October 6, 2015

U.S. DepartmentofTransportation DocketOperationsWestBuilding Ground Floor Room W12-140 1200NewJerseyAvenue SE Washington, DC 20590

RE: Exemption RequestUnderSection 333 ofthe FAA Reform ACT and Part 11 ofthe FederalAviation Regulations

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act" or "Section 333"),Subsection (f) of49 U.S.C. § 44701, and 14 C.F.R. Part 11,Vectors Aviation, LLC ("Vectors Aviation") seeks an exemption from the Federal Aviation Regulations ("F ARs") listed below and discussed in Appendix A to allow itto operate the OJI Phantom 2 Unmanned Aircraft System ("Phantom").

The safety and public benefits ofusing the Phantom for commercial aerial imagery, 30mapping, and data collection are significant. ThePhantom reduces the need to operate manned aircraft in unconventional operations, provides more accurate data in a manner that is more safe,economical and efficient, and with a reduced impact on the environment.

Operations pursuant to the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level ofsafety to currently authorized operations using manned aircraft and underconditions

as may be modified by the FAA as required by Section 333.The Phantom weighs a mere 2.2 pounds. It is powered electrically via a high capacity,high performance 5200mAh Lithium Polymerbattery. It provides battery capacity data, overcharge/discharge protection, as well as maintenance reminders making the battery extremely safe and reliable. The Phantom was designed with extensive automated control features, redundant systems, and integrated failsafes, and it will be operated under controlled conditions and at low altitudes in airspace that is limited in scope.

The Phantom is safely be operated by one person, a pilot-in-command (the "PIC"). The PIC is responsible for the direct and safe operation ofthe Phantom, monitoring its status and flight dynamics while maintaining visual line ofsight and keeping the flight within the manufacturer's specified limitsin terms ofwind, flight range, battery life, etc. Individuals acting as the PIC will complete training specific to the Phantom. The PIC will be a certificated airman with private pilot privileges and limitations, and maintain a current third-class medical certificate.

Because the Phantom will be used in lieu ofcomparatively higherrisk operations now conducted with fixed wing and rotary manned aircraft, the FAA can have confidence that Vectors Aviation's operations will achieve at least an equivalent level ofsafety and fulfill the Secretary ofTransportation's responsibilities under Section 333(c) ofthe Reform Actto "establish requirements for the safe operation ofsuch aircraft systems in the national airspace system."



### ApplicantInformation

The name ofthe applicantis:

VectorsAviation, LLC

The primarycontactfor this application is:

Jason Miller 621 E. 6th St. 

### Austin, TX 

### 78701 Jason@foreflight.com 

### 803-389-5053

ExemptionsRequested Vectors Aviation respectfully requests exemptions from the following regulations: 1

14 C.F.R. Part 21, Subpart H; 14 C.F.R. § 91.7; 14 C.F.R. § 91.9(b)(2); 14 C.F.R. § 91.113; 14 C.F.R. § 61.l 13(a), (b); 14 C.F.R. § 61.133(a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121;14 C.F.R. § 91.151; 14 C.F.R. § 91.203; 14 C.F.R. § 91.405(a) and (b); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. §91.409(a)(l)-(2); and 14 C.F.R. § 91.417(a).



### THEAPPLICABLELEGALSTANDARD UNDER SECTION333

Grant ofthis exemption application for use ofthe Phantom in precision aerial imagery, data collection and inspection operations will advance the Congressional mandate in Section 333 ofthe Reform Act to accelerate the introduction ofUAS into the national airspace system ("NAS") ifit canbe accomplished safely. This law directs the Secretary ofTransportation to consider whether certain UAS may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types ofUAS do not create a hazard to users ofthe NAS orthe public, or pose a threat to national security in light ofthe following:

• The UAS's size, weight, speed, and operational capability;

• Operation ofthe UAS in close proximity to airports and populated areas; and

• Operation ofthe UAS within visual line ofsight ofthe operator.

I As set forth in Appendix B, Vectors Aviation will operate under similar operating conditions as those required in the other grants ofexemption, in which exemptions for certain FARs was deemed by the FAA as "notnecessary." Accordingly, Vectors Aviation does not request FAA exemption from 14 C.F.R. 45.23(b), 91.103, and 91.109(a). Should the FAA determine that relieffrom these or any other regulation is required for the operations proposed herein, Vectors Aviation will be happy to submit an amendment to this request and includejustifications for those necessary additional exemptions.Reform Act§ 333(a)(l). Ifthe Secretary determines that such vehicles "may operate safely in the national airspace system,the Secretary shall establish requirements for the safe operation ofsuch aircraft in the national airspace system." Id. §333(c) (emphasis added).2

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority,by its terms, includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service:

The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a)

or (b) ofthis· section or any ofsections 44 702-44716 ofthis title ifthe Administratorfinds the exemption is in the public interest.

