**12741 Grable Place Pickerington, OH 43147**  **Office: 614**
**- 604** 
**- 7833**  **Cell: 304**
**- 550** 
**- 0791** 
July 1 7 , 2015 U.S. Department of Transportation Federal Aviation Administration Document Management Sy stem 1200 New Jersey

Ave., SE Washington , D.C. 20590
**RE: Exemption Request** 

**– Section 333 of the FAA Report Act and Part 11 of the**  **Federal Aviation Regulations**  Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L

. No.112

- 95, 126 Stat.11 (amending 49 U.S.C.) (hereinafter, the “Reform Act”) and 14 C.F.R. Part 11, Cloud Vision LLC , a developer and operator of small unmanned aircraft sy stems (singularl y a “sUAS” or cumulativel y “sUASs”) seeks an exemption from the Federal Aviation Regulations listed be low, to allow commercial operation of its sUASs. Cloud Vision , L CC provides professional a erial solutions for all ty pes of design and construction projects , m apping, inspection and photograph y of landfills, mining facilities, utilities, oil and gas facili ties, agriculture, construction sites, real estate appraisals , forensic engineering inspections, damage assessments and fire investigation applications

. As described more full y below, the requested exemption would permit the operation of small, unmanned sUAS under controlled condition in airspace that (a) is limited, (b) is predetermined, (c) is controlled as to access, and (d) would provide safety enhancements to the already s afe operations in the industry

. Approval of this exemption would thereb y enhan ce safety

and fulfill the Secretary

of Transportation’s responsibilities to “... establish requirements for the safe operation of such aircraft s ys tems in the national airspace sy stem.” Reform Act 333 (c). The name and address of the applicant (“Applicant”) : Cloud Vision , LLC Attn: James D. Singleton 12741 Grable Place Pickerington, OH 43147 TEL : 614

- 604

- 7833 MOB : 304

- 550

- 0791 Email: pipejaws@gmail.comU.S. Department of Transportation

– Federal Aviation Administration

Exemption Request

– Section 333 of the FAA Reform Act

Page 2 of 11 The Applicant hereb y requests exemption from the following FARs: • 14 C.F.R. 21, subpart H • 14 C. F.R. 61.3 • 14 C.F.R. 61.113(a)&(b) • 14 C.F.R. 61.133(a) • 14 C.F.R. 91.9(b)(2) • 14 C.F.R. 91.103(b) • 14 C.F.R. 91.105 • 14 C.F.R. 91.109(a) • 14 C.F.R. 91.119 • 14 C.F.R. 91.121 • 14 C.F.R. 91.151(a) • 14 C.F.R. 91.203(a) & (b) • 14 C.F.R. 91.319(a)(1) • 14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417) The requested exemption would authorize Cloud Vision to conduct commercial operations using the DJ I Inspire 1 and DJ I Phantom 3 f or mapping, inspection and photograph y of landfills, mining facilitie s, utilities, oil & gas facilities, agriculture, real estate appraisals, construction sites, forensic engineering inspections, damage assessments, and fire investigation applications. In order to ensure at least an equivalent level of safety to currently authorized operations using manned aircraft, all operations will be subject to the strict operating requirements defined in the Cloud Vision UAS Flight Operations Manual and Preflight Checklist ( Cloud Vision will provide these documents if required, but re quests that the FAA treat them as proprietary

under 14 C.F.R. 11.35(b) and not include this document in the public docket). Additionally , this petition for exemption is supported by the information contained in the Inspire 1 User Manual and P hantom 3 Use r Manual, Phantom 3 Pilot Training Guide, and the Smart Flight Battery

Safety Guidelines (hereafter collectivel y referred to as “Manufacturer’s Operations Manuals”).
All Cloud Vision UAS ’ will be operated onl y b y individuals who hold at least an FAA issu ed private, recreational, or sport pilot certificate and who have successfully completed Cloud Vision ’s UAS Pilot Training Program (the Cloud Vision UAS Training Program Outline will be submitted separatel y if required and Cloud Vision requests that the FAA treat this document as proprietary under 14 C.F.R. 11.35(b) and not include this document in the public docket). The characteristics of the sUAS, detailed sUAS operator requirements, and sUAS operating parameters given below will ensure that all Cloud V ision UAS operations are carried out with an equivalent or higher level of safety than currentl y authorized manned aircraft operations. The details below regarding Cloud Vision ’s intended UASU.S. Department of Transportation

