1 July 2105 

A-Real Vision, LLC 

10517 Pacific Palisades 

Las Vegas, NV 89144 

U.S. Dept. of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

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

Aviation Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization 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 of the 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. 

Our point of contact 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 accept the included user manual and safety guidelines as operations procedural 

documents. We are prepared to modify this request, or clarify any point upon notification. 

Thank you for consideration, we look forward to working with the FAA during this process. 

olby Edwards, Chief Operator 

A-Real Vision, LLC 

Commercial Pilot Certificate Number 3617441 

Flight Instructor Certificate Number 3617 441 CFI 
Operations 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 Dll Phantom 3 UAS and will be used to support aerial photography 

and video of real property. While real property is the primary focus of A V s business, A V 

request to operate its UAS for a variety of purposes, assuming that any exemptions and 

applicable F ARs are adhered to. AV believes 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 or personnel occupying elevated objects/buildings for similar 

purposes (e.g. -inspections of elevated structures). 

The following operating manuals, safety bulletins, and manufactures documents (with 

appropriate updates and changes) will be adhered to in all AV operations: 

1) Phantom 3 Professional User Manual 

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 be conducted in day, VFR conditions, lAW with all applicable 

regulations, NOTAMs, safety guidance, and exemption conditions set forth as a result of this 

request. 

The UA will be flown at an indicated airspeed of25 knots or less. 

The UA will be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents. The PIC will ensure aJ.l FAA 

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restrictions are adhered to and that there is no present conflict within the applicable airspace 

system. 

The UA will remain within visual line of sight (VLOS) ofthe PIC at all times and an additional 

visual observer (VO) will be used 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 to the 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 3 5% reserve. Flights will remain within 

4500 feet (3/4 nautical mile) of the PIC at all times. 

All safety features will be enabled lAW with manpfacturer's guidance, and any contingency or 

emergency will result in immediate termination of flight operations through the safest and most 

expedient means feasible. 

All operating documents and aircraft/pilot records will be kept with the I!IC during any 

operations. 

The UA will not be operated over congested areas, or areas of assembled persons. 

All operations will be conducted over private property with the express permission of the 

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. 

Regarding the Unmanned Aircraft System: 

AV intends to use the Dll Phantom UAS for the purposes of aerial filming and photography. The 

inherent safety provided relative to traditional, 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 of these UAs. 

The two craft operated by A-Real Vision are briefly described below and the detailed operations 

manuals are submitted as attachments. 

The Dll Phantom design and relevant characteristics are as follows: 

Phantom 3, manufactured by Dll with the following general characteristics: 

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A lightweight, 2.75lb gross weight, approximately 14 inches diagonal length with all onboard equipment, battery operated 4-motor quadcopter that takes off and lands vertically. 

The Phantom has a still air speed of no 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 return to home 

(RTH) feature included to avoid inadvertently flying beyond battery capacity. 

The UA has 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 design through the manufacturer capable of capturing 

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 

to the on-board radio transmitter including_ altitude AGL, horizontal and vertical speed, 

compass direction of flight and direction back to its launch site; 

Along with normal flight parameter indicators (altitude, airspeed, etc.), the UA 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 with this exemption request. 

The UAS will be operated in compliance with applicable FAA guidance and Operating Manuals. 

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 prior to normal operations. UAS maintenance logs will be 

maintained and kept in the location ofthe UAS at all times. 

FCC compliance - The UAS are compliant with FCC regulations. Specifications are outlined in 

the attached Operating Manuals. 

The following discussion of regulations may be considered regarding the UAS: 

14 CFR Part 21 Subpart H. Airworthiness Certificate- in review of previously granted 

exemptions and unique characteristics of the UAS described above, relief from 14 CFR Part 21 

is not pursued. The small size, lack of liquid fuel, lack of manned cockpit, and lack of 

communications requirements with other aircraft and outside agencies are submitted as 

equivalent levels of safety for voiding the requirement of an 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 of safety in the request for exemption from 14. CFR 

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91.405 (a) Maintenance required, 91.407(a) (1) Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, 91.409(a)(l) and (2) Inspections, and 91.417(a) and 

(b) Maintenance records: 

• Prior to 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 of work accomplished, and signature ofthe authorized 

repatr person . 

• All aircraft components will be continuously monitored for wear and life limits, 

and these components will be replaced at, or before, 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 prior to the next flight. 

