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 Th omas, 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 fl ight operations will be to conduct commercial and educational aerial photography and topographic data acquisition 

for purposes of photogrammetry, surveying, and aerial 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.

Th 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 CONDITIONS AND LIMITATIONS PAGE P10

V. CONCLUSION PAGE P13

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I. 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 educational aerial photography and data acquisition for 

the purposes of photogrammetry, surveying, and aerial mapping related to Ecological Design, Stream and 

Wetland Habitat Restoration, Fisheries Sciences, Flood Study, Dam Safety Inspections, Civil Design, and 

educational scientifi c research.

Th 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.

Th 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.

Th 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 analysis 

through 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

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Flight 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 fl uid 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 scientifi c research. Utilization of UAS will further our knowledge of combining ground and aerial (UAS) 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.

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II. UAS EQUIPMENT TO BE UTILIZED

Th 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. P5
III. 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 EDUCATIONAL 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 certifi cate 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 Th omas 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.

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3. C.F.R. § 14 61.113 (a): PRIVATE PILOT PRIVILEGES AND LIMITATIONS: 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 . 

Th 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 Th omas 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.

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6. 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: ALTIMETER 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.

Th 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 fl ight 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.

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8. 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-off order 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. 

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IV. Safe Operation and Expected Conditions and Limitations (by FAA)

Th e petitioner will conduct all fl ight 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.

Th 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.

Th 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). P10
5. 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.

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15. 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.

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26. 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 omas 

d/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

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