U.S. Department of Transportation Federal Aviation Administration Docket Management System 1200 New Jersey Avenue, SE Washington, DC 20590 September 13th, 2015 Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Dear Madam or Sir, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”) and 14 C.F.R. Part 11, Jason Andrew Thomas, a sole-proprietorship d/b/a Gradient Designs, seeks exemption from the requirements of 14 C.F.R. §§ 61.23 (a) and (c), 61.101 (e) (4) and (5), 61.113 (a), 61.315 (a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407 (a)(1), 91.409(a)(1) and (2), 91.417(a) and (b) to the extent necessary to allow the petitioner to operate the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, DJI S800 and S800 EVO, DJI S900 and the DJI S1000 and S1000+ unmanned aircraft systems (“sUAS”) outlined in this document in the National Airspace System (NAS) below 400 feet AGL and at low speeds. Th e purposes of flight operations will be to conduct commercial and educational aerial photography and topographic data acquisition for purposes of photogrammetry, surveying, and aeria l mapping related to Ecological Design, Stream and Wetland Habitat Restoration, Fisheries Sciences, Flood Study, Dam Safety Inspections, Dam Breach Studies, Civil Design Projects, and educational scientifi c research. In the event the requested exemptions are granted, Jason Andrew Th omas will operate UAS at all times in strict accordance to the parameters outlined in this document. Th e petitioner will also strictly adhere to all Conditions and Limitations outlined by the FAA. All fl ight operations will be conducted in visual line of sight by a trained PIC with a minimum of a Sport Pilot Certifi cate and will hold a current FAA airman medical certifi cate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. A VO (Visual Observer) will be utilized at all times.
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e utilization of UAS will allow Jason Andrew Th omas to perform data acquisition in unpopulated or sparsely populated areas in a manner safer than fl ight operations utilizing traditional manned aircraft or that of traditional ground surveying and rigging for dam safety inspection procedures. Due to the small size, light weight, unmanned nature and lack of fl ammable fuel associated with UAS fl ight operations, Jason Andrew Th omas believes that UAS operations enabled by the requested exemptions outlined in this document will provide an enhanced level of safety. As well, the educational research and commercial UAS operations to be conducted by Jason Andrew Th omas will be in the public interest. Petitioner: Jason Andrew Th omas d/b/a Gradient Designs 700 Rock Creek Rd Apt. A Charlottesville, VA 22903 304-415-1062 jason@gradient-designs.com

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## INDEX
I. APPLICATIONS, BACKGROUND, AND PUBLIC INTEREST PAGE P3

II. UAS EQUIPMENT TO BE UTILIZED PAGE P5

III. BASIS FOR PETITION PAGE P6 NAME AND ADDRESS OF PETITIONER SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH JASON ANDREW THOMAS SEEKS EXEMPTION

