### 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 gran ted your request for exemption. It transmits our decision, explains its basis, and gives you th e 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 petiti oner to operate an unmanned aircraft system (UAS) to conduct aerial photography and vi deography 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 pe titioner. 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 exemp tions 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 suspen sion or rescission of the exemption.

### 2

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, a nd limited operating area associated with the aircraft and its operation, the S ecretary of Transportation has de termined 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 materi al respects to those pres ented in your petition. In Grants of Exemption No s. 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 specifica tions described by the petition er and carrying no passengers or crew, rather than a manned aircraft of signi ficantly greater proporti ons, carrying crew in addition to flammable fuel, gi ves the FAA good cause to find th at the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for re questing an exemption, I find that—

 They are similar in all material respects to relief previously re quested 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 situ ation you present; and

 A grant of exemption is in the public interest.
Our Decision In consideration of the foregoing, I find that a gr ant 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) an d (2), and 91.417(a) and (b), to

### 3 the extent necessary to allow the petitioner to ope rate 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, In c. is hereafter referre d to as the operator. Failure to comply with any of the conditions an d 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 re quire a new petition or a peti tion 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 restricti on. 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 th e 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 PI C 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 pe rmitted during flight operations. The PIC must be designated before the flight and ca nnot transfer his or her designation for the duration of the flight. The PIC must en sure 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

### 4 Administrator upon request. If a discre pancy exists between the conditions and limitations in this exemption and the pro cedures outlined in the operating documents, the conditions and limitations herein ta ke precedence and must be followed. Otherwise, the operator must follow the pr ocedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and pr esent updated and revised documents to the Administrator or any la w enforcement official upon request. The operator must also present updated and revise d 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 wh ich the FAA granted this exemption, then the operator must petition for an amendmen t 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 aff ect the UAS operation or flight characteristics, e .g., replacement of a flight cr itical component, must undergo a functional test flight prio r to conducting further opera tions 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 functi onal 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 a nd 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. Th e 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 manu facturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.
12. Each UAS operated under this exempti on must comply with all manufacturer safety bulletins.
13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pi lot 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 PI C is rated on his or her pilot certificate.

### 5

14. The operator may not permit any PIC to ope rate unless the PIC demonstrates the ability to safely operate the UAS in a ma nner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehi cles 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 e xperience-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 dur ing dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants 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 me teorological conditions (VMC). Flights under special visual flight rule s (SVFR) are not authorized.
16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facil ity 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 pr ivate or controlled-access property.
19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies.
20. The PIC is prohibited from beginning a f light 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 Author ization (COA). All operations shall be conducted in accorda nce 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 unde r the terms of the attached COA.

### 6

22. All aircraft operated in accord ance 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 th e 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 wa y 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 pr otect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under su ch 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 struct ures 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 es sential persons are not considered nonparticipating persons under this exemption.
27. All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/contro ller 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 Sa fety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

### 7 If this exemption permits operations for th e 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 ove r the area of proposed filming. The 3-day notification may be waived w ith 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 res ponsible for the on-s cene operation of the UAS; d. Make, model, and serial or N

− Number of UAS to be used; e. Name and certificate number of UAS PI Cs involved in the aerial filming; f. A statement that the operator has obtain ed permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made av ailable to the inspector upon request; g. Signature of exemption holde r or representative; and h. A description of the flight activity, includi ng maps or diagrams of any area, city, town, county, and/or state over which film ing will be conducted and the altitudes essential to accomplish the operation.
31. Flight operations may be conducted closer th an 500 feet from pa rticipating 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 al l applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

### 8 This exemption terminates on May 31, 2017, unless sooner superseded or rescinded. Sincerely, /s/ John S. Duncan Director, Flight St andards 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)a nd (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 Regula tions (FARs) listed above so th at UAV Field Services may operate its small unmanned aircraft / lightweight unmanned aircraft system (UAS) commercially in airspace re gulated by the Federal Aviation Administration (FAA) ; as long as such operations are conducted within and under the conditions outlined her e in or as may be established by the FAA as required by Section 333. It is the request of the petitioner for exempti ons 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

. E nhance ment of Pu blic awareness of UAS operation and finally enhanced safety for both the G eneral 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 inspe ct cellular towers for the telecommunications comp anies 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 fli ghts will be under 200ft. AGL , and a ll 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 pu blic safety of utmost concern but also the safety of the climbing crews tasked with routine inspection of the towers. UAV Field Services and i ts 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 fal ls 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.
Th e secondary request for Exemption is to allow UAV Fi eld Services to utilize its UAS to inspect power transmission lines for the utility companies and their subcontractors. UAV Field Services has been given written conse nt 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 goo d safety record. The use of UAS would reduce the carbon foot print and noise po llution. 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 li nes under 4 00 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 Fi eld Services to utilize it s 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 Fi eld Services would perform would be restricted to severe, hard to access roof

