## July 22, 2015

Exemption No. 12114 Regulatory Docket No. FAA

–2015

–1064

Mr. David Pinkerton President AgriImage, LLC 91 A Milan Highway Milan, TN 38358
DearMr. Pinkerton: This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends. By letter dated April 9, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf ofAgriImage, LLC (hereinafter petitioner or operator) for an exemption

. The petitionerrequested to operate anunmanned aircraft system (UAS) to conductprecision agriculture operations

. See Appendix A for the petition submitted to the FAA describing the proposed operations and theregulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

. Airworthiness Certification The UAS proposed by the petitioner are the AgScout and AgScout Mini

. The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates

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

−95 in reference to 49 U

.S

.C

. § 44704, and in

## 2 consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates, and any associated noise certification and testing requirements of part 36, is not necessary. The Basis for Our Decision You have requested to use a UAS for aerial data collection1



## . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA

−2014

−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213; • The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and
• A grant of exemption is in the public interest. Our Decision In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore,pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, AgriImage, LLC is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

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

1 

### Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.

## 3 Conditions and Limitations
In this grant of exemption, AgriImage, LLC is hereafter referred to as the operator. Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption. 1. Operations authorized by this grant of exemption are limited to the AgScout and AgScout Mini when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

. 2. Operations for the purpose of closed

-set motion picture and television filming are notpermitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

-issued airman medical certificate or U.S. driver’s license.
6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.
7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administratorupon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents,

## 4 the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre

-flight inspection and determine the UAS is in a condition for safe flight. The pre

-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safetybulletins. 13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

## 5 14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated underthis exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the private or controlled

-access property. 19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that f or at least five minutes or with the reserve power recommended by the manufacturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

## 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−Number) 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 operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official uponrequest. 24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted over private or controlled

-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 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 be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

## 7 If this exemptionpermits operations for the purpose ofclosed

-set motion picture and television filming and production, the following additional conditions and limitations apply. 29. The operator musthave a motion picture and television operations manual (MPTOM) as documented in this grant of exemption. 30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

-day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on

-scene operation of the UAS; d. Make, model, and serial or N−Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation. 31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

## 8 This exemption terminates on July 31, 2017, unless sooner superseded or rescinded. Sincerely, /s/ John S. Duncan Director, Flight Standards Service

Enclosures

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### April 9, 2015 U.S. Department ofTransportation Docket Management System 1200NewJersey Ave, SE Washington, DC 20590 • i

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### Agrilmage, LLC 91 A MilanHwy. Milan, TN 38358 731-613-7850

RE: Request for Exemption under Section 333 oftheFAAModernization and Reform Act of2012 and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R21(h); 14 C.F.R. 45.23(b), 14 C.F.R 61.113(a) and (b), 14 C.F.R 91.7(a), 14 C.F.R 91.9(b)(2), 14 C.F.R 91.103(b)(2), 14 C.F.R. 91.105, 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) and (b), 14 C.F.R 91.405(a), 14 C.F.R 91.407(a)(l), C.F.R 91.409(a) (2), and C.F.R 91.417(a) and (b). Dear Sir orMadam: Pursuantto Section 333 oftheFFAModernization and Reform Act of2012 (the Reform Act) and C.F.R. Part 11, Agrilmage, LLC, an operator ofSmall Unmanned Aerial Systems ("sUAS") equippedto record andtake images offarmland for members ofthe agriculture industry, applies for exemption from the listed Federal Aviation Regulations ("FARs") to allowthe commercial operation ofits sUASs, so long as such operations are conducted within and under all the conditions outlined herein or as may be established by the FAA as required by Section 333. The approval ofexemptions for Agrilmage will allow commercial operations ofthe AgScout andAgScout Mini UAVs for precision agriculture. This will help farmers, agronomists, crop consultants, and other agriculture industryprofessionals locate problem areas in their field. Once aproblem area is detected, the individual can use the data in orderto write chemical and fertilizer subscriptions. The contemplated applications involve aerial surveys ofagricultural areas (includingbutnot limitedto farm fields), using a variety ofsensors andtechnologies (including but not limited to infrared photography, thermal imagery, optical zoom camera, photogrammetry, and high resolution imagery) to collect data to make more informed decisions. The pilot in command (PIC) has flown numerouspractice flights in field locations as a hobbyist in orderto prepare for future commercial use. The practice flights have increased Agrilmage's knowledge ofits sUAS performance under differenttemperature and weather conditions. This request should be granted because operation ofthe proposed small UASs conducted in the conditions outlined below, will provide an equivalent level ofsafety while still allowing commercial operations. TheAgScout andAgScoutMini, both lightweight aircrafts, covered by the exemption are saferthan operations piloted with helicopters and fixed-wing aircraft weighing thousands ofpounds containing pilot and crewmembers operating in closeproximity to the ground and people below. Congress directed the FAAto considerthe following seven factors when approving Section 33 exemption petitions: size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation within visual line ofsight (VLOS). These factors are supported in this petition. The sUASs that Agrilmage use are small, operate at slow speeds, stay below 400 feet, will not operate within 5miles ofan airport, and are not flown in populated areas. Ifwe can provide any additional informationto better assist your understanding ofthis petition, please do not hesitate to contact us at 731-613-7850 orby email at david@agriimage.com. Thank you,



# ··D_d-~ct~tS David Pinkerton President ofAgrilmage, LLC

1

### Table ofContents Item I. Petitioner's ContactInformation II. Agriimage LLC's Operations A. The sUAS B. Flight Conditions C. Flight Operations


### III. Privacy IV. Aircraft and EquivalentLevel ofSafety 

# v. Public Interest and Safety VI. Regulations from Which Exemption is Requested A. 14 C.P.R. 21 (h) and 14 C.P.R. 91.203(a)(l): Airworthiness Certificates, Manuals and the Like. B. 14 C.P.R. 45.23(b): Marking oftheAircraft. C. 14 C.P.R. 61.113 (a)(b): Private PilotPrivileges and Limitations: Pilot in Command. D. 14 C.P.R. 91.7(a) Civil aircraft worthiness. E. 14 C.P.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements. F. 14 C.P.R. 91.103(b)(2): Preflight action. G. 14 C.F.R. 91.105: Flight crewmembers at stations. H. 14 C.F.R. 91.109(a): FlightInstruction. I. 14 C.P.R. 91.119: Minimum Safe Altitudes. J. 14 C.P.R. 91.121: Altimeter Settings. 

### K. 14 C.F.R. 91.151: Fuel Requirements for flight in VFRconditions. 

### L. 14 C.P.R. 91.405 (a); 407 (a)(l); 409 (a) (2); 417 (a) (b): Maintenance Inspections. VII. ExhibitList A. Exhibit 1: Douglas Trudeau, DocketNo. FAA-2014-0481, Grant ofExemption (Jan. 6, 2015) B. Exhibit 2: UserManual C. Exhibit 3: Failsafe Safety Features D. Exhibit4: No Fly Zone E. Exhibit 5: Skyhero Syder F. Exhibit 6: Wookong G. Exhibit 7: JRModule 

### H. Exhibit 8: EZUHF 8 Channel I. Exhibit 9: DataLink J. Exhibit 10: iOSD 

### K. Exhibit 11: Skyhero Little Spyder 

### L. Exhibit 12: Naza M. Exhibit 13: EZUHF lite 8 Channel

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II. Petitioner's ContactInformation: Agrilmage, LLC 91 A Milan Hwy Milan, TN 38358 Office: 731-613-7850 Email: david@agriimage.com President: David Pinkerton 

### AgrilmageLLC's Operations:
A. sUASs
The requested exemption will permit the operation oftwo small, unmanned multirotor aircraft, the AgScout andthe AgScoutMini.


### 1. The 

### AgScout
The AgScout is a small, unmanned multirotor aircraft, weighing 11 lbs., inclusive ofbatteries and technical payload. The AgScout can operate at a speed of26knots (30 mph). The sUAS will have the following specifications orequivalent: Airframe: Skyhero Spyder Control System: Wookong Tx: ImmersionRC EZUHF JRtransmitter 

### Rx: ImmersionRC EZUHF 8ch receiver Motors: TigerRC U5 400KV brushless motors Propellers: TigerRC 15" Carbon Fiber Autonomous flight system: DJI 2.4GHz DataLink OSD: iOSD mini Gimbal: Tarot 2D gimbal Cameras: ReadyMadeRC flight camera, GoPro Hero 3 Silver edition, Tetracam ADC micro multispectral camera, Flir Tau 2 Thermal camera Batteries: Pulse 1OOOOmAh 6-cell Lithium Polymer Ion batteries with XT-60 mainpower connection Please referto Exhibits 5-10, attached to this petition, for further information about the Airframe, Control System, Tx, RX, Autonomous flight system, and the OSD respectively.

FAA has previously granted ExemptionNo. 11138, allowing commercial flight ofa for a DJI sUAS system. Exhibit 1.

3 

### 2. TheAgScout Mini


### The AgScout Mini is a small, unmanned multirotor aircraft, weighing 5lbs., inclusive ofbatteries and technical payloads. TheAgScoutMini can operate at a speed of26 knots (30 mph). The sUAS will have the following specifications orequivalent:
Airframe: Skyhero Spyder

### Control System: Nazav2 Tx: ImmersionRC EZUHF JRtransmitter Rx: ImmersionRC EZUHF 8chlite receiver Motors: Skyhero SKH04-002 950KV brushless motors Propellers: Gymfan 1 O"Carbon Fiber Autonomous flight system: DJI 2.4GHz DataLink OSD: iOSD mini Gimbal: Zenmuse H3D gimbal Cameras: ReadyMadeRC flight camera, GoPro Hero 3 Silver edition Batteries: Pulse 5000mAh4-cell Lithium Polymer ion batteries with XT-60 main power connection Please referto Exhibits 11, 12,7,13,9, and 10 attached to this petition, for further information about the Airframe, Control System, Tx, 

### Rx, Autonomous flight system, and the OSD respectively.

4 

### B. 

### Flight Conditions
The sUAS will be flown in airspace under 400 feet above ground level ("AGL") and under controlled conditions in rural areas. The majority offlights will takeplace in rural, remote areas and will avoid congested and densely populated areas. These flights occur over farmland that is usually located in very rural areas. Agriimage will abide by visual meteorological conditions (VMC), which is no less than 500 feet below and no less than 2,000 feet horizontally from a cloud or when visibility is at least 3 statute miles from the PIC. The flight crew will always conductpreflight checklists, and will only operate when it is determined that no undue dangers are present.

