June 1, 2015

 Exemption No. 11729

 Regulatory Docket No. FAA–2015–0215

Mr. Jesse Smalley

Rose Paving Company

4698 South Old Peachtree Road

Norcross, GA 30071

Dear Mr. Smalley:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated January 24, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Rose Paving Company (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to support asphalt paving 

and ground utilization.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2 Vision+.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 
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consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21 and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Rose Paving Company is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

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

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

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

Conditions and Limitations

In this grant of exemption, Rose Paving Company is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.
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1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision+ when weighing less than 55 pounds including payload. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times;

electronic messaging or texting is not permitted during flight operations. The PIC must 

be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

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 take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

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

or amendment to this grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted this exemption, then the 
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operator must petition for an amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS−80) may be contacted if questions arise regarding updates or 

revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g. inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

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

under this exemption are permitted under the terms of this exemption. However, 
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training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

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

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 
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documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 
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notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
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Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") 

and 14 C.F.R. Part 11, Rose Paving Company ("RPC"), seeks an exemption from Federal 

Aviation Regulations ("F ARs") detailed below for the DJI Phantom 2 Vision+ Unmanned 

Aircraft System manufactured by DJI of Shenzhen, China. 

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the system to support asphalt paving and ground utilization. The DJI 

Phantom 2 Vision+ system consists of a lightweight (2. 73 pounds) battery operated aircraft, 

based on a small hand-held remote control operating on 5.8 GHz and is CE and FCC compliant. 

In addition to the remote control, the DJI Phantom 2 Vision + offers the pilot with First Person 

Viewing "FPV" via WiFi connection and ground control receiver independent of the main 

remote control device. The aircraft carries an onboard geo-referenced still camera that allows it 

to conduct precision photogrammetry and videography at the resolutions necessary for accurate 

isolation of necessary safety repair areas for private property only. This high-resolution data 

can provide owners of large parcels the ability to direct necessary funding to safety and nonsafety areas of concern on paved surfaces, thus eliminating wasteful spending and maintaining a 

proactive safe environment for the general public. 

The aircraft will be operated in the field with both a Pilot in Command (PIC) and a ground-based 

Visual Observer (VO) in accordance with FAA PolicyN 8900.227 Section 14 "Operational 

Requirements for UAS" with the following additional restrictions: 

-All operations will occur in Class G airspace at no more than 400' AGL 

-Operations will be operated over private property with the permission of the land owner or 

representative of land owner 

- All required permits will be obtained from state and local government prior to operation 

- The aircraft will not be operated over urban areas 

-When necessary, the aircraft will only be operated over populated business parcels before normal 

business operating hours to maintain safe and efficient flights at all times, noting the general 

public's safety is our main priority 

-The aircraft will not be operated at air shows or over an open-air assembly of people 

- The aircraft will not be operated over heavily trafficked roads 

- The aircraft will not be operated within 5 NM of an airport or heliport 

- Operations will be limited to day, visual meteorological conditions 

-Aircraft will remain within Visual Line of Sight at no greater than 1/2 NM of the PIC at all time 

- While the aircraft is airborne, the YO will be positioned within voice distance to the PIC 

-PIC will file a NOT AM providing radiai/DME, radius, and a date/time group for each operation 

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8900.227, the FAA can have confidence that the operation will have an equivalent or greater 

level of safety of manned aircraft performing the same mission. 

The name and contact information of the applicant are: 

Rose Paving Company 

4698 S. Old Peachtree Rd. 

Norcross, Georgia 30071 

Attn: Jesse Smalley 

Ph: 770-549-0095 

Fax: 678-303-2515 

Email: jsmalley@rosepaving.com 

The regulations from which the exemption is requested are as follows: 

- 14 CFR Part 21 

- 14 CFR 91.203 

- 14 CFR 45.23, 45.29 

- 14 CFR 91.9 

- 14 CFR 61.113,61.133 

- 14 CFR 91.11 9 

- 14 CFR 91.121,91.151 

- 14 CFR Subpart E (91.401- 91.417) 

-FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) 

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. We look forward to working with your office. Please contact us at any time if 

you require additional information or clarification. 

Sincerely, 

Jesse 

rk.-~ 

Smalley 

Director of Special Projects 

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D. Training Program 

E. Quick Start Guide and Description List 

F. Model Updates 

G. Manufacture Disclaimer 

H. Energy Management & Battery Guidelines 

I. Aviation Experience 

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This part establishes the procedures for the issuance of an airworthiness certificate. While the 

FAA continues to work to develop airworthiness standards for UAS, we request an experimental 

certificate be issued for the DJI Phantom 2 Vision+ under either or both of the 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 show compliance for issuance of type 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 used for 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 aircraft will not carry persons or property, will not carry fuel, and will only fly under strict 

operational requirements. Combined with the fact that the aircraft weighs only 2. 73 pounds and 

is constructed primarily out of injected plastic, we propose that the DJI Phantom 2 Vision+ will 

be at least as safe, if not safer, than a conventionally certificated aircraft performing the same 

miSSIOn. 

If an experimental airworthiness certificate is not appropriate for this application, then we 

request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness 

certificate in general, citing the equivalent level of safety outlined in the previous paragraph. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that 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 or cockpit entrance so 

that it is legible to passengers or crew." At 2. 73 pounds, the DJI Phantom 2 Vision+ is too small 

to carry documentation, does not have an entrance, and is not capable of carrying passengers or 

crew. 

