May 8 ,	2015

US.	Department	o	f	Transportation,	Docket	Operations

West	Building	Ground	Floor,	Room	w12

- 140 1200	New	Jersey	Avenue,	SE	Washington,	DC	20590

Subj: Petition	 for	Exemption	to	Operate	the	DJI	Phantom	2 Vision	Plus Quad

- Copter	Unmanned Aerial	System	for	Co mmercial	Aerial Sensing	and	Data	Collection Purposes

Dear	Sir	or	Madam:

The	 purpose	 of	 this	 letter	 is	 to	 petition	 the	 Federal	 Aviation	 Administration	 for	 an	exemption from	 certain	 Federal	 Aviation	 Regulations	 in	 order	 for	 the	 petitioner,	 Drew	 F.	 Van	 Duren,	 to operate	 an Unmanned	 Aerial	 System	 (UAS)	 within	 California	 central	 coast	 region	 (San	 Luis Obispo,	Santa	Barbara	and	Monterey	Counties)	of	the	National	Airspace	System,	in	furtherance of	 his activities as	 a building (real	 estate	 and	 engineering) photogr apher	 and	 aeron autical engineer .	 Mr.	 Van	 Duren	 is	 well	 acquainted	 with	 the	 risks	 that	 come	 with	 the	 privilege	 of operating	 an	 aircraft	 in	 the	 United	 States,	 but	 also	 with	 the	 opportunities	 available	 via	 new unmanned	 flight	 technology.	 He	 holds	 a	 Private	 Pilot	 Certificate and	 has	 logged	 180	 hours	 of flight	time	in	single

- engine,	land

- rated	aircraft.	He	also	has	more	than	50	hours	of	logged	flight time	 of	 that	 particular	 unmanned	 aircraft	 that	 is	 the	 subject	 of	 this	 Petition.	 	He	 also	 holds	 a degree	in	Aeronautical	Enginee ring ,	has	extensive	knowledge	of	UAS	operations and	has	directly supported	 the	 FAA	 UAS	 Integration	 Office in	 the	 development	 of	 robust	 communications security	requirements	for UAS operations	in	the N ational	Airspace	System.		As	an	aerial	sensing expert,	 ph otographer and	 engineer,	 the	 petitioner	 would	 like	 to	 combine	 the	 benefits	 of	 an unmanned	 aviation	 platform	 with	 his	 profession	 to	 further	 the	 opportunities	 for	 safe,	 cost

effective	aerial	imaging	services	for	the	public	at	large.

Accordingly,	and	pursuan t	 to	14	CFR	§§	11.61

- .103	and	Section	333	of	 the	FAA	Modernization and	 Reform	 Act	 of2012,	 PL	 112

- 95	 (Feb.	 14,	 2012),	 the	 petitioner	 is	 submitting	 the	 following information	with	this	request:

Identity	of	Petitioner.

Petitioner:

Drew	Van	Duren 1365	Peac ock	Court Templeton,	CA	93465Description	of	Operations.

A.	The	UAS	that	is	the	Subject	of	this	Petition.

Mr.	Van	Duren	is	the	owner	of	a	DJI	Phantom	2	Vision	Plus	Aerial	Kit	unmanned	aircraft	with	a serial	number	of PH 645488 153 and	its	associated	portab le	ground	station	controller	 (together the	"Subject	UAS").	The	Subject	UAS	is	a	quad

- copter	with	a	camera	mounted	beneath	it,	piloted

v ia	 a	 portable	 ground	 station. It	 has	 an	 empty	 weight	 of	 approximately	 1,000	 grams,	 and	 a maximum	weight	of	1,3 00 grams,	w ith	the camera	and	3

- axis	gimbal mounted	as	payload.	The Phantom	 2	 is	 a	 widely	 known	 unmanned	 aircraft,	 and	 is	 the	 same	 type	 of	 aircraft	 that	 was recently	 the	subject	of	 the	grant	of	an	exemption	by	 the	FAA.	See	In	 re	Douglas	Trudeau,	FAA Exemption	No.	111 38	 (Jan.	5,	2015) and	 re	Daniel	Achatz,	FAA	Exemption	No.	11434	 (Apr.	27, 2015)

.
The	 portable	 ground	 station	 used	 by	Mr.	 Van	 Duren	 to	 pilot	 the	 unmanned	 aircraft	 is	 a	 two

channel,	wireless	communication	device	using	an	FCC

- compliant	5.8GHz	frequency	band for	the video	 link,	 and	 a	 2.4	 GHz	 transmitted. The	 two	 frequency	 bands	 interoperate	 well	 for simultaneous	 vehicle	 command	 and	 control	 and	 payload	 operations. The	 Subject	 UAS	 is equipped	with	lost

- link	capability,	which	enables	 the	Phantom	2	 to	enter	a	 fai l

- safe	Return

- to

Home	Mode	in	the	event	that	the	link fails	to	provide	command	authority.