C. 

### Flight Operations Agrilmage requires that the Pilot in Command (PIC) always keep the sUAS in the line ofsight of both the PIC and visual observers (VOs). Flights will remain at altitudes below400 feet AGL, and at speeds less than 20 knots.
The PIC, and the VO, have over 5years ofexperience with RC aircraft, and have numerous hours flying sUAS as hobbyist. A pilot license could be helpful, but apilot license will not ensure remote control piloting skills. The operation ofAgriimage's sUAS are far less therisks than the risk levels inherent in the commercial activities outlined in 14 CFRpart 61.113. An exemption was granted to File No. 11138 in regards to an exemption under Section 333 oftheFAAModernization and Reform Act of2012 and Part 11 ofthe Federal Aviation Regulations, and this individual did not have apilot license. Exhibit I.
The week ofan operation, the flight crew will carefully reviewthe flight location to determine ifit is a safe areato fly, based on the following criteria: at least 5miles away from airports, away from populated areas, and any obstructions. Ifthere are any individuals who live close to the area in which the flight crew will fly, the flight crew will contactthese individuals and make them aware ofthe flight. The sUAS will only fly over land ofwhich it has permission from the landowner or landowner's agent. Ifa notification is necessary to members who live close by, the flight crew will provide them withthe following: time, place, and type ofUAS operation being conducted. Ifthe flight crew is unable to reach individuals who own property close by, they will leave letters in mailboxes and/or front doors in orderto inform the individuals ofthe panned sUAS operation. The flight crew will also briefthe property owners on their safety guidelines. )

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### Flights will take place on rural farmland thatwill vary in size. The PIC will remain in visual line of sight (VLOS) at all times. For larger fields, the PIC will breakthe fields into sections in orderto remain in visual line ofsight. Operation will not take place in congested or densely populated areas, and the PIC will abide by local and federal laws and restrictions. The flight crewwill monitorweather data information prior to every flight, and conduct a preflight checklist as found in the Wookong orNaza V2 user guides. Referto exhibits 6 and 12 for the respective user guides. Agriimage will abide by the following operating conditions underthis exemption: • Agriimage will only operate its sUASs in Visual Line ofSight (VLOS) ofthepilot or observer; operating within 1,500 feet will ensurethe UAS stays within visual line ofsight (VLOS); • The sUASs will be restrictedto an altitude of400 feet above ground level (AGL); • Will not operatethe sUASs within 5 miles ofan airport. Ifflight is to be conducted within 5miles ofan airport, Agriimage will contactrespective airports to requestpermissionto fly, providingthe respective airport with: estimated flight time, flight duration, elevation offlight and otherrelevant flight information;
• Will obtain permission from land owner/controllerpriorto the beginning ofevery flight; • All operations will avoid congested orpopulated areas; • Use the UAS' global positioning system (GPS) failsafe feature in which the unit returns to its original take-offspot ifcommunication with remote control pilot is lost. This failsafe systems also monitors battery life ofthe UAS, and will return the unit home ifbattery levels get too low (referto Exhibit 3 for a detailed description ofthe failsafe safety features); • Operations will occur during daylight hours; • Will not fly the UAS unless it has the maximum amount ofsatellites as specified in the user manual; • Operatethe UAS following all safety precautions, conducting apre-flight checklistbefore every flight, and will actively monitor flight data and other sources ofinformation in orderto enhance safety protocols. The ground station software for the AgScout and AgScoutMini have "no fly zones" programmed into them, which will preventthe PIC from placing waypoints in no fly zones. A no fly zone is defined as a 5 mile circular area covering all major airports. Refer to exhibit4 for a comprehensive list ofno fly zones. Agriimage will take every precaution to avoid flying in airspace otherthan class G airspace, and the "no fly zones" will add an additional level ofsafetyto flight operations.

The sUAS has been tested by the PIC and VO in a variety ofweather conditions. The AgScout is capable offlying in winds up to 30 mph (26 knots), while the AgScout mini can fly in winds up to 15 mph (13 knots). Due to thepotential for water damage to the sUAS, Agriimage will not fly in rainstorms. Rainstorms also decrease the visibility ofthe unit, therefore it would not be safe to operate the unit in such conditions. The PIC and VO have also practiced failsafe features in case an emergency bailout is necessary. This feature allows the PIC to flip the failsafe switch, which makes the sUAS return to home. Another safety feature, ifan emergency occurs, allows the PIC to release thejoysticks. Releasing thejoysticks will make the sUAS hover in place and maintain its position and altitude. When operating the sUAS, the PIC and the VO will stand next to each other, always communicating while viewingthe ground station monitor. The VO will observe the telemetry data and images from the camera on the ground station monitor. Ifthe PIC wishes to capture a different angle on the camera, the VO will direct the PIC.

### 6 

### III. Privacy 

### Proposed flights will not invade privacy because all flights will occur overrural property with the property owner'spriorknowledge and consent. Property to be filmed will have requested and hired Agriimage for the purpose offilming andphotographingthe property with the sUAS.

IV. Aircraftand EquivalentLevel ofSafety \!


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## -) Agriimageproposes thatthe exemptionrequested herein apply to civil aircraftthathave the ) characteristics and that operate within the limitations listed herein. These limitations provide for at least an equivalent orhigher level ofsafety to operate under the currentregulatory structure. ) These limitations and conditions to which Agrilmage agrees to be bound when conducting ) commercial operations under an FAA issued exemption include: 1. The sUASs will weigh significantly less than (50) lbs. The AgScout weighs 11 lbs., inclusive of battery andpayload. The AgScoutMini weighs 5 lbs., inclusive ofbattery and payload. )
2. Flights will not exceed an altitude of400 feet AGL.
3. Flights will be operated within visual line ofsight (VLOS) ofthe PIC and VO.
4. Crew for each operation will consist ofthe sUAS PIC and VO.
5. Each flight will have a maximumtotal flight time of75% ofbattery life. Flights will be terminated once battery level reaches 25% level. The PIC and VO will have access to this information viathe telemetry data submitted to the ground station monitor and transmitter. Iffor some reason the PIC and VO do not notice battery level getting low, the sUAS will enter into failsafe mode.
6. Priorto each flight, the flight crewwill review the desired flight patterns and conductthe preflight checklist.

7. The operator will obtain a FAA UAS Civil COA prior to conducting any operations under this grant ofexemption.

8. The PIC and VOs will at all times be able to communicate with each other.

9. Flight datawill be actively analyzed, along with other sources ofinformation to constantly update and enhance safety protocols.

10. Procedures will be set in place to abort flights in the event ofsafety breaches or potential danger. Both the AgScout and AgScoutMini will have the capability to abort flight in case of unexpected obstacles or emergencies. )

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### 11. All local and federal laws and regulations will be followed.

12. The PIC has accumulated numerous flight hours that easily exceed over 100 hours. PIC has 5 years the experience with RC aircraft, and has numerous hours flying sUAS as a hobbyist.



### V. Public Interest and Safety Agriimage's safety protocolsprovide a level ofsafety equal to or exceeding existing rules. Airplanes are currentlythe means ofaerial video and photography for agricultural images. While the safety record ofsuch airplanes is astonishing, there have been accident that involves the loss oflife as well as extensiveproperty damage; it is far saferto operate battery-powered sUAS. The sUAS does not carry people and it operates in specific rural areas away from mass populations, therefore the loss oflife is diminished. There is no fuel on boardthe sUAS, whichreduces the risk for fire or explosions. The limited weight ofthe AgScout and AgScoutMini significantly reduces thepotential for harm to participating and nonparticipating individuals orproperty in the event ofan incident or accident. Both sUASs can fly at lower altitudes the manned aircraft and requires less room for takeoffand landing, allowing for flights to take place over smaller areas. The AgScout and AgScoutMini's small size, weight, speed, and limited operating area associated with the aircraft and its operation meetthe statutory considerations ofSection 333.



### VI. Regulations from Which Exemption is Requested

A. 14 C.F.R. 21 (h) and 14 C.F.R. 91.203(a)(1): Airworthiness Certificates, Manuals and the Like. Agriimage, LLC requests an exemption from 14 C.F.R. 21 (h), which "prescribes requirements for the issue ofairworthiness certificates" in relation to FAR C.F.R. 91.203(a)(1). The size, weight and enclosed operational area ofthe sUASs meets an equivalent level ofsafety pursuantto Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. Section (f)) 

### and Section 333 ofthe Reform Act. These pieces oflegislationpermitthe FAA to exempt sUAS's from the airworthiness certificate requirement in consideration to weight, size, speed, maneuverability and proximity to areas such as airports or highly populated areas. 

