1 July 2105 A-Real Vision, LLC 10517 Pacific Palisades Las Vegas, NV 89144 U.S. Dept. ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE., Washington, DC 20590 Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam: Pursuant to Section 333 ofthe FAAModernization and Reform Act of2012 and 14 C.F.R. Part 11, A-Real Vision, LLC (AV) seeks an exemption from Federal Aviation Regulations (FARs) detailed below for the following described Unmaru:ed Aerial System (UAS), which includes an Unmanned Aircraft (UA) and ground-based equipment and crew. A-Real Vision requests this exemption to operate UAS for hire, to be operated by certified airmen at the highest levels of safety and compliance. First, the general operations and restrictions that A V intends are described followed by a discussion ofthe applicable regulations for**these~perations** and is in the following sections: (1) the UAS, (2) the UAS pilot in command (PIC), (3) UAS operating parameters, and ( 4)the public safety and interest. Ourpoint ofcontact for this application is: A-Real Vision, LLC Attn: Colby Edwards Phone: 850-226-3093 Work email: colby@a-realvision.com Personal email: colby.edwards01@gmail.com Please consider this petition for exemption for small UA operations by A-Real Vision, LLC. Please also acceptthe included user manual and safety guidelines as operations procedural documents. We are preparedto modify this request, orclarify any point upon notification. Thank you for consideration, we look forward to working with the FAA during this process.

olby Edwards, ChiefOperator A-Real Vision, LLC Commercial Pilot Certificate Number 3617441 Flight Instructor Certificate Number 3617 441CFIOperations and Considerations for Exemption The following regulations (14 CFR) are discussed and considered for reliefwithin this petition:

- 14 CFR Part 21

- 14 CFR 47.31

- 14 CFR 61. 113

- 14 CFR 61.133

- 14 CFR 91.109

- 14 CFR 91.119

- 14 CFR 91.121

- 14 CFR 91. 151

- 14 CFR 91.405

- 14 CFR 91.407 "

- 14 CFR 91.409

- 14 CFR 91.417

- 14 CFR 91.9
General Operations Operations will utilize the DllPhantom 3 UAS and will be used to support aerial photography and video ofreal property. While real property is the primary focus ofAVs business, AV request to operate its UAS for a variety ofpurposes, assuming that any exemptions and applicable FARs are adhered to. AVbelieves that there are several tasks\vell-suited to UAS operations in which there is less risk and impact to individuals and property when compared to either manned aircraft operations orpersonnel occupying elevated objects/buildings for similar purposes (e.g. -inspections ofelevated structures). The following operating manuals, safety bulletins, and manufactures documents (with appropriate updates and changes) will be adhered toin all AV operations: 1) Phantom 3 Professional UserManual 2) Intelligent Flight Battery Safety Guidelines 3) Safety Guidelines Disclaimer All operations will be conducted by a qualified PIC with appropriate medical certificates as described below. Additionally, these certified airmen will maintain proficiency and currency in the UAS as described below following initial training requirements. All UAS operations will beconducted in day, VFR conditions, lAW with all applicable regulations, NOTAMs, safety guidance, and exemption conditions set forth as a result ofthis request. The UA will be flown at an indicated airspeed of25 knots orless. The UA will be operated at an altitude ofno more than 400 feet above ground level (AGL), as indicated by the procedures specified inthe operating documents. The PIC will ensure aJ.l FAA
2• restrictions are adhered to and thatthere is no present conflict within the applicable airspace system. The UAwill remain within visual line ofsight (VLOS) ofthePIC at all times and an additional visual observer (VO) will beused at all times to provide for additional safety. The sole duty of the VO and PIC will be to safely conduct flight operations. All flight operations will include appropriate pre-flight, post-flight, and maintenance procedures normal to manned-flight operations as applicable and reasonable tothe UAS (additional discussion below). All operations will adhere to operating manuals and manufacturer's guidance, including updates and safety bulletins