The	Subject	UAS	can	operate	for	a	total	of	approximately	20	minutes	on	one	battery	charge.	It has	a	maximum	range	from	the	ground	station	of	2,300	feet.	However,	it also	has	programmable height	and	radius	limits	to	establish	an	operations	area.	Without	programming	the	Subject	UAS, it	has	a	default	height	limit	of	393	feet	AGL.

B.	The	UAS	Pilot	in	Command.

Mr.	Van	Duren	began	flying	as	a	student	pilot	at	age	17	in	1 990.	He	conducted	his	flight	training at	Hayward	air	terminal	in	the	San	Francisco	bay	area.	He	was	issued	his	private	pilot	certificate in	 July	of	1990.	As	of	 the	date	of	 this	letter,	he	has	180	hours	of	accumulated	 flight	 time, has obtained basic instrum ent	flight and aerobatics	training.

Mr.	 Van	 Duren	 has	 never	 been	 subject	 to	 an	 FAA	 enforcement	 action.	 Nor	 has	 he	 ever	 been involved	with	an	aircraft	accident	or	incident.

With	regard	 to	 the	Subject	UAS,	Mr.	Van	Duren	has	made	numerous	 flights	as	a	hobbyi st,	and has	accumulated	more	than	50	hours	of	flight	time	with	the	Subject	UAS. He	has	thousands	of hours	of	hobby

- related	flight	time	of	fixed	wing,	rotor	and	multi

- rotor	Radio	Control	aircraft.

In	addition,	Mr.	Van	Duren	is	a	graduate	in	aeronautical	en gineering	from	California	Polytechnic State	University, is	an	expert	in	aircraft	guidance,	navigation	and	control, and	in	his	professional duties	 has	 performed	 extensive	 risk	modeling	 and	 development	 of	 secure,	 cryptographic UASCommand

- and

- Control communi cations	 requirements	 for	 the	 FAA	 UAS	 Integration	 Office	 and RTCA.

C.	UAS	Operating	Parameters	and	Intended	Mission	Profile.

Mr.	 Van	 Duren is	 a engineering	 entrepreneur	 and	 additionally	 holds	 a	 California	 Real	 Estate license

. He	 performs	 a	 variety	 of	 pho tographic	 work,	 video	 production	 and	 remote	 sensing research	and	development.

The majority	of	the	petitioner's	operations	will	be	conducted in	and	around	the	central	coast	of California	 supporting	 the	agricultural	and	 real	estate	industries. He	intends	 to use	 the	Subject UAS	 to	conduct	aerial	photography	 for real	estate	brokers	and	agricultural	 remote	 sen sing	 for the	central	coast	and	central	valley	wine

- growing	region.

Most	 operations	 would	 be	 flown	 in	 the	 southern	 San	 Francisco	 (SSF) Sectional	 Chart an d northern	 Los	 Angeles	 (SLA)	 Sectional	 chart.	 	 The operations	 may	 be	 conducted	 at	 various locations	in	the	area	during	the	period	that	the	exemption	would	be	in	effect .		Due	to	the	wide geographic	 range	 of	 intended	 operations,	 there	 are	 not	 specific	 locati ons	 intended	 for operation.

Mr. Van	Duren would	adopt	with	the	following	UAS	Operating	Parameters:

# Topic Parameter 1 Operating	Ceiling and	Range All	 missions	 will	 be	 conducted	 below 4 00'	 AGL,	 and	 within	 a	 radius distance	of	800'	from	the	portable	groun d	station. 2 Mission Definition Each	mission	will	consist	of	one	flight

3 Point	of	Origin and	Warnings Mr.	 Van	 Duren	 will	 establish	 a	 fixed	 location	 (home	 point)	 where	 he will	be	positioned	with	the	portable	ground	station,	and	where	he	will post	a	 sign near	 the	ground	 station	 stating, "Aerial	 Photography and Data	Collection in	Progress

- Remain	Back	150	feet." 4 Pilot

- In

Command	&	Line of	Sight Operations Mr.	Van	Duren	will	act	as	the	pilot	in	command	and	will	have	direct	line of	sight	visual	observation of	the	aircraft	at	all	times,	and	operate	only within	visual	line	of	sight.	He	will	conduct	all	operations	under	his	own personal	 and	 flight	 safety	 protocols,	 and	 post	 a	 sign	 near	 his	 control station. 5 Proximity	to Structures In	 terms	 of	 proximity	 to	 t he	 residence	 or	 structure	 being photographed,	Mr.	Van	Duren	may	operate	in	a	close	proximity	to	the structure,	and	in	 some	cases	as	close	as	 25'	away	 from	 the	 structure. When	 that	 happens,	 he	 will	 operate	 at	 less	 than	 two	 miles	 per	 hour and	 operate	 paralle l	 flight	 to	 the	 structure	 walls,	 making	 the	 risk	 of collision	almost	negligible. 6 Lost	Link Procedures Prior	 to	 the	 start	 of	 a	 flight,	Mr.	 Van	Duren	 will	 activate	 and	 use	 the UAS's	 global	 positioning	 system	 flight safety	 procedure	 and	 lost

