August 19, 2015

Exemption No. 12523

Regulatory Docket No. FAA−2015−0986

Mr. Brett Kanda

Partner

Verascan Inc.

4600 Polaris Avenue

Las Vegas, NV 89103

Dear Mr. Kanda:

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

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

including the date it ends.

By letters posted to the public docket on April 13, 2015, and July 22, 2015, you petitioned the 

Federal Aviation Administration (FAA) on behalf of Verascan Inc. (hereinafter petitioner or 

operator) for an exemption. The petitioner requested to operate an unmanned aircraft system 

(UAS) to conduct aerial inspections, acquisitions, and research.

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

the regulations that the petitioner seeks an exemption.

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

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

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

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

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 
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has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that 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 collection1or/and closed set motion picture 

and filming. The FAA has issued grants of exemption in circumstances similar in all material 

respects to those presented in your petition. In Grants of Exemption Nos. 11062 to Astraeus 

Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. 

FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 

11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the 

enhanced safety achieved using an unmanned aircraft (UA) with the specifications described 

by the petitioner and carrying no passengers or crew, rather than a manned aircraft of 

significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA 

good cause to find that the UAS operation enabled by this exemption is in the public interest.

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

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

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

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

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

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

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

delegated to me by the Administrator, Verascan Inc. is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

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

Conditions and Limitations

In this grant of exemption, Verascan Inc. is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

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

when weighing less than 55 pounds including payload. Proposed operations of any 

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

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

not permitted. 

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

exemption holder may use either groundspeed or calibrated airspeed to determine 

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

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

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

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

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

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

U.S. driver’s license.

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

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

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

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

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

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

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

required of the VO.

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

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

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

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

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

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

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

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

operator’s responsibility to track such revisions and present updated and revised 
4

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

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

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

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

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

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

updates or revisions to the operating documents.

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

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

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

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

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

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

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

in a condition for safe operation.

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

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

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

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

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

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

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

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

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

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

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

operated under this exemption, including evasive and emergency maneuvers and 

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

qualification flight hours and currency must be logged in a manner consistent with 
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14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

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

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

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

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

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

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

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

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

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

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

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

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

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

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

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

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

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

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

power recommended by the manufacturer if greater.

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

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

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

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

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

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

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

official upon request.

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

activities at all times. 

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

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

persons, vessels, vehicles, and structures unless:

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

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

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

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

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

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

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

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

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

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

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

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

must include at least the following:

a. Dates and times for all flights;

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

under this grant of exemption;

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

the UAS;

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

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

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

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

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

g. Signature of exemption holder or representative; and

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

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

essential to accomplish the operation.

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

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

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

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

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Brett	Kanda

Partner

Verascan	Inc.

4600	Polaris	Ave.

Las	Vegas,	NV.

89103

E:	brett@verascaninc.com

P:	818-515-5659

W:	www.verascaninc.com

• Verascan Inc.	seeks	exemption	from	the	requirements	of	14	C.F.R.	§§	

61.113(a)	&	(b),	91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	

91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b),	to	operate	an	Unmanned	Aircraft	

System	pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	

2012	(FMRA).	This	exemption	will	permit	Verascan	Inc.	to	operate	a	DJI	

Phantom	2	for	the	commercial	purpose	of	conducting	aerial	inspections,	

acquisitions	and	research	within	the	National	Airspace	System	(NAS)	in	the	

industries	of	agriculture,	construction,	and	engineering.

• Allowing	Verascan	to	commercially	operate	would	improve	efficiency	in	each	

industry	because	of	strict	safety	protocols,	years	of	experience,	and	qualified	

pilots.		Eliminating	the	need	for	personnel	in	hazardous	environments	is	now	

possible	through	the	effective	operations	of	Verascan.		Verascan	is	located	in	

Las	Vegas,	which	has	multiple	advantages	including	being	firmly	planted	in	
one	of	the	6	FAA	designated	test	sites.	 Our	distinct	partnerships	with	UNLV,	

NStec,	and	Space	Information	Laboratories	have	created	a	powerful	group	of	

people	that	are	ready	to	demonstrate	a	positive	representation	of	the	UAV	

industry	in	both	Southern	Nevada	and	on	a	national	level.		Our	advanced	

sensors	and	software	outputs	will	give	businesses	a	cheaper,	more	effective	

solution	to	fill	the	current	gaps	in	their	processes.	Our	teams	of	experienced	

professionals	have	created	an	Operations	Manual	and	Training	Regimen	that	

represent	the	budding	UAV	industry	in	a	positive	light.		