. All operations will begin with a fully charged battery IA W manufactures guidance and flights will not exceed 15 minutes in duration, providing a 35% reserve. Flights will remain within 4500 feet (3/4 nautical mile) ofthe PIC at all times. All safety features will beenabled lAWwith manpfacturer's guidance, and any contingency or emergency will result in immediate termination offlight operations throughthe safest and most expedient means feasible. All operating documents and aircraft/pilot records will be kept with the I!IC during any operations. The UAwill not be operated over congested areas, or areas ofassembled persons. All operations will be conducted over private property with the express permission ofthe property owners. The PIC will ensure that only essential persons remain within the affected flight area unless express permission, and/or appropriate barriers are used for reasonable protection. Regardingthe UnmannedAircraft System: AV intends to use the

### DllPhantom UAS for the purposes ofaerial filming and photography. The inherent safety provided relative totraditional, manned-aircraft are significant. These crafts are small and weigh less than 5 pounds (including battery) and require no liquid fuel. The UAs are significantly smaller and provide significant risk reduction when compared with manned aircraft operations. Additionally, no aircrew are at risk due to the unmanned operation ofthese UAs. Thetwo craft operated by A-Real Vision are briefly described below and the detailed operations manuals are submitted as attachments. The 

### DllPhantom design and relevant characteristics are as follows: Phantom 3, manufactured by 

### Dll withthe following general characteristics:

3A lightweight, 2.75lb gross weight, approximately 14 inches diagonal length with all onboard equipment, battery operated4-motor quadcopterthat takes offand lands vertically. The Phantom has a still air speed ofno more than 33mph

. The quadcopter is powered by a 15.2V, 4480mAh Lithium Polymer battery and has no liquid fuel onboard

. There is a battery warning indicator and an auto returnto home (RTH) feature included to avoid inadvertently flying beyond battery capacity

. The UAhas fixed landing gear. An on-board processor and GPS navigation system that receives signals for maneuver from a ground-based transmitter (controller). An on-board camera, installed by designthroughthe manufacturer capable ofcapturing full motions video, still photographs and media in full color high definition (liD). Or optional GoPro camera installation capable with similar weight and characteristics. An on-board telemetry system that delivers flight data from the on-board flight computer tothe on-board radio transmitter including

_ altitude AGL, horizontal and vertical speed, compass direction offlight and direction back to its launch site; Along with normal flight parameter indicators (altitude, airspeed, etc.), theUA includes a flight limits function which provides warning to operators upon limit (modifiable) breach

. 4 The Phantom comes with thorough operations and maintenance manuals to ensure proper and safe operations and is submitted as operating documents withthis exemption request. The UAS will be operated in compliance with applicable FAAguidance and OperatingManuals

. A thorough pre-flight and post

-flight inspection will be conducted IA W manufacturer guidance and any repairs will be completed IA W applicable manuals, manufacturer guidance, and will be tested in a safe, remote environment priorto normal operations

. UAS maintenance logs will be maintained and kept in the location oftheUAS at all times

. FCC compliance

- The UAS are compliant with FCC regulations

. Specifications are outlined in the attached Operating Manuals. The following discussion ofregulations may be considered regarding the UAS: 14 CFRPart 21 Subpart H. Airworthiness Certificate- in review ofpreviously granted exemptions and unique characteristics ofthe UAS described above, relieffrom 14 CFRPart 21 is not pursued

. The small size, lack ofliquid fuel, lack ofmanned cockpit, and lack of communications requirements with other aircraft and outside agencies are submitted as equivalent levels ofsafety for voiding the requirement ofan air worthiness certificate

. 14 CFR 91 Subpart E (91.401-417). Maintenance, Preventative Maintenance, and Alterations

- A-Real Video intends to have the PIC perform routine inspections, preventative maintenance and repairs IA W applicable operations manuals and manufacturer's guidance and submits the following as equivalent levels ofsafety in the request for exemption from 14.CFR
4

## .. 91.405 (a)Maintenance required, 91.407(a) (1) Operation aftermaintenance,preventive maintenance, rebuilding, oralteration, 91.409(a)(l) and (2)Inspections, and91.417(a) and (b)Maintenance records:

• Priorto each flight the PIC will inspect the UAS, to include the ground station controller to ensure it is in a condition for safe flight IA W applicable operations manuals. Any discrepancies will be immediately addressed and further operations will be prohibited until addressed. All discrepancies and associated repairs/alterations will be documented in the aircraft records and will include time in service, description ofwork accomplished, and signature ofthe authorized repatr person.
• All aircraft components will be continuously monitored for wear and life limits, and these components will bereplaced at, orbefore, manufacturer's suggested replacement times. Any components beyond minor repair and reasonable capabilities ofthe PIC will be returned to the manufacturer for repair. All safety bulletins from the manufacturer wil! be addressed immediately and any updated operating documents or software will be implemented priorto the next flight.

