pg. 1

FROM:

Versa Solutions, LLC 517 Wayland Drive Hockessin, DE 19707

Tel: 440-225-6158 Email: Christopher.Kuhman@flyversa.com

TO:

US DEPARTMENT OF TRANSPORTATION

DOCKET OPERATIONS

ROOM W12-140 OF THE WEST

BUILDING GROUND FLOOR 1200 NEW JERSEY AVENUE, SE. WASHINGTON, DC, 20590

Regulatory Docket No. _______________

PETITION FOR EXEMPTION OF: Versa Solutions, LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMEN TS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS PART 21, SUBPART H AND SECTIONS §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b)

CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 3 PR OFESSIONAL

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 O F THE FAA
MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 11 2-95)pg. 2 TABLE OF CONTENTS

GLOSSARY OF ABREVIATIONS........................................................................ 3

SUMMARY................................................................................................... 4

INTRODUCTION AND INTERESTS OF PETITIONER................................. ............ 4

BACKGROUND............................................................................................. 5

BASIS FOR PETITION..................................................................................... 5

NAME AND ADDRESS OF PETITIONER............................................................. . 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH VERSA SOLUTIONS, LLC SEEKS

EXEMPTION................................................................................................. 7

THE EXTENT OF RELIEF VERSA SOLUTIONS, LLC SEEKS AND THE REASON VERSA SOLUTIONS, LLC SEEKS THE RELIEF.......................................................... .... 10

THE REASONS WHY GRANTING VERSA SOLUTIONS, LLC RELIE F WOULD BE IN

THE PUBLIC INTEREST................................................................................. 12

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT AD VERSELY AFFECT PUBLIC SAFETY, OR HOW THE EXEMPTION WOULD PR OVIDE A LEVEL OF SAFETY AT LEAST EQUAL TO THAT PROVIDED BY THE RULE FROM WHICH VERSA SOLUTIONS, LLC SEEKS EXEMPTION............................................. ....... 14

THE FAA MAY PRESCRIBE ANY OTHER CONDITIONS FOR SAFE OPERATION...... 23

A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGI STER, STATING: THE RULES FROM WHICH VERSA SOLUTIONS, LLC SEEKS EXE MPTION.............. 24

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVA ILABLE TO SUPPORT VERSA SOLUTIONS, LLC REQUEST............................................. ...... 25

REQUEST FOR BLANKET APPROVAL.............................................................. 25

CONCLUSION..................................................................................................... 2 5

APPENDIX A – DJI PHANTOM 3 PROFESSIONAL TECHNICAL S PECIFICATIONS........... 27

APPENDIX B – DJI PHANTOM 3 PROFESSIONAL USERS MANUA L............................. 29

APPENDIX C – MONTHLY MAINTENANCE LOG............................................. ........ 30pg. 3 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

Section 333 FAA Modernization and Reform Act of 20 12 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landingpg. 4 SUMMARY

Versa Solutions, LLC seeks exemption from the requi rements of 14 C.F.R §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a ), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b), to operate an Unmanned Aircraft Sy stem pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This e xemption will permit Versa Solutions, LLC to operate an Unmanned Aircraft System (UAS) fo r the commercial purpose of conducting aerial video and photography for aerial surveying, building and monetizing YouTube channels, competitive intelligence, conservation, environment al regulation and compliance, delivery, disaster relief, feature filmmaking, news footage, pipeline and electrical line inspection, precision agriculture, real estate videos, resort a nd hotel advertising, search and rescue, security, sports and events, structural inspection and constr uction site data, surveillance, and wedding

videos over certain areas of the United States.

INTRODUCTION AND INTERESTS OF PETITIONER

Versa Solutions, LLC is a Delaware based company sp ecializing in aerial videography and photography. The founders of Versa Solutions, L LC all hold engineering degrees from accredited universities and have professional exper ience with all health, safety and environmental standards. Versa Solutions, LLC has r ecreational/hobby experience in all aspects of aerial videography and photography. The objectiv e of Versa Solutions, LLC video operations is to provide high-quality imaging for a variety of commercial and nonprofit productions, specifically targeting: home builders, home contrac tors, and/or home inspectors for real estate marketing and inspections of home exteriors as well as filming of special events, film sets, scripted and unscripted television sets, landscape, conducting pipeline and electrical line inspections, and aerial mapping and surveying utili zing a DJI Phantom 3 Professional UAS. More specifically, Versa Solutions, LLC aerial vide o and photography operations will serve in the following areas:

• Aerial photography of landscapes / residential an d commercial

• Aerial videography of estates / residential and c ommercial buildings and power lines

• Aerial photography and videography of pipelines a nd electrical lines

• Aerial event photography

• Aerial event filming

• Increase public knowledge of UAS and promote safe UAS operations

The proposed aerial filming will be conducted over private property with controlled access in the NAS and with the knowledge and permission of the pr ivate property’s owner.pg. 5 BACKGROUND

Unmanned Aircraft System: DJI Phantom 3 Professiona l UAS

Versa Solutions, LLC seeks an exemption to operate DJI systems DRONES for compensation or hire within the NAS. The DJI Phanto m 3 Professional UAS are vertical takeoff and landing (VTOL) Unmanned Aircrafts (UAS) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI P hantom 3 Professional has a maximum gross weight of approximately 2 pounds 11 ounces, while h aving a length of 16 inches, width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom 3 Professional UAS are equipped with four main rotors driven by Lithium Polymer battery powered electric motors.

