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	“Reform	Act”)	and	14	C.F.R.	Part	11,	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	exemption	would	permit	the	operation	of	sUAS	under	controlled	and	secure	conditions	

that	is:	(i)	limited,	(ii)	predetermined,	(iii)	subject	to	controlled	access,	and	(iv)	provide	greater	safety	in	connection	

with	aircraft	operations.	As	established	by	the	exemptions	already	granted	by	the	FAA,	approval	of	Nexus	Quality,	LLC's	

exemption	would	enhance	safety	and	fulfill	the	Secretary	of	Transportation’s	(the	FAA	Administrator’s)	responsibilities	

to	“...establish	requirements	for	the	safe	operation	of	such	aircraft	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	create	a	hazard	to	users	of	the	national	airspace	system	

or	the	public.”	

The	requested	exemption	would	authorize	Nexus	Quality	LLC	to	conduct	commercial	operations	using	the	DJI	Phantom	

3	and	DJI	Inspire	1	for	mapping,	inspection	and	photography	of	landfills,	mining	facilities,	utilities,	oil	&	gas	facilities,	

agriculture,	construction	sites,	engineering	assessments,	insurance	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	proposed	for	an	equivalent	or	higher	level	of	safety	because	operations	will	further	enhance	

the	safety	of	the	persons	and/or	property	using	conventional	aircraft.	

These	limitations	and	conditions	to	which	the	applicant	agrees	to	adhere	to	when	conducting	commercial	operations	

under	the	FAA	issued	exemption	as	set	forth	in	the	Flight	Operations	Manual	(FOM)	include:	

 The	UAS	will	weigh	less	than	55	lbs.	

 The	UAS	will	have	a	maximum	operating	speed	of	no	more	than	35mph.	

 Flights	will	be	operated	within	line	of	sight	of	the	Pilot	in	Command	(PIC)	and/or	Visual	Observer	(VO).	

 Maximum	flight	time	for	each	operational	flight	will	be	20	minutes.	Flights	will	be	terminated	at	25%	battery	

power	reserve	or	20	minutes	of	flight	time	whichever	occurs	first.	

 Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	Above	Ground	Level	(AGL)	and	not	more	than	

200	feet	above	an	elevated	platform	from	which	filming	is	planned.	

 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	designated	Pilot	in	Command	(PIC)	and	will	take	and	pass	all	necessary	certifications	

currently	being	approved	by	the	FAA	administration	for	commercial	use.	

 A	briefing	will	be	performed	regarding	the	planned	UAS	operations	prior	to	each	day’s	flight	consisting	of	all	

the	days’	production	activities.	

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

 The	flights	will	occur	no	closer	than	a	5	mile	radius	of	the	geographic	center/Airport	Reference	Point	
 (ARP)	of	a	tower	controlled	or	uncontrolled	airport.	The	DJI	Phantom	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	possible	flights	occurring	within	no‐fly	zones.	DJI	Phantom	3	

 Professional	has	installed	software	(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	airport	the	respective	airports	will	be	contacted	advising	them	of	the	estimated	

flight	time,	flight	duration,	elevation	of	flight	and	other	pertinent	information.	

 The	operator	will	file	FAA	Form	7711‐1,	or	its	equivalent,	as	modified	in	light	of	the	requested	exemption,	

with	the	appropriate	local	Flight	Standards	District	Office	(FSDO)	no	more	than	72	hours	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	permission	of	the	FSDO,	operations	at	closer	range	may	be	approved.	

 Written	and/or	verbal	permission	and	permits	will	be	obtained	from	territorial,	state,	county	or	city	

jurisdictions,	including	law	enforcement,	fire	or	other	appropriate	governmental	agencies.	

 If	the	UAS	loses	communications	with	the	remote	controller	or	loses	GPS	signal,	the	UAS	will	have	the	

capability	to	return	to	a	pre‐determined	location	within	a	designated	location	and	land	autonomously.	

