**U.S. Department of Transportation**

**Docket Management System 1200 New Jersey Avenue, SE**  **Washington, D.C. 20590 February 12** **, 2015**

**UAV Field Services, Inc. Brian Grant**  **/ Principal** 30 Milburn Circle Pasadena, MD 21122 410

- 916

-0109 Email briang@uavfsi.com

**RE: Exemption Request Section 333** of the **FAA Reform Act of the Federal Aviation Regulations** from 14 CFR 91.7(a); 91.9(B)(2); 91.103; 91.109; 91.119 (c); 91.121; 91.151 (a)(1); 91.203(a)(b); 91.405(a); 91.407(a)(1); 91.409(a)(1)a nd (2); 91.417(a)&(b) ; 45.23(b) ; Part 21 ; 61.113(a)(b)

Dear Sir or Madam: We are writing pursuant to the FAA Modernization and Reform Act of 2012 ( Reform Act ), and the procedures contained in 14 C.F. R. 11, to request that UAV Field Services, Inc, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regula tions (FARs) listed above so th at UAV Field Services may operate its small unmanned aircraft / lightweight unmanned aircraft system (UAS) commercially in airspace re gulated by the Federal Aviation Administration (FAA) ; as long as such operations are conducted within and under the conditions outlined here in or as may be established by the FAA as required by Section 333. It is the request of the petitioner for exempti ons listed above in order to legally and safely operate the **DJI Phantom 2 Vision Plus UAS** , in the National Airspace System, for the purpose of Unmanned Aerial Photography and Videography for the insurance , utility and telecommunications industries

. E nhance ment of Pu blic awareness of UAS operation and finally enhanced safety for both the G eneral Public, Flight Crews and the Labor Force described herein.The main purpose for the requested Exemption is to allow UAV Field Services to utilize its UASs

to inspe ct cellular towers for the telecommunications comp anies and their subcontractors. UAV Field Services has been given written consent to access these Secure / Sterile sites by the property / tower owners . The site access allows UAV Field Services to perform all inspections at low altitude and always within VLOS. Most all tower inspection fli ghts will be under 200ft. AGL , and a ll flight operations will remain below 400 ft AGL

. UAV Field Services will cordon off the site to add a buffer to keep the public / non - participants safe. This will be done by using cones and signs advising of the possible hazard. Not only is pu blic safety of utmost concern but also the safety of the climbing crews tasked with routine inspection of the towers. UAV Field Services and i ts UAS would alleviate the day to day height exposure of inspection services and allow them to concentrate on service and repairs. Climbers have one of the highest incidents of death in the labor force. UAS operations would greatly reduce the number of fal ls and deaths associated with this type of operation. UAS used to inspect cell towers allows the cell carriers to enhance operability to its clients ; reducing down time and increasing signal strength by proactively inspecting towers and making repairs before failures or damages occur. Th e secondary request for Exemption is to allow UAV Fi eld Services to utilize its UAS to inspect power transmission lines for the utility companies and their subcontractors. UAV Field Services has been given written conse nt to access these Secure / Sterile sites by the property owners. This would reduce the need for low flying manned helicopters. These manned flight systems have a relatively goo d safety record. The use of UAS would reduce the carbon foot print and noise po llution. Limiting and /or reducing these manned operations would also reduce exposure to the public and power grid infrastructure in general . The operations that UAV Field Services would perform would be localized and remain VLOS on larger transmission li nes under 400 ft AGL. These larger transmission lines are located in restricted areas which would limit concern for non

- participant exposure. UAV Field Services will cordon off the site to add a buffer to keep the public / non