- link function settings to	ensure	return	of	the	aircraft	in	the	event	of	a	lostlink	 or	 compromised	 or	 degraded	 communications	 between	 ground station	and	aircraft.
7 Reserve	Flight Time On	each	mission,	the	aircraft	will	return	to	the	control	pad	with	no	less than	five 5	minutes	of	battery	power	remaining. 8 Typical	Flight Time Each	mission	will	last	for	no	more	than	twenty	minutes	of	flight	time.

9 Controlled Airspace Operations	and Permissions In	the	event	that	any	mission	would	ever	occur	within	the	airspace	of	a specific	 airport	 (e.g.,	 if	 the	 operation	 will	 involve	 photographing	 a residence or	 performing	 agricultural	 scanning located	 in	 class	 D airspace) or	 controlled	 airspace,	 Mr.	 Van	 Duren	 shall	 obtain	 the permission	 of	 that	 control	 tower	 to	 operate	 in	 that	 air space	 or	 from the	appropriate	control	authority. 10 Controlled Airspace Operations	and Permissions In	the	event	that	any	mission	will	occur	within	five	miles	of	an	airport, Mr.	 Van	 Duren	 shall	 ensure	 the	 airport	 is	 notified	 of	 the	 estimated flight	 time, flight	 duration,	 elevation	 of	 flight,	 and	 pertinent information. 11 Weather Mr.	 Van	 Duren	 will	 conduct	 all	 flights	 in	 permissible	 weather,	 and during	hours	from	BMNT	to	EENT. 12 Secure Communications Mr.	Van	Duren	will	enable	 the	VPN	 (Virtual	Private	N etwork)	 function to	 establish	 a	 full	 duplex,	 encrypted	 and	 data

- origin	 authenticated between	the	subject	UAS	and	ground	station.		This	function	is	designed to	 mitigate	 the	 potential	 for	 malicious	 or	 accidental	 3 rd party commands	to	be	sent	to	the	subject	U AS. 13 Visual	Observer Mr.	Van	Duren	will	utilize	a	Visual	Observer	 (VO) to	assist	in	all	Visual Line	 of	 Sight	 (VLOS)	 operations.	 	 The	 VO	 will	 be	 co

- located	 with	 Mr. Van	Duren,	the	Pilot	in	Command. 14 Flight	Operation Documents Mr.	 Van	 Duren	 will	 maint ain	 accessibility	 of	 all	 Operating	 documents during	flight	operations. 15 Maintenance	and Alterations Following	 maintenance	 or	 alterations	 on	 the	 subject	 UAS,	 Mr.	 Van Duren,	as	Pilot	in	Command,	will	perform	a	functional	flight	test	of	the vehicle.		Fligh t	tests	will	be	performed	with	the	VO	and	remain	at	least 500	ft.	from	other	people. 16 Aircraft Identifier and Markings Mr.	Van	Duren	will	operate	the	subject	aircraft identified	by	its serial number	markings	(registered	in	accordance	with	14	CFR	part	4 7),	and have	identification	(N−Number)	markings	in	accordance	with	14	CFR part	45,	Subpart	C.

Specific	Sections	of14	CFR	From	Which	Petitioner	Seeks	an	Exemption

.

Mr. Van	Duren seeks	an	exemption	from	the	following	FARs:

14	CFR	Part	21,	Subpart	H Cer tification	procedures	for	products	and parts,	Airworthiness	Certificates 14	CFR	Part	36 Noise	standards:	Type	and	airworthiness 14	CFR	§	45.23 Display	of	marks;	general14	CFR	Part	61 Certification:	Pilots,	flight	instructors,	and ground	instructors 14	CFR	§	91.7 Civil	aircraft	airworthiness 14	CFR	§	91.9 Civil	aircraft	flight	manual,	marking,	and placard	requirements 14	CFR	§	91.103 Preflight	action 14	CFR	§	91.105 Flight	crewmembers	at	stations 14	CFR	§	91.109 Flight	instruction 14	CFR	§	91.11 9 Minimum	safe	altitudes 14	CFR	§	91.121 Altimeter	settings 14	CFR	§	91.151 Fuel	requirements	for	flights	in	VFR conditions 14CFR§91.173 ATC	clearance	and	flight	plan	in	IFR conditions 14	CFR	§	91.203 Civil	aircraft:	Certifications	required 14	CFR §	91.207 Emergency	locator	transmitters 14	CFR	Part	91,	Subpart	E Maintenance

The	Extent	of	Relief	Sought,	and	Reasons	for	Seeking	the	Exemption.