The DJI Phantom 3 Professional UAS that will be ope rated by Versa Solutions, LLC (trained professional, Douglas Artze) will be regis tered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R. Par t 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification a nd Registration Marking.

BASIS FOR PETITION

Petitioner, Versa Solutions, LLC, pursuant to the p rovisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Air craft Systems , hereby petitions the Administrator to commercially operate the DJI Phant om 3 Professional UAS in the National Airspace System (NAS), and for an exemption from th e requirements of 14 C.F.R §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a ), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and li mited operating area associated with the unmanned aircraft and its operation, Versa Solution s, LLC operation of DJI Phantom 3

Professional UAS meets the conditions of FMRA Secti on 333 and therefore, will not require an

airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H.

Accordingly, Versa Solutions, LLC requests relief f rom Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as thes e sections set forth requirements for maintenance that only apply to aircraft with an air worthiness certificate. Versa Solutions, LLC submits that the requested relief is proper since a n equivalent level of safety will be ensured. Versa Solutions, LLC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS u sing the methods, techniques, and practices prescribed in the operating documents (i.e., Monthl y Maintenance Log and DJI Phantom 3 Professional Instruction Manual). Furthermore, Vers a Solutions, LLC will document and

maintain all maintenance records for the DJI Phanto m 3 Professional UAS.

Relief from certain requirements of Section 61.113( a) and (b), entitled Private pilot privileges and limitations : Pilot In Command, is requested by Versa Solutions , LLC to the extent necessary to allow a Pilot in Command (PIC) holding a Supplemental Pilot Certificate, and who has demonstrated, by meeting minimum flight-hour an d currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Profession al UAS in a manner consistent with thispg. 6

exemption, including evasive and emergency maneuver s and maintaining appropriate distances from people, vessels, vehicles and structures.

Versa Solutions, LLC seeks relief from Section 91.7 (a), entitled Civil aircraft

airworthiness , because the DJI Phantom 3 Professional UAS does n ot require an airworthiness certificate in accordance with 14 C.F.R. Part 21, S ubpart H. As such, Versa Solutions, LLC

submits that it will ensure that the DJI Phantom 3 Professional UAS is in an airworthy condition, prior to every flight, by determining that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 P rofessional Instruction Manual), and that the aircraft is in a condition for safe flight.

Versa Solutions, LLC also seeks an exemption from t he requirements of Section 91.121,

entitled Altimeter Settings , as the DJI Phantom 3 Professional UAS will not ha ve a typical barometric altimeter onboard. However, altitude inf ormation of the DJI Phantom 3 Pro will be provided to the PIC via Global Positioning System ( GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with Vers a Solutions, LLC’s operation of the DJI

Phantom 3 Professional UAS within visual line of si ght, at or below 200 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Versa Solutions, LLC seeks an exempti on from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Versa Solutions, LLC submits that safety will not be affected by operati on of the DJI Phantom 3 Professional UA during daylight hours in visual meteorological cond itions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming norma l cruising speed, to fly after that for at least

4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Versa Solutio ns, LLC provides the following information in support of its petition for exemption:

NAME AND ADDRESS OF PETITIONER

Versa Solutions, LLC 517 Wayland Drive Hockessin, DE 19707

Tel: 440-225-6158

Email: Christopher.Kuhman@flyversa.compg. 7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH VERSA SOLUTIONS, LLC

SEEKS EXEMPTION

Versa Solutions, LLC Seeks Exemption From The Requi rements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges a nd limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant pa rt:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or prope rty for compensation or hire.

Versa Solutions, LLC Seeks Exemption From The Requi rements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following:

(a) No person may operate a civil aircraft unless i t is in an airworthy condition.

Versa Solutions, LLC Seeks Exemption From The Requi rements Of Section 91.121.

Section 91.121, entitled Altimeter settings , subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintai n the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a sta tion along the route and

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescri bed in paragraph (a)(1)(i) of this section, the current reported altimeter settin g of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of

the departure airport or an appropriate altimeter s etting available before departure.

Versa Solutions, LLC Seeks Exemption From The Requi rements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following:pg. 8 (b) No person may begin a flight in a rotorcraft 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 crui sing speed, to fly after that for at

least 20 minutes.

Versa Solutions, LLC Seeks Exemption From The Requi rement Of Section 91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribe d 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[.]

Versa Solutions, LLC Seeks Exemption From The Requi rements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance , rebuilding, or

alteration , subsection (a)(1), states the following:

(a) No person may operate any aircraft that has und ergone maintenance, preventive maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

Versa Solutions, LLC Seeks Exemption From The Requi rements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a ), states the following:

(a) Except as provided in paragraph (c) of this sec tion, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has

been approved for return to service by a person aut horized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthin ess certificate in accordance with part 21 of this chapter.

