November 8, 2015 U.S. Department ofTransportation (DOT) Docket Management System 1200 New Jersey Ave. , SE Washington, DC 20590 Re: Petition for Exemption, requesting reliefas perthe FAA Modernization and Reform Act of2012, Public Law 112-95, Section 333 MobiVdeo, Inc. , hereby submits to the Federal Aviation Administration, pursuant to the FAA Modernization andReformAct of2012, an exemption for petition, in accordance with Section 333 ofthe Act. This letter provides requested information as listed in the FAA's "Public Guidance for Petitions for Exemptions Filed under Section 333" and "Section 333 Petition Guidance & Checklist". MobiV deo, Inc. Background MobiVdeo, Inc

. is a Delaware Corporation that operates Small Unmanned Aircraft Systems (sUAS) equipped to conduct aerial data collection. These aerial data collection services and uses will be provided to a variety ofindustries in boththe private and public sector, including butnot limitedto commercial and private real estate, surface mapping for GIS purposes, and infrared sensing for infrastructure inspection. The MobiVdeo team has extensive experience inboth safely piloting sUASs and providing aerial photography, videography, sensing and imaging services, aerial marketing and advertising using unmanned aerial vehicles and systems. MobiVdeo will be conducting commercial operations ofsUAS for: 1. Aerial filming

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. Aerial imagery

. 3. Aerial inspections. 4. Aerial photography. 5. Aerial surveying

. 6. Aerial videography. 7. Aerial marketing and advertising. Examples include, butare not limited to: 1. Agriculture 2. Airquality monitoring 3. Athletic performances 4. Bridges 5. Building and construction zone 6. Construction sites 7. Crop surveying 8. Education 9. Electric grids 1 0. Electric utility industry, oil andpipelines 11. Emergency management assistance a. Search and rescue, hazmat/ chemical, biological, radiological and nuclear management, and emergency and disaster response 12. Establish a UAS Flight Instruction Program 13. Flare stacks 114. Geographic Information Systems (GIS) 15. Geologic hazard assessment 16. Image mapping 17. Mapping and survey applications 18

. Market research 19. Media and advertising 20. Mines 21. Petroleum and mining industry 22

. Power lines 23

. Pipeline patrol 24. Precision aerial surveys 25. Professional marketing 26. Railroad infrastructure and operations 27. Remote sensing 28. Research and development 29. Security services 30. Student instruction 31. Telecommunicationl cell tower sites 32. Wildlife and natural resource 33. Disasters and catastrophe events 

### Contact Information Nagendra Nagarajayya MobiVdeo, Inc. 4302 Denker Dr. Pleasanton, CA 94588 Telephone: 925-462-8910 Email: nnagarajayya@mobivdeo.com 

### Specific Sections of 14 CFR for which the exemption is sought: • 14 CFR21, SubpartH, Airworthiness Certificates • 14 CFR 61.23(a) and (c), Medical certificates: Requirement and duration • 14 CFR 61.101(e)(4) and (5), Recreational pilot privileges and limitations • 14 CFR 61.113(a), Certification: Pilots, Flight Instructors, and Ground Instructors • 14 CFR 61.315(a), What are the privileges and limits ofmy sport pilot certificate? • 14 CFR91.7(a), Airworthiness required for operation • 14 CFR91.119(c), Minimum safe altitudes • 14 CFR91.121, Altimeter settings • 14 CFR91.151(a)(1), Fuel requirements for flights in VFRconditions • 14 CFR91.405(a), Maintenance required • 14 CFR91.407(a)(1), Operations after maintenance • 14 CFR91.409(a)(l) and (2), Inspections • 14 CFR 91.417(a) and (b), Maintenance records 

### Equivalent level ofsafety In an effortto minimize risk to the National Airspace System, andto minimize risk to persons and property onthe ground, operations will be conducted in accordance to the following limitations and conditions:

21. Operations authorized are limitedtothe UAS requested in this petition when weighing less than 55 pounds including payload. Proposed operations ofany other aircraft will require a new petition or a petitionto amend. 2

. Operations for the purpose ofclosed-set motion picture and television filming are not permitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). Either groundspeed or calibrated airspeed may be usedto determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater

### than the maximum UA operating airspeed recommended bythe aircraft manufacturer. 4

. The UA must be operated at an altitude ofno more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able touse human vision unaided by any device other

### than corrective lenses, as specified onthe PIC's FAA-issued airman medical certificate or U.S. driver's license. 6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line ofsight (VLOS) ofthe PIC and VO atall times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations

. The PIC must be designated before the flight and cannot transfer his orher designation for the duration ofthe flight. The PIC must ensure that the VO can perform the duties required ofthe VO. 7
. All documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this petition, are hereinafter referred to as the operating documents. The operating documents mustbe accessible during UAS operations and made available tothe Administratorupon request
. Ifa discrepancy exists between the conditions and limitations in this exemption and the procedures outlined inthe operating documents, the conditions and limitations hereintake precedence and must be followed. Otherwise, the operator must follow theprocedures as outlined in its operating documents. The operator may update or revise its operating documents. Itis the operator's responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request
. The operator must also present updated and revised documents ifit petitions for extension or amendment to this petition. Ifthe operator determines that any update or revision would affect the basis upon which the FAA would grant an exemption, then the operator must petition for an amendmentto its grant ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement ofa flight critical component, must undergo a functional test flight prior to conducting further operations. Functional test flights may onlybe conducted by a PIC with aVO and must remain at least 500 feet from other people. The functional test flight must be conducted 

### in such a manner so as to not pose an undue hazard to persons and property. 9

. The operator is responsible for maintaining and inspectingthe UAS to ensure that it is in a condition for safe operation.

310. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. Ifthe inspection reveals a conditionthat affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed andthe UAS is found to be 

### ina condition for safe flight. 11. The operator must follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this petition must comply with all manufacturer safety bulletins. 13. Underthis grant ofexemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate

. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession, orthe Federal government
. The PIC must also meet the flight review requirements specified in 14 CFR 

### § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 14

. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this petition, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures
. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for thepurposes oftraining the operator's PICs and VOs (training, proficiency, and experience-building) and determining the PIC's ability to safely operatethe UAS in a manner consistent with howthe UAS will be operated underthis petition are permittedunderthe terms ofthis petition. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR 

### § 91.119

. 15. UAS operations may notbe conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized

. 16. The UA ma y not operate within 5 nautical miles ofan airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center ofthe airport symbol as denoted onthe current FAA-published aeronautical chart, unless a letter ofagreement withthat airport's management is obtained or otherwise permitted by a COA issued to the petition requester. The letter ofagreement with the airport management must be made available to the Administrator or any law enforcement official upon request
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. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 18. Fortethered UAS operations, the tether line must have colored pennants or streamers attached at not more than 50 foot intervals beginning at 150 feet above the surface ofthe 

### earth and visible from at least one mile. This requirement for pennants or streamers is not applicable when operating exclusively belowthetop ofand within 250 feet ofany structure, so long as the UA operation does not obscure the lighting ofthe structure.

419. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the private or controlled-access property. 20. The PIC must abortthe flight inthe event ofunpredicted obstacles or emergencies. 21. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conductthe intended operation and to operate after that for at least five minutes or with the reserve power recommended bythe manufacturer ifgreater. 22. Air Traffic Organization (ATO) Certificate ofWaiver orAuthorization (COA)

. All operations shall be conducted in accordance with an ATO-issued COA. The petitioner may apply for a new or amended COA ifit intends to conduct operations that cannot be conducted underthe terms of an existing COA. 23

. All aircraft operated in accordance vvith this exemption must be identified by serial number, registered in accordance with 14 CFRpart 47, and have identification (N

- Number) markings in accordance with 14 CFRpart 45, Subpart C. Markings must be as large as practicable. 24. Documents used bythe operatorto ensure the safe operation and flight ofthe UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available tothe PIC atthe Ground Control Station ofthe UAS any time the aircraft is operating

. These documents must be made available to the Administrator or any law enforcement official upon request. 25. The UA must remain clear and give way to all manned aviation operations and activities at all times. 26

. The UAS may not be operated bythe PIC from any moving device orvehicle. 27

. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris inthe event ofan accident. The operator must ensure that nonparticipatingpersons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately in a manner ensuring the safety ofnonparticipating persons; and b. The owner/controller ofany vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment ofthe risk of operating closer to those objects and determined that it does not present anundue hazard

. The PIC, VO, operatortrainees or essential persons are not considered nonparticipating persons under this exemption. 28. All operations shall be conducted over private or controlled

-access property with permission from the property owner/controller or authorized representative

. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 29. Any incident, accident, or flight operationthattransgresses the lateral orvertical boundaries of the operational area as defined bythe applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National

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### Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. For operations ofclosed-set motion picture and television filming and production, the following additional condi tions and limitations apply. 30

. The operator must have a motion picture and television operations manual (MPTOM) and submitted as an amendment to the petition

. 31. At least 3 days before aerial filming, the operator ofthe UAS affected bythis exemption must submit a written Plan ofActivities tothe local Flight Standards District Office (FSDO) with jurisdiction overthe area ofproposed filming. The 3-day notification may be waived with the concurrence ofthe FSDO

.The plan ofactivities must include at least the following: a. Dates and times for all flights ; b

. Name and phone number ofthe operator for the UAS aerial filming conducted under this grant ofexemption; c. Name and phone number ofthe person responsible for the on-scene operation ofthe UAS ; d. Make, model, and serial orN-Number ofUAS tobe used; e. Name and cert ificate number ofUAS PICs involved in the aerial filming; f. 