- top claims. Operations would remain VLOS, under 2 00 ft AGL, utilize a PIC & VO. Utilizing UAS to do these claims inspections and assist insurance carriers settle claims in a tim ely & safe manner is of public interest. The operati ons 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 safe ty 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 f light parameters , conditions, guidelines and limitations to adhere to before, dur ing and after flight operations all of which are outlined in the UAS POH / Operators Manual . The se conditions are based off of P art 333 exemptions that have already been appro ved 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 P rotocol s & P rocedures & 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 flig ht 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

- cl a ss 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 allo wed within 2 00 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) p rior 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, regis tered 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 operat ions, 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 wr iting 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 de vice 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 a pproval 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 outlin e 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 airworthine ss 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 s afety 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 A irplane 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 aircraf t 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 4 00 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 pr oposed.
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 seale d batteries thereby reducing the chance of post impact fire to nearly zero.
There will be cas es 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 st orm damage.) In this type of operation ever y assurance will be made to keep persons outside of a reasonable, safe, clear area of operations and will only be conducted with the express permissi on of the property owner. See **Protocols and Procedures S ection** 

. 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 petitione r 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 a pproximately 25 minutes depending on camera usage and other variables. The petiti oner has established th at the maximum flight will be 15 minutes on a fully charged battery. This constitut es landing with approximately 25 percent fuel remaining. The petitioner believes that this follows the spirit and intent of the rule with a great ma rgin 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 r egistrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining such certifications and registratio ns at the UAV Field Services flight operations center.

**14 CFR 91.405(a)**
Maintenanc e required; The petitioner requests relief in part from **91.405(a)(1)** based on the **Protocols and Procedures S**  **ection** on **Maintenance and M aintenance R**  **ecords**

. **Also reference Exemption No. 11138**

**14 CFR 91.407(a)(1)**
O peration after maintenance, preventive mainten ance, rebuilding, or alteration; The petitioner requests relief from **91.407(a)(1)** based on the **Protocols and Procedures S ection**  on **Maintenance, R eturn to**  **service after maintenance, and M aintenance records**  **. Reference Exemption No. 11138** **14 CFR 9 1.409(a)(1)(2)** 

Inspections; The petitioner requests relief from **91.409(a) (1)**  **(2)** bas ed on the **Protocols and Procedures S**  **ection** 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 S ection**  on **M aintenance 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 F ield Services will mark its UA S in the largest possibl e 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 re gulation 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 be cause 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 ai rworthiness certificate requirement under both the Act (49 USC 44701(f)) and Section 333 of the Reform Act. Both pieces of the legislati on permit the FAA to exempt UAS from the airworthiness certificate requirement in consideration of the weight, size, spe ed, maneuverability and proximity to areas such as airports and dense populations. UAV Field Se rvices 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 oper ation of UAV Field Services UAS i s far less than the risk levels inherent in the commercial activities outlined in CFR 61. Thus, allowing UAV Fi eld 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 t he DJI instruction and U ser M anual. 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, m otors, rotors, landing gear, camera and gimbal mount. As a part of the preflight the Pilot in Command will assure th at weather conditions, area secur ity, 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 i s in flight. Additionally all nonessential persons shall be required to remain clear of the operations area by a minimum distance of 20 0 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: “U nman ned aircraft o perations underway. Please remain clear.” **(2).** In the event of a breach by nonessential persons into the operations area durin g the flight of UAS, the P IC shall immediately terminate f light 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 pa th and Maximum altitude to be reached. Additionally the area betwe en the UAS s current position and its Home location is also considered operational area as it will proceed direct to i ts home location in the event of loss of ground control. **All nonessential perso**  **ns will not be allowed within 20 0 feet of any part of the operational**  **area during flight operations.**

## C. **Limitations of Operations**
**(1)** The UAS shall be operated in Da y 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 h ave an altitude restriction of 4 00ft 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 m ust be accessible during UAS operations and made a vailable 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 b e 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 ope rating 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 Cert ificate, w ith most appropriate Class and C ategory and a t least a current Third C lass 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 PI C 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 min imum 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 ope ration 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 with out 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 1 00 feet to any structure without the express permission of the structure / building / property owner. **(29)** The U AS 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 inspec tion 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 d ate, 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, Aircraf t 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 hou r s, 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 discr epancy, 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 Med ical whenever conducting operations. Operator prefers that the Certific ate be in the most appropriate Class and C ategor y 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 U AV 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 shal l adhere to company operating standards or Federal Aviation Admin i stration 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 th e 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 ofa b reach 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 i ncident 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 op erated 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 perime ter 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 p etitioner has attached the hyperlinks for the operating an d 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 th at can be provided by UAS . It is clear that the Cong ress of the United States, the b usiness sector , and the c onsumer want to integrate UAS into the N AS 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 w ork environ ment , 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 exem ption 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 syste ms 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