14	 CFR	 Part	 21,	 Subpart	 H.	 Part	 21	 establishes	 the	 procedures	 for	 issuance	 of	 certificates	 of airworthin ess,	as	mandated	by	49	U.S.C.	§	44704.	Under	Section	333	and	49	U.S.C.	§	44701(b), the	 FAA	 may	 exempt	 aircraft	 from	 airworthiness	 certification.	 The	 petitioner	 requests	 an exemption	 from	 the	 requirements	 of	 this	 Part	 because	 the	 size,	 weight,	 speed,	 operat ional capability	and	proximity	to	airports	in	which	the	Subject	UAS	pose	significantly	less	of	a	risk	that the	risks	posed	by	conventional	aircraft.	Manned	aircraft	pose	risks	to	the	life	and	safety	of	the crew;	that	is	not	a	consideration	with	the	Subject UAS.	Risks	to	third	parties	are	also	minimized given	 the	lightweight	and	 slow	 speed	at	which	 the	Subject	UAS	would	 operate.	Nor	are	 there risks	of	fuel	spillage	or	fire	in	the	event	of	an	accident.	Thus	Mr.	Van	Duren requests	 that the	FAA	waive	the	requi rement	that	the	Subject	UAS,	particularly	the	aircraft	portion,	require	an airworthiness	certificate.

14	 CFR	 Part	 36. FAR	 Part	 36,	 Subparts	 A,	 F	 and	 0,	 establish	 certain	 noise	 standards	 for certification	of	various	aircraft	types.	Because	the	Subject	UAS would	not	have	an	airworthiness certificate,	 and	 given	 its	 small	 size	 and	 negligible	 noise	 impact,	 the	 petitioner	 requests	 an exemption	from	FAR	Part	36.

14	 CFR	 §	 45.23. FAR	 Part	 45.23	 establishes	 marking	 requirements	 for	 aircraft;	 paragraph	 (b) mandates that	the	registration	number	be	displayed	in	letters	not	less	than	two	inches	in	height. The	 Subject	 UAS	 is	 small	 enough	 that	 it	 cannot	 accommodate	 the	 type

- size	 requirement. Accordingly,	Mr. Van	Duren requests	an	exemption	from	this	part.

14	 CFR	 Part	 61. FAR	 Part	 61	 sets	 forth	 the	 certification	 requirements	 for	 pilots. SubpartEestablishestheprivilegesandlimitationsforholdersofaprivatepilotcertificate.	 The petitioner	 requests	 an	 exemption	 that	 would	 allow	 him	 to	 operate	 the	 Subject	 UAS	 forcompensation	or hire	as	part	of	his	aerial	photography	business	for	the	reasons	articulated	in In re	Trudeau, F	A	A	Exemption	No.	11138,	and In	re	Astraeus, F	A	A	Exemption	No.	11062.	Mr. Van Duren will	operate	 the	Subject	UAS	over	property	where	 the	owner	or	owner's	 repr esentative has	requested	 that	 the	operation	occur.	Furthermore,	as	a	holder	of	a	private	pilot	certificate, Mr. Van	Duren is	an	Airman	who	meets	the	knowledge	base	and	skill	level	for	operating	an	UAS. He	 thus	 requests	 and	 exemption	 from	 the	 requirement	 th at	 he	 hold	 a	 commercial	 pilot certificate	and	anything	other	than	a	Third	Class	Medical	certificate or	valid	state

- issued	driver’s license

.

14	 CFR	§	 91.7. Under	FAR	91.7,	no	person	may	operate	an	aircraft	unless	it	is	in	an	airworthy condition.	To	the	ext ent	that	"airworthy"	is	defined	as	requiring	an	airworthiness	certificate,	the petitioner	 would	 request	 an	 exemption	 from	 this	 FAR	 for	 the	 same	 reasons	 identified	 in	 his request	 for	 an	 exemption	 of	 14	 CFR	 Part	 21,	 Subpart	 H.	 He	 will	 not,	 however,	 operate	 t he Subject	UAS	if	it	is	not	in	a	condition	for	safe	flight,	as	required	under	FAR	91.7(b).

14CFR§91.9. PetitionerrequestsexemptionfromtherequirementofFAR91.9,which	requires	that	all aircraft	 have	 certain	markings,	 placards	 and	 on

- board	 flight	manuals	 for the	 same	 reasons	 as stated	in	his	request	 fro	exemption	under	14	CFR	Part	21,	Subpart	H,	and	 for	a	deviation	 from the	marking	requirements	of	14	CFR	Part	36,	Subparts	A,	F,	and	0.

14	CFR	§	91.103. FAR	91.103	mandates	certain	pre

- flight	action.	Petitioner will	take	all	necessary
pre

- flight	action,	but	requests	an	exemption	from	this	requirement	insofar	as	it	is	interpreted	as requiring	 pre

- flight	 actions	 appropriate	 to	 manned	 aircraft	 only	 (e.g.,	 that	 flights	 be	 from	 an airport,	etc.).

