Date: Sept, 4 t" 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE Washington, DC 20590 

Re: Petition of Air Vision Industries, Inc. for an Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 

To Whom it May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 

C.F.R. Part 11, Air Vision Industries, Inc. ("COMPANY") hereby applies for an exemption from the Federal 

Aviation Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial 

vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting controlled flights for aerial 

security, monitoring and inspection of facilities, construction sites and structures, and additionally provide 

agriculture drought conditions data collection services. 

This petition for exemption is created based on information outlined in this Petition for Exemption, as 

well as but not limited to these accompanying COMPANY documents; 

1. Flight Operations Manual and; 

2. Operations Manuals 

(collectively referred to as " COMPANY' Operations Manuals") 

3. DJI Inspire 1 User Guide and; 

4. DJI Inspire 1 User Manual 

(collectively referred to as "Manufacturer's Manual").' 

The COMPANY submits these as well as other COMPANY supporting materials as confidential 

documents pursuant to 14 C.F.R. § 11.35 (b), as the materials contain confidential commercial and/or 

proprietary information that the COMPANY has not and will not share with others. Additionally, these 

documents contain operating conditions and procedures that are not generally available to the public and 

are protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq. 

1The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not 

limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training 

manuals, service information letters and, safety/service bulletins). 
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This Petition is organized as follows: 

I. Petitioner 

II. Description of Proposed Operations 

A. Aerial Security, Inspection and Agriculture Drought Conditions Data Collection Services. 

II. Relevant Statutory Authority 

IV. COMPANY' Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act 

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability 

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations 

Manuals 

V. Regulations From Which Exemption is Requested 

A. 14 C.F.R. Part 21, Subpart H— Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1) 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

C.14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements 

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance 

Inspections 

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations 

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) 

and (b): Carrying Civil Aircraft Certification and Registration 

H. 14 C.F.R. § 91.103: Preflight Action 

I. 14 C.F.R. § 91.109(a): Flight Instruction 

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes 

K. 14 C.F.R. § 91.121: Altimeter Settings 

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

VI. Drug and Alcohol Program 

VII. Public Interest 

VIII. Privacy 

IX. Federal Register Summary 

X. Conclusion 
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I. DESCRIPTION OF PETITIONER 

Based in Fresno, CA Air Vision Industries, Inc. Services has become a well-known aerial security and 

inspection company focusing on military, private and public facilities and structures adopting new 

technology solutions for the security industry. Air Vision Industries was created to coincide with our parent 

company Ameriguard Security Systems, Inc. AirVision Industries gives our existing security company the 

ability to provide additional benefits to our clientele in the form of a bird's eye viewing for the locations 

that we guard. We are able to do perimeter checks and reach remote areas of a location that are not easily 

accessible otherwise by traditional means. 

With more than 30 years of operations and 45 years of experience in the security business Air Vision 

Industries aims to develop and operate areal UAS security systems that will complete a total security 

network of guards on the ground and eye in the sky operations. With the deployment of a UAS security 

system, people, property, equipment and human lives can be protected providing immediate action from 

authorities and or security personnel. 

A very high level of danger exists for people where traditional methods use for security can and do break 

down quickly when video of an incident such as a roof top break in or a robbery takes place. With the 

deployment of UAS security systems, people, property, equipment and human lives can be protected by 

providing immediate action from authorities and or security personnel. 

The operations will be conducted in a controlled area such as a shipping yard or storage areas with airspace 

previously never used because of the confinement such controlled areas. Given the isolation of some of the 

monitored locations there will be no additional hazard in the NAS. The Company plans to expand into 

security mapping for precision water security and conservation. The Company seeks an exemption to allow 

for the commercial operations of small, 551bs UAS to facilitate this aerial security, monitoring and 

inspection of facilities, construction sites and structures, and additionally provide agriculture drought 

conditions data collection services. 

The contact information for Petitioner is as follows: 

Lawrence Garcia 

President 

Air Vision Industries, Inc. 

5470 W. Spruce Ave #102 

Fresno, CA, 93722 

559-271-5984 

Lawrence@ameriguardsecurity.com 

II. DESCRIPTION OF PROPOSED OPERATION 

COMPANY seeks an exemption pursuant to Section 333 of the Reform Act to operate the DJI Inspire 

1 UAS for the proposed operations discussed below. All UAS operations will occur under tightly 

controlled conditions at locations where COMPANY has received permission to operate from the 

landowner, controller or authorized representatives. 
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Sept, 4t" 2015 

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The proposed UAS operations will be conducted in accordance with the conditions and limitations of 

this Petition for Exemption and COMPANY Operations Manuals. As detailed in the COMPANY's 

Operations Manuals, all UAS operations will be limited to daytime VFR conditions, within visual line-ofsight ("VLOS") of the operator and or ("VO") visual observers, in uncontrolled airspace, and will occur at 

least 5 miles away from an airport. Moreover, COMPANY' Operations Manuals incorporate redundant 

safeguards to assure that the aircraft does not travel outside the controlled area of UAS operations, 

including GPS "geo-fencing" technologies. 

