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 F AA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

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### TABLE OF CONTENTS

page

Glossary of Abbreviations

... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 3 Summary

... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 4 Introduction and Interests of Petitioner

... ... ... ... ... ... ... ... ... ... ... ... ... 5 Background

... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 6 Basis for Petition

... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 7 Name and Ad dress of Petitioner

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

... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ..... 9 T he 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 S afety

... . ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. 12 Summary that can be published in the Fe deral 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 GC S 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 4SUMMARY Wilson Security Agencyseeks 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 Agencyto 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 Agencyseeks 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 VisionUA is equipped with fourpropellers, 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 Agencywill 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 Agencyis 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 t he Administrator to operate the DJI Phantom 2 VisionUAS 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 91.41 7(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 andtherefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 6

. Accordingly, Wilson Security Agencyrequests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these

se ctions set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Wilson Security Agencysubmits that the requested relief is proper since an equivalent level of safety will be ensured. Wilson Security Agencywill 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 Agencywill document an d 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 Agencyto the extent

ne cessary 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 Agencysubmits 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 Agencyseeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 2 VisionUAS does not require an airwor thiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Wilson Security Agencysubmits 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 DJIFlight 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 (G PS) 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 v isual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, Wilson Security Agencyseeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR con ditions

. Wilson Security Agencysubmits 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 Agencyprovides the following information in support of its petition for exemption:

A. Name a nd Address Of The Petitioner. The name and address of the Petitioner is: Wilson Security Agency 1314 Briggstown Road Lexington, North Carolina 27292

Contact; D arrell 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 pi lot 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 alti meter 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 depa rture airport or an appropriate altimeter setting available before departure; 4. Wilson Security Agency S eeks 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 altera tion , 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) And91.417(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 peri ods specified in paragraph (b) of this section: 10 (1) Records of the maintenance, prevent ive 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 re cords 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 aircr aft 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 curren t 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 prescr ibed: (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 b e 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 f or 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 DJItraining 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 prop erty for compensation or hire. As set forth more fully below, Wilson Security Agencysubmits 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 main tain 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 a nd
structures.Further, Wilson Security Agencysubmits 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 airworthin ess , 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 DJIFlight Manual, and that the ai rcraft is in a condition for safe flight. Wilson Security Agencyseeks the requested relief because the DJI Phantom 2 VisionUAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Wilson Security Agen cywill ensure that the DJIUAS is in an airworthy condition based upon its compliance with the operating documents (i.e., the DJIFlight Manual) prior to every flight, and as stated in the conditions and limitations below. 3. Extent of Relief Wilson S ecurity 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 commun ications 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 VisionUA’s altitude readout via GPS equipment, and Wilson Security A gency’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 DJIUA 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 Agencyseeks the requested relief because without an exemption from Section 91.151(b), the flight time durati on of the battery powered DJIUA 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 VisionUAS, the DJI Flight Manual, and Wilson Security Agency ’s proposed operating limitations, ensure that Wilson Security Agencywill safely operate the battery powered DJIUA 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 Agencyrequests relief from these Sections because the DJI Phantom 2 Vision UAS does not require an airworthiness certificate. As set forth more fully below, the DJIPhantom 2 Vision UAS meets the conditions of Section 333 of the FMRA for operation without an ai rworthiness certificate. Accordingly, Wilson Security Agencywill 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 Agencywill 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 PublicInterest; That Is, How It Would Benefit T he Public As A Whole. Granting the present Petition will further the public interest by allowing Wilson Security Agencyto safely, efficiently, and economically perform aerial photographs and video over public areas of the Unit ed 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, redu ce pollution, and provide significant benefits to the economy. Notably, the benefits of Wilson Security Agency ’s proposed operation of the DJI Phantom2 VisionUAS will be realized without implicating any privacy issues. 1. The Public Will Benefit From The Aerial Acquisition ed Photographs and Video Performed. Wilson Security Agencysubmits this Petition to commercially operate the DJI Phantom 2 Vision UAS and perform aerial acquisition s 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 aer ial 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 w ill 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 phot ographs 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, conge stion 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 ai rcraft 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 acquis itions 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 ele ctric 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
motor s, 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 i nches, and with no fuel on board), has lessphysical 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 po unds 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 VisionUAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 2 VisionUAS 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

