Jason Lines, Aerovista LLC

7440 S Juniper St.

Tempe, Arizona 85283

Telephone : 602

- 492

- 6157

Email: jlines@aerovista.biz

July 2 0 , 2015

U. S. Department of Transportation

Docket Management System

West Building Ground Floor, Room w12

- 140

1200 New Jersey A venue, SE

Washington DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam :

We respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of

the Federal Aviation Regulations

.

Petitioner:

Jason Lin es, Aerovista LLC (AEROVISTA)

7440 S Juniper St.

Tempe, AZ 85283

Telephone: 602

- 492

- 6157

Email: jlines@aerovista.biz

AEROVISTA intends to incorporate the use of sUASs for a variety of projects which may

include but not be limited to project and construction management, inspections and monitoring;

environmental review projects; aerial surveying; agricultural projects; educational and research

projects; remote sensing projects, wildlife and forestry monitoring projects; aerial filmma king,

photography and real estate purposes; search and rescue, etc.

Specific Section(s) seeking exemption:

14 C.F.R Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b)(2)

14 C.F.R. 91.109

14 C.F.R. 91.119U. S. Dep artment of Transportation

Docket Management System

July 20, 2015

Page Two

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) and (b)

14 C.F.R. 91.215

14 C.F.R. 91.104 through 91.417

Extend of relief requested:

To permit commercial operation of Sm all Unmanned Aircraft Systems (sUASs) for operations

conducted within and under the conditions outlined herein or as may be established by the FAA

as required by Section 333.

Said exemption would permit the operation of sUASs under controlled conditions i n limited,

predetermined and controlled airspace. Upon granting of this proposed exemption request,

AEROVISTA would conduct commercial operations of sUASs meeting or exceeding all

operational and safety requirements per Section 333.

Public Benefit:

1. Project and construction management, inspections and monitoring. The use of sUASs on

construction sites may improve the safety of workers, local residents and general public

by assessing potential dangerous situations. Falls and injuries may be reduced or

elimin ated 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 red uce environmental impact by reducing energy usage;

2. E nvironmental 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

helicopt ers or smal l aircraft may be eliminated;

3. Aerial surveying. The use of sUASs in connection with aerial surveying of smaller areas

may eliminate the use of helicopters or aircraft. This could provide a more cost effective,

safer and more energy efficient p roduct;

4. Agricultural projects. Wildlife and Forestry projects. The use of sUASs could assist with

surveying agricultural projects as well as wildlife and forestry projects by providing

information when problems occur, vermin infestation, fire hazards, et c.;

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. Educational and Research projects. The use of sUASs could provide information for said

projects in a more cost effective and efficient manner than other available options;U. S. Department of Transportation

Docket Management System

July 20, 2015

Page Three

7. Aerial filmmaking, photography and rea l estate purposes. The use of sUASs 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

8. 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.

Reas ons why the exemption would not adversely affect safety or how the exemption would

provide a level of safety at least equal to the existing rule.

Proposed operations using sUASs provide increased safety enhancement especially when

compared with helicopter s and aircraft for the following reasons:

1. The sUASs will weigh less than ten (10) pounds;

2. Flights will be operated within the visual line of sight of the pilot;

3. Maximum total flight time for each operational flight will be thirty (30) minutes. Flight

time s may be less than thirty (30) minutes as the UAS will continuously monitor battery

reserve and return to the ground station with at least 20% battery power reserved;

4. Flights will be operated at an altitude of 200 feet AGL. Flights w ill never exceed 400

f eet AGL;

5. Minimum crew for each operation will consist of the sUAS pilot and a Visual Observer;

6. A briefing will be conducted daily by all personnel working with said sUAS;

7. All onsite personnel and client employees will be required to execute a waiver.

Verb al/written consent will be required of all persons within 100 feet of flight operation;

8. Written and/or oral permission from relative property owners will be obtained prior to

operating the sUAS;

9. All permits, permissions, etc. will be obtained from local go vernment offices as required;

10. The sUAS operated will weigh less than 55 pounds including payload (camera, lens,

gimbal, etc.); and

11. The sUAS will operate at speeds less than 50 knots, hover and simultaneously move

vertically and horizontally;