14	 CFR	 §	 91.105. FAR 91.105	 mandates	 that	 crewmembers	 be	 at	 designated	 stations,	 have safety	belts	fastened,	etc.	Petitioner	would	be	at	a	designated	ground	station	for	each	mission, but	requests	an	exemption	to	accommodate	the	fact	that	the	Subject	UAS	is	unmanned.

14	CFR § 91.109. This	FAR	requires	that	all	flight	instruction	be	conducted	in	aircraft	that	have dual	controls,	or	 throw

- over	controls,	with	an	instructor.	From	 time	 to	 time	 the	petitioner	will conduct	 his	 own	 refresher	 training,	 but	 requests	 an	 exemption	 insofar as	 this	 FAR	 would	 be interpreted	to	require	that	the	ground	control	station	have	a	second	controller	or	dual

- control capability.

14	 CFR § 91.119. FAR	 91.119	 sets	 forth	 the	 minimum	 safe	 altitudes	 over	 various	 areas. Petitioner	 requests	 an	 exemption	 from this	 this	 FAR	 in	 order	 to	 accomplish	 the	 intended function	of the	mission	for	which	he	seeks	an	exemption.

14	 CFR	 §	 91.121. FAR	 91.121	 mandates	 various	 altimeter	 settings	 in	 order	 to	 maintain	 level flight.	 Petitioner	 requests	 and	 exemption	 from	 this	 FAR	 a s	 the	 Subject	 UAS will	 not	 have	 an altimeter	 that	 matches	 the	 requirements	 of	 this	 FAR. Operations	 with	 the	 Subject	 UAS will, however,	maintain	altitude	below	the	300'	AGL	ceiling	by	the	petitioner	monitoring	the	altitude of	 the	UAS	and	 through	 the	Subject UAS's	ability	 to	establish	a	 flight	zone	 that	cannot	exceed the	ceiling.14	 CFR	 §	 91.151. Petitioner	 requests	 an	 exemption	 from	 the	 VFR

- flight	 fuel	 carrying requirements	 because	 the	 Subject	 UAS	 will	 operate	 on	 battery	 power.	 Operations	 with	 the Subject	U AS	will,	however,	maintain	a	five

- minute	reserve	battery	time.

19	 CFR	 §	 91.173. Petitioner	 requests	 an	 exemption	 from	 the	 IFR

- clearance	 requirement	 for flights	 into	 controlled	 airspace.	 It	 is	 possible	 Mr. Van	 Duren may	 operate	 the	 Subject	 UAS	 in condition s	 that	 are	 IFR	 within	 controlled	 airspace	 (e.g.,	 a	 flight	 on	 a	 day	 with	 less	 than	 three miles	visibility	in	a	neighborhood	that	falls	within	the	Class	D	airspace	of	KBFI).	He	would	request that,	after	contacting	ATC	 for	the	controlled	airspace,	he	would	be allowed	to	operate	in	what might	 be	IFR	 conditions,	 but	where	 he	 still	 has	 complete	and	 unfettered	line	 of	 sight	visibility with	the	Subject	UAS.

14	CFR	§	91.203. FAR	91.203	requires	that	a	civil	aircraft	have	an	airworthiness	certificate	and	a registrat ion	certificate.	Mr. Van	Duren requests	that	he	be	exempt	from	complying	with	this	FAR insofar	 as	 it	 mandates	 issuance	 of	 an	 airworthiness	 certificate,	 for	 the	 reasons	 stated	 in	 his request	for	an	exemption	under	14	CFR	Part	21,	Subpart	H.

14	CFR	§	91.207

. FAR	91.207	prohibits	operation	of	a	US

- registered	aircraft	unless	it	is	equipped with	an	emergency	locator	transmitter.	Given	the	limited	distance	of	flights	of	the	Subject	UAS, Mr. Van	Duren requests	and	exemption	from	this	FAR.

14	CFR	Part	91,	Subpart E. FAR	91,	Subpart	E	requires	that	owners	or	operators	of	aircraft	have the	 aircraft	 inspected	 at	 certain	 intervals,	 and	 by	 certain	 mechanics.	 Petitioner	 requests	 an exemption	from	this	Subpart	because	the	Subject	UAS	has	a	trouble

- shooting	and	maintenanc e program	 that	 is	 best	 executed	 by	 the	 owner/operator,	 and	 is	 simply	 different	 from	 the maintenance	of	manned	aircraft.	Petitioner	will,	however,	maintain	a	maintenance	log	and	any maintenance	records	of repair	of the	Subject	UAS.

Public	Interest	and	Bene fit	Considerations.

