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 Section 333 of the FAA Modernization and 

Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation Regulations 

Dear Administrators, 

Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a 

mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. 

Section 333(a) states that the FAA "shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the (comprehensive) plan and 

rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of 

this Act." In Section 332(b)(1), The Petitioner "Vantage Imaging Solutions, LLC", hereafter 

referred to as VIS, proposes the following exemptions and meets all requirements to permit FAA 

approval of commercial UAS operations. The proposed 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 nature, 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 Observer 
 February 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 invented, used, or designed to navigate, 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 services, airports or landing areas; aeronautical 

charts, information and services; rules, regulations and procedures, technical 

information, and manpower and material 

c. Operational Control: with respect to a flight, 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 final authority and responsibility for the 

operation and safety of the flight; has been designated as PIC before or during the 

flight; and holds the appropriate category class and type-rating, if appropriate, for the 

conduct of the flight (14 CFR § 1.1) 

e. Unmanned aircraft (UA): any aircraft 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 unmanned 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 Authorization (COA): an authorization issued by the 

Air Traffic Organization to an operator for a specific unmanned aircraft activity 

h. Visual Line of Sight (VLOS): unaided (corrective lenses and/or sunglasses excepted) 

visual contact between a pilot in command and an unmanned aircraft sufficient to 

maintain safe operational control of the aircraft, know its location, and be able to scan 

the airspace in which it is operating to see and avoid other air traffic or objects aloft 

or on the ground 

II. Introduction and Interests of Petitioner 

The Petitioner, VIS is a professional consulting firm that specializes in surveying, construction 

analysis, and civil engineering services. Additionally, VIS also provides services to unique 

industries and projects that pertain to the scope of services listed below. VIS plans to use the 

unique capabilities of Unmanned Aerial Systems to more safely and efficiently 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 Archaeology services 

o Agricultural monitoring 

o Landscaping services 
 February 17, 2016 

 Page 4 of 10 

o Structural 3D modeling services 

o Wildlife and forestry monitoring 

o Scientific and Environmental 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 topographic data and analysis. Current topographic 

surveys are performed by small manned aircraft using aerial photogrammetry, which is costly 

and can have lead times of up to several months. Using a small, unmanned 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 request, flights consisting of small 

manned aircraft would be replaced by sUAS, resulting in less intrusive air traffic and would have 

a minimal impact on the NAS and environment compared 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 Certificate of Waiver or Authorization (COA) for flights at or below 200 feet to 

any UAS operator with a Section 333 exemption for aircraft that weigh less than 55 pounds, 

operate during daytime Visual Flight Rules (VFR) conditions, operate within visual line of sight 

(VLOS) of the pilots, and stay certain distances away from 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 instrument flight procedure, but not an 

operational tower; or

o 2 NM from an airport without a published instrument flight procedure or an 

operational tower; or

o 2 NM from a heliport with a published instrument flight procedure.

The specific rationale for relief from 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 and weighing less than 10 pounds. The UAV 

maximum speed is 40 mph (35knots). 

b. The aircraft will not carry persons or property, will not carry fuel, and will only fly 

under strict operational requirements. 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, performing the same mission. 

 14 CFR 36

a. The Petitioner requests relief from any associated noise certification and testing 

requirements of part 36. As a note, according 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 payload 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 and placards, shall be 

kept in a location immediately accessible to the PIC during all commercial flight 

operations in compliance with the regulations. A digital copy of all necessary 

materials shall be maintained by VIS. 

 14 CFR 91.103 (b)

a. The pilot in command shall, before beginning 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 future commercial flight operations to be within Class G 

airspace, below 400 AGL at all times. If there 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 such flight operations will be obtained 

prior to such operations. In regards to 91.103(b), the UAV will 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 including reviewing weather, flight battery 

status, landings, and takeoff clearances and aircraft 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. Additionally, its operation will be in a highly 

controlled airspace that will be deconflicted from 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 is 
 February 17, 2016 

 Page 7 of 10 

limited to 20 minutes per battery and therefore the PIC would not be able to meet the 

minimum flight reserve standards and still conduct flight operations. The UAS is 

equipped with a visual battery level indicator for the aircraft and controller that 

provide the pilot real time battery state. 

b. Additionally, the UAV has a visual and aural alarm that indicates when the battery 

reaches a state of 30 and 20 percent battery life. These indicators, coupled with pilot 

awareness and the emergency return to home point settings, provide ample time to 

land the aircraft safely whenever the battery level is low. At 20 percent, the UAS 

automatically aborts and returns to the designated home point. 

 14CFR91.203

a. The Petitioner requests relief from this section as the appropriate 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, 417

a. The Petitioner requests relief from 14 CFR 91.405, 407, 409, and 417 The abovecited regulations require, in general, aircraft owners and operators 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 within the operations manual and 

the checklists and procedures commensurate with safe aviation practices. 

VI. Public Interest 

The reasons why granting this request 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. With the help of UAS more complete site 

inspections can be performed while minimizing 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 collection by conventional means. 

o Cost Effectiveness

The UAS will be used in a variety of applications that generally require expensive 

full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer 

many benefits over the use of full-sized manned aircraft for construction and 

surveying operations, archaeology services, agricultural monitoring, 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 conventional 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 economically feasible projects. 

o Innovative Project Analysis

The UAS technology is creating a modern approach 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 services to the public. 

o Environmental Impact

Our all-electric UAS’s produce no air pollution, and are the most environmentally 

friendly alternative to the current 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 aircraft (UA) to be operated under this request is 

less than 10 lbs. fully loaded, flies at a speed of no more than 40 mph (35 knots), 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 POH. The aircraft is the Inspire 1 

Pro, manufactured by DJI. The aircraft itself, its fully gimbaled and stabilized video camera, 

and sophisticated control systems include a GPS navigation and reference system, full 

autonomous and programmable autopilot capabilities, 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 design of the UAV, as described in the POH, to 

ensure the safety of persons and property within 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 safe 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) button located within immediate reach on the 

controller. When pushed, the aircraft will immediately stop, climb or descend to the safe 

return altitude, and then return to the designated 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 standards into its proposed flight operations. For 

instance, there is a commercially rated PIC, a VO with continuous voice communications 

with the PIC, no flights beyond VLOS, no speeds above 40kts, no altitude 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 serial 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 that includes full mission planning, appropriate 

notification of any private or commercial property owners / managers, required notification 

or letters of agreement / COA’s pertinent to airspace 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 after each flight. Operations will be conducted 

in Class G airspace. If in remote or inaccessible 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 barriers or structures are present 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 preflight 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 components, 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 connectors 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. Petitioner 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 and conform to the constraints of the Section 333 COA at 

all times. 

Pilot in Command (PIC): 

The PIC has developed safe techniques and applications 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 including reviewing weather, flight battery 

requirements and status, aircraft performance data, and landing and takeoff constraints before 
 February 17, 2016 

 Page 10 of 10 

initiation of a flight. The PIC will also account for 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 devices 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 commonly 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 purposes of surveying, construction analysis, 

and civil engineering services. Additionally, VIS also provides services to unique industries and 

projects they pertain to the scope of services 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 Pro User Manual (a.k.a. POH) 

Very truly yours, 

Vantage Imaging Solutions, LLC 

Werner Pieters, P.E. 

Co-Founder 

wpieters@vantageis.com