A. Aerial Security, Inspection and Agriculture Drought Conditions Data Collection Services 

COMPANY seeks to use small UASs for the purpose of conducting high level, aerial security, 

monitoring and inspection of facilities, construction sites and structures, and additionally provide 

agricultural drought condition data collection services. COMPANY has tailored its operations to meet the 

requirements established by the FAA in prior grants of exemptions authorizing commercial use of UAS in 

high level, aerial facilities and construction site inspection including: 

✓ ATAC Global LLC (Exemption No. 11794) 

✓ Legend Creative Group (Exemption No. 11789) 

✓ Precision Design & Drafting, Inc. (Exemption No. 11783) 

All UAS aerial security, monitoring and inspection of facilities, construction sites and structures 

operations will be conducted on COMPANY and other approved property in a controlled area, away from 

spectators and persons not involved. All UAS aerial security, monitoring and inspection of facilities, 

construction sites and structures will be conducted during daylight hours, VFR conditions, at altitudes 

below 400' AGL. As set forth below, COMPANY' operations provide a superior level of safety and 

quality compared to performing the same aerial security, monitoring and inspection of facilities, 

construction sites and structures using conventional fixed-wing aircraft or helicopters. 

COMPANY seeks to use small UASs for the purpose of conducting aerial security, monitoring and 

inspection of facilities, construction sites and structures. Traditional methods of aerial security, monitoring 

and inspection of facilities, construction sites and structures are extremely costly and present uncalled for 

risk, physical harm, serious injury and death to manned aircraft participants and pedestrians on the ground. 

Further, the use of traditional aircraft exposes participants and pedestrians the risk of dangerous low level 

aircraft engine failure making recovery or emergency landings as one of the extremes. The use of small 

UASs mitigates these hazards and is ultimately a much safer method of performing these and most other 

types of aerial security, monitoring and inspection of facilities, construction sites and structures. 

Small UAS aerial security, monitoring and inspection of facilities, construction sites and structures is 

also safer than traditional manned aircraft performing the same function. Conventional operations using 

rotorcraft and fixed-wing aircraft in low level operations present risks associated with vehicles weighing 

thousands of pounds and carrying large amounts of fuel. 
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It is important to note that the use of small UAS in this area will not only be safer and more cost effective, 

but the quality of collected data and information is far superior. 

Small UAS aerial security, monitoring and inspection of facilities, construction sites and structures is 

more reliable, and allows for the collection, dissemination, and storage of visual and other sensory data 

with greater precision and duration. Small UASs are also capable of accessing and inspecting areas that 

would otherwise be inaccessible to humans or cannot be completed with conventional aircraft. 

III. RELEVANT STATUTORY AUTHORITY 

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA 

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to 

Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in 

the National Air Space ("NAS") where it is safe to do so based on the following considerations: 

• The UAS's size, weight, speed and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within the visual line of sight of the operator. 

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f) 

(permitting exemptions from § § 44701(a), (b) and; 

§§ 44702 — 44716, et seq.). A party requesting an exemption must explain the reasons why the exemption: 

(1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide 

a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption). 

IV. COMPANY' PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF 

SECTION 333 OF THE REFORM ACT 

The small UAS operations proposed by COMPANY in this Petition for Exemption qualify for 

expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant 

factors are satisfied. 

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability 

A Grant of Exemption is appropriate for operations conducted using the DJI Inspire 1 UASs due to its size 

weight, speed, and operational capability. 
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• The DJI Inspire 1 has been approved for use in prior Section 333 Grants of Exemption from the 

FAA. 2 

• The DJI Inspire I weighs less than 55 pounds, including payload. 

• The DJI Inspire 1 will not be flown at a ground speed in excess of 50 knots. 

• Altitude information will be generated by equipment onboard the UA as specified using GPS 

triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. 

This information will be transmitted to the pilot via telemetric data feed. 

• The UASs will have system redundancies and independent functionality to ensure the overall safety 

and predictability of the system. If connection to the remote control or ground control station is 

lost, failsafe systems will permit the UAS to return to a predetermined location and safely land 

without injury or damage. 

• The radio frequencies used for operations and control of the UAS comply with the Federal 

Communications Commission ("FCC") and other appropriate government oversight agency 

requirements. The operating frequency for the DJI Inspire 1 is 2.4 GHz. 

