UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Eagles View Aerial L.L.C.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF UNMANNED

AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on September 9, 2015

Paul Barsamian, Managing Partner

Eagles View Aerial L.L.C.

2426 Robincrest Lane

Glenview IL 60025

847-778-0874
TABLE OF CONTENTS Page

GLOSSARY OF ABBREVIATIONS 3

SUMMARY 4

INTRODUCTION AND INTERESTS OF PETITIONER 4

BACKGROUND 4

BASIS FOR PETITION 5

NAME AND ADDRESS OF PETITIONER 7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH 

Eagles View Aerial L.L.C. SEEKS EXEMPTION 8

THE EXTENT OF RELIEF Eagles View Aerial L.L.C.

SEEKS AND THE REASON Eagles View Aerial L.L.C. SEEKS THE RELIEF 11

THE REASONS WHY GRANTING Eagles View Aerial L.L.C.s REQUEST

WOULD BE IN THE PUBLIC INTEREST 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY 19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT Eagles View Aerial L.L.C.’s REQUEST 34

CONCLUSION 35

APPENDICES 36
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate Of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss Of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line Of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing
SUMMARY

Eagles View Aerial L.L.C. seeks exemption from the requirements of 14 C.F.R §§

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)

(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will

permit to operate an Unmanned Aircraft System (UAS) for the commercial purpose

of conducting aerial video, photography, and data gathering through sensors of farm 

land, utilities such as generators or power lines, oil & gas pipeline and facilities 

inspections, construction site monitoring, real estate, insurance inspections, 

architecture, engineering inspection of structures or land, public safety & service 

consulting, and artistic photography for film or media over certain areas of the United 

States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Eagles View Aerial L.L.C. has been designing and developing small unmanned aircraft 

systems for nearly 10 years. Paul Barsamian, (managing partner, Eagles View Aerial 

L.L.C.) has more than 15 years of flight experience, including as an instructor in AMA 

sanctioned clubs, and was previously a sponsored/team pilot for Hirobo Limited, 

(Japan) and Ikarus USA flying hundreds of hours of both fixed and rotary wing

demonstrations at AMA sanctioned events. Paul is also an experienced engineer and 

information systems consultant and provides consultation to agriculture, energy & 

utilities, construction, architecture/urban planning, film, and engineering/inspection 

organizations.

Eagles View Aerial L.L.C. seeks to provide unmanned systems consulting and 

operations in commercial applications to help clients obtain better and more consistent 

imaging and data for a wide variety of purposes from analytics to art.

Services provided by Eagles View Aerial L.L.C. will benefit a number of industries 

including

 Agriculture (imaging and data analytics)

 Utilities and Energy efficiency and safety

 Construction monitoring, management, and analytics

 Public Safety (consulting) for police, fire and rescue

 Local film and artistic interests 

 Insurance

 Architecture and urban planning
BACKGROUND

Eagles View Aerial L.L.C. seeks an exemption to operate several unmanned aircraft 

within the NAS. These aircraft are listed below and will henceforth in this document be 

referred to as “the afore mentioned UAS” collectively. All aircraft operated will be under 

55 lbs AUW, (to be measured, logged, and reported with each flight) and will never 

exceed 400ft AGL in altitude (verified using flight plan logs and altitude restrictions 

programmed into the flight controllers).

Rotary Wing:

A Tarot 18 based octocopter running 18” propellers. The Octocopter is 1800mm in 

diameter, running a Pixhawk flight controller and operated over both 2.4ghz and 

900mhz frequencies. AUW will depend on camera being used (setup for multiple) and 

will be under 55lbs regardless of payload.

Two Kong Kopter based quadcopters running 18” propellers and having a 900mm 

diameters and running Pixhawk flight controllers operated over both 2.4ghz and 900mhz 

frequencies. AUW will be under 20lbs each depending on cameras used by application

A Tarot 680 based hexacopter with 13” propellers having a 700mm diameter running 

Pixhawk flight controllers operated over both 2.4ghz and 900mhz frequencies. AUW 

will be under 9lbs.

Fixed Wing:

An AgEagle Rapid 1 flying wing using a single electric motor and designed and built for 

agriculture surveillance and mapping. The Rapid 1 will be rail launched in field to run 

autonomous missions complying with VFR rules and will be carrying a Micasense 5 

band camera. The AUW will be under 20lbs

All aircraft will be operated using Lithium Polymer batteries bought commercially 

specifically for use in unmanned aircraft. 