- participants safe. This will be done by using cones and signs advising of the possible hazard. Keeping the energy grid fully operational and maintained with the aid of UAS is definitely in public interest. The third request for Exemption is to allow UAV Fi eld Services to utilize it s UAS to assist insurance companies with claim assessments . Currently insurance companies use their employees to climb roof tops to assess damage with ladders ( ladders themselves pose a property damage exposure to gutters, windows & siding) . This involves climbing on high roof tops often with step pitches. This is an area of major concern for insurance companies as this exposure has lead to many sever falls to their employees. UAV Field Services will be given written consent to access these claim sites by the property owners and the insurance carriers. UAV Field Services will cordon off the site to add a buffer to keep the public / non

- participants safe. This will be done by using cones and signs advising of the possible hazard. The operations that UAV Fi eld Services would perform would be restricted to severe, hard to access roof

-top claims. Operations would remain VLOS, under 2 00 ft AGL, utilize a PIC & VO. Utilizing UAS to do these claims inspections and assist insurance carriers settle claims in a tim ely & safe manner is of public interest. The operati ons listed above require flight within 100 ft of buildings and structures. UAV Field Services has instituted several safety measures to limit and avoid collision or damage to such buildings or structures and / or minimize risks and exposures:

- Written permission from property / building owners outlining operations and describing potential hazards.

- General Liability insurance to cover any damages.- All flight operations follow operation manual , guidelines and procedures listed herein

.

- UAS utilizes propeller guards to reduce / eliminate flight failure in the event of collision

UAV Field Services exemption request would permit its operation of lightweight ( less than 55 lbs.) , UAS in tightly controlled and limited airspace. Predetermined, specifically marked areas of operation, cordoned off locations and corresponding enhancements to operate within current safe ty parameters and new ones to be implemented by the FAA Exemption relief

. Safety is paramount for UAV Field Services . We wish to help integrate UAS into the NAS by performing our services with the utmost concern for the safety of our operators, the general public and property. To achieve this UAV Field Services has instituted several f light parameters, conditions, guidelines and limitations to adhere to before, dur ing and after flight operations all of which are outlined in the UAS POH / Operators Manual . The se conditions are based off of P art 333 exemptions that have already been appro ved by the FAA and have been integrated into our operations :

- The UAS will not exceed a ground speed of 50 knots.

-All operations will remain below 400 ft AGL.

-The UAS will weigh less than 55 lbs.

-All operations will remain in visual line of sight (VLOS).

- All operations will utilize a visual observer (VO). This VO will always be able to communicate verbally with the pilot in command (PIC).

- The operator must follow the procedures as outlined in its operator's manual. ( listed herein as P rotocol s & P rocedures & DJI User's Manual / Operators Manual ).

- Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight.

- Any UAS that has undergone maintenance or alterations that would affect the UAS operation or flig ht characteristics must undergo a functional test flight in accordance with operators manual.

- The operator must follow the manufacturer's UAS aircraft / component, maintenance, overhaul, replacement, inspection and life limit requirements.

- The PIC will must possess at least a private pilot certificate and at least a third

- cl a ss medical certificate. And also meet flight review requirements specified in the 14 CFR 61.56.

- Prior to operations PIC will undergo UAS specific training for type (multi

- rotor) make and model aircraft and log hours appropriately. PIC will also maintain proficiency and currency (every 90 days) with UAS. Keeping with a manner consistent with 14 CFR 61.51(b).

- PIC & VO will have successfully completed a qualification process, as outlined in the operators manual. Completion of this qualification process will be documented.- The UAS will not be operated directly over any person, except authorized and consenting flight

personnel.

- The PIC & VO will ensure that no persons are allo wed within 2 00 ft of the flight area except those consenting flight personnel .

- If UAS loses communication or losses it GPS signal, the UAS must return to a pre

- determined location within the security perimeter and land or be recovered in accordance with operator's manual.

- The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with operators manual.

- The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) p rior to conducting any operations. The COA will also require the operator to request a Notice to Airmen (NOTAM) not more than 72 hours in advance, but no less that 48 hours prior to the operation.

- All aircraft will be identified by a serial number, registered in accordance with 14 CFR part 47, and have identification ( N

- Number) markings in accordance with CFR part 45(c). Markings will be as large as possible.

