JULY 12, 2015

U.S.	Department	of	Transportation
Federal	Aviation	Administration Document	Management	System 1200	New	Jersey	Ave.,	SE Washington,	D.C.	20590

Dear	Sir	or	Madam,

Pursuant	to	Section	333	of	the	FAA Modernization	and	Reform	Act of	2012,	Pub.	L.	No.	112‐ 95,	126	Stat.11	(amending 49	U.S.C.)	(Hereinafter,	the	“Ref orm	Act”)	and	14	C.F.R.	Part	1 1,	Nexus	Quality	LLC,	hereby	seeks	an	exemption	from	the Federal	Aviation	Regulations	listed	below,	to	allow	commercial operation	of	its	small	unmanned	aerial	vehicles	(i.e. “small	unmanned	aircraft”	or	“sUAS”)

Nexus	Quality,	LLC's	requested	e xemption	would	permit	the	opera tion	of	sUAS	under	controlled	and	secure	conditions that	is:	(i)	limited,	(ii)	prede termined,	(iii)	subject	to	cont rolled	access,	and	(iv)	provide	greater	safety	in	connection with	aircraft	operations.	As	esta blished	by	the	exemptions	alre ady	granted	by	the	FAA,	approval	of	Nexus	Quality,	LLC's exemption	would	enhance	safety	a nd	fulfill	the	Secretary	of	Tra nsportation’s	(the	FAA	Adminis trator’s)	responsibilities to	“...establish	requirements	for the	safe	operation	of	such	ai rcraft	systems	in	the	national	airspace	system.”	Section 333(c)	of	the	Reform	Act.

The	name	and	address	of	the	applicant	is:

Nexus	Quality	LLC Joey	Johnston

Phone: 832‐492‐7146

Email: nexusquality@outlook.com

Address: 6606	FM	1488	Suite	148‐151	Magnolia,	TX	77354 The	Applicant	hereby	requests	exemption	from	the	following	FARs :



###  14	C.F.R.	21,	subpart	H



###  14	C.F.R.	61.3



###  14	C.F.R.	61.113(a)	&	(b) Nexus	Quality	LLC
6606	FM	1488	Ste.	148‐151 Magnolia,	TX	77354
832‐492‐7146 nexusquality@outlook.com

###  14	C.F.R.	61.133(a)



###  14	C.F.R.	91.9(b)	(2)



###  14	C.F.R.	91.103(b)



###  14	C.F.R.	91.105



###  14	C.F.R.	91.109(a)



###  14	C.F.R.	91.119



###  14	C.F.R.	91.121



###  14	C.F.R.	91.151(a)



###  14	C.F.R.	91.203(a)	&	(b)



###  14	C.F.R.	91.319(a)	(1)



###  14	CFR	91,	Subpart	E	(91.405,	91.407,	91.409,	91.417)

sUAS	operated	by	Nexus	Quality,	LLC	weigh	less	than	55	pounds, including	the	payload	(i.e. camera,	lens,	and	gimbal). They	operate	at	speeds	of	no	more	than	50	knots,	can	hover,	and can	simultaneously	move	vertically	and	horizontally. Nexus	Quality,	LLC	will	only	operate	its	sUASs	in	line	of	sight and	will	operate	only	within	the	secure	area	described	in the	FOPM.	Such	operations	will	insure	that	the	sUAS	will	“not	c reate	a	hazard	to	users	of	the	national	airspace	system or	the	public.”

The	requested	exemption	would	au thorize	Nexus	Quality	LLC	to	co nduct	commercial	operations	using	the	DJI	Phantom 3	and	DJI	Inspire	1	for	mapping,	inspection	and	photography	of landfills,	mining	facilities,	ut ilities,	oil	&	gas	facilities, agriculture,	construction	sites,	engineering	assessments,	insur ance	damage	assessments,	real	estate	marketing	and events	such	concerts,	sports,	etc.	Specifications	for	all	sUAS are	attached	to	this	document.

sUAS Operating Parameters The	operation	limitations	propos ed	for	an	equivalent	or	higher level	of	safety	because	oper ations	will	fu rther	enhance the	safety	of	the	persons	and/or property	using	conventional	ai rcraft.

