Petition for Exemption (Pursuant to 14 CFR Section 11.81)

**Identification of Petitioner** This petition for exemption is submitted on behalf of Aerial Strategies, LLC 13103 Aden Road, Nokesville, VA 20181, (via email at dpreznuk@aerialstrategies.com). **Petition Based Upon Prior Exemption** This petition is based, in part, upon prior exemption granted pursuant to In the matter of Douglas Trudeau, Realtor (Regulatory Docket No. FAA

- 2014

- 0481, Exemption issued lanuary 5, 2015). **Request for Exemption** Aerial Strategies respectfully requests relief from the following regulations for the purpose of conducting flight instruction and commercial "aerial work" flight operations (as defined b y 14 CFR Section 119.1(e)(1) Student instruction, Section 119.1(e)(4)(iii) Aerial photograph y or survey , and Section 119.1(e)(4)(vi) Powerline or pipeline patrol) utilizing DJ I Phantom 3 and DJ I Inspire 1 Unmanned Aerial S ys tems ("UAS"): Part 21 prescribing the procedural requirements for issuing and changing design approvals, p roductions approvals, airworthiness certificate s, and airworthiness approvals. (A erial Strategies believes relief from this section is not necessary under the statutory criteria provided in Section 333 of Public Law 112

- 95 [P.L. 112

- 95] in reference to 49 USC Section 44794 given the size, weight, speed, and limited operating area associated with the proposed UAS) Section 45.23(b) prescribing that when marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inc hes high, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable. (A erial Strategies believes relief from this section is not necessary as the proposed UAS is not certificated under Section 21.191 and this petitio n is submitted in connection with proposed operations as a Civil UAS) Section 61.31(a) prescribing that a person who acts as a pilot in command of any of the following aircraft must hold a ty pe rating for that aircraft for other aircraft specified b y the Administrator through aircraft ty pe certificate procedures: (1) Large airc raft (except lighter

- than

- air). (2) Turbojet

- powered airplanes. (3) Other aircraft specified by the Administrator through aircraft type certificate procedures.(A erial Strategies believes reli ef from this section is not necessary under the statutory

criteria provided in Section 333 of P.L. 112

- 95 in reference to 49 USC Section 44794 given the size, weight, speed, and limited operating area associated with the proposed UAS) Section 61.31(c) prescribing that unless a person holds a category , class, and ty pe rating (if a class and ty

pe rating is required) that applies to the aircraft, that person may not act as pilot in command of an aircraft that is carryinganother person, or is operated for compensation or hire. That person also may not act as pilot in command of that aircraft for compensation or hire. (A erial Strategies believes relief from this section is not necessary under the statutory criteria provided in Section 333 of P.L. 112

- 95 in reference to 49 USC Section 44794 given the size, weight, speed, and limited operating area associated with the proposed UAS) Section 61.31(d) prescribing that to serve as the pilot in command of an aircraft, a person must

- (1) Hold the appro priate category , class, and t ype rating (if a class or type rating is required) for the aircraft to be flown; or (2) Have received training required by this part that is appropriate to the pilot certification level, aircraft category , class, and t yp e rating ( if a class or type rating is required) for the aircraft to be flown, and have received an endorsement for solo flight in that aircraft from an authorized instructor. (A erial Strategies believes relief from this section is not necessary under the statutory criteria provided in Section 333 of P. L. 112

- 95 in reference to 49 USC Section 44794 given the size, weight, speed, and limited operating area associated with the proposed UAS or, alternatively, requests relief from this section by Pilot in Command (PlC) compliance with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition) Section 91.7(a) prescribing that no person may operate a civil aircraft unless it is in an airworth y condition. (Aerial Strategies requests relief from this section by Pilot in Command (PlC) compliance with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition) Section 91.7(b) prescribing that the pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight and th at the PI C shall discontinue the flight when not airworth y mechanical, electrical, or structural conditions occur. (A erial Strategies requests relief from this section by Pilot in Command (P1C) compliance with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition) Section 91.9(b)(2) prohibits operation of U.S.

- registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. (Aerial Strategies believes relief from this section is not necessary as the FAA has previously determined relief is not required provided the relevant materials publis hed by themanufacturer are kept in a location accessible to the PIC in compliance with the

regulations) Section 91.103(b) prescribing that a pilot shall for any flight, become familiar with runway lengths at airports of intended use, and takeoff and land ing distance information. (A erial Strategies believes relief from this section is not necessary provided the PIC complies with the Proposed Conditions and Limitations set forth in this petition) Section 91.109(a) prescribing, in pertinent part, that no p erson may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. (A erial Strategies believes relief from this section is not necessary provided the P1C com plies with the Proposed Conditions and Limitations set forth in this petition or utilizes the Dll Inspire 1 UAS dual control feature) Section 91.119 prescribing that, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:
1. Any where. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (A erial Strategies believes relief from this section is not necessary provided the Pilot in Co mmand (P IC) complies with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition) 2. Over congested areas. Over an y congested area of a city, town, or settlement, or over an y open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (A erial Strategies believes relief from this section is not necessary provided the Pilot in Command (P IC) complies with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition) 3. Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (A erial Strategies requests relief from this section by Pilot in Command (PIC) compliance with the applicable operational d ocuments published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition) Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set "...to the elevation of the departure airport or an appropriate altimeter setting available before departure." (Aerial Strategies believes relief from this section is not necessary provided the PIC complies with the Proposed Conditions and Limitatio ns set forth in this petition) Section 91.151(a) prescribing that no person may begin a flight in an airplane 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, (1)during the day , to fl y after that for at least 30 minutes [emphasis added]. (A erial

Strategies requests relief from this section by Pilot in Command (PIC) compliance with the applicable operational documents publis hed by the manufacturer a nd the Proposed Conditions and Limitations set forth in this petition) Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in § 47.31(c). (A erial Strategies believes relief from this section is not necessary as the FAA has previously determined relief is not required provid ed the relevant materials published by the manufacturer and the Proposed Conditions and Limitations are kept in a location accessible to the PIC in compliance with the regulations ) Section 91.203(b) prescribing, in pertinent part, that no person may oper ate a civil aircraft unless the airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. (A erial Strategies believes relief for this section is not necessary as the FAA has previously determined relief is not required provided the relevant materials published by the manufacturer and the Proposed Conditions and Limitations are kept in a location accessible to the PIC in compliance with the regu lations) Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of the chapter. (Aerial Strategies requests relief from this section by Pilot in Command (PIC) compliance with the applicable operational documents published by the manufacturer and the Pro posed Conditions and Limitations set forth in this petition)
Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been app roved for return to service by a person authorized under § 43.7 of the same chapter. (Aerial Strategies requests relief from this section by Pilot in Command (PIC) compliance with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition)
Section 91.409(a) prescribing that 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 b y a person authorized by §43.7 of this chapter; or (2) that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. (A erial Strategies requests relief from this section by Pilot in Command (PIC) compliance with the applicable operational documents published by the manufacturer and the ProposedConditions and Limitations set forth in this petition)

Section 91.417(a) and (b) pre scribing, in pertinent part, that

— (a) Each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
1. Records of the maintenance, preventive maintenance, and alteration and records of the 10 0

- 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 airc raft. The records must include

– a. A description (or reference to data acceptable to the Administrator) of the work performed; and b. T he date of completion of the work performed; and c. The signature, and certificate number of the person approving the aircraft for return to service. 2. Records contai ning the following informati on: a. The total time in service of the airframe, each engine, each propeller, and each rotor. b. The current status of life