• Any maintenance involving flight-critical equipment will be tested in a remote area for the specific purpose ofa functional test flight**and~ill** be documented in the aircraft records. Additionally, any software updates that directly affectthe operation ofthe UAS will bedocumented and functional tested priorto normal operations.

• A post-flight inspection will be conducted after each flight, and the battery will be fully charged prior to any further operations. Regarding the UnmannedAircraftPIC: A

V intends to operate its UAS with current and qualified, certified airmen. Theprimary operator for the company will possess a Commercial Pilot certificate and will possess a current second-class medical certificate. After review ofpreviously granted exemptions (refExemption No. 11174), there appearsto be precedence for allowing Private Pilots to operate UASs "for hire" via waiver/exemption, specifically noting the lack ofpassengers and light/small characteristics oftheUAS. Accordingly, AV requests to permit operations "forhire" under control ofappropriately trained individuals holding a Private Pilot certificate and a current thirdclass medical. Inthis request, the following is submitted: AVrequests relieffrom 14 

### CFR § 61.113 (a) and (b). PrivatePilot limitations- considering the nature ofthe operations and minimal hazard to persons orproperty, AV suggests that a Private Pilot would not provide a significantly less margin ofsafety in its operations than a

5Commercial Pilot. As addressed in previous exemptions, the equivalent level ofsafety may be conductedby a Private Pilot since the UA will not carry passengers. Certified airmen will onlybe permitted tobe act as PIC assuming that they can safely operate the UAS in a manner consistent with howthe UAS is tobe operated underthis exemption and all applicable regulations. This includes evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. The following guidance and procedures will be enacted at AV in orderto act as a PIC during UAS operations:

• The PIC must possess: 1) at least a private pilot certificate and at least a current thirdclass medical certificate, or 2) at least a commercial pilot certificate and at least a secondclass medical certificate. Inboth cases, the PIC must also meet the flight review requirements specified in 14 CFR 

### § 61.56.

• PIC qualification criteria will include: o Dedicatedtraining from AV qualified UAS PIC persons o 25 hours oftotal time as a UArotorcraft pilot o 10 hours logged as a UA pilot with a similar UA type o 5 hours inthe make and model o 3 takeoffs and landings every 90 days for currency purposes o PIC qualification flight hours will be logged lAW 14 CFR 

### § 61.51(b).

• Itis requested that any prior documented flight experience that was obtained in compliance with applicable regulations may help satisfy these

### req~irements. Additionally, it is requested thattraining, proficiency, and experience-building flights may be permitted under the grant ofany applicable exemptions in order to accomplish the required flight time minimums.

• Training will be conducted to certify new PICs that includes all aspects ofthe UAS operation

. All previously mentioned maintenance, preflight, and post-flight actions will be integrated with actual flight training. Training will include all phases offlight as well as emergency procedures, lost link procedures, VO coordination and communications, and proper obstacle avoidance procedures. Special emphasis will include any update operations or safety guidance provided by the manufacturer and any restrictions imposed by the conditions ofany exemptions.
Operations with a Visual Observer (VO) will be the responsibility ofthe PIC and at no point will the PIC lose visual line ofsight (VLOS) with the UA. The VO will also be in continuous VLOS with the UA and within the limits ofthe VO's visual capabilities. lAW guidance given in previously granted exemptions (refExemptionNo. 11062), AV does not intend to certify its VOs with an airmen's medical certificate. AV intends to conduct safe operations viaPIC and other inherent safety measures and does not consider aVO to be a medical liability. Although all operations will use a VO for additional safety measure, ifthe VO were to become medical incapacitated, safe UA operations and landing may still be conducted. Inthe event ofVO