If the same operations were conducted using a helicopter, the aircraft's take-off weight would likely 

exceed 6,000 pounds carrying a pilot, camera operator and VO-visual observer- navigator. The difference 

in weight between the DJI Inspire 1 and a helicopter significantly reduces the potential harm to the 

participating and non- participating individuals or property in the event of an accident or incident. In 

addition, the risk to the onboard pilot and camera operator is eliminated. 

B. Approval is Warranted Based on the Operational Restrictions Set Forth in COMPANY' 

Operations Manuals 

2See e.g., Grant of Exemption to Legend Creative Group (Exemption No. 11789) Precision Design & Drafting, Inc. 

(Exemption No. 11783), RS&H, Inc. (Exemption No. 11772). 
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Sept, 4t" 2015 

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COMPANY' Operations Manuals and the Manufacturer's Manual for the selected UASs will contain 

all the procedures and limitations necessary to safely and successfully perform the operations specified in 

this Petition for Exemption. To assist the FAA in making a safety assessment of COMPANY' proposed 

operations, below is a summary of operational limitations and conditions that COMPANY will adhere to, 

and which will ensure an equivalent or higher level of safety to operations conducted under current 

regulatory guidelines: 

1. The UAS weighs less than 55 pounds, fully loaded. 

2. 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 operation. 

3. All UASs operated under the Grant of Exemption will be identified by serial number, registered in 

accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with 14 

CFR part 45, Subpart C. Markings will be as large as practicable. 

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot- in Command 

("PIC") of the UAS, and one or more Visual Observers ("Observer") as necessary to safely conduct 

the mission. 

5. PICs shall possess at least a Private Pilot's Certificate and current Class III Medical Certificate. The 

PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in which 

the PIC is rated on his or her pilot certificate. 

6. The UA shall be operated within VLOS of the PIC and Observer at all times. The PIC must use 

human vision unaided by any device other than corrective lenses, as specified on the PIC's FAAissued medical certificate. 

7. The PIC and Observer designated for any operation will be able to communicate verbally at all times. 

8. Electronic messaging or texting will not be permitted during flight operations. 

9. The additional requirements identified in the Grant of Exemption shall be added to the COMPANY' 

Operations Manuals. The Operations Manuals will be maintained and made available to the Administrator 

upon request. If a discrepancy exists between the conditions and limitations in the Grant of Exemption and 

COMPANY' Operations Manuals, the conditions and limitations in the Grant of Exemption shall take 

precedence and must be followed. Otherwise, COMPANY shall follow the procedures outlined in their 

Operations Manuals. 
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Sept, 4th 2015 

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10. COMPANY may update or revise its Operations Manuals. Revisions will be tracked and a revised 

copy of the Manual will be provided to the Administrator upon request. 

COMPANY will also present an updated and revised Operations Manuals if it petitions for extension or 

amendment to its Grant of Exemption. If an update or revision would affect the basis upon which the FAA 

grants the exemption, COMPANY will seek an amendment to its Grant of Exemption. COMPANY will 

contact the FAA's UAS Integration Office (AFS-80) if questions arise regarding updates or revisions to the 

operating documents. 

11. COMPANY' Operations Manuals and its Grant of Exemption will be available to the 

PIC at the ground control station anytime the UAS is operating. 

12. The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast weather 

conditions) there is enough power to fly to the first intended point of landing, and assuming normal cruising 

speed, to fly after that for at least 10 minutes. 

13. Maximum total flight time for each operational flight using the DJI Inspire 1 will be limited to 40 

minutes or the amount of time the UAS can be flown and still maintain a reserve battery power of no less 

than 25%, whichever occurs first. 

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter navigable 

controlled airspace without prior written authorization and approval from the FAA. In the event the structure 

being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest 

point on the structure, and no more than 20 feet horizontally from the structure. 

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons 

other than the PIC, VO, operator trainees or essential personnel), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 

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, VO, operator trainees or essential persons do not present an undue 
hazard to those persons per § 91.119(a). 

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16. 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. 

17. The UA may not operate within 5 miles of an airport reference point as denoted on a current FAApublished 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 COMPANY COA. The letter of 

agreement with the airport management will be made available to the Administrator upon request. 

18. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a condition safe for flight. 

The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, or equipment, 

not already covered in the relevant sections of the operating documents. The PIC shall not operate the UAS 

if the inspection reveals a condition that affects the safe operation of the UAS until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe flight. The ground 

control station shall be included in the preflight inspection. All maintenance and alternations must be 

properly documented in the UAS records as required by COMPANY' Operations Manuals. 

19. COMPANY will carry out its maintenance, inspections, and record keeping requirements in 

accordance with the Operations Manuals. Maintenance, inspection, and alterations will be noted in the UAS 

records, including total time in service, description of work accomplished, and the signature of the authorized 

person returning the UAS to service. 

