Petitioner:

Vijna Consulting LLC Akash Gupta, President
6 Sunshine Lane Edison, NJ
Email: akash.gupta@vijnaconsulting.com
Website: www.vijnaconsulting.com

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform A ct of 2012 (the Reform Act), and 14 C.F.R. Part 11, Vijna Consulting, a registered company in operation for 7 y ears, and serving the technology needs of the banking, commercial insurance and retail industry, hereby a pplies for an exemption from the Federal Aviation Regulations (FARs) listed below, to allow operation of our Small Unmanned Aircraft System (sUAS) commercially for purposes of obtaining aerial imagery that will help in property & crop damage assessment, loss estimation and implementation of loss prevention measures for our pro perty insurance clients. These services will benefit both the insurers and their clients to assess property damage and s ettle claims faster. All operations will be conducted w ithin and under the conditions and limitations outlined by the F AA as required by Section 333 and additional rules inforce at any time in the future.

1. Regulations from which exemption is sought
14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 61.113(a) & (b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2)
14 C.F.R. 91.109
14 C.F.R. 91.119
14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) & (b) 14 C.F.R. 91.205(b)
14 C.F.R. 91.215
14 C.F.R. 91.401 - 91.417

2. Commercial operations planned for which relief is reque sted

Commercial operation of sUAS, as described herein, using sUAS equipped with cameras and sensors, would provide the following services a) Aerial inspection / photography of residential / commerci al building damage including rooftop damage to assess damage and settle insurance claims b) Aerial inspection / photography of residential / commerci al property locations including parking lots, sheds etc to determine possible loss drivers and to suggest loss remediation measures. c) Aerial photography and / or video of residential / comme rcial utility infrastructure including but not limited to cell phone towers, electrical power lines, rail y ards, building construction equipment and car dealer parking lotsd) Aerial inspection / photography of commercial farms to detect crop damage due to insect or natural catastrophe causes such as tornado / hail / flood. Detect ion of pre-drought / drought / frost damage conditions in crops using image analysis. Detection of br oken fences and sick animals on farms. e) Training to individuals and / or employees of private / publi c organizations is use of sUAS with focus on ensuring awareness and safety consideration in use of U AS within the NAS.

3. Anticipated Public benefit of above listed commercial operations

a) Overall reduction in operating cost of insurance (damage ass essment, claims processing) will help drive down the cost of commercial insurance, especially to sm all and medium sized businesses. This will be beneficial to the overall economy in the long run b) Aerial inspection of large commercial properties, car de aler parking lots etc will help to put effective loss prevention mechanisms (replacement for broken fences, sh ed roof damage repair etc, replacement of broken windows etc) that will reduce attritional losses of firms. c) Aerial inspection of farms will help to prevent and miti gate losses from crop damage, crop failure, sick animals and livestock, disease containment and preventi on etc).

Unmanned Aircraft System sUAS are often seen as superio r to helicopters as an aerial video gathering platform due to the smaller devices cheaper equipment and personnel cos t, reduced noise and as such, a much smaller environmental impact which promotes public safety.

4. Commitment to regulation compliance and safety consideratio ns

Vijna Consulting commits to ensure that all sUAS flight s and operations shall a) Be in compliance with and in accordance with the rules gov erning sUAS flights at any given time, being
rules b) Occur over private and access controlled property wit h explicit authorization and consent by the property owner(s), including consent for any photographs / aerial i magery obtained from the flight. c) Always be in compliance with all rules, guidelines, limi tations, current and future legislation set forth by the FAA as well as with other federal, state and local ordinances and laws regarding operation of sUAS. d) Occur in ordinance with any state or local laws regarding privacy. e) Be conducted by operator who is qualified, trained, certif ied and is medially fit to fly the sUAS f) Be conducted in accordance with an ATO-issued COA.

I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITI ES 1. Operations authorized by this grant of exemption are limit ed to the DJI Phantom 3 when weighing less than 55 pounds including payload. 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 co mpliance with the 87 knot speed restriction. In no case w ill the UA be operated at airspeeds greater than the maxim um 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 (VL OS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than c orrective lenses, as specified on the PIC’s FAA-issued
airman medical certificate or U.S. driver’s license.6. All operations must utilize a visual observer (VO). T he 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 PI C always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; elect ronic messaging or texting is not permitted during flight operati ons. The PIC must be designated before the flight and cannot transfer his or her designation for the duration o f the flight. The PIC must ensure that the VO can perfor m 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 exem ption, are hereinafter referred to as the operating documen ts. The operating documents must be accessible during UAS oper ations and made available to the Administrator upon request. If a discrepancy exists between the conditions a nd 4 limitations in this exemption and the procedures outlined in the operating documents, the conditions and limit ations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as out lined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enfor cement official upon request. The operator must also present updated and revised documents if it petitions for ext ension or amendment to this grant of exemption. If the operator determines that any update or revision would affec t the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding upda tes or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristi cs, e.g., replacement of a flight critical component, must u ndergo a functional test flight prior to conducting furthe r operations under this exemption. Functional test flights m ay 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 inspect ing the UAS to ensure that it is in a condition for s afe operation. 10. Prior to each flight, the PIC must conduct a pre-flig ht inspection and determine the UAS is in a condition for safe flight. The pre-flight inspection must account for a ll potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that a ffects 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 mainte nance; overhaul, replacement, inspection, and life lim it requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 13. Under this grant of exemption, a PIC must hold either an a irline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a curr ent FAA airman medical certificate or a valid U.S. dr iver’s license issued by a state, the District of Columbia, P uerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements s pecified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 5 14. The operator may not permit any PIC to operate unles s the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be ope rated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances fr om persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (tr aining, proficiency, and experience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be oper ated under this exemption are permitted under the terms of this e xemption. However, training operations may only be conducted during dedicated training sessions. During training, pr oficiency, and experience-building flights, all persons not essential for flight operations are conside red nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance wi th 14 CFR § 91.119.15. UAS operations may not be conducted during night, as defi ned in 14 CFR § 1.1. All operations must be