- limited parts of each airframe, engine, p ropeller, rotor, and appliance. c. The time since last overhaul of all items installed on the aircr aft which are required to be overhaule d on a specified time basis. d. 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. e. Th e 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 dat e when the next action is required. f. Copies of the forms prescribed b y § 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 foll owing 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 b y other work or for 1 ye ar 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.(A erial Strategies requests relief from this section by Pilot in Command (PIC) compliance with the applicable operational documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition)
**Extent of and Reasons**  **for Relief Soug ht**  Aerial Strategies intends to operate two commercially available UAS t ypes (DJ I Phantom 3 and DJ I Inspire 1) for the purpose of providing flight demonstration and instruction and aerial work under the provisions of 14 CFR Section 119.1 ( e)(1) Student instruction, Section 119.1 (e)(4)(iii) Aerial photograph y or survey , and Section 119.1 (e)(4)(vi) Powerline or pipeline patrol. Aerial Strategies owner and pilot, David Preznuk , holds a current Private Pilot (Airplane Single Engine Land, Instrument) license.
**Public Interest and Benefit** The above "aerial work" services, normally provided in manned aircraft, may be provided with increased safety and at significantly lower cost in situations where the use of unmanned UAS aircraft would supplement or replace the use of manned aircraft as a result of safety or economic considerations in certain applications where extended operational range and limited time aloft are not a factor. The proposed UAS operations will pose no threat to the public given i ts small size and lack of combustible fuel when compared to larger manned aircraft, minimize potential ecological affects or damage, and promote economic growth by providing data information to individuals or companies requiring aerial survey

or imaging data. Additionally , the growth of the UAS industry has precipitated a large influx of "recreational" UAS pilots without formal knowledge or training regarding the effects or potential danger of UAS flight with the National Airspace S ys tem (NAS). While it is unclear what, if any, pilot certification requirements will ultimately

appl y to UAS pilots operating for commercial purposes under the final rulemaking process, there is a present need for training and dissemination of the applicable federal aviation regul ations and flight characteristics of UAS to the general public; specificall y current and potential UAS operators. UAS flight and ground demonstration and instruction for compensation utilizing the current s ys tem of certificated flight instructors provides economic incentive to accomplish the public goal of integration of both recreational and commercial UAS into the NAS while promoting safety and maintenance public awareness of current regulations affecting UAS operation. **Exemptions Provide a Level of Safe ty Equal to or Greater than the Existing Level**  **under Current Regulations** The use of UAS operated under the requested exemptions as set forth above have the capacity to operate with less risk of accident or injury and the associated loss of property or lif e while performing the same aerial work services offered in manned aircraft in certain situations where extended operational range and limited time aloft are not a factor. Likewise, UAS flight and ground demonstration and instruction for compensation promo te and encourage the existing sy stem of certificated flight instructors to participate in the public educational process utilizing UAS rather than manned aircraft.Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident.

The DJ I Phantom 3 and Inspire 1 carry no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated. This petition for exemption does not propose an electronic means to monitor and communicate with other aircraft, such as transponders or sense and avoid technology

. Rather the risk is mitigated by placing limits on altitude, requiring stand

- off distance from clouds, permitting day time operations onl y, and requiring that the UAS be operated within VL OS and yield right of way to all manned operations. Additionally , the Proposed Conditions and L imitations provide that the Aerial Strategies will request a notice to airmen (NOTAM) prior to operations to alert other users of the NAS. Aerial Strategies' UAS has th e capability to operate safel y after experiencing certain in

flight contingencies or failures and uses an auto

- pilot system to maintain UAS stability , augmentation and control. The UAS is also able to respond to a loss of GPS or a lost

- link event with pre

- coordinated automated flight maneuvers. These safety features provide an equivalent or higher level of safety compared to a manned aircraft holding an airworthiness certificate (restricted or otherwise) performing a similar operation. **Federal Register Su mmary**  Aerial Strategies Exploration Company , including its chief pilot Craig E Bryan, seeks exemption from the following regulations for the purpose of conducting flight instruction and commercial "aerial work" flight operations utilizing Unmanned Aerial Sy stems ("UAS") as set forth under the provisions of 14 CFR Section 119.1 (e)(1) Student instruction, Section 119.1 (e)(4)(iii) Aerial photograph y or survey , and Section 119.1 (e)(4)(vi) Powerline or pipeline patrol:
**Relief	C onsidered	(14	CFR)**  **FAA	Consideration or	Action	Requested**  Part 21 Relief not necessary pursuant to prior exemption 1 45.23(b) Relief not necessary pursuant to prior exemption 61.31(a) Relief not necessary (Section 333 of P.L. 112