These	limitations	and	conditions to	which	the	applicant	agrees to	adhere	to	when	conducti ng	commercial	operations under	the	FAA	issued	exemption	as	set	forth	in	the	Flight	Opera tions	Manual	(FOM)	include:

 The	UAS	will	weigh	less	than	55	lbs.

 The	UAS	will	have	a	maximum	opera ting	speed	of	no more	than	35m ph.

 Flights	will	be	operated	within	l ine	of	sight	of	the	Pilot	in	C ommand	(PIC)	and/or	Visual	Observer	(VO).

 Maximum	flight	time	for	each	ope rational	flight	will	be	20	minu tes.	Flights	will	be	terminated	at	25%	battery power	reserve	or	20	minutes	of	f light	time	whichever	occurs	fir st.

 Flights	will	be	operated	at	an	altitude	of	no	more	than	400	fee t	Above	Ground	Level	(AGL)	and	not	more	than 200	feet	above	an	elevated	platfor m	from	which	filming	is	plann ed.

 Minimum	crew	for	each	operation will	consist	of	the	UAS	Pilot, the	Visual	Observer	(VO)	and	may	include	but not	limited	to	a	Camera	Operator.

 The	UAS	pilot	will	be	a	designate d	Pilot	in	Command	(PIC)	and	w ill	take	and	pass	all	ne cessary	certifications currently	being	approved	by	the	F AA	administration	for	commerci al	use.

 A	briefing	will	be	performed	reg arding	the	planned	UAS	operatio ns	prior	to	each	day’s	flight	consisting	of	all the	days’	production	activities.

 All	flights	will	occur	under	Visu al	Flight	Rules	Meteorological Conditions	(VMC)	only.

 The	flights	will	occur	no	closer than	a	5	mile	radius	of	the	ge ographic	center/Airport	Reference	Point (ARP)	of	a	tower	controlled	or	u ncontrolled	airport.	The	DJI	Ph antom	3	Professional	and Inspire	1	has	built	in software	for	all	FAA	regulated	‘No	Fly	Zones’	and	was	uploaded by	DJI	(February	2015)	for	all	DJI	drones	to download	and	prevent	any	possibl e	flights	occurring	within	no‐f ly	zones.	DJI	Phantom	3

 Professional	has	installed	softwa re	(code)	that	denies	flights within	the	FAA	no‐fly	zones.

 If	operations	will	be	within	a	5 mile	radius	of	the	geographic center/Airport	Reference	Point	(ARP)	of	a	tower controlled	or	uncontrolled	airpor t	the	respective	airports	will be	contacted	advising	t hem	of	the	estimated flight	time,	flight	duration,	el evation	of	flight	and	other	per tinent	information.

 The	operator	will	file	FAA	Form 7711‐1,	or	its	equivalent,	as	m odified	in	light	of	the requested	exemption, with	the	appropriate	local	Flight	Standards	District	Office	(FS DO)	no	more	than	72	hour s	but	no	less	than	48 hours	from	planned	operation.

 The	operator	will	obtain	verbal/ written	consent	of	all	persons involved	with	the	planned	operation	and ensure	that	only	consenting	persons	will	be	allowed	within	100 feet	of	the	flight	operation,	and	the	radius	may be	reduced	to	30	feet	based	upon an	equivalent	level	of	safety determination,	as	required	under	the	FOM.	With the	advanced	permissio n	of	the	FSDO,	operations	at	closer	range may	be	approved.

 Written	and/or	verbal	permission and	permits	will	be	obtained	f rom	territorial,	state,	county	or	city jurisdictions,	including	law	enf orcement,	fire	or	other	appropr iate	governmental	agencies.

 If	the	UAS	loses	communications with	the	remote	controller	or	l oses	GPS	signal,	the UAS	will	have	the capability	to	return	to	a	pre‐de termined	location	within	a	desi gnated	location	and	land	autonomously.

 The	UAS	will	have	the	c apability	to	abort	a	flight	in	case	of	u npredicted	obstacles,	weather,	or	emergencies.

 sUAS	 operations	may	not	 be	condu cted	during	 night,	 as	defined	i n	14	CFR	 §	 1.1.	All	 operations	 must
be	 conducted	 under	 visual	 meteor ological	 conditions	 (VMC).	 Flig hts	 under	 special	 visual	 flight	 rules (SVFR)	 are	 not	 authorized.	 The	 sUAS	 may	 not	 be	 operated	 less	 th an	 400	 feet	 below	 or	 less	 than 2,000	 feet	horizontally	 from	a	cloud	or	 when	visibility	is	less than	3	statute	miles	from	the	PIC.