20. 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 in 

accordance with COMPANY Operations Manuals. The PIC who conducts the functional test flight must make 

an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight 

and UAS record entry shall be included in the COMPANY' Operations Manuals. 

21. The UAS will be operated and maintained according to the Manufacturer's 

Manuals and any required manufacturer Safety/Service Bulletins. 

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements on 

COMPANY' Operations Manuals. 

23. COMPANY will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or 

Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of 

Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in 

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements. 
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24. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies. 

25. If the UAS loses communication with the pilot, it will have the capability to return to a predetermined location within the operational area and land safely. 

26. Contingency plans will be in place to safely terminate flight if there is a loss of communication 

between the PIC and the Observer. 

27. The UAS will have the capability to safely abort flight in the case of unpredicted obstacles or 

emergencies. 

28. PICs and Observers will have at least a current Class III Medical Certificate. 

29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner 

consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time as a UA rotorcraft 

pilot and at least 10 hours logged as a UAS pilot with a similar UAS type. 

30. Prior to conducting operations for security monitoring, the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR § 61.51(b), a minimum of 54 CFR §61.51(b), a minimum of lO logged 

hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption 

and thirty take-offs and thirty landing in the preceding 90 days. 

31. Operations shall occur during daytime VFR Meteorological Conditions; flights under Special 

Visual Flight Rules ("SVFR") shall not be conducted. 

32. The UA shall remain clear and yield the right of way to all other manned operations and activities 

at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang 

gliders, etc.). 

33. UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited. 

34. The UAs will not be operated from an elevated platform or moving device / vehicle. 

35. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA will comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 
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V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act, 

including UASs, from its safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest. 3COMPANY seeks an exemption from several interrelated 

provisions of Title 14 of the Code of Federal Regulations (" 14 C.F.R") Parts 21, 45, 61 and 91 for purposes 

of conducting the requested operations using a UAS. Listed below are: (1) the specific sections of 14 C.F.R 

for which exemption is sought, and (2) the operating procedures and safeguards that Petitioner has 

established which will ensure a level of safety better than or equal to the rules from which exemption is 

sought.4 

3 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed 

pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716). 

4 14 C.F.R § 11.81(e), which requires a petition for exemption to include: 

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 you seek exemption. 
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UNMANNED AIRCRAFT SYSTEM 

A. 14 C.F.R. Part 21, Subpart H— Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1) 

The FAA has stated that no exemption is needed from this section if a flnding is made under the 

Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally 

used for the same application. These criteria are met, and therefore no exemption is needed. sIf, however, 

the FAA determines that there are some characteristics of the chosen UAS that fail to meet the requirements 

of the Reform Act, an exemption is requested. 

Equivalent Level of Sczfety 

COMPANY' use of the DJI Inspire is safe when taking into account their size, weight, speed, and 

operational capability. As set forth in the description of proposed operations in Section IV (A), the 

DJI Inspire weighs less than 55 pounds, including payload and will not be flown at a ground speed in 

excess of 50 knots. UAS is also equipped with safety features that will allow Petitioner to operate the 

UAS safely after experience certain in-flight contingencies or failures.6 7 Additionally, the UASs carry 

neither pilots nor passengers, carry no explosive materials or flammable liquid fuels, and operate 

exclusively within the parameters stated in COMPANY's Operations Manuals. 

5 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22). 

6See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): 

"The [DJI Inspire] has the capability to operate safely after experiencing certain in-flight 

contingencies or failures and uses an auto-pilot system to maintain UAS stability and control. The 

UAS is also able to respond to a loss of global positioning system (GPS) or a lost-link event with a 

pre-coordinated, predictable, automated flight maneuver, and manual flight control functionality as 

a backup. These safety features provide an equivalent level of safety compared to a manned aircraft 

performing a similar operation." 

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): 

"The DJI Inspire 1 can be operated entirely by a touch-screen, map-based interface. This means the 

operator only needs to command the system where to go, and the system does all the flying for the 

operator. The DJI Inspire 1 can be operated in both semi and fully autonomous flight modes. In 

addition, the DJI I Inspire 1 comes with pre-programmed no fly zones the UAS cannot enter areas 

deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS has built-in 

intelligent fault handling which allows the DJI Inspire 1 to detect a system fault while in the air and 

automatically fly back to its takeoff location and land. Faults that can be detected include: loss of 

communication; exceeding pre-set wind thresholds; and low battery levels. 
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Operations conducted under this exemption will be closely controlled and monitored by the operator 

and will be conducted in compliance with local public safety requirements, to provide security for the area of 

operation. COMPANY will also provide the FAA with advance notice of all operations via NOTAMs as 

required by the applicable COA. In all cases, operation of the DJI Inspire under the proposed conditions will 

be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate. 