6

## .. incapacitation orloss ofVLOS, UAS operations will be terminated immediately and will be treated as a time-critical event. OperatingParameters of the UAS: AV requests authorization to use the above described UAS to support aerial photography and video ofreal property. While real property is the primary focus ofAVs business, we request that AV be permitted to operateits UAS for a variety ofpurposes, assuming that any exemptions and applicable FARs are adhered to. AVbelieves that there are several tasks well-suited to UAS operations in which there is less risk and impact to individuals and property when compared to either manned aircraft operations orpersonnel occupying elevated objects/buildings for similar purposes (e.g. -inspections ofelevated structures). Additionally, manned aircraft operations "for hire," are typically permitted to conduct business in a number ofways (photography, passenger haul, freight, medical, etc.) as long as all normal rules and regulations are adhered to
. While AVs primary interest is real property photography, it is ourbeliefthatUASs may benefit the public interest in a number ofways assuming they are operated by a certified airman and adhere to all applicable rules and guidance. Inpursuit ofthis request, AV submits the following: AVis confident that it can meet the conditions outlined in 14 CFR 

### § 91.7(a) Civilaircraft ainvorthiness, through proper preflight inspections and adherence to operations manuals as described above. Additionally, lAW with14 CFR 

### § 91.7(b), the PIC ofthe UAS is responsible for determining whetherthe aircraft is in a condition for safe flight, and AV intends tomeet and comply with this requirement; however, in a review ofprevious exemptioos, it was shown that relieffrom 

### § 91.7(a) may be necessary. As applicable, AV requests exemption from this section at the FAA's discretion. lAW 14 CFR 

### § 91.9 Civilaircraft flight manual, marking, and placardrequirements and 14 CFR 

### § 91.203(a) and (b) Civil aircraft: Certifications required , AV will keep all relevant materials at the ground location ofthe PIC in orderto becompliant

. Since these regulations require documentationto be available in the actual aircraft, AV seeks relieffrom these regulations ifcompliance is not met as deemed by the FAA

. Additionally, all aircraft operated by AV will be identified by serial number, registered lAW 14 CFRpart 47 and have identification markings lAW 14 CFRpart 45, subpart C. Any unique instructions for UAS registration lAW with 14 CFR 

### § 47.31 is requested to be included with the response to this exemption

. Dueto the small size ofthe UAS, the markings will be displayed as large as possible in orderto meet the intent ofthis requirement. As described above, all training flights will be conducted during dedicated training sessions in a remote area free from obstacles and distractions

. All training will be conducted by a current and certified PIC meeting therequirements outlined in the previous section ofthis request
. In review ofprevious exemptions, AV does not intend to pursue relieffrom 14 CFR 

### § 91.109, Flight instruction; Simulatedinstrument flight andcertainflight tests , unless the FAAdeems necessary. Realizing dual flight controls will not be available for these training sessions, AV intends to have both the trainee and instructor co-located and having immediate access to flight controls for instruction. Given that trainees will possess at least a private pilot's certificate, AV feels that an equivalent level ofsafety will be met lAWwith the intent of14 CFR 

### § 91.109.
7Duetothe unique characteristics oftheUAS, applicable regulations contained in 14 CFR § 91.119,Minimum 

### SafeAltitude, will be met during all AV operations. The regulation will be met through normal and emergency operations that permit safe landing during emergency, o· r power-failure conditions, and will not provide an undue hazard to persons orproperty. This equivalent level ofsafety will be met primarily by operating only over private property with the express permission ofthe property owner. Additionally, the small and light-weight characteristics oftheUA offers an inherent level ofsafety that far exceeds that oflarger, manned aircraft performing similar tasks. The UA will never be operated over congested areas, orareas that contain assemblies ofpersons. It will bethe PIC responsibilityto ensure all permissions and adequate levels ofsafety are met, including appropriate distances from persons, vessels, and nonparticipating properties.