IV. SAFE OPERATION AND EXPECTED COND ITIONS AND LIMITATIONS PAGE P10

V. CONCLUSION PAGE P13

P2I. APPLICATIONS, BACKGROUND, AND PUBLIC INTEREST I, Jason Andrew Th omas d/b/a Gradient Designs, currently provides professional design and data acquisition services for the purposes of photogrammetry, surveying, and mapping related to Ecological Design, Stream and Wetland Habitat Restoration, Fisheries Sciences, Flood Study, Dam Safety Inspections, Civil Design, as well as, educational and scientifi c research. Jason Andrew Th omas seeks exemption from the requirements of 14 C.F.R. §§ 61.23 (a) and (c), 61.101 (e) (4) and (5), 61.113 (a), 61.315 (a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407 (a)(1), 91.409(a) (1) and (2), 91.417(a) and (b) to the extent necessary to allow the petitioner to operate the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, DJI S800 and S800 EVO, DJI S900 and the DJI S1000 and S1000+ unmanned aircraft systems (“sUAS”) outlined in this document for the purposes of fl ight operations in the National Airspace System (NAS) to conduct commercial and educ ational aerial photography and data acquisition for the purposes of photogrammetry, surveying, and aeria l mapping related to Ecological Design, Stream and Wetland Habitat Restoration, Fisheries Sciences, Flood Study, Dam Safety Inspections, Civil Design, and educational scientifi c research.
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e UAS fl ight operations outlined in this document will predominantly occur in unpopulated and sparsely populated areas over riverine and wetland environments. Permission from land owner or representative will be obtained before each fl ight operation.
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e aerial data acquisition will be utilized and post processed in Pix4DMapper, Autodesk Civil 3D, Autodesk,Infraworks, Autodesk Computational Fluid Dynamics, and Hydronia RiverFlow2D for hydraulic and topographic analysis, as well as, fl ood, dam breach and dam safety studies.
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e predominant goal of the petitioner is scientifi c data collection for ecological design projects, habitat restoration, and hydraulic modeling of streams and wetlands. Th e usage of a UAS will be almost exclusively completed in unpopulated natural environments. Th e usage of a UAS for data collection will not only allow data about our natural environment to be collected that would otherwise be cost prohibitive or impossible but it will also prevent injury in the fi eld and will increase the level of safety for data collection. Riverine and wetland environments require data collection in remote and inherently dangerous areas to navigate by foot. Large wet and slick boulders, river crossings, grasses, snakes and hornets are just a few of the hazards that I regularly encounter. To obtain aerial imagery and data for topographic analysis, low and slow fl ying aircraft are necessary. Th e UAS will provide higher quality data while off ering a higher level of safety for the fi eld data collection crew. Th e use of UAS instead of manned aircraft will provide for more safety during aerial data collection. Flood mapping, dam breach studies, and dam safety studies will also be conducted utilizing the UAS if the requested exemptions are granted. It is of the utmost importance for public safety to understand the eff ects of fl oods and dam breaches and failures. Th e UAS will allow for a very high quality scientifi c hydraulic analysisthrough photogrammetric surveying applied towards Computational Fluid Dynamics, RiverFlow2D Hydraulic Modeling and HEC-RAS modeling for forecasting the detrimental eff ects of fl ooding and property loss due to catastrophic dam failures and natural fl ooding. Th e data collected by UAS fl ight operations will allow for a more informed public and is in the interest of the public

P3Flight Operations of the UAS will be utilized to study and predict fl oods to personal property, bank erosion, bank stabilization and prediction of loss of property and damages through photogrammetry, surveying, and site mapping. Th e data collected will be applied to hydraulic analysis and computational fluid dynamics modeling. Publicly available lidar data is insuffi cient for the level of analysis required to appropriately analyze and model macro and micro level eff ects of fl oods to private property. Th e utilization of UAS will result in a higher level of understanding and prediction of the eff ects of fl oods on property loss and damages and will be in the best interest of the public. Additionally, I am currently a student of the Environmental Sciences with a focus on Fisheries Sciences at Oregon State University E-Campus. If granted the exemption I plan on utilizing the DJI UAS outlined in this document for fl ight operations conducted for educational and scientific research. Utilization of UAS will further our knowledge of combining ground and aerial (U AS) Photogrammetric Surveying to conduct hydraulic analysis through Computational Fluid Dynamic Solutions. Th is research is in the best interest of the public. I, Jason Andrew Th omas, have several years of practical experience operating UAS systems as a hobbiest,including the DJI UAS outlined in this document. I have extensive personal experience performing functional test fl ights, pre-fl ight inspections, and adhering to manufacturer’s documentation and directives. All UAS fl ight operations by Jason Andrew Th omas will be in strict accordance to the parameters outlined in this document as well as Conditions and Limitations outlined by the FAA. All fl ight operations will be conducted by a trained Pilot in Command (PIC) with a minimum of a Sport Pilot Certifi cate and will hold a current FAA airman medical certifi cate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. A Visual Observer (VO) will be utilized at all times. Conducting safe operations within the National Airspace System (NAS) is the number one priority.

