UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Wilson Security Agency

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATION

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE

 Phantom 2 Vision

UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)
TABLE OF CONTENTS

 page

Glossary of Abbreviations ....................................................... 3

 Summary ........................................................................... 4

 Introduction and Interests of Petitioner ....................................... 5

 Background ........................................................................ 6

 Basis for Petition .................................................................. 7

 Name and Address of Petitioner ................................................ 8

 Specific sections of 14 C.F.R from which Wilson Security Agency seeks

Exemption .......................................................................... 9

The extent of relief Wilson Security Agency seeks relief and the reason

 Wilson Security Agency seeks relief........................................... 10

 The reasons why granting Wilson Security Agency’s request would be

In the public’s interest........................................................... 11

The reasons why granting the exemptions would not adversely affect

Safety.............................................................................. 12

Summary that can be published in the Federal Register..................... 13

Any additional information, views, or arguments available to support

 Wilson Security Agency’s request..............................................

 Conclusion.........................................................................
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest ATC

Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

C.F.R. Code of Federal Regulations

COA Certificate of Authorization FAA

Federal Aviation Administration FAR

Federal Aviation Regulation GCS

Ground Control Station

GPS Global Positioning

System LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft

System VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing 4
SUMMARY

Wilson Security Agency seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b),

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to

operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and

Reform Act of 2012 (FMRA). This exemption will permit Wilson Security Agency to operate an

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial photographs and

video over certain public roadways and public areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

The petitioner, Wilson Security Agency is a licensed N.C. Private Investigative Agency under

Chapter 74-c of the N.C. Administrative statues and conducts investigations whereby aerial

photographs are necessary. Crime scenes and property locations are a part of the routine

investigative process for Wilson Security Agency.

Primarily Wilson Security Agency is a Private Investigative Agency that provides extensive

investigations for N.C. Court appointed criminal cases and private litigation support for attorneys

and private clients.

BACKGROUND

Wilson Security Agency seeks an exemption to operate the DJI Phantom 2 Vision UAS for

compensation within the NAS. The DJI Phantom 2 Vision is comprised of a vertical takeoff and

landing (VTOL) Unmanned Aircraft (UA) and a transportable Ground Control Station (GCS). The

DJI Phantom 2 Vision has a maximum gross weight of approximately 6.6 pounds, while having a

diameter of 31 inches, height of 13 inches, and maximum speed of 23 mph. The DJI Phantom 2

Vision UA is equipped with four propellers, each being driven by an electric motor powered by

Lithium Polymer battery. The DJI Phantom 2 Vision UA that will be operated by Wilson Security

Agency will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14

C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification

and Registration Marking. BASIS FOR PETITION

Petitioner, Wilson Security Agency is pursuant to the provisions of the Federal Aviation Regulations

(14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, Section 333,

Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to operate

the DJI Phantom 2 Vision UAS in the National Airspace System (NAS), and for an exemption from

the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the size, weight, speed, and limited operating area associated with the unmanned

aircraft and its operation, Wilson Security Agency operation of the DJI Phantom 2 Vision UAS

meets the conditions of Section 333 and therefore, will not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H. 6. Accordingly, Wilson Security Agency requests

relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these

sections set forth requirements for maintenance that only apply to aircraft with an airworthiness

certificate. Wilson Security Agency submits that the requested relief is proper since an equivalent

level of safety will be ensured. Wilson Security Agency will use its authorized technicians to

perform maintenance, alterations, or preventive maintenance on the UAS using the methods,

techniques, and practices prescribed in the manufacturer’s maintenance manual. Furthermore,
Wilson Security Agency will document and maintain all maintenance records for the DJI Phantom 2

Vision UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot

privileges and limitations: Pilot in command, is requested by Wilson Security Agency to the extent

necessary to allow a Pilot in Command (PIC) who has completed the DJI Phantom 2 Vision UAS

training and currency requirements, to conduct the proposed UAS flight operations. Wilson Security

Agency submits that the conditions and limitations set forth herein will ensure the safety of the NAS,

as well as the safety of persons or property on the ground.

Wilson Security Agency seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the DJI Phantom 2 Vision UAS does not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H. As such, Wilson Security Agency submits that it will ensure that

the DJI Phantom 2 Vision UAS is in an airworthy condition, prior to every flight, by determining

that the UAS is in compliance with the DJI Flight Manual, and that the aircraft is in a condition for

safe flight.

