October 6, 2015 

U.S. Department of Transportation 

Docket Operations West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue SE 

Washington, DC 20590 

RE: Exemption Request Under Section 333 of the FAA Reform 

ACT and Part 11 of the Federal Aviation Regulations 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(the "Reform Act" or "Section 333"), Subsection (f) of 49 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 it to operate the OJI Phantom 2 Unmanned 

Aircraft System ("Phantom"). 

The safety and public benefits of using the Phantom for commercial aerial 

imagery, 30 mapping, and data collection are significant. The Phantom 

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 of safety to 

currently authorized operations using manned aircraft and under conditions 

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 Polymer battery. It provides battery capacity 

data, over charge/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 of the 

Phantom, monitoring its status and flight dynamics while maintaining visual 

line of sight and keeping the flight within the manufacturer's specified limits 
in terms of wind, 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 of comparatively higher risk 

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 of safety and fulfill the Secretary of Transportation's 

responsibilities under Section 333(c) of the Reform Act to "establish 

requirements for the safe operation of such aircraft systems in the national 

airspace system." 

Applicant Information 

The name of the applicant is: 

Vectors Aviation, LLC 

The primary contact for this application is: 

Jason Miller 

621 E. 6th St. 

Austin, TX 78701 

Jason@foreflight.com 

803-389-5053 

Exemptions Requested 

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). 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

Grant of this exemption application for use of the Phantom in precision aerial 

imagery, data collection and inspection operations will advance the 

Congressional mandate in Section 333 of the Reform Act to accelerate the 

introduction of UAS into the national airspace system ("NAS") if it can be 

accomplished safely. This law directs the Secretary of Transportation to 

consider whether certain UAS may operate safely in the NAS before 

completion of the rulemaking required under Section 332 of the Reform Act. 

In making this determination, the Secretary is required to determine which 

types of UAS do not create a hazard to users of the NAS or the public, or 

pose a threat to national security in light of the following: 

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

capability; 

• Operation of the UAS in close proximity to airports and 

populated areas; and 

• Operation of the UAS within visual line of sight of the 

operator. 

I As set forth in Appendix B, Vectors Aviation will operate under similar operating conditions as those 

required in the other grants of exemption, in which exemptions for certain FARs was deemed by the FAA as 

"not necessary." 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 relief from 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 include justifications for those necessary additional exemptions. 
Reform Act§ 333(a)(l). If the Secretary determines that such vehicles "may 

operate safely in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such 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 of the 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 of a regulation prescribed under subsection (a) 

or (b) of this· section or any of sections 44 702-44 716 of this 

title if the Administrator finds 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 of the requested exemption is in the public interest based on the 

clear direction in Section 333 of the Reform Act; the additional authority in 

the Federal Aviation Act, as amended; the strong equivalent level of safety 

surrounding the proposed operations; and the significant public benefit, 

including enhanced safety and cost savings associated with transitioning to 

U AS for aerial imagery, data collection and inspection services. Vectors 

Aviation therefore respectfully requests that the FAA grant the requested 

exemption without delay. 

2 This provision places a duty on the Administrator to not only process applications for exemptions under 

Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in 

order to allow approval, to supply conditions for the safe operation of the U AS. Vectors Aviation welcomes 

the opportunity to consult with FAA staff to address any issues or concerns that this proposal may raise that 

they believe may require modification. 
Airworthiness of the Phantom 

One element of the exemption application involves evidence of the 

airworthiness of the 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 important to note that the Phantom is 

equipped with automated features that enhance safe takeoff, flight, and 

landing in many conditions, further details of which are provided in the 

Phantom User Manual, and the Phantom Justification of Airworthiness 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 system for the Phantom that monitors 

current position, wind speed and direction, battery charge, flight time, and 

altitude, including both above the takeoff location 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 of any 

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 of collecting aerial imagery and data. 

All of the Phantom operations will occur under tightly controlled conditions, 

solely during daylight hours, 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 of this 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 of exemptions. The Phantom is characterized 

by a high degree of pre-programmed control and various built-in technical 

capabilities that limit the potential for operation outside of the conditions set 
forth in Appendix B. It was also designed with internal functional and safety 

features to assist the operator in safe and reliable operation. With preprogrammed flights and manual control, operators can easily maintain 

separation from manned aircraft operations and avoid other hazards. 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 of Waiver or 

Authorization from the FAA Air Traffic Organization to address airspace 

requirements and provide notification by a Notice to Airman (NOT AM) 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 of the FAA, Vectors Aviation will also be pleased to provide, under confidentiality, its General 

Operations Manual 
Operator Requirements 

As a condition to the grant of the 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 of the Phantom. 