• Any maintenance involving flight-critical equipment will be tested in a remote 

area for the specific purpose of a functional test flight and~ill be documented in 

the aircraft records. Additionally, any software updates that directly affect the 

operation of the UAS will be documented and functional tested prior to 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 Unmanned Aircraft PIC: 

A V intends to operate its UAS with current and qualified, certified airmen. The primary 

operator for the company will possess a Commercial Pilot certificate and will possess a current 

second-class medical certificate. After review of previously granted exemptions (ref Exemption 

No. 11174), there appears to be precedence for allowing Private Pilots to operate UASs "for 

hire" via waiver/exemption, specifically noting the lack of passengers and light/small 

characteristics ofthe UAS. Accordingly, AV requests to permit operations "for hire" under 

control of appropriately trained individuals holding a Private Pilot certificate and a current thirdclass medical. In this request, the following is submitted: 

AV requests relief from 14 CFR § 61.113 (a) and (b). Private Pilot limitations- considering 

the nature of the operations and minimal hazard to persons or property, AV suggests that a 

Private Pilot would not provide a significantly less margin of safety in its operations than a 

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Commercial Pilot. As addressed in previous exemptions, the equivalent level of safety may be 

conducted by a Private Pilot since the UA will not carry passengers. 

Certified airmen will only be permitted to be act as PIC assuming that they can safely operate the 

UAS in a manner consistent with how the UAS is to be operated under this 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 order to 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. In both cases, the PIC must also meet the flight review 

requirements specified in 14 CFR § 61.56. 

• PIC qualification criteria will include: 

o Dedicated training from AV qualified UAS PIC persons 

o 25 hours of total time as a UA rotorcraft pilot 

o 10 hours logged as a UA pilot with a similar UA type 

o 5 hours in the 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). 

• It is 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 that training, proficiency, and experience-building flights 

may be permitted under the grant of any applicable exemptions in order to accomplish the 

required flight time minimums. 

• Training will be conducted to certify new PICs that includes all aspects of the UAS 

operation. All previously mentioned maintenance, preflight, and post-flight actions will 

be integrated with actual flight training. Training will include all phases of flight 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 of any exemptions. 

Operations with a Visual Observer (VO) will be the responsibility of the PIC and at no point will 

the PIC lose visual line of sight (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 (refExemption No. 11062), AV does not intend to certify its VOs 

with an airmen's medical certificate. AV intends to conduct safe operations via PIC 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, if the VO were to become medical 

incapacitated, safe UA operations and landing may still be conducted. In the event ofVO 

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incapacitation or loss ofVLOS, UAS operations will be terminated immediately and will be 

treated as a time-critical event. 

Operating Parameters of the UAS: 

A V requests authorization to use the above described UAS to support aerial photography and 

video of real property. While real property is the primary focus of A V s business, we request that 

A V be permitted to operate its UAS for a variety of purposes, assuming that any exemptions and 

applicable F ARs are adhered to. AV believes 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 or personnel occupying elevated objects/buildings for similar 

purposes (e.g. -inspections of elevated structures). Additionally, manned aircraft operations "for 

hire," are typically permitted to conduct business in a number of ways (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 our belief that UASs may benefit the 

public interest in a number of ways assuming they are operated by a certified airman and adhere 

to all applicable rules and guidance. In pursuit of this request, AV submits the following: 

AVis confident that it can meet the conditions outlined in 14 CFR § 91. 7(a) Civil aircraft 

ainvorthiness, through proper preflight inspections and adherence to operations manuals as 

described above. Additionally, lAW with14 CFR § 91.7(b), the PIC of the UAS is responsible 

for determining whether the aircraft is in a condition for safe flight, and A V intends to meet and 

comply with this requirement; however, in a review of previous exemptioos, it was shown that 

relief from § 91. 7(a) may be necessary. As applicable, A V requests exemption from this section 

at the FAA's discretion. 

lAW 14 CFR § 91.9 Civil aircraft flight manual, marking, and placard requirements and 14 

CFR § 91.203(a) and (b) Civil aircraft: Certifications required, AV will keep all relevant 

materials at the ground location of the PIC in order to be compliant. Since these regulations 

require documentation to be available in the actual aircraft, A V seeks relief from these 

regulations if compliance is not met as deemed by the FAA. Additionally, all aircraft operated 

by A V will be identified by serial number, registered lAW 14 CFR part 47 and have 

identification markings lAW 14 CFR part 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. Due to the small size of the UAS, the markings will be displayed as large as possible 

in order to 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 the requirements outlined in the previous section of this request. In review 

of previous exemptions, AV does not intend to pursue relief from 14 CFR § 91.109, Flight 

instruction; Simulated instrument flight and certain flight tests, unless the FAA deems 

necessary. Realizing dual flight controls will not be available for these training sessions, A V 

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, A V 

feels that an equivalent level of safety will be met lAW with the intent of14 CFR § 91.109. 