Versa Solutions, LLC Seeks Exemption From The Requi rements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:pg. 9 (1) Records of the maintenance, preventive maintena nce, and alteration and records of the 100-hour, annual, progressive, and o ther required or approved inspections, as appropriate, for each aircraft (inc luding the airframe) and each engine, propeller, rotor, and appliance of an aircr aft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature and certificate number of the p erson approving the

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller,

and each rotor.

(ii) The current status of life-limited parts of ea ch airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items ins talled on the aircraft which are required to be overhauled on a specified time b asis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection prog ram under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method o f compliance, the AD or safety directive number and revision date. If the A D or safety directive involves recurring action, the time and date of the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently inst alled engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the followin g records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of th is section shall be retained

until the work is repeated or superseded by other w ork or for 1 year after the

work is performed.

(2) The records specified in paragraph (a)(2) of th is section shall be retained and

transferred with the aircraft at the time the aircr aft is sold.

(3) A list of defects furnished to a registered own er or operator under § 43.11 ofpg. 10 this chapter shall be retained until the defects ar e repaired and the aircraft is approved for return to service.

THE EXTENT OF RELIEF VERSA SOLUTIONS, LLC SEEKS AND THE REASON

VERSA SOLUTIONS, LLC SEEKS THE RELIEF

Extent Of Relief Versa Solutions, LLC Seeks And The Reason Versa Solutions, LLC Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Priv ate pilot privileges and limitations: Pilot in command is requested, to the extent necess ary to allow a PIC holding a Supplemental Pilot Certificate, as well as a current and valid a irman medical certificate, and who has met certain flight-hour and currency requirements, to c onduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only i ncidental to that business or employment; and (2) The aircraft does not carry passengers or prope rty for compensation or hire.

As set forth more fully below, Versa Solutions, LLC submits that an equivalent level of safety will be maintained because no PIC will be al lowed to operate the Phantom 3 Professional UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropr iate distances from people, vessels,

vehicles and structures.

Further, Versa Solutions, LLC submits that all flig hts of the DJI Phantom 3 Professional UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Versa Solutions, LLC business; and (2) will not carry pas sengers or property for compensation or hire.

Extent Of Relief Versa Solutions, LLC Seeks And The Reason Versa Solutions, LLC Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Versa Solutions, LLC to determine that the DJI Phantom 3 Professional UAS is in airworthy condition prior to every flight by ens uring that the UAS is in compliance with the operating documents (i.e., the Versa Solutions, LLC Aerial Operations Manual, Monthly Maintenance Log, and Phantom 3 Professional Instruc tion Manual).

Versa Solutions, LLC seeks the requested relief bec ause the DJI Phantom 3 Professional UAS does not require an airworthiness certificate i n accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Versa Solutions, LLC will ensure that the DJI Phantom 3 Professional UAS is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional Ins truction Manual) prior to every flight, andpg. 11

further, determine that the aircraft are in conditi on for safe flight, as stated in the conditions and

limitations below.

Extent Of Relief Versa Solutions, LLC Seeks And The Reason Versa Solutions, LLC Seeks

Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter sett ings, may be required to allow flight operations of the DJI Phantom 3 Professional UAS, w hich utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground co ntrol station (GCS). Since the FAA requires that any altitude information concerning UAS operat ions be reported to air traffic control (ATC) in feet above ground level (AGL).

Versa Solutions, LLC seeks the requested relief bec ause the DJI Phantom 3 Professional UA’s altimeter may be set on the ground to zero fee t AGL, rather than the local barometric pressure or field altitude, before each flight. Con sidering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Ph antom 3 Professional UAS is equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads-up display of th e GCS.

Extent Of Relief Versa Solutions, LLC Seeks And The Reason Versa Solutions, LLC Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel require ments for flight in VFR conditions, is requested to the extent required to allow flights o f the battery powered DJI Phantom 3 Professional UAS during daylight hours in visual me teorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 mi nutes to the first point of intended landing and, assuming normal cruising speed, to fly after that f or at least 4.5 minutes. Versa Solutions, LLC seeks the requested relief because without an exemp tion from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 Profe ssional UAS will severely constrain the practicality of any aerial video or still photo fli ght operations that Versa Solutions, LLC proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical sp ecifications of the DJI Phantom 3 Professional UAS operating documents, and Versa Sol utions, LLC proposed operating limitations, ensure that Versa Solutions, LLC will safely operate the battery powered DJI Phantom 3 Professional UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough batter y power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after

that for at least 4.5 minutes.pg. 12

Extent Of Relief Versa Solutions, LLC Seeks Relief And The Reason Versa Solutions, LLC Seeks Relief From Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate , Versa Solutions, LLC requests relief from

these Sections because the DJI Phantom 3 Profession al UAS does not require airworthiness certificates. As set forth more fully below, the DJ I Phantom 3 Professional UAS meets the conditions of FMRA Section 333 for operation withou t an airworthiness certificate. Accordingly, Versa Solutions, LLC will use trained technicians t o perform maintenance, alterations, or preventive maintenance on the UAS using the methods , techniques, and practices prescribed in the UAS operating documents (i.e., the Versa Soluti ons, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professi onal Instruction Manual). Furthermore, Versa Solutions, LLC will document and maintain all maintenance records for the DJI Phantom

3 Professional UAS.

THE REASONS WHY GRANTING VERSA SOLUTIONS, LLC RELIE F WOULD

BE IN THE PUBLIC INTEREST

The Public Will Benefit From Decreased Congestion O f The NAS.