Wilson Security Agency also seeks an exemption from the requirements of Section 91.121, entitled

Altimeter Settings, as the DJI Phantom 2 Vision UA will not have a typical barometric altimeter

onboard. However, altitude information of the DJI Phantom 2 Vision UAS will be provided to the

PIC via Global Positioning System (GPS) equipment and a radio communications telemetry data

link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude

information, combined with Wilson Security Agency operation of the DJI Phantom 2 Vision UA

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to

Section 91.121.

Additionally, Wilson Security Agency seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. Wilson Security Agency submits

that safety will not be affected by terminating flights of the battery powered DJI Phantom 2 Vision

UA after 30 minutes of continuous flight, which would allow for five minutes of battery power

remaining.

In accordance with 14 C.F.R. § 11.81, Wilson Security Agency provides the following information

in support of its petition for exemption:

A. Name and Address Of The Petitioner.

The name and address of the Petitioner is:

Wilson Security Agency

1314 Briggstown Road

Lexington, North Carolina

27292

Contact; Darrell R Wilson

Wilson Security Agency

B. The Specific Sections Of 14 C.F.R. From Which Wilson Security Agency Seeks Exemption.

1. Wilson Security Agency Seeks Exemption From The Requirements Of Section 61.113(a)

And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a)

and (b) prescribe the following, in relevant part: 8 No person who holds a private pilot certificate

may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for

compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(a) A private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if—
(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

2. Wilson Security Agency Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Wilson Security Agency, Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that

aircraft, as the case may be, by reference to an altimeter that is set, when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of

the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the

current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or

an appropriate altimeter setting available before departure;

4. Wilson Security Agency Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the

following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind

and forecast weather conditions) there is enough fuel to fly to the first point of intended landing

and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. Wilson Security Agency Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between

required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired

as prescribed in part 43 of this chapter[.]

6. Wilson Security Agency Seeks Exemption From The Requirements Of Section 91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or

alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

7. Wilson Security agency Seeks Exemption From The Requirements Of Sections 91.409(a)(1)

And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless,

within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for

return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of

this chapter.
8. Wilson Security Agency Seeks Exemption From The Requirements Of Sections 91.417(a)

And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or

operator shall keep the following records for the periods specified in paragraph (b) of this section: 10

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 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 of an aircraft. The records

must include--

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

(ii) The date of completion of the work performed; and

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

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each 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 of the aircraft, including the time since the last inspection required

by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for

each, the method of compliance, the AD or safety directive number and revision date. If the AD or

safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to

the airframe and currently installed engines, rotors, propellers, and appliances.

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

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is

repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with

the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be

retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief Wilson Security Agency Seeks And The Reason Wilson Security

Agency Seeks The Relief.

1. Extent of Relief Wilson Security Agency Seeks And The Reason Wilson Security Agency

Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in

command, is requested to the extent necessary to allow a PIC holding a private pilot certificate and a

third-class airman medical certificate, and who has completed the DJI training and currency

requirements, to conduct the proposed UAS flight operations for compensation.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private

pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or

employment if - (1) The flight is only incidental to that business or employment; and (2) The

aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, Wilson Security Agency submits that an equivalent level of safety

will be maintained because no person who is not an employee of Wilson Security Agency will have

operation rights to fly or maintain the DJI Phantom 2 Vision and fly the UAS in a manner consistent

with the operations specifications as described in this exemption, including evasive and emergency

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and

structures.
Further, Wilson Security Agency submits that all flights of the DJI Phantom 2 Vision conducted

by the PIC pursuant to the grant of this Petition - (1) will be incidental to Wilson Security

Agency’s business; and (2) will not carry passengers or property for compensation or hire. 12

2. Extent of Relief Wilson Security Agency Seeks And The Reason Wilson Security Agency

Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to

allow American Drones L.L.C. to determine that the DJI Phantom 2 Vision UAS is in an airworthy

condition prior to every flight by ensuring that the UAS is in compliance with the DJI Flight Manual,

and that the aircraft is in a condition for safe flight.

Wilson Security Agency seeks the requested relief because the DJI Phantom 2 Vision UAS does not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore,

Wilson Security Agency will ensure that the DJI UAS is in an airworthy condition based upon its

compliance with the operating documents (i.e., the DJI Flight Manual) prior to every flight, and as

stated in the conditions and limitations below.

3. Extent of Relief Wilson Security Agency Seeks And The Reason Wilson Security Agency

Seeks Relief From Section 91.121.

Relief from Section 91.121 entitled Altimeter settings, may be required to allow flight operations of

the DIJ UAS, which utilizes GPS equipment and a radio communications telemetry data link to

downlink altitude information to the PIC from the UA to the GCS. As more fully set forth below,

safety will be maintained as a result of the DIJ Phantom 2 Vision UA’s altitude readout via GPS

equipment, and Wilson Security Agency’s operation of the DJI Phantom 2 Vision UA within visual

line of sight, at or below 400 feet AGL.

