City of Burleson-Public Works Department, UAV Petition for Exemption

U.S. DepartmentofTransportation Docket ManagementSystem 1200 NewJerseyAvenue, SE Washington, D.C. 20590 Kevin North Assistant DirectorofPublic Works City of Burleson 141West Renfro Street Burleson,Texas76028 BASIS FOR PETITION Petitioner, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT, pursuanttothe provisions ofthe Federal Aviation Regulations {14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, Special Rules forCertain Unmanned Aircraft Systems, hereby petitionsthe Administrator to commercially operate the DJI Phantom 2Vision+, in the National Airspace System (NAS), and for an exemption from the requirements of:
14C.F.R §§ 61.113{a) 

### & {b)
14 CFR 45.23{b) 91.7{a), 91.121, 91.151{b), 91.405(a), 91.407{a){1), 91.409{a)(1) 

### & (a){2), and 91 Name and Address ofthe Petitioner The name and address ofthe Petitionerand pointofcontact is: Kevin North Assistant DirectorofPublic Works City of Burleson Burleson, Texas 76028 Office: (817)426-9830 Email: knorth@burlesontx.com PREFACE: The Federal Aviation Act expressly grantsthe FAA the authorityto issue exemptions. This statutory authority by itsterms includes exempting civil aircraft, as the term is defined under §40101 oftheAct, that includes UAS, from the requirementthatall civil aircraft must have acurrent airworthiness certificate. The Administrator maygrant an exemption from a requirement ofa regulation prescribed under subsection (a) or(b) ofthis section orany sections 44702- 44716 ofthistitle iftheAdministratorfindsCity of Burleson-Public Works Department, UAV Petition for Exemption

the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). The City ofBurleson-Public Works Department proposesto use one or more Unmanned Aerial Drones (DJI PHANTOM 2Vision+), forthefollowing uses:

• Inspections ofcity-owned stormwatersystems • Inspections ofcity-owned waterand wastewater infrastructure systems • Inspections ofcity-owned rights-of-way • Inspections ofcity-owned orcity-funded infrastructure improvement projects • Bridge inspections • Assist with damage assessments orsituational status reports during emergency response operations • Evaluations within the city related toflora 

### & fauna (vegetation 

### & wildlife) issues. • Supportto lawenforcementand fire departmentsduring response operations. • Assist with site security duringcity-sponsored events (i.e. SummerConcert Series, parades, etc.) This aircraft has four rotors and four motors in aquadcopterconfiguration (X4). It is only capable of vertical takeoffand landings. This UAS weighs less than 55 lbs. including payload, can fly, under normal conditions ataspeed ofno morethan 30 knots and has the capabilityto hover, and move in thevertical and horizontal plane simultaneously.This UAS is equipped with GPS and auto-return function tothe predetermined safe landing area as well as allowing reading ofmagnetic interference thatcan cause loss offGPS signal. The UAS will operate only in line ofsight and will operate onlywithin the limitsofpublic rights ofwayoreasements. Such operationswill be conducted to insure thatthe UAS will "not create a hazard to users ofthe national airspace system orthe public." (Reform Act Section 333 (b)). This exemption application is expressly submitted tofulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This lawdirectsthe Secretary ofTransportation to considerwhether certain unmanned aircraftsystems mayoperate safely in the national airspace system (NAS) before completion ofthe rule making required underSection 333 ofthe Reform Act. In makingthis determination,the Secretary is required to determinewhich types of UASs do notcreate ahazard to users ofthe NAS orthe public or pose athreatto national security in lightofthefollowing:

• The UAS's size, weight, speed and operational capability; • Operation ofthe UAS in close proximityto airports and populated areas; and • Operation ofthe UAS withinvisual line ofsight ofthe operator. Reform Act§ 333 (a). Secretarydeterminesthat such vehicles "mayoperate safely in the national airspace system, the Secretary shall establish requirementsforthe safe operation ofsuch aircraft in the national airspace system." ld. §333(c).City of Burleson-Public Works Department, UAV Petition for Exemption