49 U.S.C. §44701(f). See also 49 USC §4471 l(a); 49 USC §44704.

The grant ofthe requested exemption is in the public interestbased on the cleardirection in Section 333 ofthe Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings associated with transitioning to UAS for aerial imagery,data collection and inspection services. Vectors Aviation therefore respectfully requests that the FAA grant the requested exemption without delay.

2This provision places a duty on the Administrator to not only process applications for exemptions under Section 333,butfor the Administrator, ifhe deems the conditions proposed herein require modification in orderto allow approval, to supply conditions for the safe operation ofthe UAS. Vectors Aviation welcomes the opportunity to consult with FAA staffto address any issues orconcerns that this proposal may raise that they believe may require modification.Airworthiness ofthe Phantom

One element ofthe exemption application involves evidence ofthe airworthiness ofthe Phantom. Vectors Aviation believes that the Phantom has been shown to be airworthy and compliant with a significant level of safety. To enhance safety, it is also importantto note that the Phantom is equipped with automated features that enhance safe takeoff, flight, and landing in many conditions, further details ofwhich are provided in the Phantom UserManual, and the PhantomJustification ofAirworthiness and Safety Assessments.3

To maintain airworthiness, Vectors Aviation will follow the inspection and maintenance program designed specifically for the Phantom. That program is enhanced by an inflight monitoring systemfor the Phantom that monitors
currentposition, wind speed and direction, battery charge, flight time, and altitude, including both above the takeofflocation and above sea level. If onboard sensors detect a critical situation at any time (low battery, close proximity to the ground, weak data link signal,etc.) the Phantom will automatically initiate a preprogrammed safety procedure. In the event ofany malfunction, the Phantom will undergo all maintenance required by the manufacturer and undergo flight testing before recommencing commercial operations.

Proposed Operations and Associated Conditions

Vectors Aviation intends to use the Phantom that weighs significantly less than 55 pounds for the purpose ofcollecting aerial imagery and data.

All ofthe Phantom operations will occurunder tightly controlled conditions, solely during daylighthours, and at altitudes well below that which would pose a risk to other aircraft. The operations will take place in areas away from people, crowds and airports.

Grant ofthis exemption to Vectors Aviation will be subject to the conditions listed in Appendix B,which are based upon the operating conditions required by the FAA's previous grants ofexemptions. The Phantom is characterized by a high degree ofpre-programmed control and various built-in technical capabilities that limit the potential for operation outside ofthe conditions setforth in Appendix B. Itwas also designed with internal functional and safety features to assist the operatorin safe and reliable operation. With preprogrammed flights and manual control, operators can easily maintain separation from manned aircraft operations and avoid otherhazards. In the controlled environment under the operations conditions in Appendix B, operations will remain within visual line-of-sight (VLOS) and below 500 feet AGL. In addition, Vectors Aviation will obtain a Certificate ofWaiver or Authorization from the FAA AirTraffic Organization to address airspace requirements and provide notification by a Notice to Airman (NOTAM) as appropriate.

3 Vectors Aviation submits the following documents,as proprietary and under confidentiality, in support of this Exemption Request: the OJI Phantom 2 User Manual and the Phantom Training Documentation. the request ofthe FAA,Vectors Aviation will also be pleased to provide, underconfidentiality, its General Operations Manual

### OperatorRequirements

As a condition to the grant ofthe exemptions, Vectors Aviation will require that the PIC hold a private pilot's certificate and a valid third-class medical certificate. The PIC will have accumulated and logged a minimum number of flight cycles and hours for daytime operations, as necessary. The PIC will also be subject to the flight review requirements pursuant to the Federal Aviation Regulations ("F ARs").

In addition, the PIC must complete a training program for the Phantom. This training familiarizes the PIC to the operations and limitations ofthe Phantom. Training will also include discussions on the basic fundamentals ofUAS aerodynamics and technical limitations, as well as the more general topics of weather, the National Airspace System, and the regulatory framework.