The UAS's that will be operated by Eagles View Aerial, will be registered in accordance 

with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and 

Registration Marking.

BASIS FOR PETITION

Petitioner, Eagles View Aerial, pursuant to the provisions of the Federal

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act

of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems,

hereby petitions the Administrator to commercially operate the above mentioned UAS's 

in the National Airspace System (NAS), and for an exemption from the

Unmaned Aircraft Systems requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated
with the unmanned aircraft and its operation, Eagles View Aerial L.L.C. operation of the 

aforementioned UAS's meets the conditions of FMRA Section 333

and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R.

Part 21, Subpart H. Accordingly, Eagles View Aerial requests relief from Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections 

set forth requirements for maintenance that only apply to aircraft with an airworthiness 

certificate.

Eagles View Aerial submits that the requested relief is proper since an

equivalent level of safety will be ensured. Eagles View Aerial will use experienced

personnel or technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS's using the methods, techniques, and practices prescribed in 

the operating documents (i.e., Monthly Maintenance Log, and Pixhawk/flight control 

instruction manuals). Furthermore, Eagles View Aerial will document and maintain

all maintenance records for the aforementioned UAS's as well as maintain flight logs for 

all commercial flight operations. The flight logs will be provided in raw digital format and 

as required, compiled into digital spreadsheet format and available to the FAA or 

aviation authorities upon request. The flight logs include position, location, duration, 

altitude, attitude, system information and errors, and other information pertinent to the 

safe operation of the UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot

privileges and limitations: Pilot in command, is requested by Eagles View Aerial to the

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher 

level certificate, as well as an airman medical certificate, and who has demonstrated, by 

meeting minimum flight- hour and current requirements, that the PIC is able to safely 

operate the aforementioned UASs, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures.

Eagles View Aerial seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the aforementioned UAS's do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such,

Eagles View Aerial submits that they will ensure that the aforementioned UASs are in 

an airworthy condition, prior to every flight, by determining that the

UAS's are in compliance with the operating documents (i.e., Monthly Maintenance Log,

Flight control Instruction Manual), and that the aircraft are in a condition for safe flight

through an extensive physical inspection of the UAS. Eagles View Aerial also seeks an 

exemption from the requirements of Section 91.121, entitled Altimeter Settings. The 

UAS's will all have barometric altimeters onboard that will be used to control and limit 

altitude and these will be used for both controlling altitude (limiting) as well as logging 

the flight operation. However, the altitimeters are not programmable/do not operate in 

the same manner as full scale aircraft and as such will be used in conjunction with 

Global Positioning System (GPS) equipment and radio communications telemetry data 

link, to which downlinks from the UAS to the GCS for active monitoring of the flight path. 

This altitude information, combined with Eagles View Aerials operation of the 

aforementioned UAS's within visual line of sight, at or below 400 feet AGL, will ensure a 
level of safety equivalent to Section 91.121. Additionally, Eagles View Aerial seeks an 

exemption from the requirements of Section 91.151(b), entitled Fuel requirements for 

flight in VFR conditions. Eagles View Aerial submits that safety will not be affected by 

operation of the aforementioned UAS's during daylight hours in visual meteorological 

conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a 

total duration of approximately 45 minutes for the intended data gathering or 

photo/video activities and, assuming normal cruising speed, to fly after that for at least 

2.5 minutes for recovery and landing. In accordance with 14 C.F.R. § 11.81, Eagles 

View Aerial provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner

The name and address of the Petitioner and point of contact is:

Paul Barsamian

Eagles View Aerial L.L.C.

2426 Robincrest Lane

Glenview IL, 60025

847-778-0874

Email: pbarsamian@eaglesviewaerial.com

B. The Specific Sections Of 14 C.F.R. From Which Eagles View Aerial seeks

Exemption

1. Eagles View Aerial Seeks Exemption From The Requirements Of

Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for compensation or

hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2.Eagles View Aerial Seeks Exemption From The Requirements Of

Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the

following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Eagles View Aerial Seeks Exemption From The Requirements Of Section

91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in

part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraft, as the case may be, by reference to an altimeter that is set,
when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of

this section, the current reported altimeter setting of an appropriate

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the

departure airport or an appropriate altimeter setting available before

departure.