• If	granted	an	exemption,	Verascan	would	adhere	to	the	attached	Operations	

Manual	in	a	strict	manner	by	conducting	commercial	flights	with	a	P.I.C.	

holding	a	Private	Pilots	License,	necessary	medical	clearance,	a	V.O.	with	

U.S.A.F.	Unmanned	training	credentials,	fly	within	V.L.O.S,	fly	under	200	feet	

and	only	to	400	feet	if	the	local	FAA	office	is	notified,	and	follow	the	

guidelines	highlighted	by	the	FAA	as	well	as	our	unique	Operations	Manual.		

Conducting	these	flights	with	proper	risk	management,	pre-flight	checklists,	

flight	checklists,	and	post-flight	checklists	would	provide	a	higher	level	of	

safety	to	the	community	that	we	would	be	flying	in	and	the	nation	as	a	whole.		

Verascan	Inc.	would	not	conduct	commercial	flights	in	crowded	areas,	at

night,	at	altitudes	exceeding	200	feet	and	up	to	400	feet	if	the	local	FAA	office	

is	not	notified,	and	with	an	aircraft	that	has	not	met	our	training	standards	

and	required	test	flight	times.		
Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	61.113(a)	And	

(b)	Would	Not	Adversely	Affect	Safety:	Verascan	submits	that	the	equivalent	level	

of	safety	established	by	Section	61.1	DJI	Phantom	2	unless	that	PIC	has	

demonstrated,	through	the	DJI	Phantom	2	UAV	training	and	currency	requirements,	

that	the	PIC	is	able	to	safely	operate	the	DJI	Phantom	2	in	a	manner	consistent	with	

this	exemption,	including	evasive	and	emergency	maneuvers	and	maintaining	

appropriate	distances	from	people,	vessels,	vehicles	and	structures.	Considering	

Verascan’s	proposed	area	of	operations,	and	the	operating	limitations	set	forthabove;	the	parallel	nature	of	private	pilot	aeronautical	knowledge	requirements	to	

those	of	commercial	pilot	requirements	(See	Exemption	No.	11062);	and	the	

airmanship	skills	necessary	to	safely	operate	the	DJI	Phantom	2,	Verascan	submits	

that	the	additional	manned	airmanship	experience	of	a	commercially	certificated	

pilot	would	not	correlate	to	the	airmanship	skills	necessary	for	Verascan’s	specific	

proposed	flight	operations.	Additionally,	the	FAA	has	previously	granted	relief	from	

Section	61.113(a)	and	(b)	specific	to	UAS,	in	circumstances	similar,	in	all	material	

respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	11062,	11063,	11064,	

11065,	11066,	11067,	11080,	11109,	11110,	11112,	11136,	11138).	As	in	

Exemption	No.	11109,	Verascan	will	not	allow	any	PIC	to	operate	the	DJI	Phantom	2	

unless	that	PIC	has	demonstrated	through	the	DJI	Phantom	2	UAV	training	and	

currency	requirements,	that	the	PIC	is	able	to	safely	operate	the	DJI	Phantom	2	UAV

in	a	manner	consistent	with	this	exemption,	including	evasive	and	emergency	

maneuvers	and	maintaining	appropriate	distances	from	people,	vessels,	vehicles	

and	structures.	A	complete	description	of	the	DJI	Phantom	2	Training	and	
Qualification	requirements	is	set	forth	in	the	attached	Operations	Manual.	

Operations	Manual	contains	proprietary	information	and	is	to	be	held	in	a	separate	

file	pursuant	to	14	C.F.R.	§	11.35(b).	

Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.7(a)	Would	

Not	Adversely	Affect	Safety:	The	equivalent	level	of	safety	established	by	Section	

91.7(a)	will	be	maintained	because	prior	to	every	flight,	Verascan	will	ensure	that	

the	DJI	Phantom	2	is	in	an	airworthy	condition	based	upon	the	aircraft’s	conformity	

to	its	type	design,	including	compliance	with	its	operating	documents	(i.e.,	the	DJI	

Phantom	2	User	Manual	and	the	DJI	Phantom	2	Maintenance	Manual),	and	that	the	

UAV	is	in	a	condition	for	safe	flight,	as	stated	in	the	conditions	and	limitations	

contained	herein.	

Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.121	Would	

Not	Adversely	Affect	Safety:	The	equivalent	level	of	safety	established	by	Section	

91.121	will	be	maintained	because	the	altitude	information	of	the	DJI	Phantom	2	

will	be	provided	to	the	PIC	via	GPS	equipment	and	a	radio	communications	

telemetry	data	link,	which	downlinks	from	the	UAV	to	the	GCS	for	active	monitoring	

of	the	flight	path	and	altitude.	This	altitude	information,	combined	with	Verascan’s	

operation	of	the	DJI	Phantom	2	within	visual	line	of	sight,	at	or	below	400	feet	AGL,	

will	ensure	a	level	of	safety	equivalent	to	Section	91.121.	The	altitude	information	

will	be	generated	by	GPS	equipment	installed	onboard	the	aircraft.	Prior	to	each	

flight,	a	zero	altitude	initiation	point	is	automatically	established	by	the	UAV.	The	

FAA	has	previously	granted	relief	from	Section	91.121	specific	to	UAV,	in	

circumstances	similar,	in	all	material	respects,	to	those	presented	herein	(e.g.	
Exemption	Nos.	11062,	11063,	11064,	11065,	11066,	11067,	11080,	11109,	11112,	

11136,	11138).	

Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.151(b)	

Would	Not	Adversely	Affect	Safety:	A	grant	of	this	exemption	would	ensure	an	

equivalent	level	of	safety	established	by	14	C.F.R.	Section	91.151(b)	as	a	result	of	(1)	

the	technical	specifications	of	the	DJI	Phantom	2;	(2)	the	limitations	on	the	proposed	

flight	operations;	and	(3)	the	location	of	the	proposed	flight	operations.	Accordingly,	

Verascan	will	ensure	that	it	will	safely	operate	the	battery	powered	DJI	Phantom	2	

during	daylight	hours	in	VMC	conditions,	under	VFR,	with	enough	battery	power	to	

fly	for	a	total	duration	of	15	minutes	to	the	first	point	of	intended	landing	and,	

assuming	normal	cruising	speed,	to	fly	after	that	for	at	least	five	minutes	(i.e.,	25	

percent	battery	power	remaining).	Similar	to	the	FAA’s	Grant	of	Exemption	No.	

11109,	AgScan	hereby	submits	that	the	technical	specifications	of	the	DJI	Phantom	

2;	the	limitations	on	the	proposed	flight	operations;	and	the	location	of	the	

proposed	operations,	will	ensure	an	equivalent	level	of	safety	established	by	14	

C.F.R.	Section	91.151(b).	Furthermore,	an	equivalent	level	of	safety	will	be	ensured	

as	the	DJI	Phantom	2	provides	audible	and	visual	warnings	to	the	PIC	at	the	GCS	

when	the	UA	reaches	20	percent	and	10	percent	of	battery	power	remaining.	

Significantly,	previous	exemptions	granted	by	the	FAA	concerning	Section	91.151	

establish	that	safety	is	not	adversely	affected	when	the	technical	characteristics	and	

operating	limitations	of	the	UAS	are	considered.	Relief	has	been	granted	for	manned	

aircraft	to	operate	at	less	than	the	minimums	prescribed	in	Section	91.151,	

including	Exemption	Nos.	2689,	5745,	and	10650.	Moreover,	the	FAA	has	previously	
granted	relief	from	Section	91.151	specific	to	UAS,	in	circumstances	similar,	in	all	

material	respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	8811,	10808,	

10673,	11042,	11062,	11063,	11064,	11065,	11066,	11067,	11080,	11109,	11110,	

11136,	11138).	30	

Reasons	Why	An	Exemption	From	The	Requirements	Of	Sections	91.405(a),	

91.407(a)(1),	91.409(a)(1)	&	(a)(2),	And	91.417(a)	&	(b)	Would	Not	Adversely	

Affect	Safety:	In	seeking	this	exemption,	Verascan	submits	that	an	equivalent	level	

of	safety	with	regard	to	the	regulatory	maintenance	and	alteration	requirements	

established	by	Sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	

91.417(a)	&	(b)	will	be	met	because	Verascan	will	use	manufacturer	trained	

technicians	to	perform	maintenance,	alterations,	or	preventive	maintenance	on	the	