Vectors Aviation does not believe that certified airmen, medical certificates, and the related operating conditions, are necessary orrequired to operate the Phantom. However, Vectors Aviation will accept these requirements as a condition to the grant ofthis exemption. If,and when, the FAA finds such conditions unnecessary for operations conducted pursuant to Section 333 exemptions,Vectors Aviation respectfully reserves the right to amend its operating conditions and request exemption from the relevant FARs to operate without such conditions.



### Public Interest

The use ofthe Phantom in lieu ofcomparatively hazardous operations currently conducted with conventional fixed wing and rotary aircraft offers a net safety benefit and will achieve an enhanced level ofsafety, as mandated under Section 333(c) ofthe Reform Act. Approval ofthis application will also benefitthe public interestby allowing better, safer, and more cost efficient information for Vectors Aviation and the public.

Conventional aerial imagery and inspection operations using manned aircraft involve heavy aerial aircraft that must transit from airports to the operational location, carrying significant amounts ofcombustible fuel, and a multiperson crew. Manned aircraft are also at risk offuel spillage and fire in the
eventofan accident or incident. By contrast,use ofthe Phantom is safe, economical and efficient. The Phantom weighs a mere 2.2 pounds, is carried (notflown) to and from the area ofactivity, removes the need for an airbornecrew, and poses less risk to people and infrastructure on the ground, as well

as other aircraft.

No national security issue is raised by the grant ofthe requested exemptions. Given the size, load-carrying capacity, the speed at which the Phantom operates (22-35 mph), and the fact that it does not carry explosives orother dangerous materials, the use ofthe Phantom poses no threat to national security. In fact, the threat ofcausing damage to property is significantly reduced with the extremely low weight ofthe Phantom and limited operating

areas. Any other security concerns are ameliorated by the fact that all individuals holding a private pilot certificate are subject to a security screening by the U.S. Department ofHomeland Security.

The grant ofthe requested exemption is in the public interestbased on the cleardirection in Section 333,the Federal Aviation Act,4 the high and equivalent level ofsafety oftheproposed operations, and the significant public benefit, including enhanced safety and cost savings to be realized as a result ofthe use ofthe Phantomfor aerial imagery, 30mapping, and data collection.

Sincerely,

Jason Miller

4 The Federal Aviation Act C'FAAct") expressly grants the FAA the authority to issue exemptions: The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section orany ofsections 44702- 44716 ofthis title ifthe Administrator finds the exemption is in the public interest. 49 U.S.C. § 44701(t).

### APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVELOFSAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECTTO EXEMPTION

14 C.F

### .R.Part21, SubpartH: Airworthiness Certificates 14 CFR § 

### 91.203(a)(l)

Section 91.203(a)(l) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitledAirworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR§ 91.203(a)(l). Given the very small size of the aircraft and the limited operating area associated with their utilization, it is unnecessary to go through the certificate ofairworthiness process under Part 21 Subpart H to achieve orexceed current safety levels

.5

Such an exemption meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act and Section 333 ofthe Reform Actboth 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 ofthe UAS involved.

In this case, an analysis ofthese criteriademonstrates that the Phantom operated without an airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing orrotorcraft) with an airworthiness certificate. The Phantom weighs 2.2 pounds. It does not carry a pilot orpassenger, does not carry flammable fuel, and will operate exclusively within an areapre-disclosed and in compliance with conditions set forth herein. Operations under this exemption will be tightly controlled and monitored by the operator,pursuant to the conditions
set forth in Appendix B,the OJI Phantom 2 manuals, Vectors Aviation GOM, and by local public safety requirements.

The FAA will have advance notice ofall operations through the filing of NOTAMs. Receipt ofthe priorpermission ofthe land owner (or lessee), the size ofthe aircraft, the lack offlammable fuel, and the fact that the aircraft is carried to the location and not flown there all establish the equivalent level ofsafety. The Phantom provides at least an equivalent level ofsafety to that of such operations conducted with conventional manned aircraft that would be orders-of-magnitude larger and would be carrying passengers,cargo, and flammable fuel. The safety features including the redundant sensor systems,

as described in the OJI Phantom 2 UserManual, the Phantom Inspection and Maintenance Requirements, the PhantomJustification ofAirworthiness and Safety Assessments, and throughout this document,underscore the importance placed on safety and reliability in the design and manufacture of the Phantom.