conducted under visual meteorological conditions (VMC). Fl ights under special visual flight rules (SVFR) are not
authorized. 16. The UAS may not operate within 5 nautical miles of a n airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, u nless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA i ssued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon
request. 17. The UA may not be operated less than 500 feet below or l ess than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC

. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined locatio n within the private or controlled-access property. 19. The PIC must abort the flight in the event of unpredi cted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (c onsidering wind and forecast weather conditions) there i s enough available power for the UA to conduct the intended o peration and to operate after that for at least five minutes or with the reserve power recommended by the manuf acturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted un der the terms of the attached COA. 6 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N−Numb er) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 23. Documents used by the operator to ensure the safe opera tion and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at t he Ground Control Station of the UAS any time the aircraft is operating. These documents must be made ava ilable to the Administrator or any law enforcement official upon request. 24. The UA must remain clear and give way to all manned avi ation operations and activities at all times. 25. The UAS may not be operated by the PIC from any mov ing device or vehicle. 26. All Flight operations must be conducted at least 500 fee t from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are pres ent that sufficiently protect nonparticipating persons fro m the UA and/or debris in the event of an accident. The operator m ust ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner e nsuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or st ructures has granted permission for operating closer to th ose objects and the PIC has made a safety assessment of th e risk of operating closer to those objects and determined th at 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 cont rolled-access property with permission from the property owner/controller or authorized representative. Permiss ion from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that tran sgresses the lateral or vertical boundaries of the ope rational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National Trans portation Safety Board (NTSB) per instructions containe d on the NTSB Web site: www.ntsb.gov.Vijna Consulting is petitioning for an exemption to operate a DJI Phantom 3 Professional with a built-in stabiliz ed

HD camera and GPS safety features which limit its abilit y to limit the height it flies above ground level (AGL ), to
limit the radius of the distance it flies from the o perator and to exclude it from operations within designated Class B, C and D airspace including a no-fly zone feature. The DJ I Phantom 3 also has a failsafe function that is triggered in
the event communication is lost between the sUAS and the main controller transmitter. At that time, the s UAS will return to its point of takeoff and land safety. If the conn ection is restored, the PIC can regain control of flight and land manually. These specifications meet with the Aircraft Operating St andards as set below and outlined in section B of the FA A NPRM published and available at https://www.faa.gov/regulations_policies/rulemaking/recentl y_published/media/2120-AJ60_NPRM_2-15- 2015_joint_signature.pdf



### Operational Limitations

• Unmanned aircraft must weigh less than 55 lbs. (25 kg).

• Visual line-of-sight (VLOS) only; the unmanned aircraft must remain within VLOS of the operator or
visual observer.

• At all times the small unmanned aircraft must remain clo se enough to the operator for the operator to be capable of seeing the aircraft with vision unaided by any device other than corrective lenses.

• Small unmanned aircraft may not operate over any person s not directly involved in the operation. Daylight-only operations (official sunrise to official sunset, local time)

• Must yield right-of-way to other aircraft, manned or unm anned.

• May use visual observer (VO) but not required.

• First-person view camera cannot satisfy “see-and avoid” requirement but can be used as long as requirement is satisfied in other ways.

• Maximum airspeed of 100 mph (87 knots).

• Maximum altitude of 500 feet above ground level.

• Minimum weather visibility of 3 miles from control sta tion.

• No operations are allowed in Class A (18,000 feet & above ) airspace.

• Operations in Class B, C, D and E airspace are allowe d with the required ATC permission.

• Operations in Class G airspace are allowed without ATC pe rmission

• No person may act as an operator or VO for more than on e unmanned aircraft operation at one time.

• No operations from a moving vehicle or aircraft, exce pt from a watercraft on the water.

• No careless or reckless operations.

• Requires preflight inspection by the operator.

• A person may not operate a small unmanned aircraft if he or she knows or has reason to know of any physical or mental condition that would interfere with the safe operation of a small UAS. 

### Operator Certification and Responsibilities

• Pilots of a small UAS would be considered “operators”.

• Operators would be required to:

o Pass an initial aeronautical knowledge test at an FAA-app roved knowledge testing center. O Be vetted by the Transportation Security Administration.

o Obtain an unmanned aircraft operator certificate with a small UAS rating (like existing pilot airman certificates, never expires).

o Pass a recurrent aeronautical knowledge test every 24 months

.o Be at least 17 years old.

o Make available to the FAA, upon request, the small UAS fo r inspection or testing, and any associated documents/records required to be kept under the p roposed rule.

o Report an accident to the FAA within 10 days of any operatio n that results in injury or property damage.

o Conduct a preflight inspection, to include specific aircr aft and control station systems checks, to ensure the small UAS is safe for operation.



### Enclosures:
1. UAS Operation Safety Checklist

### DJI Phantom 3 Professional Manufacturer Specifications

Full user manual can be found at http://www.dji.com/product/phantom-3/download