- All operators will comply with all manufacturers Safety Bulletins.

- Before conducting operat ions, the radio frequency spectrum used for operation and control of UAS will comply with Federal Communications Commission (FCC).

- Prior to the planned operation (3 days) the operator will contact the local FSDO (that has jurisdiction of the area ) in wr iting and cover the plan of activities for the flight operation.

- The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the ground station during all operations.

- The UAS will remain clear and yield the right of way to all other manned operations and activities at all times.

- All operations will be conducted under visual meteorological conditions (VMC) and no night operations during night as defined in 14CFR 1.1.

- The UAS will not be operated by the PIC from any moving de vice or vehicle.

- The UAS will not be operated less than 500 ft below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

- The UAS will not operate in Class B, C, or D airspace without written a pproval from the FAA. The UAS will not operate within 5 nautical miles of the geographic center of a non

-towered airport.

- Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours.

- Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB website.The petitioner will outlin e in this document:

**1. Request for exemptions by Part and Subpart**  **2. Petitioners protocols and procedures for operations**  **3. The Unmanned Aircraft System (UAS)**  **4. The Public Interest** 



# 1. **REQUESTS FOR EXEMPTION BY PART AND SUBPART** 

**14 CFR 91.7(A)** Airworthiness Certificate; Prohibits the operation of an aircraft without an airworthiness certificate. Petitioner requests exemption based on previous **Exemption No. 11138** . The FAA has ruled that this make and model of aircraft (UAS) does not require an airworthine ss certificate.
**14 CFR 91.9 (B) (2)** Aircraft Flight Manual in the aircraft; Requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS, this regulation is inapplicable. An equivalent level of s afety will be achieved by maintaining a manual at the flight operations center. The FAA has previously issued exemptions to this regulation in **Exemption No. 10700 and 32827 14 CFR 91.103**  Pre

- Flight; No approved A irplane Flight Manual on board the aircraft . The petitioner asserts that an equivalent level of safety will be achieved by the PIC taking all preflight actions set forth in the operating documents, including reviewing weather, flight battery requirements, landing and take

- off distances, and aircraft performance data before initiation of flight.**14 CFR 91.109**

Flight Instruction; No dual controls available for flight instruction. **14 CFR 91.119(C)** Minimum Safe Altitudes; States that no person may operate an aircraft below the following altitudes: over other than congested areas, an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. The petitioner will never operate any UAS over an altitude of 400 AGL. The majority of the operations proposed will operate around 100 to 150 feet AGL as this usually provides the best angle of capture for the type of photography and videography operations proposed. The UAS utilized for this exemption is of exceptionally light weight and is not capable of speeds over 30 knots. The UAS is equipped with GPS guided auto pilot with a return home function in case loss of control by the PIC and is powered by seale d batteries thereby reducing the chance of post impact fire to nearly zero. There will be cas es when the 500 foot distance from structures will need to be exempted. (Example: Aerial Video of a 2 story home roof to determine and/or document extent of st orm damage.) In this type of operation every assurance will be made to keep persons outside of a reasonable, safe, clear area of operations and will only be conducted with the express permissi on of the property owner. See **Protocols and Procedures S ection** 

. The petitioner will implement procedures and policies to ensure that any person in the general vicinity of operations will be aware of such operations and ensure that all non

- essential personnel are cleared of the area of operations. See **Protocols and procedures Section 3.**  The petitioner therefore requests relief in part from **14 CFR 91.119(C)**

**14 CFR 91.121** Altimeter Settings; The petitioner requests relief from **91.121** for the following reason. The UAS is equipped with GPS derived altitude capability, however due to the limited altitude requested in this exemption, the FAA has previously granted Exemption for these types of operations. **Reference Exemption No. 11138** **14 CFR 91.151(a)**

