator's) responsibilities to " ... establish requirements for the safe operation of such aircraft

systems in the national airspace system." Section 333(c) of the Reform Act.

Information Supporting this Petition as Specified in 14 C.F.R. §11.81

--- ------------------------------------------------------------------------------------------------------------ (a) Your name and mailing address and, if you wish, other contact information such as a fax number,

telephone number, or e

- mail address;

Voler UAV , LLC.

Marc Asselin.

3825 Majestic Palm Way

Delray Beach Florida 33445

(561) 676

- 3917

Email: info@voleruav.com

(b) The specific section or sections of 14 C.F.R. from which Voler seeks an exemption

· 21

- Subpart H C ertification procedures for products and parts, Airworthiness

Certificates

45.23

- Display of marks; general

61.113

- Private pilot privileges and limitations: Pilot in command

91.103

- Preflight Actions

91.105

- Flight crewmembers at stations

91.109

- Flight i nstruction; Simulated instrument flight and certain flight tests

91.119

- Minimum safe altitudes: General

91.121

- Altimeter settings

91.151

- Fuel requirements for flights in Visual Flight Rules (VFR) conditions

91.203

- Civil aircraft: certification required

91.405

- Maintenance required

91.407

- Operation after maintenance, preventative maintenance, rebuilding, and

alteration91.409

- Inspections

· 91.417

- Maintenance records

We believe an exemption from the above regulations will allow Voler to conduct the nee ded work

as described above.

(c) The extent of relief Voler seeks, and the reason Voler seeks the relief

Voler seeks an exemption for several provisions of 14 C.F.R. Parts 21, 45, 61, and 91 to the extent

to operate small UASs around in sured properties.

14 C.F.R. 21

- Subpart H Certification procedures for products and parts, Airworthiness

Certificates

Voler seeks exemption from 14 C.F.R. 21, Subpart H which states the certification procedures for

products and parts as well as airworthiness certificates. D ue to the limited airspace that Voler will

be using at insurance locations across the country, we are seeking exemption to the airworthiness

certification process. Voler has developed our own training procedures and regulations to

promote and provide safe flying experiences for our PIC(s) which can be viewed in section (e) of this

petition. The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot

nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this

exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual's

requirements, and under the requireme nts and in compliance with local public safety requirements,

to provide security for the area of operation.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

Voler seeks exemption from 14 C.F.R. 45.23, which discusses the display of marks. Specifically,

section 45.23 states, "(a) each operator of an aircraft must display on that aircraft marks consisting of

the Roman capital letter "N" (denoting United States registration) followed by the registration

number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital

letter (b) when marks include only the Roman capital letter "N" and the registration number is

displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally

certificated air craft, 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 "provisi onal," as applicable".

Voler will need exemption from this regulation due to the small size of the aircraft and that there

is no cabin, cockpit, or pilot station for the aircraft. The words "Experimental" can be placed on the

fuselage in compliance with §4 5.29 (f) where the pilot, observer and others working with the sUAV

will see the identification of the UAS as "Experimental." The FAA has issued the following exemptions

to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Voler seeks exemption from 14 C.F.R. 61.113, which discusses private pilot privileges and

limitations for the Pilot in command (PIC).

Voler is seeking exemption from this regulat ion, because Voler believes that there is

inconclusive evidence that a person with a private pilot certificate can successfully maneuver a sUAS

without first hand flight experience with the particular sUAS. In fact, having a private pilot license

does not automatically ensure competence at flying an sUAS in 3rd person view as required to

properly operate an sUAS within the required line of sight. However, we believe that the PIC and our

FOVO (Field Operation Visual Observer) must be able to understand and c orrectly interact with the

general aviation community. Therefore, we believe our own flight training with the sUAS will be

more than satisfactory. Our PIC and FOVO will be both certified in Ground School training to be able

to properly interact with Genera l Aviation protocols. They will also actively pursue a private pilot's

license as well have the necessary medical qualifications.