The DJI Phantom 3 Professional UAS is battery power ed and serves as a safe, efficient,

and economical alternative to the manned aircraft t raditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 Professional UA S would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution , as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircr aft operating in the NAS, congestion around airports caused by arriving and d eparting aircraft will be reduced. The Phantom 3 Professional UAS does not require an airp ort to take off or land. Likewise, a reduction of manned aircraft conducting aerial vide o and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

The Public Will Benefit From The Safety And Efficie ncy Of The DJI Phantom 3

Professional UAS.

Conducting aerial acquisitions with the DJI Phantom 3 Professional UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Ph antom 3 Professional UAS produces no air pollution, and is the most viable environmentally c onscious alternative to the cabin class, six cylinder internal combustion engine aircraft that a re typically utilized for aerial video and photography, while burning approximately 20-30 gall ons per hour of leaded aviation fuel. The Phantom 3 Professional UAS, while reducing the carb on footprint of aerial acquisitions, alsopg. 13

eliminates noise pollution, as the UAS are propelle d by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3 Professional UAS to perf orm aerial acquisitions, the substantial risk to life and property in the air an d on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew memb ers located onboard the aircraft, the DJI Phantom 3 Professional UAS (weighing approximately 2 pounds 11 ounces respectively, at its maximum gross weights with length of 17.3 inches re spectively, width of 17.3 inches respectively, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compare d to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a f uel capacity of 180 gallons).

Performing Aerial Video and Photography Operations With The DJI Phantom 3 Professional UAS Will Benefit The Economy.

In addition to being safe and efficient, the Phanto m 3 Professional is also an economical alternative to using manned aircraft to conduct sim ilar aerial operations. As such, operation of

the DJI Phantom 3 Professional UAS will allow Unite d States based companies, like Versa Solutions, LLC, to remain competitive and contribut e to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviat ion fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 Professional UAS is one such technology that not only allows companies greater operational flexibility co mpared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3 Professional UAS, co mpanies such as Versa Solutions, LLC, can remain competitive and profitable, and the refore, provide greater job stability to employees and contractors, which will ultimately co ntribute to growth of the U.S. economy. Improved financial performance of U.S. companies, t hrough commercial use of the DJI Phantom 3 Professional UAS, provides a stable workforce tha t increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

There Are No Privacy Issues.

Similar to the manned aerial acquisition flight ope rations that have been conducted for decades, Versa Solutions, LLC proposed operation of the DJI Phantom 3 Professional UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional UAS will be operated only in compliance with operating document s (i.e., the Versa Solutions, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual) which requires property owner involvement a s well as local law enforcement notification, and in accordance with the Federal Av iation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.pg. 14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT AD VERSELY AFFECT PUBLIC SAFETY, OR HOW THE EXEMPTION WOULD PR OVIDE A LEVEL OF SAFETY AT LEAST EQUAL TO THAT PROVIDED BY THE RULE FROM

WHICH VERSA SOLUTIONS, LLC SEEKS EXEMPTION.

Reasons Why The DJI Phantom 3 Professional UAS Meet s The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333

In consideration of the size, weight, speed, and li mited operating area associated with the unmanned aircraft and its operation, Versa Solution s, LLC operation of the DJI Phantom 3

Professional UAS meets the conditions of FMRA Secti on 333, and will not require an

airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to na tional security.

Specifically, FMRA Section 333 states the following , in part:

(a) In General.--Notwithstanding any other requirem ent of this subtitle, and not later than 180 days after the date of enactment of this A ct, the Secretary of Transportation shall determine if certain unmanned aircraft system s may operate safely in the national airspace system before completion of the plan and r ule-making required by section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In ma king the determination under subsection (a), the Secretary shall determine, at a minimum—

(1) which types of unmanned aircraft systems, if an y, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not cr eate a hazard to users of the national airspace system or the public or pose a th reat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, Unit ed States Code, is required for the operation of unmanned aircraft systems identifi ed under paragraph (1).

(c) Requirements for Safe Operation.--If the Secret ary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requ irements for the safe operation of such aircraft systems in the national airspace s ystem.

In seeking this exemption, Versa Solutions, LLC sub mits that the DJI Phantom 3 Professional UAS can operate safely in the NAS purs uant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional UAS; (b) the pilot certification requirement; and (c) the specific ope rating limitations.pg. 15

The Specifications Of The DJI Phantom 3 Professiona l UAS Demonstrate Its Safe

Characteristics

The DJI Phantom 3 Professional UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national secu rity, considering its size, weight, speed, and operational capability.

Technical Specifications Of The DJI Phantom 3 Profe ssional UAS

The technical specifications of the DJI Phantom 3 P rofessional UAS are set forth by the DJI Phantom 3 Professional Specifications and Data Sheet, attached hereto as Appendix A.

The DJI Phantom 3 Professional UAS Autonomous Fligh t And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area

.