The Federal Aviation Act expressly grants the FAA the authorityto issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under§40101 oftheAct, that includes UAS, from the requirementthatall civil aircraft must have acurrent airworthiness certificate. The Administrator may grant an exemption from a requirementofa regulation prescribed under subsection (a) or(b) ofthis section orany sections 44702-44716 ofthis title iftheAdministratorfinds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). RELIEF OVERVIEW Given the small size ofthe UAS involved and the restricted environmentwithin which theywill operate, the applicantfalls withinthat zone ofsafety (an equivalent level ofsafety) in which Congress envisioned thatthe FAA allow commercial operations ofUASs to commence immediately. Also due tothe size of the UASs and the restricted areas in whichthe relevant UAS will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authoritycontained in the Federal Aviation Act, as amended; the strong equivalent level ofsafetysurrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs foraerial inspections, surveying, photography and videography, the grantofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests thatthe FAA grantthe requested exemption. AIRCRAFTAND EQUIVALENT LEVEL OF SAFETY CITY OF BURLESON-PUBLIC WORKS DEPARTMENT proposes thatthe exemption requested herein apply to civil aircraftthat have the characteristics and thatoperate with the limitations listed herein. These limitations provide forat least an equivalent oreven higher level ofsafetyto operations underthe current regulatory structure because the proposed operations represent asafety enhancementtothe alreadysafe aerial inspections, surveying and photography and videography operations conducted with conventional aircraft. These limitationsand conditionsto which CITY OF BURLESON-PUBLIC WORKS DEPARTMENT agrees to be bound when conducting commercial operations underan FAA issued exemption include: 

### 1. The UAS will weigh less than 55 lbs. 2. Flights will be operated within line ofsight ofa Pilot-In Command (PIC) and a Safety Observer (SO). 3. Maximum total flighttime foreach operational flightwill be 30 minutes or less. Flights will be terminated at 25% battery power reserve should that occur priorto the 30 minute limit.City of Burleson-Public Works Department, UAV Petition for Exemption

4. Flights will be operated at an altitude ofno more than 400feetAGL or, not morethan 200 feet above an elevated platformforwhich filming is planned. 5. Minimum crewforeach operation will consist ofthe UAS Pilot and oneVisual Observer. 6. The UAS will onlyoperate withinthe defined projectarea, the boundaries ofwhich will be determined by the UAS Pilot-In-Command (PIC) based on the site-specific activities and speed ofthe UAS required forthe operation, and coordinated with thejurisdictional FAA FSDO and local government officials as applicable. 7. A briefing will be conducted in regards to the planned UAS operations priorto each day's operation. Itwill be mandatorythatall personnel whowill be performing dutieswithin the boundaries ofthe project be present forthis briefing. 8. The UAS Pilot and Safety Observerwill be able to communicate byvoice and/ortwoway radio communication system at all times. 9. The operations ofthe UAS will be limitedto daylight-onlyoperations. 10. Ifthe UAS loses communications or loses its GPS signal, the UAS will have the capabilityto return to a pre- determined location within the Project Perimeterand land safely. 11. The UAS will have the capabilityto abortflight in case of unpredicted obstacles or emergencies. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirementsforthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized by the Applicant, an exemptionfrom Part 21 Subpart H meets the requirementsofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirementforan airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstratesthatthe UAS operated withoutan airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as CITY OF BURLESON-PUBLIC WORKS DEPARTMENT, UAV Petition for Exemption safe, orsafer, than aconventional aircraft (fixed wing or rotorcraft) operatingwith an airworthiness certificate without the restrictions and conditions proposed. In consideration ofthe speed, weight, size, and limited operating area associated withthe unmanned aircraft and its operation, the CITYOF BURLESON-PUBLIC WORKS DEPARTMENT's operation ofDJI Phantom 2Vision+, UAS meetsthe conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, the CITY OF BURLESON-PUBLIC WORKS DEPARTMENT requests relieffrom Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) 