Aerial	 imaging	 services	 generally	 require	 use	 of	 a	 manned	 platform.	 Close

- proximity	 aerial photography	 is	 difficult	 to	 do,	 and	 usually	 requires	 the	 use	 of	 a	 helicopter	 or	 slow

- moving aircraft	at	an	appropriate	distance	over	a	populated area.	The	operation	must	be	conducted	in VFR	conditions,	and	adds	aircraft	in	congested	airspace.

By	 using	 the	 Subject	 UAS,	 Mr. Van	 Duren aims	 to	 provide	 the	 public	 with	 quality	 aerial photography	 services	 at	 a	 fraction	 of	 the	 cost	 involved	 with	 manned	 f light.	 Furthermore,	 the risks	 inherent	 with	 manned	 flight	 are	 significantly	 reduced	 where	 the	 aircraft	 conducting	 the operation	 is	 less	 than	 five	 pounds,	 remains	 below	 300'	 AGL,	 and	 can	 operate	 within	 a	 very confined	cylinder	on	or	directly	over	the	locati on	being	photographed.	Finally,	as	a	certificated airman,	 he	 has	 the	 knowledge	 and	 experience	 to	 conduct	 a	 safe,	 efficient	 flight	 operation	 in furtherance	 of	 his	 primary	 occupation.	 Thus	 the	 public	 will	 be	 better	 served	 by	 having	 more affordable	aerial	ima ging	options	available,	and	through	an	operation	that	is	being	conducted	by an	FAA

- certificated	airman.Why	the	Exemptions	Would	Not	Adversely	Affect	Safety.

The	proposed	operations	will	not	adversely	affect	safety	for	four	primary	reasons.

First,	 the	 o perations	 will	 be	 conducted	 in	 airspace	 where	 there	 is	 typically	 no	 activity	 among other	users	of	the	NAS.	Flights	are	limited	to	property	over	which	the	owner	has	requested	that the	Subject	UAS	operate,	so	the	owners	will	be	aware	of the	flight	operation. As	a	pilot	himself, Mr. Van	Duren fully	recogni zes	the	dangers	that	a	small	UAS could	pose	to	all	types	of	manned aircraft.	 The	 operations	 he	 is	 proposing	 to	 undertake	 pending	 approval	 of	 this	 Exemption Request	are	 operations	where	manned	aircraft	will	 no t	 fly.	There	 would	 be	 a	 rigid	 separation between	 where	 a	 manned	 aircraft	 can	 fly	 (particularly	 due	 to	 FAR	 91.119	 which	 establishes minimum	safe	altitudes,	to	include	an	absolute	prohibition	of	operating	an	aircraft	within	500'	of any	structure)	and	where	M r. Van	Duren would	operate	the	UAS

.
Second,	the	Subject	UAS	is	simply	not	a	large	aircraft.	Weighing	in	at	a	maximum	of	five	pounds fully	loaded,	the	likelihood	that	it	would	damage	property	or	injure	a	person	is	not	low,	even	in the	event	of	a	mishap.	Fu rthermore,	aerial	imaging	is	still	something	done	via	manned	aircraft, and	the	risk	there	is	at	least	equal	to	the	risk	posed	by	the	proposed	operation.

Third,	the	Subject	UAS	has	inherent	lost

- link	capabilities	to	bring	it	back	to	its	operating	base	for each	mission.	It	is	a	redundant	system	for	a	more	foreseeable	problem	that	could	arise.

Fourth,	the	Subject	UAS	will	be	operated	only	by	the	petitioner.	Mr. Van	Duren is	a	certificated pilot	 with	 sufficient	 flight	 time	 and	 experience	 with	 the	 aircraft	 to conduct	 a	 reasonably	 safe operation.

Language for	Inclusion	in	the	Federal	Register.

Mr. Van	Duren proposes	that	the	following	language	be	included	in	the	Federal	Register:

Petition for	Exemption.

Federal	Aviation	Regulations	from	which	Petitioner	seek s	exemption:	14	CFR	14	CFR	Part 21,	Subpart	H;	Part	36;	§	45.23;	Part	61;	§§	91. 7; 91.9;	91.103;	91.105;	91.109;	91.119; 91.121;	91.151;	91.173;	91.203;	91.207;	and	14	CFR	Part	91,	Subpart	E.

Description	 of Relie f Sought:	 The	 petitioner	 is	 seeking	 an	 exe mption	 from	 the	 above

referenced	 Federal	 Aviation	 Regulations	 to	 conduct	 aerial	 photography and	 data collection using	a	light,	unmanned	aerial	vehicle	for real	estate	and	agricultural	sensing purposes	in the California	central	coast area.Conclusion.

Mr. Van	Duren thank s the	FAA	for	considering	his request.	Please	contact the	petitioner should there	be	a	need	for	additional	information.