- 95) 2 61.31(c) Relief not necessary (Section 333 of P.L. 112

- 95) 2 61.31(d) Relief not necessary (Section 333 of P.L. 112

- 95) 2 91.7(a) Relief granted in prior exemption with conditions and limitations 91.7(b) Relief not necessary pursuant to prior exemption 1 91.9(b)(2) Relief not necessary pursuant to prior exemption 1 91.103(b) Relief not necessary pursuant to prior exemption 1 91.109(a) Relief not necessary pursuant to prior exemption 1 91.119 Relief [paragraph (c)] granted in prior exemption with conditions and

1 In the matter of Douglas Trudeau, Realtor, Regulatory Docket No. FAA

- 2014

- 0481

2 Relief from this section is not necessary under the statutory criteria provided in Section 333 of P.L. 112

- 95 in reference to 49 USCSection 44794 given the size, weight, speed, and limited operating area associated with the proposed UASlimitations 1

91.121 Relief granted in prior exemption with conditions and limitations 91.151(a) Relief [paragraph 91.151(a)(1), day] granted in prior exemption with conditions and limitations 1 91.203(a) and (b) Relief not necessary pursuant to prior exemption 1 91.405(a) Relief granted in prior ex em ption with conditions and limitations 1 91.407(a)(1) Relief grant 1 ed in prior exemption with conditions and limitations 1 91.409(a)(1) and (2) Relief granted in prior exemption with conditions and limitations 1 91.417(a) and (b) Relief granted in prior e xemption with conditions and limitations 1
**Additional Information Offered in Support of this Petition for Exemption** Aerial Strategies , Owner & CEO, David Preznuk, holds a current Airplane Single

- Engine Land, Instrument airman’s certificate. Additionally , Mr. Preznuk has operated commerciall y available UAS vehicles for the past two in order gain flight experience and familiarity

with the operating characteristics and limitations of the UAS and its videograph y and photography s ys tems. As a res ult it is believed there are certain aerial work situations, where the range and time aloft limitations of UAS are not a factor, whereb y aerial work may be conducted with greater safety and less risk to persons or property on the ground while offering the same or improved level of aerial work product. Manned aircraft platforms such as airplanes and helicopters often subject the occupants as well as persons and property on the ground to higher levels of risk for accident or injury even while being operated p ursuant to all of the applicable federal aviation regulations. 1 In the matter of Douglas Trudeau, Realtor, Regulatory Docket No. FAA

- 2014

- 0481 2 Relief from this section is not necessary under the statutory

criteria provided in Section 333 of P.L. 112

- 95 in reference to 49 USCSection 44794 given the size, weight, speed, and limited operating area associated with the proposed UAS The DJ I Phantom 3 and the DJ I Inspire 1 UAS are both commerciall y produced and widely available aeria l videography and photography

platforms utilizing advanced GPS enabled stability

augmentation and control sy stems including "failsafe" features allowing the operator to manually

take control of the aircraft or initiate an automated "return to home" feature in the event of adverse inflight events. The UAS also incorporates automated "failsafe" features to initiate "return to home" or "autoland" commands in the event of loss of control signal link or diminished battery output or capacity. The manufacturer, D JI , provides comprehensive operational and safety manuals for both UAS and all flights will be conducted in accordance with the requirements and guidance issued in these manuals. Aerial Strategies states that § 91.7(a) prohibits the operation of an aircra ft without an airworthiness certificate. Aerial Strategies asserts that since there is currently no certificate applicable to his operation, this regulation is inapplicable. Aerial Strategies states that § 91.9(b)(2) requires an aircraft flight manual in the aircraft,however since there are no pilots or passengers on board his aircraft and given its size,

this regulation is inapplicable. Aerial Strategies further indicates an equivalent level of safety will be achieved by maintaining a safety/ flight manua l with the UAS ground station. **Proposed Conditions and Limitations** Aerial Strategies (also hereafter referred to as the operator) proposes the following Proposed Conditions and Citations in the form of a proposed Grant of Exemption: The following docume nts, including any updates or revision by

the manufacturer, provided b y the operator in its petition are incorporated b y reference, and are hereinafter referred to as operating documents:

. 1) DJ I Inspire 1 User Manual (EN) v1.0

. 2) DJ I Inspire 1 Safety Guidelines v1.0

. 3) DJ I Intelligent Flight Battery Safet y Guidelines v1.0

. 4) DJ I Phantom 3 User Manual (EN) v1.6

. 5) DJ I Phantom 3 Pilot Training Guide (EN) v1.1

. 6) DJ I Smart Flight Battery Safety Guidelines(EN, FR, DE and JP) Failure to compl y with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption. 1) Operations authorized b y this grant of exemption are limited to the following aircraft described in the op erating documents which are quad

- rotor aircraft weighing less than 55 pounds:
DJIPHANTOM 3 Unmanned Aircraft S ys tem (manufacturer published gross weight 2.74 pounds) ; and, DJIInspire 1 Unmanned Aircraft S ys tem (manufacturer published gross weight 6.47 pounds). Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

. 2) The UAS may

not be flown at an indicated airspee d exceeding 43 knots

.

. 3) The UAS must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents. AII altitudes reported to ATC must be in feet AGL.

. 4) The UAS mu st be operated within visual line of sight (VLOS) of the Pilot inCommand (PI C) at all times. This requires the PIC to be able to use human vision unaided b y an y device other than corrective lenses, as specified on the PIC's FAA

- issued airman medical certi ficate.

. 5) AII operations commercial "aerial work" flight operations [as defined by 14 CFR Section 119.1 (e)(1) Student instruction, Section 119.1 (e)(4)(iii) Aerial photograph y or survey, and Section 119.1 (e)(4)(vi) Powerline or pipeline patrol] must utilize a visual observer (VO). The UAS must be operated within the visual line of sight (VLOS) of the VO at all times. The VO may be used to satisfy

the VLOS requirement as long as the PIC alway s maintains VL OS capability . The VO and PI C must be able to c ommunicate verbally at all times. The PI C must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the VO can perform the functions prescribed in the operating documents.

. 6) AII flight instruction operations must be conducted such that the flight instructor has immediate access to the master ground control station (either through phy sical proximity or electronic access through a slave ground controller) for the purpose of ass uming positive control of the UAS in the event of loss of control by a trainee or person acting under the provisions of a student pilot certificate issued by the FAA.

. 7) The operating documents and this grant of exemption must be accessible during UAS o perations 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 operating documents, the conditions and limitations herein tal(e precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if he petitions for extension or amendment to this grant of exemption. I f the operator determines that an y update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for amendment to its grant of exemption. The FAA's UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

. 8) Prior to each flight, the PI C 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 UAS is prohibited from
3 Maximum published velocity [D JIPh antom 3 (29.16 knots), DJIInspire 1 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. AII maintenance and alterations must be properl y documented in the aircraft records.9) An y UAS 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. The PIC who c onducts the functional test flight must make an entry in the aircraft records. 10) The pre

- flight inspection section in the operating documents must account for all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 11) The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 12) The operator must carry out its maintenance, inspectio ns, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations must be noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service. 13) Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 14) The authorized person must make an entry in the aircraft record of the corrective action taken against discrepanc ies discovered between inspections. 15) UAS operations must be conducted b y a PI C possessing at least a private pilot certificate and at least a current third

- class medical certificate. The PIC must also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate. 16) Prior to operations conducted for the purpose of flight instruction or aerial work as defined b y 14 CFR Section 119.1 (e)(1) Student instruction, Section 119.1 (e)(4) (iii) Aerial photograph y or survey , and Section 119.1 (e)(4)(vi) Powerline or pipeline patrol, the PI C must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency , and experience

- building flights can also be co nducted under this grant of exemption to accomplish the required flight time. However, said training operations may

only be conducted during dedicated training sessions. During training, proficiency , and experience

- building flights the PI C is required to o perate the UAS with appropriate distances in accordance with 14 CFR 91.119. 17) Prior to operations conducted for the purpose of flight instruction or aerial work as defined b y 14 CFR Section 119.1 (e)(1) Student instruction, Section 119.1 (e)(4)(iii) Aerial photograph y or survey , and Section 119.1 (e)(4)(vi) Powerline or pipeline patrol, the PI C must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot operating the make and model of the UAS to be use d in operations under the exemption; 5 hours make and model time may beincluded in the 10 hours of multi