4. Extent Of Relief Wilson Security Agency Seeks And The Reason Wilson Security Agency

Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to

the extent required to allow flights of the battery powered DJI UA during daylight hours in visual

meteorological conditions (VMC), under visual flight rules (VFR) conditions, to continue for a total

duration of 30 minutes, which will ensure that the UA will land with five minutes of battery power

remaining. Wilson Security Agency seeks the requested relief because without an exemption from

Section 91.151(b), the flight time duration of the battery powered DJI UA will severely constrain the

practicality of any aerial acquisition and research flight operations that Wilson Security Agency

proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 Vision UAS, the DJI

Flight Manual, and Wilson Security Agency’s proposed operating limitations, ensure that Wilson

Security Agency will safely operate the battery powered DJI UA during daylight hours in VFR

conditions, for a total flight duration of 30 minutes, landing with five minutes of battery power

remaining.

5. Extent Of Relief Wilson Security Agency Seeks And The Reason Wilson Security Agency

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And

91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to

aircraft with an airworthiness certificate, Wilson Security Agency requests relief from these Sections

because the DJI Phantom 2 Vision UAS does not require an airworthiness certificate. As set forth

more fully below, the DJI Phantom 2 Vision UAS meets the conditions of Section 333 of the FMRA

for operation without an airworthiness certificate. Accordingly, Wilson Security Agency will use

authorized technicians to perform maintenance, alterations, or preventive maintenance on the UAS

using the methods, techniques, and practices prescribed in the manufacturer’s maintenance manual.

Furthermore, Wilson Security Agency will document and maintain all maintenance records for the

DJI Phantom 2 Vision UAS.

D. The Reasons Why Granting Wilson Security Agency’s Request Would Be In The Public
Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Wilson Security Agency to

safely, efficiently, and economically perform aerial photographs and video over public areas of the

United States, commercially, in support of government entities, court ordered investigations, crime

scene documentation, scientific studies, and private investigations. Additionally, use of the DJI

Phantom 2 Vision UAS will decrease congestion of the NAS, reduce pollution, and provide

significant benefits to the economy. Notably, the benefits of Wilson Security Agency’s proposed

operation of the DJI Phantom2 Vision UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit From The Aerial Acquisitioned Photographs and Video Performed.

Wilson Security Agency submits this Petition to commercially operate the DJI Phantom 2 Vision

UAS and perform aerial acquisitions and research throughout areas of the United States, in support of

government entities, private investigations, court appointed investigations, evidentiary video and

photographs of crime scenes, and crime scene direction mapping. The DJI Phantom 2 Vision UAS

will provide safe, efficient, and economical aerial acquisition and research operations to further each

of these fields, all of which are critical to the well-being of the general public.

The specific operations that Wilson Security Agency will perform with the DJI Phantom 2 Vision

UAS demonstrate how the requested exemption will directly benefit the above-referenced industries

and the public. In court appointed investigations, the aerial acquisition performed by the DJI

Phantom 2 Vision will create critical aerial evidence of a wider area than could be done on the

ground. In private investigations the DJI Phantom 2 Vision UAS will be used to aid in property

inspections, and crime scene evidence. The DJI Phantom 2 Vision UAS will also further the

investigative process since large and vast amounts of photographs can be condensed into one video

segment for court preparation and court viewing.

2. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 2 Vision UA is battery powered and serves as a safe, efficient, and economical

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use

Of a DJI Phantom 2 Vision UAS would reduce the amount of manned aircraft in the NAS, reduce

noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around

airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 2 Vision UA

does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting

aerial survey missions would result in fewer aircraft that must be handled by air traffic control during

the ground, takeoff, departure, arrival, and landing phases of flight operations.

3. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 Vision UAS.

Conducting aerial acquisitions with the DJI Phantom 2 Vision UAS, instead of manned aircraft, will

greatly benefit the public by drastically reducing the levels of air and noise pollution generated

during traditional aerial survey flight operations. By using battery power and electric motors, the

DJI Phantom 2 Vision UAS produces no air pollution, and is the most viable environmentally

conscious alternative to the cabin class, six cylinder internal combustion twin engine aircraft that are

typically utilized for aerial acquisitions, while burning approximately 20-30 gallons per hour of

leaded aviation fuel. The DJI Phantom 2 Vision UA, while reducing the carbon footprint of aerial

acquisitions, also eliminates noise pollution, as the UA is propelled by battery powered electric

motors, rather than an internal combustion engine.