4. Eagles View Aerial Seeks Exemption From The Requirements Of

Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing and, assuming normal cruising speed, to

fly after that for at least 20 minutes.

5. Eagles View Aerial Seeks Exemption From The Requirement Of

Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected 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[.]

6. Eagles View Aerial Seeks Exemption From The Requirements Of

Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration,subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under §

43.7 of this chapter.

7. Eagles View Aerial Seeks Exemption From The Requirements Of

Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has

been approved for return to service by a person authorized by § 43.7 of this

chapter or
(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter.

8. Eagles View Aerial Seeks Exemption From The Requirements Of

Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

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(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100-hour, annual, progressive, and other required or approved

inspections, as appropriate, for each aircraft (including the airframe) and

each engine, propeller, rotor, and appliance of an aircraft. The records must

include--

(i) A description (or reference to data acceptable to the Administrator) of

the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and

each rotor.

(ii) The current status of life-limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the

last inspection required by the inspection program under which the

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or

Safety directive number and revision date. If the AD or safety directive

involves recurring action, the time and date when the next action is

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained

until the work is repeated or superseded by other work or for 1 year after the

work is performed.

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(2) The records specified in paragraph (a)(2) of this section shall be retained
and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of

this chapter shall be retained until the defects are repaired and the aircraft is

approved for return to service.

C. The Extent Of Relief Eagles View Aerial Seeks And The Reason Eagles View 

Aerial Seeks The Relief.

1. Extent Of Relief Eagles View Aerial Seeks And The Reason Eagles View Aerial

Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and

limitations: Pilot in command, is requested to the extent necessary to allow a PIC 

holding a private pilot or higher level certificate, as well as a current and valid airman 

medical certificate, and who has met certain flight-hour and currency requirements, to 

conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and

(b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if: (1) The flight is only incidental to that

business or employment; and (2) The aircraft does not carry passengers or property for

compensation or hire. As set forth more fully below, Eagles View Aerial submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate 

the aforementioned UAS's unless that PIC has met certain flight-hour and

and current requirements, demonstrating that the PIC is able to safely operate either the

aforementioned UAS's in a manner consistent with the operations

specifications as described in this exemption, including evasive and emergency 

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles 

and structures.

Further, Eagles View Aerial submits that all flights of the afore mentioned UASs, 

conducted by the PIC pursuant to the grant of this Petition: (1)

will be incidental to Eagles View Aerial's business; and (2) will not carry passengers for 

compensation or hire.

2.Extent Of Relief Eagles View Aerial Seeks And The Reason Eagles View Aerial

Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the

extent required to allow Eagles View Aerial to determine that the aforementioned UAS's 

are in airworthy condition prior to every flight by ensuring that the UAS is in compliance 

with the operating documents (i.e., the Monthly Maintenance

Log and flight control manuals.)

Eagles View Aerial seeks the requested relief because the aforementioned UAS's do 

not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. Therefore, Eagles View Aerial will ensure that the 

aforementioned UAS's are in airworthy condition based upon its compliance

with the operating documents (i.e., Monthly Maintenance Log, and flight control 

Instruction Manual) prior to every flight, and further, determine that the

aircraft are in condition for safe flight, as stated in the conditions and limitations below.
3. Extent Of Relief Eagles View Aerial Seeks And The Reason Eagles View Aerial

Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow

flight operations of the Aforementioned UAS's, which utilize a barometric pressure 

sensor, GPS equipment, and a radio communications telemetry data

link to downlink altitude information from the UA to the PIC at the ground control station

(GCS). Since the FAA requires that any altitude information concerning UAS operations 

be reported to air traffic control (ATC) in feet above ground level (AGL), Eagles View 

Aerial seeks the requested relief because the aforementioned UAS’s altimeters may be 

set on the ground to zero feet AGL, rather than the local barometric

pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR

91.121 is sought to the extent necessary to comply with the applicable conditions and

limitations stated below. As more fully set forth herein, an equivalent level of safety will

be maintained since the aforementioned AP UAS's are equipped with a barometric 

pressure sensor and GPS equipment, which automatically ensures that a ground

level pressure setting will be established prior to each flight, and provides the PIC with

altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Eagles View Aerial Seeks And The Reason Eagles View Aerial

Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR

conditions, is requested to the extent required to allow flights of the battery powered 

aforementioned UAS's during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), for a total duration of 45 minutes to

the first point of intended landing and, assuming normal cruising speed, to fly after that 

for at least 2.5 minutes. Eagles View Aerial seeks the requested relief because without

an exemption from Section 91.151(b), the flight time duration of the battery powered 

UAS's will severely constrain the practicality of any aerial data gathering, video or still 

photo flight operations that Eagles View Aerial proposes to conduct pursuant to this 

Petition.

