4790 N Powerline Rd

Pompano Beach, FL 33073

Contact: Gabriel E Alvarez, President

(954) 937-4029

RE: EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM ACT AND PART 11 OF 

THE FEDERAL AVIATION REGULATIONS 

 

Dear Sir/Madam,

As requested in your letter dated August 3, 2015, we are providing detailed information on why 

the approval of this request is in the public’s interest and how the approval will provide a level 

of safety at least equal to that provided by the rule, Aerial Vision Services seeks exemption 

from. We look forward to working closely with the FAA to "... safely accelerate the integration of 

civil unmanned aircraft systems into the national airspace system ..." as directed by Congress.

Within this letter you will find our internal logs procedures: a) Equipment Checklist, b) Job 

Description & Assessment and c) Maintenance. In two separate attachments within the public 

docket No. FAA-2015-1733 you will find the “Phantom 3 Safety Guidelines and Disclaimer” to 

support our request on reference of the safety of our equipment. 

Thank you for your time and consideration in this matter and please feel free to contact us

with additional information or requests.

 

PUBLIC’S INTEREST 

The public's best interest is achieved by the safe integration of UAS into the NAS. With the 

ongoing exemption process, the FAA has to identify those exemption requests with the public's 

best interest in mind and select the companies who will be able to achieve this in a safe and 

responsible manner.
 

 

Safety Benefits for the Community 

Two of the main problems the public has with UAS are the fear of what they will be used for 

and whether or not they are safe to fly within the same airspace as commercial airliners, or get 

in the way of first responders when other people’s lives are at risk. Aerial Vision Services is 

more than willing to help with public education and that starts with conducting operations 

within strict operating environments and then providing the results to the public to start to 

sway opinion in a positive light.

Also sending police, fire or search & rescue workers into harm's way without knowing what 

danger they will encounter is an unacceptable risk. Using drone technology, you can fly a 

camera into the scene to assess the danger before sending in human beings.

Helicopter type drones are the perfect answer for this application as they do not require 

takeoff or landing space and can be flown into small spaces and hovered to gather images and 

assess risk. Flying a drone-mounted high-resolution video/still camera into an emergency 

scene provides instant visual feedback on what is taking place without having to risk the safety 

of a first responder.

As we mentioned on our request, entered on May 15, 2015 into the public docket No. FAA2015-1733, we use the DJI PHANTOM 3 PROFESSIONAL, is powered by batteries, is smaller, 

lighter, requires no fuel, and more maneuverable than larger aircraft running on combustible 

fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk 

levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. 

With a small payload and maximum flight time of only 25 minutes with maximum air speed of 

30 knots, this is offers little or no risk to national security.

Also we operate with 2 ground personnel: the PIC (Pilot in Command) which conducts a preflight inspection and determine the UAS is in a condition for safe flight, and also is responsible 

for the equipment maintenance to ensure that the sUA is in good condition for a safe flight, 

and the VO (Visual Observer) who will remain within 5-10 feet of the PIC for duration of flight in 

order to effectively communicate potential safety of flight issues

Commercial Benefits for Small Businesses 

Providing aerial images with a sUA reduce costs and improved quality of presentation which 

will be valuable to and benefit many buyers and sellers of real property; low-level oblique 

photos and video from several angles are far more effective than ground based imagery for 

displaying the characteristics of large, complex properties with several buildings and large 
trees. The applicants in the past have chartered 2-seat full-sized helicopters for this purpose, 

which has proven more costly than many potential clients have been able to afford. 

Aerial Vision Services will provide any additional information requested and will diligently work 

with the FAA to make this approval a reality as it is in the best interest and safety of the public 

as directed by Congress.

Best Regards,

Gabriel E Alvarez

President

(954) 937-4029