r emain 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 compare d 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 profitabl e, 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 V isionUAS, 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. T here 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, th e DJI Phantom 2 VisionUAS 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 operate d 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 VisionUAS Meets The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weig ht, 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 VisionUAS 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 othe rwise 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 laterthan 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 t hreat 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 ope ration 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 Secreta ry 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 VisionUAS; (b) the pilot certification requirement; and (c) the specific operating limitations. a. The Specifications Of The DJI Phantom 2 VisionUAS 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, weig ht, speed, and operational capability. i. Technical Specifications Of The DJI Phantom 2 VisionUAS. 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 VisionUnmanned Aircr aft 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 VisionUAS Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area. A complete description of the autono mous modes and methods of navigation of the DJI Phantom 2 VisionUAS is provided at pages 2, 4, 5, and 10 of the “Flight Manual For The DJI Phantom 2 VisionUnmanned Aircraft System (UAS),” attached hereto as Exhibit A. Exhibit A contains proprietary infor mation and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). iii. The DJI Phantom 2 VisionUAS 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 VisionUAS’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),” attache d 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 VisionUAS Are Limited To The Line Of Sight Of A Certificated Pilot in Comman d 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 i s to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). 20 c. Flights Of The DJI Phantom 2 VisionUAS 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 authoriz ed 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 VisionUnmanned Aircraft System. Proposed operations of any other aircraft wil l 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 pr ocedures 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 PI C 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 limitatio ns 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 a nd 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 bas is 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) Prio r 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 be en 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 unde rgone 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 discr epancies, 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, insp ection, and life limit requirements, with particular attention to flight critical components that may not be addressed in the manufacturer’s manuals. 10) Wilson Security Agencymust carry out their maintenance, inspections, and record keeping requirement s 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 AgencyUAS 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 Agencymaintenance personnel must make a record entry in the UAS logbook or equivalent document of the corrective action taken against discrepancies discovered between i nspections. 15) The PIC must possess at least a private pi lot certificate and a third

- class airman medical certificate. The PIC must also meet the flight review requirements specified in 14 C.F.R. § 61.56in an aircraft in which the PIC is rated on his or her pilot certificate. 16) The operator may not permit an y 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 exempti on, 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 und er 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. Th e 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 f light 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 u nder 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 l arge 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 upo n 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). Howeve r, 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 nonparticipatin g 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 suchprotection. 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. Pe rmission 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 defin ed 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 Agencysubmits 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 Agencysubmits 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 VisionUAS by a PIC holding a private pilot certificate and third clas s 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 nat ure 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 commerci ally 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 fo r 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 Clay co 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, includin g 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 Agencywill not allow any PIC to operate the DJI Phantom 2 Vision UAS unless that PIC has demonstrated through the DJI Phantom 2 VisionUAS 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, v ehicles and structures. A complete description of the DJI Phantom 2 VisionUAS Training and Qualification requirements is set forth at page 5 of the “Flight Manual For The DJI Phantom 2 Visionh 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 e quivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Wilson Security Agencywill ensure that the DJI Phantom 2 Vision UAS is in an airworthy condition based upon the DJI Phantom 2 Vision UAS’s complianc e with its operating documents (i.e., the DJI Phantom 2 VisionFlight 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, 11 112, 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 Phan tom 2 VisionUA 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 Agencywill 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 powerremaining. In a previous Petition for Exemption, in which an operator was utilizing a DJI Phanto m 2 VisionUAS identical in all material respects to the DJI Phantom 2 Vision UAS Wilson Security Agencyproposes 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 DJ I 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 tho se 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 Agencymay 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 characterist ics 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. R easons 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 Agencysubmits 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 Agencywill u se 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 VisionUAS. Since the DJI Phantom 2 Vision UAS will be inspected as prescribed by the manufacturer’s maintenance manual, Wilson Security Agencywill 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 thecomponents of the propulsion system, avionics system, and payload system. A complete description of the DJI Phantom 2 VisionUAS airworthiness and maintenance requirements is set forth at page 6 of the “Flight Manual For The DJI Phantom 2 VisionUnmanned Aircraft 29 System (UAS),” attached hereto as Exhibit A. Exhibit A contain s 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 VisionUAS will be performed by Wilson Security Agencytrained 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 characteristic s 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 91.40 5 (a) Maintenance required

, 91.407(a)(1) O peration 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 nec essary 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 VisionUAS 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 adve rsely 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 co nditions 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 VisionUAS, Wilson Security Agencysubmits thatsafety 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

re spects, 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 Moderni zation and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions

, Wilson Security Agencyrequests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2 VisionUAS, which contain such safety standard s 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 considerin g 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 tha t 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 VisionUAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusualdesign 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 p ropeller, 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 Sec tions 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: Wils on 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 d etermine 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 requirem ents 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 det ail above, Wilson Security Agencywill operate the DJI Phantom 2 VisionUAS 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 AGencyseeks 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 Agencyto safely, efficiently, and economically operate the DJI Phantom 2 VisionUAS commercially within the NAS. WHEREFORE , i n accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Wilson Security Agencyrespectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sec tions 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 purposeof conducting aerial acquisitions , investigations, crime scene video rendering and research over certain public areas of the United States.Dated: February 17 th

, 2015 Submitted on behalf of Wilson Security Agency

Darrell Reid Wilson O wner Investigator Wilson Security Agency 1314 Briggstown Road Lexington, North Carolina 27292

Email 

### wilsonsecurityagency@gmail.com