DJS	Associates,	Inc. SECTION	333 EXEMPTION	REQUEST Page 1 of 

### 4 April 21 ,	2015 U.S.	Dept.	of	Transportation,	Docket	Operations

West	Building	Ground	Floor,	Room	w12

- 140

1200	New	Jersey	Avenue,	SE.,

Washington,	DC	20590

Submitted	Electronically	via	the	Federal	Docket	Management	System	(FDMS)

Re:	Exemption	Request	under	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal

Aviation	Regulations

Dear	Sir	or	Madam:

On	Behalf	of DJS	Associates,	Inc. and Pursuant	to	S ection	333	of	the	FAA	Modernization	and	Reform	Act

of	2012	and	14	C.F.R.	Part	11, I	Jon athan Adams, Director	of	Architectural	&	Heritage	Services am

seeking an	exemption	from Part	21	Subpart	H ;	and Sections	91.203	(a)	(1)

, 45.23	(b) ,	91.7	(a),	91.9,

61.113 ,	61.133, 91.109,	91.119,	91.1 21,	91.151,	and (91.401

- 91.417 ) Subpart	E, of	Title	14,	Code	of

Federal	Regulations	(14	CFR). This	proposed	exemption	would	allow	for	the	operation	of	our	unmanned

aircraft	(UA)	the	DJI	Phantom 2 Vision +	for	the	purpose	of	a erial	image	acquisition.

T he	FAA	has	recently	approved	the use	of	the	DJI	Phantom 2 Vision + in	Exemption	No. 11313;	DeGrazia

Music,	LLC

, for	the	same	purpose.		This	exemption	also cites	similarity	with	relief	previously	requested	in

Grant	of	Exemption	Nos .	11062,	11109,	11112,	and	11213; 11138

The DJI	Phantom 2 Vision + is	comprised	of an	Unmanned	Aircraft	(UA)	and	ground	station

- based

equipment	and	crew:

THE	UNMANNED	AIRCRAFT	(UA):

• DJI	 Phantom 2	 Vision	 + light weight	 (under	 3 lb.	 gross	 weight),	 battery	 operated	 4

- motor	 quad

copter	that	takes	off	and	lands	vertically

THE	UA INCLUDES:

• An	 on

- board	 flight	 computer	with	GPS	 navigation	and	 location	ability	 that	 receives	 signals	 for

flight	controls	from	a	ground

- based transmitter/controller;

• An	on

- board	camera	capable	of	capturing	imagery	in	 the	 form	of	 full	color,	high	definition	still

photos	and	video

• An	on

- board	telemetry	system	that	delivers	flight	data	from	the	on

- board	flight	computer	to	the

on

- board	 radio	 transmi tter	 including	 altitude	 AGL,	 horizontal	 and	 vertical	 speed,	 compass

direction	of	flight	and	direction	back	to	its	launch	site

• A	5.8GHz	on

- board	radio	transmitter	that	transmits	live	video	from	the	on

- board	camera	plus	all

the	flight	data	from	the	telemetry system	described	above

THE	GROUND	STATION	PART	OF	THE	SYSTEM:

• A	 Pilot	in	Command	 (PIC)	I n	operati onal	control	of	a	mission	 from	 beginning	 to	end, and	who

controls	the	UA	while	in	the	air

• A	2.4GHz	radio	transmitter/controller	operated	by	the	PIC	to	contro l	the	UA	while	in	flightDJS	Associates,	Inc. SECTION	333 EXEMPTION	REQUEST Page 2 of 

### 4 • Ground	Station	DJI	Vision	App which	receives	and	displays	video	and	system	telemetry	real	time

from	the	UA

• A	 Visual	Observer	 (VO),	a person	who	 provides	a	 second	 pair	 of	eyes	 to	 visually	 track	 the	UA

while	in	flight.

U AS	OPERATIN G	GUIDELINES :

The UA will	be	operated	in	the	field	with	both	a	PIC	and	a	VO	in	accordance	with	and	w ith	the	following

Restrictions:

• All	operations	must	occur	in	FAA	Class	G	airspace	at	no	more	than 4 00	ft AGL,	at	an	airspeed	of

no	more	than	25	knots	and	no	further	than	3/4	NM	from	the	PIC;

• All	operations	must	utilize	a	visual	observer	(VO).	The	VO	and	PIC	must	be	able	to	communicate

by	voice	at	all	times	during	a	flight	operation;

• The	PIC	must	have	accumul ated	and	logged,	in	a	manner	consistent	with	14	CFR	§

61.51	(b),	10	hours	of	total	time	as	a	UA	rotorcraft	pilot	and	at	least	5	hours	logged	as	a	UA	pilot

with	a	similar	UA	type;

• The UA will	not	be	operat ed	over	densely	populated	areas;	without	prior	appro val.