5The FAA has stated that no exemption is needed from this section ifa finding is made under the Reform Act that the Phantom provides an equivalent level ofsafety when compared to aircraft normally used for the

same application. However,Vectors Aviation requests an exemption in the event that the FAA determines that some characteristics ofthe Phantom fail to meet the requirements ofthe Reform Act.

### 14 C.F.R. § 

### 91.7(a)-(b); Civil Aircraft Airworthiness

Section 91.113 requires that vigilancebe maintained by each person operating an aircraft to see and avoid other aircraft. Unlike manned aircraft, the Phantom pilot is not on-board the aircraft to observe and avoid other aircraft, operating the Phantom from the ground.

Vectors Aviation's proposed operating conditions will achieve an equivalent

orgreaterlevel ofsafety. All operations will involve a certificated private pilot as the PIC. The Phantom will also be limited to designated areas below 500 feet AGL and within a virtual fence. Vectors Aviation will notify the FAA and otherpilots ofthe s UAS operations by NOTAM.



### 14 C.F.R. § 

### 61.113(a) & 

### (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations

Section 61.l13(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo,the Phantom is remotely controlled with no passengers orproperty ofothers onboard. Section 61.133(a) requires an individual with a commercial pilot's license to act as pilot in command ofan aircraft for compensation orhire.

Vectors Aviation respectfully proposes that operatorrequirements should take into account the characteristics ofthe particular UAS. Here,the Phantom has a high degree ofpre-programmed control and various built-in technical capabilities that strictly limit the potentialfor operation outside ofthe operating conditions set forth in Appendix Bandthe exemption application. The small size, endurance, range and payload capacities ofthe Phantom

mean that no passengers and/orcargo will everbe carried by the aircraft. Rather, commercial operations will be strictly limited to acquiring aerial imagery, 30mapping, and datacollection.

Considering these conditions, operating limitations and restrictions, an equivalentlevel ofsafety will be providedby allowing operation ofthe Phantomby Vectors Aviation with individuals who possess a valid FAA privatepilotcertificate and Class III medical certificate. The risks associated with the operation ofthe Phantom (given its small size, speed, operational capabilities and limitations, and lack ofcombustible fuel) are so diminishedfrom the level ofrisk associated with commercial operations (and even operations permitted with a private pilotcertificate) contemplatedby Part 61 with manned aircraft, that allowing operations ofthe Phantom as set forth in Appendix B meets and exceeds the present level ofsafety provided under 14 C.F.R. § 61.113(a)-(b), and does not call for a commercial pilot certificate as setforth in§ 61.133. [Exemption Nos. 11136,p. 15 (requiring private pilot certificate and Class III medical certificate); 11170,p. 16 (same); 11193,p. 4 (same).]



### 14 CFR § 

### 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Specifically,91.119(c) limits aircraft flying over areas otherthan congested

areas to an altitude of500 feet above the surface,except overopen water or sparsely populated areas. 

### In those cases,the aircraft may not be operated closerthan 500 feet to any person, vessel, vehicle, or structure.

As setforth herein, the Phantom will not operate at higher than 500 feet AGL. ThePhantom will, however, be operated to avoid congested or populated areas. Because aerial imagery and data collection work mustbe accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.l19(c) is needed.

The equivalent level ofsafety will be achieved given the size, weight, speed, and material with which the Phantom are built.

Compared to operations conducted with aircraft orrotorcraft weighing far

more than the Phantom, and carrying flammable fuel, any risk associated with these operations will be significantly less than those currently allowed with conventional aircraft operating at orbelow 500 feet AGL. Indeed,the low-altitude operations ofthe Phantom will maintain separation from operations ofconventional aircraft that must comply with Section 91.119.



### 14 C.F.R. § 

### 91.lSl(a): FuelRequirementsfor Flightin VFR Conditions

This regulation prohibits an individual from beginning "aflight in an airplane underVFR 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 afterthatfor
at least 30 minutes; or (2) At night, to fly after that for atleast45 minutes."The Phantom is powered by a removable,rechargeable, lithium-polymer battery thatprovides approximately 28 minutes ofpowered flight. Without an exemption from § 14 CFR 91.151, flights by Vectors Aviation would be limited to 20 minutes. Given the limitations on the proposed operations and their locations, a longertime frame for flight in daylight VFR conditions is reasonable. Moreover, OJI has integrated "low" and "critical"battery level warnings and implemented a "Return to Home" actions in these situations.