– Federal Aviation Administration

Exemption Request

– Section 333 of the FAA Reform Act

Page 3 of 11 applications provide clear evidence that approval of this exempt ion is in the public interest.
**CHARACTERISTICS OF THE sUAS** The Inspire 1 and Phantom 3 are all very similar UAS. The Inspire 1 h a s a diagonal motor

- to

- motor distance of approximately 438x451x301 mm . The Phantom 3 is approximately

27 inches across, meas ured diagonally and including the propellers. Both are constructed primarily of frangible materials (plastic) . The Phantom 3 weighs less than 3 pounds and the Inspire weighs 6.5 pounds. T he Inspire 1 is powered by a 4700mAH L iPo battery

and the Phantom 3 is powered b y a 4480 mAh 4S LiPo battery. The max flight speed of the Inspire 1 is approximately 50 mph and Phantom 3 is 36 mph

. Both contain an on

- board GPS and an inertial measurement unit for flight stabilization and automatic failsafe return to home in case of a lost control signal. Additionally , these UAS offer geo

- fencing and max altitude features to restrict the maximum vertical and horizontal distance the aircraft will fly from its home point. Both the Inspire 1 and the Phantom 3 offer the added feature of displaying real time flight data, including battery status, altitude and distance from home, within the DJIApp. Each sUAS operated b y Cloud Vision for commercial use will be registered in accordance with 14 C.F.R Part 47, and will be marked in accordance with 14 C.F.R. Part 45, , Subpart C, in a size as large as practical for the size of the sUAS. All sUASs operated b y Cloud Vision will be maintained in accordance with the manufacture’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components and all pertinent instructions in the user manuals. Repairs, component changes, and software/firmware updates will be recorded in the sUAS’s maintenance log. Maintenance log entries will include the date, sUAS ID number, registration number, current sUAS flight time, a description of work performed, and the name of the individual who completed the work. An y UAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight, prior to use in an y commercial operations. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to person s and property. The PI C who conducts the functional test flight must make an entry in the aircraft records. A pre

- flight inspection of the sUAS will be completed by the PI C prior to each flight operation as specified in the Cloud Vision sUAS Flight Operat ions Manual. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is removed from service and prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. All Cloud Vision UAS will comply with all applicable manufacturer safety bulletins. The safety and reliability of the DJ I Inspire 1 and Phantom 3 sUAS is further supported by the fact that numerous FAA exemptions have previously been approved for their use in commercial operations.U.S. Department of Transportation

– Federal Aviation Administration

Exemption Request

– Section 333 of the FAA Reform Act

Page 4 of 11 **UAS OPERATOR REQUIREMENTS** All Cloud Vision sUAS operators will hold at least an FAA issued private, recreational, or sport pilot certificate and will have successfully completed H3DS’s UAS Training Program. Completion of the Cloud Vision sUAS Training Program will ensure safe operations b y not allowing an y P IC to operate a sUAS unless that PI C has demonstrated, that he/she is able to safely operate the sUAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. All operators will either meet the flight review requirements specified in 14 CFR § 61.56 or will annually complete and log at least 4 ho urs of ground instruction with a certified flight instructor (CFI) covering regulations and issues pertinent to commercial operation of the Inspire 1 and Phantom 3 sUAS. The individual acting as PI C of a sUAS will be identified prior to any flight and wil l not change once the flight has begun. The PI C is the individual in operational control of the flight operation from beginning to end and is responsible for safe flight of the sUAS. All PI C flight hours used to demonstrate qualifications and currency will be logged in a manner consistent with 14 CFR §61.51(b). In order to act as PIC, all Cloud Vision sUAS operators will hold a current FAA issued private, recreational, ore sport pilot certificate and a valid U.S. driver’s license issued by a state, the Dis trict of Colombia, Puerto Rico, a territory , a possession, or the Federal government. **UAS OPERATING PARAMETERS** In order to provide for a level of safety at least equivalent to operations conducted using manned aircraft, all Cloud Vision commercial sUAS op erations will be conducted in accordance with the following specific operating limitations: • The sUAS may