• The UA will	not	be	operated	over	an y	open

- air	assembly	of people; without	prior	approval.

• The UA will	not	be	operated	within	5	NM	of	an	airport	or	heliport ;	without	prior	approval.

• Operations	will	be	restricted	to	day	only	and	weather	co nditions	eq uivalent	to	VFR ;

• The	PIC	will	brief	the	VO	and	property	owner	about	the	operation	a nd	risk	before	operation

• No	 flight will be	 made	 without	 a	 Pre

- Flight	 Inspection	 by	 the	 PIC	 before	 each	 operation	 to

ascertain	that	the	UA	is	in	a	condition	safe	for	flight

PILOT	IN	COMMAND	(PIC) AND	VISUAL	OBSERVER:

The	 PIC	 and	 VO	 will	 meet	 the	 requirements	 outlined	 in	 FAA	 Policy	 N	 8900.227	 Section	 16	 personnel

Qualifications.	Additionally,	the	PIC	and	VO	will	per form	maintenance	on	the	system and	will	complete	a

course	of	m aintenance	instruction	as	part	of	their	initial	training.

I submit that	the	combination	of	the	UA’s light	weight,	flight	performance	and	ability,	fully	qualified

flight	crew	and	strict	operation	under	the	guidelines	established	in	8900.227,	and	under	all	o f	the

Restrictions	listed	above,	the	FAA	can	have	full	confidence	that	the	operation	wil l	have	an	equivalent	or

greater	level	of safety	than	manned	aircraft	performing	the	same	mission.

INTENDED	USE:

The	requested	exemption	would	allow	us	to	use	the	UA	f or	aerial	image	acquisition	to	support	various

mapping	 and	 surveying	 applications	 as	 well	 as	 video	 documentation	 for	 the	 public	 good.	 Typical

applications	would	include,	but	are	not	limited	to:

• Photography

• Aerial	Mapping

• Architectural	Surveys

• Historical	P reservation	Surveys

• Archaeological	Surveys

• Forensic	SurveysDJS	Associates,	Inc. SECTION	333 EXEMPTION	REQUEST Page 3 of 

### 4 The	inherent	ability	of	 the	UA	is	 to	capture	imagery	 from	a	low	altitude	including	oblique	photos	and

video	 from	 several	 angles	 is	 far	 more	 effective	 than	 ground

- based	 imagery	 for	 displaying	 the

characteristics	 of	 buildings,	 sites	 and	 properties	 or	 areas	 where	 consistent	monitoring	 is	 needed.	 The

applicant	in	 the	past	has	chartered	 fixed	wing	aircraft	and/or	helicopters	 for	 this	purpose,	which	have

proven	more	costly	than	many	potential	clients	ha ve	been	able	to	afford,	resulting	loss	of	opportunities.

The	reduced	cost	and	higher	quality	data	from	the	UA	will	be	beneficial	to	the	public	in	applications	such

as	 preservation	 of	 historic	 buildings	 or	 archeological	 sites	 where	 access	 is	 limited	 and	 pro ject	 sites

potentially	sensitive	to	disruption.

PUBLIC SAFETY :

UA’s,	 are	 powered	 by	 batteries,	 they	 are	 smaller,	 lighter	 and	more	maneuverable	 than	 larger	 aircraft

running	 on	 combustible	 fuel;	 they	 operate	 at	 lower	 altitudes	 (under	 400’)	 with	 no	 people	 o n	 board

thereby	 reducing	 current	 risk	 levels	and	enhancing	 public	 safety.	With	a	 small	 payload	and	maximum

flight	time	of	approximately	20	minutes,	UA’s	offer	little	or	no	risk	to	national	security.	In	addition	the

DJI	UA	has	its	own	built	in	flight	restri ctions	in	special	areas	ie:	airports,	which	limit	flight	in	these	areas.

More	information	can	be	found	in	the	UA’s	User	Manual	or	on	DJI’s	website	at https://www.dji.com/fly

safe

.

SUMMARY	GRANT	REQUEST :

This request	follows	many	others	using	similar	systems	and	process	tha t	have	been	granted	previously. I

am	requesting	the	FAA issue	a	summary	grant of	exemption	as	this request would	not	set	a	precedent

.

The	 UA	 has previously	 received	 Summary	 Grants	 under Exe mption	 No.	 11313 ; DeGrazia	 Music,	 LLC

Which	cites	similarity	with	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 this	request

• A	grant	of	exemption	would	be	in	the	public	interest.

