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July 10,2015

United States Department ofTransportation FederalAviationAdministration DocketManagement System 1200 NewJerseyAvenue, NE Washington, DC 20590 Filedinwww.regulations.gov Re: Petition for Exemption ofPrecisionAerial Compliance Solutions LLC under Section 333 ofthe FAAModernization andReformAct, 49 U.S.C. 44701(±), and 14 C.F.R. Part 11; Request for Expedited Processing On behalfofPrecision Aerial Compliance Solutions LLC ("Precision Aerial"), we hereby seek an exemption from certain Federal Aviation Regulations enumerated below, as authorized by Section 333 ofthe 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-Mto provide:

• Aerial sensor datacollection • Aerial survey, inspection, andphotogrammetry • 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 expeditioushandling ofthis petition as 

### ithasrecently been approached to assist in conducting survey and inspection of flood and other environmental damage on behalf ofthe State ofTexas. 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 ofthis 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 putthemselves inlife threatening situations.

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

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### The name of the applicant is. Precision Aerial Compliance Solutions LLC. Theprimary contact is Mr. Scott McGowan, 15000 Mansions View Drive #907 Conroe, Texas 77384. Telephone is 713-857-3583 andweb address iswww.precsionaerialcompliance.com. 

### Exemptions requested

• 14 C.P.R. Part21 (airworthiness certification) • 14 C.P.R. Part27 (normal categoryrotorcraft) • 14 C.P.R. 61.113 (a) and (b) (pilotcertificationand 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 inVPRconditions) • 14 C.P.R. 91.405 (a) and (b) (maintenance) • 14 C.P.R. 91.407(a)(l) (approval for returnto service) • 14 C.P.R. 91.409(a) (annual and airworthiness certificationinspection) • 14 C.P.R. 91.417(a) and (b) (maintenance records) 

### Safety equivalence orno adverse effecton safety 

### Unmanned AerialVehicles and Systems The DJI and 3DR flight controllers, the common control platforms inthe listed devices, have a number oftechnological capabilities to demonstrate their airworthiness. 

### In the event ofa loss of GPS signal, the UAS will lock in its position and automatically go to ATTI mode and remain stable. Loss ofconnection to the remote control transmitter (or software navigation controller) causes the vehicle to immediately achieve a preset altitude, and thenreturn to its home point and land in a controlled way. All ofthe 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 ofpower, the UAVs are designed to perform a vertical hard landing with propellers providing stabilizingresistance duringdescent. Ifthe UAV encounters an unexpected obstacle, the pilot will either divert the flight or maintain the UA V ina safe hover position away from the obstacle. Given its small size, operational capabilities, and restricted areainwhich theUAS will operate, an exemptionfrom Part21, Subpart H, Airworthiness Certificates, and 14 C.P.R. 91.7(a), is warranted, as PrecisionAerial'sUAS satisfies the equivalent level ofsafety as compared with manned aircraft and meets the criteriain section 333. Operatingthe UAS without an airworthiness certificate inthe restricted enviroument overprivateproperty underthe conditions 2 1500 Mansions View Drive #907 Conroe, Texas 77384 713-857-3583

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### proposed will be saferthan operating amannedhelicopteroperating with an airworthiness certificate and not subjectto such conditions. Each UAV (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 FAAhas found in granting an exemption to Clayco, ExemptionNo. 11109, atpage 10: The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals or property in the event ofan incident or accident. The risk to an onboard pilot and crew during an incident or accident is eliminated withthe use ofa UAS forthe 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 theseUAS 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: PrecisionAerial will inspectthe UAS before and after each operation, as well as perform daily, weekly, monthly, and annual inspections, as set forth inits 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 ifthe inspectionreveals a conditionthat adversely affects the safety ofoperations, 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 returnto 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 ofwork accomplished, and the signature ofthe UAS technician who returned the UAS to service. 1 

### Precision Aerial's UASs are equipped with an altimeter that provides the pilot with real-time telemetry data in additionto a constant digital display ofaltitude, speed, and UAS proximity.