### Equivalent level ofsafety: Agriimage'sproposed exemption meets the requirements for an equivalent level ofsafety ofthis section, pursuantto Section 333, based upon the following factor:

• Small Size: • AgScout: The AgScout's external dimensions can be found in Exhibit 5. • AgScout Mini: The AgScout Mini's external dimensions can be found in Exhibit 11. • Light weight: • AgScout: 11 lbs. inclusive ofbattery and technical payload. • AgScout Mini: 5 lbs. inclusive ofbattery and technical payload. • Operate at relatively slow speed:

### 8 

### • AgScout and AgScoutMini: while the AgScout and AgScoutMini are capable ofoperating at speeds up to 30 mph (26 knots), flights will be limited to the slower speed of20 mph (17 knots).
• Operational capacity: • AgScout and AgScoutMini: the low battery failsafe is triggered in both ofthese units, as found in exhibit 3, when battery level is depleted to 84%. • Operating near airports: Agriimage will only operate in class G airspace, and will not operate within 5miles ofan airport. Ifoperation within 5 miles musttakeplace, Agriimage will contact necessary officials at the airport to obtainpermissionto operate its unit. • Visual line ofsight (VLOS): the PIC will always fly the sUAS within his line ofsight. • Altitude: Agriimagewill always operate no more than 400 feet AGL. • Operating nearpopulated areas: Agriimage will only operate in Class G airspace in rural, natural areas. Dueto the industry in which Agriimage serves, flights take place over rural farmland. These areas are typically far away from heavily populated areas. • Area in which the sUAS will be operated: The aircraft will operate in the area in which Agriimage has permissionto operate within. The flight crew will watch for individuals and other aircraft entering the area. Flights will be aborted ifflight crewnotices any individuals or aircraft entering the area.

B. 14 C.F.R. 45.23(b): Markingofthe Aircraft. This regulation statesthe following: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental orprovisionally certified aircraft, the operatormust also display on that aircraft near each entrance to the cabin, cockpit, orpilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "lightsport," "experimental," or "provisional," as applicable. Agrilmage seeks exemption from 14 C.F.R. 45.23(b) due to the fact the AgScout does nothave a cabin, cockpit, orpilot station on which the word "experimental" can be placed. The 2-inch lettering would not fit due to the size ofthe aircraft. However, in orderto comply with 14 C.F.R. Section 45.29(f), Agriimage will markthe fuselage with the word "Experimental."Agriimage will also mark one or more ofthe "arms" ofthe sUAS. The size ofthe marking will be determined by the size ofthe "arm" being used and may be less than 1inch in size. Equivalent level ofsafety: Marking the fuselage as required by 14 C.F.R. 45.29(f) will meetthe equivalent level ofsafety. It

### will allow the PIC, VO and others working with the sUAS will see the identification ofthe UAS as "Experimental." This request is consistent with the following exemptions to this regulation thatthe FAAhas issued: ExemptionNos. 10700, 8738, 10167 and 10167A. C. 14 C.F.R. 61.113 (a)(b): PrivatePilotPrivileges and Limitations: Pilot in Command. Agriimage requests an exemption from 14 C.F.R. 61.113. The PIC ofthe sUAS does notpossess either aprivate orcommercial license. However, both sUASs are essentially model aircrafts. The AgScout weighs 11 lbs. inclusive ofbattery and technical payload, and the AgScout Mini weighs 5 lbs. inclusive ofbattery and technical payload. Agrilmage's sUASs will not carry any pilot or passengers, the area ofoperation is controlled and restricted, all flights will be planned in advance, and the maximum altitude will not exceed 400 feet AGL. A pilot license could be helpful, but a pilot license 

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### will not ensure remote control piloting skills. The operation ofAgriimage's sUAS are far less the risks than the risk levels inherent in the commercial activities outlined in 14 CFRpart 61.113. The FAApreviously granted exemption for this section for File No. 11138 (Exhibit 1). Agriimage requests the same determination to be made for this Petition. Equivalent level ofsafety: The sUASs do not carry pilot or passengers and will operate in controlled areas. Flights will not exceed 400 feet AGL. The sUASs are very light in weight, and they both contain failsafe features (Exhibit 3). The PIC, and the VO, have over 5years ofexperience with RC aircraft, and have numerous hours flying sUAS as hobbyist. The flight crew are familiar with the unit and have knowledge ofits operations. D. 14 C.F.R. 91.7(a): Civil aircraftworthiness. Agrilmage, LLC requests exemption from Section 91.7(a). As no such certificate will be applicable in the form contemplatedby the FARs, this Regulation is inapplicable. Equivalent level ofsafety: The PIC and VO assemble the sUAS from startto finish, which makes themthe most qualified to confirmthatthe copters is in an airworthy mechanical and electrical condition. Thus, this exemption provides an equivalent level ofsafety to 14 C.F.R. 91.7(a) because the PIC and VO contain knowledge ofthe aircraft, which will enable them to make the determination as to the airworthy condition. E. 

### 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements. The FAApreviously stated that no exemption is required for this section, Exhibit 1. Agrilmage requests the same determination to be made for this Petition. Alternatively, Agrilmage requests exemption from Section 91.9(b) (2) becausethe UAS does not contain any pilots orpassenger on board, and due to the size ofthe UAS it is impossible to place an aircraft flight manual inside ofthe aircraft. To provide an equivalent level ofsafety, Agrilmage will maintain a safety flight manual with the UAS ground station, Exhibit 2. F. 14 C.F.R. 91.103(b)(2): Preflight action. Agrilmage, LLC requests exemption from Section 91.103(b)(2) because the UAS will not be operated at airports orrequire arunway for takeoff. To provide an equivalent level ofsafety, Agrilmage, LLC will make surethat all pre-flight safety instructions are followed. Agrilmage, LLC will ensure thatthe landing and take-offarea ofthe UAS is clear ofany obstructions, and that the user or observer is at least 15 feet away from the UAS at takeoffand landing. G. 14 C.F.R. 91.105: Flight crewmembers at stations. Agrilmage requests an exemption for 14 C.F.R. 91.105 due to the fact that the sUAS carries no flight crewmembers. EquivalentLevel ofSafety: Agriimage will achieve an equivalent level ofsafety by ensuring that someone is atthe controls at all times. The flight crew will consist ofthe PIC and the VOs. These individuals will remain at their stations at all times during flight. These stations will be on the ground, not in the air. H. 14 C.F.R. 91.109(a): Flight Instruction These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

### 10 

### The AgScout and AgScout Mini are remotely piloted aircraft and by design, does nothave fully functional dual controls. Flight control is accomplished through the use ofa control boxthat communicates with the aircraft viaradio communications. Ifneeded during flight, the observer can easily gain control of the aircraft by commandeeringthe UAS' control unit. This serves as an equivalent level ofsafety for fully functioning dual controls. The FAA has approved exemptions for flight training without fully functional dual controls for number ofaircraft and for flight instruction in experimental aircraft (See ExemptionNos. 5778k & 

### 9862A). Agriimage requests the same determination be made for this Petition. I. 

### 14 C.F.R. 91.119: Minimum Safe Altitudes. This Section establishes safe altitudes for operation ofcivil aircraft. 91.119(c) states the following: "Exceptwhen necessary for takeoffor landing, no person may operate an aircraftbelowthe following altitudes

..... (c) Over other than congested areas. An altitude of500 feet above the surface, except over open water or sparselypopulated areas. In those cases, the aircraft may not be operated closerthan 500 feet to any person, vessel, vehicle, or structure." The AgScout and AgScout Mini will never operate at higherthan 400 feet AGL. They will, however, be operatedto avoid congested orpopulated area. Because aerial survey workmust be accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91,119(c) is needed. The equivalent level ofsafety will be achieved given the size, weight, speed, and material with which the sUASs are built. Agriimage will operatethe UAS underthe following, self-imposed restrictions:

o the UAS will not be operated over congested orpopulated areas, and will stay away from power lines, elevated lights, airports, and other relevant obstructions;

o ifflight is to be conducted within 5 miles ofan airport, Agrilmage will contactrespective airports and advise them ofestimated flight time, flight duration, elevation offlight and other relevant flight information;

o Agriimage will seekpermission from land owner/controllerpriorto thebeginning ofevery flight;

o All operations will occur overprivate or controlled access property. Agriimage, will be flying overprivate agricultural land. These areas are secluded and are not consideredto be congested orpopulated areas. Agriimage will also follow all safety requirements as mentioned in the user manual. Agriimage will not fly in congested and highly populated areas. Therefore, emergency landings can be performed without causing hazard to persons orproperty on the surface. The failsafe mechanism built into the UAS also ensures that safe landings will be performed. J. 

### 14 C.F.R. 91.121: Altimeter Settings Agriimage requests exemption from 14 C.F.R. 91.121. The AgScout and AgScoutMini's flight controllerboth have an internal measurement unit ("IMU"). This is a built-in internal sensor and barometric altimeter that measures both attitude and altitude, Exhibit 2. Agriimage is not requesting a general exemption from the requirementthat its sUAS have an Altimeter. However, Agrilmage requests an exemption from the requirement to set its altimeterto a station along the route, or out ofan airport, because the AgScout and AgScout Mini will not be traveling from point-to-point and it has to remain in the VLOS ofthe PIC. Agrilmage will also not operate within 5 miles ofan airport. 

### EquivalentLevel ofSafety: Agrilmage will never exceed an altitude of400 feet AGL and will not exceed the speed of20 knots. The PIC and VO will be able to observe and control the maximum height of the sUAS through telemetry features ofthe transmitter and on the ground station monitor. Boththe ' ) 

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### AgScout and AgScoutMini, through the use oftelemetry features, provide altitude information from the ground station monitor. The PIC will always keep the sUAS in VLOS. Therefore, Agrilmage will meetthe equivalent level ofsafetyprovided by Section 91.121. The FAA has previously granted this exemption. Exhibit 2. K. 14 C.F.R. 91.151: Fuel Requirements for flight in VFRconditions. The AgScout and AgScoutMini are powered by lithium polymerbatteriesthat currently have a flight time ofno morethan 30 minutes. Due to the limitations ofthebatteries, it is currently impossibleto comply with 14 C.F.R. 91.151. During the flight, the PIC will keep the sUAS in VLOS while the VO observes the battery life viathe telemetry display on the ground station monitor. EquivalentLevel ofSafety: The failsafe mechanisms is triggered in both ofthese units, as found in exhibit 3, when battery level is depletedto 84%. This meets an equivalent level ofsafety to 14 C.F.R. 91.151(a) due to limitations on Agriimage'sproposed operations and locations ofthe operations, a reduced minimum powerreserve for flight in daylight VFRconditions is reasonable. L. 