An exemption from 14 CFR § 91.151(a) is safe and within the scope ofthe prior exemptions for the Phantom. [See, e.g., Exemption No. 11136,p. 17- 18.] In line with the previous grants ofexemption, Vectors Aviation requests that the FAA grant reliefunder the condition that the PIC will notbegin a flight unless (considering wind and forecast weather conditions) there is enough power to fly to the first point ofintended landing and, assuming normal cruise speed, land the Phantom with 30% battery powerremaining.

14 C.F

### .R. §§ 91.9(b)(2); 91.203(a)-(b); CarriageofCivil Aircraft Airworthiness Certificate and Registration

Sections 91.9(b) and 91.203(a)-(b) require an aircraft operatorto carry airworthiness documents and other aircraft manuals onboard the aircraft at all times. Because the Phantom is small in size and contains no cabin orflight deck, carriage ofsuch documents and manuals is impossible.

The intent ofthese regulations is to ensure that the PIC has access to important documents during flight. Here, an equivalent level ofsafety is achieved ifthe PIC has access to the applicable Phantom manual(s), registration certificate and otherrequired documents from the Ground Control Station from which he or she is conducting operations. This is consistent with a prior opinion ofthe FAA Office ofthe ChiefCounsel,and other grants ofexemptions for commercial UAS operations. [See Memorandum from Mark Bury,FAA Assistant ChiefCounsel for International Law, Legislation and Regulation, to John Duncan,FAA Flight Standards Service (Aug. 8, 2014); see also Exemption No. 11136.]14 C.F.R. § 91.121: Altimeter Settings

Section 91.121 requires thateach individual operating an aircraft shall maintain the cruising altitude orflight level ofthat aircraft, as the case may be,by reference to an altimeterthat is set, when operating below 18,000 feet MSLto:

• The current reported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft;

• Ifthere is no station within the areaprescribed in paragraph (a)(l)(i) of this section, the currentreported altimeter setting ofan appropriate available station;

• In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport oran appropriate altimeter setting available before departure.

To provide an equivalent level ofsafety, the Phantom autopilot calculates the reference altitude (ground level) with the on-board GPS during the pre-flight
tests. The GPS and barometerdata are merged with respect to theirrespective precisions. The GPS provides reliable information to correctpotential barometric bias, while rapid variations in altitude are detected through the barometer. Thus, barometric bias induced by environmental factors is rejected. The FAAhas granted relieffrom this section in three prior grants of exemption under the condition that the operator set the altimeterto zero feet AGL ratherthan local barometric pressure orfield altitude before each flight. [Exemption Nos. 11136,p. 9; 11170,p. 20; 11193,p. 7.] Furthermore, ifthe [Phantom] loses GPS signal orencounters a barometererror,the Phantom is programmed to go to the Home point." [Exemption No. 11167,p. 13.] A similar grant ofexemption is thus warranted here.

14 C.F

### .R. §§ 91.405(a); 407(a)(l); 409(a)(2); 417(a): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator orowner "shall have that aircraft inspected as prescribed in subpartE ofthis part and shall between required inspections,except as provided in paragraph (c) ofthis section,have discrepancies repaired as prescribed in part43 ofthis chapter

...." Section 91.407 similarly makes reference to requirements in Part43; Section 91.409(a)(2) requires an annual inspection for the issuance ofan airworthiness certificate. Section 91.417(a) requires the owneroroperatortokeep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43,or licensed pilots and records of approval ofthe aircraft for return to service.

An equivalent level ofsafety will be achieved because the Phantom is small in size,will solely operate in controlled and predetermined areas, and is not a large, complex mechanical device. Vectors Aviation will perform all maintenance and inspections in accordance with the manufacturers' manuals and any required manufacturer Safety or Service Bulletins. In addition, the PIC will conduct a pre-flight inspection ofthe Phantom and all associated equipment to account for all discrepancies and/or inoperable components. Maintenance will be performed and verified to address any conditions potentially affecting safe operation ofthe Phantom and no flights will occur unless and until all flight critical components ofthe Phantomhave been found to bein a condition for safe operation. A functional flight test will be conducted following the replacement ofany flight-critical components.