Training will also include discussions on the basic fundamentals of U AS 

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 or required to operate the 

Phantom. However, Vectors Aviation will accept these requirements as a 

condition to the grant of this 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 F ARs to 

operate without such conditions. 

Public Interest 

The use of the Phantom in lieu of comparatively hazardous operations 

currently conducted with conventional fixed wing and rotary aircraft offers a 

net safety benefit and will achieve an enhanced level of safety, as mandated 

under Section 333( c) of the Reform Act. Approval of this application will 

also benefit the public interest by 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 of combustible fuel, and a multiperson crew. Manned aircraft are also at risk of fuel spillage and fire in the 

event of an accident or incident. By contrast, use of the Phantom is safe, 

economical and efficient. The Phantom weighs a mere 2.2 pounds, is carried 

(not flown) to and from the area of activity, removes the need for an airborne 
crew, 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 of the 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 or other 

dangerous materials, the use of the Phantom poses no threat to national 

security. In fact, the threat of causing damage to property is significantly 

reduced with the extremely low weight of the 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 of Homeland Security. 

The grant of the requested exemption is in the public interest based on the 

clear direction in Section 333, the Federal Aviation Act,4 the high and 

equivalent level of safety of the proposed operations, and the significant 

public benefit, including enhanced safety and cost savings to be realized as a 

result of the use of the Phantom for aerial imagery, 30 mapping, 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 of a regulation prescribed under subsection (a) or 

(b) of this section or any of sections 44702- 44716 of this title if the Administrator finds the exemption is in 

the public interest. 49 U.S.C. § 44701(t). 
APPENDIX A 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO 

EXEMPTION 

14 C.F .R. Part 21, Subpart H: 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, entitled Airworthiness Certificates, 

establishes the procedural requirements for the issuance of airworthiness 

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 of airworthiness process under 

Part 21 Subpart H to achieve or exceed current safety levels .

5 

Such an exemption 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 both 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 UAS involved. 

In this case, an analysis of these criteria demonstrates 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 or rotorcraft) with an airworthiness certificate. The Phantom weighs 2.2 

pounds. It does not carry a pilot or passenger, does not carry flammable fuel, 

and will operate exclusively within an area pre-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 of all operations through the filing of 

NOTAMs. Receipt of the prior permission of the land owner (or lessee), the 

size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is 

carried to the location and not flown there all establish the equivalent level of 
safety. The Phantom provides at least an equivalent level of safety 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 User Manual, the Phantom Inspection and 

Maintenance Requirements, the Phantom Justification of Airworthiness and 

Safety Assessments, and throughout this document, underscore the 

importance placed on safety and reliability in the design and manufacture of 

the Phantom. 

5 The FAA has stated that no exemption is needed from this section if a finding is made under the Reform 

Act that the Phantom provides an equivalent level of safety 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 of the Phantom fail to meet the requirements of the Reform Act. 
14 C.F .R. § 91.7(a)-(b); Civil Aircraft Airworthiness 

Section 91.113 requires that vigilance be 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 

or greater level of safety. 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 other pilots of the s U AS operations by NOT AM. 

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.l 13(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 or property of others onboard. Section 61.133(a) requires an individual with a commercial pilot's 

license to act as pilot in command of an aircraft for compensation or hire. 

Vectors Aviation respectfully proposes that operator requirements should 

take into account the characteristics of the particular UAS. Here, the Phantom 

has a high degree of pre-programmed control and various built-in technical 

capabilities that strictly limit the potential for operation outside of the 

operating conditions set forth in Appendix Band the exemption application. 

The small size, endurance, range and payload capacities of the Phantom 

mean that no passengers and/or cargo will ever be carried by the aircraft. 

Rather, commercial operations will be strictly limited to acquiring aerial 

imagery, 30 mapping, and data collection. 

Considering these conditions, operating limitations and restrictions, an 

equivalent level of safety will be provided by allowing operation of the 

Phantom by Vectors Aviation with individuals who possess a valid FAA 

private pilot certificate and Class III medical certificate. The risks associated 

with the operation of the Phantom (given its small size, speed, operational 

capabilities and limitations, and lack of combustible fuel) are so diminished 
from the level of risk associated with commercial operations (and even 

operations permitted with a private pilot certificate) contemplated by Part 61 

with manned aircraft, that allowing operations of the Phantom as set forth in 

Appendix B meets and exceeds the present level of safety provided under 14 

C.F.R. § 61.113(a)-(b), and does not call for a commercial pilot certificate as 

set forth 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 of civil aircraft. 

Specifically, 91.119( c) limits aircraft flying over areas other than congested 

areas to 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. 

As set forth herein, the Phantom will not operate at higher than 500 feet 

AGL. The Phantom will, however, be operated to avoid congested or 

populated areas. Because aerial imagery and data collection work must be 

accomplished at relatively low altitudes and at altitudes less than 500 feet 

AGL, an exemption from Section 91.l 19(c) is needed. 

