May 8, 2015 

 Exemption No. 11512 

 Regulatory Docket No. FAA–2015–0474 

Mr. Brian Grant 

Principal 

UAV Field Services, Inc. 

30 Milburn Circle 

Pasadena, MD 21122 

Dear Mr. Grant: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

By letter posted February 25, 2015, you petitioned the Federal Aviation Administration 

(FAA) on behalf of UAV Field Services, Inc. (hereinafter petitioner or operator) for an 

exemption. The exemption would allow the petitioner to operate an unmanned aircraft system 

(UAS) to conduct aerial photography and videography for the insurance, utility, and 

telecommunications industries. 

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. The FAA received one 

individual comment in opposition to the petition. In granting this exemption, the FAA has 

determined that the proposed operations can safely be conducted under the conditions and 

limitations of this exemption. As with exemptions issued to Aeryon Lab, Astraeus Aerial, 

Clayco, Inc., and VDOS Global, LLC, failure to comply with the document’s conditions and 

limitations is grounds for immediate suspension or rescission of the exemption. 
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Airworthiness Certification 

The UAS proposed by the petitioner is a DJI Phantom 2 Vision+. 

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary. 

The Basis for Our Decision 

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

Having reviewed your reasons for requesting an exemption, I find that— 

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213; 

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, UAV Field Services, Inc. is granted an exemption from 

14 CFR §§ 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), and 91.417(a) and (b), to 
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the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below. 

Conditions and Limitations 

In this grant of exemption, UAV Field Services, Inc. is hereafter referred to as the operator. 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision+ when weighing less than 55 pounds including payload. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 
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Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. 

11. The 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. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate 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. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA 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. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request. 

17. The 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 must return to a 

pre-determined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least 5 minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

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. 
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22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance 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 flight 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. 

These documents must be made available to the Administrator or any law enforcement 

official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The 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, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and 

b. The 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. 

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption. 

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 flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (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. 
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply. 

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption. 

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption; 

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N−Number of UAS to be used; 

e. Name and certificate number of UAS PICs involved in the aerial filming; 

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM. 

Unless otherwise specified 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. 

 
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This exemption terminates on May 31, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 
U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE 

Washington, D.C. 20590

February 12, 2015

UAV Field Services, Inc.

Brian Grant / Principal

30 Milburn Circle

Pasadena, MD 21122

410-916-0109

Email briang@uavfsi.com

RE: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 

14 CFR 91.7(a); 91.9(B)(2); 91.103; 91.109; 91.119 (c); 91.121; 91.151(a)(1); 91.203(a)(b); 91.405(a); 

91.407(a)(1); 91.409(a)(1)and (2); 91.417(a)&(b); 45.23(b); Part 21; 61.113(a)(b)

Dear Sir or Madam:

We are writing pursuant to the FAA Modernization and Reform Act of 2012 ( Reform Act), and 

the procedures contained in 14 C.F.R. 11, to request that UAV Field Services, Inc, an owner and operator 

of small unmanned aircraft, be exempted from the Federal Aviation Regulations (FARs) listed above so 

that UAV Field Services may operate its small unmanned aircraft / lightweight unmanned aircraft system 

(UAS) commercially in airspace regulated by the Federal Aviation Administration (FAA); as long as such 

operations are conducted within and under the conditions outlined herein or as may be established by 

the FAA as required by Section 333. 

It is the request of the petitioner for exemptions listed above in order to legally and safely 

operate the DJI Phantom 2 Vision Plus UAS, in the National Airspace System, for the purpose of 

Unmanned Aerial Photography and Videography for the insurance, utility and telecommunications

industries. Enhancement of Public awareness of UAS operation and finally enhanced safety for both the 

General Public, Flight Crews and the Labor Force described herein. 
The main purpose for the requested Exemption is to allow UAV Field Services to utilize its UASs 

to inspect cellular towers for the telecommunications companies and their subcontractors. UAV Field 

