LHRECISION 

~ AERIAL 

COMPUANCE SOLUTIONS 

July 10,2015 

United States Department of Transportation 

Federal Aviation Administration 

Docket Management System 

1200 New Jersey Avenue, NE 

Washington, DC 20590 

Filed in www.regulations.gov 

Re: Petition for Exemption of Precision Aerial Compliance Solutions LLC under 

Section 333 of the FAA Modernization and Reform Act, 49 U.S. C. 44701(±), and 14 

C.F .R. Part 11; Request for Expedited Processing 

On behalf of Precision Aerial Compliance Solutions LLC ("Precision Aerial"), we hereby seek 

an exemption from certain Federal Aviation Regulations enumerated below, as authorized by 

Section 333 of the FAA Modernization and Reform Act ("Section 333"), Subsection 44701(±) of 

the Federal Aviation Act, and pursuant to the procedures set forth in Part 11 of the Federal 

Aviation Regulations, to allow Precision Aerial to operate the DJI Phantom 3 Professional, DJI 

Inspire 1, DJI 900s, 3D Robotics X8, and 3D Robotics Aero-M to provide: 

• Aerial sensor data collection 

• Aerial survey, inspection, and photogrammetry 

• Aerial photography and video services 

Precision Aerial will comply with the same conditions and limitations as provided in numerous 

Section 333 exemptions granted recently. Accordingly, we respectfully ask the FAA to grant 

this petition in summary fashion, and obviate Federal Register publication and public comment. 

Precision Aerial respectfully requests expeditious handling of this petition as it has recently been 

approached to assist in conducting survey and inspection of flood and other environmental 

damage on behalf of the State of Texas. It would be very beneficial for the state to be able to 

utilize the considerable monetary savings and superior flexibility that UAS deployment brings to 

this undertaking. Ideally this would commence in 30-45 days from the date of this petition. 

Precision Aerial is a Texas-based, UAS Service Company. Precision Aerial delivers a diverse 

product offering of aerial photography, 3D imaging, and data collection to the construction, 

energy, and real estate industries. Providing information that will save our clients time and 

money in a safe manner is the company goal. Using UAS technology is at the core of our 

business plan as the information we can provide is either currently unobtainable or requires low 

flying manned aircraft or employees to put themselves in life threatening situations. 

1500 Mansions View Drive #907 Conroe, Texas 77384 713-857-3583 
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~RECISION AERIAL 

COMPLIANCE SOLUTIONS 

The name of the applicant is. Precision Aerial Compliance Solutions LLC. The primary contact 

is Mr. Scott McGowan, 15000 Mansions View Drive #907 Conroe, Texas 77384. Telephone is 

713-857-3583 and web address is www.precsionaerialcompliance.com. 

Exemptions requested 

• 14 C.P.R. Part 21 (airworthiness certification) 

• 14 C.P.R. Part 27 (normal category rotorcraft) 

• 14 C.P.R. 61.113 (a) and (b) (pilot certification and qualification) 

• 14 C.P.R. 91.7(a) (airworthiness) 

• 14 C.P.R. 91.119(b) and (c) (minimum safe altitudes) 

• 14 C.P.R. 91.15l(a) and (b) (fuel requirements in VPR conditions) 

• 14 C.P.R. 91.405 (a) and (b) (maintenance) 

• 14 C.P.R. 91.407(a)(l) (approval for return to service) 

• 14 C.P.R. 91.409(a) (annual and airworthiness certification inspection) 

• 14 C.P.R. 91.417(a) and (b) (maintenance records) 

Safety equivalence or no adverse effect on safety 

Unmanned Aerial Vehicles and Systems 

The DJI and 3DR flight controllers, the common control platforms in the listed devices, have a 

number of technological capabilities to demonstrate their airworthiness. In the event of a loss of 

GPS signal, the UAS will lock in its position and automatically go to ATTI mode and remain 

stable. Loss of connection to the remote control transmitter (or software navigation controller) 

causes the vehicle to immediately achieve a preset altitude, and then return to its home point and 

land in a controlled way. 

All of the UASs intended for use contain a power storage monitoring system and fail-safe modes 

to force controlled landing before the power supply drops below operational levels. Should there 

be a loss of power, the UAVs are designed to perform a vertical hard landing with propellers 

providing stabilizing resistance during descent. 