### APPENDIXB

VECTORS AVIATION SYSTEMS OPERATING RESTRICTIONS AND LIMITATIONS

1) Operations authorized by this grant ofexemption are limited to the OJI Phantom 2,which weighs approximately 2.2 pounds. Proposed operations ofany other aircraft will require a new petition ora petition
to amend this grant. 2) The Phantom shall not beflown at a ground speed exceeding 70 knots. 3) Above Ground Level ("AGL") altitude shall be restricted to 500 feet,

as indicated by the procedures specified in the Phantom User Manual and the GOM. All altitudes reported to Air Traffic Control ("ATC") shall be in feet AGL. 4) The Phantom shall be operated within Visual Line-of-Sight ("VLOS") ofthe pilot-in-command ("PIC") and visual observer at all times. The PIC must use human vision unaided by any device otherthan corrective lenses, as specified on the PIC's FAA issued medical certificate. 5) Any and all additional requirements identified in the exemption grant by the FAA shall be added to the GOM. The GOM mustbe maintained and made available to the Administratorupon request. Ifa discrepancy exists between the conditions and limitations in the granted exemptions and the GOM,the conditions and limitations in the granted exemptions shall take precedence and mustbe followed. Otherwise, the operator mustfollow the procedures outlined in the GOM. 6) Any and all additional requirements identified in the exemption grant by the FAA shall be added to the GOM. The GOM mustbe maintained and made available to the Administrator upon request. Ifa discrepancy exists between the conditions and limitations in the granted exemptions and the GOM,the conditions and limitations in the granted exemptions shall take precedence and mustbe followed. Otherwise,the operator mustfollow the procedures outlined in the GOM.

The operator may update orrevise its GOM. Itis the operator's responsibility to track such revisions and presentupdated and revised documents to the Administratorupon the request. The operator must also presentupdated and revised documents ifit petitions for an extension oramendment ofthe granted exemptions. Ifthe operator determines that any update orrevision would affect thebasis uponwhich the FAA granted the exemptions, then the operatormust petition for amendmentto its exemptions. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions to the GOM. 7) Priorto each flight the PIC mustinspect the Phantom to confirm that it is in a condition for safe flight. ThePIC shall not operate the aircraft if the inspection reveals a condition that affects the safe operation ofthe Phantom until the necessary maintenance has been performed and the Phantom is found to be in a condition for safe flight. The Ground Control Station ("GCS") shallbe included in the preflight inspection. All maintenance and alternations mustbe properly documented in the aircraft records. 8) Any Phantom that has undergone maintenance or alterations that affect the Phantom operation orflight characteristics (e.g.,replacement ofa flight critical component) mustundergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the Phantom aircraftrecords. 9) Vectors Aviation mustfollow the manufacturer's aircraft/component maintenance, overhaul,replacement,inspection, and life limit requirements. 10) Vectors Aviation shall carry outits maintenance,inspections, and record keeping requirements, in accordance with the Phantom User Manual, the Phantom Inspection and Maintenance Requirements, and the GOM. Maintenance, inspection, and alterations mustbe noted in the aircraft logbook, including total flight hours, description ofwork accomplished, and the signature ofthe authorized PIC or technician returning the Phantom to service. 11) The PIC must make a record entry in the Phantom logbook or equivalentdocument ofthe corrective action taken against discrepancies discoveredbetween inspections. 12) The PIC must possess atleast a private pilot certificate and at least a currentthird-class medical certificate. The PIC must also meet the flight review requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his orherpilotcertificate. 13) Vectors Aviation will notpermit any PIC to operate the Phantom unless and until that PIC has demonstrated through the training and currency requirements setforth in the GOM, that the PIC is able to safely operate the Phantom in a mannerconsistent with how the Phantom will be operated pursuantto this exemption,includingevasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 14) The Phantom shall notbe operated directly over any person, except authorized and consenting individuals, below an altitude that is hazardous to persons orproperty on the surf ace in the event ofa Phantom failure oremergency. 15) Operating ofthe Phantom may be conducted at distances less than 500 feet from participating persons, vessels, vehicles or structures that perform an essential function in connection with these special purpose operations. Operations closerthan 500 feet from the PIC, operatortrainees, and essential persons, are permitted when operationally necessary; but never so close as to present an undue hazard, per§ 91.l19(a). 16) Operation ofthe Phantom must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. the aircraft is operated near vessels, vehicles or structures where the land owner/controllerhas granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does not present an undue hazard. 17) Ifthe Phantom loses communications orloses its GPS signal, the Phantom must return to a predetermined location within the security perimeter and land orbe recovered in accordance with the Phantom UserManual and the GOM. 18) The Phantom must abort the flight in the event ofunpredicted obstacles oremergencies in accordance with the Phantom User Manual and the GOM 19) The PIC is prohibited from beginning a Phantom flight unless (considering wind and forecast weather conditions) there is enough powerto fly to the intended point oflanding and, assuming normal cruising speed, land the Phantom with 30% battery powerremaining. 20) Vectors Aviation shall obtain an AirTraffic Organization (ATO) issued Certificate ofWaiver ofAuthorization (COA) priorto conducting any operation. This COA will also require the filing ofthe NOTAM not more than 72 hours in advance,butnot less than 48 hours priorto the operation. 21) All aircraft operated in accordance with the requested exemption must be identified by serial number,registered in accordance with 14 C.F.R. Part47, and have identification (N-Number) markings inaccordance with 14 C.F.R. Part45, Subpart C. Markings shall be as large as practicable. 22) Each Phantom must comply with all manufacturer System and Safety Bulletins. 23) The preflight inspection section in the Phantom User Manual and the GOM shall account for all discrepancies (i.e., inoperable components, items, orequipment) not covered in the relevant pre-flight inspection sections ofthe Phantom UserManual and the GOM. 24) The radio frequency spectrum used for operation and control of the Phantom must comply with Federal Communication (FCC) or other appropriate government oversight agency requirements. 25) The documents required under 14 C.F.R. §§ 91.9 and 91.203 shall be available to the operator at the Ground Control Station ofthe Phantom any time the aircraft is operating. These documents must be made available to the Administrator orany law enforcement official upon request.6 26) The Phantom mustremain clear and yield the right ofway to all othermanned operations and activities at all times (including, without limitation, ultralight vehicles, parachute activities, parasailing activities, hang gliders,etc.). 27) Operations shall occurunder Visual Meteorological Conditions (VMC); flights under special visual flight rules (SVFR) shall not be conducted. 28) The Phantom shall not be operated from any moving device or vehicle. 29) The Phantom shall notbe operated less than 500 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 30) Operations shall not occurin congested or densely populated