THE	REGULATIONS	FROM WHICH	THE	EXEMPTION S	ARE	BEING REQUESTED

Beside	each	regulation	number	is	the	page	of	the	attached	Addendum	upon	which	each	may	be	found

together	with a proposed equivalent	level	of	safety	for	each	regulation:

- 14	CFR	Part	21 Subpart	H Addendum	Page	1

- 14	CFR 91.203	(a)	(1) Addendum	Page	1

- 14	C F R	45.23 (b) Addendum	Page 1

- 14	CFR	91.7	(a) Addendum	Page	2

- 14	CFR	91.9 Addendum	Page	2

- 14	CFR	61.113, 61.133 Addendum	Page	2

- 14	C F R	91.109,	91.119,	91.12 1 Addendum	Page 3

- 14	CFR	91.151 Addendum	Page 3

- 14	CFR	Subpart	E	(91.401

- 91.417) Addendum	Page 4

- FAA	Policy	8900.227	Paragraph	16(c)(4)	and	Paragraph	16(e)(1) Addendum	Page	4DJS	Associates,	Inc. EXEMPTION	REQUEST AND	LEVEL	OF	SAFETY	Page 1 of 

### 4 A D DEN D UM

EXE M P TION	RE Q UE S TS A N D	EQUI V AL E NT L EVEL OF S A F ETY

I

, Jo hn athan Adams, Director	of	Architectural	&	Heritage	Services at DJS	Associates,	Inc. r e qu e st a n

e x e mp t ion	 f r om t he f ol l owing	re g u l a t i ons a s	w e ll a s	a n y a ddi t ional r e g ulations	that	m a y t e c hnic a l l y

a pp l y t o	the	op e r a t i on	of the DJI	Phantom	2	V i sion	+ (UA) :

14	C.F.R.	Part	21,	Subpart	H:	Airwo rthiness	Certificates	14	C.F.R. 91.203	(a)	(1)

Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedura l requirements	for	the	issuance

of	airworthiness	certific ates	as	required	by	FAR	91.203( a )	(1).	Given	the	size	and	limited	operating	area

associated	with	the	UA	to	be utilized	by	the	Petitioner,	an	exemption	from	Part	21	Subpart	H	meets	the

requiremen ts of	an	equivalent	level	of	safety	under	Part	11	a nd	Section	333	of	the	FMRA.	The	Federal

Avi ation	 Act	 (49	 U.S.C. 44701	 (f))	 and	 Section 333	 of	 the	 FMRA	 both	 authorize the	 FAA	 to	 exempt

aircraft	 from	the	requirement	 for	an airworthiness	certificate,	upon consideration	of	 the	size,	weight,

speed,	operational	capabi lity,	and	proximity	to	airports and populated	areas	of	the	particular UA .	In	all

cases ,	 an	 analysis	 of	 these	 criteria	 demonstrates	 that	 the	 UA operated	 without	 an	 airworthiness

certificate,	in the restricted	environment	and	under	the	conditions	propos ed	will	be	at	least	as	safe,	or

safer,	t han	a	conventional	aircraft	(fixed	wing	o r	rotorcraft)	operating	with	an airworthiness	certificate

without	the	restri ctions	and	conditions	proposed. The UA to	be	operated	hereunder	is	less	t han	55	lbs.

fully	loaded,	is	by definition	unmanned	and	carries	ne ither	a	pilot	nor passenger,	carries	no	explosive

materials	or	 flammable	liquid	 fuels,	and	operates	exclusivel y	within	a	limited	 flight	area. Unlike	other

civil	aircraft,	operations	under	this	exemption will	be	tightly	controlled	and monitored	by	the	Opera tor

and	 will	 also	 remain	 wit hin	 the	 requirements	 of,	 and	 in compliance	 with,	 local	 public	 safety

requirements.	 These	 safety	 enhancements,	 whic h	 already	 apply	 to	 civil aircraft	 provide	 a	 greater

deg ree	 of	 safety	 to	 the	 public	 and property	 owners	 than	 conven tional	 operations	 conducted with

airworthiness	certificates issued	under	14	C.F.R.	Part	21,	Subpart	H.	Lastly,	application	of	 these	same

crite ria	demonstrates	 that there	is	no	credible	 threat	 to	nationa l	security	posed	by	 the	UA	due to	its

size,	 speed	 of	 o peration,	 location	 of	 operation, lack	 of	explosive	materials	 or flammable	 liquid	 fuels,

and	inability	to	carry	a	substantial	external	load.