UAS	using	the	methods,	techniques,	and	practices	prescribed	in	the	manufacturer’s	

maintenance	manual.	Furthermore,	Verascan	will	document	and	maintain	all	

maintenance	records	for	the	DJI	Phantom	2.	Since	the	DJI	Phantom	2	will	be	

inspected	as	prescribed	by	the	manufacturer’s	maintenance	manual,	Verascan	will	

maintain	the	equivalent	level	of	safety	established	by	Sections	91.405(a),	

91.409(a)(1),	and	91.409(a)(2).	The	DJI	Phantom	2	System	Operations	Manual	sets	

forth	airworthiness	requirements	for	the	UA,	including	preflight	inspections,	as	well	

as	scheduled	maintenance	after	every	three	months,	every	year	or	300	flight	hours	

(whichever	comes	first),	and	after	every	600-flight	hours.	Likewise,	the	exemption	

sought	will	not	adversely	affect	safety	because	Verascan	will	use	manufacturer	

trained	technicians	to	perform	maintenance,	alterations	or	preventive	maintenance	

on	the	UAS	using	the	methods,	techniques,	and	practices	prescribed	by	the	
manufacturer’s	maintenance	manual.	The	DJI	Phantom	2	Operations	Manual	details	

procedures	for	inspection,	firmware	upgrades,	motor	testing,	and	motor	

replacement.	A	complete	description	of	the	DJI	Phantom	2	maintenance	

requirements	is	set	forth	in	the	DJI	Phantom	2	Operations	Manual,	which	is	

attached.	Attached	Operations	Manual	contains	proprietary	information	and	is	to	be	

held	in	a	separate	file	pursuant	to	14	C.F.R.	§	11.35(b).	Furthermore,	the	exemption	

sought	would	maintain	an	equivalent	level	of	safety	established	by	Sections	91.407,	

91.417(a)	and	91.417(b),	because	all	maintenance	of	the	DJI	Phantom	2	will	be	

performed	by	manufacturer	trained	technicians,	which	will	document	and	maintain	

maintenance	records	for	the	UAS.	Significantly,	previous	exemptions	granted	by	the	

FAA	concerning	the	DJI	Phantom	2	and	Sections	91.405(a),	91.407(a)(1),	

91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b)	establish	that	safety	is	not	adversely	

affected	when	the	technical	characteristics	and	operating	limitations	of	the	UAS	are	

DJI	Phantom	2	Operations	Manual,	and	the	technical	aspects	of	the	DJI	Phantom	2

Verascan	submits	that	safety	will	not	be	adversely	affected	by	granting	exemption	

from	14	C.F.R.	Sections	91.405(a),	91.407(a)(1)	and	(a)(2),	91.409(a)(2),	and	

91.417(a)	and	(b).	The	FAA	has	previously	granted	relief	specific	to	UAS	in	

circumstances	similar,	in	all	material	respects,	to	those	presented	herein	(e.g.	

Exemption	Nos.	11062,	11063,	11064,	11065,	11066,	11067,	11080,	11109,	11110,	

11112,	11136,	11138).	7.	The	FAA	May	Prescribe	Any	Other	Conditions	For	Safe	

Operation.	In	accordance	with	Section	333	of	the	FAA	Modernization	and	Reform	

Act	of	2012	(FMRA)	and	14	C.F.R.	§	21.16	entitled	Special	Conditions,	Verascan

requests	that	the	FAA	prescribe	special	conditions	for	the	intended	operation	of	the	
DJI	Phantom	2,	which	contain	such	safety	standards	that	the	Administrator	finds	

necessary	to	establish	a	level	of	safety	equivalent	to	that	established	by	14	C.F.R.	