### & (a)(2), and 91.417(a) 

### & (b), as these sections set forth requirementsfor maintenancethatonlyapplytoaircraftwith an airworthiness certificate. CITY OF BURLESON-PUBLIC WORKS DEPARTMENT submitsthatthe requested relief is propersince an equivalentCity of Burleson-Public Works Department, UAV Petition for Exemption

level ofsafetywill be ensured. CITY OF BURLESON-PUBLIC WORKS DEPARTMENT will use experienced personnel ortechnicians as needed to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2Vision+ Instruction Manual). Furthermore, CITY OF BURLESON-PUBLIC WORKS DEPARTMENTwill documentand maintain all maintenance records forthe DJI Phantom 2Vision+ UAS. Relieffrom certain requirements ofSection 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by CITY OF BURLESON-PUBLIC WORKS DEPARTMENTtothe extent necessaryto allow a Pilot in Command (PIC) meetorexceed the described requirements ofoperations set by manufacturer, and who has demonstrated,thatthe PIC is able to safely operate the DJI Phantom 2Vision+ UAS in a mannerconsistent with this exemption, including evasive and emergency maneuversand maintaining appropriate distances from people, vessels, vehicles and structures. CITY OF BURLESON-PUBLIC WORKS DEPARTMENT seeks relieffrom Section 9L7(a), entitled Civil aircraftairworthiness, because the DJI Phantom 2Vision+ UAS do not require an airworthiness certificate in accordance with 14C.F.R. Part 

### 21, Subpart H. As such, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT submitsthat he will ensure thatthe DJI Phantom 2Vision+ UAS is in an airworthy condition, priorto everyflight, by determiningthatthe UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2Vision+ Instruction Manual), and thatthe aircraft are in acondition forsafe flight. CITY OF BURLESON-PUBLIC WORKS DEPARTMENT also seeks an exemption from the requirementsof Section 91.121, entitled AltimeterSettings, as the DJI Phantom 2Vision+ will not have atypical barometricaltimeteronboard. However, altitude information ofthe DJI Phantom 2Vision+ will be provided tothe PIC via Global PositioningSystem {GPS) equipmentand radio communicationstelemetry data link, which downlinksfrom the UAto the GCS foractive monitoringofthe flight path.This altitude information, combined with CITY OF BURLESON-PUBLIC WORKS DEPARTMENT's operation ofthe DJI Phantom 2Vision+ UAS within visual line ofsight, ator below400feetAGL, will ensure a level ofsafety equivalentto Section 91.121. Additionally, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT seeks an exemption from the requirementsofSection 91.151(b), entitled Fuel requirements forflight in VFR conditions. JWR submits that safetywill not be affected by operation ofthe DJI Phantom 2Vision+ duringdaylight hours in visual meteorological conditions (VMC) undervisual flight rules (VFR), with enough battery powerto flyfor a total duration ofapproximately 30 minutesto the first pointofintended landing and, assuming normal cruising speed, to fly afterthatforat least 5 minutes. EXTENTAND REASONING WHY CITY OF BURLESON-PUBLIC WORKS DEPARTMENT SEEKS RELIEF FROM THE LISTED SECTIONS ABOVE: 1. Section 61.113(a) 