Services has been given written consent to access these Secure / Sterile sites by the property / tower 

owners. The site access allows UAV Field Services to perform all inspections at low altitude and always 

within VLOS. Most all tower inspection flights will be under 200ft. AGL , and all flight operations will 

remain below 400 ft AGL. UAV Field Services will cordon off the site to add a buffer to keep the public / 

non-participants safe. This will be done by using cones and signs advising of the possible hazard. Not 

only is public safety of utmost concern but also the safety of the climbing crews tasked with routine 

inspection of the towers. UAV Field Services and its UAS would alleviate the day to day height exposure 

of inspection services and allow them to concentrate on service and repairs. Climbers have one of the 

highest incidents of death in the labor force. UAS operations would greatly reduce the number of falls 

and deaths associated with this type of operation. UAS used to inspect cell towers allows the cell 

carriers to enhance operability to its clients ; reducing down time and increasing signal strength by 

proactively inspecting towers and making repairs before failures or damages occur.

The secondary request for Exemption is to allow UAV Field Services to utilize its UAS to inspect 

power transmission lines for the utility companies and their subcontractors. UAV Field Services has been 

given written consent to access these Secure / Sterile sites by the property owners. This would reduce

the need for low flying manned helicopters. These manned flight systems have a relatively good safety 

record. The use of UAS would reduce the carbon foot print and noise pollution. Limiting and/or

reducing these manned operations would also reduce exposure to the public and power grid 

infrastructure in general. The operations that UAV Field Services would perform would be localized and 

remain VLOS on larger transmission lines under 400 ft AGL. These larger transmission lines are located in 

restricted areas which would limit concern for non-participant exposure. UAV Field Services will cordon 

off the site to add a buffer to keep the public / non-participants safe. This will be done by using cones 

and signs advising of the possible hazard. Keeping the energy grid fully operational and maintained with 

the aid of UAS is definitely in public interest.

The third request for Exemption is to allow UAV Field Services to utilize its UAS to assist

insurance companies with claim assessments. Currently insurance companies use their employees to 

climb roof tops to assess damage with ladders ( ladders themselves pose a property damage exposure to 

gutters, windows & siding). This involves climbing on high roof tops often with step pitches. This is an 

area of major concern for insurance companies as this exposure has lead to many sever falls to their 

employees. UAV Field Services will be given written consent to access these claim sites by the property 

owners and the insurance carriers. UAV Field Services will cordon off the site to add a buffer to keep the 

public / non-participants safe. This will be done by using cones and signs advising of the possible hazard. 

The operations that UAV Field Services would perform would be restricted to severe, hard to access 

roof-top claims. Operations would remain VLOS, under 200 ft AGL, utilize a PIC & VO. Utilizing UAS to do 

these claims inspections and assist insurance carriers settle claims in a timely & safe manner is of public 

interest.

The operations listed above require flight within 100 ft of buildings and structures. UAV Field 

Services has instituted several safety measures to limit and avoid collision or damage to such buildings 

or structures and / or minimize risks and exposures:

- Written permission from property / building owners outlining operations and describing 

potential hazards.

- General Liability insurance to cover any damages.
- All flight operations follow operation manual, guidelines and procedures listed herein.

- UAS utilizes propeller guards to reduce / eliminate flight failure in the event of collision

UAV Field Services exemption request would permit its operation of lightweight ( less than 55 

lbs.), UAS in tightly controlled and limited airspace. Predetermined, specifically marked areas of 

operation, cordoned off locations and corresponding enhancements to operate within current safety 

parameters and new ones to be implemented by the FAA Exemption relief.

Safety is paramount for UAV Field Services. We wish to help integrate UAS into the NAS by 

performing our services with the utmost concern for the safety of our operators, the general public and 

property. To achieve this UAV Field Services has instituted several flight parameters, conditions,

guidelines and limitations to adhere to before, during and after flight operations all of which are 

outlined in the UAS POH / Operators Manual. These conditions are based off of Part 333 exemptions 

that have already been approved by the FAA and have been integrated into our operations: 

- The UAS will not exceed a ground speed of 50 knots. 

-All operations will remain below 400 ft AGL. 

-The UAS will weigh less than 55 lbs. 

-All operations will remain in visual line of sight (VLOS). 

- All operations will utilize a visual observer (VO). This VO will always be able to communicate verbally 

with the pilot in command (PIC).

- The operator must follow the procedures as outlined in its operator's manual. ( listed herein as 

Protocols & Procedures & DJI User's Manual / Operators Manual).

- Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight.