Significantly, as set forth below, the technical specifications of the aforementioned

UAS's, operating documents and Eagles View Aerial's proposed operating limitations, 

ensure that Eagles View Aerial will safely operate the battery powered UAS's during 

daylight hours in visual meteorological conditions (VMC), under visual flight

rules (VFR), with enough battery power to fly for a total duration of 45 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for 

at least 2.5 minutes.

5.Extent Of Relief Eagles View Aerial Seeks And The Reason Eagles View Aerial

Seeks Relief From Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

only apply to aircraft with an airworthiness certificate, Eagles View Aerial requests
relief from these Sections because the aforementioned UAS's do

not require airworthiness certificates. As set forth more fully below, the aforementioned

UAS's meet the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, Eagles View Aerial will use trained technicians

to perform maintenance, alterations, or preventive maintenance on the UAS's

using the methods, techniques, and practices prescribed in the UAS operating 

documents (i.e., the Aerial Operations Manual, Monthly Maintenance Log, and flight 

control Instruction Manual). Furthermore, Eagles View Aerial will document

and maintain all maintenance records for the aforementioned UAS's.

D. The Reasons Why Granting Eagles View Aerial Request Would Be In The

Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Eagles View 

Aerial to safely, efficiently, and economically perform aerial video and

photography of construction sites, real estate, and landscape over certain areas of the

United States. Additionally, use of the aforementioned UAS's will decrease congestion 

of the NAS, reduce pollution, and provide significant benefits to the economy. In 

addition, the use of Eagles View Aerial UAS for agriculture studies, data gathering, and 

crop health will assist farming operations in the US in boosting yield, reducing chemical 

use in farm fields, and provide more timeline information about crop stress and disease 

to local Co-ops and agriculture consulting. Notably, the benefits of Eagles View Aerial's 

proposed operation of the UAS's will be realized without implicating any privacy issues.

1.The Public Will Benefit From Decreased Congestion Of The NAS.

The aforementioned UAS's are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery and data in multiple operations. By reducing the amount of manned aircraft 

needed to perform aerial acquisitions, an exemption allowing the use of the 

aforementioned UAS's would reduce the amount of manned aircraft in the NAS, reduce 

noise and air pollution, as well as increase the safety of life and property in the air and 

on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports caused by arriving and departing aircraft will be reduced. 

The aforementioned UAS's do not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting agriculture data gathering, aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations.

2. The Public Will Benefit From The Safety And Efficiency Of The Afore Mentioned

UAS's.

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Conducting aerial acquisitions with the Afore mentioned

UAS's instead of manned aircraft, will greatly benefit the public by drastically reducing

the levels of air and noise pollution generated during traditional aerial video and still

photography flight operations. By using battery power and electric motors, the afore 

mentioned UAS's produce no air pollution, and is the most
viable environmentally conscious alternative to the cabin class, six cylinder internal

combustion engine aircraft that are typically utilized foraerial video and photography

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The afore 

mentioned UAS's, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UA's are propelled by battery powered

electric motors, rather than an internal combustion engine.

By using the afore mentioned UAS's to perform aerial

acquisitions, the substantial risk to life and property in the air and on the ground, which 

is

usually associated with traditional manned aircraft flight operations, will be substantially

reduced or completely eliminated. Aside from the lack of flight crew members located

onboard the aircraft, the Afore mentioned UAS's (weighing

under 55 lbs, at their maximum

gross weights with respectively (and with no fuel on board) has less physical potential

for collateral damage to life and property on the ground, and in the air, compared to the

manned aircraft that typically conduct similar operations (weighing approximately 6,000

pounds, and a fuel capacity of 180 gallons.

18

3. Performing Aerial Video and Photography Operations With The afore 

mentioned UAS's Will Benefit The Economy.