14 C.F.R. 91.103

- Preflight Actions

Voler seeks exemption from 14 C.F.R. 91.103 which states that each pilot in command shall,

before beginning a flight, become familiar with all available information concerning that flight. This

information must include: (a) For a flight under IFR or a flight no t in the vicinity of an airport,weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot

be completed, and any known traffic delays of which the pilot in command has been advised by ATC;

actions, including revi ewing weather, flight battery requirements, landing and takeoff distances, and

aircraft performance data before starting a flight.

Voler's will be operating our sUAS in VFR. Our operations manual already includes preflight

procedures directly pertaining to our sUAS which includes equipment checklist as well a preplanning

details regarding weather conditions, review of any possible flight path of general aviation, our

mission flight path and weather conditions amongst other parameters required to complete th e

mission.

14 C.F.R. 91.105

- Flight crewmembers at stations

Voler seeks exemption from 14 C.F.R. 91.105, which discusses flight crewmembers at stations.

Specifically, 91.105 states "(a) During takeoff and landing, and while en route, each required flight

crewmember shall (1) Be at the crewmember station unless the absence is necessary to perform

duties in connection with the operation of the aircraft or in connection with physiological needs; and

(2) Keep the safety belt fastened while at the crewmember st ation. (b) Each required flight

crewmember of a U.S.

- registered civil aircraft shall, during takeoff and landing, keep his or her

shoulder harness fastened while at his or her assigned duty station. This paragraph does not apply if

(1) The seat at the crew member' s station is not equipped with a shoulder harness; or (2) The

crewmember would be unable to perform required duties with the shoulder harness fastened.

Voler will need exemption from this regulation due to the fact that the sUAS will not have a fli ght

crew or crew stations other than the PIC and a FOVO. The PIC will also not have to be restrained into

a seat via shoulder harness or safety belt at the time of the flight.

14 C.F.R. 91.109

- Flight instruction; Simulated instrument flight and certain flight tests

Voler seeks exemption from 14 C.F.R. 91.109, which discusses flight instruction, simulated

instrument flight, and certain flight tests. Specifically, 91.109 states "(a) No person may operate a

civil aircraft (exc ept a manned free balloon) that is being used for flight instruction unless that

aircraft has fully functioning dual controls. However, instrument flight instruction may be given in an

airplane that is equipped with a single, functioning throw over control wheel that controls the

elevator and ailerons, in place of fixed, dual controls, when (1) The instructor has determined that

the flight can be conducted safely; and (2) The person manipulating the controls has at least a private

pilot certificate with app ropriate category and class ratings. (b) An airplane equipped with a single,

functioning throw over control wheel that controls the elevator and ailerons, in place of fixed, dual

controls may be used for flight instruction to conduct a flight review requir ed by §61.56 of this

chapter, or to obtain recent flight experience or an instrument proficiency check required by §61.57

when (1) The airplane is equipped with operable rudder pedals at both pilot stations; (2) The pilot

manipulating the controls is quali fied to serve and serves as pilot in command during the entire

flight; (3) The instructor is current and qualified to serve as pilot in command of the airplane, meets

the requirements of §61.195 (b), and has logged at least 25 hours of pilot

- in

- command fli ght time in

the make and model of airplane; and ( 4) The pilot in command and the instructor have determined

the flight can be conducted safely. (c) No person may operate a civil aircraft in simulated instrument

flight unless (1) The other control seat is occupied by a safety pilot who possesses at least a private

pilot certificate with category and class ratings appropriate to the aircraft being flown. (2) The safety

pilot has adequate vision forward and to each side of the aircraft, or a competent observe r in the

aircraft adequately supplements the vision of the safety pilot; and (3) Except in the case of lighterthan

air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated

instrument flight may be conducted in a sin gle

- engine airplane, equipped with a single, functioning,

throw over control wheel, in place of fixed, dual controls of the elevator and ailerons, when (i) The