not be operated at a speed exceeding 30 knots (34 miles per hour). In no case will the sUAS be operated at airspeeds greater than the maximum sUAS o perating airspeed recommended by the aircraft manufacturer. • All operations shall be conducted in accordance with an ATO

- issued COA. • All sUAS operations will occur at or below 500 ft AGLor the maximum altitude specified in the COA limitations, unless the purpose of the flight is to inspect a building or structure which is taller than 500 ft. If the purpose of the flight is to inspect a building or structure which is taller than 500 ft then the max altitude of the sUAS will be restricted to 20 ft above the highest point of that building or structure. All altitudes must be reported in feet AGL. • No sUAS will be operated within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory

(AFD) or for airp orts not denoted with an ARP, the center of the airport s ymbol as denoted on the current FAA published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to Cloud Vision . The l etter ofU.S. Department of Transportation

– Federal Aviation Administration

Exemption Request

– Section 333 of the FAA Reform Act

Page 5 of 11 agreement with the airport management must be made available to the Administrator or any law enforcement official upon request. • No sUAS will be operated within class B, C, D or E airspace unless a letter of agreement from the controlling ATC of fice is obtained or the flight is otherwise permitted by

a COA issued to Cloud Vision . The letter of agreement from ATC must be made available to the Administrator or any law enforcement official upon request. • The sUAS must be operated within visual lin e of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided b y an y device other than corrective lenses, as specified on the U.S. driver’s license. • All operating documents and a grant of exemption must be acces sible during sUAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitatio ns in the grant of exemption take precedence and must be followed. Otherwise, the PIC must follow the procedures as outlined in the operating documents. Cloud Vision may update or revise its operating documents. However, it is Cloud Vision ’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. Cloud Vision must also present updated and revised documents if it petitions for extension or amendment to the grant of ex emption. I f Cloud Vision determines that an y update or revision would affect the basis upon which the FAA granted the exemption, then Cloud Vision must petition for an amendment to the grant of exemption. • sUAS operations may

not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. The sUAS 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 PI C. • Prior to each flight the PI C must inspect the sUAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS, the aircraft is removed from service and prohibited from operating until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. All maintenance and alterations must be properl y docume nted in the aircraft records. • Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PI C who conducts the functional test flight must make an entry in the aircraft records. • If the UAS loses communications or loses its GPS signal, the sUAS must return to a predetermined location.U.S. Department of Transportation

– Federal Aviation Administration

Exemption Request

– Section 333 of the FAA Reform Act

Page 6 of 11 • The PI C must abort the flight in the event of unpredicted obstacles or eme rgencies. • The PI C is prohibited from beginning a flight unless the sUAS’s battery level is at 75% or higher. The PIC must begin returning the sUAS to the designated landing area when the battery

level drops below 25%. • Documents used b y the operator t o ensure the safe operation and flight of the sUAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the sUAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. • The sUAS must remain clear and give way to all manned aviation operations and activities at all times. • The sUAS may

not be operated b y the PIC from any moving device or vehicle.
• sUAS will not be operated directl y over nonparticipating persons unless barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. UA will not be operated over any open - air ass embly of people. • Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Acc idents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.
**APPLICATIONS AND PUBLIC INTEREST** The requested exemption would allow Cloud Vision to operate the DJ I Inspire 1 and Ph antom 3 for the purposes of forensic engineering inspections and fire cause and origin investigations. These inspections and investigations are completed on both residential and commercial properties and are typicall y conducted in support of the property i nsurance industry