 Documents	used	by	the	operator	t o	ensure	the	safe	operation	and flight	of	the	sUAS	and	any	documents required	under	14	CFR	§§	91.9 and	91.203	must	be	available	to	t he	PIC	at	the	Ground	Control	Station	of	the sUAS	any	time	the	aircraft	is	op erating.	These	documents	must	b e	made	available	to	the	Administrator	or	any law	enforcement	official	upon	request

 sUAS	 will	 not	 be	 operated	 directly	 over	 nonparticipating	 person s	 unless	 barriers	 or	 structures	 are present	 that	 sufficiently	 protect	 nonparticipating	 persons	 from the	 UA	 and/or	 debris	 in	 the	 event
of	 an	 accident.	 UA	will	 not	 be	 o perated	 over	 any	 open‐air	 assem bly	of	people.

 The	sUAS	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.

 Any	 incident,	 accident,	 or	 flight	 operation	 that	 transgresses	 t he	 lateral	 or	 vertical	 boundaries	 of	 the operational	area	as	defined	by	the	applicable	COA	will	be	repor ted	to	 the	FAA's	UAS	Integration	Office (AFS‐80)	within	24	hours.	Accidents	will	be	reported	to	 the	Nat ional	Transportation	Safety	Board	(NTSB) per	instructions	contained	on	the	NTSB	 Web	site:	www.ntsb.gov.

Characteristics of the sUAS:

DJI Phantom 3:

Weight (Including Battery and Propellers) 1280	g Diagonal Size (Including Propellers) 590	mm Max Ascent Speed 5	m/s Max Descent Speed3	m/s Hover Accuracy

 Vertical:	+/‐	0.1	m	(when	Vision Positioning	is	active)	or	+/‐ 0.5	m

 Horizontal:	+/‐	1.5	m Max Speed 16	m/s	(ATTI	mode,	no	wind) Max Altitude Above Sea Level 6000	m Operating Temperature 0°C	to	40°C GPS Mode GPS/GLONASS Operating Frequency 2.400	GHz‐2.483	GHz Max Distance 2000m	(outdoors	and unobstructed) Video Output Port USB Operating Temperature 0°C‐	40°C Battery 6000	mAh	LiPo	2S Mobile Device Holder For	tablet	or	phone Receiver Sensitivity (1%PER) ‐101	dBm	±2	dBm Transmitter Power (EIRP)

 FCC:	20	dBm

 CE:	16	dBm Working Voltage 1.2	A	@7.4	V Battery Capacity 4480	mAh Voltage 15.2	V Battery Type LiPo	4S Energy 68	Wh Net Weight 365	g Max Flight Time Approximately	23	minutes Operating Temperature ‐10°C	to	40°C Max Charging Power 100	W

DJI Inspire 1 Specs:

Model T600 Weight (Battery Included) 2935	g Hovering Accuracy (GPS Mode)Vertical:	0.5	m Horizontal:	2.5	m Max Angular Velocity Pitch:	300°/s Yaw:	150°/s Max Tilt Angle 35° Max Ascent Speed 5	m/s Max Descent Speed 4	m/s Max Speed 22	m/s	(ATTI	mode,	no	wind) Max Flight Altitude 4500	m Max Wind Speed Resistance 10	m/s Max Flight Time Approximately	18	minutes Motor Model DJI	3510 Propeller Model DJI	1345 Indoor Hovering Enabled	by	default Operating Temperature Range ‐10°	to	40°	C Diagonal Distance 559	to	581	mm Dimensions 438x451x301	mm Remote
Name
C1 Operating Frequency 922.7~927.7	MHz	(Japan	Only)
5.725~5.825	GHz
2.400~2.483	GHz Transmitting Distance (Outdoor And Unobstructed)
2	km
EIRP 10dBm@900m,	13dBm@5 .8G,	20dBm@2.4G
Video Output Port USB,	mini‐HDMI
Power Supply Built‐in	battery Charging DJI	charger
Dual User Capability
Host‐and‐Slave	connection
Mobile Device Holder
Tablet	or	Phone
Max Mobile Device Width170mm Output Power
9	W Operating Temperature Range
‐10°	to	40°	C Storage Temperature Range
Less	than	3	months :	‐20°	to	45°	C
More	than	3	mont hs:	22°	to	28°	C Charging Temperature Range
0‐40°	C Battery
6000	mAh	LiPo	2S Battery for sUAS
Name Intelligent	Flight	Battery
Model
TB47 Capacity
4500	mAh Voltage
22.2	V Battery Type LiPo	6S	High	voltage	battery Energy
99.9	Wh
Net Weight 570	g Operating Temperature Range
‐10°	to	40°	C Storage Temperature Range
Less	than	3	months :	‐20°	to	45°	C
More	than	3	months :	22°	C	to	28°	C Charging Temperature Range
0°	to	40°	C
Max Charging Power
180	WPre