### 14 C.F.R. 91.405 (a); 407 (a)(1); 409 (a) 

### (2); 417 (a) (b): Maintenance Inspections. The regulations cited above require aircraft owners and operatorsto "havethe aircraft inspected as prescribed in subpartE ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43

....." The aforementioned regulations only apply to aircraft with an airworthiness certificate. Therefore, these regulations do not apply to Agrilmage's sUASs. EquivalentLevel ofSafety: This exemption will meet an equivalent level ofsafety to 14 C.F.R. 91.405 (a); 407 (a)(l); 409 (a)(2); and 417 (a)&(b) because Agriimage will repair and maintainthe AgScout and AgScoutMini by following the manufacturer's specifications. Exhibit 5 and Exhibit 11. Agrilmage will also conductpreflight inspections to ensure the sUAS is ready to fly. Agriimage will keep detailed maintenance record on every part as it is replaced, includingbutnot limited to motors, propellers, batteries, and electrical components.

# VII. Exhibit List A. Exhibit 1: Douglas Trudeau, Docket No. FAA-2014-0481, Grant of Exemption (Jan. 6, 2015)

In the matter ofthe petition of


## DOUGLAS TRUDEAU, REALTOR®

for an exemption from Part 21; and §§ 45.23(b); 61.113(a) 

### &(b); 91.7(a); 91.9(b)(2); 91.103(b); 91.109; 91.119; 91.121, 91.151(a); 91.203(a) 

### & (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) 

### & (b) of Title 14, Code of Federal Regulations Exemption No. 11138
UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC 20591



### RegulatoryDocketNo. FAA-2014-0481



## GRANT OF EXEMPTION By letter dated July 12, 2014, Mr. Douglas Trudeau, Realtor®, ofTierra Antigua Realty (Trudeau), 1650 ERiver Road, Suite 202, Tucson, AZ 85718 petitioned the Federal Aviation Administration (FAA) for an exemption from part 21, subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), \) 1 I

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91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) ofTitle 14, Code of Federal Regulations (14 CFR). The proposed exemption 1 would allowTrudeau to operate the PHANTOM 2 Vision+ quad-copter unmanned aircraft system (UAS) to conduct aerial videography and cinematography to enhance academic community awareness forthose individuals and companies unfamiliarwith the geographical layout ofthe metroTucson area and augment real estate listing videos.



### The petitioner requests relieffrom the following regulations: Part 21 prescribes the procedural requirements for issuing and changing design approvals, productions approvals, airworthiness certificates, and airworthiness approvals.

Section 45.23(b) prescribes that when marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the
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### ) operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Section 61.113(a) and (b) prescribes that- 

### (a) no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or propertyfor compensation or hire; nor maythat person, for compensation or hire, act as pilot in command of an aircraft. 

### (b) a private pilot may, for compensation or hire, act as pilot in command ofan aircraft in connection with any business or employment if: 

### (1) The flight is only incidental to that business or employment; and 

### (2) The aircraft does not carry passengers or propertyfor compensation or hire.
Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy condition.
Section 91.7(b) prescribes that the pilot in command ofa civil aircraft is responsible for determiningwhetherthat aircraft is in condition for safe flight and thatthe PIC shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur.
Section 91.9(b)(2) prohibits operation of U.S.-registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.
Section 91.103(b) prescribes that a pilot shall for any flight, become familiar with runway lengths at airports of intended use, and takeoffand landing distance information.
Section 91.109(a) prescribes, in pertinent part, that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fully functioning dual controls.
Section 91.119 prescribes that, except when necessary fortakeoffor landing, no person may operate an aircraft below the following altitudes:

13 

### (a) Anywhere. An altitude allowing, ifa power unit fails, an emergency landing without undue hazard to persons or property on the surface. 

### (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000feet above the highest obstacle within a horizontal radius of2,000 feet ofthe aircraft. 

### (c) Over otherthan congested areas. An altitude of500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. 

### (d) Helicopters, powered parachutes, and weight-shift-control aircraft. lfthe operation is conducted without hazard to persons or property on the surface- 

### (I) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) ofthis section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

### (2) A powered parachute orweight-shift-control aircraft may be operated at less than the minimums prescribed in paragraph (c) ofthis section.
Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure."
Section 91.151(a) prescribes that no person may begin aflight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to flyto the first point of intended landing and, assuming normal cruising speed, (1) duringthe day, to fly afterthat for at least 30 minutes [emphasis added].
Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy ofthe Aircraft registration Application as provided for in§ 47.31(c).
Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft unless the airworthiness certificate or aspecial flight authorization issued under§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.
Section 91.40S(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart Eofthe same part and shall, between required inspections, except as provided in paragraph (c) ofthe same section, have discrepancies repaired as prescribed in part 43 ofthe chapter.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraftthat has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for return to service by a person authorized under§ 43.7 ofthe same chapter.

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection forthe issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter.

Section 91.417(a) and (b) prescribes, in pertinent part, that14 

### (a) Each registered owner or operator shall keep the following records forthe periods specified in paragraph (b) of this section: 

### (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, 

### rotor, and appliance ofan aircraft. The records must include- 

### (i) A description (or reference to data acceptable to the Administrator) ofthe work performed; and 

### (ii) The date ofcompletion ofthe work performed; and -)

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) (iii) The signature, and certificate number ofthe person approving the aircraft for return to service. 

### (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor. (ii) The current status of life-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv)The current inspection status ofthe aircraft, includingthe time since the last inspection required by the inspection program underwhich the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. lfthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi)Copies ofthe forms prescribed by§ 43.9(d) ofthis chapterfor each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. 

### (b) The owner or operator shall retain the following records forthe periods prescribed: 

### (1) The records specified in paragraph (a)(1) ofthis section shall be retained until the work is repeated or superseded by otherwork orfor 1year afterthe work is performed. 

### (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft atthe time the aircraft is sold. 

### (3) A list ofdefects furnished to a registered owner or operator under§ 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.


### The petitioner supports his requestwith the following information: The petitioner has provided the following information- contained in his petition and supporting documentation including: 1) Supplemental Response for Petition, 2) PHANTOM Flying Flow Chart V1.0 (Simplified Version), PHANTOM Quick Start Manual v1.7, PHANTOM Advanced Manual v.1.4, 3) PHANTOM 2 Vision+ User Manual4) restricted areas map, 5) personal protocols and controls, and 6) Safety/Flight Manual (all hereinafter referred to as operating documents).
The FAA has organized the petitioner's information into four sections: 1) the unmanned aircraft system (UAS), 2) the UAS Pilot In Command (PIC), 3) the UAS operating parameters and 4) Public Interest.
Unmanned Aircraft System The petitioner states he plans to operate a UAS, the PHANTOM 2 Vision+, which is comprised of an unmanned aircraft (UA or PHANTOM) and atransportable ground station. The PHANTOM is referred to as a quad-copter with a maximum gross weight ofabout 3 pounds. It is equipped with four rotors that are driven by electric motors powered by batteries. The UA has a maximum airspeed of30 knots. Petitioner plans to attach a small ultralightweight GoPro 3+ camera to his UA and operate the UA overvarious areas nearTucson, Arizona to enhance academic community awareness and augment real estate listing videos. Petitioner makes the following representations of operational enhancements which he proposes to abide by to ensure this exemption will provide a level ofsafety at least equal to existing rules:


### 15He will only operate in reasonably safe environments that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; and • He will conduct extensive preflight inspections and protocols, during which safety carries primary importance.
The petitioner states that given the size, weight, speed, and limited operating area associated with the aircraftto be utilized by him, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and§ 91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meetsthe requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 (Section 333).

Petitioner requests an exemption from§ 45.23

### Marking of the aircraft because his UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, he states thattwo-inch lettering is difficultto place on such a small aircraft with dimensions smallerthan the minimal lettering requirement. Regardless ofthis, petitioner states that he will mark his UAS in the largest possible lettering by placing the word "Experimental" on its fuselage as required by§ 45.29(f) so that he or anyone assisting him as a spotter will see the markings.

The petitioner states that an exemption from§§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) 

### Maintenance inspections may be required and should be granted since they only applyto aircraft with an airworthiness certificate. However, the petitioner states as asafety precaution he will perform a preflight inspection of his UAS before each flight as outlined in his operating documents. 

### UAS Pilot in Command (PIC) The petitioner asserts that under§ 61.113 (a) and (b) private pilots are limited to noncommercial operations, however he can achieve an equivalent level ofsafety as achieved by current regulations because his UAS does not carry any pilots or passengers. Further, he states that, while helpful, a pilot license will not ensure remote control piloting skills. He further indicates thatthe risks ofoperating a UAS are far less than the risk levels inherent in the commercial activities outlined in 14 CFR part 61, et seq., thus he requests an exemption from § 61.113 

### Private PilotPrivileges andLimitations: Pilot in command.
Regarding UAS operational training, the petitioner states he has flown numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of his UAS' performance under differenttemperature and weather conditions. He further states that he practices computerized simulated flights to maintain adequate skills and response reflex time. 

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## ' In asupplemental request to the FAA, the petitioner requests consideration ofa 120 day temporary airman certificate in J accordance with § 63.13, to allow him time to obtain a private pilot certificate orto allowthe FAA time to establish minimum UAS airman certification standards. 