- rotor time prescribed above. The PIC must accomplish

3 take

- offs and landings in the preceding 90 day s (for currency purposes). Training, proficiency , experience

- building, and take

- off and landing currency flights can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency . However, said training operations may onl y be conducted during dedicated training ses sions. During training, proficiency , and experience

- building flights the PI C is required to operate the UAS with appropriate distances in accordance with 14 CFR 91.119. 18) The operator may

not permit the PI C to operate the UAS for the purpose of flight instruction or aerial work as defined b y 14 CFR Section 119.1 (e)(1) Student instruction, Section 119.1 (e)(4)(iii) Aerial photograph y or survey , and Section 119.1 (e)(4)( vi) Powerline or pipeline patrol, unless the PI C has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability 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. 19) UAS operations may

not be conducted during night, as defined in 14 CFR 1.1. AII operations must be conducted under visual meteorological conditions (VMC). 20) The UAS may

not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless, prior to such operation, the PI C coordinates and obtains authorization and airspace clearance from any National Airspace S ys tem (NAS) controlling authority having jurisdiction over the affected airspace and establishes and maintains continuous verbal communication or contact with said authority

(ATC) through radio or telephonic methods for the dur ation of flight. 21) The UAS 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 PI C. 22) If the UAS loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23) The PI C must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the op erating documents. 24) The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fl y atnormal cruising speed to the intended landing point and land the UAS with 30% battery power rema ining. 25) 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 a Notice to Airm an (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.26) AII aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identi fication (N

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 27) Before conducting operations, the radio frequency spectrum used for operation and control of the UAS must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28) The documents required under 14 CFR 91.9 and 91.203 must be available to the PI C at the Ground Control Station of the UAS an y time the UAS is operating. These d ocuments must be made available to the Administrator or any law enforcement official upon request. 29) The UAS must remain clear and yi eld the right of way to all manned aviation operations and activities at all times 30) The UAS may

not be operated b y the PIC from any moving device or vehicle. 31) The UAS may

not be operated over congested or densel y populated areas. 32) Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a
. Barriers or structures are present that sufficiently protect nonparticipating persons from the UAS and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UAS, flight operations must cease immediatel y and/or;
b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or s tructures has granted permission and the PI C has made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PI C, VO, operator trainees or essential pe rsons do not present an undue hazard to those persons per § 91.119(a). 33) AII 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 for each flight to be conducted. 34) An y incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA must b e reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the Nationa) Transportation Safety Board (NTSB) per instructions contained on theNTSB Web site: www.ntsb.gov.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. Respectfully

submitted, Aerial Strategies, LLC

__________________________ David Preznuk, CEO

Attachments: Note: A11 attachments provided by hyperlink to insure document revision currency and compliance with manufacture's copyright policy 1) DJ I Inspire 1 User Manual (EN) v1.0 http://download.dii

innovations.com/downloads/in spire 1/en/Inspire 1 User Manual v1.0 en.pdf 2) DJ I Inspire 1 Safety Guidelines v1.0 http://download.dii

innovations.com/downloads/inspire 1/en/Inspire 1 Safety Guidelines en.pdf 3) DJ I Intelligent Flight Battery Safet y Guidelines v1.0 http://downloa d.dii

innovations.com/downloads/inspire 1/en/Intelligent Flight Battery Safet y Guidelines en.pdf 4) DJ I Phantom 3 User Manual (EN) v1.6 http://download.dii

innovations.com/downloads/phantom 2 vision plus/en/Phantom 2 Vision Plus User Manual v1.6 en.pdf 5) DJ I Phantom 3 Pilot Training Guide (EN) v1.1 http://download.dii

innovations.com/downloads/phantom 2 vision plus/en/Phantom 2 Vision Plus Pilot Training Guide v1.1 en.pdf 6) DJ I Smart Flight Battery Safety Guidelines(EN, FR, DE and JP) http://down load.dii

innovations.com/downloads/phantom 2 vision plus/Smart Flight Battery Safety Guidelines.pdf