June 15th, 2015

U.S. Dept. ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New JerseyAvenue, SE., Washington, DC 20590 NexusUAS LLC. 822 Law Lane Mount Pleasant, SC 29464

VIA EEDERAL DOCUMENT MANAGEMENT SYSTEM

Re: Exemption Request under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations
Dear Sir or Madam:
Pursuantto Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14C.F.R. Part 11, NexusUAS LLC., seeks an exemption from Federal Aviation Regulations ("FARs") detailed belowfor the following described UnmannedAerial System called in this application the ME System, which includes an UnmannedAircraft (UA) and ground stationbased equipment and crew:
THE UNMANNEDAIRCRAFT (UA): 

## 00 A lightweight (20 lb gross weightwith all on-board equipment), manufactured by DJI, Inspire 1- t-600, Phantom 3, Phantom 2 Vision Plus, Spreading Wings 81000+ and 3DR x8-M that includes the following equipment in flight; 

### li)An on-board flight computerwith GPS navigation and location abilitythat receives signals for flight controls from a ground-based transmitter/controller; 

### [!) An on-board camera capable of capturing imagery in the form of full color, high definition still photos and video; 

### {i) An on-boardtelemetry system thatdelivers flight datafrom the on-board flight computerto the on-board radio transmitter Including altitude AGL, horizontal and vertical speed, compass direction offlight and direction backto its launch site; 

## 00 A 2.4GHz on-board radio transmitterthat transmits live video from the on-board camera plus all the flight datafrom the telemetry system described above;
THE GROUD STATION -BASED PART OFTHE SYSTEM: 

## 00 A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who controls the UAwhile in the air; 

### [iJ A 2.4GHz radio transmitter/controller operated by the PIC to control the UAwhile in flight; 

## 00 A radio receiver receiving livevideo and flight data from the on-board camera and computer projects it all together onto a screen for the PIC to viewduring flight; 

### (!] A Visual Observer (VO) is a person who provides a second pair ofeyes to visually trackthe UAwhile in flight.The requested exemption would support an application for a commercial Certificate of Authorization to use the above described ME System to support Event marketing photo and video media,Television & Movie Film Production,Industrial & Agriculturallnspections,Mapping 

### & GIS (survey-grade construction mapping and monitoring),Cellular tower and compound surveys for wireless providers Residential & Commercial Real Estate,Event marketing photo and video media, Television & Movie Film Production,lndustrial & Agricultural Inspections, Mapping & GIS (survey-grade construction mapping and monitoring),Cellulartower and compound surveys for wireless providers operating over persons not directly involved with the ME system.
The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time of only 18 minutes, this is offers little or no risk to national security.
Low level oblique photos and video from several angles are far more effective than groundbased imageryfor displaying the characteristics of large, complex properties with several buildings and large trees. The alternative could be to charter a full-sized helicopterfor this purpose, which has proven more costly than many potential clients are able to afford. The benefits of reduced cost and improved quality of presentation from the UAwill be valuable to and benefit many buyers and sellers of real propertyand marine property

. Additionally, we request that we be allowed to use oursystem to benefitfirst responders nearby who might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to all limitations cited in this application as we do so.
The ME System will be operated in the field with both a PIC and a VO in accordancewith FAA Policy N 8900.227 Section 14 "Operational Requirementsfor UAS" and with the following Restrictions: a) No flight will be made with a UAGrossweight exceeding 55 pounds; b) All operations must occur in FAA Class G airspace at no more than 400ftAGL, at an airspeed of no morethan 50 knots and nofurther than 3/4 NM from the PIC; c)All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate byvoice at all times during a flight operation; d) Operations will be restricted to flights over property with the permission ofthe property owner; e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcran pilot and at least ten hours logged asa UA pilot with a similar UAtype; f) All required permits will be obtained from state and local government priorto operation; g) The ME System will not be operated over densely populated areas; 

### h) The ME System will not be operated at air shows; i) The ME System will not be operated over any open-airassembly of people; 