‐ flight Action: Section	91.103	requires	each	pilo t	to	preflight	an	aircraft	bef ore	flight	to	insure	the	safety	of	flight.	As	FAA	approved rotorcraft	flight	manuals	will	no t	be	used,	an	exemption	is	req uested.	However,	an	equivale nt	level	of	safety	will	be provided.	The	PIC	will	take	all	ac tions,	including	reviewing	we ather,	flight	battery	requirements,	landing	and	takeoff distances,	and	aircraft	performa nce	data	before	commencement	of flight.

PIC & Flight Crewmembers: Pilot	in	Command	Sections	61.113 (a)	and	(b)	limit	private	pilo ts	to	non‐commercial	operations.	Because	the	sUAS will	not	carry	a	pilot	or	passengers,	the	proposed	operations	c an	achieve	the	equivalent level	of	safety	of	current operations	by	requiring	the	PIC operating	the	aircraft	to	have a	private	pilot’s	license	rath er	than	a	commercial	pilot’s license	to	operate	a	sUAS.	Unlik e	a	conventional	manned	aircraf t,	a	sUAS	is	remotely	controlled	by	a	ground‐based operator.	The	operational	area	is	controlled	and	restricted,	an d	all	flights	are	planned	and	coordinated	in	advance.	The level	of	safety	exceeds	that	provi ded	by	a	single	individual	ho lding	a	commercial	pilot’s	certificate	operating	a
conventional	aircraft.	The	risks associated	with	the	use	of	a	s UAS	are	so	diminished	from	t he	level	of	risk	associated with	commercial	operations	contemplated	by	Part	61	allowing	sUA S	use	by	a	sport	pilot	a s	the	PIC	exceeds	the present	level	of	safety	sought by	14	C.F.R.	§61.113	(a)	and	(b)

.

All	Nexus	Quality	LLC	sUAS	opera tors	will	have	successfully	com pleted	Nexus	Quality	LLC	UAS	Training	Program. Completion	of	the	Nexus	Quality LLC	sUAS	Training	Program	will ensure	safe	operations	by not	allowing	any	PIC	to operate	a	sUAS	unless	that	PIC	h as	demonstrated,	that	he/she	is able	to	safely	operate	the	sUAS	in	a	manner consistent	with	the	exemption,	in cluding	evasive	and	emergency maneuvers	and	maintaining	appropriate	distances from	people,	vessels,	vehicles	a nd	structures.	All	operators	wi ll	either	meet	the	flight	review	requirements	specified	in 14	CFR	§	61.56	or	will	annually	c omplete	and	log	at	least	4	hou rs	of	ground	instruction	with	a	certified	flight instructor	(CFI)	covering	regulations	and	issues	pertinent	to	c ommercial	operation	of	the Phantom	3,	Inspire	1	or
Steadidrone	Mavrik. The	individual	acting	as	PIC	of a	sUAS	will	be	identified	prior to	any	flight	and	will	not	change	once	the	flight	has begun.	The	PIC	is	the	individual in	operational control	of	the flight	operation	from	beginning to	end	and	is	responsible for	safe	flight	of	the sUAS.	All	PIC	flight	hours	used	to	demon strate	qualifications	and	cu rrency	will	be	logged	in	a manner	consistent	with	14	CFR	§	61.51(b).