By using the DJI Phantom 2 Vision UAS to perform aerial acquisitions, the substantial risk to life and

property in the air and on the ground, which is usually associated with traditional manned aircraft flight

operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew

members located onboard the aircraft, the DJI Phantom 2 Vision UA (weighing approximately 6.6

pounds at its maximum gross weight with a diameter of 31 inches, and with no fuel on board), has less
physical potential for collateral damage to life and property on the ground, and in the air, compared to the

manned aircraft that typically conduct aerial acquisitions (weighing approximately 6,500 pounds with

a wingspan of approximately 40 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

4. Performing Aerial Acquisition Operations With The DJI Phantom 2 Vision UAS Will

Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision UAS is also an economical

alternative to using manned aircraft to conduct aerial acquisitions. As such, operation of the DJI

Phantom 2 Vision UAS will allow United States based companies, like American Drones L.L.C, to

remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost

of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out

leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative

technology in order to remain competitive. Operating the battery powered DJI Phantom 2 Vision

UAS is one such technology that not only allows companies greater operational flexibility compared

to manned aircraft, but provides such flexibility without the high operational cost of a traditional

manned aircraft.

By operating the DJI Phantom 2 Vision UAS, companies such as American Drones L.L.C. can

remain competitive and profitable, and therefore, provide greater job stability to employees and

contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial

performance of U.S. companies, through commercial use of the DJI Phantom 2 Vision UAS,

provides a stable workforce that increases consumer spending; improves local, state, and federal

tax revenues; and allows companies to invest in research and development in order to remain

competitive both in the United States and abroad.

5. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades,

American Drones L.L.C’s proposed operation of the DJI Phantom 2 Vision UAS will not

implicate any privacy issues. Specifically, the DJI Phantom 2 Vision UAS will be operated only in

rural areas, and in accordance with all Federal Aviation Regulations, including the minimum

altitude requirements of 14 C.F.R. § 91.119. Most significantly, the DJI Phantom 2 Vision UA

will not be operated closer than 500 feet to any person, vessel, vehicle, or structure, which is not

directly involved in the operation.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or

How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided

By The Rule From Which American Drones L.L.C. Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision UAS Meets The Conditions Of The FAA

Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned

aircraft and its operation, American Drones L.L.C’s operation of the DJI Phantom 2 Vision UAS

meets the conditions of FMRA Section 333, and will not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the

following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days

after the date of enactment of this Act, the Secretary of Transportation shall determine if certain

unmanned aircraft systems may operate safely in the national airspace system before completion of

the plan and rulemaking required by section 332 of this Act or the guidance required by section 334

of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a),

the Secretary shall determine, at a minimum-- 18
(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed,

operational capability, proximity to airports and populated areas, and operation within visual line

of sight do not create a hazard to users of the national airspace system or the public or pose a threat

to national security; and
(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under

section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft

systems identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section that certain

unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall

establish requirements for the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, American Drones L.L.C submits that the DJI Phantom 2 Vision UAS can

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics

of the DJI Phantom 2 Vision UAS; (b) the pilot certification requirement; and (c) the specific

operating limitations.

a. The Specifications Of The DJI Phantom 2 Vision UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision UAS does not create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security considering its size, weight, speed, and operational

capability.

i. Technical Specifications Of The DJI Phantom 2 Vision UAS.

The technical specifications of the DJI Phantom 2 Vision UAS are set forth in Appendix C of the

“Flight Manual For The DJI Phantom 2 Vision Unmanned Aircraft System (UAS),” attached hereto

as Exhibit A. Exhibit A contains proprietary information and is to be held in a separate file pursuant

to 14 C.F.R. § 11.35(b)1. 1 Exhibits to this Petition contain proprietary information, and in accordance with 14 C.F.R. § 11.35(b),

are not to be included in the Federal Docket Management System (FDMS).

ii. The DJI Phantom 2 Vision UAS Autonomous Flight And Navigation Modes Enable The

UAS To Remain Within A Defined Operational Area.

A complete description of the autonomous modes and methods of navigation of the DJI Phantom 2

Vision UAS is provided at pages 2, 4, 5, and 10 of the “Flight Manual For The DJI Phantom 2

Vision Unmanned Aircraft System (UAS),” attached hereto as Exhibit A. Exhibit A contains

proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

iii. The DJI Phantom 2 Vision UAS Is Designed For Automatic Return To Launch In The

Event Of Loss Of The Control Link Or Navigation.

