August 19, 2015

Exemption No. 12523 Regulatory Docket No. FAA

− 20 15

− 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 letter s 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 ai rcraft system (UAS) to conduct aerial inspections, acquisitions , and research

. See Appendix A for the petition submitted to the FAA des cribing the proposed operat ions 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 P ublic 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 Transportation2

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that relief from 14 CFR part 21 , C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary. The Basis for Our Decision You have requested to use a UAS for aerial data collection 1 or /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 No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA f ound 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 previo usly 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 petit ioner 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 (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.3

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 l ess 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 gre ater 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 operation s 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 ; e lectronic 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 proced ures 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 operati ng documents. It is the operator’s responsibility to track such revisions and present updated and revised4

documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it peti tions 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 exemptio n. The FA A’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 i nspection 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 exempt ion, 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew 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 approp riate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficie ncy, 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 traini ng, 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 (S VFR) 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 symbo l 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 avail able 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 c ommunications or loses its GPS sign al, the UA must return to a pre

- determined location within the pr ivate or controlled

- access property.

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

20. The PIC is prohibited from beginn ing 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 manufacture r if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted 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 num ber, 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.6

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 enforcem ent 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 tha t 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 nonparticipa ting 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 control led

- access property with permission from the prop erty 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 vert ical boundaries of the operational area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions containe d 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.7

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 a rea 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 f

or 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 th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to b e 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 , unle ss sooner superseded or rescinded. Sincerely, / s/ John S. Duncan Director, Flight Standards Service

EnclosuresBrett	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.	§§

6 1.113(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	perm it 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	inone	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	chea per,	more	effective

solution	to	fill the	cu r rent	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	Opera tions 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	2 00	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	p rovide	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	2 00	feet and	up	to	400	feet	if	the	local	FAA	offic e

is	not	notified ,	and	with	an	aircraft	that	has	not	met	our	training	standards and	required	test	flight	times.Reasons	Why	An	Exemptio n	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,	vesse ls,	vehicles	and	structures. C onsidering

Verascan’s proposed	area	of	operations,	and	the	operating	limitations	set	forth

above;	the	parallel	nature	of	private	pilot	aeronautical	knowledge	requirements	to those	of	commercial	pilot	requirements	(See	Exemption	No.	11062);	and	the

airmansh ip	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	o perations.	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,	1108 0,	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	a ndQualification	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	Secti on	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	D JI	Phantom	2 Maintenance	Manual),	and	that	the

UA V is	in	a	condition	for	safe	flight,	as	stated	in	the	conditions	and	limitation s

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	UA V to	the	GCS	for	active	monitoring of	the	flight	path	and	altitude.	This	altitude	information,	combined	with Verascan’s operation	of	th e 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	alti tude	initiation	point	is	auto matically	established	by	the	UAV .	The FAA	has	previously	granted	relief	fro m	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	o perate	the	battery	powered	D JI	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	f or	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	t he	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 operatin g	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	previouslygranted	relief	from	Sec tion	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,	11 109,	11110, 11136,	11138).	30 Reasons	Why	An	Exem ption	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	main tenance	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	mainte nance	on	the UAS	using	the	methods,	techniques,	and	practices	prescribed	in	the	manufacturer’s

mainten ance	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	m anual,	Verascan will maintain	the	equivalent	level	of	safety	established	by	Sections	91.405(a), 91.409(a)(1),	and	91.409(a)(2).	The	D JI	Phantom	2 System Operations Manual	sets forth	airworthiness	requirements	f or	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	advers ely	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	themanufacturer’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	t he 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,	1 1080,	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

requ ests	that	the	FAA	prescribe	special	conditions	for	the	intended	operation	of	theDJI	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.

Pa rt	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

conducti ng	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	pr escribe	special	conditions	pursuant	to	14	C.F.R.	§ 21.16,	for	operation	of	the DJI	P h antom 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	featu res	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	prope ller	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	conta in	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	1 4	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	establishe d	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	Operat ions	Manual	for	a	DJI	Phantom	2.”

IMPORTANT	PROPRIETARY	INFORMATION!!!

At tach ed “ Operations	Manual ” is a PROPRIETARY	DOCUMENT that	support s

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

contain s trade	secret	and	commercial	pr oprietary	information	that	Verascan has	not and	will	not	share	with	others	except	under	appropriate	co nfidentiality	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	attachme nts	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	h ave	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	op erations	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	me et	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'	trai ning	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	V AS

- 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	noexemption	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	2 1	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 ext ent	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 le vel	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	a ttached	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	exempti on	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	fl y	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	"su mmary	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	manuf acturer	ifgreater.	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	afte r	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	o wner	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	regulati ons	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	re quirements.	See	Exemption	No.	11062	(FAA	Docket	No.	2014

- 0352, atp.	14

- 15)	and	Exemption	No.	11374	(FAA	D ocket	No.	2015

- 0091,	at	p.	4). Verascan	will	follow	the	UAS	manufacturer 's	maintenance	requirements.	As provided	in the attached Operations	Manual,	flights	wil l	not	be	conducted	unless	a flight	operations	checklist	is	performed that	includes	all	of	the	aircraft's compon e nts.