The DJI Phantom 3 Professional UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3 Professional UAS is provided at page 26 o f the DJI Phantom 3 Professional User Manual, attached hereto as Appendix B.

The DJI Phantom 3 Professional UAS Is Designed For Automatic Return To Home

Point Or Hover In The Event Of Loss Of The Control Link Or Navigation

When the Control Link is lost, the DJI Phantom 3 Pr ofessional UAS will remain stationary, in flight, for 3 seconds or more. If, a fter 3 seconds, the DJI Phantom 3 Professional UAS does not reacquire control link data from the G CS, the UA will assume that the Control Link is lost and the UA will return to the home pos ition (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shut down.

A complete description of the Failsafe Functions of the DJI Phantom 3 Professional UAS are set forth at pages 12 through 14 of the DJI Pha ntom 3 Professional UAS User Manual,

attached hereto as Exhibit B.

The Phantom 3 Professional GCS And Its Operation

A complete description of the operation and specifi cations of the DJI Phantom 3 Professional GCS and flight control software is pro vided at pages 23 through 29 of the Phantom

3 Professional User Manual. DJI Phantom 3 Professio nal User Manual is attached hereto as

Exhibit B.

Flight Operations Of DJI Phantom 3 Professional UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Ob server.pg. 16 Versa Solutions, LLC will only utilize certificated pilots who possess a current and valid

airman medical certificate to act as a pilot in com mand (PIC) of the DJI Phantom 3 Professional UAS. Additionally, a safety observer will assist al l pilots during flight time.

Flights Of DJI Phantom 3 Professional UAS Will Be C onducted Pursuant To Specific Operating Limitations

In seeking this exemption, Versa Solutions, LLC pro poses to commercially operate the DJI Phantom 3 Professional UAS for the special purp ose of conducting aerial video and photography over certain areas of the United States , pursuant to the following operating

limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, roto rcraft UAS's weighing less than 55 pounds maximum gross weight: DJI Phantom 3 Professi onal Unmanned Aircraft System. Proposed operations of any other aircraft will requ ire a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limi ted to conducting operations for the purpose of aerial video and photography for homeown ers, Realtors, home builders, contractors, home inspectors for use in real estate marketing and real estate inspections. Additionally, aerial video and photography may be c onducted on occasional basis for film and television sets, special events and landsc ape photography, conducting power line inspection, aerial mapping, and surveying as deemed necessary.

3. The UAS may not be flown at an indicated airspee d exceeding 30 knots (16 m/s).

4. The UAS must be operated at an altitude of no mo re than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents, unless a special request is made and approved by ATC. All al titudes reported to ATC must be in

feet AGL.

5. The UAS must be operated within visual line of s ight (VLOS) of the PIC at all times. This requires the PIC to be able to use huma n vision unaided by any device other than corrective lenses, as specified on the PIC’s F AA-issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (S O). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintain s VLOS capability. The SO and PIC must be able to communicate verbally at all tim es. The PIC must be designated before the flight and cannot transfer his or her de signation for the duration of the flight. The PIC must ensure that the SO can perform the fun ctions prescribed in the operating

documents.pg. 17 8. The SO must not perform any other duties beyond assisting the PIC with seeing and

avoiding other air traffic and other ground based o bstacles/obstructions, and is not permitted to operate the camera or other instrument s.

9. The operating documents and the grant of exempti on must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its opera ting documents. The operator may update or revise the operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. I f the operator determines that any update or revision would affect the basis upon whic h the FAA granted the exemption, then the operator must petition for amendment to it s grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if que stions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the U AS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspectio n. All maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alter ations that affect the UAS operation or flight characteristics, e.g. replaceme nt of a flight critical component, must undergo a functional test flight. The PIC who condu cts the functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not alr eady covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit r equirements.

14. The operator must carry out its maintenance, in spections, and record keeping requirements in accordance with the operating docum ents. Maintenance, inspection, alterations, and status of replacement/overhaul com ponent parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning th e UAS to service.

15. Each UAS operated under this exemption must com ply with all manufacturer Safety

Bulletins.pg. 18 16. The authorized person must make an entry in the aircraft record of the corrective

action taken against discrepancies discovered betwe en inspections.

17. The PIC must possess at least a Supplemental Pi lot certificate and at least a current third-class medical certificate. Supplemental pilot s must have, at a minimum, successfully completed private pilot ground school. Additionally, supplemental pilots without a current FAA private pilot certificate mus t have successfully passed the private pilot, commercial pilot, or airline transport pilot knowledge test within the past 24

calendar months.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight h ours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for t he purposes of training the operator’s PICs are permitted under the terms of the exemption ; however, training operations may only be conducted during dedicated training session s. During training, proficiency and experience-building flights, all persons not essent ial for flight operations are considered nonparticipants, and the PIC must operate the UA wi th appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.1 19.

19. UAS operations may not be conducted during nigh t, as defined in 14 C.F.R. §1.1. All operations must be conducted under visual meteorolo gical conditions (VMC). If flight at night is required, a special request will be made a t the FAA office closest to proposed area of operations. Flights under special visual fl ight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical cha rt unless a letter of agreement with that airport’s management is obtained, and the oper ation is conducted in accordance with a NOTAM as required by the operator’s COA. The lett er of agreement with the airport management must be made available to the Administra tor upon request.

