21 DEC 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

Re: Petition for Exemption Request of AirVisionPlus, under Section 333 of the FAA Reform Act and Part 11

of the Federal Aviation Regulations from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113 (a)&

(b); 14 C.F.R. 91.7 (a); 14 C.F.R. 91.9 (b) (2); 14 C.F.R. 91.103; 14 C.F.R. 91.109; 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. 91.405 (a); 14 C.F.R. 91.407(a)

(1); 14 C.F.R. 91.409 (a) (2); 14 C.F.R. 91.417 (a) &(b).

Dear Sir/Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R.

Part 11, AirVisionPlus, an operator of small Unmanned Aircraft Systems (UASs) hereby applies for an

exemption from the before mentioned Federal Aviation Regulations (FARs) to allow commercial

operation of its UASs. AirVisionPlus will conduct its operations within and under the conditions of this

petition or as established by the FAA in granting a Section 333 exemption toAirVisionPlus.

The name and address of the applicant is:

AirVisionPlus

Robert Lawn

219 Salk Way

Placentia, CA 92870

Ph.: 714-854-5029

Email: info@airvisionplus.com

Specific Sections of 14 CFR from which AirVisionPlusseeks an exemption:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

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. 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (b)
AirVisionPlus seeks an exemption to be able to provide the following services to our public and privateclients:

· Construction site observation and monitoring.

· Aerial surveying, mapping, Cad and photogrammetry.

· Photography, videography and marketing.

· Inspection of structures and site plans.

· Land survey and development.

· Closed set filming.

· Weddings, Events and or promotions.

The requested exemptions would permit AirVisionPlus to operate small, unmanned UASs under conditions that are

1) limited, 2) controlled, 3) economical, and 4) would provide safety enhancements over conventional aircraft.

Approval of this exemption would thereby enhance safety to the public and fulfill the FAAS responsibilities to

establish requirements for the safe operation of such aircraft systems in the national airspace system.

AirVisionPlus proposes to operate the Yuneec Q500 Typhoon, Q500 4K and the DJI Phantom 3 Professional, DJI

Inspire 1. The relevant user manuals of the UASs are attached. AirVisionPluss UASs weigh 55 or fewer pounds

including payload. The UASs will be operated, under normal conditions, at a speed of no more than 25 mph and have

the capability to movein the vertical and horizontal plane simultaneously. The UASs will be operated only in line of

sight and only within a controlled area. These operations will insure that the UAS will not create a hazard to users of

the national airspace system or the public.

Given the small size of the UASs involved and the restricted controlled environment which the UASs will operate,

AirVisionPlus falls within that zone of safety (an equivalent level of safety) in which Congress envisioned that the

FAA, by exemption, allow commercial operations of UASs to operate. Also, due to the size of the UASs and the

controlled areas in which the UASs will operate, approval of the application presents no national security issue.

Under Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, the equivalent level of

safety surrounding the proposed operations, and the public benefit, including enhanced safety, reduction in

environmental impacts, including reduced emissions associated with allowing UASs, the grant of the requested

exemptions is in the publicsinterest.

AirVisionPlus proposes that the exemption requested apply to civil aircraft that have the characteristics and that

operate with the limitations listed. These limitations provide for at least an equivalent or evenhigher level of safety

to operations under the current regulatory structure because the proposed operations represent a safety

enhancement to the existing safe operations conducted with conventional aircraft.These limitations and conditions

to which AirVisionPlus agrees to be bound when conducting commercialoperations under an FAA issued exemption

include:

1. The UAS will weigh less than 55 pounds (25 kg).

2. The UAS will be operated at a speed of no more than 25 mph.

3. Only visual line-of-sight (VLOS) operations will be allowed; the UAS must remain within VLOSof the

operator or a visual observer (VO).

4. UAS operations will occur during daylight hours only.

5. No person may act as an operator or VO for more than one unmanned aircraft operation atone time.

6. Minimum crew for each operation will consist of the UAS Operator and a VisualObserver.

7. The UAS Operator will be Pilot in Command (PIC) who shall have completed the requiredFAA training,

along with training from the manufacturer or distributor of theUAS.

8. The PIC will be vetted by the TSA and have a TSA Known Traveler Number, and have avalid drivers

license from the State of the PICs domicile.

9. The UAS will only operate within a confined controlled area of the flight operationsarea.
10. Maximum total flight time for each operational flight will be 15 minutes. Flights will be terminated

at 30% battery power reserve, should that occur prior to the 15-minutelimit.

11. A briefing will be conducted in regard to the planned UAS operations prior to each days activities.

It will be mandatory that all personnel who will be performing duties within the boundaries of the

safety perimeter be present for this briefing.

12. The operator will obtain the consent of all persons involved and ensure that only consenting persons will

be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based upon

an equivalent level of safety determination.