safety pilot has determined that the flight can be conducted safely; and (ii) The person manipul ating

the controls has at least a private pilot certificate with appropriate category and class ratings. (d) No

person may operate a civil aircraft that is being used for a flight test for an airline transport pilot

certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless

the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in

command of the aircraft". Again, Except when neces sary for takeoff or landing, no person may

operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit

fails, an emergency landing without undue hazard to persons or property on the surface. (b) Overcongested are as. 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 alt itude of 500 feet above the

surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be

operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered

parachutes, and weight

- shi ft

- control aircraft. If the operation is conducted without hazard to persons

or property on the surface

- (1) A helicopter may be operated at less than the minimums prescribed

in paragraph (b) or (c) of this section, provided each person operating the helic opter complies with

any routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A powered

parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in

paragraph (c) of this section (a) Each pers on 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 stati on

along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area

prescribed in paragraph (a)(l)(i) of this section, the current reported altimeter setting of an

appropriate available station; or (iii) In the cas e 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

atm ospheric pressure in the area of operation as shown in the following table:

Voler believes that there is inconclusive evidence that a person with a private pilot certificate or

license can successfully maneuver or train someone to use an sUAS without first hand flight

experience with the particular sUAS. Flying in 3rct person orientation requires built

- up experience in

that form of flying for many years. Therefore, we believe our own flight training, pilot protocols and

first hand experiences with the sUAS as laid out in our Flight Operations Manual meets and exceeds

the requirements necessary to safely operate our sUAS for the tasks we purpose. Also, the sUAS will

be operated by a remote control, which will only require a single person operator and dual co ntrols

will not be necessary.

14 C.F.R. 91.119

- Minimum safe altitudes: General

Voler seeks exemption from 14 C.F.R. 91.119, which discusses minimum safe altitudes. Since most of our insurance

inspections are much less than 500ft and our flight ceiling will be below 400ft, this would not pertain to

our sUAS operations

14 C.F.R. 91.121

- Altimeter settings

Voler seeks exemption from 14 C.F.R. 91.121, which discusses altimeter settings for lowest usable

flig ht level.Voler's sUAS uses both GPS altitude and barometric sensors and relays that information to our

ground station. However, this data is used to help the sUAS automatically maintain position hold at

the required elevation and therefore this code is not pertinent the functionality of this sUAS.

14 C.F.R. 91.151

- Fuel requirements for flights in Visual Flight Rules (VFR) conditions

Voler seeks exemption from 14 C.F.R. 91.151, which discusses fuel requirements for flight in VFR

conditions. Specificall y, 91.151 states "(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) Dur ing 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".

Voler's sUAS has a typical mission time of less than 15 minutes with maximum flight time of 25

minutes. Since this am ount less than the 30 minute reserve minimum, this reserve minimum would

not even make sense in allowing the sUAS a chance to fly. According to Voler's aircraft flight

manual, the PIC is instructed to maintain flight until battery power reaches 2 5%, or 1s t level warning.

At this level, landing procedures will be intiated. Once the sUAS reads 20%, 2nct level warning, the

flight control system automatically take over and initiates safe landing sequence at the logged in

takeoff point. Voler policy outlined in our operating flight manual achieves a satisfactory safety

standards.

14 C.F.R. 91.203

- Civil aircraft: certification required

Voler seeks exemption from 14 C.F.R. 91.203, which discusses states:

(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 subparagraph (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

und er §91.611) must have on it the registration number assigned to the aircraft under part 47 of thischapter. However, the airworthiness certificate need not have on it an assigned special identification

number before 10 days after that number is first affix ed 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 application to an FAA Flight Standards district office. (2) An effective U.S.

re gistration certificate issued to its owner or, for operation within the United States, the second copy

of the Aircraft registration Application as provided for in §4 7.31 (c), or a registration certification

issued under the laws of a foreign 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 displayed at the cabin or cockpit entrance so that it is legible to passengers

or crew. (c) No person may operate an aircraft with a fuel tank installed within the passenger

compartment or a baggage compartment unless the installation was accomplished pursuant to part

43 of this chapter, and a copy of FAA Form 337 authorizing that in stallation is on board the aircraft.