### & b).City of Burleson-PublicWorks Department, UAV Petition for Exemption

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC meet all requirements as described in the DJI Phantom 2 Vision+ owner's manual to conduct the proposed UAS flight operations forcompensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only City of Burleson, UAV Petition for Exemption incidental to that business oremployment; and (2) The aircraft does notcarry passengers or propertyfor compensation or hire. As set forth more fully below, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT submits that an equivalent level ofsafety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ UAS unless that PIC has demonstrated that the PIC is able to safely operate either the DJI Phantom 2 Vision+ UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT submits that all flights ofthe DJI Phantom 2 Vision+ 1 UAS, conducted by the PIC pursuant to the grant ofthis Petition: (1) will be incidental to CITY OF BURLESON-PUBLIC WORKS DEPARTMENT's business; and (2) will notcarry passengers or propertyfor compensation or hire.
2. 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow CITY OF BURLESON-PUBLIC WORKS DEPARTMENT to determine that the DJI Phantom 2 Vision+ UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the CITY OF BURLESON-PUBLIC WORKS DEPARTMENT Operations Manual, Monthly Maintenance Log, and DJI Phantom 2Vision+ Instruction Manual). CITY OF BURLESON-PUBLIC WORKS DEPARTMENTseeks the requested relief because the DJI Phantom 2 Vision+ UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, CITY OF BURLESON-PUBLIC WORKS DEPARTMENTwill ensure thatthe DJI Phantom 2 Vision+ UAS are in airworthycondition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2Vision+ Instruction Manual) priorto every flight, and further, determinethatthe aircraft are in condition forsafe flight, as stated in the conditions and limitations below. 3. 91.121. Relieffrom Section 91.121, entitled Altimeter settings, may be required to allow flight operations ofthe DJI Phantom 2 Vision+ UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to airtraffic control (ATC) in feet above ground level (AGL), CITY OF BURLESON-

### City of Burleson-Public Works Department, UAV Petition for Exemption

PUBLIC WORKS DEPARTMENT seeks the requested relief because the DJI Phantom 2 Vision+ UA altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure orfield altitude, before each flight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level ofsafety will be maintained since the DJI Phantom 2Vision+ UA are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information ofthe UA on the heads-up display ofthe GCS.

4. 91.151(b). Relieffrom Section 91.151(b) entitled Fuel requirements forflight in VFR conditions, is requested to the extent required to allow flights ofthe battery powered DJI Phantom 2Vision+ UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 25 minutesto the first point of intended landing and, assuming normal cruising speed, to fly afterthat for at least 5 minutes. CITY OF BURLESON-PUBLIC WORKS DEPARTMENT seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2 Vision+ UA will severely constrain the practicality of any aerial video or still photo flight operations that CITY OF BURLESON-PUBLIC WORKS DEPARTMENT proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications ofthe DJI Phantom 2 Vision+ UAS, the DJI Phantom 2 Vision+ operating documents, and CITY OF BURLESON-PUBLIC WORKS DEPARTMENT's proposed operating limitations, ensure that CITY OF BURLESON-PUBLIC WORKS DEPARTMENT will safely operate the battery powered DJI Phantom 2 Vision+ UA during daylight hours in visual meteorological conditions (VMC), undervisual flight rules (VFR), with enough battery powerto flyforatotal duration of 25 minutes to the first point of intended landing and, assuming normal cruising speed, to fly afterthat for at least 4.5 minutes.
14 CFR 45.23(b) Marking oftheAircraft; Applicable codes of Federal Regulation require aircraft to be marked according to certain specifications. UAV Field Services UASs are, by definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two inch lettering is difficult to place on such small aircraft. CITY OF BURLESON-PUBLIC WORKS DEPARTMENT petition for exemption by placing the "N "number on its fuselage as required by 14 CFR 45.29 (f) so that the pilot, technician, spotter and others working with the UAV will see the markings. The FAA has previously issued exemptionstothis regulation through- Exemption No 10167 and 10700
5. 91.405(a), 91.407(a)(1), 91.409(a)(1) 

### & (a)(2), And 91.417(a) 

### & (b).City of Burleson-Public Works Department, UAV Petition for Exemption

Since Sections 91.405{a), 91.407{a)(1), 91.409{a){1) 