Lastly, the UASs do not need a means to communicate with other aircraft or ATC, because those 

capabilities will be possessed by the PIC and Observer, who are not onboard the UAS. gIn addition, no 

sense-and-avoid technology is necessary for the UASs because they will be operated at all times in VFR 

conditions and within VLOS of the PIC and Operator. 9 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft 

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of 

normal category rotorcraft. To the extent that COMPANY's small UASs would otherwise require 

certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for 

the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H, szcpra. 

gSee Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13). 

yId. airworthiness standards for the same reasons identified in the request for exemption from 14 

C.F.R. Part 21, Subpart H, supra. 
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C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements 

COMPANY seeks an exemption from the aircraft marking and identification requirements contained 

in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 

• 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with Part 45 of this chapter. 

• 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 

than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or 

"provisional," as applicable. 

• 14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of 

the cabin, fuselage, boom, or tail the marks required by § 45.23. 

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was 

warranted provided that the aircraft "have identification (N-Number) markings in accordance with 14 C.F.R 

Part 45, Subpart C if the markings are as large as practicable." lo 

Equivalent Level of Safety 

All UA flown by COMPANY will bear N-number markings that are as large as practicable in 

accordance with 14 C.F.R. Part 45, Subpart C. 11 

lo FAA Docket No. FAA-2014-0352 

11 See, e.g., FAA Docket No. FAA-2014-0352, at 14. 
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D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance 

Inspections 

COMPANY seeks an exemption from the maintenance inspection requirements contained in 

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance 

and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each 

owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). 

An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with 

an airworthiness certificate, which the UAS to be operated under this grant of exemption will not have. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because maintenance and inspections will be performed 

in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. 

Further, as required by COMPANY' Operations Manuals, the PIC will conduct a pre-flight inspection of the 

UAS and all associated equipment to account for all discrepancies and/or inoperable components. 

Maintenance will be performed and verified to address any conditions potentially affecting safe operation of 

the UAS and no flights will occur unless, and until, all flight critical components of the UAS have been 

found to be airworthy and in a condition safe for operation. A functional test flight will be conducted 

following the replacement of any flight-critical components. As required by COMPANY' Operations 

Manuals, the PIC who conducts the functional test flight will make an entry in the UAS aircraft records of the 

flight. 

COMPANY' Operations Manual also includes requirements to follow the manufacturer's UAS 

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the 

following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces 

(including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries), 

ground control station, hazard accessories, and spare parts. Further, COMPANY' Operations Manuals also 

includes procedures to document and maintain a record of the UAS maintenance, preventative maintenance, 

alterations, status of replacement /overhaul component parts, and the total time in service of the UASs used 

under this Grant of Exemption. As a whole, the maintenance and inspection procedures required in 

COMPANY' Operations Manuals ensure that an equivalent or higher level of safety will be achieved. 
U. S. Department of Transportation 

Sept, 4th2015 

Page 16 

PILOT-IN-COMMAND OF THE UAS 

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations 

COMPANY seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders 

from flying aircraft for compensation or hire, and would also require a second class medical certificate. The 

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the 

PIC will be operating, as well as requiring certifications if the private pilot is carrying passengers or cargo for 

hire. In this case, while the UASs will be operated as part of a commercial operation, it carries neither 

passengers nor cargo. In the Grant of Exemption to Astraeus Aeria1 12 , the FAA determined that the unique 

characteristics of UAS operation outside of controlled airspace did not warrant the addition cost and 

restrictions attendant with requiring a the PIC to have a Commercial Pilot Certificate and Class 11 Medical 

Certificate. The fulfillment of the additional requirements for a private pilot to become qualified as a 

commercial pilot would not lead to any additional safety benefits when UAS operations are involved. 

Equivalent Level of Safety 

The restrictions COMPANY has placed on its UAS operations meet or exceed the restrictions 

similarly imposed on Astraeus Aerial. COMPANY will operate on private property away from persons and 

property not involved in the operation. COMPANY will also obtain an ATO issued COA prior to conducting 

any operations under this Grant of Exemption. All operations will be conducted in accordance with airspace 

requirements in the ATO issued COA including class of airspace, altitude level and potential transponder 

requirements. A NOTAM will also be issued as required by the applicable COA. 

In addition to these flight restrictions, COMPANY will further ensure safe operation by requiring that 

any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft 

operators but also in the unique aspects of UAS flight. As set forth in the Operations Manuals, pilots will 

have experience not only in UAS operations generally but have logged flight time in the specific make and 

model used for the operations before they are permitted to participate in commercial flights on behalf of 

COMPANY. The pilot qualification, training, and currency requirements in the Operations Manuals ensure 

that COMPANY' pilots are competent and proficient in the UAS they are operating. COMPANY' training 

and qualification requirements are consistent with those contained in prior FAA Section 333 Grants of 

Exemption, and will provide a higher level of competency and proficiency for its pilots and will ensure at 

least an equivalent level of safety. 