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Due to the unique characteristics of the UAS, applicable regulations contained in 14 CFR § 

91.119, Minimum Safe Altitude, 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 or property. This 

equivalent level of safety will be met primarily by operating only over private property with the 

express permission ofthe property owner. Additionally, the small and light-weight 

characteristics of the UA offers an inherent level of safety that far exceeds that oflarger, manned 

aircraft performing similar tasks. The UA will never be operated over congested areas, or areas 

that contain assemblies of persons. It will be the PIC responsibility to ensure all permissions and 

adequate levels of safety are met, including appropriate distances from persons, vessels, and nonparticipating properties. 

.. In review of previous exemptions, AV intends to meet the intent set forth in 14 CFR § 91.119 

sections (a) and (b), but requests relief from 91.119 section (c) through appropriate mitigating 

procedures. Section 91.119 (c) requires that aircraft operate no closer than 500 feet to these 

persons or objects. AV operations may require that the UA be operated closer than 500 feet to 

essential persons, or objects and requires relief 

• AV will ensure that all persons not required for flight operations (nonparticipating 

persons) will remain at appropriate distances. 

• lAW previous exemptions, if barriers or structures are present tivtt can sufficiently 

protect nonparticipating persons from the UA or debris in the event of an accident, then 

AV requests that the UA may operate closer than 500 feet to persons afforded such 

protection. It will be the PIC 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 of the UA, 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 of any such vessels, vehicles or structures 

grants permission for these operations. The PIC will be responsible to assess that these 

operations ensure adequate levels of safety and avoid undue hazards. 

Regarding 14 CFR § 91.121, Altimeter settings, AV intends to set the altimeter to zero feet in 

order to provide an accurate AGL readout of the GPS altimeter. The GPS altimeter on the 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 altimeter readout from ground 

level and provide a margin of safety to avoid conflicts within the NAS. A V 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 of intended landing and still have at least 30 minutes of fuel beyond that planned route. 

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A V intends to meet the intent of this regulation by limiting operations to provide sufficient 

battery power for operations to ensure safe landing at the point of intended landing with reserves. 

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

• AV will operate the UA for a maximum of 15 minutes, which will provide an 8 minute 

buffer to ensure safe landing. This provides an approximate 3 5% reserve under normal 

conditions. 

• Additionally, there are multiple safety features on the UA that 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 UA prior to battery exhaustion. 

A V will never operate the UA unless a full battery capacity is available prior to flight, 

and will keep all operations within 4500 feet (3/4 nautical mile) . 

Under these conditions, A V feels that an equivalent level of safety will be met and requests relief 

from 14 CFR § 91.151 as applicable. 

Public Safety and Interest 

With the dramatic increase in use ofUAVs, we believe there is good reason to establish solid 

foundational procedures in all areas of use 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 UA integration practices. This will not only aid in safety but 

will also bring awareness to proper, certified UA operations. 

Furthermore, AV's specific UA- the Dfl Phantom 3-is powered by batteries, is smaller, lighter 

and more maneuverable than larger aircraft running on combustible fuel, it operates at lower 

altitudes than manned aircraft. Additionally, without persons on board it will thereby reduce 

current risk levels and enhance safety. This diminishes the likelihood of death 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 or no risk to national security. 

A V feels that there are tremendous advantages to the use of U As when considering safety and 

public interest, especially when compared to traditional, manned operations of similar nature. 

We therefore request the above considerations be considered for exemption in pursuit of"for 

hire" operations. 

Summary 

A V respectfully submits the above in consideration for exemption of applicable regulations. It is 

our intent to maintain the highest standards of safety and adherence to any and all applicable 

regulations in all UA operations. In this endeavor, A V will rely on fully-certified airmen and 

continue full cooperation with the FAA. Please reference our POC, Colby Edwards, for any 

questions or supporting documentation needed. 

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