### & (a)(2), and 91.417{a) 

### & (b) only apply to aircraft with an airworthiness certificate, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT requests relieffrom these Sections because the DJI Phantom 2 Vision+ UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+ UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly CITY OF BURLESON-PUBLIC WORKS DEPARTMENT will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the CITY OF BURLESON-PUBLIC WORKS DEPARTMENT aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual). Furthermore, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT will document and maintain all maintenance records for the DJI Phantom 2Vision+ UAS. The Reasons forgrantingthis request are entirelybeneficialtothe public and communityas awhole. Granting the present Petition will further the public interest by allowing CITY OF BURLESON-PUBLIC WORKS DEPARTMENT to safely, efficiently, and economically perform aerial video and photographic surveys and inspections ofconstruction sites, rights ofway, utility easements, and other sites within the City of Burleson, Texas and its extraterritorialjurisdiction (ETJ). This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333{a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system {NAS) before completion of the rule making required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UAS do not create a hazard to users ofthe NAS orthe public orpose athreatto national security in light ofthefollowing:

• The UAS's size, weight, speed and operational capability; • Operation ofthe UAS in close proximityto airports and populated areas; and • Operation ofthe UAS within visual line ofsight ofthe operator. Reform Act § 333 (a). Lastly, the Secretary determines that such vehicles 11may operate safely in the national airspace 

### system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace 

### system." ld. §333{c). Given the small size ofthe UAS involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA 

### must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size ofthe UASs and the restricted areas in which the relevant UAS will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surroundingthe proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for video and photographic operations, the grant of the requested CITY OF BURLESON-PUBLIC WORKS DEPARTMENT, UAV Petition for Exemption is in the public interest. Accordingly, the applicant respectfully requests thatthe FAA grantthe requested exemption. REASONS BENEFICIALTO THE PUBLIC/COMMUNITY

### City of Burleson-Public Works Department, UAV Petition for Exemption

1. 

### The Public Will Benefitfrom Decreased Congestion ofthe NAS. The DJI Phantom 2 Vision+ UA are battery powered and serve as a safe, efficient, and economical alternative to the manned aircrafttraditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 2Vision+ UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the airand on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 2 Vision+ UA does not require an airport to takeoff or land. likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in feweraircraftthat must be handled by airtraffic control duringthe ground, takeoff, departure, arrival, and landing phases offlight operations.
2. The Public Will Benefit From The SafetyAnd Efficiency OfThe DJI Phantom 2Vision+ UAS. Conducting aerial acquisitions with the DJI Phantom 2 Vision+ UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 2Vision+ UAS produce no air pollution, and is the mostviable environmentally conscious alternativetothe cabin class, six cylinder internal combustion engine aircraftthat are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 Vision+ UA, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, ratherthan an internal combustion engine. By using the DJI Phantom 2 Vision+ UAS to perform aerial observation, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 2Vision+ UA (weighing approximately 2 pounds 11 ounces, at their maximum gross weights with length of 16 inches, widths of 16 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 

### 6,000 pounds with a wingspan ofapproximately 42 feet, a length of 34 feet, and a fuel capacity of180 gallons). 3. PerformingAerial Video and Photography, Surveys and Inspections, Operations with the DJI Phantom 2Vision+ UAS Will Benefitthe Economy. In addition to being safe and efficient, the DJI Phantom 2 Vision+ UAS are also provides an economical alternativeto using manned aircraftto conduct similaraerial operations. As such, operation CITY OF BURLESON-PUBLIC WORKS DEPARTMENT, UAV Petition for Exemption ofthe DJI Phantom 2 Vision+ UAS will allowthe CITY OF BURLESON-PUBLIC WORKS DEPARTMENT, to provide qualityservices tothe residents and businesses ofthe City and the Region at minimum costs. Specifically, with the rising cost ofaviation fuel and the Environmental Protection Agency {"EPA") regulatory actions phasing outCity of Burleson-Public Works Department, UAV Petition for Exemption

leaded aviationfuels, agencies must adopt new and alternativetechnology in continue to provide required services at reasonable costs. Operatingthe battery powered DJI Phantom 2Vision+ UAS is one such technologythat notonly allows agencies 