If the UA V encounters an unexpected obstacle, the pilot will either divert the flight or maintain 

the UA V in a safe hover position away from the obstacle. 

Given its small size, operational capabilities, and restricted area in which the UAS will operate, 

an exemption from Part 21, Subpart H, Airworthiness Certificates, and 14 C.P.R. 91.7(a), is 

warranted, as Precision Aerial's UAS satisfies the equivalent level of safety as compared with 

manned aircraft and meets the criteria in section 333. Operating the UAS without an 

airworthiness certificate in the restricted enviroument over private property under the conditions 

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1500 Mansions View Drive #907 Conroe, Texas 77384 713-857-3583 

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proposed will be safer than operating a manned helicopter operating with an airworthiness 

certificate and not subject to such conditions. 

Each UA V (with payload) is less than 55 pounds, carry no explosive materials or flammable 

liquid fuels, and would operate outside controlled airspace, with no passengers or crew on board. 

As the FAA has found in granting an exemption to Clayco, Exemption No. 11109, at page 10: 

The limited weight significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. The risk 

to an onboard pilot and crew during an incident or accident is eliminated with the use of a 

UAS for the aerial operations. 

For the reasons outlined above, Precision Aerial also seeks an exemption from the certification 

requirements for normal category rotorcraft in Part 27. 

Precision Aerial notes also that the FAA has granted exemptions to many petitioners proposing 

to operate these UAS type and models. 

In support of Precision Aerial's request for an exemption from 14 C.F.R. 91.405(a), 

91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b), Precision Aerial will adhere to the 

following inspection and maintenance program: Precision Aerial will inspect the UAS before and 

after each operation, as well as perform daily, weekly, monthly, and annual inspections, as set 

forth in its operations manual. Before each flight, the pilot in command will inspect the UAS to 

ensure it is in a safe condition for flight. The preflight inspection will account for any 

discrepancy, such as an inoperable component, item, or equipment. Precision Aerial will not 

initiate a flight if the inspection reveals a condition that adversely affects the safety of operations, 

and will not operate that UAS until it is found to be in a safe condition. Any UAS that has 

undergone maintenance or an alteration that affects the UAS's operation or flight characteristics 

will undergo a functional flight test before return to service. 

Precision Aerial will follow the manufacturer's UAS requirements relating to components, 

maintenance, overhaul, replacement, inspection and life limits. Precision Aerial will record all 

maintenance, alterations, and the functional flight test in the UAS logbook, including total flight 

hours, description of work accomplished, and the signature of the UAS technician who returned 

the U AS to service. 1 

Precision Aerial's UASs are equipped with an altimeter that provides the pilot with real-time 

telemetry data in addition to a constant digital display of altitude, speed, and UAS proximity. 

1 Precision Aerials believes that the FAA has in its possession manufacturer manuals for each of the UAS tyupe and 

models Precision Aerials proposes to operate under the requested exemption. We will separately provide any 

manual upon the FAA's request. 

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1 500 Mansions View Drive #807 Conroe, Texas 77384 713-857-3583 
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L]dRECISION AERIAL 

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Moreover, the UASs will be operated within the visual line of sight of the pilot in command and 

observer and below 400 feet AGL. In addition, the flight controllers are progranuned not to 

allow the aircraft to exceed the 400 feet ceiling, even if the pilot command input is in-conflict, or 

if communication with the remote control transmitter fails. Accordingly, Precision Aerial does 

not believe an exemption from 14 C.F.R. 91.121 is required. 

In support of Precision Aerial request for an exemption from fuel requirements in 14 C.F .R. 

91.15l(a) and (b), we note that its UAS is battery-powered and is operated for brief periods of 

time, within the battery capacity of the UAS. 

The remote control transmitter/receiver combinations will work within the 2.4 GHz and 5.8 Ghz 

FCC-approved ranges. 

UA V and UAS Operator Oualifications and Training 

In support of Precision Aerial's request for an exemption from the pilot certification and 

qualifications requirements in 14 C.F.R. 61.113(a) and (a), Precision Aerial asserts that an 

equivalent level of safety is achieved by the VAS-specific experience of its Pilots. Each 

Precision Aerial pilot, before conducting a commercial operation under the requested exemption, 

will have successfully completed an aeronautical knowledge test, performed at least 20 takeoffs 

and landings of the particular UAV, and flown the particular UAV for at least 10 hours. 