21. The UA may not be operated less than 500 feet b elow or less than 2,000 feet horizontally from a cloud or when visibility is les s than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.

23. The PIC must abort the flight in the event of u npredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight u nless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery powe r remaining.pg. 19 25. The operator must obtain an Air Traffic Organiz ation (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting a ny operations under the grant of exemption. This COA will also require the operator to request a Notice to Airmen (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in acc ordance with airspace requirements in the ATO issued COA including class of airspace, alt itude level and potential transponder requirements.

26. All aircraft operated in accordance with the ex emption must be identified by serial number, registered in accordance with 14 C.F.R. par t 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequen cy spectrum used for operation and control of the UA must comply with the Federal Comm unications Commission (FCC) or other appropriate government oversight agency requi rements.

28. The documents required fewer than 14 C.F.R. 91. 9 and 91.203 must be available to

the PIC at the Ground Control Station of the UAS an y time the UAS is operating. These

documents must be made available to the Administrat or or any law enforcement official
upon request.

29. The UAS must remain clear and yield the right o f way to all manned aviation operations and activities at all times. The UAS may not be operated by the PIC from any moving device or vehicle.

30. Flight operations must be conducted at least 50 0 feet from all nonparticipating persons (persons other than the PIC, SO, operator t rainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficie ntly protect nonparticipating persons from the UA and/or debris in the event of a n accident. The operator must ensure that nonparticipating persons remain under s uch protection. If a situation arises where nonparticipating persons leave such pr otection and are within 500 feet of the UA, flight operations must cease immedi ately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or struc tures has granted permission and the PIC has made a safety assessment of the ris k of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator train ees or essential persons do not present an undue hazard to those persons per § 91.119(a).

31. All operations shall be conducted over private or controlled-access propertypg. 20 with permission from the land owner/controller or a uthorized representative. Permission

from land owner/controller or authorized representa tive will be obtained for each flight to

be conducted.

32. Any incident, accident, or flight operation tha t transgresses the lateral or vertical boundaries of the operational area as defi ned by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-8 0) within 24 hours. Accidents must be reported to the National Transportation Safety B oard (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

Reasons Why An Exemption From The Requirements Of S ection 61.113(a)And (b) Would Not Adversely Affect Safety.

Versa Solutions, LLC submits that the equivalent le vel of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom

3 Professional UAS unless that PIC has demonstrated , by meeting minimum flight-hour and currency requirements, that the PIC is able to safe ly operate the DJI Phantom 3 Professional UAS in a manner consistent with the exemption, incl uding evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Versa Solutions, LLC's proposed area of operations, and the operating limitations set forth above; the parallel nature of private pil ot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 3 Profe ssional UAS, Versa Solutions, LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Ve rsa Solutions, LLC specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11 09, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Versa Solutions, LLC will not allow any PIC to oper ate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting mi nimum flight-hour requirements or the DJI Phantom 3 Professional UAS training and currency re quirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in a man ner consistent with this exemption, including evasive and emergency maneuvers and maint aining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hou rs of total time as a UAS rotorcraft pilot (with a minimum of 5 of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the prec eding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulati ons will ensure an equivalent level of safety during Versa Solutions, LLC's proposed operations. The Administrator has held that priorpg. 21

documented flight experience that was obtained in c ompliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar opera tions), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.5 1(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours lo gged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UA S pilot operating the same make and model of UAS to be used for operations under th e exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 ta keoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petition er’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requireme nt. Training, proficiency, and experience-building flights can also be conducted u nder the grant of exemption to accomplish the required flight time. During trainin g, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance

with 14 C.F.R 91.119.

Accordingly, Versa Solutions, LLC will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 Professional UAS unles s that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI

Phantom 3 Pro UAS in a manner consistent with the e xemption, including evasive and emergency maneuvers and maintaining appropriate dis tances from people, vessels, vehicles and

structures.

Reasons Why An Exemption From The Requirements Of S ection 91.7(a) Would Not Adversely Affect Safety

The equivalent level of safety established by Secti on 91.7(a) will be maintained because prior to every flight, Versa Solutions, LLC will en sure that the DJI Phantom 3 Professional UAS is in an airworthy condition based upon the UAS’s c ompliance with its operating documents and

as stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material resp ects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 1113 8, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).pg. 22

Reasons Why An Exemption From The Requirements Of S ection 91.121 Would Not Adversely Affect Safety

The equivalent level of safety established by Secti on 91.121 will be maintained

because the altitude information of the Phantom 3 P rofessional UA will be provided to the PIC via GPS equipment and a radio communications teleme try data link, which downlinks from the UA to the GCS for active monitoring of the flight p ath and altitude. This altitude information, combined with Versa Solutions, LLC’s operation of t he DJI Phantom 3 Professional UAS within visual line of sight, at or below 400 feet AGL, wil l ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude ini tiation point is automatically established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11 109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