14	C.F.R.		45.23	(b).	Marking	of	the	Aircraft

The	 regulation	 requires;	When	 marks	 include	 on ly	 the	 Roman	 capital	 letter	 "N" and	 the	 registration

number	 is	 displayed	 on	 limited,	 res tricted	 or	 light

- sport	 category aircraft	 or	 experimental	 or

provisionally	certificated	a ircraft,	the	operator	must	also display	on	that	aircraft	near	each	entrance	to

t he	 cabin,	 cockpit,	 or	 pilot	 stat ion,	in letters	 not	less	 than	 2	inches	 nor	more	 than	 6	in ches	 high,	 the

words	"limited," "restricted,"	"light

- sport,"	"experimental,"	o r	"provisional,"	as	applicable. Even	though

the UA will	 have	 no	 airworthines s	 certificate ,	 an	 exemption	 may be	 needed	 as	 the UA will	 have	 no

entrance	to	the	cab in,	cockpit	or	pilot	station	on which	the	word	"Experimental"	can	be	placed.	Given

the	size	of	the	UA,	two

- inch lettering	will	be	impossible.	The	word	"Experimental"	wi ll	be	placed	on	t he

fuselage	in	compliance	with 45.29	(f).	The	equivalent	level	of	safety will	be	provided	by	having	the	UA

marked on	its	fuselage	as	required	by 45.29	(f )	where	the	pilot,	observer	and others	working	with	the

UA will	see	the identification	of	the	UA	as "Ex perimental."DJS	Associates,	Inc. EXEMPTION	REQUEST AND	LEVEL	OF	SAFETY	Page 2 of 

### 4 The	FAA	has	issued	the	following	e xemptions	to	this	regulation	to Exemptions	Nos.	10700,	8738,	10167

and	10167	A.

14	C.F.R.	91.7(a):	Civil	aircraft	airworthiness.

The	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	i t	is	in	airworthy	condition.	As

there	will	be	no	airworthiness	certificate	issued	for	the	aircraft,	should	this	exemption	be	granted,	no

FAA	regulatory	standard	will	exist	for	determining	airworthiness.	Given	the	size	of	the	aircraft	and	the

requirements	c ontained	herein	for	the	use	of	safety	check	lists	prior	to	each	flight,	an	equivalent	level

of	safety	will	be	provided.

14	C F R	91.9	Civil air c r a f t f l ig h t m a nu al, m a r k i n g,	a n d p laca r d re qu ir e m e n ts.

This	 r e g u l a t i on	 p r ovides that	 no	 p e rson	 m a y op e ra te a n a ir c r a ft	 unless a c u r r e nt,	 app r o v e d	 fli g h t

manu a l i s	in t he a ir c r a ft. We a ssu m e that	the	intent	of	this	r e quir e ment	is	to	ensu r e that fl i g ht	manu a l

i n f o r mation i s	a v a i l a ble	 to	 the a ir c r e w while	op e r a t i n g the a i r c r a ft. We re qu e st	an e x e mp t ion t o	 th i s

r e quir e ment	sin c e the a i r c r a ft	is not	on l y too	small t o ca r r y do c u m e ntation; t he	do c ument a t i on	would

not	be a v a i l a ble	to	the c rew during f l i g ht	ope r a t i on s

.

To	 obtain a n e quival e nt l e v e l	 of	 s a f e t y a nd	 m e e t t he in t e nt	 of	 91.9, we pr o pose that	 a c u r r e nt,

a ppro ve d U A F l i g ht Operations/Procedures ( App e ndix A) must be a v a i l a ble	to	the c rew a t the g rou n d

station a n y t i me	the a ir c r a ft	is i n,	or p re p a ring	fo r

, f l i g ht.

T he	 FAA	 has	 issued	 the	 following	 exemptions to	 this	 regulation:	 Exemption	 Nos.	 8607,	 8737,	 8738,

9299, 9299A, 9565, 95658,	10167,	10167A,	10602,	32827,	and	10700.

14	C F R	61.113 P r iva t e p i l ot p r iv i leg e s	a n d l i m ita t io n s: P i l ot in C o m m a n d a n d 61.133 C o m m e rc ial p i l ot

p r iv i l e g e s	a n d l i m ita t io n s.