Fuel for Flight; No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) unless there is enough fuel to fly to the first point of intended landing and, assuming normal cruise speeds (a)(1)During the day to fly for at least 30 minutes. The petitione r requests relief from **91.151(a)** due to the fact that the UAS is equipped with a battery and percentage indicator system. The UAS has a flight capability on full charge of a pproximately 25 minutes depending on camera usage and other variables. The petiti oner has established th at the maximum flight will be 15 minutes on a fully charged battery. This constitut es landing with approximately 25 percent fuel remaining. The petitioner believes that this follows the spirit and intent of the rule with a great ma rgin of safety. No UAS operations will be conducted at night, as defined by Federal Aviation Regulations.
**14 CFR 91.203(a)(b )**  Carrying of civil aircraft Certifications and Registrations; Provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining such certifications and registratio ns at the UAV Field Services flight operations center.
**14 CFR 91.405(a)** Maintenanc e required; The petitioner requests relief in part from **91.405(a)(1)** based on the **Protocols and Procedures S** **ection** on **Maintenance and M aintenance R** **ecords**

. **Also reference Exemption No. 11138**
**14 CFR 91.407(a)(1)** O peration after maintenance, preventive mainten ance, rebuilding, or alteration; The petitioner requests relief from **91.407(a)(1)** based on the **Protocols and Procedures S ection**  on **Maintenance, R eturn to**  **service after maintenance, and M aintenance records**  **. Reference Exemption No. 11138** **14 CFR 9 1.409(a)(1)(2)** 

Inspections; The petitioner requests relief from **91.409(a) (1)**  **(2)** bas ed on the **Protocols and Procedures S** **ection** on **Inspections. Reference Exemption No. 11138** 
**14 CFR 91.417(a)(b)** Maintenance records; The petitioner requests relief from **91.417(a)(b)** based on the **Protocols and Procedures S ection**  on **M aintenance records** 

.
**14 CFR 45.23(b)** Marking of the Aircraft; Applicable codes of Federal Regulation require aircraft to be marked according to certain specifications. UAV Field Services UASs are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two inch lettering is difficult to place on such small aircraft. Regardless, UAV F ield Services will mark its UAS in the largest possibl e lettering by placing the " N "number on its fuselage as required by 14 CFR 45.29 (f) so that the pilot, technician, spotter and others working with the UAV will see the markings. The FAA has previously issued exemptions to this re gulation through **Exemption No 10167 and 10700**

**14 CFR 21, Sub Part H** Airworthiness Certificates; Entitled Airworthiness Certificates, set forth requirements for procurement of necessary airworthiness certificates in relation to FAR 91.203(a)(1). The size, weight and enclosed operational area of UAV Field Services UAS permits exemption from Part 21 be cause UAV Field Services UAS meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the ai rworthiness certificate requirement under both the Act (49 USC 44701(f)) and Section 333 of the Reform Act. Both pieces of the legislati on permit the FAA to exempt UAS from the airworthiness certificate requirement in consideration of the weight, size, spe ed, maneuverability and proximity to areas such as airports and dense populations. UAV Field Se rvices UAS meet or exceed each of the elements.**14 CFR 61.113 (a)(b)** 

Private Pilot Privileges and Limitations / PIC; Private pilots are limited to non - commercial operations. UAV Field Services can achieve an equivalent level of safety as achieved by current Regulations because UAV Field Services UASs do not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills, though UAV Field Services pilot vetting and training program will. Further, private pilot licensees will operate UAV Field Services UASs with the same skill. Further, the risk attendant to the operation of UAV Field Services UAS i s far less than the risk levels inherent in the commercial activities outlined in CFR 61. Thus, allowing UAV Fi eld Services to operate its UAS with a private pilot as the pilot in control will exceed current safety levels in relation to CFR 61.113(a)(b).