Reasons Why An Exemption From The Requirements Of S ection 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalen t level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the tec hnical specifications of the DJI Phantom 3 Professional UAS; (2) the limitations on the propos ed flight operations; and (3) the location of the proposed flight operations. Accordingly, Versa Solutions, LLC will ensure that it will safely operate the battery powered DJI Phantom 3 Professio nal UAS during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising s peed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical spec ifications of the DJI Phantom 3 Professional UAS; the limitations on the proposed f light operations; and the location of the proposed operations, will ensure an equivalent leve l of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as t he DJI Phantom 3 Professional UAS provides audible and visual warnings to the PIC at the GCS w hen the UA experiences low battery voltage, the first warning occurring at approximately 30% re maining battery power, and again at approximately 10% remaining battery power. At the c ritically low battery level, the DJI Phantom

3 Professional UAS will descend and land automatica lly.

Significantly, previous exemptions granted by the F AA concerning Section 91.151 establish that safety is not adversely affected whe n the technical characteristics and operating

limitations of the UAS are considered. Relief has b een granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151 , including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted rel ief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 110 65, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11 159, 11160, 11161).pg. 23

Reasons Why An Exemption From The Requirements Of S ections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would No t Adversely Affect Safety

In seeking this exemption, Versa Solutions, LLC sub mits that the equivalent level of safety with regard to the regulatory maintenance an d alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a )(2), and 91.417(a) & (b) will be met because Versa Solutions, LLC will use trained technicians t o perform maintenance, alterations, or preventive maintenance on the UAS using the methods , techniques, and practices prescribed in the operating documents (i.e., the Versa Solutions, LLC Aerial Operations Manual, Monthly Maintenance Log, and Phantom 3 Professional Instruc tion Manual). Furthermore, Versa Solutions, LLC will document and maintain all maint enance records for the DJI Phantom 3

Professional UAS.

Since the DJI Phantom 3 Professional UAS will be in spected as prescribed by the operating documents, Versa Solutions, LLC will main tain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), an d 91.409(a)(2). A copy of DJI Phantom 3 Professional User Manual is attached hereto as Appe ndix B; a copy of the DJI Phantom 3

Professional UAS Maintenance LOG is attached hereto as Appendix C.

Likewise, the exemption sought will not adversely a ffect safety because Versa Solutions, LLC will use trained technicians to perform mainten ance, alterations or preventive maintenance on the UAS using the methods, techniques, and pract ices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because a ll maintenance of the DJI Phantom 3 Professional UAS will be performed by trained techn icians. Maintenance will be documented and maintained utilizing the monthly maintenance lo g.

Significantly, previous exemptions granted by the F AA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and ope rating limitations of the UAS are considered. In consideration of Versa Solutions, LLC proposed o perating limitations, the operating documents, and the technical aspects of the DJI Pha ntom 3 Professional UAS, Versa Solutions, LLC submits that safety will not be adversely affec ted by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409 (a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circum stances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11 156, 11157, 11158, 11159, 11160, 11161).

THE FAA MAY PRESCRIBE ANY OTHER CONDITIONS FOR SAFE OPERATION.

In accordance with Section 333 of the FAA Moderniza tion and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Condi tions, Versa Solutions, LLC requests that the FAA prescribe special conditions for the intend ed operation of the DJI Phantom 3 Professional UAS, which contain such safety standar ds that the Administrator finds necessary to establish a level of safety equivalent to that esta blished by 14 C.F.R. Part 21, Subpart H, and 14pg. 24

C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151( b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special condition s will permit safe operation for the limited purpose of conducting aerial and video photography over certain areas of the United Sates for compensation or hire. FMRA sets forth the requireme nts for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be estab lished for the safe operation of the UAS in

the NAS.

Likewise, the Administrator may prescribe special c onditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 3 Professio nal UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or app ropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21 .16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an air craft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, ai rcraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to e stablish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21. 16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Versa Solutions, L LC’s intended operation of the DJI Phantom 3 Professional UAS, which contain such safety standar ds that the Administrator finds necessary to establish a level of safety equivalent to that esta blished by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91 .151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGI STER, STATING: THE RULES FROM WHICH VERSA SOLUTIONS, LLC SEEKS EXE MPTION

Versa Solutions, LLC seeks exemption from the requi rements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a ), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Brief Description Of The Nature Of The Exemption Ve rsa Solutions, LLC Seeks:

This exemption will permit Versa Solutions, LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain

areas of the United States.pg. 25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVA ILABLE TO

SUPPORT VERSA SOLUTIONS, LLC REQUEST

This Petition is made pursuant to the FAA Moderniza tion and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Versa Solut ions, LLC's request for exemption may be granted pursuant to the authority of FMRA Section 3 33 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for co nsidering whether a UAS will create a hazard to users of the NAS or the public, or otherw ise pose a threat to national security; and further, provides the authority for such UAS to ope rate without airworthiness certification. As discussed in detail above, Versa Solutions, LLC wil l operate the DJI Phantom 3 Professional UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

REQUEST FOR BLANKET COA APPROVAL

On March 24, 2015, the FAA announced that it has im plemented a new policy of granting "blanket" COAs to applicants requesting ex emptions from the Federal Aviation Regulations under Section 333 of the FAA Modernizat ion and Reform Act of 2012. The Applicant hereby requests a "blanket" COA that conf orms to the terms set forth in https://www.faa.gov/news/updates/?newsId=82245 upon approval of Versa Solutions, LLC's exemption request.