12 Exemption No. 11062 (FAA Docket No. FAA-2014-0352). 
U.S. Department of Transportation 

Sept, 4t" 2015 

Page 17 

OPERATING PARAMETERS OF THE UAS 

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Although there will be no airworthiness certificate issued for the UASs, COMPANY seeks an 

exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be 

operated. The FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the 

requirements of Part 21 are waived or found inapplicable. 13Accordingly, Petitioner requests that the 

requirements for § 91.7(a) be treated in accordance with Section V(A), supra. 

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness 

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2): 

(b) No person may operate a U.S.-registered civil aircraft — 

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. 

Pursuant to 14 C.F.R. § 91.203(a) and (b): 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following: 

(1) An appropriate and current airworthiness certificate. .. 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph 

(a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew. 

13 See id. at 13-14, 22 
U.S. Department of Transportation 

Sept, 4t" 2015 

Page 18 

Given the small size and configuration of the UASs, it would be impossible to keep airworthiness 

documents and other aircraft manuals on board the UAS because there is simply no room and the UAS has 

no cabin or cockpit. 

Equivalent Level of Snfety 

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and 

(b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, 

and other required documents from the ground control station from which he or she is operating the 

aircraft. 14As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the 

pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be 

achieved by ensuring that the pilot has access to the documents at the ground control station from which he 

or she is piloting the UAS. 

H. 14 C.F.R. § 91.103: Preflight Action 

COMPANY seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar 

with specific information before each flight, including information contained in the FAA-approved Flight 

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely 

conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is required. 

Equivalent Level of Snfety 

An equivalent level of safety will be provided by following the COMPANY' Operations Manuals 

and the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any 

defects or inoperable components in accordance with the COMPANY' Operations Manuals, including 

checklists covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required 

to review weather, flight requirements, battery charge, landing and takeoff distance, UA performance data, 

and contingency landing areas—before initiation of flight. COMPANY' Operations Manuals and the 

Manufacturer's Manual will be kept at the ground control station and will be accessible to the PIC at all 

times while operating the UAS. 

I. 14 C.F.R. § 91.109(a): Flight Instruction 

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and 

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA2014-03 52 at 16-18. 
U.S. Department of Transportation 

Sept, 4th2015 

Page 19 

COMPANY seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that 

"[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, by 

their design, do not have functional dual controls. Instead, flight control is accomplished through the use of 

a device that communicates with the aircraft via radio communications. Accordingly, an exemption will be 

required for the flight instruction requirements of 14 C.F.R. § 91.109(a). 

Equivalent Level of Safety 

Given the size and speed of the UASs that COMPANY intends to use, an equivalent level of safe 

training can still be performed without dual controls because no pilot or passengers are aboard the UAS, and 

as required by the COMPANY' Operations Manuals, all persons will be a safe distance away in the event that 

the UAS experiences any difficulties during flight instruction. Moreover, as required by the COMPANY' 

Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, 

the safety procedures provided for in COMPANY' Operations Manuals ensure that the proposed UAS 

operations provide an equivalent or higher level of safety than that provided by the flight instruction 

regulations. 

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes 

COMPANY requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119(c). 15Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, 

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested 

areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those 

minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided 

that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for 

helicopters by the FAA." 

An exemption is required because the proposed UAS operations will normally need to occur below 

400 feet AGL. In circumstances where the UAS is used to inspect a structure whose height exceeds 400 feet 

AGL, the UAS will not be operated more than 100 feet above the highest point on the structure, and within 

50 feet horizontally of the structure. ~Additionally, due the nature of the proposed operations, the Pilot and/or 

Observers(s) may need to be less than 500 feet away from the UAS. 

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency 

landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's 

proposed UAS operations will not occur over congested areas, and therefore an exemption from § 91.119(b) 

will not be necessary. See e.g., Grant of Exemption No. 11157 to Slug wear, Inc., dba Like on a tree Aerial 

(FAA-2014-0534 at 15) 
U.S. Department of Transportation 

Sept, 4th2015 

Page 20 

Equivalent Level of Safety 

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed 

herein, and given the lack of flammable fuel with the UASs, any risk associated with these operations is far 

less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved 

given the size, weight, and speed of the UASs, as well the controlled location where the operations will 

occur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL or 

below, or when inspecting a structure whose height exceeds 400 feet AGL, within 100 feet above the highest 

point on that structure and 50 feet horizontally of the structure. 

As set forth in the Operations Manuals, the UASs will be operated in a restricted area, and all flights 

will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless that person 

is in a position where he or she is shielded from the UAS and any possible debris resulting from UAS failure. 