areas. The Phantom may not operate in Class B, C,DorE airspace without written approval from the controlling authority. Operations will not be conducted within a 5 NM range ofthe geographic center of

an airport as denoted on a current FAA-published aeronautical chart unless permission has been obtained from the local control toweror, in the case ofa nontowered airport, written notice has been provided to the airport's management, and the operation is conducted in accordance with a NOTAM as required by the grant ofthis exemption. 31) Any incident, accident, orflight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA shall be reported to the FAA's UAS Integration Office(AFS-80) within 24 hours. Accidents shall be reported to the National Transportation Safety Board (NTSB) perinstructions contained on the NTSB Web site: www.ntsb.gov. 32) Phantom operations may notbe conducted during night, as defined by 14 C.F.R. § 1.1.

6 This is consistent with an FAA Office ofChiefCounsel Opinion,dated August 8, 2014, and prepared by Dean E. Griffith, AGC-220, in which it was acknowledged that the intent of 14 C.F.R. § 91.9(b) and 91.203(a}, (b) is met ifthe PIC ofthe UAS has access to the aircraft flight manual,registration certificate, and otherrequired documents from the ground control station from which he orshe is operating the UAS. Memorandum from Mark Bury,FAA Assistant ChiefCounsel for International Law,Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8,2014).

### APPENDIXC

FEDERAL REGISTRY SUMMARY

Pursuant to 14 C.F.R. Part 11,Vectors Aviation offers the following summary for publication in the Federal Register, should publication be necessary:

Vectors Aviation seeks an exemption from the following rules:

14 C.F.R. Part 21, Subpart H; 14 C.F.R. § 91.7; 14 C.F.R. § 91.9(b)(2); 14 C.F.R. § 91.113; 14 C.F.R. § 61.113(a)-(b); 14 C.F.R. § 61.133(a); 14 C.F.R. §91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151; 14 C.F.R. § 91.203; 14 C.F.R. § 91.405(a)-(b); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. § 91.409(a)(l)-(2); and, 14 C.F.R. § 91.417(a).

Approval ofthese exemptions will permit Vectors Aviation to conduct commercial unmanned aircraft systems ("UAS") operations in aviation applications. The exemptions will enhance safety by reducing risk to the general public and property owners from the risk and hazards associated with performing equivalent work through conventional manned aircraft.