### UAS Operating Parameters The petitioner states that he will abide by the following additional operating conditions underthis exemption:

• operate his UAS below 300 feet and within a radius distance of 1000feet from the controllerto both aid in direct line ofsight visual observation; 1 operate the UAS for 3-7 minutes perflight; land his UAS priorto the manufacturer's recommended minimum level of battery power; • operate his UAS only within visual line ofsight (VLOS);

1 

### As specified in Douglas Trudeau Supplementary InformationNo.2 16 1 )

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### ) I ) use the UAS' global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost; conduct all operations under his own personal and flight safety protocols (including posting awarning sign reading: "Attention Aerial Photography in Progress- Remain Back 150feet") contained in the operating documents and will actively analyze flight data and other sources of information to constantly update and enhance his safety protocols; contact respective airports ifoperations will be within 5 milesto advise them of his estimated flighttime, flight duration, elevation offlight and other pertinent information; always obtain all necessary permissions priorto operation; and have procedures in place to abort flights in the event ofsafety breaches or potential danger.
Petitioner states that§ 91.7(a) prohibits the operation ofan aircraft without an airworthiness certificate. The petitioner asserts that since there is currently no certificate applicable to his operation, this regulation is inapplicable.

Petitioner states that§ 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board his aircraft and given its size, this regulation is inapplicable. He further indicates an equivalent level of safetywill be achieved by maintaining a safety/flight manual with the UAS ground station.
Although petitioner requests an exemption from § 91.103(b)

### Preflightaction, he provides no information supporting his request.
Similarly, the petitioner requests an exemption from§ 91.109 

### Flight instruction; simulatedinstrument flight andcertain flight test, and provides no information indicating how safety will be maintained ifan exemption to this section is granted.

Petitioner states that§ 91.119 prescribes safe altitudes forthe operation ofcivil aircraft, butthat it allows helicoptersto be operated at loweraltitudes in certain conditions. Petitioner states he will not operate his UAS above the altitude of300 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus "providing a level ofsafety at least equivalent to or belowthose in relation to minimum safe altitudes." The petitioner asserts that given the size, weight, maneuverability, and speed of his UAS, an equivalent or higher level ofsafety will be achieved.

Petitioner indicates that§ 91.121

### Altimetersettings is inapplicable since he UAS utilizes electronic GPS with a barometric sensor.

While petitioner requests an exemption from§ 91.151(a) 

### Fuel requirementsforflight in VFR conditions, he provides no information supporting his request forthis exemption.


### ) Public Interest ) 

### ) ) 

### ) ) )



### ) The petitioner states that aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has been costprohibitive. Granting this exemption to the petitionerwould allow him to provide this service at a much lower cost. Further, the petitioner indicates his small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. The petitioner also states that the operation of his UAS will minimize ecological damage and promote economic growth by providing information to companies looking to relocate or build in the Tucson metro area.



### Discussion ofPublic Comments: 17A summary ofthe petition was published in the Federal Register on August 8, 2014 (79 FR 46500). The petition received five comments. During the comment period, the petitioner submitted supplemental information in response to several ofthe comments.

Ofthe five comments received, including fourfrom trade organizations and one submitted by an individual, three raised concerns with the petition and one was specifically opposed. The othertwo supported the petition. Three trade organizations submitted letters expressing various concerns with the petition for exemption, includingthe Air Line Pilots Association International (ALPA), the National Agricultural Aviation Association (NAAA), and the United States Hang Gliding 

### & Paragliding Association (USHPA).

ALPA expressed concern regarding certain conditions outlined in Trudeau's petition. ALPA noted thatthe proposed operations will be for "compensation or hire," and believes the UAS pilot must hold at least a current FAA Commercial Pilot Certificate with an appropriate category and class rating forthe type ofaircraft being flown and a current second-class airman medical certificate. ALPA also noted that this is the requirementfor compensation or hire operations in the National Airspace System (NAS) today. NAAA and USHPA raised similar concerns on pilot qualification. NAAA and USHPA asserted thatthe operator should hold a pilot certificate and be thoroughly familiar with the limitations of manned aircraft flight. NAAA further stated that requirements for UAS pilot licensing should be developed along with other rigorous rules and qualifications to ensure safe integration ofthe unmanned aircraft into the NAS. The Small UAV Coalition (Coalition) disagreed with ALPA, NAAA and USHPA, asserting that a pilot certification should not be required for small unmanned operations such as the petitioner's.
The FAA has carefully reviewed the concerns expressed in these comments and the discussion regarding knowledge, training, and medical certification required by holders of both private and commercial pilot certificates. Additional details are available in the ensuing analysis ofthis issue with regard to 14 CFR part 61.
ALPA stated that the petitioner asserts that although he plans to fly below 300 feet above the surface and will generally not operate near populated areas, he also states he plans to survey real estate development which ALPA believes are by definition populated areas. ALPA also stated thatthe petitioner's area ofoperations as outlined in his exhibits show he would be within the airporttraffic area of both Tucson International Airport and Davis-Monthan AFB. ALPA also raised concerns about whetherthe petitioner's UAS' barometric sensor will enable him to accurately address his altitude restrictions. ALPA also asserted that processes or mitigations, such as redundant control capability, fail-safe systems, and backups, and specific, validated procedures for system and equipment failures, must be in place to ensure the aircraft and its control system(s) operate to the same level ofsafety as other aircraft operated commercially in the NAS. NAAA stated commercial UAS should have to receive airworthiness certification by the FAA to ensure they can safely operate in the NAS without posing a hazard to persons or property.
ALPA commented that command and control (C2) link failures are one ofthe most common failures on a UAS, and that lost link mitigations should require safe modes to prevent UA fly-away or other scenarios. If lost-link occurs, mitigations like auto-hover, auto-land, returnto-home and gee-fencing boundary protection must be incorporated into the navigation and control systems forthe UAS to safely land or re-establish C2. The FAA agrees and carefully examined the proposed operation to ensure thatthe vehicle design and the petitioner's supporting documentation addressed potential hazards related to C2 failure. The FAA finds thatthe UAS to be operated by Trudeau has sufficient design features to address these hazards. Further detail is contained in the analysis ofthe UAS below.
Regarding use ofthe NAS, ALPA noted there must be means to ensure the UA remains within the defined airspace and to ensure the hazard of other aircraft intruding on the operation is mitigated. ALPA stated given the absence of an onboard pilot, the means to meetthe requirements to "see and avoid" must be specified. ALPA also expressed concern, stating that "because the waiver request is notfor a specific operation but rather for all operations ofthe same general type, the FAA's 

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\ ) \ ) ) ) oversighttask is considerably increased." Per the conditions and limitations below, the FAA has prescribed operator, pilot and notification requirements to ensure that appropriate oversight can occur.

The FAA agrees and has required specific conditions and limitations outlined below related to the use ofavisual observer, thatthe pilot be acurrent FAA certificated private pilot and that a notice-to-airmen (NOTAM) be issued priorto operations.

NAAA stated that it represents the interests ofsmall business owners and pilots licensed as commercial applicators and ensuring safe low-level airspace includes minimizing obstructions which are difficultto be seen and identified by the pilots. NAAA members operate in lowlevel airspace, and clear low-level airspace is vital to the safety ofthese operators. NAAA stated that seeing and avoiding other aircraft and hazardous obstructions is the backbone for agricultural safety, and agricultural pilots depend on pilots ofother aircraft to perform their see and avoid functions needed to prevent collisions. NAAA believes that UA operations at low altitudes will increase the potential ofcollision hazards with agricultural aircraft. NAAA requested that operators of UAS develop ways of making the presence of UAS known to VFR airtraffic ifthey are to be integrated intothe NAS and, for areas with less UAS activity, recommended a procedure for issuing NOTAMs when they are present.

The FAA agrees and has incorporated this intothe conditions and limitations ofthis exemption. NAAA's notification concerns are also addressed bythe conditions and limitationsthat will require an AirTraffic Organization issued Certificate ofWaiver orAuthorization (COA) to address airspace requirements and notification. Further detail is contained in the analysis ofthe UAS operating parameters below.

NAAA proposed UAS comply with 13 measures similarto those presented by the North Dakota Agricultural Aviation Association to the North Dakota Department ofCommerce, the organization awarded the North Dakota UAS test site.

The FAA believes the limitations underwhich the petitionerwill operate (i.e. VLOS and at or below 300 feet AGL) and the UAS emergency procedures as outlined in the petitioner's supplemental documentation are sufficient mitigations to this risk so thatthe operations will not adversely affect safety. Further, the FAA addressed additional concerns raised by NAAA by adding operating conditions and limitations regarding operations in the proximity ofairports, stand-off distance from clouds, altitude restrictions, and operating distance from nonparticipating persons. Further detail is contained in the analysis ofthe UAS operating parameters below.

The USHPA also raised concerns aboutthe identification marking regulations as well as the petitioner's need to coordinate his operations with airports and comply with local and state notification regulations associated with his type ofactivity.

CommenterJames Lee wrote in support ofTrudeau's petition, so long as he does notfly higherthan 200 feet within a quarter mile from an airport or any flight path orflight operation and neverflies above 400 feet AGL.

The FAA considered USHPA's and Mr. Lee's concerns and included conditions and limitationsto address these issues as outlined below.
Lastly, the Small UAV Coalition submitted extensive comments supportingthe petition. These included suggestions that the FAA: apply regulations differentlyto small UAVs versus those in the airtransport category, not require all seven factors outlined in Section 333 as a prerequisite for every exemption (i.e. beyond visual line ofsight (VLOS); weight; size, altitude, airspace, geographic area, and proposed technology), and considerTrudeau's safety protocols including his posting ofsigns warning offlights as sufficientto enable operations in populated areas. Regarding use in the NAS, the Small UAV Coalition 

### 19stated, in part, thatthe FAA's safety evaluation of UAV operations should not hinge on the type ofoperation (i.e. public, commercial, recreational or philanthropic) rather operational risks and steps that can be taken to eliminate or reduce such risks. The Small UAV Coalition also commended the petitionerfor developing a "Personal Protocols and Controls" document that details how he will contact any airport within a 5 mile radius in advance of his proposed UAV operation.