# 2. **Protocols and Procedures for UAS operations.**

**A. Preflight**  **B. Area Security**  **C. Limitations of Operations**  **D. Airworthiness**  **E. Maintenance and Records**  **F. Pilot in Command Requirements**  **G. Visual Observer and Requirements**  **H. Reporting of Incidents and Accidents** 



## A. **Preflight Inspection of UAS (1).**  Preflight of the Unmanned Aerial System will follow the instructions in t he DJI instruction and U ser M anual. The Pilot in Command will certify that a preflight inspection has been accomplished with the date and time and signature in the UAS logbook. The preflight shall include the aircraft, transmitter, and batteries, m otors, rotors, landing gear, camera and gimbal mount. As a part of the preflight the Pilot in Command will assure th at weather conditions, area secur ity, and any other information essential to safe operation has been obtained.



## B. **Area Security (1).**  The PIC of the UAS will ensure that the operational area for the purposes of UAS flight shall be cleared of all nonessential persons at all times the UAS i s in flight. Additionally all nonessential persons shall be required to remain clear of the operations area by a minimum distance of 200 feet during operations. PIC shall ensure that cones and clearly marked signs are posted at all ingress\egress points to the operations areas. These signs will be of white background with red lettering stating the following: “U nman ned aircraft o perations underway. Please remain clear.” **(2).** In the event of a breach by nonessential persons into the operations area durin g the flight of UAS, the P IC shall immediately terminate flight operations until such time as the area can be cleared of these persons. **(3).** The UAS area of operation is defined as the Horizontal flight path(s) of the UAS as well as the Vertical flight pa th and Maximum altitude to be reached. Additionally the area betwe en the UAS s current position and its Home location is also considered operational area as it will proceed direct to i ts home location in the event of loss of ground control. **All nonessential perso**  **ns will not be allowed within 20 0 feet of any part of the operational**  **area during flight operations.**

## C. **Limitations of Operations (1)**  The UAS shall be operated in Da y time only, as defined by **14 CFR (2)**  UAS night operations are prohibited. **(3)** The UAS shall be operated by VLOS at all times **(4)** A Visual Observer shall be utilized at all times and must maintain VLOS at all times. **(5)** The UAS shall remain within 1000ft horizontal distance of the PIC at all times. **(6)** The UAS to be utilized is the **DJI Phantom 2 Vision + Unmanned Aircraft System**  . No other systems will be operated. **(7)** The UAS will h ave an altitude restriction of 400ft AGL. **(8)** The UAS will not be operated at a speed exceeding 30 Knots. **(9)** Operations Documents will be accessible to the PIC at all times and m ust be accessible during UAS operations and made a vailable to the Administrator on request. **(10)** PIC must inspect and ensure that UAS and ground control station is in airworthy condition prior to each operation; if determined un

- airworthy, all operations will b e suspended until such time as necessary maintenance has been performed and the UAS is determined to be in a safe condition for flight. **(11)** An operational flight test is required after any maintenance or alterations that may affect UAS operation or flight. **(12)** UAS maintenance must follow Manufactures aircraft/component, maintenance, overhaul, and replacement, inspection, and life limit requirements. **(13)** The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the ope rating documents. Maintenance and inspection, and alterations must be noted in the aircraft records, including total flight hours, description of work performed, and the signature of the authorized person returning the UAS to service. **(14)** UAS must comply with all Manufacturers’ Safety Bulletins

. **(15)** An authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. **(16)** UAS must by operated by a PIC possessing at least a Private Pilot Cert ificate, w ith most appropriate Class and C ategory and a t least a current Third C lass Medical. **(17)** PIC must meet the flight review requirements of 14 CFR 61.56 in an aircraft in which the PIC is rated. **(18)** Prior to operations for which exemption is requested the PI C must have accumulated and logged , in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours of UAS multi