The equivalent level of safety will be achieved given the size, weight, speed, 

and material with which the Phantom are built. 

Compared to operations conducted with aircraft or rotorcraft 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 or below 500 feet AGL. Indeed, the 

low-altitude operations of the Phantom will maintain separation from 

operations of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. § 91.lSl(a): Fuel Requirements for Flight in VFR Conditions 

This regulation 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 of intended landing 

and, assuming normal cruising speed- (1) During the day, to fly after that for 

at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." 
The Phantom is powered by a removable, rechargeable, lithium-polymer 

battery that provides approximately 28 minutes of powered 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 longer time 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 of the 

prior exemptions for the Phantom. [See, e.g., Exemption No. 11136, p. 17-

18.] In line with the previous grants of exemption, Vectors Aviation requests 

that the FAA grant relief under the condition that the PIC will not begin a 

flight unless ( considering wind and forecast weather conditions) there is 

enough power to fly to the first point of intended landing and, assuming 

normal cruise speed, land the Phantom with 30% battery power remaining. 

14 C.F .R. §§ 91.9(b)(2); 91.203(a)-(b); Carriage of Civil Aircraft 

Airworthiness Certificate and Registration 

Sections 91.9(b) and 91.203(a)-(b) require an aircraft operator to carry 

airworthiness documents and other aircraft manuals onboard the aircraft at all 

times. Because the Phantom is small in size and contains no cabin or flight 

deck, carriage of such documents and manuals is impossible. 

The intent of these regulations is to ensure that the PIC has access to 

important documents during flight. Here, an equivalent level of safety is 

achieved if the PIC has access to the applicable Phantom manual(s), 

registration certificate and other required documents from the Ground 

Control Station from which he or she is conducting operations. This is 

consistent with a prior opinion of the FAA Office of the Chief Counsel, and 

other grants of exemptions for commercial UAS operations. [See 

Memorandum from Mark Bury, FAA Assistant Chief Counsel 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 that each individual operating an aircraft shall 

maintain the cruising altitude or flight level of that aircraft, as the case may 

be, by reference to an altimeter that is set, when operating below 18,000 feet 

MSLto: 

• The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

• If there is no station within the area prescribed in paragraph (a)(l)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; 

• In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 

To provide an equivalent level of safety, the Phantom autopilot calculates the 

reference altitude (ground level) with the on-board GPS during the pre-flight 

tests. The GPS and barometer data are merged with respect to their respective 

precisions. The GPS provides reliable information to correct potential 

barometric bias, while rapid variations in altitude are detected through the 

barometer. Thus, barometric bias induced by environmental factors is 

rejected. The FAA has granted relief from this section in three prior grants of 

exemption under the condition that the operator set the altimeter to zero feet 

AGL rather than local barometric pressure or field altitude before each flight. 

[Exemption Nos. 11136, p. 9; 11170, p. 20; 11193, p. 7 .] Furthermore, if the 

[Phantom] loses GPS signal or encounters a barometer error, the Phantom is 

programmed to go to the Home point." [Exemption No. 11167, p. 13.] A 

similar grant of exemption 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 or owner "shall have that 

aircraft inspected as prescribed 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 .... " Section 

91.407 similarly makes reference to requirements in Part 43; Section 

91.409(a)(2) requires an annual inspection for the issuance of an 

airworthiness certificate. Section 91.417(a) requires the owner or operator to 
keep records showing certain maintenance work that has been accomplished 

by certificated mechanics, under Part 43, or licensed pilots and records of 

approval of the aircraft for return to service. 

An equivalent level of safety 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 of the 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 of the Phantom and no flights will occur 

unless and until all flight critical components of the Phantom have been 

found to be in a condition for safe operation. A functional flight test will be 

conducted following the replacement of any flight-critical components. 
APPENDIXB 

VECTORS AVIATION SYSTEMS OPERATING RESTRICTIONS 

AND LIMITATIONS 

1) Operations authorized by this grant of exemption are limited to the OJI 

Phantom 2, which weighs approximately 2.2 pounds. Proposed 

operations of any other aircraft will require a new petition or a petition 

to amend this grant. 

2) The Phantom shall not be flown 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") 

of the pilot-in-command ("PIC") and visual observer at all times. The 

PIC must use human vision unaided by any device other than 

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 must be maintained 

and made available to the Administrator upon request. If a 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 must be followed. Otherwise, the operator 

must follow 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 must be maintained 

and made available to the Administrator upon request. If a 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 must be followed. Otherwise, the operator 

must follow the procedures outlined in the GOM. 