### TheFAA's analysis is as follows: 

### Unmanned aircraft system (UAS)

The petitioner requested relieffrom 14 CFR part 21, 

### Certificationproceduresforproducts andparts. In accordance with the statutory criteria provided in Section 333 of P.L. 112-95 in reference to 49 USC§ 44704, and in consideration ofthe size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary ofTransportation has determined that this aircraft meets the conditions ofSection 333. Therefore, the FAA finds thatthe requested relieffrom 14 CFR part 21, and any associated noise certification and testing requirements of part 36, is not necessary.

Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, are operated by an onboard pilot and may carry other onboard crewmembers, as well as 100gallons or more offuel. The petitioner's UA weighs less than 3 lbs. The pilot and crew will be remotely located from the aircraft. The limited weight reduces the potential for harm to persons or damage to property in the event ofan incident or accident. The risk to an onboard pilot and crew during an incident or accident is eliminated with the use ofa UAS forthe proposed operation.

Manned aircraft are at risk offuel spillage and fire in the event ofan incident or accident. The Phantom 2 Vision+ carries no fuet and therefore the risk offire following an incident or accident due to fuel spillage is eliminated.

This exemption does not require an electronic means to monitor and communicate with other aircraft, such as transponders or sense and avoid technology. Rather the FAA is mitigating the risk ofthese operations by placing limits on altitude, requiring stand-offdistance from clouds, permitting daytime operations only, and requiring thatthe UA be operated within VLOS and yield right ofway to all manned operations. Additionally, the exemption provides thatthe operator will request a notice to airmen (NOTAM) priorto operations to alert other users ofthe NAS. These mitigations address concerns raised by NAAA and ALPA regarding awareness of UAS operations occurring in the airspace

The petitioner's UAS has the capabilityto operate safely after experiencing certain in-flight contingencies orfailures and uses an auto-pilot system to maintain UAS stability and control. The UAS is also able to respond to a loss ofGPS or a lostlink event with pre-coordinated automated flight maneuvers. These safety features provide an equivalent level of safety compared to a manned aircraft holding a restricted airworthiness certificate performing a similar operation and address concerns raised by ALPA and NAAA.
Regarding the petitioner's requested relieffrom 14 CFR 45.23(bL 

### Display of marks, the petitioner requests this relief under the assumption that marking with the word "experimental" will be required as a condition of a grant ofexemption. However, this marking is reserved for aircraftthat are issued experimental certificates under 14 CFR 21.191. The petitioner's UAS will not be certificated under§ 21.191, and therefore the "experimental" marking is not required. Since the petitioner's UAS will not be certificated under§ 21.191, a grant ofexemption for§ 45.23(b) is not necessary.
Regarding the petitioner's requested relieffrom 14 CFR 91.405(aL

### Maintenance required, 91.407(a)(1L 

### Operation aftermaintenance,preventive maintenance, rebuilding, oralteration, 91.409(a)(2L 

### Inspections, and 91.417(a) and (bL

### Maintenance records, the FAA has determined that relieffrom§ 91.409(a)(1) is also necessary because it
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Therefore, the FAA finds that adherence to the petitioner's operating documents and the conditions and limitations below, describing the requirements for maintenance, inspection, and recordkeeping, are sufficient to ensure that safety is not adversely affected. Accordingly, the FAA finds that exemption from 14 CFR 91.40S(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) is warranted.



### PilotIn Command (PIC) ofthe UAS Regarding the petitioner's requested relieffrom 14 CFR 61.113(a) and (b), 

### Privatepilot privileges andlimitations, the petitioner requested regulatory reliefto operate his UAS without an FAA-certificated pilot. In support of his request, the petitioner states that "while helpful, a pilot license will not ensure remote control piloting skills." However, the FAA does not possess the authorityto exempt the petitionerfrom the statutory requirement to hold an airman certificate, as prescribed in 49 USC§ 44711. 2 Although Section 333 provides limited statutoryflexibility relative to 49 USC§ 44704 forthe purposes ofairworthiness certification, it does not provide similar flexibility relative to other sections ofTitle 49.

Unlike operations pursuant to public COAs, the FAA is also requiring a pilot certificate for UAS operations fortwo reasons, the first ofwhich is to satisfythe statutory requirements as stated above. The second is because pilots holding an FAA issued private or commercial pilot certificate are subject to the security screening by the Department of Homeland Security that certificated airmen undergo. As previously determined by the Secretary ofTransportation, the requirementto have an airman certificate ameliorates security concerns over civil UAS operations conducted in accordance with Section 333.

Given these grounds, the FAA must determinethe appropriate level of pilot certification forthe petitioner's proposed operation.

Under current regulations, civil operations for compensation or hire require a PIC holding a commercial pilot certificate per 14 CFR part 61. Based on the private pilot limitations in accordance with pertinent parts of 14 CFR 61.113(a) and (b), a pilot holding a private pilot certificate cannot act as a PIC ofan aircraft for compensation or hire unless the flight is only incidental to a business or employment. However, in Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate operating the Astraeus UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground.

As discussed above, the petition received three comments registering concern about pilot certification. ALPA stated its opposition to the proposed operation by a non-certificated pilot without a required medical certificate. ALPA believes that the operation should be conducted by a PIC holding a current FAA commercial pilot certificate with an appropriate category and class rating forthe type ofaircraft being flown and a current second-class airman medical certificate. NAAA stated that the UAS pilot should be a commercial pilot or have similartraining and can demonstrate knowledge of aviation safety and communication procedures. USHPA stated that since the petitioner has not indicated any restriction to location of his operations, nor his knowledge ofairspace rules, and because his operations would constitute commercial operations, he should be required to meetthat level of certification.

\ / 2 49 USC §44711 prohibits a person from serving "in any capacity as an airman with respectto a civil aircraft, aircraft engine, propeller, ) or appliance used, or intended for use, in air commerce...without an airman certificate authorizing the airman to serve in the capacity for which the certificate was issued

....".

\ J 21The FAA has analyzed the petitioner's proposed operation, considered the comments above, and determined it does not differsignificantly from the situation described in Grant of Exemption No. 

### 11062 (Astraeus). The petitioner plans to operate in the NAS over private property while also limiting access to the property at times he is operating the UA. Given: 1) the similar nature ofthe petitioner's proposed operating environmentto that ofAstraeus, 2) the parallel nature of private pilot aeronautical knowledge requirements to those ofcommercial requirements [ref: Exemption No. 

### 11062L and 3) the airmanship skills necessary to operate the UAS, the FAA finds that the additional manned airmanship experience ofa commercially certificated pilot would not correlate to the airmanship skills necessary forthe petitioner's proposed operations. Therefore, the FAA finds that a PIC holding a private pilot certificate and athird-class airman medical certificate is appropriate forthe proposed operations.

With regard to the airmanship skills necessary to operate the UAS, the petitioner has provided no training program, minimum flight time hours, ortest standards to demonstrate his capability to meet some ofthe conditions and limitations below including avoiding hazards, reacting to emergencies, or maintaining specific distances from persons or property. The 

### ) ) )

petitioner indicates he avoids risks that may cause a crash and that he has flown numerous practice flights in remote areas ) as a hobbyist simulating flights forfuture commercial use to gain familiarization with the characteristics and performance of this UAS under differenttemperature and wind conditions. He also mentions his computerized simulated flights to maintain adequate skills and response reflex time.

Since the petitioner provides no information regarding atraining program, minimum flight time hours, ortest standards to demonstrate his capability to operate safely, and in response to concerns raised by ALPA, NAAA, and USHPA, the FAA reviewed the minimum requirements for providing a waiverto manned operations under 14 CFR 

### 91.119. While this process applies to an operator seeking a waiver ratherthan an exemption, the exemption process is similar. Manned operations that require relieffrom 14 CFR 91.119 in the form ofa waiver have established minimum requirements for pilot personnel (PIC). 3


### 1) at least 

### 500 hours logged as the PIC and at least 

### 20 hours logged as the PIC in the aircraft type; 

### 2) a minimum of

### 25 hours (or 

### 100 hours in the case of motion picture operations) in the same category and class of aircraftto be used; and 

### 3) a minimum of5 hours in the make and model aircraft to be used under the waiver.
However, given the relative size, weight, speed and operating parameters ofthe proposed UAS operations and its accompanying reduction in risk to persons and property when compared to manned operations, these minimum requirements should be reduced, but not eliminated. UAS operators still need to establish airmanship skills in orderto meet the conditions and limitations listed below such as the abilityto maneuver near but maintain specific distances from 

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persons and property, respond to unexpected emergencies, or avoid objects as well as the abilityto avoid potential \ conflicts with manned aircraft. In consideration ofthe above, the FAA must determine the appropriate level of pilotflight hours necessary to qualify the PIC forthe petitioner's proposed operations. The FAA has considered minimum skills and associated flight-hours necessary to practice and build proficiency in these skills. The petitioner is responsible for assessing its operations and identifying any additional skills required to operate safely under normal and abnormal conditions. Normal condition skills may include the ability to maintain altitude, maintain VLOS, and navigational skills. Abnormal condition skills may include the abilityto avoid obstacles, avoid airtraffic, and respond to loss of link.

In making its determination the FAA considered the requirements proposed by Astraeus in Exemption No. 