P4II. UAS EQUIPMENT TO BE UTILIZED
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e DJI UAS outlined in this document have demonstrated airworthiness and an exemplary safety record. Jason Andrew Th omas requests fl ight approvals for the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, DJI S800 and S800 EVO, DJI S900 and the DJI S1000 and S1000+ UAS. Th e requested aircraft are currently operating safely within the National Airspace System (NAS). DJI has obtained fl ight approvals for commercial projects for similar purposes of those outlined by Jason Andrew Th omas. All aircraft will be operated with a 2.4ghz - 2.48ghz or 5.725ghz-5.825ghz transmitter at low speeds and weight well under 5 lbs. Speeds will be maintained well below 87 knots (100 miles/hour). Areas of operation will be over unpopulated or sparsely populated areas. Manufactures operating manuals and safety bulletins are included in this petition and will be strictly adhered to. DJI Phantom 2 Vision and Vision + Takeoff Weight: ~1000g - 1242g Max Speed: 15 m/s - Will be operated at low speeds Flight Times: ~20 to 20 min. DJI Phantom 3 Standard, Professional and Advanced Takeoff Weight: 1216g - 1280g Max Speed: 16 m/s - Will be operated at low speeds Flight Times: ~25 min DJI Inspire 1 Takeoff Weight: ~2935g Max Speed: 22 m/s - Will be operated at low speeds Flight Times: ~18 min DJI S800 - Spreading Wings Takeoff Weight: 6.0kg - 8.0kg Max Speed: ~16 m/s Flight Times: ~18 min DJI S800 Evo - Spreading Wings Takeoff Weight: 4.7kg - 8.2kg Max Speed: ~16 m/s Flight Times: ~18 min DJI S900 - Spreading Wings Takeoff Weight: 4.7kg - 8.2kg Max Speed: ~16 m/s Flight Times: ~18 min DJI S1000 and S100+- Spreading Wings Takeoff Weight: 6.0 - 11.0 kg Max Speed: ~16 m/s Flight Times: ~15 min User Manuals and Specifi cations Provided. P5III. BASIS FOR PETITION Jason Andrew Th omas seeks exemption from C.F.R. §§ 61.23 (a) and (c), 61.101 (e) (4) and (5), 61.113 (a), 61.315 (a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407 (a)(1), 91.409(a)(1) and (2), 91.417(a) and (b) to the extent necessary to allow Jason Andrew Th omas to operate the UAS outlined in this document in the National Airspace System (NAS) to perform aerial data collection for commercial purposes as well as educational research as outlined in this document. In accordance with 14 C.F.R. 11.81, Jason Andrew Th omas provides the following information in support of its petition for exemption. A) NAME AND ADDRESS OF THE PETITIONER
Th e name and address and point of contact of the Petitioner is: Name: Jason Andrew Th omas d/b/a Gradient Designs Mailing Address: 700 Rock Creek Rd. Apt A, Charlottesville, VA 22903 Phone: (304) 415-1062 Email: jason@gradient-designs.com B) LIST OF SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH JASON ANDREW THOMAS SEEKS EXEMPTION TO THE EXTENTS NECESSARY FOR THE PETITIONER TO OPERATE A UAS TO CONDUCT COMMERCIAL AND EDUCA TIONAL AERIAL DATA ACQUISITION FOR ECOLOGICAL DESIGN, STREAM AND WETLAND HABITAT RESTORATION, CIVIL DESIGN, AND EDUCATIONAL SCIENTIFIC RESEARCH. 1. 14 C.F.R. § 61.23 (a) and (c) - MEDICAL CERTIFICATES: REQUIREMENT AND DURATION Sections 61.23(a) and (c) requires pilots of manned aircraft to hold a FAA medical certificate in order to exercise pilot privileges. However, the FAA has determined that operators holding a valid driver’s license in lieu of a third class medical certifi cate may conduct commercial UAS operations. Jason Andrew Th omas requests an exemption from these provisions to the extent necessary to give Jason Andrew Thomas the ability to operate the listed DJI UAS for commercial and educational research purposes. 2. 14 C.F.R. § 61.101 (e) (4) and (5) - RECREATIONAL PILOT PRIVILEGES AND LIMITATIONS Sections 61.101(e) (4) and (5) prohibit a recreational pilot from acting as pilot in commend of an aircraft for compensation or hire or in furtherance of a business. Jason Andrew Th omas will be operating the DJI UAS listed in this document for commercial compensations and educational research, hence, Jason Andrew Th

omas requests an exemption from these provisions to the extend necessary to conduct UAS operations in the National Airspace System (NAS) in a safe and appropriate manner as outlined in this document.

P63. C.F.R. § 14 61.113 (a): P RIVATE PILOT PRIVILEGES AND LIMIT ATIONS: PILOT IN COMMAND Exemption to Section 61.113 is requested by Jason Andrew Th omas to the extent necessary to allow a Pilot In Command (PIC) holding a Sport Pilot Certifi cate or higher with appropriate medical requirements and who has demonstrated a high level of competency at operating aircraft to safely operate the DJI Phantom 2,DJI Phantom 3, DJI Inspire 1, DJI S800, DJI S800 EVO, DJI S900, and DJI S1000 and S1000+ UAS in a manner consistent with the requested exemptions. Th e PIC will achieve a high level of competency conducting evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Section 61.113 (a) provides regulations for the limitation of private pilot privileges to non-commercial operations. Th is section requires an individual to hold a commercial pilot’s license when acting as pilot in command of an aircraft used for compensation or hire. Since UAS aircraft does not carry pilot, passengers, or fuel, a higher level of safety will be achieved than that of fl ight operations utilizing a non - UAS aircraft