Respectfully	Submitted,

Drew	F

. Van	Duren

PetitionerExhibit	A:		Components	of	the	Subject	UAS,	Nomenclature	and Operating	Instructions

The	 following	 list	 identifies	 components	 of	 the	 subject	 UAS	 per	 the	 Phantom	 2	 V ision	 Plus Operating	Manual	 (current	version	is	V1.8
, dated	 Jan.	2015) and	additional,	extra	components procured	for	its	use

.



## # Item

– (Description)

1 UA S

– Subject	UAS	possesses	an	integrated,	but	replaceable	gimbal	and	camera 2 Propeller	 Pairs	 (4)

– All	 are	 self

- tightening

– 2	 tighten	 Clockwise,	 2	 tighten	 Counter

Cockwise 3 Micro

- SD	Card

– Inserted	in	the	aircraft	Micro

- SD	Slot 4 Lens	Cap

– Lens	cover for	integrated	HD	camera 5 Gimbal	Clamp

– Attached	to	gimbal	to	prevent	pan/tilt	motions	when	not	flying 6 Propeller	Wrench
7 Remote	 Control

– Includes	 holder	 for	Mobile	 Device	 and	WiFi	 range	 extender.	 	 Remote control	unit	possesses	self

- contained,	re chargeable	batteries 8 DJI	 Smart	 Flight	 Battery

– Lithium

- Ion	 battery,	 rechargeable	 and	 removable	 from	 the aircraft 9 Charger

– Charger	 for	 DJI	 Smart	 Flight	 Battery.	 	 Adaptive	 to	 110

- 240	 Volt	 input	 charge voltage. 10 Power	Cables

– Cables	for	Charger 1 1 Plug	Adapters

– Adapters	for	international	support 12 Micro

- USB	Cable

– Used	for	1)	Connecting	subject	UAS	to	computer	for	firmware	updates, 2)	Charging	 range	extender,	and	3)	Connecting	 to	Phantom	2	Vision	Plus	camera	payload for	downloading	imagery. 13 Manuals

– Includes:	Disclaimer,	 Phantom	 Pilot	Training	Guide,	 Phantom	 2	Vision	+	Quick Start	Guide	and	Manual 14 Stickers 15 Anti

- Drop	Kit 16 Spare	Screws

– Motor	and	body	fastening	screws 17 Landing	Pad

– Foam	mounts	to	cushion	the	landing	gear 18 Propeller	 Guards

- (not	 included	 with	 original	 aircraft)	 Add

- on	 propeller	 guards	 provide extra	protection	to	rotating	propellers	in	the	event	of	an	external	object	or	ground	strike.



### Phantom	2	Vision	+	Operations	(per	Phantom	2	Vision	+	Quick	St art	Guide)

### The	 following	 instructions	 are	 from	 the	 subject	 UAS	 Quick	 Start	 Guide.	 	 Explanatory details	may	be	 found	in	 the latest	Phantom	2	Vision+	User	Manual.		Current	version	is 1. 8 ,	dated January ,	201 5 1 

### which	is	consistent	with	the	latest	firmware	vers ions.

1. Start

• View	tutorials: http://www.dji.com/phantom2visionplus/training

• Search DJI	 Vision*	 in	 the	 App	 Store	 or	 Google	 Play.	 	 Download,	 then	 launch	 and register	for	a	DJI	account.

• Ensure	 the Smart	 Flight	 Battery,	 Range	 Extender	 and	 Remote	 Control	 are	 fully charged

• Important:	For	SAFETY	reasons	please	watch	the	tutorials,	read	the	disclaimer	and manuals	thoroughly	before	using	this	product

o DJI	VISION	App	supports	the	Phantom	2	Vision	and	the	P hantom	2	Vision+. It	is	compatible	with	iOS	and	Android	devices

o See	 steps	 3,	 4,	 5	 for	 checking	 battery	 levels.	 	 Refer	 to	 user	 manual	 for charging.

2. Preparing	Phantom	2	Vision	+

• Remove	the	gimbal	clamp,	the	lens	cap	and	the	four	warning	cards	from	motors

• S crew	the	propellers,	clockwise	for	grey	nuts	and	anti

- clockwise	for	black	nuts,	onto the	 four	 motors.	 	 Be	 sure	 to	 match	 the	 black	 propeller	 nuts	 with	 the	 black	 dot
motors

• Make	sure	your	Smart	Flight	Battery	and	Micro

- SD	card	are	inserted	correctly

• Importan t:	Remove	gimbal	clamp	before	powering	on.

3. Preparing	Remote	Control

• Twist	the	Mobile	Device	Holder	to	face	outwards	and	fix	in	position

• Be	sure	S1	and	S2	are	stitched	to	the	upper	most	position.		Push	the	Power	Switch to	the	right	to	power	on	the	Remote	C ontrol.		The	LED	will	go	green	if	the	Remote Control	is	functioning.		The	Battery	Level	Indicators	display	the	current	battery	level.