A complete description of the DJI Phantom 2 Vision UAS’s automatic return to launch function in

the event of a break in communication or loss of telemetry data is set forth on pages 2, 9, and 10 of

the “Flight Manual For The DJI Phantom 2 Vision Unmanned Aircraft System (UAS),” attached

hereto as Exhibit A. Exhibit A contains proprietary information and is to be held in a separate file

pursuant to 14 C.F.R. § 11.35(b). b. Flight Operations Of The DJI Phantom 2 Vision UAS Are

Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

American Drones L.L.C will only utilize certificated pilots who possess a valid airman medical

certificate to act as a pilot in command (PIC) of the DJI Phantom 2 Vision UAS. Additionally, a

safety observer will assist all pilots. The PIC must complete the DJI Phantom 2 Vision UAS training

and qualification, as set forth in the “Flight Manual For The DJI Phantom 2 Vision Unmanned

Aircraft System (UAS),” attached hereto as Exhibit A. Exhibit A contains proprietary information

and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). 20

c. Flights Of The DJI Phantom 2 Vision UAS Will Be Conducted Pursuant To Specific

Operating Limitations.

In seeking this exemption, Wilson Security Agency proposes to commercially operate the DJI

Phantom 2 Vision UAS for the special purpose of conducting aerial acquisitions over public areas of

United States, pursuant to the following specific operating limitations:

1) Operations authorized by this grant of exemption are limited to the following aircraft described in

the operator’s manual which is a quad rotor aircraft weighing less than 10 pounds: DJI Phantom 2

Vision Unmanned Aircraft System. Proposed operations of any 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 25 MPH & the UA must be operated

at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures

specified in the operator’s manual. All altitudes reported to ATC must be in feet AGL.

3) 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.

4) All operations must utilize a visual observer (VO). 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 for the duration of the flight.

5) The operator’s manual and this grant of exemption must be maintained and made available to the

Administrator upon request. If a discrepancy exists between the conditions and limitations in this

exemption and the procedures outlined in the operator’s manual, the conditions and limitations herein

take precedence and must be followed. Otherwise, the operator must follow the procedures as

outlined in its operator’s manual.

The operator may update or revise its operator’s manual. It is the operator’s responsibility to track

such revisions and present updated and revised documents to the Administrator upon request. The

operator must also present updated and revised documents if it petitions for extension or

amendment. 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 amendment to their exemption.

The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates

or revisions to the operator’s manual.

6) Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. 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. The Ground Control Station must be included in the preflight inspection.

All maintenance and alterations must be properly documented in the aircraft records.

7) 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

in accordance with the operator’s manual. The PIC who conducts the functional test flight must make

an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional

test flight and aircraft record entry must be added to the operator’s manual.

8) The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or

equipment, not covered in the relevant preflight inspection sections of the operator’s manual.

9) The operator must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul,

replacement, inspection, and life limit requirements, with particular attention to flight critical

components that may not be addressed in the manufacturer’s manuals.

10) Wilson Security Agency must carry out their maintenance, inspections, and record keeping

requirements in accordance with the operator’s manual. Maintenance, inspection, and alterations

must be noted in the aircraft logbook, including total flight hours, description of work accomplished,

and the signature of the authorized UAS technician or PIC returning the UAS to service.

11) Wilson Security Agency UAS technicians must receive and document training referenced in

the operator’s manual.

12) Each UAS operated under this exemption must comply with all manufacturer System and Safety

Bulletins.

13) Wilson Security Agency maintenance personnel must make a record entry in the UAS logbook

or equivalent document of the corrective action taken against discrepancies discovered between

inspections.

15) The PIC must possess at least a private pilot certificate and a third-class airman medical

certificate. The PIC must also meet the flight review requirements specified in 14 C.F.R. § 61.56
in an aircraft in which the PIC is rated on his or her pilot certificate.

16) The operator may not permit any PIC to operate unless that PIC has demonstrated, through

the training and currency requirements set forth in the operator’s manual, that the PIC is able to

safely operate the UAS in a manner consistent with how the UAS will be operated under this

exemption, including evasive and emergency maneuvers and maintaining appropriate distances

from people, vessels, vehicles and structures. 22

17) UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations

must be conducted under visual meteorological conditions (VMC). Flights under special visual flight

rules (SVFR) are not authorized.

18) The UA may not operate within 5 nautical miles of the airport reference point as denoted on a

current FAA-published aeronautical chart. The UA may not operate within 3 nautical miles from any

city or densely populated area.

19) 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.

20) 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 and land, or be recovered in accordance with

the operator’s manual.

21) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance

with the operator’s manual.

22) The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast

weather conditions and assuming normal cruising speed) there is enough power to fly to the first

point of intended landing prior to utilizing battery reserve power.

23) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or

Authorization (COA) prior to conducting any operations under this grant of exemption. This COA

will also require the operator to request issuance of a Notice to Airman (NOTAM) not more than

72 hours in advance, but not less than 48 hours prior to the operation.

24) All aircraft operated in accordance with this exemption must be identified by serial number,

registered in accordance with 14 C.F.R. Part 47, and have identification (N-Number) markings

in accordance with 14 C.F.R. Part 45, Subpart C. Markings must be as large as practicable.

25) Before conducting operations, the radio frequency spectrum used for operation and control of

the UA must comply with the Federal Communications Commission (FCC) or other appropriate

government oversight agency requirements.

26) The documents required under 14 C.F.R. 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 upon request.

27) The UA must remain clear and yield the right of way to all other manned aviation operations and

activities at all times.

28) The UAS may not be operated by the PIC from any moving device or vehicle. 23

29) The UA may not be operated over congested or densely populated areas. These areas include but

are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional

Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). However, aeronautical charts may

not reflect pertinent local information. Ultimately, it

is the PIC’s responsibility to maintain the minimum safe altitudes required by § 91.119.

30) Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons

other than the PIC or VO), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 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 and/or;

b. the aircraft is operated near vessels, vehicles or structures where the land owner/controller has

granted permission and the PIC has made a safety assessment of the risk of operating closer to those

objects and;

c. operations near the PIC or VO do not present an undue hazard to the PIC or VO, per § 91.119(a). 31)

All operations shall be conducted over private or controlled-access property with permission from the

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

representative will be obtained prior to the beginning of every flight.

32) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries

of the 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.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would

Not Adversely Affect Safety.

Wilson Security Agency submits that the equivalent level of safety established by Section 61.113(a)

and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision

UAS unless that PIC has demonstrated, through the DJI Phantom 2 Vision UAS training and

currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision UAS in a

manner consistent with this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from people, vessels, vehicles and structures. 24

Considering Wilson Security Agency’s proposed area of operations, and the operating limitations

set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to

safely operate the DJI Phantom 2 Vision UAS, Wilson Security Agency submits that the additional

manned airmanship experience of a commercially certificated pilot would not correlate to the

airmanship skills necessary for Wilson Security Agency’s specific proposed flight operations.

The DJI Phantom 2 Vision UAS was the subject of a previous Grant of Exemption from Section

61.113(a) and (b). In Exemption No. 11109, the FAA granted relief from Section 61.113(a) and (b)

concerning the operation of the DJI Phantom 2 Vision UAS by a PIC holding a private pilot

certificate and third class airman medical certificate, based upon the following analysis:

The FAA has analyzed Clayco’s proposed operation and has determined that it does not differ

significantly from the situation described in Grant of Exemption No. 11062 (Astraeus Aerial). Clayco

plans to operate over private property with controlled access in the NAS. Given: 1) the similar nature

of Clayco’s proposed operating environment to that of Astraeus’, 2) the parallel nature of private

pilot aeronautical knowledge requirements to those of commercial requirements [ref: Exemption No.

11062], and 3) the airmanship skills necessary to operate the UAS, the FAA finds that the additional

manned airmanship experience of a commercially certificated pilot would not correlate to the

airmanship skills necessary for Clayco’s specific proposed operations. Therefore, the FAA finds that

a PIC holding a private pilot certificate and a third-class airman medical certificate is appropriate for

the proposed operations.

With regard to the airmanship skills necessary to operate the UAS (item #3 stated above), Clayco has

proposed a 100 hour training program and 6 month currency requirements. The conditions and

limitations below stipulate that Clayco may not permit any PIC to operate unless that PIC has

demonstrated through Clayco’s training and currency requirements that the PIC is able to safely

operate the UAS in a manner consistent with how the UAS will be operated under this exemption,

including evasive and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.
See Exemption No. 11109 at 12.

Additionally, the FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS,

in circumstances similar, in all material respects, to those presented herein (e.g. 25

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138).

As in Exemption No. 11109, Wilson Security Agency will not allow any PIC to operate the DJI

Phantom 2 Vision UAS unless that PIC has demonstrated through the DJI Phantom 2 Vision UAS

training and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision

UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from people, vessels, vehicles and structures.

A complete description of the DJI Phantom 2 Vision UAS Training and Qualification requirements is

set forth at page 5 of the “Flight Manual For The DJI Phantom 2 Vision h Unmanned Aircraft

System (UAS),” attached hereto as Exhibit A. Exhibit A contains proprietary information and is to

be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to

every flight, Wilson Security Agency will ensure that the DJI Phantom 2 Vision UAS is in an

airworthy condition based upon the DJI Phantom 2 Vision UAS’s compliance with its operating

documents (i.e., the DJI Phantom 2 Vision Flight Manual), and as stated in the conditions and

limitations herein.