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e area of operation is limited with fl ights not exceeding 400 feet in altitude and will be within visual line of sight. All fl ights are planned and coordinated in advance and will be monitored by both the PIC and VO. For these reasons, Jason Andrew Th omas believes that an equal or greater level of safety will be achieve with UAS fl ight operations, thus, the petitioner seeks exemption from C.F.R. 61.113 (a) 4. C.F.R. § 61.315 (a) - SPORT PILOT CERTIFICATE PRIVLEGES AND LIMITS Section 61.315 (a) authorizes a sport pilot certifi cate holder to act as pilot in command of a light-sport,subject to certain restrictions, these include a prohibition on doing so for compensation or hire or in furtherance of a business, among other restrictions. Jason Andrew Th omas will be conducing UAS fl ight operations for compensation for the reasons listed in this documents, hence, Jason Andrew Thomas requests an exemption from this provision to the extent necessary to operate UAS for commercial purposes outlined in this document. Due to the size and speed limitations of the UAS outlined in this document and the lack of crew, passengers, or fuel, Jason Andrew Th omas believes that an equal or higher level of safety than expected will be achieved with UAS fl ight operations. 5. C.F.R. § 91.7(a): CIVIL AIRCRAFT AIRWORTHINESS C.F.R. Section 91.7 requires that “no person may operate a civil aircraft unless it is in airworthy condition.” An equivalent level of safety will be achieved by ensuring compliance with the UAS standard operating procedures, fl ight operations manuals, and following established practices which utilize safety checklists, pre-fl ight checklists and regularly scheduled maintenance. Extensive record keeping of any repairs will be maintained. Th e Pilot in Command will review any and all repairs or maintenance that has been conducted prior to the commencement of any fl ight operations. If the PIC fi nds that the aircraft is not in an airworthy condition than fl ight operations will be suspended immediately until the aircraft can be put back in service in an airworthy condition.

P76. C.F.R. § 91.119(c): MINIMUM SAFE ALTITUDES Section 91.119(c) establishes safe altitudes for operation of civil aircraft . Th is section limits aircraft fl

ying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle or structure. Because UAS are specifi cally required to operate below 400 feet AGL Jason Andrew Th omas requests an exemption from Section 91.119(c). An equivalent or greater level of safety will be achieved due to the small size, weight, and low speeds of UAS. Use of UAS will contribute to lower level of hazards to persons, property, vessels, vehicles or structures. Autopilot features include a return home feature in case of loss of contact with UAS. Due to extremely low altitude fl ights and the nature of river canyons and riverine environments that fl ight operations need to be conducted, it is not feasible or safe for conventional aircraft to fl y within these parameters. Th erefore, UAS provide a lower level of risk than traditional manned aircraft conducting fl ight operations. Th erefore the petitioner is requesting exemption from Section 91.119(c)
7. C.F.R. § 91.121: AL TIMETER SETTINGS Section 91.121 requires a person operating an aircraft to maintain cruising altitude or fl ight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. Some UAS have a barometric pressure sensor, while others only use GPS for elevation or altitude. When a barometric pressure sensor is on the UAS, it is corrected to the point of take-off so the altitude reading will be relative to that launch point on the ground.
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e equivalent level of safety will be achieved by the PIC. As part of the pre-fl ight checklist, the PIC and will confi rm the elevation or altitude of the launch site. Using the altitude of the launch site shown on the GPS altitude indicator and then confi rming the UAS AGL altimeter is set to zero on the ground before each fl ight is initiated. Th e altitude of the UAS will also be displayed via telemetry and will be constantly monitored by the PIC during the entire fl ight operation. Furthermore, DJI systems allow a maximum ceiling to be set prior to each fl ight operation. Th e PIC will set the maximum fl ight elevation of 399 feet AGL when appropriate COAs have been obtained. Otherwise the PIC will set a maximum flight elevation of 199 feet AGL as set by the “blanket” 200-foot COA for an operator with a Section 333 exemption. Th e “blanket” 200-foot COA states that Section 333 exemption holders will automatically receive a “blanket” 200 foot COA. Th e 200 foot restriction will be monitored by UAS telemetry at all times.