In addition to being safe and efficient, the Afore mentioned

UAS's are also an economical alternative to using manned aircraft to conduct similar 

aerial

operations. As such, operation of the Afore mentioned UAS's will

allow United States based companies, like Eagles View Aerial's to remain competitive

and contribute to growth of the U.S. economy. Specifically, with the rising cost of 

aviation

fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out

leaded aviation fuels, U.S. owned and operated companies must adopt new and 

alternative

technology in order to remain competitive. Operating the battery powered 

aforementioned UAS's is one such technology that not only allows companies greater

operational flexibility compared to manned aircraft, but provides such flexibility without

the high operational cost of a traditional manned aircraft.

By operating the afore mentioned UAS's, companies such

as Eagles view Aerial can remain competitive and profitable and therefore, provide

greater job stability to employees and contractors, which will ultimately contribute to

growth of the U.S. economy. Improved financial performance of U.S. companies, 

through

commercial use of the afore mentioned UAS's, provides a stable

workforce that increases consumer spending, improves local, state, and federal tax

revenues and allows companies to invest in research and development in order to 

remain

competitive both in the United States and abroad.

4.There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for
decades, Eagles View Aerial's proposed operation of the afore mentioned UAS's will not 

implicate any privacy issues. Specifically, the afore mentioned UAS's will be operated 

only in compliance with operating documents

documen ts (i.e. Aerial Operations Manual, Monthly Maintenance Log, and the afore 

mentioned UAS flight control systems Instruction Manual's) which requires property 

owner imvolvement as

well as local law enforcement notification, and in accordance with the Federal Aviation

Regulations, including the minimum altitude requiremants of 14 C.F. R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That

Provided By The Rule From Which Eagles View Aerial Seeks Exemption.

1. Reasons Why The afore mentioned UAS's Meet The

Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA)

Section 333.

In consideration of the size, weight, speed, and limited operating area associated

with the unmanned aircraft and its operation, Eagles View Aerial's operation of the

Afore mentioned UAS's meet the conditions of FMRA Section

333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21,

Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness

certification and sets forth requirements for considering whether a UAS will create a

hazard to users of the NAS or the public, or otherwise pose a threat to national security.

Specifically, FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not

later than 180 days after the date of enactment of this Act, the Secretary of

Transportation shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of the plan

and rulemaking required by section 332 of this Act or the guidance required by

section 334 of this Act.

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(b) Assessment of Unmanned Aircraft Systems.--In making the determination under

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their

size, weight, speed, operational capability, proximity to airports and

populated areas, and operation within visual line of sight do not create

a hazard to users of the national airspace system or the public or pose a

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United States

Code, is required for the operation of unmanned aircraft systems

identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this

section that certain unmanned aircraft systems may operate safely in the

national airspace system, the Secretary shall establish requirements for the safe

operation of such aircraft systems in the national airspace system.
In seeking this exemption, Eagles View Aerial submits that the afore mentioned UAS's 

can operate safely in the NAS pursuant to FMRA Section 333,

as demonstrated by: (a) the characteristics of the Afore mentioned

UAS's; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The Afore mentioned UAS's

Demonstrate Its Safe Characteristics.

The AforementionedUAS's do not create a hazard to users of the

NAS or the public, or otherwise pose a threat to national security considering its size, 

weight,

speed, and operational capability.

i. Technical Specifications Of The afore mentioned UAS's.

The technical specifications of the Afore mentioned UAS's

are set forth by the Afore mentioned Specifications and Data Sheet,

attached hereto as Exhibit A and B.

21

ii. The Afore mentioned UAS's Autonomous

Flight And Navigation Modes Enable The UAS's To Remain Within A

Defined Operational Area.

The afore mentioned UAS may be operated in both manual and fully autonomous flight 

modes.

Iii. The afore mentioned UAS's Are Designed For

Automatic Return To Home Point Or Hover and land In The Event Of Loss Of

The Control Link Or Navigation Abilities.

If the Control Link is lost, GPS navigation signals are lost, battery shows signs of decay, 

or if other component failures are detected, the afore mentioned UAS are programmed 

to maintain position while initiating a landing procedure or returning to home as able. 

These capabilities can be demonstrated and are logged as part of the flight log and 

navigation done during operation. Programming of the safety features is described in 

the Pixhawk open source documentation for the flight controller.

iv. The Afore mentioned GCS And Its

Operation.

A complete description of the operation and specifications of the afore mentioned UAS

and flight control software is provided on the Pixhawk online open source 

documentation as well as by AgEagle as required (Ag Eagle documentation is closed 

sourced and copywrited).

b. Flight Operations Of Afore mentioned UAS's

Are Limited To The Line Of Sight Of A Certificated Pilot in Command

With A Safety Observer.