The r e g ulation	 provid e s t h a t	 no	 pe r son	 th a t	 ho l ds	 a p riv a te	 pilot ce rtif i ca te m a y ac t	 as	 pilot i n

c om m a nd	of a n a i r c r a ft f or c ompens a t i on	or h i r e

. S ubp a ra g r a ph (b) a l l ows a priv a te	pilot to	a c t a s	pilot

in	 command	 of a n a ir c r a ft	 in c onn e c t i on	 with	 a n y busin e ss	 or e m p l o y ment	 if:	 (1) T h e	 fli g ht i s	 on l y

inci d e ntal	to t h a t bus i n e ss	or e mp l o y ment;	and ( 2) The a ir c r a f t	does	not	c a r r y	p a sse n g e rs o r	p r op e r t y

f o r c ompens a t i on	or hi r e

.

Our pro p osed o p e r a t i ons r e quire that	the P I C	must e i t h e r

1. Hold	 a Private	 Pilot C e rtifi ca te is s u e d b y the F AA, a nd h a ve l o g g e d 10 hou r s	 of f l i g ht

e x p e ri e n c e in t his t y p e of U A ,	or

2. M ee t t he re qui r e ments	of 8900.227	p a ra	16 ( c ) ( 2 ) ( c ) " Op e r a t i ons without a pi l ot	c e rtifi ca t e "

in	which	the P I C	is	r e qu i r e d	to	complete " F AA p r ivate pi l ot g round ins t ruct i on" a nd	p a ss " the

F AA P riv a te	P i lot w ritten e x a m i n a t i on." S ince the r e a r e c u r r e nt l y no me a ns	a va i l a ble	for the

pilot of	a U A to g a in t he e x p e ri e n c e in a n e quival e nt	c a t e g o r y a nd c lass in	ord e r	to a pp l y f o r	a

private p i l ot ' s	l i ce nse, we pro p ose to g e n e r a te a n e quiva l e n t l e v e l	of s a f e t y b y r e quiri n g our

p i l ots t o c omp l e te, a t	 a	 min i mu m

, F AA private pi l ot	 ground	 ins t ru c t i on a nd	 p a ss t he F AA

Private P i l ot	w r i t ten e x a m i n a t i on	in	add i t i on	 to c omp l e t i ng the	 p r i v a te	 p i lot re quir e ments.

S ince t he a ir c r a ft c a nnot	c a r r y p a sse n g e rs o r	p r op e r t y

, we f e e l that	we me e t t he in t e nt	of

61.113 S ubp a ra g r a ph	( b ) e v e n	tho u gh	the	intent	of	th i s	ap p l i ca t i on	is	to c ondu c t	a	business.DJS	Associates,	Inc. EXEMPTION	REQUEST AND	LEVEL	OF	SAFETY	Page 3 of 

### 4 14	C F R	91.109 F l i g h t	I n st r u c tion; S i m u lat e d i n st r u me n t f l i g h t	and c e r tain f l i g h t te sts

The r e g ulation stat e s	 that " No	 p e rson	 m a y op e r a te a c iv i l air c r a ft	 th a t i s	 be i ng used for f l i g ht

instru c t i on	unless	that a ir c r a ft h a s ful l y fun c t i oning du a l c ontrols."

The UA’s g roun d

- b a s e d c ontrol	station c o nsi s ts	of a small	h a nd

- h e l d	r a dio t r a nsm i t t e r a nd	while	it	does

not	of f e r	a se c ond s e t	of " c ontro l s " ,	both t he student a nd i nstru c tor ca n, a nd	wil l ,	op e r a te	the si n g le

s e t of c ontrols si m ul t a n e ous l y

. W i t h	 both	 student a nd	 instru c tor	 h a ving " h a nds

- o n " the c ontrols

d u r ing f l i g ht, we f e e l t h a t t his t ec hnique	m ee ts t he i ntent	91.109 a nd	p r ovides a n e quiva l e nt le v e l	of

s a f e t y

.

14	C F R	91.119 M i n i m u m sa f e altitu d e s: G e ner al.

The re g ulation stat e s	that ov e r	sp a r s e l y popu l a ted a r e a s	t h e a ir c r a ft ca nnot be op e r a t e d c loser

than	 500 fee t t o a n y p e r s on,	 v e ssel,	 v e hicl e ,	 or	 st r u c tur e

. S ince the a ir c r a ft will be op e r a t i n g a t	a

ma x i m um	of 500 fee t	A G L

, we c a nnot	comp l y w i t h	th i s	r e quir e m e nt.