Precision Aerial's pilots will also hold at least a current and valid sport pilot certificate. 

UA V and UAS Operating Parameters 

Precision Aerial will operate its UASs in full compliance with the applicable manufacturer 

manual. Precision Aerial will operate its UASs under 400 feet AGL and within the visual line 

of sight of the operator. 

All flights will be conducted within the visual line of sight of the pilot in command, within noncontrolled airspace, with the consent of any property owner and/or developer. 

Precision Aerial will also notify the appropriate Flight Standards District Office "("FSDO") and 

Air Traffic Control for any operation within five miles of an airport. 

Precision Aerial will conduct a briefing before each day's operations, which all personnel 

participating in the operations must attend. Precision Aerial will obtain written consent of any 

person who will be participating in the operations or otherwise be on the private property where 

operations are to take place. Precision Aerial will provide notice to any adjacent buildings or 

structures. Precision Aerial will limit its operations to daytime Visual Flight Rules ("VFR"). 

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1500 Mansions View Drive #807 Conroe, Texas 77384 713-857-3583 

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Precision Aerial seeks an exemption from the requirement in 14 C.F .R. 91.119, subsection (b), 

that an aircraft must remain at least I ,000 feet above any congested area or open air assembly of 

persons, and subsection (c), that an aircraft must remain at least 500 feet above any person or 

structure in an area other than populated or congested, and not closer than 500 feet to any person, 

vehicle, or structure. These requirements were adopted with fixed-wing, manned aircraft 

operations in mind. While Precision Aerial may operate its UASs in a populated area, the 

operations will be carefully pre-planned to minimize risk to persons or property, avoid intrusion 

into unauthorized airspace, and avoid a public annoyance. Its UASs will not be operated over a 

highly-congested area or open air assembly of persons. 

Precision Aerial will make every reasonable effort to ensure that no unauthorized person will be 

on the land over which the UASs will be operated, and will provide notice to adjacent buildings 

and furnish proctors as may be necessary to ensure that unauthorized persons do not come within 

the narrow parameters in which the UASs will be operated. Combined with the technological 

capabilities of the UASs and that the UASs will be operated within the visual line of sight of the 

pilot and an observer, Precision Aerial submits that its operational limitations provides an 

equivalent level of safety to that provided in section 91.119. 

Public interest 

Precision Aerial's U AS operations will substantially benefit public and private organizations 

which have an interest in gathering critical data and information to support their operations. 

Depending on the use-case, these scenarios may include: 

• the gathering of sensor data to document and assess real-time awareness of potential 

hazards or the aftermath of natural disasters, fires, floods etc. 

• construction site and progress monitoring, 

• photographic and video services 

• ecological, agricultural, or land management surveying, 

• infrastructure surveying, inspection, and improvement 

Precision Aerial expects to assist the State of Texas and FEMA in the very near term in 

conducting inspections, surveys, and data acquisition over the areas impacted by flooding and 

other weather-related environmental damage. There is a considerable area that was affected by 

the June 2015 floods in Texas that will need post-flood damage and erosion assessment. It will 

far exceed the normal capabilities and budgeting of using traditional methods and the use of 

UASs will considerably mitigate the added expense to the state of Texas and its constituents. 

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1500 Mansions View Drive #907 Conroe. Texas 77384 71 3-857-3583 
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~RECISION AERIAL 

COMPUANCE SOLUTIONS 

Operating UASs under the limitations proposed by Precision Aerial will avoid any risk of harm 

to pilots as well as persons and people on the ground that would be present during the operation 

of manned aircraft. U AS operations will also require a much smaller energy footprint than with 

manned aircraft. 

Operations limited to the United States 

Under the requested exemption, Precision Aerial will operate its UASs within the United States. 

Summary for Federal Register 

Should the FAA determine that publication of a summary is required, Precision Aerial submits 

the following summary to be included in the Federal Register: 

Precision Aerial seeks an exemption to operate the DJI Phantom 3 Professional, DJI 

Inspire 1, DJI 90 3DR X8, and 3DR Aero-M unmanned aircraft systems to perform 

aerial ectio inspection and survey, and photographic and video services. 

Sincerely, 

ScottMcG 

Principal 

Precision Aerial Compliance Solutions LLC 

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1500 Mansions View Drive #907 Conroe, Texas 77384 713-857-3583