Part	21,	Subpart	H,	and	14	C.F.R	§§	61.113(a)	&	(b),	91.7	(a),	91.121,	91.151(b),	

91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).	2	Such	special	

conditions	will	permit	Verascan’s	safe	operation	of	the	UA	for	the	limited	purpose	of	

conducting	aerial	acquisitions	over	certain	rural	areas	of	the	United	States	for	

compensation	or	hire.	FMRA	Section	333	sets	forth	the	requirements	for	

considering	whether	a	UAS	will	create	a	hazard	to	users	of	the	NAS	or	the	public,	or	

otherwise	pose	a	threat	to	national	security;	and	further,	provides	the	authority	for	

such	UAS	to	operate	without	airworthiness	certification	in	accordance	with	any	

requirements	that	must	be	established	for	the	safe	operation	of	the	UAS	in	the	NAS.	

Likewise,	the	Administrator	may	prescribe	special	conditions	pursuant	to	14	C.F.R.	§	

21.16,	for	operation	of	the	DJI	Phantom	2,	since	the	airworthiness	regulations	of	14	

C.F.R.	Part	21	do	not	contain	adequate	or	appropriate	safety	standards,	due	to	the	

novel	or	unusual	design	features	of	the	aircraft.	Section	21.16,	entitled	Special	

Conditions,	states	the	following:	If	the	FAA	finds	that	the	airworthiness	regulations	

of	this	subchapter	do	not	contain	adequate	or	appropriate	safety	standards	for	an	

aircraft,	aircraft	engine,	or	propeller	because	of	a	novel	or	unusual	design	feature	of	

the	aircraft,	aircraft	engine	or	propeller,	he	prescribes	special	conditions	and	

amendments	thereto	for	the	product.	The	special	conditions	are	issued	in	

accordance	with	Part	11	of	this	chapter	and	contain	such	safety	standards	for	the	

aircraft,	aircraft	engine	or	propeller	as	the	FAA	finds	necessary	to	establish	a	level	of	

safety	equivalent	to	that	established	in	the	regulations.	See	14	C.F.R.	§	21.16.	
Therefore,	in	accordance	with	FMRA	Section	333	and	14	C.F.R.	§	21.16,	the	FAA	may	

prescribe	special	conditions	for	Verascan’s	intended	operation	of	the	DJI	Phantom	2,	

which	contain	such	safety	standards	that	the	Administrator	finds	necessary	to	

establish	a	level	of	safety	equivalent	to	that	established	by	14	C.F.R.	Part	21,	Subpart	

H,	and	14	C.F.R	Sections	61.113(a)	&	(b),	91.7(a),	91.121,	91.151(b),	91.405(a),	

91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).

The	extent	to	which	we	seek	relief	from	the	listed	sections	is	described	in	the	

attached	“Verascan	Operations	Manual	for	a	DJI	Phantom	2.”

IMPORTANT	PROPRIETARY	INFORMATION!!!

Attached	“Operations	Manual” is a	PROPRIETARY	DOCUMENT	that	supports

Verascan’s	petition.	Attachment	is	referenced	in	the	request	for	exemption	and	

contains	trade	secret	and	commercial	proprietary	information	that	Verascan	has	not	

and	will	not	share	with	others	except	under	appropriate	confidentiality	agreements.	

The	Verascan Operations	Manual	attachment	contains	operating	conditions	and	

procedures	that	have	been	developed	exclusively	by	Verascan,	and	that	are	not	

available	to	the	public.	Verascan	is	requesting	that	these	attachments	be	treated	as	

proprietary	information	pursuant	to	14	C.F.R.	Section	11.35,	and	maintains	that	they	

are	protected	from	release	under	the	Freedom	of	Information	Act.	See	5	U.S.C.	552	et	

seq.

The	extent	of	relief	you	seek,	and	the	reason	you	seek	

relief;