To obtain an equivalent level of safety and meet the intent of91.203, we propose that documents 

deemed appropriate for this aircraft by the FAA will be co-located with the crew at the ground 

control station and available for inspection upon request. In order to identify the aircraft, we 

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PH645439463 

Registered 

to: 

Rose Paving Company 

7300 W. 1001h Place 

Bridgeview, IL 

60455 

If found please contact: (770) 549-0095 

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 display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The 2.73 pound DJI Phantom 2 Vision+ does not have an entrance in which the 

word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it 

by the FAA. 

We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" 

on the top of the aircraft, where the PIC, VO and others in the vicinity of the aircraft while it is 

preparing for launch will be able to see the designation. Additionally, we feel that the permanent 

placard discussed in the previous paragraph will provide the aircraft's registration information 

should it be found on the ground. Finally, we will display at the ground station a high contrast 

flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches 

high or greater. Since the aircraft will operate within 112 NM of the ground station, the banner 

should be visible to anyone that observes the aircraft and chooses to investigate it's point of 

ongm. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight 

manual information is available to the aircrew while operating the aircraft. We request an 

exemption to this requirement since the aircraft is not only too small to carry documentation, the 

documentation would not be available to the crew. 

To obtain an equivalent level of safety and meet the intent of91.9, we propose that a current, 

approved Airplane Flight Manual (appendix E) must be available to the crew at the ground 

station anytime the aircraft is in, or preparing for, flight. 

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Our proposed operations meet the requirements of8900.227 para 16(c)(2)(c) "Operations 

without a pilot certificate" in which the PIC is required to complete "FAA commercial pilot 

ground instruction" and pass "the FAA commercial pilot written examination." Since there are 

currently no means available for the pilot of a UAS to gain the experience in an equivalent 

category and class in order to apply for a commercial pilot's license, we propose to generate an 

equivalent level of safety by requiring our pilots to complete, at a minimum, FAA Private Pilot 

ground instruction and pass the FAA Private Pilot written examination in addition to completing 

the Private Pilot requirements. Since the aircraft cannot carry passengers or property, we feel we 

meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to 

conduct a business. 

14 CFR 91.119 Minimum safe altitudes: General. 

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a 

maximum of 400 feet AGL, we cannot comply with this requirement. 

To provide an equivalent level of safety we will only fly over private property with the 

permission of the land owner. The land owner will be briefed of the expected route of flight and 

the associated risks to persons and property on the ground. We maintain that due to the small 

size of the DJI Phantom 2 Vision+, the hazard to persons, vessels, vehicles, and structures is not 

comparable to manned aircraft and should be considered in granting the exemption. 

The aircraft will not be operated over congested areas nor over any open air assembly of persons. 

The aircraft will be operated at an altitude allowing, if a power unit fails, an emergency landing 

without undue hazard to persons or property on the surface. 

14 CFR 91.121 Altimeter settings. 

The regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 nautical miles of the aircraft. The aircraft will fly below 400 feet 

AGL and will not need to maintain hemispherical cruising altitudes in order to de-conflict with 

other aircraft. As such, an appropriate altimeter measurement presented to the pilot should be 

Above Ground Level and should be based on the barometric pressure at the point of launch. To 

provide an equivalent level of safety, the UAS's AGL altimeter will be set to zero on the ground 

prior to every flight. Since the aircraft will fly no more than 15 minutes per flight, even rapid 

changes in barometric pressure will have limited affect on the safety of the flight. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

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14 CFR Subpart E (91.401 - 91.417)- Maintenance, Preventive Maintenance, and 

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 is our intention that the PIC perform maintenance and 

inspection of the aircraft and "be authorized to approve the aircraft for return to service." 

As provided in the attached Maintenance Procedures (appendix D), the PIC will ensure that the 

aircraft is in an airworthy condition prior to flight and conduct detailed inspections after every 1 0 

hours. Maintenance performed by the PIC is limited to repairing small cracks, replacing a 

propeller, and updating software and firmware. All other maintenance will be performed by the 

manufacturer. The PIC will document work performed in accordance with 91.417. We feel that 

due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level 

of safety. 

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(l) Observer Medical. 

This policy provides that both the PIC and VO must have a valid FAA second-class medical 

certificate issued under part 67 in order to perform as a pilot or observer. The aircraft weighs 2.73 

pounds and is constructed out of injected plastic. Requiring the crew to meet the same medical 

requirements as a commercial pilot carrying passengers in a large aircraft is an unnecessary burden. 

We propose that the minimum medical requirements be the PIC must possess a current third-class 

medical certificate. Given the unlikely event that both the PIC and VO become medically 

incapacitated while the aircraft is in flight, the DJI Phantom 2 Vision+ will recover autonomously to 

the landing location designated prior to launch without crew intervention. 

Additional Information to Support Request. 

Per Regulatory Docket No. FAA-2014-0508 and Exemption Number 11136, we feel Rose Paving 

Company models the similar aforementioned request and that all information provided should meet 

the requirements for Section 333 Grant of Exemption. 

Parts of this letter for 333 Exemption Status has been copied with the expressed consent from 

Advanced Aviation Solutions President and CEO, Seven C. Edgar. 

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