1PrecisionAerials believes thatthe FAA has in its possessionmanufacturermanuals for each ofthe UAStyupe and models Precision Aerials proposes to operate underthe requested exemption. We will separatelyprovide any manual uponthe FAA'srequest. 3 1 500 Mansions View Drive #807 Conroe, Texas 77384 713-857-3583

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### Moreover, the UASs will be operated within the visual line ofsight ofthe pilot in command and observer and below 400 feet AGL. In addition, the flight controllers are progranuned not to allowthe aircraftto exceedthe 400 feet ceiling, even ifthe pilot command input is in-conflict, or ifcommunication with the remote control transmitter fails. Accordingly, Precision Aerial does notbelieve 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 briefperiods of time, withinthebattery capacity ofthe UAS. The remote control transmitter/receiver combinations will work within the 2.4 GHz and 5.8 Ghz FCC-approvedranges. 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. PrecisionAerial'spilots will also hold at least a current and valid sportpilot certificate. UA V and UAS OperatingParameters 

### 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 ofsight ofthe operator. All flights will be conducted within the visual line ofsight ofthe pilot in command, within noncontrolled airspace, with the consent ofanyproperty 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 ofan airport. Precision Aerial will conduct a briefing before each day's operations, which all personnel participatinginthe operations must attend. Precision Aerial will obtainwritten consent ofany personwho will be participating inthe operations or otherwise be ontheprivatepropertywhere operations are to take place. PrecisionAerial will provide notice to any adjacentbuildings or structures. Precision Aerial will limit its operations to daytime Visual Flight Rules ("VFR").



### 4 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 mustremain 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 inan area otherthanpopulated orcongested, and not closerthan 500 feet to anyperson, 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 orproperty, avoid intrusion into unauthorized airspace, and avoid a public annoyance. Its UASs will not be operated over a highly-congested areaoropen air assembly ofpersons. 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 andfurnish proctors as maybenecessary to ensure that unauthorized persons do notcome within the narrow parameters in which the UASs will be operated. Combined with the technological capabilities ofthe UASs and that the UASs will be operated within the visual line ofsight ofthe pilot and an observer, Precision Aerial submits that its operational limitations provides an equivalentlevel ofsafety to thatprovidedin section 91.119.

Public interest Precision Aerial's UAS operations will substantially benefit public and private organizations which have an interest in gathering critical data and information to support their operations. Depending onthe use-case, these scenarios may include:

• the gathering of sensor data to document and assess real-time awareness of potential hazards orthe aftermath ofnatural disasters, fires, floods etc. • construction site and progress monitoring, • photographic and video services • ecological, agricultural, orland management surveying, • infrastructure surveying, inspection, andimprovement 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 ofTexas and its constituents.



### 5 1500 Mansions View Drive #907 Conroe. Texas 77384 71 3-857-3583

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Operating UASs under the limitations proposed by Precision Aerial will avoid any risk ofharm to pilots as well as persons and people onthe ground that would be present during the operation ofmanned aircraft. UAS operations will also require a much smaller energy footprint than with manned aircraft.
Operationslimitedtothe UnitedStates Under the requested exemption, Precision Aerial will operate its UASs withinthe United States.
Summary forFederalRegister Should the FAA determinethat publication ofa summary is required, PrecisionAerial submits the following summaryto be included inthe FederalRegister: PrecisionAerial seeks an exemption to operate the DJI Phantom 3 Professional, DJI Inspire 1, DJI 90 3DRX8, and 3DRAero-M unmanned aircraft systems to perform aerial ectio inspection and survey, and photographic and video services. Sincerely,
ScottMcG Principal Precision Aerial Compliance Solutions LLC

6 1500 Mansions View Drive #907 Conroe, Texas 77384 713-857-3583