### A statemen t thatthe operator has obtained permission from property owners and/or local officials to conductthe filming production event; the list ofthose who gave permission must be made available to the inspector upon request; g. Signature ofexemption holder orrepresentative; and h. A description ofthe flight activity, including maps or diagrams ofany area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation

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. Flight operations ma y be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified inthe MPTOM

. Unless otherwise specified, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFRincluding, but not limited to, parts 45, 47, 61 , and 91. Public 

### Interest 1. Project and construction management, inspections and monitoring. The use of sUASs on construction si tes may improve the safety ofworkers, local residents and general public by assessing potential dangerous situations. Falls and injuries may be reduce9- or eliminated through a more thorough review of the construction sites

. In 

### some cases, sUASs may reduce the reliance of helicopters or small aircraft to monitor said sites. This may improve safety as well as reduce environmental impact by reducing energy usage; 2

. Environmental Review projects. The use of sUASs during the process of reviewing projects as required by 24 C.F

.R 50.4, 58

.5 and 58.6 would provide a more in-depth Environmental Review of the project site as well as surrounding areas. Reliance of helicopters or small aircraft may be eliminated; 3. Aerial surveying. The use of sUASs in connection with aerial surveying of smaller areas may eliminate the use ofhelicopters or aircraft

. This could provide a more cost effective, safer and more energy efficien t product;

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### 4. Agricultural projects. Wildlife and Forestry projects. The use ofsUASs could assist with surveying agricultural projects as well as wildlife and forestry projects by providing information when problems occur, vermin infestation, fire hazards, etc.; 5. Remote Sensing projects. The use of sUASs could provide views and information for remote and inaccessible areas. This could promote worker safety as well as reduce the reliance on helicopters and aircraft; 6. Aerial Marketing and Advertising projects. The use ofsUASs could provide views and information for community service type information like amber alerts, early warning systems, America's most wanted, missing children, public safety messages, etc. This could promote community building, relationships and providing assistance to local law organizations during search, rescue and alert miSSIOns. 

### 7. Educational and Research projects. The use ofsUASs could provide information for said projects in a more cost effective and efficient manner than other available options; 8. Aerial filmmaking, photography and real estate purposes. The use ofsUASs may provide a point of view previously unavailable through other means. They would be more cost effective, efficient and more safely than helicopters and aircraft; and 9. Search and rescue. The use of sUASs may provide assistance to local law organizations during search and rescue missions. SUASs may reach areas unattainable or viewable with helicopters and aircraft. SUASs may be implemented quicker as time is of the essence during search and rescue operations. 

### Proposed Operations As will be shown herein, MobiVdeo meets and exceeds the stated §333 requirements as well asthe guidance promulgated bythe FAA. The proposed operations inthis petition for exemption qualify for expedited approval under §333 ofthe FMRA. Each ofthe statutory criteria and other relevant factors are satisfied. The proposed operations permit the use ofsmall and relatively inexpensive UAS under controlled conditions in airspace that is: (1) 

### limited; (2) predetermined; (3) controlled as to access; and that ( 4) provides an increased level ofsafety beyondthat existing when fixed or rotor wing aircraft are used to accomplish the same purpose. MobiVdeo sUAS are multi-rotor sUAS, weighing 55 or fewer pounds, including payload. They operate, under normal conditions, at low speed and have the capability to hover and move inthe vertical and horizontal plane. MobiV deo UASs will operate in line ofsight, orpursuantto the prevailing FAA regulations and guidance. Giventhe small size ofthe sUASs involved and the restricted environment within which they will operate, the comprehensive safety and operational parameters used by MobiV deo, and MobiVdeo commitment to compliance with the FAA's regulations now and into the future, this petition exemption falls withinthe equivalent level ofsafety that Congress desired the FAA to 

### permit commercial UAS operations by exemption pending completion offormal rulemaking. Also, due tothe size ofthe sUASs and the restricted area in whichthe sUASs will operate, approval ofthe applicationpresents no national security issue.

7Granting the requested exemption will benefit the public interest as a whole in many ways, including (1) significantly improving safety and reducing risk by alleviating human exposure to danger, (2) improving operations USES and decreasing operating costs, and (3) providing an environmentally conscientious way ofproducing aerial photography, videography, sensing and imaging services, aerial marketing and advertising and otl1er aerial data collection services operations. Considering the clear direction in §333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level ofsafety surrounding the proposed operations, andthe significant public benefit, the grant ofthe requested exemptions is also in the public interest. Accordingly, MobiVdeo respectfully requests the FAA grantthe requested exemption without delay. Unmanned Aircraft Systems to be used for Proposed Operations • Aeryon Sky Ranger • DJI Inspire 1 • DJI Phantom 3 Professional • Zero-Tech High One • 3D Robotics Solo • DJI Spreading Wings S800 • 3D Robotics X8 • DJI Phantom 2 Vision Plus • Tarot T960 A2 50 Wps ARTF Combo • Airborne A1 HD X8 • Airborne A2 HD X4 • Airborne A2 HD X8 • DYS D800-X8 • Foxtechfpv D 130 X8 V2 A2 12S RTF COMBO

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