As required by the Operations Manuals, flights will be terminated if a nonparticipating person within 500 feet 

of the UAS leaves a shielded position. Further, UAS operations will occur at least 500 feet away from 

vehicles or structures unless the property owner/controller has granted permission and the PIC has made a 

safety assessment of the risk of operating closer to those objects and, operations near the PIC or Observer 

will not present an undue hazard per § 91.119(a). Adherence to these restrictions in the elevation of the 

departure airport or barometric pressure. An exemption is required to the extent that the UASs do not have a 

barometric altimeter, but rather a GPS altitude read out. COMPANY' Operations Manuals will ensure 

operations can be conducted without compromising safety. 16 

K. 14 C.F.R. § 91.121: Altimeter Settings 

COMPANY seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft 

to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure An exemption is required to the extent that the UASs do not have a 

barometric altimeter, but rather a GPS altitude read out. 

16See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19): 

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the 

UA or debris in the event of an accident, then the UA may operate closer than 500 feet to persons 

afforded such protection. The operator must also 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. When considering how to 

immediately cease operations, the primary concern is the safety of those nonparticipating persons. In 

addition, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles 

and structures when the owner/controller of any such vessels, vehicles or structures grants permission 

for the operation and the PIC makes a safety assessment of the risk of operating closer to those 

objects and determines that it does not present an undue hazard." 
U.S. Department of Transportation 

Sept, 4th2015 

Page 21 

Equivalent Level of Srafety 

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. § 

91.121 can be achieved in circumstances where: (1) the UASs will be operated below 400 feet AGL or 

below", (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the operator 

at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude initiation point is 

established for the PIC to confirm accuracy of the onboard GPS. 18 

The UASs that COMPANY intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by COMPANY' Operations Manuals, the PIC will be required to 

calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants of 

Exemption, the UASs COMPANY intends to use, and the safety mitigation procedures contained in the 

Operations Manuals, both ensure that an equivalent level of safety will be achieved, and a Grant of 

Exemption to the requirements of § 191.121 is therefore appropriate. 

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

COMPANY requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR 

conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane 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 — 

(1) During the day, to fly after that for at least 30 minutes; 

or 

(2) At night, to fly after that for at least 45 minutes. 

Here, the technological limitations on UAS battery power means that no meaningful flight operations 

can be conducted while still maintaining a 30-minute battery reserve. An exemption from the fuel 

requirements of 14 C.F.R. § 91.151(a) is therefore required. 

17 If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more 

than 100 feet above the highest point on the structure. 

18 See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21). 
U.S. Department of Transportation 

Sept, 4t" 2015 

Page 22 

Equivtclent Level of Srcfety 

In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a DJI Inspire 1 flight unless (considering wind and forecast weather 

conditions) there was enough power to fly to the first intended point of landing and, assuming normal 

cruising speed, to fly after that for at least 10 minutes. 

In reaching this conclusion, the FAA considered that the UAS batteries for the DJI Inspire 1 

provided provide approximately 20 minutes of powered flight (with payload) and provided battery level 

and battery time remaining in minutes and seconds to the PIC. 19The FAA also considered the fact that the 

DJI Inspire 1 operating manual states: "start every flight with a fully charged battery in the aerial vehicle", 

and that in the event that the UAS should run low on power, the PIC will be alerted and can land the DJI 

Inspire as soon as possible. Like the VDOS Grant of Exemption, COMPANY use of the DJI Inspire 1, 

combined with the requirements of Petitioner's Operations Manuals, ensure that an equivalent level of 

safety can be achieved. 

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined 

that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a flight with the DJI Inspire 1 unless (considering wind and forecast 

weather conditions), there was enough power to fly at normal cruising speed to the intended landing point 

and land the UA with 25% battery power remaining. COMPANY will adhere to this limitation for DJI 

Inspire 1 flights. 

The DJI Inspire includes a low battery warning system and the amount of battery reserve power 

remaining is transmitted to the PIC via telemetric data feed, which downlinks from the UAS to a groundbased-on-screen display. 20As required by COMPANY' Operations Manuals, the PIC will promptly fly the 

UAS back to the home launch location or pre-determined abort location where the UAS may safely land, 

while still maintaining a minimum of 25% reserve battery power. COMPANY submits that the procedures 

requiring flights to be safely terminated once the batteries fall below 25% capacity, combined with the 

requirement that flights only be conducted within a secure, isolated area, using a UAS weighting less than 

25 pounds, and within VLOS of the PIC and Observer(s), ensure that the proposed operation will provide 

an equivalent or higher level of safety to that provided by the regulations from which exemption is sought. 

19 Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 

20The DJI Inspire 1 ground control station displays, the UASs position, navigation route, tail number, 

altitude, heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor 

heading and orientation relative to the UAS. 
U.S. Department of Transportation 

Sept, 4t" 2015 

Page 23 

VI. DRUG AND ALCOHOL PROGRAM 

COMPANY will have policies in place to ensure that no person may participate in UAS flight 

operations if they are under the influence of alcohol or any drug. 