- Any UAS that has undergone maintenance or alterations that would affect the UAS operation or flight 

characteristics must undergo a functional test flight in accordance with operators manual.

- The operator must follow the manufacturer's UAS aircraft / component, maintenance, overhaul, 

replacement, inspection and life limit requirements.

- The PIC will must possess at least a private pilot certificate and at least a third-class medical certificate. 

And also meet flight review requirements specified in the 14 CFR 61.56.

- Prior to operations PIC will undergo UAS specific training for type (multi-rotor) make and model aircraft

and log hours appropriately. PIC will also maintain proficiency and currency (every 90 days) with UAS. 

Keeping with a manner consistent with 14 CFR 61.51(b).

- PIC & VO will have successfully completed a qualification process, as outlined in the operators manual. 

Completion of this qualification process will be documented. 
- The UAS will not be operated directly over any person, except authorized and consenting flight 

personnel. 

- The PIC & VO will ensure that no persons are allowed within 200 ft of the flight area except those 

consenting flight personnel .

- If UAS loses communication or losses it GPS signal, the UAS must return to a pre-determined location 

within the security perimeter and land or be recovered in accordance with operator's manual.

- The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with 

operators manual.

- The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations. The COA will also require the operator to 

request a Notice to Airmen (NOTAM) not more than 72 hours in advance, but no less that 48 hours prior 

to the operation.

- All aircraft will be identified by a serial number, registered in accordance with 14 CFR part 47, and have 

identification ( N- Number) markings in accordance with CFR part 45(c). Markings will be as large as 

possible.

- All operators will comply with all manufacturers Safety Bulletins.

- Before conducting operations, the radio frequency spectrum used for operation and control of UAS will 

comply with Federal Communications Commission (FCC).

- Prior to the planned operation (3 days) the operator will contact the local FSDO (that has jurisdiction of 

the area ) in writing and cover the plan of activities for the flight operation.

- The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the ground 

station during all operations.

- The UAS will remain clear and yield the right of way to all other manned operations and activities at all 

times.

- All operations will be conducted under visual meteorological conditions (VMC) and no night 

operations during night as defined in 14CFR 1.1.

- The UAS will not be operated by the PIC from any moving device or vehicle.

- The UAS will not be operated less than 500 ft below or less than 2,000 feet horizontally from a cloud or 

when visibility is less than 3 statute miles from the PIC.

- The UAS will not operate in Class B, C, or D airspace without written approval from the FAA. The UAS 

will not operate within 5 nautical miles of the geographic center of a non-towered airport.

- Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office 

(AFS-80) within 24 hours.

- Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB website.
The petitioner will outline in this document:

1. Request for exemptions by Part and Subpart

2. Petitioners protocols and procedures for operations

3. The Unmanned Aircraft System (UAS)

4. The Public Interest

1. REQUESTS FOR EXEMPTION BY PART AND 

SUBPART

14 CFR 91.7(A)

Airworthiness Certificate;

Prohibits the operation of an aircraft without an airworthiness certificate. Petitioner requests 

exemption based on previous Exemption No. 11138. The FAA has ruled that this make and model of

aircraft (UAS) does not require an airworthiness certificate.

14 CFR 91.9 (B) (2)

Aircraft Flight Manual in the aircraft;

Requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given 

the size of the UAS, this regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining a manual at the flight operations center. The FAA has previously issued exemptions to 

this regulation in Exemption No. 10700 and 32827

14 CFR 91.103

Pre-Flight;

No approved Airplane Flight Manual on board the aircraft. The petitioner asserts that an 

equivalent level of safety will be achieved by the PIC taking all preflight actions set forth in the 

operating documents, including reviewing weather, flight battery requirements, landing and take-off 

distances, and aircraft performance data before initiation of flight.
14 CFR 91.109

Flight Instruction;

No dual controls available for flight instruction.

14 CFR 91.119(C)

Minimum Safe Altitudes;

States that no person may operate an aircraft below the following altitudes: over other than 

congested areas, 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.

The petitioner will never operate any UAS over an altitude of 400 AGL. The majority of the 

operations proposed will operate around 100 to 150 feet AGL as this usually provides the best angle 

of capture for the type of photography and videography operations proposed.