P88. C.F.R. § 91.151(a)(1): FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS C.F.R. Section 91.151(a)(1) provides that no fl ight may begin in an airplane under day VFR conditions unless there is enough fuel to fl y to the fi rst point of intended landing and to fl y aft er that for at least 30 minutes. Given the area of operation for the DJI Phantom 2, DJI Phantom 3 Advanced and Professional, DJI Inspire 1, DJI S800, DJI S800 EVO, DJI, S900, DJI S1000 and DJI, S1000+, Jason Andrew Th omas, believes that an equivalent level of safety will be achieved with the specifi c procedure preventing the DJI UAS listed in this document to accept a take-offorder if the battery level is at a fully charged level. Moreover, the DJI UAS listed in this document have integrated critical battery level warnings and have a return to home feature that will be utilized in case of low battery. Due to appropriate safety measures being in place, Jason Andrew Th omas requests exemption from C.F.R. Section 91.151 (a) (1) 9. C.F.R. § 91.405(a), 91.407 (a)(1), 91.409(a)(1) and (2), 91.417(a) and (b) - MAINTENANCE INSPECTIONS Jason Andrew Th omas requests exemption from Sections 91.405(a), 91.407 (a)(1), 91.409(a)(1) and (2), 91.417(a) and (b) in the extent necessary to operate UAS outlined in this document for the purposes of commercial compensation and educational research outlined in this document. Jason Andrew Th omas will perform maintenance as outlined by the manufactures documentation. Th e Pilot in command will utilize maintenance records and a pre-fl ight checklist to insure that any maintenance since the last fl ight operation has been thoroughly reviewed before the commencement of fl ight operations. Jason Andrew Th omas will assure that all maintenance and inspections are conducted on a routine basis as outlined by the manufactures recommendations.

P9IV. Safe Operation and Expected Conditions and Limitations (by FAA)
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e petitioner will conduct all flight operations in the National Airspace System (NAS) in a safe and appropriate manner in strict accordance to the parameters outlined in this document as well as Conditions and Limitations placed upon Jason Andrew Th omas by the FAA. Operations will be conducted by a Pilot in Command (PIC) who holds either an airline transport, commercial, private, recreational, or sport pilot certifi cate along with a Visual Observer (VO) at all times. Jason Andrew Th omas believes fl ight operations above and beyond expected levels of safety will be achieved due to the areas of operations (unpopulated, sparsely populated), the small size and speed of the aircraft , and the safety measure in place for safe operations.
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e Pilot In Command and the Visual Observer will be required to have extensive training and be able to show a competency to perform their duty in a professional and safe manner. All fl ight operations by the Pilot In Command will begin with extensive prefl ight inspections as outlined by the manufactures recommendations. Th

e PIC will review any maintenance or repairs in detail that were complete since the last fl ight operation to ensure that the UAS is in a condition for safe fl ight. Before any fl ight operation, the PIC shall establish that a minimum of 3 statue miles of visibility exists for Visual Flight Rules (VFR). Th e craft shall maintain a distance of 500 feet below and 2,000 feet horizontally from any cloud. Th e PIC and Visual Observer shall maintain visual contact without the aid of any device other than corrective lenses at all times, except the PIC may utilize on screen display as long as the PIC maintains the ability of having visual contact and the VO maintains visual contact with the aircraft

