Brett	Kanda Partner Verascan	Inc. 4600	Polaris	Ave. Las	Vegas,	NV. 89103
E: brett@verascaninc.com P:	818

- 515

- 5659 W:	www.verascaninc.com

• Verascan Inc.	seeks	exemption	from	the	requirements	of	14	C.F.R.	§§
6 1.113(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),	to	operate	an	Unmanned	Aircraft System	pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of 2012	(FMRA).	This	exemption	will	perm it Verascan Inc.	to	operate	a	DJI Phantom	2 for	the	commercial	purpose	of	conducting	aerial inspections, acquisitions	and	research	within	the	National	Airspace	System	(NAS) in	the industries	of	agriculture,	construction,	and	engineering

.

• Allowing	Verascan to	commercially	operate	would	improve	efficiency	in	each industry	because of	strict	safety	protocols,	years	of	experience,	and	qualified pilots.		Eliminating	the	need	for	personnel	in	hazardous	environments	is	now possible	through	the	effective	operations of	Verascan.		Verascan	is	located	in
Las Vegas,	which has	multiple	advantages	including	being	firmly	planted	inone	of	the	6	FAA	designated	test	sites. Our	distinct	partnerships	with	UNLV, NStec,	and	Space	Information	Laboratories	have	created	a	powerful group	of people	that	are	ready	to	demonstrate	a	positive	representation	of	the	UAV industry	in	both	Southern	Nevada	and	on	a	national	level.		Our	advanced sensors	and	software	outputs	will	give	businesses	a	chea per,	more	effective solution	to	fill the	cu r rent	gaps	in	their	processes.	Our	teams	of	experienced professionals	have	created	an	Operations	Manual	and	Training	Regimen	that represent	the	budding	UAV	industry	in	a	positive	light.

• If	granted	an	exemption,	Verascan	would	adhere	to	the	attached	Opera tions Manual	in	a	strict	manner	by	conducting	commercial	flights	with	a	P.I.C. holding	a	Private	Pilots	License,	necessary	medical	clearance,	a	V.O.	with
U.S.A.F

. Unmanned	training	credentials, fly	within	V.L.O.S,	fly	under	2 00	feet and	only	to	400	feet	if the	local	FAA	office	is	notified, and	follow	the guidelines	highlighted	by	the	FAA	as	well	as	our	unique	Operations	Manual. Conducting	these	flights	with	proper	risk	management,	pre

- flight	checklists, flight	checklists,	and	post

- flight	checklists	would	p rovide	a	higher	level	of safety	to	the	community	that	we	would	be	flying	in	and	the	nation	as	a	whole. Verascan	Inc.	would	not	conduct	commercial	flights	in	crowded	areas,	at night,	at	altitudes	exceeding	2 00	feet and	up	to	400	feet	if	the	local	FAA	offic e is	not	notified ,	and	with	an	aircraft	that	has	not	met	our	training	standards and	required	test	flight	times.Reasons	Why	An	Exemptio n	From	The	Requirements	Of	Section	61.113(a)	And (b)	Would	Not	Adversely	Affect	Safety : Verascan submits	that	the	equivalent	level of	safety	established	by	Section	61.1 DJI	Phantom	2 unless	that	PIC	has demonstrated,	through	the DJI	Phantom	2	UAV training and	currency	requirements, that	the	PIC	is	able	to	safely	operate	the DJI	Phantom	2 in	a	manner	consistent	with this	exemption,	including	evasive	and	emergency	maneuvers	and	maintaining appropriate	distances	from	people,	vesse ls,	vehicles	and	structures. C onsidering Verascan’s proposed	area	of	operations,	and	the	operating	limitations	set	forth

above;	the	parallel	nature	of	private	pilot	aeronautical	knowledge	requirements	to those	of	commercial	pilot	requirements	(See	Exemption	No.	11062);	and	the airmansh ip	skills	necessary	to	safely	operate	the DJI	Phantom	2,	Verascan submits that	the	additional	manned	airmanship	experience	of	a	commercially	certificated pilot	would	not	correlate	to	the	airmanship	skills	necessary	for Verascan’s specific proposed	flight	o perations.	Additionally,	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,	1108 0,	11109,	11110,	11112,	11136,	11138).	As	in Exemption	No.	11109, Verascan will	not	allow	any	PIC	to	operate	the DJI	Phantom	2 unless	that	PIC	has	demonstrated	through	the DJI	Phantom	2	UAV training	and currency	requirements,	that	the	PIC	is	able	to	safely operate	the DJI	Phantom	2	UAV in	a	manner	consistent	with	this	exemption,	including	evasive	and	emergency maneuvers	and	maintaining	appropriate	distances	from	people,	vessels,	vehicles and	structures.	A	complete	description	of	the DJI	Phantom	2 Training	a ndQualification	requirements	is	set	forth	in the	attached	Operations	Manual