CONCLUSION

As set forth herein, Versa Solutions, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization an d Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 Professional UAS commercially, without an airworthiness certificate, for the limited purpo se of conducting aerial video and photography over certain areas of the United States. By grantin g this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Mod ernization and Reform Act of 2012, while also advancing the interests of the public, by allo wing UAV Aerial Video to safely, efficiently, and economically operate the DJI Phantom 3 Professi onal UAS commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Versa Solutions, LLC respectfully requests that the Administrator grant this Petition for an e xemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b ), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Versa Solut ions, LLC to operate the DJI Phantom 3 Professional UAS commercially for the purpose of co nducting aerial video and photography for aerial surveying, building and monetizing YouTube c hannels, competitive intelligence, conservation, environmental regulation and complian ce, disaster relief, feature filmmaking, news footage, pipeline and electrical line inspection, p recision agriculture, real estate videos, resort and hotel advertising, search and rescue, security, sports and events, structural inspection and construction site data, surveillance, and wedding v ideos over certain areas of the United States.pg. 26

Dated: December 16, 2015

Respectfully submitted,

Versa Solutions, LLC 517 Wayland Drive Hockessin, DE 19707

Tel: 440-225-6158 Email: Christopher.Kuhman@flyversa.compg. 27 APPENDIX – A

DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS

Versa Solutions, LLC only utilizes safe and reliabl e UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground bre aking software enabling the user to set parameters which will not allow flight into control led airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI so ftware provides real-time altitude and location information to the PIC via the linked monitor (smar t phone/tablet devices)

DJI Phantom 3 Pro

Aircraft Weight (Battery & Propellers Included): 2.82 lbs (1 280g) Hovering Accuracy (GPS Mode) Vertical: +/- 10cm, Ho rizontal: +/- 1m Max Ascent Speed: 5m/s Max Descent Speed: 3m/s Max Speed: 16m/s (ATTI mode, no wind) Max Flight Altitude: 6000m Max Flight Time: Approximately 23 minutes Operating Temperature Range: 32°F to 104°F (0°C to 40°C)

Dimensions: 27 1/8" x 27 1/8" x 7.5"

GPS Mode: GPS/GLONASS

Gimbal Controllable Range Pitch: - 0°C to + 30°C

Vision Positioning Velocity Range: < 8 m/s (2 m above the ground) Altitude Range: 30 cm-300 cm Operating Range: 30 cm-300 cm Operating Environment: Brightly lit (lux >15) patte rned surfaces

Camera Sensor: Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M) Lens: FOV 94° 20 mm (35 mm format equivalent) ISO Range: 100-3200 (Video) 100-1600 (Photo) Electronic Shutter Speed: 8/s - 1/8000s Image Max Size: 4000x3000 Single Shot Burst shooting 3/5/7 frames Still Photography Modes: Auto Exposure Bracketing (AEB): 3/5

Bracketed frames at 0.7EV Bias Time Lapse Supported SD Card Types:pg. 28 Micro SD Max capacity: 64GB. Class 10 or UHS-1 rating requir ed Video Recording Modes: UHD: 4096x2160p, 3840x2160p 24/25/30 FHD: 1920x1080p 24/25/30/48/50/60 HD: 1281x720p 24/25/30/48/50/60 Max Bit Rate Of Video Storage: 60 Mbps Supported File Formats: FAT 32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG-4 AVC/H.264 Operating Temperature Range: 0°C to 40°C

Remove Controller Operating Frequency: 2.400 GHz-2.483 GHz Transmitting Distance: 2000 m (Outdoor And Unobstru cted Video Output Port: USB Operating Temperature Range: 0°C to 40°C Battery: 6000 mAh LiPo 2s Mobile Device Holder: Tablets and smartphones Transmitter Power (EIRP): FCC: 20 dbm; CE: 16 dbm Working Voltage: 1.2 A @ 7.4 V

Charger Voltage: 7.4 V

Rated Power: 100 W

Intelligent Flight Battery (PH3-4480 mAh-15.2 V) Capacity: 4481 mAh Voltage: 15.2 V Battery Type: LiPo 4S Energy: 68 W Net Weight: 365 g Operating Temperature: -10°C to 40°C Max Charging Power: 100 Wpg. 29 APPENDIX – B

DJI PHANTOM 3 PRO MANUFACTURER’S USER MANUAL

Most current version of the user manual can be foun d at:

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Pr ofessional_User_Manual_v1.2_en.pdfpg. 30 APPENDIX – C



### VERSA SOLUTIONS, LLC MONTHLY MAINTENANCE LOG



## Versa Solutions, LLC Monthly Maintenance Log

Month: ______ Year: ________

Date Issue

Discovered Date Issue

Addressed Issue Description & Maintenance Conducted Maintenance Performed By: Print and Sign
Software Updates

Airframe

Engines
Propellers

Camera Gimbal
Landing Gear

Batteries

Other