VII. PUBLIC INTEREST 

The public interest will be served by granting COMPANY' Petition for Exemption. Congress has 

established a national policy that favors early integration of UAS into the NAS in controlled, safe working 

environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill 

Congress' goal in passing Section 3 3 3 (a) through (c) of the Reform Act—the FAA Administrator's 

assessment of whether certain UAS may operate safely in the NAS before completion of the statutorily 

required rulemaking. 

The proposed UAS operations in this Petition for Exemption significantly improve safety and 

reduce risk harm or serious injury to security personnel and client employees. Traditional methods of 

securing, inspecting and monitoring industrial and construction sites, and utility power-generation facilities 

and infrastructure requires security personnel to climb towers or otherwise perform elevated work, which 

exposes them to the risk of dangerous falls. Inspectors are often exposed to hazardous chemicals or oxygendeficient atmospheres, burns from steam or from hot equipment, and other mechanical hazards associated 

with industrial sites and construction facilities. The use of UAS for California's severe drought conditions 

help to manage water consumption in these extreme conditions. The use of small UASs can eliminate these 

hazards and is ultimately a much safer method of performing these types of inspections. 

The use of small UASs also enhances safety and reduces risk because, unlike manned aircraft 

weighing thousands of pounds, carrying crew in addition to flammable fuel, the UASs carry no passengers 

or crew. Further, in the unlikely event of an accident, COMPANY small battery powered UASs presents 

significantly less danger to persons on the ground when compared to operations by conventional manned 

aircraft. 21 

21 See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): 

"Manned helicopters conducting aerial security and inspection can weigh 6,000 pounds or more and are 

operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner's 

UAs will weigh less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely 

located from the aircraft. The limited weight significantly reduces the potential for harm to participating 

and nonparticipating individuals or property in the event of an incident or accident. The risk to an onboard 

pilot and crew during an accident is eliminated with the use of a UA for aerial inspection operations." 
U.S. Department of Transportation 

Sept, 4th2015 

Page 24 

As Petitioner's UASs are battery powered, the public will also benefit from a reduction in harmful 

emissions associated with conventional aircraft performing in the same functions proposed herein. Lastly, 

as recognized by the FAA in prior Section 333 Grants of Exemption to security, UASs provide an 

additional tool for aerial security industry, adding a greater degree of flexibility, which supplements the 

current capabilities offered by manned aircraft. 22 

VIII. PRIVACY 

All COMPANY UAS operations will be conducted in accordance with applicable federal, state, or 

local laws regarding privacy. 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. 

IX. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL 

REGISTER, should it be determined that publication is needed: 

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: 

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 

91.119(c); 91.121; 91.151(a); 91.203 (a) &(b); 91.405(a); 91.407(a)(1); 91.409(a)(1) &(2); 91.417 (a) & 

(b). 

The exemption will enhance safety by reducing risk to the general public and property owners from 

the substantial hazards associated with performing equivalent work and aerial security, monitoring and 

inspection of facilities, construction sites and structures with conventional fixed-wing aircraft, rotorcraft, or 

other methods. 

X. CONCLUSION 

COMPANY Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform 

Act of 2012 including weight, speed, operating capabilities, proximity to airports and populated areas, 

operation within VLOS and national security. The proposed UAS operations will benefit the public as a 

whole by improving safety and reducing risk by alleviating human exposure to danger. In consideration of 

the foregoing, this Petition for Exemption provides the FAA with more than adequate justification for 

granting the requested exemptions allowing COMPANY to provide aerial security, monitoring and 

inspection of facilities, construction sites and structures, and additionally provide agriculture drought 

conditions data collection services. 

22 See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18). 
U.S. Department of Transportation 

Sept, 4th2015 

Page 25 

We thank you for your prompt consideration of our requested exemptions. 

Respectfully submitted, 

Lawrence Garcia 

President 

Air Vision Industries, Inc. 

5470 W. Spruce Ave #102 

Fresno, CA, 93722 

Phone: 559-271-5984 

Email: Lawrence@ameriguardsecurity.com 

(The following attached items contain proprietary and commercial information exempt from disclosure 

under the Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant 

to 14 C.F.R. § 11.35(b)). 

Attachments: 

1. General Operations Manual 

2. PIC Operating Manual 

3. Company Protocols 

4. Location Protocols 

5. Flight Communications Protocols 

6. Departing Location Protocols 

7. Transmitter Protocols 

8. Preflight Checklist 

9. Post Flight Checklist 

10. Equipment Checklist 

11. UAS Manufacturer's Manuals 

a. User Manuals 

b. UAS Maintenance Manuals