Maintenance and Inspections for sUAS: 14	C.F.R.	§91.405	(a);	407	(a)	(1 );	409	(a)	(2); 417(a)	&	(b): These	regulations	require	that	an	aircraft	operator	or	owner	sh all	“have	that	aircraft	inspected	as	prescribed	in subpart	E	of	this	part	and	shall	between	required	inspections, except	as	provided	in	paragraph	(c)	of	this	section,	have discrepancies	repaired	as	prescr ibed	in	part	43	of	this	chapter ...,”	and	others	shall	inspect or	maintain	th e	aircraft	in compliance	with	Part	43.	Given	t hat	these	sections	and	Part	43 apply	only	to	aircraft	with	an	airworthiness	certificate, these	sections	will	not	apply	to	Nexus	Quality	LLC.	Maintenance will	be	accomplished	by	the	operator.	An	equivalent level	of	safety	will	be	achieved because	the	sUASs	are	limited in	size,	will	carry	a	small	pa yload	and	operate	only	in restricted	areas	for	limited	per iods	of	time.	If	mechanical	iss ues	arise,	the	sUAS	can	land	immediately	and	will	be operating	from	no	higher	than	400	feet	AGL.	As	provided	in	the FOPM,	the	operator	will	ensure	that	the	sUAS	is	in working	order	prior	to	flight,	p erform	any	required	maintenance ,	and	keep	a	log	of	any	maintenance	performed. Moreover,	the	operator	is	the	pe rson	most	familiar	with	the	sUA S	and	best	suited	to	maintain	it	in	an	airworthy condition.	Operations	after	maintenance	will	have	the	sUAS	fly at	an	altitude	of	no	more	than	4	feet	from	the	ground	inPage	8 a	marked	off	area	to	ensure	the	maintenance	of	the	sUAS	was	don e	properly	prior	to	doing	another	flight.	Maintenance records	shall	be	kept	on	file	for	at	least	5	years.

FEDERAL REGISTER SUMMARY

Pursuant	to	14	C.F.R.	Part	11,	the	following	summary	is	provide d	for	publication	in	the	Fed eral	Register,	should	it	be determined	that	public ation	is	necessary:

Nexus	Quality	LLC	seeks	an	exemp tion	from	the	following	rules:

14	CRF	Part	21,	Subpart	H;	14	CF R	Part27;	14	CFR	45.23(b);	14	C FR	§	61.113;	14	CFR

91.7(1);	14	CFR	91.9(b)(2);	14 CFR	91.103;	14	CFR	91.109(a);	14 CFR	91.119;	14	CFR	91.121;

14	CFR	91.151(a);	14	CFR	91.203(a) &	(b);	14	CFR	91.405(a);	14 CFR	91.407(a)(1);	14	CFR

91.409(a)(2);	14	CF R	91.417	(a)	&	(b).

This	exemption	will	enhance	the	safety	by	reducing	risk	to	the general	public	and	propert y	owners	from	the	hazards associated	with	performing	the	s ame	work	with	conventional	roto rcraft	and	aircraft.

Conclusion

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Ref orm	Act	of	2012:	size,	weight,	speed,	operating capabilities,	proximity	to	airports	and	populated	areas,	operat ion	within	visual	line	of	si ght,	and	national	security; provides	more	than	adequate	just ification	for	the	grant	of	the requested	exemptions	to	permit	9three	to	operate	the
selected	UAS	in	the	manner	described	within.

Granting	the	requested	exemption	will	benefit	the	public	intere st	in	many	ways	including	(1)	significantly	improving safety	and	reducing	risk	to	human	life,	and	(2)	improving	the	q uality	of	services	offered.

In	closing	the	exemption	being	requested	has	previously	been	gr anted	to	other	companies	t hat	will	be	performing	the same	scope	of	work	as	Nexus	Quality	LLC	will	be	performing.	The companies	that	have	been	granted	exemptions	are
as	follows:

 FlightWink	LLC

 GSC	Surveying	Inc

 Pro	Drones	Canada

 Soar	Environmental	Consulting

 Stark	Aerospace

 Nixon	Engineering	Solutions	LLC

 Sky	Futures	UAS

 Droneview	LLC

 Precisionhawk

Page	9 Warm	regards,

Joey Johnston

PRESIDENT

NEXUS QUALITY LLC

Attachments:

DJI	Phantom	3	Manual

DJI	Inspire	1	Manual

Nexus	Quality	LLC	Quality	Manual

DJI	Phantom	Safety	Guidelines

Inspire	1	Safety	Guidlines