Eagles View Aerial will only utilize certificated pilots who possess a current and
valid airman medical certificate to act as a pilot in command (PIC) of the afore 

mentioned UAS's. Additionally, a safety observer will assist all pilots during

flight time.

c. Flights Of Afore mentioned UAS's Will Be

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Eagles View Aerial proposes to commercially

operate afore mentioned UAS's for the special purpose of

conducting aerial video and photography over certain areas of United States, pursuant 

to

the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following

aircraft described in the operating documents, rotorcraft UAS's weighing less

than 55 pounds maximum gross weight: afore mentioned Unmanned Aircraft Systems. 

Proposed operations of any other aircraft will

require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations

for the purpose of aerial video and photography.

3. The UA may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must 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 unless a special request is made and approved by ATC. All altitudes

reported to ATC must be in feet AGL.

5. The UA's must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any

device other than corrective lenses, as specified on the PIC’s FAA-issued airman

medical certificate.

23

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not

permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy

the VLOS requirement as long as the PIC always maintains VLOS capability.

The SO 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 or her designation for the

duration of the flight. The PIC must ensure that the SO can perform the

functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing

and avoiding other air traffic and other ground based obstacles/obstructions and

is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during

UAS operations and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations contained in the grant

of exemption and the procedures outlined in the operating documents, the

conditions and limitations contained in the grant of exemption take precedence

and must be followed. Otherwise, the operator must follow the procedures as

outlined in its operating documents. The operator may update or revise its
operating documents. It is the operator’s responsibility to track such revisions

and present updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for

extension or amendment to the grant of exemption. If the operator determines

that any update or revision would affect the basis upon which the FAA granted

the exemption, then the operator must petition for amendment to its grant of

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if

questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a

condition for safe flight. If the inspection reveals a condition that affects the

safe operation of the UAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical

component, must undergo a functional test flight. The PIC who conducts the

functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g.

inoperable components, items, or equipment, not already covered in the

relevant sections of the operating documents.

24

13. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. maintenance,

inspection, alterations, and status of replacement/overhaul component parts

must be noted in the aircraft records, including total time in service, description

of work accomplished, and the signature of the authorized person returning the

UAS to service.

15. Each UAS's operated under this exemption must comply with all manufacturer

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the

corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current

third-class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the

operator’s qualification criteria and demonstrates the ability to safely operate

the UAS in a manner consistent with how the UAS will be operated under the

exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours must be logged in a manner consistent with 14 C.F.R.

§61.51(b). Flights for the purposes of training the operator’s PIC's are

permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training,
proficiency, and experience-building 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 C.F.R. §

91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the FAA

office closest to proposed area of operations. Flights under special visual flight

rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA published aeronautical chart unless a letter of

agreement with that airport’s management is obtained, and the operation is

conducted in accordance with a NOTAM as required by the operator’s COA.

The letter of agreement with the airport management must be made available to

the Administrator upon request.

25

21. 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.

22. If the UA loses communications or loses its GPS signal, it must return to a 

predetermined

location within the planned operating area and land or be recovered

in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or

emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is enough power to fly at normal cruising

speed to the intended landing point and land the UAS with 25% battery power

remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate

of Waiver or Authorization (COA) prior to conducting any operations under the

grant of exemption. This COA will also require the operator to request a Notice

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48

hours prior to the operation. All operations shall be conducted in accordance

with airspace requirements in the ATO issued COA including class of airspace,

altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by

serial number, registered in accordance with 14 C.F.R. part 47, and have

identification (N-Number) markings in accordance with 14 C.F.R. part 45,

Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation

and control of the UAS must comply with the Federal Communications

Commission (FCC) or other appropriate government oversight agency

requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be

available to the PIC at the Ground Control Station of the UAS any time the
UAS is operating. These documents must be made available to the

Administrator or any law enforcement official upon request.

29. The UAS must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating

persons (persons other than the PIC, SO, operator trainees or essential persons),

vessels, vehicles, and structures unless:

26

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UAS and/or debris in the event of an accident. The

operator must ensure that nonparticipating persons remain under such

protection. If a situation arises where nonparticipating persons leave such

protection and are within 500 feet of the UA, flight operations must cease

immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted

permission and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present

an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons

do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property

with permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable COA

must be reported to the FAA's UAS Integration Office (AFS-80) within 24

hours. Accidents must be reported to the National Transportation Safety Board

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a)

And (b) Would Not Adversely Affect Safety.