(d) No person may operate a civil airplane (domestic or foreign) into or out of an airport in the

United States unless it complies with the fuel venting and exhaust emissions requirements of part 34

of this chapter".

ce rtifications. Specifically, 91.2 0 3 states "

Voler believes that an appropriate and current airworthiness certificate would not be necessary

to fly a sUAS given the size of the aircraft and the necessary level of skill needed to operate the

aircraft. Bef

ore putting in to service, each of our sUAS goes through our own airworthiness

proceedures of miminum test flight and reliability checks. Also, our sUAS are recalibrated each at the

site location before each flight to ensure that all systems functions as d esigned. Voler seeks

exemption from this regulation because we believe this rule was not meant for a sUAS and operators.

14 C.F.R. 91.405, 91.407,91.409, and 91.417

Voler seeks exemption from 14 C.F.R. 91.405, 91.407, 91.409, and 91.417, which discusses

r equired aircraft maintenance, operation after maintenance, preventive maintenance, rebuilding, or

alteration, inspections, and maintenance records. In Voler's aircraft flight manual, maintenance

and inspection procedures have been established for the aircr aft. Voler believes these regulations

are meant for manned operated aircrafts and not unmanned systems, therefore making them

unnecessary.

Nevertheless, we seek an exemption from any such specific provisions to the extent FAA finds it

necessary to grant th is request.

(d) The reasons why granting Voler's request would be in the public interest; that is, how it would

benefit the public as a whole.

Voler is classified as an engineering company by the U.S. Department of Transportation and

provides services to aerial support for commercial interest. Voler's use of a sUAS can assist in

making task safer and minimize human exposure to being at dangerous elevations. Voler's sUAS

usage will also reduce the time required to capture the needed imaging or data to convention

helicopters or airplanes. Ultimately, the result is quick completion of task an reduction of dangerous

elevation perspective needs.

(e) The reasons why granting the exemption would not adversely affect safety, or how the exemption

would provide a level of safety at least equal to that provided by the rule from which Voler seeks

exemption Our Engineering department will provide a level of safety that exceeds the level of safety

required by the FAA for its use on sUAS. The following are Vo ler's safety procedures, features,

regulations, and operating specifications for our sUAS:

 Our staff includes an FAA

- rated commercial flight instructor (ret) who coordinates our FOVO

team in integration with general aviation.

 The Pilot In Command (PIC) an d Field Operations Visual Observer (FOVO) will be required

to wear hard hats, safety vests, and safety glasses to protect the head and eyes from potential

mishaps during given operational flights including training or testing of sUAS.

 The flight area of th e sUAS will be observed for best take off and landing locations. Desiredconditions include: flat and level surfaces clear of debris, at least 15ft from power lines and

structures, and a minimum distance of 12ft from the PIC and observers.

 The sUAS will also be in the Visual Line of Sight (VLOS) to both the PIC and FOVO during all

flights.

 Flights must take place during good weather conditions with no rain, low layi,ng clouds, or

heavy winds. All flights will take place during daylight hours with no evening or late night

flights.

 The PIC(s) of the sUAS will at least have 12 training hours or 24 flights accrued before being

designated working flights.

 All batteries must be charged completely before each flight and each flight must end when

the battery has a 30% power level remaining.

 A visual safety inspection will occur before each flight, testing propeller tightness, security

mount of camera/detection equipment, remote range test, and proper safety equipment is

adorned to PIC and FOVO.

 The sUAS will be flown under a height of 500ft AGL.

 No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity during a critical

phase of flight so as to ensure that the sUAS is in a condition for safe flight operation and in a

configuration appropriate f or the purpose of the intended flight.

