## Vector Aerial Images, LLC **10301 Terry LN Portage, MI 49002** 

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

**Petition for Section 333**  **Exemption to Operate Unmanned Aircraft Systems for Aerial Photography, Filming, Building and Tower Inspections** 
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), Vector Aerial Images is petitioning for an exemption from the Federal Aviation Regulations and other rules/statutes pertaining to unmanned aircraft systems. Section 333 of the FMRA addresses special rules for certain unmanned aircraft systems and grant the FAA authority to al low for the safe operation of certain unmanned aircraft systems (UAS) within the national airspace. Vector Aerial Images is here to provide the new technology of aerial filming and photography in the Southwest Michigan area. Our business will provide the Michigan area with the opportunity to give great aerial video and photography to the commercial business and community for the near future .



## Why **Granting this request would be in the public interest** Our UAS systems consist of the Tarot 1000 which will serve many functions for the local co mmunity. Vector Aerial Images will be using these UAS for building inspections, tower inspections, real estate photography and advertisement, local filming for commercials and small local events , in edition we have been involved with the local Portage Police and Fire Department and offering volunteer assistance should they need our services. This UAV will not only serve the local business purposes but also the local law enforcement and other community needs.Without this exemption we will not be able to serve the community with this great business and it would : 1. Enhance community awareness in geographical areas and uas usage, 2. Provide photography and videos , and commercials at less cost than conventional aircraf t . 3. Provide a significantly lower threat (accident impact and no flammable fuel) than manned aircraft, and carry no crew increasing safety in all proportions for tho se in the air and on the ground. This would also decrease congestion over lower altitudes , and lower the noise pollution over suburban areas. 4. Provide economic growth in our community for advertising and surveying our clients business’s. 5. Vector Aerial Images also provides videos and photography for free to our local schools churchs and non -profit organizations around our community. 

## Why the exemption would not adversely affect safety and how the exemption **would provide a level of safety at least equal to that provided by the rule** In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Vector Aerial Images operation of the Tarot 1000 UAS 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. Operations authorized by this grant of exemption will be limited to rotorcraft UAS weighing less than 55 pounds maximum gross weight: 1. The UAS must be operated at all times within visual line of sight (VLOS) of the operator or visual observer. 2. At all times the UAS must remain close enough to the operator for the operator to be capable of seeing the Aircraft with vision unaided by any device other than corrective lenses. 3. No person may act as an operator or VO for more than one unmanned aircraft op eration at one time. 4. Aircraft over 4.4 pounds may not operate over any persons not directly involved in the operation. 5. Daylight
- only operations 6. Must yield right
- of