Eagles View Aerial submits that the equivalent level of safety established by

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate

the afore mentioned UAS's unless that PIC has demonstrated, by

meeting minimum flight-hour and currency requirements, that the PIC is able to safely

operate the afore mentioned UAS in a manner consistent with the

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

Considering Eagles View Aerial's proposed area of operations, and the

operating limitations set forth-above; the parallel nature of private pilot aeronautical

knowledge

27

requirements to those of commercial pilot requirements (See Exemption No. 11062); 

and
the airmanship skills necessary to safely operate the afore mentioned UAS, Eagles 

View Aerial submits that the additional manned airmanship experience

of a commercially certificated pilot would not correlate to the airmanship skills necessary

for Eagles View Aerial's specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to

UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112,

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Eagles View Aerial will not allow any PIC to operate the afore mentioned UAS unless 

that PIC has demonstrated, by meeting minimum flight-hour requirements of the afore 

mentioned UAS training and currency requirements, that the PIC is able to safely 

operate the afore mentioned UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels,vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a

minimum of 5 hours of those hours as a UAS pilot operating the same make and model 

of UAS to be used for operations under the exemption). In addition to the hour 

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight

experience that was obtained in compliance with applicable regulations will ensure an

equivalent level of safety during Eagles View Aerial's proposed operations. The

Administrator has held that prior documented flight experience that was obtained in

compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for

the purpose of motion picture filming (or similar operations), the PIC must have

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot

operating the same make and model of UAS to be used for operations under the

exemption. For clarification, the FAA considers these minimum hour requirements

to be inclusive rather than additive; i.e. 5 hours make and model time may be

included in the 10 hours of multi-rotor time and the 10 hours may be included in

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for

currency purposes). The FAA finds that at a minimum, the flight-hour requirements

in Exemption No. 11062 are appropriate to practice and build proficiency in the

skills necessary to safely conduct the petitioner’s proposed operations. The FAA

also finds that prior documented flight experience that was obtained in compliance

with applicable regulations would satisfy this requirement. Training, proficiency,

and experience-building flights can also be conducted under the grant of exemption

to accomplish the required flight time. During training, proficiency, and
experience-building flights the PIC is required to operate the UA with appropriate

distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Eagles View Aerial will ensure safe operations by not allowing

any PIC to operate the Aforementioned UAS unless that PIC has

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC

is able to safely operate the Aforementioned UAS in a manner

consistent with the exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from people, vessels, vehicles and structures.

29

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained

because prior to every flight, Eagles View Aerial will ensure that the afore mentioned

UAS is in an airworthy condition based upon the UAS’s

compliance with its operating documents and as stated in the conditions and limitations

herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific

to UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of the afore mentioned UAS's will

will be provided to the PIC via GPS equipment and a radio communications telemetry 

data

link, which downlinks from the UA to the GCS for active monitoring of the flight path and

altitude. This altitude information, combined with Eagles View Aerial's operation of the

afore mentioned UA's within visual line of sight, at or below 400

feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude

information will be generated by GPS equipment installed on board the aircraft. Prior to

each flight, a zero altitude initiation point is automatically established by the UAS's at

ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

30

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the afore 

mentioned UAS's; (2) the limitations on the proposed flight
operations; and (3) the location of the proposed flight operations. Accordingly, Eagles 

View Aerial will ensure that he will safely operate the battery powered afore mentioned

UA's during daylight hours in VFR conditions, with enough

battery power to fly for a total duration of 10 minutes to the first point of intended

landing and, assuming normal cruising speed, to fly after that for at least 2.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the afore mentioned

UAS's the limitations on the proposed flight operations and the location of the proposed 

operations, will ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the afore 

mentioned UAS's provide audible and visual warnings to the PIC at the

GCS when the UA's experiences low battery voltage, the first warning occurring at

approximately 33% remaining battery power, and again at approximately 10% 

remaining battery power. At the critically low battery level, the afore mentioned UAS's 

will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristics and

operating limitations of the UAS are considered. Relief has been granted for manned

aircraft to operate at less than the minimums prescribed in Section 91.151, including

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted 

relief from Section 91.151 specific to UAS in circumstances similar in all material 

respects to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 

11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 

11156,

11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) &(b)

Would Not Adversely Affect Safety.

