Vector Aerial Images, LLC

10301 Terry LN

Portage, MI 49002

FAA-2007-0001

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), United Services 

Automobile Association (USAA) 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 grants the FAA authority to allow 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. Vector 

Aerial has already had the opportunity to shoot a few commercials and programs around the Kalamazoo 

area. Without this exemption we will not be able to serve the community with this great business. Our 

UAS systems consist of the Tarot 1000 and Tarot T18 which will serve many functions for the local 

community. 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 will also be communicating 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.

In operating the Tarot 1000 and Tarot T18, safety will be my number one priority during all operations 

and events. Both the Tarot 1000 an Tarot T18 are very safe UAS vehicles and have been proven in the 
field with many other UAS devices known to be in service. Both UAS platforms are a heavy lift aerial 

vehicle with all carbon fiber parts and 3 fixed landing gear. The Tarot T18 is similar but has the foldable 

arms for transportation and storage. 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 UAS consist of eight Sunnysky 340 KV motors which 

offer more than enough powers to safe altitudes and can be done quickly if needed. Sunnysky motors are 

known for their excellent qualities and safe operation. They have given me no problems/failures with 

more than 50 hours of operation. This UAV offers more than a 1000’ fpm rate of climb easily and only 

weighs a total of 18 lbs when fully loaded with a Canon 5D DLSR. The eight motors also offer enough 

power should one motor fail during flight. I have tested this theory 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-described voltage. In any of these events, the Tarot 1000 will fly home to the predetermined take off 

point and land itself if needed 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 maintenance in a log book. The 

logbooks will consist of two separate logbooks from Jeppesen, one for maintenance and the other for 

flight time. Each logbook will have a section for the date, place, time of takeoff, time off landing, total 

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(b)), each 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. This will ensure that I will not miss any 

parts of the safety check before the flight. After landing there will also be a post flight safety check in 

making sure all required items are still functional, attached, and working in a safe manner. Wire 

connections will be attached with heat shrink and electrical tape to prevent open circuits and loosened 

wires/connections due to any chaffing or vibrations.

Beyond the preflight and post flight checklist that will be used, I will have weekly inspection interval that 

will be used. This will be done with a flashlight to observe any parts of the UAS that are not in good 

lighting and not with in plain eyesight. I will be looking for any loose or worn wires, nuts, bolts, burn 

marks or anything that could be missed that is not in my regular pre/post flight checklist. Yearly routine 

maintenance will be performed. This will similar to a C check done on a part 121 aircraft although not 

quite as extensive. Motors will be replaced if needed when showing where and tare. All bearing on the 

motors will be replaced along with bearings in parts of the hinges for the camera gimble and any bolts 
that have wear will also be replaced. The UAS will be partly disassembled and checked for any abnormal 

ware such as cracks or broken/loose parts. They will be replaced.

In accordance with the statutory mandate under Section 333(b)(1) the operational borders that I will be 

operating in will always be in visual line of sight (VLOS) for the UAS. I will also have a camera 

equipment operator operating the camera on the UAS. They will be with me at all times and will also be 

observing the UAS. We both have clear concise information given before the flight. We talk about any

obstacles and anything or anyone that may be of concern to the safety of the flight including people and 

additional observers. We are well aware of the people who may like to watch and we will also mention to 

others to keep their distance while we are using the UAS. We will also have signs in the future near our 

operation that will tell others to stay back from the UAS and to not talk to the PIC UAS operator during 

operation until the UAS has landed and shutdown with motors off. This is very important to not create 

undo distraction to the PIC. Communication between myself (PIC) and the observer will be made from 

Takeoff to touchdown. I have invested in Motorola voice operated radio (vox) systems with an ear piece 

and microphone. Naturally these are hands free and we will be using them at all times even when we are 

within earshot off each other. This will keep us in clear communication at all times.

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 strictly 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. The 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 the UAS operation. These operations include inspections 

for certain city and municipal buildings and sites, over certain areas for police and fire departments such 

as 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 Aerial Images, LLC and will be the sole PIC (Pilot in Command) of the 

aerial UAS for the Tarot 1000 and Tarot T18. 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 PIC 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 requirements 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 helicopters with the last 2 

years of that including RC quad copters. I have been flying the Tarot 1000 and Tarot T18 for 1 year with 

no accidents or incidents. I have held a first class medical for over 12 years. Before that time I held a 3rd

class medical since 1990.\

The proposed maximum operating speed and limited airspeed for the UAS will be no faster than 50 MPH.

We know from experience that the stopping distance is close to 18’ at high rate of speeds close to 40 

MPH beginning from full forward pitch of 30 deg., reaching full speed then to a full aft pitch deflection 

of 30 deg. and we have tested this. Being a good PIC involves knowing your UAS vehicles limitations 

and we have tested turning radius, start-stop distances, climb rates, descent rates, and other limitations. 

We are very pleased with the performance of this UAS. Because of the nature of our business in 

performing smooth operational camera shots we will not be operating anywhere close to the abilities of 

the Tarot 1000 UAS but it always good to know of those abilities when we may need them.

Staying out of clouds is of the utmost importance and would negate the VLOS rule. We will maintain at 

least 2000’ horizontally and 500’ below the clouds at all times keeping with the VFR distance 

requirements. At all times the UAS operation will never exceed 400’ and, in fact, will be much less than 

that within 5 miles or closer to any airport and subject to the airport managers approval and notification 

when appropriate. The majority of flight altitude’s (90%) will be with in 10-50’ AGL. Only occasional 

higher altitudes will be needed when surveying buildings, police or fire department issues.

The operations involved for our UAS do not require us to operate within close proximity of an airport or 

outside of the United States.

Vector Aerial Images is requesting exemption for these items listed below:

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates

14 CFR part 36 associated noise certification and testing requirements

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 Maintenance records8 Rev. 9/25/2014

I would to sincerely thank you for your time in this matter.

Sincerely,

Patrick Gage

Vector Aerial Images

269-598-0165