I n o rd e r	to	pr o vi d e a n e q uival e nt l e v e l	of	s a f e t y The UA ’s will not	be	op e r a ted	ov e r c ong e sted a r e a s o r

ov e r a n y o p e n a ir a ssemb l y o f p e rsons with	 prior	 approval

. Any	 property owner	 affected w i l l	 be

b r i e f e d	 on the e x p ec ted r oute	 of flight a nd the a ssoci a ted risks	 to	 p e rsons	 a n d	 p r op e r t y on	 the

g roun d

. The a ir c r a ft	will	 be o p e rated a t	a low a l t i t ude a l l o win g ,	if	a pow e r	 unit	 f a i l s,	an e me r g e n c y

land i ng without undue h a z a rd to	pe r sons	or	p r op e r t y on the	su r f a c e .	Th e r e f o re we maintain	t h a t	due

to	 the	 sm a ll si z e of	 the UA,	 the	 h a z a rd	 to	 p e rsons,	 v e hicl e s	 and	 stru c tur e s	 is m i ni m a l	 comp a r e d	 to

mann e d a ir c ra ft,	whi c h	should	be c ons i d e r e d	in g r a nt i ng the e x e mp t ion.

14	C F R	91.121 A lt i m e ter S e t ting s

.

The r e g ulation r e quir e s t h a t	air c r a ft	sh a ll mainta i n c ruising a l t i t ud e s b y r e f e r e n c e to	an a l t i m e ter

s e t t ing a v a i l a b l e with i n	100 NM	of the a i r c raft.

The UA	will a lw a y s f l y b e low 500 fee t A G L a nd will n o t	ne e d	to m a in t a in	c r uis i ng a l t i t ud e s in	o r d e r	to

p re v e nt c onfli c t with other a ir c r a ft.	An A bove G r ound L e v e l a l t i m e ter me a s u r e ment a bove the	t a k e o f f

point	is t r a nsm i t t e d via ra dio	f r o m t he UA’S on

- bo a rd c o m puter to t he	disp la y	s c r e e n h e ld b y the P I C,

p rovi d ing a c onst a n t l y up d a ted	A G L r ea dout.

14	C F R	91.151 F u e l	r e q u ir eme n ts f or f l i g h t	in VFR c o nd itio n s.

The r e g ulation	 provid e s t h a t	 no	 pe r son	 m a y b e g in a f l i g ht i n a n a irpl a ne u n d e r	 d a y

- V F R c ondi t ions

unless	the r e is	enou g h fu e l t o	f l y to t he fi r st	po i nt	of in t e nd e d	la n ding a nd	to	f l y a ft e r	that f or a t l ea st

30	m i nutes.

The in t e nt i on	of th i s	pa r a g r a ph	is	to	provi d e a n e n e r g y r e s e r v e a s	a s a f e t y buf f e r f o r	d e l a y s	to l a ndi n g

. Each U A	 is	 batt e r y op e r a ted a nd the	 m a x i m um	 dur a t i on o f f l i g ht f rom	 a sin g l e	 b a t t e r y c h ar g e	 is 45

m i nutes	 with	 a	 20% re s e rv e

. S ince the a i r c raft	 will	 n e v e r f l y mo r e than 3/4NM	 f r om t he point of

intend e d landi n g ,	 a f ull b a t t e r y c h ar g e a t l a un c h	 will e nsure that w e me e t	 the re s e r v e e n e r g y

r e qui r e ment of th i s	pa r a g ra ph. W e re qu e st a n e x e mp t ion t o	the w o r d	"fu e l " a nd a sk for a n e quival e nt

in t e rp re tation	wi t h	the w o r d	"en e r g y ".DJS	Associates,	Inc. EXEMPTION	REQUEST AND	LEVEL	OF	SAFETY	Page 4 of 

### 4 14	C F R	S ubp a r t	E	( 9 1.401

- 91.417)

- M ai n t e n a n ce ,	P re v e n tive M ai nt e n a n ce ,	Alt e r a t io n s

The r e g ulation	 provid e s t h a t t he op e r a t o r	 is	 p r i m a r i l y re spons i ble f o r maintaining the a ir c r a ft	 in a n

a irwo r t h y c ondi t ion, i n c lud i ng c omp l ia n c e wi t h	p a rt	39 a nd	43. P a ra g r a phs	91.407 a nd

91.409 re quire that	the a i r c raft	be " a ppro v e d	for return	to	se r vice b y a p e rs o n a uthori z e d	und e r

43.7" a ft e r	m a in t e n a n c e a nd	insp ec t i on.

