Nikolaos K. Louvros April 29, 2015

177 Stevens St

Wellsville, NY 14895

Cell: (585)808-8140

Email: louvros@gmail.com

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave., 

SE Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 

Attachments:

1) Phantom 2 Vision+ User Manual V1.8

2) Phantom 2 Vision Plus (Quick Start Guide) 

3) Phantom pilot training guide V1.1 

4) Preflight Checklist

References: 

1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 

 in the matter of the petition of DOUGLAS TRUDEAU 

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the matter of the petition of 

ADVANCED AVIATION SOLUTIONS LLC 

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter of the petition of 

FLYING CAM INC 

Dear Sir or Madam, 

 In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under

section 333 of the FAA Modernization and Reform Act of 2012, I Nikolaos K. Louvros, referred to 

hereafter as the petitioner, request exemption from the following sections of Title 14, Code of Federal 

Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409

(a)(1); 91.409(a)(2); 91.417(a) & (b);

 In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the 

Federal Aviation Administration (FAA) for the purposes of aerial photography, cinematography, 

videography, and other flight operations that could be performed safely and more cost effectively with 

the use of small UAS at low altitude within the U.S. national airspace system as compared to a manned 

aircraft. Operations will be performed only at the request of and with the authorization and permission 

of clients or their authorized agents in order to facilitate commerce and raise awareness of the 

beneficial uses of small unmanned air systems.

 So long as such operations are conducted within and under the conditions outlined herein or as may 

be established by the FAA as required by Section 333. The conditions identified and proposed by the 

petitioner are drawn from references 1-3.
The FARs

The petitioner seeks exemption from the above mentioned FARs for the following reasons;

61.113(a) & (b);

 The petitioner requests relief in order to facilitate the utilization of an experienced UAS operator with 

the addition of a trained observer. All pre-flight inspection, maintenance and flight logs will be saved 

and made available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of 

safely integrating civil UAS operation in the National Airspace System.

91.119(c)

 As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 

feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects 

that would not be possible without additional relief. The petitioner requests modification, waiver or 

exemption and clarification concerning the terms “congested areas” and “densely populated”. 

The petitioner requests waiver for this condition to allow reasonable and responsible operations in areas 

of subdivisions and neighborhoods if required. The petitioner will primarily operate the UAS between 

ground level and 400 feet. The UAS will be operated over designated properties with the owner’s consent 

and while maintaining a safe distance from persons. The petitioner will compile flight data from the logs. 

This data may assist the FAA in development of regulations for commercial operations in low-risk, 

controlled environments.

91.121

 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not 

have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information.

91.151(a)

 As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has 

been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption 

Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 

8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in 

percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information 

provided in the operating documents discusses procedures regarding remaining battery power 

management. Those documents contain a condition in which the PIC will initiate a landing procedure 

when battery remaining reaches a specified level. Given the limitations on proposed operations and the 

location of those proposed operations, The FAA found that a reduced minimum power reserve for flight 

in daytime VFR conditions was reasonable.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b)

 As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and 

ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The 

FAA found that adherence to the petitioner’s operating documents and the conditions and limitations 

specified, describing the requirements for maintenance, inspection, and recordkeeping, were sufficient to 

ensure that safety would not be adversely affected.
The UAS

 The DJI Phantom 2 vision plus is a highly successful consumer grade small rotorcraft in the 

quadcopter configuration with an advertised weight of less than 44 Ounces (1242g) designed primarily to 

carry aloft a high definition camera. It has an advertised maximum speed of less than 30 knots (15m/s) 

and a maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by four electric motors 

with a distance between motors of less than 14 inches (350mm). It utilizes an internal inertial measuring 

unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to 

maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio 

control (RC) unit. Real time video and telemetry information is transmitted back to a ground control 

station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), 

distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for 

either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum 

altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 25 minutes. 

The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a 

low battery state. An automatic termination of flight and landing will be initiated when the battery reaches 

a predetermined low state. It is anticipated that flights will usually last less than 12 minutes. More 

information is available in attachment 1.

Risk mitigation

 The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and Limitations section and 

believes that the procedures specified therein are reasonable and will be utilized in order to manage and 

mitigate risk and ensure public safety. A preflight checklist (see attachment 4) will be developed and 

employed to ensure that the UA airworthiness will be verified before launch. Airworthiness will be 

maintained by performance of routine inspections before each flight, maintaining flight and maintenance 

logs to record time on failure prone components. These documents will be made available to the FAA and 

SoT to assist in future implementation of safety standards and regulations. The petitioner will only 

operate the UAS over designated properties with the owner’s consent. Flight plans will be predetermined 

to limit the UASs flight time and limit safety concerns. The petitioner will take into account distance from 

persons and potential flight obstacles prior to operating the UAS. UAS operation will always be within 

VLOS of the PIC and the observer.

Public interest

 Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental 

impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying 

a crew and flammable fuel. Additionally, use of the UAS in order to facilitate commerce could lead to 

economic growth. Operations for this petition will enable service for property owners or their designees 

seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic 

subjects that cannot be displayed through ground level videography/photography. Aerial photography is a 

valuable marketing tool that can lead to increased commerce and enhance personal photography. Aerial 

surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce 

risks. The petitioner will provide clients with photographic data for these purposes on a

‘for hire’ basis acting as an independent contractor. A visual observer will be utilized. Flight data 

including UA flight time, Control Unit operation time, incident, accident, and details concerning any 

deviations from normal operations will be available to FAA for use in collecting data regarding the use of 

UAS as part of this application. This data may be submitted to FAA via traditional means or other means 

as required.
Conclusion

 The petitioner is requesting this exemption for the purposes of “aerial photography, cinematography, 

videography, inspections and other flight operations”. The reason for such a general and broad based 

request is that the petitioner wishes to utilize a business strategy of horizontal integration and maximize 

economies of scope in order to capitalize on opportunities as they may arise in the future without the long 

turnaround time associated with additional exemptions. The petitioner's business model is based on the 

idea of offering ad hoc small UAS services to individuals or companies who wish to employ these 

services as a safe, effective, and legal option to enhance their business or hobby. The petitioner has 

refrained from engaging in commercial use of the UAS. The primary purpose of seeking this exemption is 

to obtain the capability to offer those services while remaining in compliance. The petitioner has 4 years 

of experience in the radio control model aircraft hobby, and 3 years of experience with at home flight 

simulation.

Respectfully submitted,

Nikolaos K Louvros