The UAS utilized for this exemption is of exceptionally light weight and is not capable of speeds 

over 30 knots. The UAS is equipped with GPS guided auto pilot with a return home function in case 

loss of control by the PIC and is powered by sealed batteries thereby reducing the chance of post 

impact fire to nearly zero. 

There will be cases when the 500 foot distance from structures will need to be exempted. 

(Example: Aerial Video of a 2 story home roof to determine and/or document extent of storm 

damage.) In this type of operation every assurance will be made to keep persons outside of a 

reasonable, safe, clear area of operations and will only be conducted with the express permission of 

the property owner. See Protocols and Procedures Section. 

The petitioner will implement procedures and policies to ensure that any person in the general 

vicinity of operations will be aware of such operations and ensure that all non-essential personnel 

are cleared of the area of operations. See Protocols and procedures Section 3.

The petitioner therefore requests relief in part from 14 CFR 91.119(C)

14 CFR 91.121

Altimeter Settings;

The petitioner requests relief from 91.121 for the following reason. The UAS is equipped with 

GPS derived altitude capability, however due to the limited altitude requested in this exemption, the 

FAA has previously granted Exemption for these types of operations. Reference Exemption No. 

11138
14 CFR 91.151(a)

Fuel for Flight;

No person may begin a flight in an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) unless there is enough fuel to fly to the first point of intended landing 

and, assuming normal cruise speeds

(a)(1)During the day to fly for at least 30 minutes. 

The petitioner requests relief from 91.151(a) due to the fact that the UAS is equipped with a 

battery and percentage indicator system. The UAS has a flight capability on full charge of 

approximately 25 minutes depending on camera usage and other variables. The petitioner has 

established that the maximum flight will be 15 minutes on a fully charged battery. This constitutes 

landing with approximately 25 percent fuel remaining. The petitioner believes that this follows the 

spirit and intent of the rule with a great margin of safety. 

No UAS operations will be conducted at night, as defined by Federal Aviation Regulations.

14 CFR 91.203(a)(b)

Carrying of civil aircraft Certifications and Registrations;

Provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for 

the same reasons described above. The equivalent level of safety will be achieved by maintaining 

such certifications and registrations at the UAV Field Services flight operations center.

14 CFR 91.405(a)

Maintenance required; 

The petitioner requests relief in part from 91.405(a)(1) based on the Protocols and Procedures 

Section on Maintenance and Maintenance Records. Also reference Exemption No. 11138

14 CFR 91.407(a)(1)

Operation after maintenance, preventive maintenance, rebuilding, or alteration;

The petitioner requests relief from 91.407(a)(1) based on the Protocols and Procedures Section

on Maintenance, Return to service after maintenance, and Maintenance records. Reference 

Exemption No. 11138
14 CFR 91.409(a)(1)(2)

Inspections;

The petitioner requests relief from 91.409(a)(1)(2) based on the Protocols and Procedures 

Section on Inspections. Reference Exemption No. 11138

14 CFR 91.417(a)(b)

Maintenance records;

The petitioner requests relief from 91.417(a)(b) based on the Protocols and Procedures Section

on Maintenance records.

14 CFR 45.23(b)

Marking of the Aircraft;

Applicable codes of Federal Regulation require aircraft to be marked according to certain 

specifications. UAV Field Services UASs are, by definition, unmanned. They therefore do not have a 

cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two inch lettering 

is difficult to place on such small aircraft. Regardless, UAV Field Services will mark its UAS in the 

largest possible lettering by placing the " N "number on its fuselage as required by 14 CFR 45.29 (f) 

so that the pilot, technician, spotter and others working with the UAV will see the markings. The FAA 

has previously issued exemptions to this regulation through Exemption No 10167 and 10700

14 CFR 21, Sub Part H

Airworthiness Certificates;

Entitled Airworthiness Certificates, set forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR 91.203(a)(1). The size, weight and enclosed operational

area of UAV Field Services UAS permits exemption from Part 21 because UAV Field Services UAS

meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized 

to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 

44701(f)) and Section 333 of the Reform Act. Both pieces of the legislation permit the FAA to 

exempt UAS from the airworthiness certificate requirement in consideration of the weight, size, 

speed, maneuverability and proximity to areas such as airports and dense populations. UAV Field 

Services UAS meet or exceed each of the elements. 
14 CFR 61.113(a)(b)