- rotor. **(19)** Prior to operations PIC must have accumulated and logged a min imum of 5 hours as a UAS pilot in make and model listed in exemption. PIC must log at a minimum 3 takeoffs and landings in the preceding 90 days to meet currency requirements. **(20)** PIC is required to operate the UAS in accordance with 14 CFR 91.119. **(21)** No UAS ope ration within 5 nautical miles of an airport reference point as denoted on a current FAA chart. **(22)** No operations are allowed in the surface areas of Class B , C, and D airspace or in restricted airspace. **(23)** No operations are allowed if the return home function and \or autopilot are, or are suspected to be malfunctioning.**(24)** UAS shall not be operated from a moving platform of any type. **(25)** No operations shall be conducted with out an appropriate Certificate of Authority issued by the Administrator

. **(26)** A Visual Observer shall be utilized at all times when operating the UAS. **(27)** Should the PIC or Visual Observer detect that a manned aircraft is being operated in close proximity to the operations area , the UAS shall give right of way to the manned aircraft, and the PIC shall cease operations and land until such time as the manned aircraft has cleared the area. **(28)** The UAS will not be operated any closer than 1 00 feet to any structure without the express permission of the structure / building / property owner. **(29)** The U AS will be limited to 15 minutes of flight or 25% of battery power, whichever occurs first.



## D. **UAS Airworthiness (1)**  The PIC shall ensure that the UAS is in an airworthy condition before each flight. Airworthiness shall be determined by a preflight inspection in accordance with DJI operating documents and any and all applicable Federal Aviation Regulations, and any additional requirements as defined by the Administrator. PIC shall document each preflight inspection by date, Aircraft total Flight time to d ate, any discrepancies noted, and signature and certificate number. Any discrepancy noted shall be addressed before UAS operation.



## E. **UAS Maintenance and Records (1).**  The operator shall maintain aircraft maintenance logbooks. Each UAS shall have its own and separate maintenance log book. DJI documents, handbooks, user manuals, supplements, Safety Bulletins, etc., shall be the only approved documents for performing repairs, maintenance, inspections, overhauls, or replacement of life limited components. A record of each preflight inspection will additionally be recorded in these logbooks. The preflight inspection must be conducted by the PIC for that operation. Preflight signoff shall include at least the following information: date of operation, Aircraft Total time, aircraft serial or operating number, PIC signature and certificate number. **Example:** Preflight inspection completed, No defects noted. 1

- 1

- 15, ACFTT 50.1 hou rs, UAS number 1, Brian Grant

- PIC **(2).** Any required maintenance, inspection, alteration or repair must be completed by an approved person. At the completion of this work the approved person must make an entry in the aircraft log book that at least includes: Date, Aircraft serial or operating number, brief description of the discrepancy, inspection, alteration or repair, the reference material used as guidance for the repair, statement approving the aircraft for return to service, and signature of person who completed the work.Example: 1

- 1

- 15 UAS 1, ACFTT 50.1 hours, replaced number 3 rotor with new rotor, IAW DJI Phantom 2 Vision + User Manual. Flight or ops check completed. Aircraft is approved for return to service. Brian Grant **(3).** Maintenance records shall be kept with the UAS at all times and shall be made available to any authorized agency or the Administrator upon request.



## F. **Pilot in Command Requirements (1).**  The Pilot in Command shall hold at least a Private Pilot Certificate and a current Third Class Med ical whenever conducting operations. Operator prefers that the Certific ate be in the most appropriate Class and C ategory to the UAS being operated. **(2).** The Pilot in Command shall have accumulated and logged a minimum of 200 flight cycles and 25 hours of rotorcraft U AV flight time before performing any operation for which exemption is requested. **(3).** The Pilot in Command shall have at least 5 hours in make and model before performing any operation for which exemption has been requested. **(4).** The Pilot in Command shall perform a pre -flight inspection before each flight is conducted. **(5).** The Pilot in Command shall observe all Federal Aviation Regulations at all times with the exceptions of the exemptions requested by the operator. In those cases the Pilot in Command shal l adhere to company operating standards or Federal Aviation Admin i stration Limitations placed upon exemptions, whichever is more stringent.