• Important:	 A	 red	 blinking	 and	 a	 continuous	 beeping	 from	 the	 Remote	 Control indicate	 LOW	 BATTERY	 VOLTAGE.	 	 Recharge	 the	 Bat tery	 when	 there	 is	 only	 one LED	blinking.

4. Powering	On	Smart	Flight	Battery

• Press	 the	 circular	 power	 button	 once,	 then	 press	 again	 and	 hold	 for	 2	 seconds	 to power	on	the	Smart	Flight	Battery

• Rear	LED	Flight	Indicators	light	up	to	indicate	flight	status:

o Sl ow	Green	Flashing.		Ready	to	Fly	(GPS)

o Slow	Yellow	Flashing.		Ready	to	Fly	(Non

- GPS)

o Fast	yellow	flashing.		Remote	control	signal	lost.

o Fast	red	flashing.		Smart	Flight	Battery	level	warning.

• Important: 1. Press	circular	power	button	once	to	check	battery	lev el

1 http://download.dji

innovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_V ision_Plus_User_Manual_v1.8_en.pdf2. Front	LEDs	light	up	until	motors	start	up 3. Refer	to	the	LED	Flight	Indicator	card	attached	or	user	manual	for	more	details

5. Powering	On	Range	Extender/Linking	Camera

• Toggle	 power	 switch	 to	 ON	 position.	 	 SYSTEM	 Indicator	 will	 blink	 green	 to	 show normal	op eration

• Enable	 Wi

- Fi	 on	 your	 mobile	 device	 then	 select	 Phantom_XXXXXX	 from	 Wi

- Fi network	list.

• Tap CAMERA icon	in	the	DJI	VISION	App	for	a	live	camera	view	to	ensure	the	camera is	linked,	then	clip	your	mobile	device	into	the	Mobile	Device	Holder

• Important : 1. If	 the	 POWER	 indicator	 is	 red,	 this	 means	 battery	 level	 is	 low.	 	 Charge	 your Range	Extender	by	Micro

- USB	cable. 2. Only	if	both	Range	Extender	and	Smart	Flight	Battery	are	powered	on,	you	will be	able	to	link	the	camera.

6. Calibrating	Compass

• Always	calibra te	compass	before	your	flight

• Step	1:	To	enter	calibration	mode,	flip	S1	switch	rapidly	from	top	to	bottom	5	times

• Step	2:	Hold	Phantom	horizontally	then	rotate

• Step	3:	Hold	aircraft	vertically	with	nose	pointing	to	the	ground,	rotate	360	degrees around	 th e	 center	 axis	 until	 Rear	 LED	 Flight	 indicators	 resume	 normal	 blinking patterns.

• If	rear	LED	Flight	Indicators	blink	red	and	yellow,	calibration	has	failed.		Re

- calibrate by	repeating	Step	1

- 3	until	normal	blinking	begins.

7. Remote	Control	Settings

• The	Remot e	Control	is	by	default	set	to	Mode	2	(left	hand	controls	throttle)

• Important:		You	can	use	PHANTOM	RC	Assistant	to	switch	it	to	Mode1	(right	hand controls	throttle)

8. Taking	off	(Outdoors)

• Place	 the	Phantom	2	Vision+	on	 flat	ground	in	an	open	space	with	Re ar	LED	Flight Indicators	facing	you.

• Power	 on	 the	 Remote	 Control,	 the	 Range	 Extender	 and	 the	 Smart	 Flight	 Battery mounted	 in	 Phantom	 2	 Vision+.	 	 Make	 sure	 that	 the	 DJI	 VISION	 App	 is	 working properly.

• Start	 motors	 by	 pulling	 both	 control	 sticks	 to	 the	 botto m	 corners.	 	 Release	 sticks
once	motors	start.

• Wait	until	Rear	LED	Flight	Indicators	go	from	a	slow	yellow	blinking	to	a	slow	green, indicating	GPS	locked.

• Slowly	push	the	left	(throttle)	stick	up	to	take	off.

• Important: 1. Beginner	flyers	are	recommended	t o	only	fly	when	the	slow	green	flashes 2. Rear	LED	Flight	Indicators	will	go	from	slow	yellow	flashing	to	slow	green flashing	if	more	than	6	GPS	satellites	have	been	found. 3. Never	stop	the	motors	during	flight9. Landing	(Outdoors)

• Pull	down	the	throttle	stick to	descend.		The	stick	will	lock	into	place	and	the	aircraft will	descend	steadily.

• When	landing	on	the	ground,	pull	both	sticks	to	bottom	corners	to	stop	motors.

• Press	 the	 circular	 power	 button	 once,	 then	 press	 again	 and	 hold	 for	 2	 seconds	 to power	 off	 th e	 Smart	 Flight	 Battery.	 	 Turn	 off	 the	 Remote	 Control	 and	 Range Extender.

• Important: 1. Land	only	on	flat	ground	in	open	spaces. 2. Stop	motors	immediately	after	lan ding.