The DJI Phantom 2 Vision UAS was the subject of a previous Grant of Exemption from Section 91.7(a)

(Exemption No. 11109). Additionally, the FAA has previously granted relief from Section 91.7(a)

specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,

11138). 26

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the altitude

information of the DJI Phantom 2 Vision UA will be provided to the PIC via GPS equipment and a

radio communications telemetry data link, which downlinks from the UA to the GCS for active

monitoring of the flight path. This altitude information, combined with American Drones L.L.C’s

operation of the DJI Phantom 2 Vision UA within visual line of sight, at or below 400 feet AGL,

will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated

by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point

will be established and confirmed for accuracy by the UAS PIC. The DJI Phantom 2 Vision UAS

was the subject of a previous Grant of Exemption from Section 91.121 (Exemption No. 11109).

Additionally, the FAA has previously granted relief from Section 91.121 specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would

Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R.

Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 2 Vision UAS;

(2) the limitations on the proposed flight operations; and (3) the location of the proposed flight

operations. Accordingly, Wilson Security Agency will ensure that it can safely operate the battery

powered DJI Phantom 2 Vision UA during daylight hours, in VFR conditions, for a total flight

duration of no more than 30 minutes, resulting in a landing with five minutes of battery power
remaining. In a previous Petition for Exemption, in which an operator was utilizing a DJI Phantom 2

Vision UAS identical in all material respects to the DJI Phantom 2 Vision UAS Wilson Security

Agency proposes to use, the FAA granted an exemption from the requirements of Section 91.151,

stating as follows:

In the event that the UAS should run out of power, it would simply land within the access controlled

operating area. Given its weight and construction material, the risks are less than contemplated by

the current regulation. Prior relief has been granted for manned aircraft to operate at less than the

minimums prescribed in § 91.151 (a), including Exemption Nos. 2689, 5745, and 10650. In addition,

similar UAS-specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for

daytime, Visual Flight Rules (VFR) conditions. The DJI Phantom 2 Vision provides a battery failsafe

that commands the UA’s return to the launch point when critical minimum voltage is reached. The

UAS batteries provide approximately 35 minutes of powered flight. The FAA agrees with Clayco’s

proposal to limit UAS flights to not more than 30 minutes, or enough battery reserve to ensure that

the UAS lands at the ground station with at least 20% battery reserve power, whichever happens

first. Given the limitations on its proposed operations and the location of those proposed operations,

a reduced minimum power reserve for flight in daylight VFR conditions is reasonable.

See Exemption No. 11109 at 15.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 Vision UAS; the

limitations on the proposed flight operations; and the location of the proposed operations, will ensure

that Wilson Security Agency may safely operate the battery powered DJI Phantom 2 Vision UA

during daylight hours in VFR conditions for a total duration of not more than 30 minutes, and

landing with five minutes of battery power remaining.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that

safety is not adversely affected when the technical characteristics and operating limitations of the

UAS are considered. Relief has been granted for manned aircraft to operate at less than the

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650.

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

288811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109,

11110, 11136, 11138).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, Wilson Security Agency submits that the equivalent level of safety with

regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Wilson Security

Agency will use its trained technicians to perform maintenance, alterations, or preventive

maintenance on the unmanned aircraft system using the methods, techniques, and practices

prescribed in the manufacturer’s maintenance manual. Furthermore, Wilson Security Agency will

document and maintain all maintenance records for the DJI Phantom 2 Vision UAS.

Since the DJI Phantom 2 Vision UAS will be inspected as prescribed by the manufacturer’s

maintenance manual, Wilson Security Agency will maintain the equivalent level of safety

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The Flight Manual For The

DJI Phantom 2 Vision UAS sets forth airworthiness requirements for the UA, including preflight

and post flight inspections, as well as scheduled maintenance in four categories: daily, weekly,

monthly, and yearly.

Likewise, the exemption sought will not adversely affect safety because Wilson Security Agency

will perform maintenance, alterations or preventive maintenance on the UAS using the methods,

techniques, and practices prescribed by the manufacturer’s maintenance manual. The Flight Manual

For The DJI Phantom 2 Vision UAS details procedures for each component of the UA, including the
components of the propulsion system, avionics system, and payload system.

A complete description of the DJI Phantom 2 Vision UAS airworthiness and maintenance

requirements is set forth at page 6 of the “Flight Manual For The DJI Phantom 2 Vision Unmanned

Aircraft 29 System (UAS),” attached hereto as Exhibit A. Exhibit A contains proprietary

information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

Furthermore, the exemption sought would maintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2

Vision UAS will be performed by Wilson Security Agency trained technicians, who will

document and maintain maintenance records for the DJI Phantom 2 Vision UAS.