13. UAS operations may not occur over any persons not directly involved in theoperation.

14. PIC and VO will at all times be able to communicate by voice.

15. PIC will conduct preflight inspections to ensure the UAS is safe foroperation.

16. The UAS will be required to yield right-of-way to all other aircraft, manned orunmanned.

17. Flights will be operated at an altitude of no more than 200 feet AGL.

18. The UAS will only operate in Class G airspace.

19. The UAS will stay certain distances away from airports or heliports:

a. Five (5) nautical miles (NM) from an airport having an operational control tower;or

b. Three (3) NM from an airport with a published instrument flight procedure, but not an

operational tower; or

c. Two (2) NM from an airport without a published instrument flight procedure or an

operational tower; or

d. Two (2) NM from a heliport with a published instrument flight procedure.

20. UAS operations will be permitted to occur only when conditions allow minimumweather visibility

of 3 miles from the controlstation.

21. Written permission from the relevant property owners will be obtained.

22. All required permissions and permits will be obtained from territorial, state, county, or city jurisdictions,

including local law enforcement, fire, or other appropriate governmentalagencies.

23. If the UAS loses communication or loses its GPS signal, the UAS will have capability to return toa predetermined location within the Security Perimeter and land.

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

emergencies.

Accordingly, AirVisionPlus respectfully requests that the FAA grant the requested exemption.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. 91.203 (a) (1).

Part 21 Subpart H, entitled Airworthiness Certificates, sets forth the procedural requirements for the issuance of

airworthiness certificates as required by 14 C.F.R. 91.203 (a) (1). Given the limited size, weight, and operating area

associated with the UAS to be utilized by AirVisionPlus, an exemption from Part 21, Subpart H meets the requirements

of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section

333 of the Reform Act 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 particularUAS.

The UASs operated by AirVisionPlus is less than 55 pounds fully loaded, carries no pilot or passenger, carries no

explosive materials or flammable liquid fuels, and operates exclusively within a secured area.Operations under this

exemption will be controlled and monitored by the operator and in compliance with the conditions of this document

and also in compliance with any local public safety requirements. The FAA will have advance notice of all operations

through a COA or more likely be operated under the blanket 200- foot COA.
In this case, an analysis of these criteria demonstrates that the UAS operated without an airworthiness

certificate, in the restricted environment and under the conditions proposed, will be at least as safe, or safer,

than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the

restrictions and conditionsproposed.

14 C.F.R. 45.23 (b). Marking of the Aircraft.

14 C.F.R. 45.23 prescribes that 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.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no

entrance to the cabin, cockpit, or pilot station on which the word Experimental can be placed. Given the size of the

UAV, 2-inch lettering will not be possible. An equivalent level of safety will be theword Experimental, at a size that

is as large as practicable, will be placed on the fuselage in compliance with Section 45.29 (f). Additionally, Parametrix

will mark its UASs with its company name and contact information.

14 C.F.R. 61.113 (a) &(b): Private Pilot Privileges and Limitations: Pilot in Command. Sections 61.113

(a) & (b) limit private pilots to non-commercialoperations.

Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of

safety of current operations by requiring the PIC operating the aircraft to have successfully completed, at a minimum,

FAA sport pilot ground instruction and passed the FAA Sport Pilot written examination or other FAA recognized

equivalent training. The PIC will have also completed amanufacturers training program for the model the PIC will be

operating.

Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living thing

on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance.

The level of safety provided by these requirements will be at least as safe, or safer, than that provided by a single

individual holding a commercial pilots certificate operating a conventional aircraft. The risks associated with the

operation of the UASs are diminished from the level of risk associated with commercial operations contemplated by

Part 61, when drafted, that allowing operations of the UAS as requested with FAA ground instruction and

manufacturers training exceeds the present level of safety achieved by 14 C.F.R. 61.113 (a) &(b).

14 C.F.R. 91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthycondition.

As there will be no airworthiness certificate issued for the UAS, should this exemption be granted, no FAA regulatory

standard will exist for determining airworthiness of the UASs operated by AirVisionPlus. Given the size of the aircraft

and the requirements contained in the manufacturers manual for maintenance and use of safety check lists prior to

each flight, an equivalent level of safety will beprovided.

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

Section 91.9 (b) (2) provides that no person may operate a U.S.-registered civil aircraft . . . . (2) For which an Airplane

or Rotorcraft Flight Manual is not required by Section 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.
AirVisionPluss UAS, given its size and configuration, has no ability or place to carry such a flight manual on the

aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item

on the aircraft. The equivalent level of safety will be maintained by keeping the UAS flight manual at the ground

control point where the PIC operating the UAS will have immediate access toit.

14 C.F.R. 91.103: Preflight action.

This regulation requires each pilot in command to take certain actions before flight to insure the safetyof flight.

Because FAA-approved UAS flight manuals will not be provided for the aircraft, an exemption will be needed. An

exemption is requested from this requirement as the PIC will take separate preflight actions, including checking the

condition of the UAS, checking flight battery requirements, weather conditions, checking takeoff and landing

distances, and all other actions in the User Guide and safety checklists. These actions will provide an equivalent level

ofsafety.

14 C.F.R. 91.109: Flightinstruction.

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being

used for flight instruction unless that aircraft has fully functioning dualcontrols.