The operator may update or revise its GOM. It is the operator's 

responsibility to track such revisions and present updated and revised 

documents to the Administrator upon the request. The operator must 

also present updated and revised documents if it petitions for an 

extension or amendment of the granted exemptions. If the operator 

determines that any update or revision would affect the basis upon 
which the FAA granted the exemptions, then the operator must petition 

for amendment to its exemptions. The FAA' s U AS Integration Office 

(AFS-80) may be contacted if questions arise regarding updates or 

revisions to the GOM. 

7) Prior to each flight the PIC must inspect the Phantom to confirm that it 

is in a condition for safe flight. The PIC shall not operate the aircraft if 

the inspection reveals a condition that affects the safe operation of the 

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") shall be included in the preflight inspection. 

All maintenance and alternations must be properly documented in the 

aircraft records. 

8) Any Phantom that has undergone maintenance or alterations that affect 

the Phantom operation or flight characteristics (e.g., replacement of a 

flight critical component) must undergo a functional test flight. The 

PIC who conducts the functional test flight must make an entry in the 

Phantom aircraft records. 

9) Vectors Aviation must follow the manufacturer's aircraft/component 

maintenance, overhaul, replacement, inspection, and life limit 

requirements. 

10) Vectors Aviation shall carry out its 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 must be noted in 

the aircraft logbook, including total flight hours, description of work 

accomplished, and the signature of the authorized PIC or technician 

returning the Phantom to service. 

11) The PIC must make a record entry in the Phantom logbook or 

equivalent document of the corrective action taken against 

discrepancies discovered between inspections. 

12) The PIC must possess at least a private pilot certificate and at 

least a current third-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 or her pilot certificate. 

13) Vectors Aviation will not permit any PIC to operate the 

Phantom unless and until that PIC has demonstrated through the 

training and currency requirements set forth in the GOM, that the PIC 

is able to safely operate the Phantom in a manner consistent with how 

the Phantom will be operated pursuant to this exemption, including 
evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

14) The Phantom shall not be operated directly over any person, 

except authorized and consenting individuals, below an altitude that is 

hazardous to persons or property on the surf ace in the event of a 

Phantom failure or emergency. 

15) Operating of the 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 closer than 500 feet from the PIC, 

operator trainees, and essential persons, are permitted when 

operationally necessary; but never so close as to present an undue 

hazard, per§ 91.l 19(a). 

16) Operation of the 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/controller has granted permission and the PIC 

has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue 

hazard. 

17) If the Phantom loses communications or loses its GPS signal, the 

Phantom must return to a predetermined location within the security 

perimeter and land or be recovered in accordance with the Phantom 

User Manual and the GOM. 

18) The Phantom must abort the flight in the event of unpredicted 

obstacles or emergencies 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 

power to fly to the intended point of landing and, assuming normal 

cruising speed, land the Phantom with 30% battery power remaining. 

20) Vectors Aviation shall obtain an Air Traffic Organization (ATO) 

issued Certificate of Waiver of Authorization (COA) prior to 

conducting any operation. This COA will also require the filing of the 

NOTAM not more than 72 hours in advance, but not less than 48 hours 

prior to 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. Part 47, and have identification (N-Number) markings in 
accordance with 14 C.F.R. Part 45, 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, or equipment) not covered in the relevant pre-flight 

inspection sections of the Phantom User Manual 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 of the 

Phantom any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement official 

upon request.6 

26) The Phantom must remain clear and yield the right of way to all 

other manned operations and activities at all times (including, without 

limitation, ultralight vehicles, parachute activities, parasailing 

activities, hang gliders, etc.). 

27) Operations shall occur under 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 not be operated less than 500 feet below or 

less than 2,000 feet horizontally from a cloud or when visibility is less 

than 3 statute miles from the PIC. 

30) Operations shall not occur in congested or densely populated 

areas. The Phantom may not operate in Class B, C, Dor E airspace 

without written approval from the controlling authority. Operations 

will not be conducted within a 5 NM range of the geographic center of 

an airport as denoted on a current FAA-published aeronautical chart 

unless permission has been obtained from the local control tower or, in 

the case of a nontowered airport, written notice has been provided to 

the airport's management, and the operation is conducted in 

accordance with a NOT AM as required by the grant of this exemption. 

31) Any incident, accident, or flight operation that transgresses the 

lateral or vertical boundaries of the 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) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 

32) Phantom operations may not be conducted during night, as 

defined by 14 C.F.R. § 1.1. 

6 This is consistent with an FAA Office of Chief Counsel 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 if the PIC of the UAS has access to the aircraft flight manual, registration certificate, 

and other required documents from the ground control station from which he or she is operating the UAS. 

Memorandum from Mark Bury, FAA Assistant Chief Counsel 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 of these 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.