### & companies greateroperational flexibility compared to manned aircraft, but provides such flexibilitywithoutthe high operational cost ofatraditional manned aircraft. By operating the DJI Phantom 2Vision+ UAS, the CITY OF BURLESON-PUBLIC WORKS DEPARTMENT can maintain and hopefully improve our ability to operate and maintain critical infrastructure and at the same time collect important data for further development of system-wide modeling of water, wastewater, stormwater, and roadway systems as well as provide accurate and current data related to environmental issues such as ground cover, vegetation 

### & wildlife habitats.
4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, the CITY OF BURLESON-PUBLIC WORKS DEPARTMENT's proposed operation of the DJI Phantom 2 Vision+ UAS will not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+ UAS will be operated only in compliance with operating documents (i.e., the CITY OF BURLESON-PUBLIC WORKS DEPARTMENT Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the maximum altitude limitationsas perthe requirements of 14C.F.R. § 91.119.
THE REASONS WHY GRANTING THE EXEMPTION WOULD NOTADVERSELYAFFECT SAFETY, OR HOWTHE EXEMPTION WOULD PROVIDE A LEVEL OF SAFETYAT LEAST EQUALTO THAT PROVIDED BYTHE RULE FR OM WHICH CITY OF BURLESON-PUBLIC WORKS DEPARTMENT SEEKS EXEMPTION.
1. Reasons WhyThe DJI Phantom 2Vision+ UA MeetThe Conditions OfThe FAA Modernization and Refo rm Act of2012 (FMRA) Section 333.
In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT's operation of the DJI Phantom 2 Vision+ UAS meetthe conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
In seeking this exemption, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT submits that the DJI Phantom 2 Vision+ UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics ofthe DJI Phantom 2 Vision+ UAS; (b) the pilot certification requirement; and (c) the specificoperating limitations. a. The Specifications OfThe DJI Phantom 2Vision+ UAS Demonstrate Its Safe Characteristics.
The DJI Phantom 2Vision UAS do not create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.
i. Technical Specifications ofThe DJI Phantom 2Vision+ UAS.City of Burleson-Public Works Department, UAV Petition for Exemption

The technical specifications ofthe DJI Phantom 2 Vision+ UAS are set forth by the DJI Phantom 2Vision+ Specifications and Data Sheet attached. ii. The DJI Phantom 2Vision+ UAS Autonomous FlightAnd Navigation Modes Enable The UAS To Remain Within A Defined Operational Area. The DJI Phantom 2 Vision+ UAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 2Vision+ UAS are included in the User Manuals. iii. The DJI Phantom 2Vision+ UASs Are Designed ForAutomatic Return To Home Point Or Hover In The Event OfLoss OfThe Control Link Or Navigation. When the Control Link is lost, the DJI Phantom 2 Vision+ UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+ UA does not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoffposition and shutdown. A complete description ofthe Failsafe Functions ofthe DJI Phantom 2Vision+ UA are set forth in the DJI Phantom 2Vision+ User Manual. iv. The DJI Phantom 2Vision+ GCS And Its Operation.
A complete description ofthe operation and specifications ofthe DJI Phantom 2Vision+ GCS and flight control software is provided in the DJI Phantom 2Vision+ User Manual. b. Flights Of DJI Phantom 2Vision+ UAS Will Be Conducted PursuantTo Specific Operating Limitations.
In seeking this exemption, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT proposes to commercially operate DJI Phantom 2 Vision+ UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant tothe following specific operating limitations:
1. Operations authorized bythis grant ofexemption will be limitedtothe following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 2Vision+ Unmanned Aircraft Systems. Proposed operations ofany otheraircraftwill require a new petition ora petition to amend this grant.
2. UAS operations underthis exemption will be limited to conducting operationsforthe purpose ofaerial video and photography.
3. The UA may not be flown at an indicated airspeed exceeding 20 knots.