. **(6 ).**  The Pilot in Command will not operate the UAS without a Visual Observer present. **(7 ).**  The Pilot in Command must have 3 takeoff and landings within the preceding 90 days. **(8 ).**  The Pilot in Command must maintain a record of flight information to establish currency and that he or she meets the requirements of this section. **(9).** The Pilot in Command will utilize eye protection in the event that sun glare would reduce VLOS operations.



## G. **Visual Observers: Responsibilities and Requirements (1).**  A Visual Observer shall be used during any and all operations of the UAS System. **(2).** The Visual Observer shall maintain verbal communication with the PIC at all times during UAS operation. **(3).** The Visual Observer shall maintain Visual Contact with the UAS at all times. In the event that Visual Contact is lost the VO will notify th e PIC who will immediately cease operations and land the aircraft. **(4).** The Visual Observer shall also help the PIC maintain area of operations security and ensure that all nonessential persons remain clear of the area of operations. In the event ofa b reach by unauthorized person(s) the VO shall notify the PIC and operations will cease immediately. **(5).** The Visual Observer shall also assist the PIC in looking for manned aircraft traffic near the operations area. If manned aircraft traffic is observed near the operations area, the VO will notify the PIC who will immediately cease operations and land the UAS. **(6).** The VO will utilize eye protection in the event that sun glare would reduce VLOS operations.



## H. **Reporting of Incidents and/or Accidents** Any i ncident or accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported within 24 hours to: FAA UAS Integration Office (AFS

- 80) Accidents: National Transportation Safety Board

www.ntsb.gov.

# 3 **. The Unmanned Aircraft System UAS** 

The petitioner will operate **the DJI Phantom 2 Vision +** UAS System. This shall be the only system op erated by the petitioner. This is an ultra

- light weight system using a quad

- rotor system for flight. The manufacturer has built in several features to make operations safer: in the event of lost signal the UAS will return to its pre

- determined location within the security perime ter and land ; PIC has ability to take over / abort flight manually in the event of loss to GPS; and the UAS has built

- in software that limits operations near airports and restricted airspace. The p etitioner has attached the hyperlinks for the operating an d user documents for the system as additional supplements for this petition. No modification to the factory system is to be utilized other than the dorsal surface area of the aircraft will be painted a bright safety orange to help manned aircraft see the unit while in flight. Please see attached supplemental documents. 

# DJI Phantom 2 Vision Plus Quick Start Guide DJI Phantom 2 Vision Plus User's Manual **DJI Phantom 2 Vision Plus Smart Flight Battery Safety Guidelines** 

# 4 **. The Public Interest** 

The request for this exemption is in the Public Interest as it is safe to assume that there are many consumer applications for the services th at can be provided by UAS . It is clear that the Cong ress of the United States, the b usiness sector, and the c onsumer want to integrate UAS into the N AS and utilize their unique and cost effective capabilities. It is also in the Public Interest that many of the low level flight operations now conducted by manned aircraft could be accomplished with these light, fire resistant and environmentally friendly unmanned aircraft that can operate at a fraction of the cost to both the operator and consumer. These aircraft can be operated without risk of loss of life or limb, and without significant financial impact to the operator or any person or property on the ground in the event of the loss of an aircraft . Utilizing these UAS will create a safer more productive work environ ment, reduce environmental pollution and have a positive impact on the local community which is in the Public Interest
. Finally the petitioner believes that granting this exem ption would help to further by Administrators process of integration of UAS systems and possibility help to create additional regulations and guidance to be used as these syste ms become more widely utilized.

# Abbreviations

**VLOS VISUAL LINE OF SIGHT**  **PIC PILOT IN COMMAND VO VISUAL OBSERVER**  **UAS UNMANNED AIRCRAFT SYSTEM NAS National Airspace System** 

Please forward any questions or concerns to the address or email below.

Sincerely,

**Brian Grant / Principal UAV Field**  **Services, Inc.** 30 Milburn Circle Pasadena, MD 21122 410

- 916

-0109 Email : briang@uavfsi.com