I t i s our intention t h a t t he P I C	p e r fo r m m a in t e n a n c e a nd inspe c t i on	of the a i r c raft a nd " be a uthori z e d

to	app r ove the a i r c r a ft f or r e turn	to	se r v ic e ." As	p r ovided	in	the P r e

- F l i g ht C h ec kl i st	in	App e ndix A,	the

P I C	will e nsure that	the a i r c raft	is i n a n a irwo r t h y c on d i t ion	prior	to e v e r y	fli g ht and	in	addit i on c o n du c t

det a i l e d	 insp ec t i ons a ft e r e v e r y two	 ho u rs	 of f l i g ht. Mainten a n c e	 p e r f o r med b y t h e P I C	 is l i m i t e d	 to

r e p a iring small c r a c ks, r e pl a c ing	a p r o p e l l e r, c h ec ki n g e le c tri c a l	conn e c t i ons a nd	upd a t i ng soft w a re a nd

f irmw a re	f o r	the on

- b o a rd c ompu t e r.	All	o t h e r	mainten a n c e will be p e r f o r med b y t h e m a nu f ac tu r e r	or

their d e si g n a ted r e p a ir f a c i l i t y .	The P I C	will do c ument	wo r k	p e r f o r med	in acc o rd a n c e wi t h	91.417. We

fee l t h a t d ue to t he si z e

, c onstru c t i on, a nd	simp l ici t y of	the a i r c r a ft,	the P I C ca n e nsure a n e quiva l e nt

l e v e l of sa fe t y

.

8900.227 P a r ag r a p h 16( c ) ( 4) P I C Me d ical. And P a r a g r a p h 16( e ) ( 1 )	Ob s er v e r Me d ical.

This	po l i c y pro v ides	 that both t he P I C a nd	VO m u st	have a v a l i d F AA s e c o n d

- c lass	medi ca l ce rtifi c a te

issued	und e r p a rt	67	in ord e r	to pe r f o r m a s	a	pilot	or	o b s e rver.

The	 UA’s ma x i m um g ross w e i g ht is less	 than 4 lb s., are constru c ted primarily of ,	 plastic	 and	 carbon

fiber. T he P I C	is	not	on	boa r d. B oth t he P I C a nd	the V O a re r e quir e d	to	be	in V LO S .	Giv e n	t h e unl i k e l y

e v e nt t h a t bo t h	 the P I C a nd	VO b ec ome m e dic a l l y in c a p ac i t a ted while	 the a ir c r a ft	is i n	 fli g ht, t he	UA

will re turn a utono m o us l y to t he	 si t e of	 laun c h i ng a nd l a nd	 without c r e w in t e rv e nt i on.	 Th e r e f o r e

,

r e quiri n g the P I C a nd	 VO	 to me e t t he s a me	 m e d i ca l r e quir e m e nts a s commercial	 pilot	 carrying

passengers in	a	l a r g e a i r c r a ft	is a n u nn ece ss a r y burd e n.

W e pro p ose	th a t t he m i ni m um m e dic a l	r e quir e m e nts for the P I C a nd	VO b e vis i on c o r re c ted	to

20/20	and	a v a l i d,	st a te	i s sued	d r ive r ' s	l i ce n s e .	The 20/20	v i sion	r e quir e me n t	wi l l	ensu r e that	the P I C

and	 VO n	 see	 and	 avoid	 air	 traffic;	 a	 licensed	 driver	 is	 medically	 qualified	 to	 operate	 a	 much	 larger

vehicle.DJS	Associates,	Inc.

– APPENDIX	A

– FLIGHT	OPERATIONS	AN D	PROCEDURES AP P E N DIX	A

– F LIG H T OPERATIONS/PROCEDURES

The	UA will	be	operated	under	the	following	flight	restrictions.	R estrictions	and	procedures are	the	same

for	both	DJI	UA’s	in	this	request

OPERATIONAL F L I G HT RE S TRI C T I ONS

The	UA	will	be	operated	in	the	field	with	both	a	PIC	and a	VO	in	accordance	with	and	with	the	following

Restrictions:

• All	operations	must	occur	in	FAA	Class	G	airspace	at	no	more	than	400	ft	AGL,	at	an	airspeed	of

no	more	than	25	knots	and	no	further	than	3/4	NM	from	the	PIC;

• All	operations	must	utilize	a	visua l	observer	(VO).	The	VO	and	PIC	must	be	able	to	communicate

by	voice	at	all	times	during	a	flight	operation;

• The	PIC	must	have	accumulated	and	logged,	in	a	manner	consistent	with	14	CFR	§

• 61.51	(b),	10	hours	of	total	time	as	a	UA	rotorcraft	pilot	and	at	le ast	5	hours	logged	as	a	UA	pilot

with	a	similar	UA	type;

• The	UA	will	not	be	operated	over	densely	populated	areas;	without	prior	approval.

• The	UA	will	not	be	operated	over	any	open

- air	assembly	of	people;	without	prior	approval.