### 11062. The FAA notes that the petitioner's proposed operation is similarto that authorized in Exemption No. 

### 11062 because both include

3 FAA Order 8900.1, Volume 3, Chapter 7, Section 1

### Issue a Certificate ofWaiver orAuthorization:§9I.I19(b) and/or (c) (Minimum SafeAltitudes) and FAA Order 8900.1, Volume 3, Chapter 8, Section 1, 

### Issue a Certificate ofWaiver forMotion Picture andTelevision Filming. 22 \\ ) \ )

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\ ) operations closerthan 500 feet from persons, vessels, vehicles, and structures. In Exemption No. 11062, the FAA required that priorto conducting operations forthe purpose ofmotion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours oftotal time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Priorto operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model of UAS to be used for operations underthe exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive ratherthan additive; i.e. 5 hours make and model time may be included in the 10 hours of multirotortime and the 10 hours may be included in the total 25 hours of UAS rotorcrafttime. In addition to the hour requirements, the PIC must accomplish 3 take-offs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner's proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted underthe grant ofexemption to accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 CFR 91.119.

The flight-hours above are considered appropriate given the circumstances ofthe proposed operation and the description provided by the petitioner ofthe preparations he has undertaken to conduct the UAS operation safely. The petitioner may determinethrough its safety assessment that additional hours are necessaryto address all potential flight hazards and requisite airmanship skills. Consequently, the FAA has included in the conditions and limitations below thatthe petitioner may not permit any PIC to operate unless that PIC is able to safely operate the UAS in a manner consistent with howthe UAS will be operated underthis exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures.

In conclusion, the FAA finds that priorto operations the PIC must, at a minimum, hold a private pilot certificate, athird-class airman medical certificate, and completed the minimum flight hour and currency requirements as stated in the conditions and limitations below. Thus, the FAA finds relieffrom 14 CFR 61.113(a) and (b) is warranted.

In a supplemental request to the FAA, the petitioner requests consideration ofa 120 daytemporary airman certificate in accordance with 14 CFR 63.13, to allow him time to obtain a private pilot certificate. The requested relief is not applicable to pilot certificates because, 14 CFR 63.1,

### Applicability, states this part prescribes the requirements for issuing flight engineer and flight navigator certificates and the general operating rules for holders ofthose certificates, only. Thus, 14 CFR 63.13 does not provide a basis from which to issue atemporary pilot certificate as requested by the petitioner and the requested relief is denied.

The petitioner has also indicated he will supplement his proposed operation(s) with a spotter, hereafter referred to as a visual observer (VO). The conditions and limitations below stipulate thatthe PIC must ensure that the VO can perform the functions prescribed in the operating documents. Additionally, as discussed in Exemption No. 11109 to Clayco, Inc., there are no regulatory requirements forvisual observer medical certificates. Although a medical certificate is not required for a VO, the UA must never be operated beyond the actual visual capabilities ofthe VO, and the VO and PIC must have the abilityto maintain visual line ofsight (VLOS) with the UA at all times. It is the responsibility ofthe PIC to be aware ofthe VO's visual limitations and limit operations ofthe UA to distances within thevisual capabilities of both the PIC and VO. Moreover, the VO will not be operating the aircraft. Therefore, as in Grant of Exemption No. 11062 to Astraeus, the FAA does not consider a medical certificate necessary forthe VO. 

### Operating parameters ofthe UAS

23Regarding the petitioner's requested relieffrom 14 CFR 91.7(a) 

### Civil aircraftairworthiness, petitioner's request is based on his beliefthat since no FAA regulatory standard exists for determining airworthiness ofthe UAS, the regulation is inapplicable. While the petitioner's UAS will not require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H, the FAA considers the petitioner's compliance with his operating documents to be sufficient means for determining an airworthy condition. Therefore, relieffrom § 91.7(a) is granted. The petitioner is still required to ensure that his aircraft is in an airworthy condition- based on compliance with the operating documents priorto every flight, and as stated in the conditions and limitations below. Additionally, in accordance with 14 CFR 91.7(b), the PIC ofthe UAS is responsible for determiningwhetherthe aircraft is in a condition for safe flight. The FAA finds that the PIC can comply with this requirement, therefore relieffrom§ 91.7(b) is not necessary. Regarding the petitioner's requested relieffrom 14 CFR 91.9 

### Civil aircraft flightmanual, marking, andplacardrequirements and 14 CFR 91.203(a) and (b) 

### Civilaircraft: Certifications required, the FAA has previously determined that relieffrom these sections is not necessary. Relevant materials may be kept in a location accessible to the PIC in compliance with the regulations. Regarding the petitioner's requested relieffrom 14 CFR 91.103, 

### PreflightAction, the petitioner requires each PIC to take certain actions before flight to ensure the safety ofthe flight. The exemption is needed because the pilot will take separate preflight actions as referenced in the operating documents. Although there will be no approved Airplane or Rotorcraft Flight Manual available, the FAA believes that the petitioner can comply with the other applicable requirements in 14 CFR 91.103(b)(2). The procedures outlined in the operating documents address the FAA's concerns regarding compliance with § 91.103(b). The PIC will take all actions including reviewing weather, flight battery requirements, landings, and takeoff distances and aircraft performance data before initiation offlight. The FAA has imposed stricter requirements with regard to visibility and distance from clouds; this is to both keep the UA from departingthe VLOS and to preclude the UA from operating in the NAS. The FAA also notes the risks associated with sun glare; the FAA believes that the PIC's and VO's ability to still see other air traffic, combined with the PIC's abilityto initiate a return-to-home sequence, are sufficient mitigations in this respect. The PIC will also account for all relevant site-specific conditions in his or her preflight procedures. Therefore, the FAA finds that exemption from 14 CFR 91.103 is not necessary. Regarding the petitioner's requested relieffrom 14 CFR 91.109(a), 

### Flight instruction; Simulated instrument flight andcertain flight tests, the petitioner did not describe training scenarios in which a dual set ofcontrols would be utilized or required, i.e. dual flight instruction, provided by a flight instructor or other company-designated individual, that would require that individual to have fully functioning dual controls. Rather, the petitioner refers to his "numerous practice flights in remote areas as a hobbyist." But, as outlined above, the FAA is requiring that the petitioner's PIC possess at least a private pilot's certificate. Also, the currency requirements expressed in the conditions and limitations below will help ensure that a PIC training on the UAS has the authorityto operate the UAS during training flights as PIC in accordance with§ 61.31(1). The FAA will impose a limitation that those training operations are only conducted during dedicated training sessions. As such, the FAA finds that the petitioner can conduct his operations without the requested relieffrom § 91.109.
The petitioner's requested relieffrom 14 CFR 91.119, 

### Minimum safe altitudes, relieffrom§ 91.119(a), which requires operating at an altitude that allows a safe emergency landing ifa power unit fails, is not granted. The FAA expects the petitioner to be able to perform an emergency landing without undue hazard to persons or property on the surface if a power unit fails. Relieffrom§ 91.119(b), operation over congested areas, is not granted, because, as discussed below, operations over congested areas will not be permitted underthis exemption.
Relief from§ 91.119(c) is necessary because the aircraft will be operated at altitudes below 300 feet AGL. Section 91.119(c) states that no person may operate an aircraft belowthe following altitudes: 

### over other than congestedareas, an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be

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• operate in reasonably safe environment that are strictly controlled, are away from power lines, elevated lights, airports and actively populated areas awayfrom public and traffic; conduct all operations under his own personal safety protocols (including posting awarning sign reading: "Attention Aerial Photography in Progress- Remain Back 150 Feet") contained in the operating documents and will actively analyze flight data and other sources of information to constantly update and enhance his safety protocols; contact respective airports ifoperations will be within 5 miles to advise them of his estimated flighttime, flight duration, elevation offlight and other pertinent information; and always obtain all necessary permissions priorto operation

. The petitioner proposes to avoid "actively populated areas" but does not explain howthese areas are determined. As in Exemption No. 11110 (Trimble Navigation, Ltd.), the FAA notesthat avoidance of areas which are depicted in "yellow" on VFR charts is a practicable step in assuring that operations are not conducted over congested or densely populated areas. However, using these "yellow" areas solely to make this determination is not sufficient. Pilots mayobtain information regarding congested areas from the local Flight Standards District Office (FSDO). Therefore, operations over congested or densely populated areas are prohibited as stated in the conditions and limitations below.
The petitioner did not describe stand-offdistances from persons, vessels, vehicles and structures. Section 91.119(c) requires that aircraft operate no closerthan 500 feet to these persons or objects. As discussed in Exemption No. 11109 (Ciayco, Inc.), operations conducted closerthan 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. Therefore, the FAA is requiring that priorto conducting UAS operations, all persons not essential to flight operations (nonparticipating persons) must remain at appropriate distances. In open areas, this requires the UA to remain 500 feet from all persons otherthan essential flight personnel (i.e. PIC, VO, operatortrainees or essential persons). The FAA has also considered the UA's maximum gross weight ofapproximately 3 pounds. If barriers or structures are presentthat can sufficiently protect nonparticipating persons from the UA or debris in the event ofan accident, then the UA may operate closerthan 500 feet to persons afforded such protection. The operator must also ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately. When considering howto immediately cease operations, the primary concern is the safety ofthose nonparticipating persons. In addition, the FAA finds that operations may be conducted closerthan 500 feet to vessels, vehicles and structures when the owner/controller ofany such vessels, vehicles or structures grants permission forthe operation and the PIC makes a safety assessment ofthe risk ofoperating closer to those objects and determinesthat it does not present an undue hazard.
Thus, the FAA finds that relieffrom§ 91.119(c) is warranted provided adherence to the procedures in the operating documents and the FAA's additional conditions and limitations outlined below. Relieffrom § 91.119(a) is unwarranted as the FAA expects the petitionerto be able to perform an emergency landing without undue hazard to persons or property on the surface. Relieffrom §§ 91.119(b) is not granted and 91.119(d) is not applicable.
Regarding the petitioner's requested relieffrom 14 CFR 