### j) The ME System will not be operated over heavily trafficked roads; k) The ME System will not be operated within 5 NM of an airport or heliport: I) Operations will be restricted to day only and weather conditions equivalentto VFR; m) The PIC will briefthe VO and property owneraboutthe operation and risk before the first flight ateach new location;

### n) Noflight may be made without a Pre-Flight Inspection by the PIC before each operation to ascertain thatthe UAis in a condition safe for flight (see AppendixA).
The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel Qualifications. Additionally, the PIC and VOwill perform maintenance on the system and will complete a course of maintenance instruction as part oftheir initial training.
We submit that the combination ofthe UA's light weight, flight performance and ability, fully qualified flight crew and strict operation underthe guidelines established in 8900.227, and under all of the Restrictions (a) through (n) listed above, the FAA can have full confidence that the operation will have an equivalent or greater level ofsafety than manned aircraft performing the same mission.
The name and contact information ofthe applicant are: dba NexusUAS LLC. : Jon Patterson Ph; 919-435-4450 Email:admin@nexusuas.com
The regulations from which the exemption is requested are listed below. Beside each regulation number is the page of the attached Addendum upon which each may be found together with our proposed equivalent level of safety for each regulation:

- 14 CFR Part21

................................. Addendum Page 1

- 14 CFR 91.203

............................. ....Addendum Page 1

- 14 CFR 45.23, 45.29

..........................Addendum Page 2

- 14CFR 91.9
....................................Addendum Page 2

- 14CFR 61.113, 61.133

.......................Addendum Page 2 -14 CFR 91.109, 91.119, 91.121..

............Addendum Page 3 -14 CFR 91.151

............................ .....Addendum Page 3

- 14 CFR Subpart E (91.401

- 91.417)

......Addendum Page 3 -FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

...Addendum 1
We are prepared to modify or amend any part ofthis request to satisfy the need for an equivalent level of safety. Please contact us at anytime if you require additional information or clarification. forw to w ing with your office.

atterson, NexusUAS LLC. endum containing Exemption Requests and Equivalent Level of SafetyAppendix A- Flight Manual's Appendix B- Owner's Manual for UAADDENDUM EXEMPTION REQUESTS AND EQUIVALENT LEVELOF SAFETY
NexusUAS LLC. requests an exemption from the following regulations as well as any additional regulations that maytechnically applyto the operation ofthe ME System:

14CFR Part 21 , Subpart H: Airworthiness Certificates This part establishes the proceduresforthe issuance ofan airworthiness certificate. While the FAAcontinues to workto develop airworthiness standards for UnmannedAerial Systems, we request an experimental certificate be issued for the ME System under either or both ofthe following provisions: 21.191 Experimental certificates

. Experimental certificates are issued for the following purposes: (a} Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. {b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to showcompliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be usedfor commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well.
The aircraftwill notcarry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA 's light weight, being constructed primarily of carbon fiber and plastic, we propose thatthe UAwill be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. Ifan experimental airworthiness certificate is not appropriatefor thisapplication, then we request an exemption of 14CFR Part 21 , Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level ofsafetyoutlined in the previous paragraph.

14CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation providesthat an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft.Additionally,subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin orcockpit entrance so that it is legible to passengers or crew."At a maximum gross weight of6.5 pounds, the UAis too small to carrydocumentation, does not have an entrance, and is not capable of carrying passengers orcrew. To obtain an equivalent level ofsafety and meetthe intent of 91

.203, we propose that documents deemed appropriate for this aircraft by the FAAwill beco-located with the crew atthe ground control station and available for inspection upon request. In orderto identifythe aircraft, we propose thatthe information found on airworthiness and registration certificates be permanently affixed to the aircraftvia placard containing the following information plus the word "EXPERIMENTAL" to satisfythe requirement of 14CFR 45.23, which follows immediately afterthe proposed placard description below:AppendixA EXPERIMENTAL Manufacturer: DJIInnovations, Inc. 950 E BaselineAve. Ste. 210Apache JunctionAZ 85119 Models: Inspire 