12. The sUAS will have the capability to return and land at the pre

- determined location with

the Security Perimeter should the sUAS lose communication or GPS signal during any

operatio ns;

13. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies;

14. Operations will not be conducted over densely populated areas or heavily traffic

highways; and

15. Operations will not be conducted within five (5) NM of an airport or heliport.U. S. Department of Transportation

Docket Management System

July 20, 2015

Page Four

AEROVISTA will abide by all regulations including the following:

1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. Airworthiness

Certificates;

2. 14 C.F.R. 45.23 Display of marks; general and 45.29 Size of marks;

3. 14 C .F.R. 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133

Commercial pilot privileges and limitations;

4. 14 C.F.R. 91.7 Civil aircraft airworthiness;

5. 14 C.F.R. 91.9 Civil aircraft flight manual, marking and placard requirements;

6. 14 C .F.R. 91.109 Flight instruction; Simulated instrument flight and certain flight tests;

7. 14 C.F.R. 91.119 Minimum safe altitudes: general;

8. 14 C.F.R. 91.121 Altimeter settings;

9. 14 C.F.R. 91.151 Fuel requirements for flight in VFR conditions;

10. 14 C.F.R. 91.203 Civil aircraft: Certifications required;

11. 14 C.F.R. 91.205 Powered civil aircraft with standard category U.S. airworthiness

certificates: Instrument and equipment requirements;

12. 14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use;

13. 14 C .F.R. 91.401 Applicability;

14. 14 C.F.R. 91.403 General;

15. 14 C.F.R. 91.405 Maintenance required;

16. 14 C.F.R. 91.407 Operation after maintenance, preventive maintenance, rebuilding or

alteration;

17. 14 C.F.R. 91.409 Inspections;

18. 14 C.F.R. 91.411 Altimeter system and altitude reporting equipment tests and

inspections;

19. 14 C.F.R. 91.413 ATC transponder tests and inspections;

20. 14 C.F.R. 91.415 Changes to aircraft inspection programs; and

21. 14 C.F.R. 91.417 Maintenance records.

Privileges of exemption outside the United St ates.

AEROVISTA may wish to exercise the privileges of this exemption outside the United States

should a contract with a governmental office require same. All required rules and regulations

will be followed should this occur.U. S. Department of Transportation

Docket Management System

July 20, 2015

Page Five

Equipment and Specifications

.

3DR SOLO KIT ~ 3DR solo, 3DR Solo Gimbal, 3DR Solo Controller, 3DR Solo Propeller Set

– Black, 3DR Solo Battery Charger, 3DR Solo Controlle r Charger

Specifications:

Up to 26 minutes of flight time (20 with camera and Solo Gimbal),

HD video streaming to mobile

Top speed: 55 mph

Max Altitude: 400ft, per FAA rules

Weight: 1600 g; 1760 g with Solo Gimbal and GoPro

Wifi range: up to a half a mile, depending on environment

Controller with color screen and live flight data

Pixhawk 2 flight controller software

Customizable color LEDs for orientation

Solo Battery: 14.8 V LiPo (5200mAh)

Rechargeable controller batter: 2600 mAh/7.2 Vdc; lasts 4 hou rs (extendable battery available)

10x4.5 self tightening props

880 kV motors

Plug and play with 3

- axis Solo Gimbal from 3DR

SenseFly EBEE RTK

Specifications:

Weight (inc. supplied camera) Approx. 0.73 kg (1.61 lb)

Wingspan 96 cm (38 in)

Material EPP foa m, carbon structure & composite parts

Propulsion Electric pusher propeller, 160 W brushless DC motor

GNSS/RTK receiver L1/L2, GPS & GLONASS

Battery 11.1 V, 2150 mAh

Maximum flight time 40 minutes

Nominal cruise speed 40

- 90 km/h (11

- 25 m/s or 25

- 56 mph)

Rad io link range Up to 3 km (1.86 miles)

Maximum coverage (single flight) 8 km 2 / 3 mi 2 (974 m / 3,195 ft alt. AGL)

Wind resistance Up to 45 km/h (12m/s or 28 mph)

Multi

- drone operation Yes (inc. mid

- air collision avoidance)

Automatic 3D flight planning Yes

L inear landing accuracy Approx. 5 m (16.4 ft)

Please feel free to contact our office if there are any additional questions or concerns.