## Requested Exemptions

14 CFR 61.23(a) and (c) Our current pilot holds a commercial helicopter rating. However, our VO may pursue an FAA airman certificate in the future. Therefore we request relief from 61.23(a) and (c) to allow any pilot that holds an FAA airman certificate to operate a UAS under thi s exemption with a U.S. issued driver’s license, in lieu of an FAA

- issued medical certificate. Our PICs will, of course, comply with 61.53, Prohibition on operations during medical deficiency. 

### 14 CFR 61.101(e)(4) and (5) 14 CFR 61.113(a) 14 CFR 61.315(a) We request relief from 61.101(e)(4) and (5) and 61.113(a) to allow a PIC holding a recreational or private pilot certificate to operate a UAS for compensation and hire, subject to limitations. We also request relief from 613.15(a) to permit the holder of a sport pilot certificate to act as the PIC of UAS operated under this exemption, if issued. 

### 14 CFR 91.7(a) Based upon previously issued exemptions No. 11481 and No. 11138, we submit that our aircraft, a DJI Phantom 3 Advanced and a DJI Phantom 1, will not require an airworthiness certificate. We request relief from 91.7(a) as we believe the PIC can safely determine whether the aircraft are in a condition for safe flight. 

### 14 CFR 91.119(c) In order to safely integrate with the NAS, we request relief fro m 91.119(c) because our aircraft would be operated at altitudes below 500 feet AGL. Our UASs are rotorcraft and 91.119 (d)(1) seems like a more reasonable minimum safe altitude standard providing that permission has been granted from nonparticipants and t hat said nonparticipants are sufficiently protected from the UAS and/or debris in the event of an accident/incident. 

### 14 CFR 91.121 Because both of our aircraft, the DJI Phantom 3 Advanced and the DJI Phantom 1 utilize electronic global positioning system s with a barometric sensor; we request relief from 91.121. 

### 14 CFR 91.151(a)(1) Our aircraft use battery power instead of fuel and the duration of our flights are much shorter than the listed minimums for fixed

-wing or rotorcraft. Based upon previously issued exemptions, we request limited relief from 91.151(a)(1) that would prohibit the PIC from beginning a UAS flight unless (considering wind and forecast weather conditions) there is enough available power for the UAS to operate for the intended operati onal time and to operate thereafter for at least five minutes or with the reserve power recommended by the manufacturer if greater.

### E. 14 CFR 91.405(a); 407(a)(1) and (2); 417(a) and (b)

These regulations apply to aircraft with an airworthiness certifica te and we submit, based upon previously issues exemptions No. 11481 and No. 11138, that our aircraft will not require an airworthiness certificate. We believe we can achieve an equivalent level of safety with relief from the aforementioned regulations, as such shows in our operational procedures, as well as the multiple safety system checks onboard the UAS’s. An inspection will be performed by the PIC prior to each flight. Issues not addressed in the operational manual will be addressed through the manufacturer by qualified maintenance personnel. The DJI Phantom aircraft we operate are equipped with software that performs automated system checks; the failure of any check prevents take

- off. And in the case of any failures during flight, such as low battery or loss of ground control functions and/or signal, our UAS’s are programmed with the return to home function and will automatically return to their original take

- off position on the ground. 

## Operational Procedures Mission Planning Each flight is preced ed by a mission evaluation between the PIC, VO, and any participating parties (property owners, observers). This evaluation covers the mission goals and an assessment of safety concerns. 

### Preflight Weather

– check NOAA to confirm weather conditions in th e area meet day VFR minimums. Operational Area

– Confirm that aircraft user manual and any other necessary documentation (pending exemption approval) including written permission from property owners is readily available. Confirm that nonparticipants ar e not in the area or are appropriately sheltered in the event of accident or incident. Landing Area

– ensure a firm takeoff/landing surface. If departing from other than firm surface (grass, gravel) utilize the portable landing pad. Ensure appropriate dis tance from obstacles and confirm that the planned flight path can be executed. Confirm appropriate abort sites if mission cannot be completed as planned. Equipment
– visually inspect aircraft: check blades, body, and landing gear for cracks or flaws. Ins pect battery: check connection terminals, check leads for wear, check case for cracks or flaws. Inspect remote: before powering on, check that each button properly actuates and ensure that control sticks have full range of motion. Ensure auxiliary flight t imer is functioning. Proceed to manufacturer’s preflight checklist: 1. Remote controller, Intelligent Flight Battery, and mobile device are fully charged.2. Propellers are mounted correctly and firmly.

3. Micro

- SD card has been inserted, if necessary. 4. Gimbal is functioning normally. 5. Motors can start and are functioning normally. [VO

- start auxiliary flight timer now] 6. The DJI Pilot app is successfully connected to the aircraft. DJI Pilot app, check values: Compass status, IMU values, Gain va lues, Max height, RTH height, R/C EXP & Gain, satellite status. Confirm GPS signal is sufficient for safe flight. Set Home Point. Hover pre

-takeoff checks

– Bring UAS to 8 foot AGL hover, confirm GPS signal, check altitude readout. Confirm battery and UAS LEDs are functioning normally. Check that all control inputs are functioning normally. Conduct flight. Ensure PIC and VO are a safe distance from landing site. Land, power off. VO

– stop auxiliary flight timer. 

### Post

- flight Confirm power off on UAS and re mote. Touch each motor to check for inordinately high temperature. Visually inspect blades, body, and landing gear for flaws or cracks. Remove battery from UAS. If necessary, clean UAS with a damp cloth. Before leaving the landing area, record flight in b attery performance log. Return to base of operations. Download flight data. PIC and VO log flight time after comparing manually recorded flight time to onboard flight log. 

### Inspections Thorough inspections occur every four flights or if the time between flights exceeds 14 days. The 14 day time period has been established based upon the frequency of firmware updates for the DJI Phantom 3. Visually inspect UAS (body, landing gear) for cracks or flaws. Inspect blades for wear. Check that blades are mounted to the correct motor and are tensioned properly. Clean all surfaces. Check battery wires, terminals, and case. DJI pilot app: Check battery error log. Firmware
– if a new version is available, review release notes, then install. If an update was required, perform thorough control checks followed by a test flight while following normal operating procedures and safety checks.