.. In review ofprevious exemptions, AV intends to meet the intent set forth in 14 CFR § 91.119 sections (a) and (b), but requests relieffrom 91.119 section (c) through appropriate mitigating procedures. Section 91.119 (c) requires that aircraft operate no closer than 500 feet to these persons orobjects. AV operations may require that the UAbe operated closer than 500 feet to essential persons, orobjects and requires relief

• AV will ensure that all persons not required for flight operations (nonparticipating persons) will remain at appropriate distances.

• lAW previous exemptions, ifbarriers or structures are present tivtt can sufficiently protect nonparticipating persons from the UA or debris in the event ofan accident, then AV requests that the UAmay operate closer than 500 feet to persons afforded such protection. It will bethePIC responsibility to ensure that nonparticipating persons remain under such protection. In situations in which this protection is lost, and nonparticipating persons are within 500 feet oftheUA, flight operations will cease immediately.

• A V requests that operations may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller ofany such vessels, vehicles or structures grants permission for these operations. The PIC will beresponsible to assess that these operations ensure adequate levels ofsafety and avoid undue hazards. Regarding 14 CFR § 91.121, Altimeter settings, AV intends to setthe altimeterto zero feet in order to provide an accurate AGL readout ofthe GPS altimeter. The GPS altimeter onthe UA will provide a constantly transmitted AGL altitude to the PIC. This, coupled with restrictions to operations below 400 feet AGL, will provide both an accurate altimeterreadout from ground level and provide a margin ofsafety to avoid conflicts within theNAS. AV requests relief/direction regarding other concerns for the intent contained in 14 CFR § 91.121. 14 CFR § 91.151 (a), Fuel requirements for flight in VFR conditions, states that no person may begin a flight under day, VFR conditions unless there is sufficient fuel to fly to the first point ofintended landing and still have at least 30minutes offuel beyond that planned route.

8

## .. A V intends to meet the intent ofthis regulation by limiting operationsto provide sufficient battery powerfor operations to ensure safe landing atthe point ofintended landing with reserves.

• The Phantom 3 has approximately 23 minutes offlight with a full battery charge.

• AV will operate the UAfor a maximum of 15 minutes, which will provide an 8 minute buffer to ensure safe landing. This provides an approximate 35% reserve undernormal conditions.

• Additionally, there are multiple safety features onthe UAthat will provide additional safety under contingencies. This includes a low-battery warning and an automatic return to home (RTH) feature that will automatically land the UAprior to battery exhaustion. A V will never operate theUAunless a full battery capacity is available priorto flight, and will keep all operationswithin 4500 feet (3/4 nautical mile)

. Under these conditions, AV feels that an equivalent level ofsafety will be met and requests relief from 14 CFR § 91.151 as applicable. Public Safety andInterest With the dramatic increase inuse ofUAVs, webelieve there is good reason to establish solid foundational procedures in all areas ofuse by developing these practices through certified airmen. Having appropriate training and qualifications will help airmen glan and execute UA operations in a safe and effective manner that will support further integration into the NAS. AV pilots will be previously certified airmen who understand the aerial environment and NAS and will uphold the highest standards in UAintegration practices. This will not only aid in safety but will also bring awareness to proper, certified UA operations. Furthermore, AV's specific UA- the 

### DflPhantom 3- is powered bybatteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes than manned aircraft. Additionally, without persons onboard it will thereby reduce current risk levels and enhance safety. This diminishes the likelihood ofdeath or serious bodily injury for both airmen and public persons. With a small payload and maximum flight time of only 15 minutes, this is offers little orno risk to national security. A V feels that there are tremendous advantages to the use ofUAs when considering safety and public interest, especially when compared to traditional, manned operations ofsimilar nature. Wetherefore request the above considerations be considered for exemption in pursuit of"for hire" operations. Summary AV respectfully submits the above in consideration for exemption ofapplicable regulations. It is ourintent to maintain the highest standards ofsafety and adherence to any and all applicable regulations in all UAoperations. Inthis endeavor, A V will rely on fully-certified airmen and continue full cooperation with the FAA. Please reference ourPOC, Colby Edwards, for any questions or supporting documentation needed. 9