. Use of sUAS for these applications will offer significant advantages related to safety, time, and cost. Most properties throughout the country are insured, and property owners have an interest in insurance underwriting, coverage, and cl aims processing; therefore it is clear that grant of this exemption would be in the public interest. Current options for gathering the data which under this exemption would be collected using sUAS, include use of ladders, lifts, and manned aircraft. Use o f ladders and lifts are inherently

dangerous and result in numerous injuries each ye ar. Use of manned aircraft is ty picall y not feasible and therefore valuable information remains beyond the reach of the investigator. In most cases, use of a sUAS is quicke r and easier than any other alternative and often yi elds better information. Due to their small size and the fact they carry noU.S. Department of Transportation

– Federal Aviation Administration

Exemption Request

– Section 333 of the FAA Reform Act

Page 7 of 11 fuel, both DJ I models pose a very low risk of damage to persons or structures on the ground. Because these sUAS are electric po wered, they create no harmful emiss ions and create less than 7 5 dB of noise.
**SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER** Cloud Vision requests the grant of an exemption to the following specific sections of the Title 14 Code of federal Regulation s which would allow it to operate micro UAS for commercial use: 14 CFR 21, subpart H, 14 C.F.R Sections 61.3, 61.113(a)&(b), 61.133(a), 91.9 (b)(2), 91.103(b), 91.105, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.319(a)(1), 91.405, 91.407, 91. 409, 91.417
**CONCLUSIONS** Cloud Vision respectfully requests that the FAA grant the exemption sought in this request. Cloud Vision believes that considering the small size and weight of the sUAS, along with the sUAS PI C training and certification requirements stipulated above and the strict operating guidelines proposed herein, it is clearl y demonstrated that the sUAS will be operated safely

in the national air space (NAS) with an equivalent or greater level of safety compared to manned aircraft. We are prepared to modify or amend any

part of this request as deemed necessary by the FAA to satisfy

the need for an equivalent level of safety. Please contact us at an y time if yo u require additional information or clarification. Respectfully

Submitted, 

# J a m es D

. Si n g l e t o n
CL OUD VISION , LLC James D. Singleton President & Owner 614

- 604

- 7833 DIR 304

- 550

- 0791 CELL pipejaws@gmail.comU.S. Department of Transportation

– Federal Aviation Administration

Exemption Request

– Section 333 of the FAA Reform Act

Page 8 of 11

**APPENDIX A: REGULATIONS REQUIRING EXEMPTION** Cloud Vision requests an exemption from the following regulations as well as a ny additional regulations that may technicall y appl y t o the operation of the Inspire 1 and Phantom 3 sUAS: **14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1)** Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a). Given the size of the sUAS, its light weight, and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H in order to achieve or exceed current safety levels. Such an exemption meets the requirements of an equivalent le vel of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the sUAS involved. An anal ys is of these different criteria demonstrates that the sUAS operated without an airworthiness certificate, under the conditions proposed in that ex emption, will be at least as safe, or safer, than a conventional aircraft with an airworthiness certificate. **14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations 14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and L**  **imitations; Pilot in**  **Command; Commercial Pilot Privileges and Limitations** The regulation provides that no person may serve as a required pilot flight crewmember of a civil aircraft of the United States, unless that person: (1) Has a pilot certificate or special purpose pilot authorization issued under this part in that person's ph ys ical possession or readil y accessible in the aircraft when exercising the privileges of that pilot certificate or authorization. However, when the aircraft is operated within a foreign country , a pilot license issued by that country

may be used. The regulation provides also that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employ ment if: (1) The flight is only

incidental to that business or employ ment; (2) The aircraft does not carry passengers or property

for compensation or hire.U.S. Department of Transportation

– Federal Aviation Administration

Exemption Request

– Section 333 of the FAA Reform Act

Page 9 of 11 Given the size, weight, speed, operational limitations, and range of the sUAS, Cloud Vision proposes that operators of the UAS should not be required to hold a commercial pilot certification. Instead, operators should be required to: Hold at least an FAA issue d private, recreational, or sport pilot certificate. All operators will either meet the flight review requirements specified in 14 CFR § 61.56 or will annually complete and log at least 4 hours of ground instruction with a certified flight instructor (CFI) covering regulations and issues pertinent to commercial operation of the Inspire 1 and Phantom 3 UAS. **14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard requirements.** This regulation provides that no person may operate an aircraft unle ss a current, approved flight manual is in the aircraft. H3DS proposes to provide an equivalent level of safety b y maintaining a copy