### 91.121AltimeterSettings, the petitioner has a barometric altimeter and GPS derived altitude capabilities. However, as stated in the conditions and limitations below, the FAA requires any altitude reported to ATC to be in feet AGL. The petitioner may choose to set the altimeterto zero feet AGL rather than local barometric pressure orfield altitude before flight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is granted to the extent necessary to comply with the applicable conditions and limitations stated below.
Regarding the petitioner's requested relieffrom§ 91.151 (a) 

### Fuel requirementsforflight in VFR conditions, prior relief has been granted for manned aircraftto operate at less than prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR 25conditions. The petitioner's only reference to this section is his commitmentto land the UAS priorto the manufacturer's recommended minimum level of battery power. The operating documents indicate thattwo low-voltage (low battery) 

## J alerts are issued- warningthat the first alert should be followed (30%- low battery level warning). Further, the petitioner ', has indicated his flights will last only 3-7 minutes each. Also, the UAS has an automated function which results in '> immediate landing when a low battery is detected. These factors provide the FAA with sufficient reason to grant the relief from 14 CFR 91.151(a) as requested in accordance with the conditions and limitations below, that prohibit the PIC from beginning aflight unless (considering wind and forecast weather conditions) there is enough powerto flyto the first point of intended landing and, assuming normal cruising speed, land the UA with 30% battery power remaining. Regarding an AirTraffic Organization (ATO) issued Certificate ofWaiver or Authorization (COAL the majority ofcurrent UAS operations occurring in the NAS are being coordinated through AirTraffic Control (ATC) bythe issuance of a COA. This is an existing process that not only makes local ATC facilities aware of UAS operations, but also provides ATC the ability to consider airspace issues that are unique to UAS operations. The COA will require the operatorto request a NOT AM, which is the mechanism for alerting other users ofthe NAS to the UAS activities being conducted. The conditions and limitations below prescribe the requirement forthe petitionerto obtain an ATO-issued COA.



### Public Interest

The FAA finds that a grant ofexemption is in the public interest. The enhanced safety and reduced environmental impact achieved using a UA with the specifications described bythe petitioner and carrying no passengers or crew, ratherthan a manned aircraft ofsignificantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. The following table summarizes the FAA's determinations regarding the relief sought by the petitioner:

**R'~liefconsiaered** (14 CFR)

**FAAd~termination(14CFR)'>** 

### ''.'''\ 

# ·' \ Part 21 Relief not necessary 45.23(b) Relief not necessary 61.113(a) and (b) Relief granted with conditions and limitations

63.13 Relief not granted 91.7(a) Relief granted with conditions and limitations 91.9(b)(2) Relief not necessary 91.103{b) Relief not necessary 91.109 Relief not necessary 91.119 Paragraph (c) granted with conditions and limitations 91.121 Relief granted with conditions and limitations
91.151(a) Paragraph 91.151(a)(1), day, granted with conditions and limitations 91.203(a) and (b) Relief not necessary 91.405(a) Relief granted with conditions and Relief considered {14 CFR) FAA determination (14 CFR) limitations 91.407(a)(1) Relief granted with conditions and limitations

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## FAA's Decision In consideration ofthe foregoing, Ifind that a grant ofexemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Mr. Douglas Trudeau, Realtor®, ofTierra Antigua Realty, is granted an exemption from 14 CFR 61.113(a) and (b), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) to the extent necessary to allow petitioner to operate an unmanned aircraft systems (UAS) forthe purpose of aerial videography/cinematography and augment real estate listing videos. This exemption is subject to the conditions and limitations listed below. 

### Conditions and Limitations Relative to this grant ofexemption, Trudeau is hereafter referred to as the operator.
The following documents provided by the operator in its petition, 1) Supplemental Response for Petition, 2) PHANTOM Flying Flow Chart V1.0 (Simplified Version), PHANTOM Quick Start Manual v1.7, PHANTOM Advanced Manual v.1.4, 3) PHANTOM 2 Vision+ User Manual4) restricted areas map, 5) personal protocols and controls, and 6) Safety/Flight Manual, are hereinafter referred to as operating documents.
Failure to comply with any ofthe conditions and limitations ofthis grant ofexemption will be grounds forthe immediate suspension or rescission ofthis exemption.

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### 1) Operations authorized by this grant of exemption are limited to the following aircraft described in the operating documents which is a quad-rotor aircraft weighing less than 3 pounds: PHANTOM 2 Vision+ Unmanned Aircraft System. Proposed operations ofany other aircraft will require a new petition or a petition to amend this grant. 

### 2) The UA may not be flown at an indicated airspeed exceeding 30 knots. 

### 3) The UA must be operated at an altitude of no morethan 300 feet above ground level (AGL), as indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be in feet AGL. 

### 4) The UA must be operated within visual line ofsight (VLOS) ofthe Pilot In Command (PIC} at all times. This requires the PIC to be able to use human vision unaided by any device otherthan corrective lenses, as specified on the PIC's FAA-issued airman medical certificate. 

### 5) All operations must utilize avisual observer (VO). The UA must be operated within the visual line ofsight (VLOS) of the VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. The PIC must be designated before the flight and cannot transfer his or her designation forthe duration ofthe flight. The PIC must ensure that the VO can perform the functions prescribed in the operating documents. 

### 6) The operating documents and this grant ofexemption must be accessible during UAS operations and made available to the Administrator upon request. Ifa discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator mustfollow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documentsto the Administrator upon request. The operator must also present updated and revised documents if he petitions for extension or amendmentto this grant of exemption. Ifthe operator determinesthat any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for amendmentto its grant of exemption. The FAA's UAS28 Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents. 

### 7) Priorto each flight, the PIC must inspectthe UAS to ensure it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the UAS is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition 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. 

### 8) Any UAS maintenance or alterations that affectthe UAS operation orflight characteristics, e.g. replacement ofa 

### J flight critical component, must undergo afunctional test flight. The PIC who conducts the functional testflight ) must make an entry in the aircraft records. ) 

### 9) The pre-flight inspection section in the operating documents must account for all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sections ofthe operating documents. 

### 1

0) The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 

### 11) The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations must be noted in the aircraft records, including total flight hours, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service. 

### 12) Each UAS operated underthis exemption must comply with all manufacturerSafety Bulletins. 

### 13)The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 

### 14) UAS operations must be conducted by a PIC possessing at least a private pilot certificate and at least a current third-class medical certificate. The PIC must also meetthe flight review requirements specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.



### 15) Priorto operations conducted forthe purpose ofaerial videography/cinematography and augmenting real estate listing videos (or similar operationsL the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(bL a minimum of

25 hours oftotal time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior documented flight experiencethat was obtained in compliance with applicable regulations may satisfy 

### )

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this requirement. Training, proficiency, and experience-building flights can also be conducted underthis grant of '· exemption to accomplish the required flighttime. However, said training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 CFR 91.119.


### 16) Priorto operations conducted forthe purpose ofaerial videography/cinematography and augmenting real estate listing videos (or similar operationsL the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(bL a minimum of5 hours as UAS pilot operating the make and model ofthe UAS to be used in operations underthe exemption; 5 hours make and model time may be included in the 10 hours of multi-rotortime prescribed above. The PIC must accomplish 3 take-offs and landings in the preceding 90 days (for currency purposes). Training, proficiency, experience-building, and take-off and landing currency flights can be conducted underthis grant of exemption to accomplish the required flight time and 90 day currency. However, said training \ )

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### ) 29 operations may only be conducted during dedicated training sessions. During training, proficiency, and experiencebuilding flights the

PIC is required to operate the UA with appropriate distances in accordance with 14 CFR 91.119. 17)The operator may not permitthe PIC to operate the UAS forthe purpose ofaerial videography/cinematography and augmenting real estate listing videos (or similar operations), unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(bL the abilityto safely operate the UAS in a manner consistent with howthe UAS will be operated underthis exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 18)UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All operations must be conducted undervisual meteorological conditions (VMC}. 19)The UA may not operate within 5 nautical miles ofan airport reference point as denoted on a current FAA-published aeronautical chart. 20}The UA may not be operated less than 500 feet below or less than 2,000 feet horizontallyfrom a cloud or when visibility is less than 3 statute miles from the PIC. 21)1fthe UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents. 22}The PIC must abortthe flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 23)The PIC is prohibited from beginning aflight unless (considering wind and forecast weather conditions) there is enough powerto fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining. 24)The operator must obtain an AirTraffic Organization (ATO) issued Certificate ofWaiver orAuthorization (COA) prior to conducting any operations underthis grant of exemption. This COA will also require the operatorto request a Notice to Airman (NOTAM) not morethan 72 hours in advance, but not less than 48 hours priorto the operation. 25)AII aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 26)Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 27)The documents required under 14 CFR 91.9 and 91.203 must be available to the PIC atthe Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 28)The UA must remain clear and yield the right ofwayto 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)The UA may not be operated over congested or densely populated areas.31)Fiight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are presentthat sufficiently protect nonparticipating persons from the UA and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; 

### b. The aircraft is operated nearvessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk of operating closerto those objects and determined that it does not present an undue hazard, and; 

### c. Operations nearerto the PIC, VO, operatortrainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 32)AII operations shall be conducted over private or controlled-access property with permission from the land \)



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owner/controller or authorized representative. Permission from land owner/controller or authorized 

### '! representative will be obtained for each flight to be conducted.**~** } 33)Any incident, accident, orflight operation thattransgresses the lateral orvertical 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 be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. ) j Unless otherwise specified in this grant ofexemption, the UAS, the UAS PIC, and the UAS operations must comply with all ) applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.
This exemption terminates on January 31, 2017, unless sooner superseded or rescinded. 

### ) Issued in Washington, DC, on January 5, 2015. 

### /sf JohnS. Duncan Director, Flight Standards Service

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