### City of Burleson-Public Works Department, UAV Petition for Exemption

4. The UA must be operated at an altitude ofno more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feetAGL.
5. The UAs must be operated withinvisual line ofsight (VLOS) ofthe PIC atall 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. 6. The use of first person view camera to satisfy the visual line of site by the PIC or safetyobserver (SO) is not permitted.
7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging ortexting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or herdesignation forthe duration ofthe flight. The PIC must ensure thatthe SO can perform thefunctions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operatethe camera orother instruments. 9. The operating documents and the grant ofexemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption 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 responsibilitytotrack such revisions and present updated and revised documentstothe Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant ofexemption. Ifthe operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition foramendmentto its grant of exemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions tothe operating documents. 10. Priorto each flight the PIC must inspectthe UAS to ensure that it is in acondition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating untilthe necessary maintenance has been performed and the UAS is found to be in acondition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.
11. Any UAS that has undergone maintenance or alterations that affect the UAS operation orflight characteristics, e.g. replacement of aflight critical component, must

### City of Burleson-Public Works Department, UAV Petition for Exemption

undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections ofthe operating documents. 13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature ofthe authorized person returning the UAS to service. 15. Each UASs operated underthis exemption must comply with all manufacturerSafety Bulletins. 16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 17. The PIC must meet or exceed all requirements as set forth by manufacturer in order to justifiably operate the DJI Phantom 2 Vision+, or hold an equivalent pilot license approved bythe FAA. 18. The operator may not permit any PIC to operate unless the PIC meetsthe operator's qualification criteria and demonstratesthe abilityto safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be CITY OF BURLESON-PUBLIC WORKS DEPARTMENT, UAV Petition for Exemption logged in a manner consistent with 14 C.F.R. § 

### 61.51(b). Flights for the purposes of training the operator's PICs are permitted under the terms of the 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 C.F.R. § 

### 91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

### 1.1. All operations must be conducted undervisual meteorological conditions (VMC). Ifflight at night is required, a special request will be made at the FAA office closest to proposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in

### City of Burleson-Public Works Department, UAV Petition for Exemption

accordance with a NOTAM as required by the operator's COA. The letter of agreement with the airport management must be made available to the Administrator upon request.
21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontallyfrom acloud orwhen visibility is less than 3 statute miles from the PIC.
22. If the UA loses communications or loses its GPS signal, it must return to a pre- determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.
24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UAwith 25% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.
26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification {N- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.
27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission {FCC) or otherappropriate government oversight agency requirements. 28. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. 29. The UAS may not be operated by the PIC from any moving device orvehicle. 30. All operations shall be conducted over publicly owned or controlled property. Any operation over privately owned property would require permission from the land owner/controller or authorized representative. Permission from land owner/controller orauthorized representativewill be obtained for each flight to be conducted. 31. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe 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 beCityof Burleson-PublicWorks Department, UAV Petition for Exemption

reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov
THE CITY OF BURLESON-PUBLIC WORKS DEPARTMENTAFFIRMS ALL INFORMATION LISTED ABOVE TO BE TRUE AND BINDING UPON FAA'S FINDINGS OF EXEMPTION REGARDING COMMERCIAL OPPERATIONS OF LISTED UAS, UNTIL FURTHER NOTICE OF LAWS OR REGULATIONS DECIDED BY THE GOVERNEMENT/FAA. THANK YOU FOR YOUR CONSIDERATION.

KEVIN NORTH ASSISTANT DIRECTOR OF PUBLIC WORKS

### Appendix

RearLED Flight Indicators Normal status

......(Red, Green, Yellowflashes in turn) Power On Self-Test :.·s··-:1:}

...... (Green, Yellowflashes in turn) Warming Up :J:?;i·······(SlowGreen flashes) Readyto Fly ',YJ: ······(SlowYellowflashes) Readyto Fly (non-GPS) Rear LED Flight

**lndicat~rs** Abnormal status

......(Quick Yellowflashes) Remote Controller Signal Lost ······(Slow Red flashes) Low Battery Level Warning .R'

...... (Quick Red flashes) Critical Low Battery Level Warning

·• ···(ThreeRedflashes off and on) NotStationary or Sensor Bias is too big Error•

......(Red, Yellowflashes inturn) Compass Needs Calibration 'You can learn more about error byconnecting the Phantom 2Vision+ to the Assistant.