Significantly, previous exemptions granted by the FAA concerning the DJI Phantom 2 Vision

UAS and Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish

that safety is not adversely affected when the technical characteristics and operating limitations of

the UAS are considered. In Exemption No. 11109, the FAA stated the following concerning the

DJI Phantom 2 Vision UAS and the DJI Phantom 2 Vision Flight Manual:

Regarding the petitioner’s requested relief from 14 C.F.R 91.405 (a) Maintenance required, 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 91.409(a)(2) Inspections, and 91.417(a) and (b) Maintenance records, the FAA has determined that

relief from § 91.409(a)(1) is also necessary because it is an alternate inspection requirement of §

91.409(a)(2). The FAA has carefully evaluated the petitioner’s request and determined that cause for

granting the exemption is warranted. The FAA notes that the petitioner’s DJI Phantom 2 Vision UAS

Flight Manual contain daily, preflight, monthly and yearly checks for the UAS. The FAA finds that

adherence to the DJI Phantom 2 Vision Flight Manual, as required by the conditions and limitations

below, is sufficient to ensure that safety is not adversely affected. In accordance with the petitioner’s

UAS maintenance, inspection, and recordkeeping requirements, the FAA finds that exemption from

14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) is warranted subject to

the conditions and limitations below.

In consideration of Wilson Security Agency’s proposed operating limitations, the most recent DJI

Phantom 2 Vision Flight Manual, and the technical aspects of the DJI Phantom 2 Vision UAS,

Wilson Security Agency submits that safety will not be adversely affected by granting exemption

from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b).

The FAA has previously granted relief specific to UAS in circumstances similar, in all material

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11112, 11136, 11138).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and

14 C.F.R. § 21.16 entitled Special Conditions, Wilson Security Agency requests that the FAA

prescribe special conditions for the intended operation of the DJI Phantom 2 Vision UAS, which

contain such safety standards that the Administrator finds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b),

91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Such special conditions will permit safe operation of the UAS for the limited purpose of conducting

aerial acquisitions over certain rural areas of the United States. FMRA Section 333 sets forth the

requirements for considering whether a UAS will create a hazard to users of the NAS or the public,

or otherwise pose a threat to national security; and further, provides the authority for such UAS to

operate without airworthiness certification in accordance with any requirements that must be

established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Phantom 2 Vision UAS, since the airworthiness regulations of 14

C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual
design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual

design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and

amendments thereto for the product. The special conditions are issued in accordance with Part 11 of

this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA

finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16. 31

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe

special conditions for Wilson Security Agency’s intended operation of the DJI Phantom 2 Vision

UAS, which contain such safety standards that the Administrator finds necessary to establish a level

of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating:

The Rules From Which Wilson Security Agency Seeks Exemption:

Wilson Security Agency seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b),

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Wilson Security Agency Seeks:

This exemption will permit Wilson Security Agency to commercially operate an Unmanned Aircraft

System (UAS) for the purpose of conducting aerial acquisitions and research over certain public

areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Wilson Security

Agency’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section

333, which directs the Secretary of Transportation to determine if certain UAS may operate safely

in the NAS. As such, Wilson Security Agency’s request for exemption may be granted pursuant to

the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard

to users of the NAS or the public, or otherwise pose a threat to national security; and further,

provides the authority for such UAS to operate without airworthiness certification. As discussed in

detail above, Wilson Security Agency will operate the DJI Phantom 2 Vision UAS safely in the

NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to

national security.

CONCLUSION

As set forth herein, Wilson Security AGency seeks an exemption pursuant to 14 C.F.R. § 11.61 and

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe

operation of the DJI Phantom 2 Vision UAS commercially, without an airworthiness certificate, for

the limited purpose of conducting aerial acquisitions over certain public areas of the United States.

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the

FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by

allowing Wilson Security Agency to safely, efficiently, and economically operate the DJI Phantom

2 Vision UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and

Reform Act of 2012, Section 333, Wilson Security Agency respectfully requests that the Administrator

grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b),

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and

permit Wilson Security Agency to operate the DJI Phantom 2 Vision UAS commercially for the purpose
of conducting aerial acquisitions, investigations, crime scene video rendering and research over certain

public areas of the United States.
Dated: February 17th

, 2015

Submitted on behalf of Wilson Security Agency

Darrell Reid Wilson

Owner Investigator

Wilson Security Agency

1314 Briggstown Road

Lexington, North Carolina 27292

Email

wilsonsecurityagency@gmail.com