. Operations	Manual contains	proprietary	information	and	is	to	be	held	in	a	separate file	pursuant	to	14	C.F.R.	§ 11.35(b). Reasons	Why	An	Exemption	From	The	Requirements	Of	Secti on	91.7(a)	Would Not	Adversely	Affect	Safety : The	equivalent	level	of	safety	established	by	Section 91.7(a)	will	be	maintained	because	prior	to	every	flight, Verascan will	ensure	that the DJI	Phantom	2 is	in	an	airworthy	condition	based	upon	the	aircraft’s conformity to	its	type	design,	including	compliance	with	its	operating	documents	(i.e.,	the DJI Phantom	2 User	Manual	and	the	D JI	Phantom	2 Maintenance	Manual),	and	that	the
UA V is	in	a	condition	for	safe	flight,	as	stated	in	the	conditions	and	limitation s contained	herein. Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.121	Would Not	Adversely	Affect	Safety : The	equivalent	level	of	safety	established	by	Section 91.121	will	be	maintained	because	the	altitude	information	of	the DJI	Phantom	2 will	be	provided	to	the	PIC	via	GPS	equipment	and	a	radio	communications telemetry	data	link,	which	downlinks	from	the	UA V to	the	GCS	for	active	monitoring of	the	flight	path	and	altitude.	This	altitude	information,	combined	with Verascan’s operation	of	th e DJI	Phantom	2 within	visual	line	of	sight,	at	or	below	400	feet	AGL, will	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	alti tude	initiation	point	is	auto matically	established	by	the	UAV .	The FAA	has	previously	granted	relief	fro m	Section	91.121	specific	to	UAV ,	in circumstances	similar,	in	all	material	respects,	to	those	presented	herein	(e.g.Exemption	Nos.	11062,	11063,	11064 ,	11065,	11066,	11067,	11080, 11109,	11112, 11136,	11138). Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.151(b) Would	Not	Adversely	Affect	Safety : A	grant	of	this	exemption	would	ensure	an equivalent	level	of	safety	established	by	14	C.F.R .	Section	91.151(b)	as	a	result	of	(1) the	technical	specifications	of	the DJI	Phantom	2 ;	(2)	the	limitations	on	the	proposed flight	operations;	and	(3)	the	location	of	the	proposed	flight	operations.	Accordingly,
Verascan will	ensure	that	it	will	safely	o perate	the	battery	powered	D JI	Phantom	2 during	daylight	hours	in	VMC	conditions,	under	VFR,	with	enough	battery	power	to fly	for	a	total	duration	of	15	minutes	to	the	first	point	of	intended	landing	and, assuming	normal	cruising	speed,	to	fly	after	that	f or	at	least	five	minutes	(i.e.,	25 percent	battery	power	remaining).	Similar	to	the	FAA’s	Grant	of	Exemption	No. 11109,	AgScan	hereby	submits	that	the	technical	specifications	of	the DJI	Phantom
2 ;	the	limitations	on	the	proposed	flight	operations;	and	the location	of	the proposed	operations,	will	ensure	an	equivalent	level	of	safety	established	by	14 C.F.R.	Section	91.151(b).	Furthermore,	an	equivalent	level	of	safety	will	be	ensured as	the DJI	Phantom	2 provides	audible	and	visual	warnings	to	the	PIC	at	t he	GCS when	the	UA	reaches	20	percent	and	10	percent	of	battery	power	remaining. Significantly,	previous	exemptions	granted	by	the	FAA	concerning	Section	91.151 establish	that	safety	is	not	adversely	affected	when	the	technical	characteristics	and operatin g	limitations	of	the	UAS	are	considered.	Relief	has	been	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	previouslygranted	relief	from	Sec tion	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,	11065,	11066,	11067,	11080,	11 109,	11110, 11136,	11138).	30 Reasons	Why	An	Exem ption	From	The	Requirements	Of	Sections	91.405(a), 91.407(a)(1),	91.409(a)(1)	&	(a)(2),	And	91.417(a)	&	(b)	Would	Not	Adversely Affect	Safety : In	seeking	this	exemption, Verascan submits	that	an	equivalent	level of	safety	with	regard	to	the	regulatory	main tenance	and	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	Verascan will	use	manufacturer	trained technicians	to	perform	maintenance,	alterations,	or	preventive	mainte nance	on	the UAS	using	the	methods,	techniques,	and	practices	prescribed	in	the	manufacturer’s
mainten ance	manual.	Furthermore,	Verascan will	document	and	maintain	all maintenance	records	for	the DJI	Phantom	2 .	Since	the DJI	Phantom	2 will	be inspected	as prescribed	by	the	manufacturer’s	maintenance	m anual,	Verascan will maintain	the	equivalent	level	of	safety	established	by	Sections	91.405(a), 91.409(a)(1),	and	91.409(a)(2).	The	D JI	Phantom	2 System Operations Manual	sets forth	airworthiness	requirements	f or	the	UA,	including	preflight	inspections,	as	well as	scheduled	maintenance	after	every	three	months,	every	year	or	300	flight	hours (whichever	comes	first),	and	after	every	600