In seeking this exemption, Eagles View Aerial submits that the equivalent level

of safety with regard to the regulatory maintenance and alteration requirements 

established

by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be

met because Eagles View Aerial will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UAS's using the methods, techniques, 

and

practices prescribed in the operating documents i.e., the Operations Manual, Monthly

Maintenance Log, and Afore mentioned Instruction Manual.

Furthermore, Eagles View Aerial will document and maintain all maintenance records

for the Afore mentioned UAS's.

Since the Afore mentioned UAS's will be inspected as

prescribed by the operating documents, Eagles View Aerial will maintain the equivalent

level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A 

copy

of the Afore mentioned User Manuals are attached hereto as
Exhibit C and D; a copy of the afore mentioned UAS

Maintenance LOG is attached hereto as Exhibit E.

Likewise, the exemption sought will not adversely affect safety because Eagles View 

Aerial will use trained technicians to perform maintenance, alterations or

preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety

Established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of 

the afore mentioned UAS's will be performed by trained technicians.

Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety 

is

not adversely affected when the technical characteristics and operating limitations of the

UAS are considered.

In consideration of Eagles View Aerial's proposed operating limitations, the

operating documents, and the technical aspects of the afore mentioned UAS's, Eagles 

View Aerial submits that safety will not be adversely affected by

granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 

91.409(a)

(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in

circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Eagles View Aerial requests

that the FAA prescribe special conditions for the intended operation of the afore 

mentioned UAS's, which contain such safety standards that the administrator finds 

necessary to establish a level of safety equivalent to that established

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such

special conditions will permit safe operation of the UA's for the limited purpose of

conducting aerial video and photography over certain areas of the United States for

compensation or hire. FMRA Section 333 sets forth the requirements for considering

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose

a threat to national security and further, provides the authority for such UAS to operate

without airworthiness certification in accordance with any requirements that must be

established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§21.16, for operation of the Afore mentioned UAS's, since the airworthiness regulations 

of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to 
the novel or unusual design features of the aircraft. Section 21.16, entitled Special 

Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

because of a novel or unusual design feature of the aircraft, aircraft engine or

propeller, it may prescribe special conditions and amendments thereto for the product.

The special conditions are issued in accordance with Part 11 of this chapter and

contain such safety standards for the aircraft, aircraft engine or propeller as the

FAA finds necessary to establish a level of safety equivalent to that established in

the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA

may prescribe special conditions for Eagles View Aerial's intended operation of the 

afore mentioned UAS's, which contain such safety standards that the administrator finds 

necessary to establish a level of safety equivalent to that established by

14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register stating: The Rules

From Which Eagles View Aerial Seeks Exemption:

Eagles View Aerial seeks exemption from the requirements of 14 C.F.R Sections

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Eagles View Aerial Seeks:

This exemption will permit Eagles View Aerial to commercially operate an

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and

photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Eagles 

View Aerial's Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if 

certain

UAS may operate safely in the NAS. As such, Eagles View Aerial request for exemption

may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, 

as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will

create a hazard to users of the NAS or the public, or otherwise pose a threat to national

security and further, provides the authority for such UAS to operate without 

airworthiness

certification.

As discussed in detail above, Eagles View Aerial will operate the afore mentioned

UAS's safely in the NAS, without creating a hazard to

users of the NAS, or the public, or otherwise pose a threat to national security.
CONCLUSION

As set forth herein, Eagles View Aerial seeks an exemption pursuant to 14

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA), which will permit safe operation of the afore mentioned UAS's commercially, 

without an airworthiness certificate, for the limited purpose

of conducting aerial video and photography over certain areas of the United States.

By granting this Petition, the FAA Administrator will be fulfilling the Congressional

mandate of the FAA Modernization and Reform Act of 2012, while also advancing

the interests of the public, by allowing Eagles View Aerial to safely, efficiently,

and economically operate the Afore mentioned UAS's

commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, Eagles View Aerial respectfully

requests that the Administrator grant this Petition for an exemption from the 

requirements

of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Eagles View Aerial to operate the

Afore mentioned UAS's commercially for the purpose of conducting

aerial video and photography over certain areas of the United States.

Dated: September 9th, 2015

Respectfully submitted,

Eagles View Aerial L.L.C.