-way to other aircraft, manned or unmanned. 7. May use visual observer 8. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 9. Minimum weather visibility of 3 miles 10. First
-person view camera cannot satisfy “see
- and
- avoid” requirement but can be used as long as requirement is s atisfied in other ways. 11. Maximum airspeed of 50 knots. 12. Operations in Class B, C, D and E airspace allowed with required ATC permission. 13. No reckless or careless operations.14. Maximum altitude of 400 feet AGL. 15. Requires prefli ght inspection by the operator before each flight 16. PI C may not operate the Aircraft if he or she knows or has reason to know of any physical or mental condition that would interfere with the safe operation of a small UAS. In operating the Tarot 1000 and safety will be my number one priority during all operations and events. T he Tarot 1000 is a safe UAS vehicle and has been proven in the field with many other UAS devi ces known to be in service. Both UAS platforms are a heavy lift aerial vehicle with all carbon fiber parts and 3 f ixed landing gear. I chose the Tarot 1000 UAS because of the fixed gear in the event that I should need to land quickly the gear are stationary in the down and locked position at all times and believe this is an important safety feature . This UAV offers more th an a 1000’ fpm rate of climb easily and only weighs a total of 18 lbs when fully loaded with a Canon 5D DLSR camera . The eight motors also offer enough power should one motor fail during flight. I have tested this theo ry by flying with seven motors and the Ironman performed very well for the payload that I will be using. This UAS is equipped with the latest technology from 3D Robotics and uses the Pixhawk flight controller. This flight controller is equipped with the entire standard features such as altimeter, magnetic compass, and gyros, but also with satellite GPS and sonar for close proximity to the ground. The functions available are stabilize mode which will be used at all times, GPS hold, altitude hold, and a return to home function which will always be used should any radio interference happen. Also, a battery safety mode will be used should the batteries get under a pre
- de scribed voltage. In any of these events, the Tarot 1000 will fly home to the predetermined take off point and land itself if neede d using GPS and sonar and will do so if any signal is lost or any battery is below a preset voltage. Operating procedures will follow guidelines that I am used to in my Part 121 Airline experience and I will treat it as such. Operations with the Tarot 1000 will not be conducted during night, as defined in 14 CFR § 1.1 or in wet moisture such as heavy fog or any light rain. Operations will not continue if such weather develops. The procedures will begin with logging every part of my flight time and maintena nce in a log book . The logbooks will consist of two separate logbooks from Jeppesen , one for maintenance and the other for flight time. Also the maintenance logbook will have the type of maintenance performed or any corrective actions taken to fix the discrepancy. In accordance with (14 CFR § 91.7 (a) (b)), e ach flight will begin with a “walk around” for a preflight safety checklist. I will have and create a physical paper checklist that will be followed for each flight that I can refer back to when needed. To remain safe from the public, The UAS will remain a far distance from the general public and will not over fly anyone not involved in the operation and not in the explicit agreement of the operation of the UAS . We realize this and will be subject to stri ctly maintaining a safe distance from the general public. I am requesting an exemption from 14 CFR § 91.119 but never to come within a 200’ proximity from the general public or anyone not involved in the agreement of UAS operation. T he UAS will maintain a distance of 200’ or greater from those persons . In addition, to not fly directly over any such person during the UAS operation. Some operations may require us to operate the UAS with in 500’ of any person not involved and not in direct agreement with th e UAS operation . These operations include inspections for certain city and municipal buildings and site s , over certain areas for police and fire departments suchas aerial accident sites including areas for insurance claims of vehicles and buildings within the city limits . I have obtained a radio operators license since I am a commercial airline pilot and all frequencies and equipment will be in compliance with the FCC. I am using the standard radio Frequency of 2.4 GHZ . As I am the sole owner of Vector A erial Images, LLC and will be the sole PIC (Pilot in Command) of the aerial UAS for the Tarot 1000 . My qualifications in the aviation industry include: **Airline Transport Pilot Airplane Multiengine Land** CL - 65 Type rating, DHC
- 8 Type rating SIC Privileges 8400 Total Time 8000 Turbine 4800 PI C 8100 Multiengine 1000 Instrument 384 Single Engine **Certified Flight Instructor Instrument, Ground Instructor Restricted Radio Telephone Operator Permit**  **First Class Medical** I (PIC) meet the flight review requirement s specified in 14 CFR § 61.56, and flight hours and currency are logged in a manner consistent with 14 CFR § 61.51(b). My qualifications in flying RC models airplanes extends to over 30 years of experience from flying gas and electric aircraft and off road buggies. The last 5 years I have been flying helicopter s with the last 2 years of that including RC quad copters. I have been flying the Tarot 1000 and for 1 year with no accidents or incidents. I have held a first class medical for over 12 years . 

## Vector Aerial Images is requesting exemption for these items listed below **due to the examples listed above**  **: 14 CFR part 21, Certification procedures for products and parts, Subpart H** 
**— Airworthiness**  **Certificates 14 C.F.R. Part 27 Airworthiness Standards:**  **Normal Category Rotorcraft 14 CFR part 36 associated noise certification and testing requirements**  **45.23 Aircraft Markings 91.7(a) Aircraft Airworthiness**  **91.103(b)(2) Preflight action 91.105 Flight crewmembers at stations**  **91.109 Flight instruction 91.119**  **Minimum safe altitudes 91.121 Altimeter settings**  **91.151 Fuel requirements for flights in VFR conditions 91.405 Maintenance required**  **91.407 Operation after maintenance 91.409 Inspections**  **91.417 Mai ntenance records** 

## A Summary That Can Be Published In **the Federal Register, stating:** The rules from which Vector Aerial Images seeks e xemption: Vector Aerial Images seeks exemption from the requirements of 14 C.F.R Sections part 21 Subpart H, Part27, part 36, 91.103(b)(2), 91.105 , 91.109 , 91.119 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) , 45.23 . 

## A Brief Description of the Nature of the Exemption **Vector Aerial Images Seek** **s:** Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL REGISTER: This exemption will permit Vector Aerial Images to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video , commercials, and photography over certain areas of the United States . Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: Part 21 Subpart H, Part27, part 36, 91.103(b)(2), 91.105 , 91.109 , 91.119 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), 45.23. 

## If you want to exercise the privileges of your exemption outside the united **states** Vector Aerial Images does not have a need to operate outside the United States 

## Additional Information, Views, **or Arguments Available t**  **o Support Vector Aerial**  **Images Request .**  Example A
- 3DR Robotics Pixhawk Specification (See Below) Example B
- Tarot Ironman 1000 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, Vector Aerial Images 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. As discussed in detail above, Vector Aerial Images will operate the Aircraft safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security. I would to sincerely thank you for your time in this matter. Sincerely, President Patrick Gage Vector Aerial Images 269 - 598 - 0165

## Example A**- 3DR Robotics PIXHAWK**  OVERVIE W The benefits of the Pixhawk system include integrated multithreading, a Unix/Linux- like programming environment, completely new autopilot functions such as sophisticated scripting of missions and flight behavior, and a custom PX4 driver layer ensuring tight timing across all process es. These advanced capabilities ensure that there are no limitations to your autonomous vehicle. Pixhawk allows existing APM and PX4 operators to seamlessly transition to this system and lowers the barriers to entry for new users to participate in the exci ting world of autonomous vehicles. The flagship Pixhawk module will be accompanied by new peripheral options, including a digital airspeed sensor, support for an external multi - color LED indicator and an external magnetometer. All peripherals are automatic ally detected and configured. 