UASs, by their design, do not have fully functional dual controls. Flight control is accomplished throughthe use of a

controls that communicate with the aircraft via radio communications. The equivalent level of safety provided by the

fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. 91.119: Minimumsafe altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (c) limits aircraftflying over

areas other than congested areas to 500 AGL. Over sparsely populated areas, aircraft cannot be operated closer than

500 feet of any person, vessel, orstructure.

This exemption is requested for minimum safe altitudes as AirVisionPlus proposes to operate its UASs below 200

AGL. As set forth herein, the UAS will never operate at higher than 200 AGL. 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. Additionally, no

flight operations will be made without the permission of the property owner or local officials.

14 C.F.R. 91.121Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference toan altimeter

that is set to the elevation of the departure airport or an appropriate altimeter setting available before departure.

Because the UAS will not have a barometric altimeter, but instead a GPS altitude read-out, an exemption is requested.

An equivalent level of safety will be achieved by confirming the altitude of the launch siteshown on the GPS altitude

indicator before flight.

14 C.F.R. 91.151(a): Fuel Requirementsfor Flight in VFR Conditions.

Section 91.151 (a) prohibits an individual from beginning 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 ofintended

landing, and, assuming normal cruising speed  (1) During the day, to fly after that for at least 30minutes; or (2) At

night, to fly after that for at least 45 minutes.

The intent of this requirement is to provide enough fuel or energy reserve in the event of delays due to congestion or

weather at an airport. The typical battery powering a UAS provides approximately 25 minutes of powered flight. To

meet reserve requirement in 14 CFR 91.151, AirVisionPluss UAS flights would be limited to approximately 15 minutes

or less in length. Given that the limitations of a UAS proposed flight will be operated with visual line of sight and the

location of its proposed operations within a predetermined area. AirVisionPlus believes that an equivalent level of
safety can be achieved by limiting flights to 15 minutes or 70% ofbattery power, whichever happens first. This

exemption would be more than adequate to return the UAS to the landing zone from anywhere in its limited

operating area. Night flights are not requiered or needed.

14 C.F.R. 91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration. The regulation provides in pertinent part:

(a) Except as provided in Section 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 Section 91.715 is displayed at the cabin or cockpit

entrance so that it is legible to passengers or crew.

The UAS has no cabin or cockpit, there is no ability or place to carry certification and registrationdocuments or to

display these documents on the UAS. As with 14 C.F.R. 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft, an

equivalent level of safety will be achieved by keeping these documents at the ground control point where the PIC

operating the UAS will have immediate access to the documents, to the extent needed and applicable to the UAS.

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.

These regulations require that an aircraft operator or owner shall have that aircraft inspected asprescribed in

subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have

discrepancies repaired as prescribed in Part 43 of this chapter..., and others shall inspect or maintain the aircraft in

compliance with Part 43.

Because these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not

apply to AirVisionPlus. The operator following the manufacturers product and operating manual will accomplish

maintenance. An equivalent level of safety will be achieved because AirVisionPluss UASs are very limited in size and

will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise,

the UAS can immediately land and will be operating from no higher than 200 feet AGL. As provided in the

manufacturers manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform

required maintenance, and keep a log of any maintenanceperformed.

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: Applicant seeks an exemption from the followingrules:

14 C.F.R. 21, subpart H; 14 C.F.R 45.23(b); 14 C.F.R. 61.113( a) & (b); 14 C.F.R. 91.7 (a); 14 C.F.R. 91.9 (b) (2);

14 C.F.R. 91.103(b); 14 C.F.R. 91.109; 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) and (b); 91.405 (a); 14 C.F.R. 91.407 (a) (1); 14 C.F.R. 91.409 (a) (2); 14 C.F.R. 91.409 (a) (2);and

14 C.F.R. 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 pounds orless).

Approval of exemptions allowing commercial operations of UASs will enhance safety by reducing risk. Conventional

operations, using jet or piston-power aircraft, operate at low altitudes just feet from the subjects being photographed

and in close proximity to people and structures and present the risks associated with vehicles that weigh in the

neighborhood of 4,000 pounds and carrying large amounts of aviation fuel. In contrast, a UAS weighing fewer than 55

pounds and powered by batteries eliminates almost all of that risk given the reduced weight and lack of combustible

fuel carried on board. The UAS will carry no passengers or crew and, therefore, will not expose anyone to the risks

associated with manned aircraft flights.
The operation of UASs, weighting less than 55 pounds, conducted in the strict conditions outlined above, will provide

an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting the

applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at

slow speeds, close to the ground, and in a controlled environment and, as a result, are far safer than conventional

operations conducted with turbine helicopters operating in close proximity to the ground and people.

Additional Information: Privacy

All flights will occur over private or public controlled access property with the property owners prior consent and

knowledge. Photography will be of people who have also consented to being filmed or otherwise have agreed to be in

the area where filming will take place. The grant of this exemption request will provide improved safety in both day

and night operations. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012, size, weight,

speed, operating capabilities, proximity to airports and populated areas, and operation within visual line of sight and

national security provide more than adequate justification for granting the requested exemptions allowing

commercialoperations.

Regards,

AirVisionPlus

Robert Lawn

info@airvisionplus.com

714 854-5029