Private Pilot Privileges and Limitations / PIC;

Private pilots are limited to non-commercial operations. UAV Field Services can achieve an 

equivalent level of safety as achieved by current Regulations because UAV Field Services UASs do 

not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote

control piloting skills, though UAV Field Services pilot vetting and training program will. Further, 

private pilot licensees will operate UAV Field Services UASs with the same skill. Further, the risk 

attendant to the operation of UAV Field Services UAS is far less than the risk levels inherent in the 

commercial activities outlined in CFR 61. Thus, allowing UAV Field Services to operate its UAS with a 

private pilot as the pilot in control will exceed current safety levels in relation to CFR 61.113(a)(b).
2. Protocols and Procedures for UAS operations.

A. Preflight

B. Area Security

C. Limitations of Operations

D. Airworthiness

E. Maintenance and Records

F. Pilot in Command Requirements

G. Visual Observer and Requirements

H. Reporting of Incidents and Accidents

A. Preflight Inspection of UAS

(1). Preflight of the Unmanned Aerial System will follow the instructions in the DJI instruction 

and User Manual. The Pilot in Command will certify that a preflight inspection has been 

accomplished with the date and time and signature in the UAS logbook. The preflight shall 

include the aircraft, transmitter, and batteries, motors, rotors, landing gear, camera and gimbal 

mount. As a part of the preflight the Pilot in Command will assure that weather conditions, area 

security, and any other information essential to safe operation has been obtained.

B. Area Security

(1). The PIC of the UAS will ensure that the operational area for the purposes of UAS flight 

shall be cleared of all nonessential persons at all times the UAS is in flight. Additionally all 

nonessential persons shall be required to remain clear of the operations area by a minimum 

distance of 200 feet during operations. PIC shall ensure that cones and clearly marked signs 

are posted at all ingress\egress points to the operations areas. These signs will be of white 

background with red lettering stating the following: “Unmanned aircraft operations 

underway. Please remain clear.”

(2). In the event of a breach by nonessential persons into the operations area during the

flight of UAS, the PIC shall immediately terminate flight operations until such time as the 

area can be cleared of these persons.

(3). The UAS area of operation is defined as the Horizontal flight path(s) of the UAS as well 

as the Vertical flight path and Maximum altitude to be reached. Additionally the area 

between the UASs current position and its Home location is also considered operational 

area as it will proceed direct to its home location in the event of loss of ground control. 

All nonessential persons will not be allowed within 200 feet of any part of the operational 

area during flight operations.
C. Limitations of Operations

(1) The UAS shall be operated in Day time only, as defined by 14 CFR

(2) UAS night operations are prohibited.

(3) The UAS shall be operated by VLOS at all times

(4) A Visual Observer shall be utilized at all times and must maintain VLOS at all times.

(5) The UAS shall remain within 1000ft horizontal distance of the PIC at all times.

(6) The UAS to be utilized is the DJI Phantom 2 Vision + Unmanned Aircraft System. No 

other systems will be operated.

(7) The UAS will have an altitude restriction of 400ft AGL.

(8) The UAS will not be operated at a speed exceeding 30 Knots.

(9) Operations Documents will be accessible to the PIC at all times and must be accessible 

during UAS operations and made available to the Administrator on request.

(10) PIC must inspect and ensure that UAS and ground control station is in airworthy 

condition prior to each operation; if determined un-airworthy, all operations will be 

suspended until such time as necessary maintenance has been performed and the UAS 

is determined to be in a safe condition for flight.

(11) An operational flight test is required after any maintenance or alterations that may 

affect UAS operation or flight.

(12)UAS maintenance must follow Manufactures aircraft/component, maintenance, 

overhaul, and replacement, inspection, and life limit requirements.

(13) The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance and 

inspection, and alterations must be noted in the aircraft records, including total flight 

hours, description of work performed, and the signature of the authorized person 

returning the UAS to service.

(14)UAS must comply with all Manufacturers’ Safety Bulletins.

(15) An authorized person must make an entry in the aircraft record of the corrective action 

taken against discrepancies discovered between inspections.

(16)UAS must by operated by a PIC possessing at least a Private Pilot Certificate, with most 

appropriate Class and Category and at least a current Third Class Medical.