14	C.F.R.	§	61.113:	Private	Pilot	Privileges	and	Limitations

Verascan	Inc.	seeks	exemption	from	14	CFR	§	61.113,	which	restricts	private	pilots	

from	flying	aircraft	for	compensation	or	hire	and	would	also	require	a	second	class	

medical	certificate.	The	purpose	of	Part	61	is	to	ensure	that	the	skill	and	competency	

of	any	PIC	matches	the	airspace	in	which	the	PIC	will	be	operating,	as	well	as	

requiring	certifications	if	the	pilot	is

carrying	passengers	or	cargo	for	hire.	While	the	UAS	will	be	operated	as	part	of	a	

commercial	operation,	they	carry	neither

passengers	nor	cargo.	In	the	Grant	of	Exemption	in	FAA	Docket	No.	FAA-2015-0986,	

the	FAA	determined	that	the	unique	characteristics	of	UAS	operation	outside	of	

controlled	airspace	did	not	warrant	the	additional	cost	and	restrictions	attendant	

with	requiring	the	PIC	to	have	a	commercial	pilot	certificate	and	a	class	II	medical	

certificate.	The	FAA	has	also	determined	that	the	required	knowledge	for	a	

commercial	pilot	covers	the	same	fundamental	principles	as	a	private	pilot.	The	FAA	

has	also	granted	exemptions	allowing	operations	by	people	who	hold	an	airline	

transport,	commercial,	private,	recreational,	or	sport	pilot	certificate	with	a	current	

FAA	airman	medical	certificate	or	a	valid	U.S.	driver's	license	issued	by	a	state	or	the	

Federal

Government.	The	PIC	must	also	meet	the	flight	review	requirements	specified	in	14	

CFR	§	61.56.	See	FAA	Exemption	No.	11374.	Verascan	will	ensure	the	PIC	will	meet	

the	requirements	listed	in	the	above	paragraph.	Verascan	will	also	ensure	the	PIC	

will	have	completed	the	manufacturers'	training	guidelines	outlined	in	the	Manuals.	

The	FAA	stated	in	its	grant	of	an	exception	to	Astraeus	Aerial	the	"the	FAA	considers	

the	overriding	safety	factor	for	the	limited	operations	proposed	by	the	petitioner	to	

be	the	airmanship	skills	acquired	through	VAS-specific	flight	cycles,	flight	time,	and	

specific	make

and	model	experience,	culminating	in	verification	through	testing."	The	restrictions	

Verascan	has	placed	on	its	UAS	operations	meet	or	exceed	the	restrictions	similarly	

imposed	on	Astraeus	Aerial	in	FAA	Docket	No.	F	AA-20	14-0352	and	those	listed

in	the	FAA's	"summary	grant"	process.	

14	C.F.R.	§	91.7(a):	Civil	Aircraft	Airworthiness

Verascan	seeks	an	exemption	from	14	C.P.R.§	91.7(a),	which	requires	that	a	civil	

aircraft	be	in	airworthy	condition	to	be	operated.	The	FAA	has	stated	that	no	
exemption	is	required	to	the	extent	that	the	requirements	of	Part	21	are	waived	or	

found	inapplicable.	Accordingly,	Verascan	requests	that	the	requirements	for	

Section	91.7	be	treated	in	accordance	with	FAR

Part	21	Subpart	H.	See	Grant	of	Exemption	No.	11062

14	C.F.R.	§	91.121:	Altimeter	Settings

This	petition	seeks	an	exemption	from	14	C.F.R.	§	91.121,	which	requires	a	person	

operating	an	aircraft	to	maintain	cruising	altitude	or	flight	level	by	reference	to	an	

altimeter	that	is	set	to	the	elevation	of	the	departure	airport.	The	UASs	proposed	

here	use	both	barometricpressure	sensors	and	GPS	to	determine	altitude	but	do	not	

have	the	ability	to	set	in	a	current	altimeter	setting.	An	exemption	is	required	to	the	

extent	that	the	UAS	does	not	have	a	barometric	altimeter	setting.	The	altitude	of	the	

UAS	is	monitored	by	the	PIC	on	the	ground	control	station	and	by	the	visual	

observer.

Extent	and	Reason	for	Which	Relief	is	Sought:	The	FAA	has	stated	that	an	equivalent	

level	of	safety	can	be	achieved	if	the	aircraft	will	be	operated	at	or	below	400	feet	

AGL	and	within	visual	line-of	sight	in	addition	to	GPS	based	altitude	information	

relayed	in	real	time	to	the	operator.	See	Grant	of	Exemption	No.	11062,	p.	20-21.	As	

the	attached	Manuals	indicate,	the	UAS	will	be	operated	at	or	below	400	feet	AGL	

and	otherwise	comply	with	the	limitations	in	the	Grant	of	Exemption	No.	11062.	