Aircraft Supported Battery DJI 5200mAh Li-Po Battery Weight (Battery& Propellers included) 1242g Recommend payload ,;;1300g )> 3 Maximum payload 1350g 3 Hovering Accuracy (Readyto Fly) Vertical: 0.8m; Horizontal: 2.5m D

**~** :0. MaxYawAngularVelocity 200°/S x· MaxTillable Angle 35° MaxAscentIDescent Speed Ascent: 6m/s; Descent: 2m/s Max Flight Speed 15rn/s (Not Recommended) Motor Diagonal Length 350mm 3-axial stabilized Gimbal Working Current Static :750mA; Dynamic :900mA Control Accuracy ±0.03° Controllable Range Pitch :-90'- 0' Maximum Angular Speed Pitch :90' /s Camera Operating Environment Temperature O'C- 40'C Sensor Size 1/2.3" Effective Pixels 14 Megapixels Resolution 4384x3288 HD Recording 1 080p30/1080i60 Recording FOV 110'/85' 48Remote Controller Operating Frequency Communication Distance (open area) Receiver Sensitivity (1%PER) Transmitting Power (EIRP) Working CurrenWoltage Battery Range Extender Operating Frequency Communication Distance {open area) Transmitting Power Power Consumption 5.728 GHz

- 5.85 GHz CE Compliance: 400m; FCC Compliance: BOOm -93dBm CE Compliance:25mW; FCC Compliance: 100mW 120mA@3.7V 2000mAh rechargeable LiPo battery

2412MHz- 2462MHz 500m-700m 20dBm 2W

3.1 Howto solve large margin(s) mid-pointerror? Appendix

If the Remote Controller stick{s) mid-point margin of error is too big, the motors will fail to start when you execute the CSC and the Phantom will nottake off. The beloware some possiblefixesforthis. (1) One of the Remote Controller's stick positions (except the throttle stick) is not centered when powering on the Phantom 2Vision+. Solution: Place all Remote Controller sticks at their mid-point positions and then power cycle the Phantom 2 Vision+ to re-record the mid-point. (2) The Remote Controller sticks have beentrimmed, leadingto a deviation in the mid-point position. Solution: UseAssistant to perform a Remote Controller calibration. a) Connect to Assistant, tap Basic -> RC -> Command Sticks Calibration and push all Remote Controller sticks

through their completetravel range tosee if any stick cannot reach its outermost position. b) Power cycle the Phantom 2Vision+. Power cycling is required. c) Re-attempt Remote Controllercalibration in Assistant. Ifthe above solutions do not solveyour issue, please sendyour Remote Controllerto DJI Customer servicefor repair. 3.2 Howto restore avideo file if power isturned offduring arecording session? Solution: Keep or placethe Micro-SO card back into the camera. Power cyclethe cameraand wait about30 secondsfor thevideo file to be restored. 3.3 Failureto acquirethe SSID. Solution: Double check whether both the camera and Range Extender are powered on and the power switch of the camera is switched to "Wi-Fi ON." 3.4Whatto do if Phantom 2Vision+ is outofsight and the Wi-Fi connections is lost? Solution: Turn offthe Remote Controller to trigger the Failsafe mode and the aircraft will start to fly back, descend, and land at the Home point. Please make surethere are no obstacles between the Phantom and the home point andthat you arefamiliar with the procedurefor regaining control. 3.5 Wi-Fi connection fails all the time. Solution: Double checkthe current Wi-Fi connection status of the mobile device. The mobile device may be connecting to otherWi-Fi networks after a connection breaks with the Phantom 2Vision+. 3.6 Filesfail to synchronize. Solution: Video files that are too large (file sizes close to 4GB) cannot be synchronized to the mobile device. Some mobiledevices do not supportthe synchronization ofthe 1080i60 video files.

49