(17) PIC must meet the flight review requirements of 14 CFR 61.56 in an aircraft in which 

the PIC is rated.

(18) Prior to operations for which exemption is requested the PIC must have accumulated 

and logged , in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours of UAS multi-rotor. 

(19) Prior to operations PIC must have accumulated and logged a minimum of 5 hours as a 

UAS pilot in make and model listed in exemption. PIC must log at a minimum 3 

takeoffs and landings in the preceding 90 days to meet currency requirements.

(20) PIC is required to operate the UAS in accordance with 14 CFR 91.119.

(21)No UAS operation within 5 nautical miles of an airport reference point as denoted on a 

current FAA chart.

(22)No operations are allowed in the surface areas of Class B, C, and D airspace or in 

restricted airspace.

(23)No operations are allowed if the return home function and\or autopilot are, or are 

suspected to be malfunctioning.
(24)UAS shall not be operated from a moving platform of any type.

(25)No operations shall be conducted without an appropriate Certificate of Authority 

issued by the Administrator.

(26) A Visual Observer shall be utilized at all times when operating the UAS.

(27) Should the PIC or Visual Observer detect that a manned aircraft is being operated in 

close proximity to the operations area, the UAS shall give right of way to the manned 

aircraft, and the PIC shall cease operations and land until such time as the manned 

aircraft has cleared the area.

(28) The UAS will not be operated any closer than 100 feet to any structure without the 

express permission of the structure / building / property owner.

(29) The UAS will be limited to 15 minutes of flight or 25% of battery power, whichever 

occurs first.

D. UAS Airworthiness

(1) The PIC shall ensure that the UAS is in an airworthy condition before each flight. 

Airworthiness shall be determined by a preflight inspection in accordance with DJI operating 

documents and any and all applicable Federal Aviation Regulations, and any additional 

requirements as defined by the Administrator. PIC shall document each preflight inspection by 

date, Aircraft total Flight time to date, any discrepancies noted, and signature and certificate 

number. Any discrepancy noted shall be addressed before UAS operation. 

E. UAS Maintenance and Records

(1). The operator shall maintain aircraft maintenance logbooks. Each UAS shall have its own 

and separate maintenance log book. DJI documents, handbooks, user manuals, 

supplements, Safety Bulletins, etc., shall be the only approved documents for performing 

repairs, maintenance, inspections, overhauls, or replacement of life limited components. A 

record of each preflight inspection will additionally be recorded in these logbooks. The 

preflight inspection must be conducted by the PIC for that operation. Preflight signoff shall 

include at least the following information: date of operation, Aircraft Total time, aircraft 

serial or operating number, PIC signature and certificate number.

Example: Preflight inspection completed, No defects noted. 1-1-15, ACFTT 50.1 hours, 

UAS number 1, Brian Grant - PIC

(2). Any required maintenance, inspection, alteration or repair must be completed by an 

approved person. At the completion of this work the approved person must make an entry 

in the aircraft log book that at least includes: Date, Aircraft serial or operating number, brief 

description of the discrepancy, inspection, alteration or repair, the reference material used 

as guidance for the repair, statement approving the aircraft for return to service, and 

signature of person who completed the work.
Example: 1-1-15 UAS 1, ACFTT 50.1 hours, replaced number 3 rotor with new rotor, IAW 

DJI Phantom 2 Vision + User Manual. Flight or ops check completed. Aircraft is approved for 

return to service. Brian Grant

(3). Maintenance records shall be kept with the UAS at all times and shall be made available 

to any authorized agency or the Administrator upon request.

F. Pilot in Command Requirements

(1). The Pilot in Command shall hold at least a Private Pilot Certificate and a current 

Third Class Medical whenever conducting operations. Operator prefers that the Certificate 

be in the most appropriate Class and Category to the UAS being operated. 

(2). The Pilot in Command shall have accumulated and logged a minimum of 200 flight cycles 

and 25 hours of rotorcraft UAV flight time before performing any operation for which 

exemption is requested.

(3). The Pilot in Command shall have at least 5 hours in make and model before performing 

any operation for which exemption has been requested.

(4).The Pilot in Command shall perform a pre-flight inspection before each flight is 

conducted.