 If there is more than just an operator at a site during a flight, the PIC operator and observer

or FOVO will maintain two

- way communication with each other during all operations; if

unable to maintain two

- way communic ations, or if any condition occurs that may otherwise

cause the operation to be unsafe, the operator will immediately conclude the operation.

 If the communication link is lost, the sUAS will go into fail

- safe mode and safely descend to

its designated home

- point location. If the communication link is reconnected during fail

- safe

mode, control of the sUAS can be regained before landing occurs at the home

- point location.

 There is no fuel or payload to the sUAS, therefore there will be no poten tial explosives or risk

of explosion if a crash occurs with the sUAS.

The sUAS will feature a built in compass that will be recalibrated at every site to maintain

accurate directional readings. The compass will also help in keeping the sUAS stable during

f lights.

 The sUAS will record GPS location data once Ready to Fly status has been obtained. A

minimum of 6 satellites will activate the Ready to Fly status.

 The weight of the sUAS is less than 10 lbs. with a maximum ascent speed of 6 

### mjs and a



###  descent speed of 2 

### mjs. The aircrafts maximum flight speed is 15 

### mjs.

 The aircrafts vertical and horizontal aspect concerning hovering accuracy is 0.8m and 2.5m

respectfully.

 The typical aircraft wheelbase will be less than 600mm in length .

 The aircraft runs off a Li

- Po battery .

(f) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The rule from which you seek

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

Petitioner: Voler UAV , LLC.

Sections of 14 C.F.R. Affected: 21 Subpart H; 45.23(b); 61.113(a)(b); 91.103; 91.105; 91.109;

91.119( c); 91.121(a)(l)(iii); 91.151(a)(l); 91.203; 91.405; 91.407; 91.409; and 91.417

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. 21

Subpart H; 45 .23(b); 61.113(a)(b); 91.103; 91.105; 91.109; 91.119(c); 91.121(a)(1)(iii);

91.151(a)(l); 91.203; 91.405; 91.407; 91.409; and 91.417 to conduct aerial inspection for

insurance industry and their properties and subject to operating procedures that meet or

e xceed those that FAA requires.

(g) Any additional information, views or arguments available to support your request

Please see the introduction to this exemption request.(h) If you want to exercise the privileges of your exemption outside of the United S tates, the reason

why you need to do so

The Operations described in this exemption request will be conducted wholly within the

United States.

Please do not hesitate to contact me via email at info@Voleruav.com if you have any questions

or concerns.

Marc Asselin

President

Voler UAV , LLC

### Voler plans to use the 3D Robotics X8 rotorcraft (already approved in our exemptions) , 3D Robotics Solo,

DJI Phantom 3 , and DJI Phantom 2

. Below you will find specifications for each craft.

3D Robotics X8 (already approved in our exemptions #11335 )

http://3drobotics.com/x8/

Specs for the 3D Robotics X8 :

 

### X8 format including 8 propellers (4 above, 4 below).

 

### Vehicle Dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 20 cm)

 

### Payload Capacity: 800 g (1.7 lbs).

 

### Vehicle W eight with Battery: 2.56 kg (5.6 lbs)

 

### Maximum Estimated Flight Time: 15 min

### 3D Robotics Solo

http://3drobotics.com/solo/

Specs for the 3D Robotics Solo :

Flight time: up to 25 min without payload, or up to 20 min with GoPro and Solo Gimbal

Controller battery life of up to 4 hours; built

- in rechargeable battery (8 hours with optional extended

battery)

Weight: 1500 g; 1800 g with Solo Gimbal and GoPro

### DJI Phantom 3

http://www.dji.com/product/phantom

- 3

Specs for the DJI Phantom 3:

 Weight (Including Battery a nd Propellers)

- 1280 g (2.8 lbs)

 Diagonal Size (Including Propellers)

- 590 mm

 Max Flight Time: Approximately 23 minutes

### Specs for the DJI Phantom 2:

http://www.dji.com/product/phantom

- 2

### Please let me know if you require any other information.

Best Regards,

Marc Asselin