# eagle vision usa productions, LLC

PETITION FOR EXEMPTION PURSUANT TO SECTION 333 of the Eagle Vision USA Productions, LLC Braselton • GA • 30517 carlmartin1000 @gmail.COM EagleVisionUSA @gmail.com JULY 31, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590 

### RE: Exemption Request Section 333 of the FAA Reform Act Eagle Vision USA Productions, LLC Carl W. Martin carlmartin1000@gmail.com To Whom It May Concern: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Eagle Vision USA Productions, LLC (EV), hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow commercial operations of our Small Unmanned Aircraft System (sUAS) in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The proposed exemption, if granted, would allow Eagle Vision USA to conduct commercial operations of small unmanned aircraft systems (“sUAS”) meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333. Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems” provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited operation authorization” if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial sUAS operations. We have closely reviewed the FAA’s existing exemptions grants under section 333, and submit this request as being materially similar to Exemption Numbers: 12204 11430, 11365, 11409, 11209, 11111 among others. We are fully prepared and willing to operate under (and abide by) the exemptions already granted and the conditions required in Exemptions 11430 and 11365. The detailed request below is provided to further demonstrate our understanding of the rationale for the FAR exemption requests and associated decisions by the FAA, as well as provide a basis for establishing our need for the same. We hope the FAA determines that good cause exists for not requiring publishing petition summary in the Federal Register as this request does not set a precedent and parallels existing grant authorizations. Respectfully Submitted, Eagle Vision USA Productions, LLC

# eagle vision usa productions, LLC PETITION FOR EXEMPTION PURSUANT TO SECTION 333 of the FAA MODERNIZATION AND REFORM ACT OF 2012 Page 2 

## PETITION FOR EXEMPTION 14 CFR § 11.81 SECTION 1 NAME AND ADDRESS OF PETITIONER: Eagle Vision USA Productions, LLC Carl W. Martin PO Box 1000 Braselton, Georgia 30517 carlmartin1000@gmail.com 

## SECTION 2 THE PETITIONER REQUESTS RELIEF FROM THE FOLLOWING REGULATIONS:
14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.405 14 C.F.R. 91.407 14 C.F.R. 91.409 14 C.F.R. 91.417 

## SECTION 3 HOW EAGLE VISION'S REQUEST AND GRANT OF AN EXEMPTION WILL BENEFIT THE PUBLIC: Granting Eagle Vision an exemption furthers the public interest and benefit. National policy set by Congress favors early integration of VAS into the NAS in controlled, safe working environments such as those proposed in this petition. Eagle Vision seeks to help facilitate safe integration of sUASs into mainstream USA in the following areas: • Real estate photography and videography relative to environmental audits and surveys (sUAVs) provide a much safer and cost efficient method to view possible land contamination issues • Construction progress photography • Residential property marketing • Utility Inspection Services • Search and rescue

- disaster rescue assistance • Education and Research • Current event photography

# eagle vision usa productions, LLC PETITION FOR EXEMPTION PURSUANT TO SECTION 333 of the FAA MODERNIZATION AND REFORM ACT OF 2012 Page 3 

## PETITION FOR EXEMPTION 14 CFR § 11.81 SECTION 4 EQUIVILANT LEVEL OF SAFTEY: An equivalent level of safety will be achieved because the operations will be conducted on

-site without significant transit time by the sUAS. All flights will be planned to terminate with no less than 25% reserve battery power still available. This restriction would be more than adequate to return the sUAS safely to its planned landing zone from anywhere in its confined area of operation even in the event of an unexpected occurrence. Operation of the sUAS with Less than 30 minutes of reserve fuel does not include the type of risks that Section 14 CFR § 91.151(b) was intended to alleviate given the size and speed of the sUAS, and the proximity of the flight operation to the landing zone Additionally, an equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the Eagle Vision's standard operating procedures and equipment User's Manuals. As provided in the Safety Checklists, the PIC will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. The PIC is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. Compared to normal flight aircraft, Eagle Vision's multi