(5).The Pilot in Command shall observe all Federal Aviation Regulations at all times with the 

exceptions of the exemptions requested by the operator. In those cases the Pilot in 

Command shall adhere to company operating standards or Federal Aviation Administration 

Limitations placed upon exemptions, whichever is more stringent..

(6). The Pilot in Command will not operate the UAS without a Visual Observer present.

(7). The Pilot in Command must have 3 takeoff and landings within the preceding 90 days.

(8). The Pilot in Command must maintain a record of flight information to establish currency 

and that he or she meets the requirements of this section.

(9). The Pilot in Command will utilize eye protection in the event that sun glare would 

reduce VLOS operations.

G. Visual Observers: Responsibilities and Requirements

(1). A Visual Observer shall be used during any and all operations of the UAS System.

(2). The Visual Observer shall maintain verbal communication with the PIC at all times 

during UAS operation. 

(3). The Visual Observer shall maintain Visual Contact with the UAS at all times. In the 

event that Visual Contact is lost the VO will notify the PIC who will immediately cease 

operations and land the aircraft.

(4). The Visual Observer shall also help the PIC maintain area of operations security and 

ensure that all nonessential persons remain clear of the area of operations. In the event of 
a breach by unauthorized person(s) the VO shall notify the PIC and operations will cease 

immediately.

(5). The Visual Observer shall also assist the PIC in looking for manned aircraft traffic near 

the operations area. If manned aircraft traffic is observed near the operations area, the VO 

will notify the PIC who will immediately cease operations and land the UAS.

(6). The VO will utilize eye protection in the event that sun glare would reduce VLOS 

operations.

H. Reporting of Incidents and/or Accidents

Any incident or accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be reported

within 24 hours to:

FAA UAS Integration Office (AFS-80) 

Accidents: National Transportation Safety Board

 www.ntsb.gov.

 
3. The Unmanned Aircraft System UAS

The petitioner will operate the DJI Phantom 2 Vision + UAS System. This shall be the only system 

operated by the petitioner. This is an ultra-light weight system using a quad-rotor system for flight. 

The manufacturer has built in several features to make operations safer: in the event of lost signal 

the UAS will return to its pre-determined location within the security perimeter and land; PIC has 

ability to take over / abort flight manually in the event of loss to GPS; and the UAS has built-in 

software that limits operations near airports and restricted airspace. The petitioner has attached

the hyperlinks for the operating and user documents for the system as additional supplements for 

this petition. No modification to the factory system is to be utilized other than the dorsal surface 

area of the aircraft will be painted a bright safety orange to help manned aircraft see the unit while 

in flight. Please see attached supplemental documents.

DJI Phantom 2 Vision Plus Quick Start Guide

DJI Phantom 2 Vision Plus User's Manual

DJI Phantom 2 Vision Plus Smart Flight Battery Safety 

Guidelines 
 4. The Public Interest

The request for this exemption is in the Public Interest as it is safe to assume that there are 

many consumer applications for the services that can be provided by UAS. It is clear that the Congress 

of the United States, the business sector, and the consumer want to integrate UAS into the NAS and 

utilize their unique and cost effective capabilities. It is also in the Public Interest that many of the low 

level flight operations now conducted by manned aircraft could be accomplished with these light, fire 

resistant and environmentally friendly unmanned aircraft that can operate at a fraction of the cost to 

both the operator and consumer. These aircraft can be operated without risk of loss of life or limb, and

without significant financial impact to the operator or any person or property on the ground in the event 

of the loss of an aircraft. Utilizing these UAS will create a safer more productive work environment, 

reduce environmental pollution and have a positive impact on the local community which is in the Public 

Interest. Finally the petitioner believes that granting this exemption would help to further by 

Administrators process of integration of UAS systems and possibility help to create additional 

regulations and guidance to be used as these systems become more widely utilized.
Abbreviations

VLOS VISUAL LINE OF SIGHT

PIC PILOT IN COMMAND

VO VISUAL OBSERVER

UAS UNMANNED AIRCRAFT SYSTEM

NAS National Airspace System 

Please forward any questions or concerns to the address or email below.

Sincerely,

Brian Grant / Principal

UAV Field Services, Inc.

30 Milburn Circle

Pasadena, MD 21122

410-916-0109

Email: briang@uavfsi.com