14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions

Verascan	requests	an	exemption	from	14	C.F.R.	§	91.15l(a)'s	fuel	requirements	for	

flight	in	VFR	conditions.	Section	91.151	states:

(a)	No	person	may	begin	a	flight	in	an	airplane	under	VFR	conditions	unless	

(considering	wind	and	forecast	weather	conditions)	there	is	enough	fuel	to	fly	to	the	

first	point	of	intended	landing	and,	assuming	normal	cruising	speed	-(1)	During	the	

day,	to	fly	after	that	for	at	least	30	minutes;	or	(2)	At	night,	to	fly	after	that	for	at	

least	45	minutes.	Here,	the	technological	limitations	on	the	UAS	battery	power	

means	that	no	meaningful	flight	operations	can	be	conducted	while	maintaining	a	

30	minute	reserve.	The	aircraft	are	battery	powered	with	a	maximum	flight	time	of	

approximately	24	minutes	for	the	Phantom	2.	The	PIC	will	ensure	that	before	each	

flight,	there	is	enough	available	power	for	the	UAS	to	conduct	the	intended	

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

power	recommended	by	the	manufacturer	if	greater.

Extent	and	Reason	for	Which	Relief	is	Sought:	The	FAA	has	stated	that	an	equivalent	

level	of	safety	is	provided	if	the	UAS	flight	is	conducted	under	daytime	VFR	flight	

conditions	using	VLOS,	and	terminated	with	at	least	25%	reserve	battery	power	still	

available.	See	Grant	of	Exemption	No.	11062.	The	FAA's	"summary	grant"	process	

provides	that	the	PIC	is	prohibited	from	beginning	a	flight	unless	there	is	enough	

available	power	to	conduct	the	intended	operation	and	to	operate	after	that	for	at	

least	five	minutes	or	with	the	reserve	power	recommended	by	the	manufacturer	if	
greater.	See	FAA	Exemption	No.	11374	(FAA	Docket	No.	2015-0091	at	p.	5).	The	

Manuals	here	provide	that	the	PIC	will	ensure	that	before	each	flight,	there	is	

enough	available	power	for	the	UAS	to	conduct	the	intended	operation	and	to	

operate	after	that	for	at	least	five	minutes	or	with	the	reserve	power	recommended	

by	the	manufacturer	if	greater.	

14	C.F.R.	§§	91.405(a),	91.407(a)(l),	91.409(a)(1)(a)(2);	91.417(a)	and	(b):	

Maintenance	Inspections

Verascan	seeks	an	exemption	from	the	maintenance	inspection	requirements	

contained	in	14	C.P.R.§	91.405(a),	91.407(a)(l),	91.409(a)(2);	91.417(a)	and	(b).	

These	regulations	specify	maintenance	and	inspection	standards	in	reference	to	14	

C.P.R.	Part	43.	See,	e.g.,	14	C.P.R.§	91.405(a)	(stating	that	each	owner	or	operator	of	

an	aircraft	"[s]hall	have	the	aircraft	inspected	as	prescribed	in	subpart	E	of	this	part	

and	shall	between	required	inspections	...	have	discrepancies	repaired	as	prescribed	

in	part	43	of	this	chapter").	An	exemption	from	these	regulations	is	needed	because	

Part	43	and	these	sections	only	apply	to	aircraft	with	an	airworthiness	certificate,	

which	the	UAS	proposed	here	will	not	have.

Extent	and	Reason	for	Which	Relief	is	Sought:	An	equivalent	level	of	safety	will	be	

achieved	because	maintenance	and	inspections	will	be	performed	in	accordance	

with	the	Manuals.	This	includes	maintenance,	overhaul,	replacement,	and	preflight	

inspection	requirements.	See	Exemption	No.	11062	(FAA	Docket	No.	2014-0352,	

atp.	14-15)	and	Exemption	No.	11374	(FAA	Docket	No.	2015-0091,	at	p.	4).		

Verascan	will	follow	the	UAS	manufacturer's	maintenance	requirements.	As	

provided	in the	attached	Operations	Manual,	flights	will	not	be	conducted	unless	a	

flight	operations	checklist	is	performed that	includes	all	of	the	aircraft's	

components.