. Before any fl ight operation the PIC shall establish fl ight boundaries and evaluate any potential hazards. Th e Pilot in Command will discuss the boundaries and potential hazards with anyone and everyone present before fl ight operations are conducted. No one will be permitted to enter the fl ight boundaries who has not been briefed and given consent for the fl ight operation to proceed prior to the fl ight operation. If for any reason the PIC feels as if any of the terms outlined in this document can not be met then the PIC will abort the fl ight operation immediately and resume when all terms outlined in this document can be met.
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e Pilot In Command shall not commence any fl ight operation within 5 nm of any airport without proper authorization. Jason Andrew Th omas shall obtain necessary Certifi cate of Waiver or Authorization (COA) from the FAA Air Traffi c Organization prior to conducting operations in the National Airspace System (NAS).
Expected Conditions and Limitations for UAS Operations 1. Operations will be limited to the approved DJI Family of UAS systems when weighing less than 55 lbs including payload. 2. Operations for the purposes of closed-set motion picture and television will not be permitted
3. Th e UAS will not be operated at speed exceeding 87 knots (100 miles per hour). Jason A. Th omas d/b/a Gradient Designs will utilize either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction.
4. Th e UAS must be operated at an altitude of no more than 400 feet above ground level (AGL). P105. Th e UAS must be operated within visual line of sight (VLOS) of the PIC at all times. Th is requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specifi ed on the PIC’s FAA-issued airman medical certifi cate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). Th e UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. Th e VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. Th e VO and PIC must be able to communicate Verbally at all times; electronic messaging or texting will not be permitted during fl ight operations. Th e PIC must be designated before the fl ight and cannot transfer his or her designation for the Duration of the fl ight. Th e PIC must ensure that the VO can perform the duties required of the VO.
7. Th e operating documents will be accessible during UAS operations and made available to the Administrator upon request. Jason Andrew Th omas must follow the procedures as outlined in the operating documents if approved. 8. Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or fl ight characteristics, e.g. replacement of a fl ight critical component, must undergo a functional test fl ight prior to conducting further operations under this exemption. Functional test fl ights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. Th e functional test fl ight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. Th e operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.
10. Prior to each fl ight , the PIC must conduct a pre-fl ight inspection and determine the UAS is in a Condition for safe fl ight. Th e pre-fl ight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that aff ects 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 fl ight.
11. Th e operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 13. If the exemptions are granted, A PIC must hold either an airline transport, commercial, private, Recreational, or sport pilot certifi cate. Th e PIC must also hold a current FAA airman medical certif- icate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. Th e PIC must also meet the fl ight review Requirements specifi ed in 14 C.F.R. 61.56 in an aircraft in which the PIC is rated on his or her pilot certifi cate. 14. Jason Andrew Th omas will not permit any PIC to operate unless the PIC demonstrates the ability to safety operate the UAS in a manner consistent with how the UAS will be operated under the exemption of approved. Th is includes evasive an emergency maneuvers and the ability to maintain appropriate distances from persons, vessels, vehicles and structures.

P1115. UAS operations may not be conducted during night, as defi ned in 14 CFR 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual fl ight rules (SVFR) are not authorized.
16. Th e UAS may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. Th e letter of agreement with the airport management must be made available to the Administrator or any law enforcement offi cial upon request.
17. Th e UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 18. If the UAS loses communications or loses its GPS signal, the UA mus return to a pre-determined location within the private or controlled-access property.
19. Th e PIC must abort the fl ight in the event of unpredicted obstacles or emergencies.
20. Th e PIC is prohibited from beginning a fl ight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate aft er that for at least fi ve minutes or with the reserve power recommended by the manufacturer if greater.
21. Air Traffi c Organization (ATO) Certifi cate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO-issued COA. Th e exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA.
22. All aircraft operated in accordance with this exemption must be identifi ed by serial number, registered in accordance with 14 CFR part 47, and have identifi cation (N-Number) markings in ac cordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 23. Documents used by the operator to ensure the safe operation and fl ight of the UAS and any documents required under 14 CFR 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. Th ese documents must be made available to the Administrator or any law enforcement offi cial upon request.
24. Th e UA must remain clear and give way to all manned aviation operations and activities at all times.
25. Th e UAS may not be operated by the PIC from any moving device or vehicle.

P1226. All Flight operation must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that suffi ciently protect nonparticipating persons from the UA and/or debris in the event of an accident. Th e operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, fl ight operations must cease immediately in a manner ensuring the safety of nonparticipating persons b. Th e owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. 27. All operations shall be conducted over private or controlled-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each fl ight to be conducted. 28. Any incident, accident, or fl ight operation that 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 Offi ce (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web Site: www.ntsb.gov. 29. Closed set motion picture and television fi lming will not be permitted if exemption is granted. 30. Unless otherwise specifi ed in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

V. CONCLUSION In the event the requested exemptions are granted, the utilization of UAS will allow Jason Andrew Th omasd/b/a/ Gradient Designs to perform data acquisition in unpopulated and sparsely populated areas in a manner consistent with this document. Th e safety measures outlined in this document will provide for UAS fl ight operations safer than fl ight operations utilizing traditional manned aircraft or that of traditional ground surveying and rigging for dam safety inspection procedures. Due to the small size, light weight, unmanned nature and lack of fl ammable fuel associated with UAS fl ight operations, Jason Andrew Th omas, believes that UAS operations enabled by the potential exemptions outlined in this document will provide an enhanced level of safety. As well, the scientifi c educational research and commercial UAS operations to be conducted by Jason Andrew Th omas will be in the public interest. Th e petitioner feels as if proper training, appropriate training procedures and the safety guidelines in this document will provide for very safe operations of UAS within the National Airspace System. Sincerely, Jason Andrew Th omas d/b/a Gradient Designs 700 Rock Creek Rd. Apt. A Charlottesville, VA 22903 304-415-1062 P13