 The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles,	weather,	or	emergencies.	

 sUAS	 operations	may	not	 be	conducted	during	 night,	 as	defined	in	14	CFR	 §	 1.1.	All	 operations	 must	

be	 conducted	 under	 visual	 meteorological	 conditions	 (VMC).	 Flights	 under	 special	 visual	 flight	 rules	

(SVFR)	 are	 not	 authorized.	 The	 sUAS	 may	 not	 be	 operated	 less	 than	 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	to	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	the	PIC	at	the	Ground	Control	Station	of	the	

sUAS	any	time	the	aircraft	is	operating.	These	documents	must	be	made	available	to	the	Administrator	or	any	

law	enforcement	official	upon	request	

 sUAS	 will	 not	 be	 operated	 directly	 over	 nonparticipating	 persons	 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	 operated	 over	 any	 open‐air	 assembly	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	 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	 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 Speed
3	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 Width
170mm	

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	months:	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	W	
Pre‐flight Action:

Section	91.103	requires	each	pilot	to	preflight	an	aircraft	before	flight	to	insure	the	safety	of	flight.	As	FAA	approved	

rotorcraft	flight	manuals	will	not	be	used,	an	exemption	is	requested.	However,	an	equivalent	level	of	safety	will	be	

provided.	The	PIC	will	take	all	actions,	including	reviewing	weather,	flight	battery	requirements,	landing	and	takeoff	

distances,	and	aircraft	performance	data	before	commencement	of	flight.	

PIC & Flight Crewmembers:

Pilot	in	Command	Sections	61.113	(a)	and	(b)	limit	private	pilots	to	non‐commercial	operations.	Because	the	sUAS	

will	not	carry	a	pilot	or	passengers,	the	proposed	operations	can	achieve	the	equivalent	level	of	safety	of	current	

operations	by	requiring	the	PIC	operating	the	aircraft	to	have	a	private	pilot’s	license	rather	than	a	commercial	pilot’s	

license	to	operate	a	sUAS.	Unlike	a	conventional	manned	aircraft,	a	sUAS	is	remotely	controlled	by	a	ground‐based	

operator.	The	operational	area	is	controlled	and	restricted,	and	all	flights	are	planned	and	coordinated	in	advance.	The	

level	of	safety	exceeds	that	provided	by	a	single	individual	holding	a	commercial	pilot’s	certificate	operating	a	

conventional	aircraft.	The	risks	associated	with	the	use	of	a	sUAS	are	so	diminished	from	the	level	of	risk	associated	

with	commercial	operations	contemplated	by	Part	61	allowing	sUAS	use	by	a	sport	pilot	as	the	PIC	exceeds	the	

present	level	of	safety	sought	by	14	C.F.R.	§61.113	(a)	and	(b).	

All	Nexus	Quality	LLC	sUAS	operators	will	have	successfully	completed	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	has	demonstrated,	that	he/she	is	able	to	safely	operate	the	sUAS	in	a	manner	

consistent	with	the	exemption,	including	evasive	and	emergency	maneuvers	and	maintaining	appropriate	distances	

from	people,	vessels,	vehicles	and	structures.	All	operators	will	either	meet	the	flight	review	requirements	specified	in	

14	CFR	§	61.56	or	will	annually	complete	and	log	at	least	4	hours	of	ground	instruction	with	a	certified	flight	

instructor	(CFI)	covering	regulations	and	issues	pertinent	to	commercial	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	demonstrate	qualifications	and	currency	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	shall	“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	prescribed	in	part	43	of	this	chapter...,”	and	others	shall	inspect	or	maintain	the	aircraft	in	

compliance	with	Part	43.	Given	that	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	payload	and	operate	only	in	

restricted	areas	for	limited	periods	of	time.	If	mechanical	issues	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,	perform	any	required	maintenance,	and	keep	a	log	of	any	maintenance	performed.	

Moreover,	the	operator	is	the	person	most	familiar	with	the	sUAS	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	in	
Page	8	

a	marked	off	area	to	ensure	the	maintenance	of	the	sUAS	was	done	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	provided	for	publication	in	the	Federal	Register,	should	it	be	

determined	that	publication	is	necessary:	

Nexus	Quality	LLC	seeks	an	exemption	from	the	following	rules:	

14	CRF	Part	21,	Subpart	H;	14	CFR	Part27;	14	CFR	45.23(b);	14	CFR	§	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	CFR	91.417	(a)	&	(b).	

This	exemption	will	enhance	the	safety	by	reducing	risk	to	the	general	public	and	property	owners	from	the	hazards	

associated	with	performing	the	same	work	with	conventional	rotorcraft	and	aircraft.	

Conclusion

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	of	2012:	size,	weight,	speed,	operating	

capabilities,	proximity	to	airports	and	populated	areas,	operation	within	visual	line	of	sight,	and	national	security;	

provides	more	than	adequate	justification	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	interest	in	many	ways	including	(1)	significantly	improving	

safety	and	reducing	risk	to	human	life,	and	(2)	improving	the	quality	of	services	offered.	

In	closing	the	exemption	being	requested	has	previously	been	granted	to	other	companies	that	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	


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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