- rotor aircraft weigh a maximum of 20 pounds, and given the lack of flammable fuel, 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 UAS, as well as the location where it is operated. Furthermore, by operating at such lower altitudes (400' or less), the sUAS will not interfere with aircraft that are subject to the minimum safe altitude regulations. Eagle Vision considers public safety to be its number one priority before it commences any flight operations. As such, Eagle Vision will: • Only operate u nmanned aircraft weighing less than 20 lbs. • Only operate within visual line

- of

- sight (VLOS) only; the unmanned aircraft must remain within VLOS of the operator or visual observer. • At all times the small unmanned aircraft must remain close enough to the operator for the operator to be capable of seeing the aircraft with vision unaided by any device other than corrective lenses. • Small unmanned aircraft may not operate over any persons not directly involved in the operation. • Daylight

- only operations (official sunrise to official 11 sunset, local time).
• Must yield right

- of

-way to other aircraft, manned or unmanned. • Maximum airspeed of 50 mph
• Maximum altitude of 400 feet above ground level.
• Minimum weather visibility of 3 miles from control station.
• No operations from a moving vehicle or aircraft, except from a watercraft on the water.
• Eagle Vision will require a preflight inspection of the aircraft by the operator before every flight. • UAV operator will not conduct flight operations without an additional person assisting in with flight observation.

# eagle vision usa productions, LLC PETITION FOR EXEMPTION PURSUANT TO SECTION 333 of the FAA MODERNIZATION AND REFORM ACT OF 2012 Page 4 

## PETITION FOR EXEMPTION 14 CFR § 11.81 SECTION 5 sUAVs PROPOSED TO BE FLOWN BY EAGLE VISION UNDER THIS EXEMPTION: (1) DJI Phantom 2 Vision Plus (2) DJI Phantom 3 (3) DJI Inspire 1



## SECTION 6 A summary the FAA can publish in the Federal Register, stating: (1) The rule from which you seek the exemption; and (2) A brief description of the nature of the exemption you seek. 1. Petitioner: Eagle Vision Usa Productions, LLC 2. Sections of 14 C.F.R. Affected: §§ Part 21, Subpart H; 91.203; 45.23; 91.9; 91.119; 91.121; 91.151; Subpart E; and 8900.227 para(16)(4). 3. Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §§ Part 21, Subpart H; 91.203; 45.23; 91.9; 91.119; 91.121; 91.151; Subpart E; and 8900.227 para(16)(4)in order to conduct commercial small unmanned aircraft system operations on operations described herein and these operations will meet or exceed those requirements that the FAA requires for similar operations.



## SECTION 7 REQUEST TO FLY OUTSIDE OF THE USA: Eagle Vision USA Productions, LLC does NOT request permission to fly outside of the USA.

# eagle vision usa productions, LLC PETITION FOR EXEMPTION PURSUANT TO SECTION 333 of the FAA MODERNIZATION AND REFORM ACT OF 2012 Page 5 

## PETITION FOR EXEMPTION 14 CFR § 11.81 SECTION 8 SUMMARY Eagle Vision USA Productions, LLC shares Congress’s goal of getting sUAS flying commercially in the United States safely and soon. In the FAA Modernization and Reform Act of 2012, Congress directed the FAA “to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system” and, under Section 333 of that law, gave the FAA power to grant innovators “expedited operational authorization” to do so. By this petition, Eagle Vision is seeking authorization to conduct sUAS operations on sites in order to be more helpful to the public concerning environmental issues and by providing other

- 'from the air' valuable services. Further, granting this request will do nothing more than allow Eagle Vision to do what thousands of hobbyists and manufacturers of model aircraft do every day, except we will abide by much stronger safety measures. Eagle Vision has, as one of its owners an aviation expert and licensed private pilot to manage our sUAS program. Under his supervision we would provide a safer level of operation that is superior to current regulations.

Thank you for your consideration and I look forward to your response. I can be contacted directly via email or cell phone at your convenience. Respectfully Submitted,
Carl W. Martin, CPA President Eagle Vision USA Productions, LLC