of all documents used by the operator to ensure the safe operation and flight of the UAS as well as documentation of an ex emption and COA with the ground control station and accessible to the PI C during flight operations. **14 C.F.R. § 91.103: Preflight action** This regulation requires that each pilot in command shall, before beginning a flight, become familiar with all availa ble information concerning that flight. This information must include runway lengths at airports of intended use, and the following takeoff and landing distance information. This regulation is not applicable due to the fact H3DS sUAS operations will not oc cur at an airfield. To provide an equivalent level of safety, the PI C will complete a preflight inspection as directed by the manufacturer’s manuals and H3DS UAS operations manual before any flight. **14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instructio n**  The regulation provides that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has full y functioning dual controls." The equivalent level of safety will be achieved through H3DS’s sUAS flight training program and conducting flight training within controlled environments. **14 C.F.R § 91.105: Flight Crewmembers at Stations** The regulation states that required crewmembers must be at their stations in the aircraft during specific portions of a flight. Thi s is not applicable since the sUAS carry no crewmembers. An equivalent level of safety will be maintained b y ensuring that the PIC is identified prior to any flight and that the PIC does not change during a flight. The PIC will maintain control of the UAS for the duration of the flight.U.S. Department of Transportation

– Federal Aviation Administration

Exemption Request

– Section 333 of the FAA Reform Act

Page 10 of 11 **14 CFR § 91.119: Minimum Safe Altitudes** The regulation provides that over sparsel y populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the UA will be operating at a maximum of 500 feet AGL, these operations cannot comply with this requirement. The equivalent level of safety will be achieved given the size, weight and speed of the sUAS. Additionally the sUAS will be operated in a defined and relativel y small AOI . Moreover, the sUAS will not be operated over any open - air assembly of persons or over an y person not involved with the operation. The aircraft will be operated at an altitude allowing, if a power unit fails, an emergency landing without undue h azard to persons or property

on the surface.
**14 CFR 91.121**

**– Altimeter settings**  This section requires that each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an alt imeter that is set, when operating below 18,000 feet MSL to: • The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; • If there is no station within the area prescribed in paragraph (a)(1)(i) o f this section, the current reported altimeter setting of an appropriate available station;
• In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.
To provide an equivalent level of safety , the sUAS utilize a GPS system, barometric pressure sensors, and internal gy roscopes to calculate the altitude. **14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions** The regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fl y to the first point of intended landing and to fly after that for at least 30 minutes. Given the area of operation for the UAS, H3DS believes that an equival ent level of safety is achieved by requiring at least 75% battery power in order to begin a flight and requiring the UA to return to land when the battery power reaches 25%. **14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registr ation**  This regulation provides as follows: • No person may

operate a civil aircraft unless it has an appropriate and current airworthiness certificate. • No person may

operate a civil aircraft unless the airworthiness certificate required byU.S. Department of Transportation

– Federal Aviation Administration

Exemption Request

– Section 333 of the FAA Reform Act

Page 11 of 11 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. To obtain an equivalent level of safety and meet the intent of 91.203, Cloud Vision propose s to maintain a copy of all documents used by the operator to ensure the safe operation and flight of the sUAS as well as documentation of an exemption and COA with the ground control station and these will be available to the Administrator or any law enfo rcement official upon request. **14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91 .417)** 
**- Maintenance, Preventive**  **Maintenance, and Alterations** The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy

co ndition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. Section 91.409(a)(2) requires an annual inspe ction for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service. Cloud Vision proposes that the maintenance, as well as preflight inspections of the sUAS will be accomplished by the PI C. All maintenance will be conducted and logged in accordance with the manufacturer’s s pecifications. An equivalent level of safety will be achieved because the sUAS are small in size, are not complex mechanical devices, and will carry no external payload.