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.	§§	

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),	to	operate	an	Unmanned	Aircraft	

System	pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	

2012	(FMRA).	This	exemption	will	permit	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	in	
one	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	cheaper,	more	effective	

solution	to	fill	the	current	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	Operations	

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	200	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	provide	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	200	feet	and	up	to	400	feet	if	the	local	FAA	office	

is	not	notified,	and	with	an	aircraft	that	has	not	met	our	training	standards	

and	required	test	flight	times.		
Reasons	Why	An	Exemption	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,	vessels,	vehicles	and	structures.	Considering	

Verascan’s	proposed	area	of	operations,	and	the	operating	limitations	set	forthabove;	the	parallel	nature	of	private	pilot	aeronautical	knowledge	requirements	to	

those	of	commercial	pilot	requirements	(See	Exemption	No.	11062);	and	the	

airmanship	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	operations.	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,	11080,	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	and	
Qualification	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	Section	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	DJI	Phantom	2	Maintenance	Manual),	and	that	the	

UAV	is	in	a	condition	for	safe	flight,	as	stated	in	the	conditions	and	limitations	

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	UAV	to	the	GCS	for	active	monitoring	

of	the	flight	path	and	altitude.	This	altitude	information,	combined	with	Verascan’s	

operation	of	the	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	altitude	initiation	point	is	automatically	established	by	the	UAV.	The	

FAA	has	previously	granted	relief	from	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	operate	the	battery	powered	DJI	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	for	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	the	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	

operating	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	previously	
granted	relief	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,	11065,	11066,	11067,	11080,	11109,	11110,	

11136,	11138).	30	

Reasons	Why	An	Exemption	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	maintenance	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	maintenance	on	the	

UAS	using	the	methods,	techniques,	and	practices	prescribed	in	the	manufacturer’s	

maintenance	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	manual,	Verascan	will	

maintain	the	equivalent	level	of	safety	established	by	Sections	91.405(a),	

91.409(a)(1),	and	91.409(a)(2).	The	DJI	Phantom	2	System	Operations	Manual	sets	

forth	airworthiness	requirements	for	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	adversely	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	the	
manufacturer’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	the	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,	11080,	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

requests	that	the	FAA	prescribe	special	conditions	for	the	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	established	by	14	C.F.R.	

Part	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	

conducting	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	prescribe	special	conditions	pursuant	to	14	C.F.R.	§	

21.16,	for	operation	of	the	DJI	Phantom	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	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	

aircraft,	aircraft	engine,	or	propeller	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	contain	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	14	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	established	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	Operations	Manual	for	a	DJI	Phantom	2.”

IMPORTANT	PROPRIETARY	INFORMATION!!!

Attached	“Operations	Manual” is a	PROPRIETARY	DOCUMENT	that	supports

Verascan’s	petition.	Attachment	is	referenced	in	the	request	for	exemption	and	

contains	trade	secret	and	commercial	proprietary	information	that	Verascan	has	not	

and	will	not	share	with	others	except	under	appropriate	confidentiality	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	attachments	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.