• The	UA	will	not	be	operate d	within	5	NM	of	an	airport	or	heliport;	without	prior	approval.

• Operations	will	be	restricted	to	day	only	and	weather	conditions	equivalent	to	VFR;

• The	PIC	will	brief	the	VO	and	property	owner	about	the	operation	and	risk	before	operation

• No	 flight	 wil l	 be	 made	 without	 a	 Pre

- Flight	 Inspection	 by	 the	 PIC	 before	 each	 operation	 to

ascertain	that	the	UA	is	in	a	condition	safe	for	flight

P RE

- F L I G HT CHECKLI S T

Prior	to	operation preflight	checklists	provided	by	the	manufacturer of	the	UA’s	will	be	followed. Below

is	such	an	example.

1. Remote	Controller,	smart	battery,	Range	Extender	and	smartphone	are	fully	charged.

2. Propellers	are	mounted	correctly.

3. Damping	absorbers	are	in	good	condition,	not	broken	or	worn.

4. Camera	lens	cap	has	been	removed.

5. Micro

- SD	card has	been	inserted	if	necessary.

6. Gimbal	is	functioning	as	normal.

7. Motors	can	start	and	are	functioning	as	normal.

8. DJI	App	can	connect	to	the	camera.DJS	Associates,	Inc.

– APPENDIX	A

– FLIGHT	OPERATIONS	AN D	PROCEDURES TAKE	OFF/LANDING	PROCEDURES

Manufacturer	recommended	Takeoff	and	Landing	procedures	will	be	followed.

Place	the UA on	ground	with	the	battery	level	indicator	facing	you.

1. Power	on	the	remote	controller.

2. Power	on	the	range	extender.

3. Switch	the	camera	to	the	“WIFI	ON”	position.

4. Power	on	the	aircraft	by	turning	on	the	intelligent	battery

5. Connect	the	mobile	d evice	to	the UA ,	run	the	DJI	App	to	enter	the	camera	preview	page.

6. Wait	until	the	LED	flight	indicator	starts	to	slowly	blink	green/yellow.	This	means	the	aircraft	is

initializing	and	entering	the	“Ready	to	Fly”/“Ready	to	Fly	 (non

- GPS).”	state.	Then	procee d	to

execute	the	CSC	command	to	start	motors.

7. Push	the	throttle	stick	up	slowly	to	lift	the	aircraft	off	the	ground.

8. When	landing,	be	sure	to	be	hovering	over	a	level	surface.	Pull	down	on	the	throttle	stick

gently	to	descend	and	land.

9. After	landing	the aircraft	on	the	ground,	keep	the	throttle	stick	at	its	lowest	position	 for

about	3	to	5	seconds	which	will	automatically	stop	the	motors.

FAILSAFE	FUNCTION

The UA will	 enter	 Failsafe	 mode	 when	 the	 connection	 from	 the	 remote	 controller	 is	 lost.	 The	 flight

control	system	will	automatically	control	 the	aircraft	 to	 return	 to	home	and	land	 to	 reduce	injuries	or

damage.	 The	 following	 situations	 would	 make	 the	 aircraft	 fa il	 to	 receive	 a	 signal	 from	 the	 remote

controller	and	enter	Failsafe	mode:

1. The	remote	controller	is	powered	off.

2. The	aircraft	has	flown	out	of	the	effective	communication	range	of	the	remote	controller.

3. There	is	an	 obstacle	 obstructing	 the	 signal	 between t he	 remote	 controller	and	 the aircraft,

essentially	reducing	the	distance	the	signal	can	travel.

4. There	is	interference	causing	a	signal	problem	with	the	remote	controller.

Failsafe	 works	 differently	 depending	 on	 the	 mode	 the	 aircraft	 is	 in	 when	 Failsaf e	 mode	 is	 initiated

whether	it	is	in	the	Ready	to	Fly	or	Ready	to	Fly	(non

- GPS)	mode.

Ready	to	Fly	(non

- GPS)

---- Automatic	landing

The	flight	control	system	will	try	to	keep	the	aircraft	level	during	descent	and	landing.	Note	that	the

aircraft	may	be drifting	during	descent	and	landing	process.

Ready	to	Fly

---- Automatic	go	home	and	land

The	 flight	 control	 system	will	automatically	 control	 the	aircraft	 to	 fly	 back	 to	 the	 home	 point	and

land.DJS	Associates,	Inc.

– APPENDIX	B

– DJI	PHANTOM	2	VISION + AP P E N DIX	B

– USER’S MANUAL	FOR	UA (DJI	Phantom	2	Vision + )

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