### Pixhawk includes:

 Pixhawk autopilot  Buzzer  Safety switch button  3DR power module with XT60 connectors and 6 - position connector cable  Extra 6 - position cable to connect a 3DR GPS+Compass module  Micro USB cable  SD card and adapter  Mounting foam  3 -wire servo cable  I2C splitter module with cable 

### Features

 Advanced 32 bit ARM Cortex® M4 Processor running NuttX RTOS  14 PWM /servo outputs (8 with failsafe and manual override, 6 auxiliary, high - power compatible)  Abundant connectivity options for additional peripherals (UART, I 2 C, CAN)  Integrated backup system for in - flight recovery and manual override with dedicated processor and stand alone power supply  Backup system integrates mixing, providing consistent autopilot and manual overr ide mixing modes  Redundant power supply inputs and automatic failover  External safety button for easy motor activation  Multicolor LED indicator  High - power, multi -tone piezo audio indicator  microSD card for long - time high - rate logging 

### Options:

 PPM encoder for RC receivers that do not provide PPM output.  External USB and LED module for convenient status indicator and micro - USB port on your vehicle  Digital airspeed sensor for fixed -wing aircraft  Telemetry radios wi th one - mile range for two -way control, telemetry and datalogging via free mobile apps or PC/Mac/Linux ground station  u - blox GPS with compass (required for autonomous flight) 

### Sp ecifications:**Microprocessor:**

 32 - bit STM32F427 Cortex M4 core with FPU  168 MHz/256 KB RAM/2 MB Flash  32 bit STM32F103 failsafe co - processor **Sensors:**

 ST Micro L3GD20 3 - axis 16 - bit gyroscope  ST Micro LSM303D 3 - axis 14 - bit accelerometer / magnetometer  Invense nse MPU 6000 3 - axis accelerometer/gyroscope  MEAS MS5611 barometer **Interfaces:**

 5x UART (serial ports), one high - power capable, 2x with H W flow control  2x CAN  Spektrum DSM / DSM2 / DSM -X® Satellite compatible input up to DX8 (DX9 and above not supported)  Futaba S.BUS® compatible input and output  PPM sum signal  RSSI (PWM or voltage) input  I 2 C®  SPI  3.3 and 6.6V ADC inputs  External microUSB port **Pow er Sy** 

**stem:**

 Ideal diode controller with automatic failover  Servo rail high - power (7 V) and high - current ready  All peripheral outputs over- current protected, all inputs ESD protected **Weight and Dimensions:**

 We ight: 38g (1.31oz)  Wi dth: 50mm (1.96")  Thickness: 15.5mm (.613")  Length: 81.5mm (3.21")

## Example B **- Tarot Ironman 1000 UAS**  **Product Description :**  **Tarot IRON MAN 1000 FPV Octa**  **- Rotor 8 rotor Copter**  **Carbon Fiber Frame TL100B01**  **Description:** Tarot IRON MAN 1000 multirotor aircraft frame adopts imported Toray 3K plain carbon fiber woven CNC precision machining, 2.0mm carbon fiber plate is exceeding all other products in the market. The motor holder using 6061T6 CNC process. Full folding design, satisfied users' high portability requirements, particularly suited to do surveillance, remote sensing, mapping, airborne reconnaissance, Observed fire, life exploration, cable line patrol, farm monitoring, and other high mobile performance requirements. The overall use of materials and design standards higher than similar products, the full set rack with tripod weighs only 1.6KG. Carrying load 8kg, specially designed heavy load aircraft for meeting requirement of 5DII, RED EPIC, C300, FS100, FS700 and large
- scale video equipment. **Product parameters:**

- we ighs : 1.6KG

- Tube diameter: 25MM

- Wheelbase: 1020MM

- Rack diameter: 1070MM

- Total height: 38 0CM

- Center cover Specifications: 250 ¡Á 240 MM

- The equilateral triangle Installation of the motor mounting hole distance: 16MM/19MM/25MM/27MM **Specifications:**

- Pure carbon fiber on the main cover

- Pure carbon fiber under the body of the cover plate

- M3 the PTZ nut ¡Á 48

- Pure carbon fiber battery holder

- Manual