### 1- t-600, Phantom 

### 3, Phantom 

### 2 Vision Plus, Spreading Wings 

### 81000+ and 3DR x8

-M


### 14 CFR

### 45.23 Display of marks; general and

### 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 

### 3 inches high. Additionally, the aircraft must displaythe word "EXPERIMENTAL" in letters at least 2 Inches high nearthe entranceto the cabin, cockpit, or pilot station. The UAdoes not have

## an entrance in which theword "EXPERIMENTAL" 

## can be placed, and may not have a registration number assigned to it bythe FAA.
We propose to achieve an equivalent level ofsafety by including the word "EXPERIMENTAL" in the placard on thetop of the aircraft, as shown above, wherethe PIC, VO and others in the vicinity of the aircraftwhile it 

### is preparing for launch will be ableto see the designation. Additionally, we feel thatthe permanent placard discussed in the previous paragraph will providethe aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or bannerthat contains the words "UnmannedAircraft Ground Station" in letters 3 Inches high orgreater. Since the aircraft will operate within 3/4 NM ofthe ground station, the bannershould be visible to anyonethat observes the aircraft and chooses to investigate its point of origin.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. This regulation providesthat no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assumethatthe intentofthis requirement isto ensure that flight manual information is available

### to the aircrew while operating the aircraft. We request an exemption to this requirement sincethe aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of91.9, we propose that a current, approved UA Flight Manual (AppendixA) must be available to the crew atthe ground station anytime the aircraft is in, or preparing for, flight.


### 14 CFR 

### 61.113 Private pilot privileges and limitations: Pilot in Command and 

### 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraftfor compensation or hire. Subparagraph {b) allows a private pilot to act as pilot in command of an aircraft in connection with any business oremployment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry 

## passgngers or propertyfor compensation or hire. Our proposed operations require that the PIC must either

1. Hold a Commercial Pilot Certificate issued bythe FAA, and have logged 25 hours offlight experience in thistype of UA, or 2. Meetthe requirements of 8900.227 para 16(c)(2)(c) "Operations without a pilot certificate" In which the PIC is required to complete "FAA private pilot ground instruction" and pass "the FAAPrivate Pilot written examination." Since there are currently no means available for the pilot of a UAS to gain the experience in an equivalent categoryand class in orderto apply for a commercial pilot's license, we propose to generate an equivalent level ofsafety by requiring our pilots to complete, at a minimum, FAA commercial pilot ground instruction and passthe FAA Commercial Pilotwritten examination in addition to completing the private pilot requirements. Since the aircraft cannot carry passengers or property, we feel we meetthe intent of61.113 Subparagraph (b) even though the intent ofthis application isto conduct a business.

14CFR 91.109 Flight Instruction; Simulated instrumentflight and certain flight tests The regulation states that "No person mayoperate a civil aircraftthat is being used for flight instruction unless that aircraft has fully functioning dual controls."
The ME System ground-based control station consists of a small hand-held radio transmitter and while it does notoffer a second setof "controls", both the student and Instructor can, and will, operate the single setof controls simultaneously. With both student and instructor having "hands-on" the controls during flight, we feel thatthis technique meets the intent91.1 09 and provides an equivalent level ofsafety.
14 CFR 91.119 Minimum safe altitudes: General. The regulation statesthat oversparsely populated areas the aircraft cannot be operated closer than 500 feetto any person, vessel, vehicle, or structure. Sincethe aircraft will be operating at a maximum of400 feet AGL, we cannot comply with this requirement.

In orderto provide an equivalent level ofsafety we will onlyfly over private propertywith a size of at leasttwo acres with the permission ofthe ownerofthe propertyflown over. The aircraftwill not be operated over congested areasor over any open air assembly of persons. The property ownerwill be briefed on the expected route offlight and the associated risks to persons and property on the ground. The aircraftwill be operated ata low altitude allowing, ifa power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain thatdue tothe small size ofthe UA, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in grantingthe exemption.
14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM ofthe aircraft.
The UAwill alwaysfly below 400feet AGLand will not need to maintain cruising altitudes in orderto prevent conflict with other aircraft. An Above Ground Level altimeter measurement above thetakeoff point is transmitted via radio from the UAon-board computerto the display
screen held bythe PIC, providing a constantly updated AGL readout.

14CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane underday-VFR conditions unless there isenough fuel to fly to the first pointof intended landing and to fly after that for at least 30 minutes. We feel the Intention of this paragraph isto provide an energy reserve as a safety bufferfor delays to landing. The UA is battery operated and the maximum duration offlight from a single battery charge is 18 minutes with a 20% reserve

. Since the aircraft will neverfly morethan 314 NM from the point of intended landing, a full battery charge at

### launch will ensure thatwe meet the reserve energy requirement ofthis paragraph. We request
an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".

14CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in
an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection.
It isour intention that the PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraftfor return to service." As provided in the Pre-Flight Checklist in AppendixA, the PIC will ensurethatthe aircraft is in an airworthy condition priorto everyflight and in addition conduct detailed inspections aftereverytwo hours offlight. Maintenance performed bythe PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware forthe on-board computer. All other maintenance will be performed bythe manufacturer ortheir designated repair facility. The PIC will documentwork performed in accordance with 91.417. Wefeel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level of safety.
8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(1) Observer MedicaL This policy providesthat both the PIC and 

### VO must have a valid FAAsecond-class medical certificate issued under part 67 in orderto perform as a pilot or observer. The UAmaximum gross weight is 6.5 pounds, it is constructed ofcarbon fiber and plastic and the PIC is noton board. Both the PIC and the 

### VO are required to be In VLOS. Given the unlikely eventthat both the PIC and 

### VO become medically incapacitated while the aircraft is in flight, the UAwill return autonomouslyto the site of launching and land without crew intervention. Therefore, requiring the PIC and 

### VO to meetthe same medical requirements as a commercial pilot carrying passengers in a large aircraft isan unnecessary burden.
We propose that the minimum medical requirements for the PIC and 

### VO be vision corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure thatthe PIC and 

### VO can see and avoid airtraffic; a licensed driver is medically qualified to operate a much largervehicle. AppendixA APPENDIX A- FLIGHT MANUAL
FLIGHT RESTRICTIONS a) No flight will be made with a UA Gross weight exceeding 55 pounds; b) All operations must occur in FAAClass G airspace at no more than 400'AGL, at an airspeed of no more than 

### 50 knots and 

## no further than 3/4 NM from the 

### PIC; c) All operations must utilize a visual observer (VO). The YO and 

### PIC must be able to communicate verbally at all times during a flight operation; d) Operations will be restricted to flights over property with the permission of the property owner; e) The PIC must have accumulated and logged, in a mannerconsistent with 14CFR 

### § 61.51 (b), a minimum of 100flight cycles and 25 hours oftotal time as a UA rotorcraft pilot and at least ten hours logged as a UApilot with a similar UA type;

### f) All required permitswill be obtained from state and local government priorto operation; g) The ME System will not be operated overdensely populated areas; h) The ME System will not be operated at air shows; i) The ME System will not be operated over any open-airassembly of people; 

### j)The ME System will not be operated over heavilytrafficked roads; k) The ME System will not be operated within 5 NM of an airport or heliport; I) Operations will be restricted to day only and weather conditions equivalentto VFR; m) The PIC will briefthe VO and property owner aboutthe operation and risk before the first flight at each new location; n) No flight may be made without a successful Pre-Flight Inspection bythe PIC before each operation to ascertain that the UA is in a condition safeforflight.
PREFLIGHT CHECKLIST 1. Remote controller, aircraft battery, and mobile device are fully charged. 2. Propellers are mounted correctly and firmly. 3. Micro-SO card has been inserted 

### if necessary. 4. Gimbal isfunctioning as normal. 5. Motors can start and arefunctioning as normal. 6. DJI Pilot app connected to the aircraft.
TO REGAIN CONTROLAFTER LOST RADIO CONTACT If radio contact is lostand not restored within 3 seconds, an automatic Return to Home feature is activated and will bring the UAV backto the PIC.