- flight	hours.	Likewise,	the	exemption sought	will	not	advers ely	affect	safety because	Verascan will	use	manufacturer trained	technicians	to	perform	maintenance,	alterations	or	preventive	maintenance on	the	UAS	using	the	methods,	techniques,	and	practices	prescribed	by	themanufacturer’s	maintenance	manual.	The DJI	Phantom	2	Operations Manual	details procedures	for	inspection,	firmware	upgrades,	motor	testing,	and	motor replacement.	A	complete	description	of	the DJI	Phantom	2 maintenance requirements	is	set	forth	in	the DJI	Phantom	2	Operations Manual, which	is attached. Attached	Operations	Manual contains	proprietary	information	and	is	to	be held	in	a	separate	file	pursuant	to	14	C.F.R.	§	11.35(b).	Furthermore,	the	exemption sought	would	maintain	an	equivalent	level	of	safety	established	by	Sections	91.407, 91.417(a) and	91.417(b),	because	all	maintenance	of	the DJI	Phantom	2 will	be performed	by	manufacturer	trained	technicians,	which	will	document	and	maintain maintenance	records	for	the	UAS.	Significantly,	previous	exemptions	granted	by	the FAA	concerning	t he DJI	Phantom	2 and	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	operating	limitations	of	the	UAS	are DJI	Phantom	2	Operations Manual,	and	the	technical	aspects	of	the DJI	Phantom	2
Verascan submits	that	safety	will	not	be	adversely	affected	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 circumstances	similar,	in	all	material	respects,	to	those	presented	herein	(e.g. Exemption	Nos.	11062,	11063,	11064,	11065,	11066,	11067,	1 1080,	11109,	11110, 11112,	11136,	11138).	7.	The	FAA	May	Prescribe	Any	Other	Conditions	For	Safe Operation.	In	accordance	with	Section	333	of	the	FAA	Modernization	and	Reform Act	of	2012	(FMRA)	and	14	C.F.R.	§	21.16	entitled	Special	Conditions, Verascan
requ ests	that	the	FAA	prescribe	special	conditions	for	the	intended	operation	of	theDJI	Phantom	2 ,	which	contain	such	safety	standards	that	the	Administrator	finds necessary	to	establish	a	level	of	safety	equivalent	to	that	established	by	14	C.F.R.
Pa rt	21,	Subpart	H,	and	14	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).	2	Such	special conditions	will	permit Verascan ’ s safe	operation	of	the	UA	for	the	limited	purpose	of conducti ng	aerial	acquisitions	over	certain	rural	areas	of	the	United	States	for compensation	or	hire.	FMRA	Section	333	sets	forth	the	requirements	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	established	for	the	safe	operation	of	the	UAS	in	the	NAS. Likewise,	the	Administrator	may	pr escribe	special	conditions	pursuant	to	14	C.F.R.	§ 21.16,	for	operation	of	the DJI	P h antom 2 ,	since	the	airworthiness	regulations	of	14 C.F.R.	Part	21	do	not	contain	adequate	or	appropriate	safety	standards,	due	to	the novel	or	unusual	design	featu res	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 aircraft,	aircraft	engine,	or	prope ller	because	of	a	novel	or	unusual	design	feature	of the	aircraft,	aircraft	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	conta in	such	safety	standards	for	the aircraft,	aircraft	engine	or	propeller	as	the	FAA	finds	necessary	to	establish	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	1 4	C.F.R.	§	21.16,	the	FAA	may prescribe	special	conditions	for Verascan ’ s intended	operation	of	the DJI	Phantom	2 , which	contain	such	safety	standards	that	the	Administrator	finds	necessary	to establish	a	level	of	safety	equivalent	to	that	establishe d	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).

The	extent	to	which	we	seek	relief	from	the	listed	sections	is	described	in	the attached	“Verascan	Operat ions	Manual	for	a	DJI	Phantom	2.”

IMPORTANT	PROPRIETARY	INFORMATION!!!

At tach ed “ Operations	Manual ” is a PROPRIETARY	DOCUMENT that	support s Verascan ’ s petition.	Attachment is referenced	in	the	request	for	exemption	and
contain s trade	secret	and	commercial	pr oprietary	information	that	Verascan has	not and	will	not	share	with	others	except	under	appropriate	co nfidentiality	agreements. The	Verascan Operations	Manual attachment	contains	operating	conditions	and procedures	that	have	been	developed	exclusively	by Verascan ,	and	that	are	not available	to	the	public. Verascan is	requesting	that	these	attachme nts	be	treated	as proprietary	information	pursuant	to	14	C.F.R.	Section	11.35,	and	maintains	that	they are	protected	from	release	under	the	Freedom	of	Information	Act.	See	5	U.S.C.	552	et
seq.