# _=. PRECISION PRODUCTS

Lasers, Instruments, GPS, Software 1400 Hugh Avenue •Knoxville, TN Louisville, KY 40213 •Nashville, TN Ph: 502-459-1300 •Lexington, KY Fax: 502-473-1900

www.yourprecision.com

October 1, 2015
U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam, Pursuant to the Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Precision Products, LLC (Precision Products), a Kentucky based limited liability company operating and selling of Unmanned Aircraft Systems (UAS) equipped to conduct aerial photography, inspections, training, demonstrations, and surveys for various industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our UAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by the Section 333. The requested exemption would permit Precision Products to pursue its commercial interests in providing services to consumers interested in training, research, and aerial data capture using UAS technology in the following areas: • Aerial Photography and Videography for real estate, construction, utilities, and local/state government organizations • Inspecting/Surveying for real estate, construction, utilities, and local/state government organizations • UAS Operator Training for both external clients and internal employees • Product Demonstrations • Research and Development
Additionally, all Precision Products UAV pilots will hold an airline transport, commercial, private, recreational, or sport pilot certificate and also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. If an observer is not a qualified pilot, they will be trained by Precision Products pilots to understand the proper roles of an observer, communication procedures, proper visual scan techniques, operations at non-towered airports, and appropriate sections of the Aeronautical Information Manual



### The Petitioner Requests Relief From the following regulations: Regulations from which the exemption is requested: 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.109, 91.119(c), 91.121, 91.151(a)(1), 91.215, 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 Precision Products to operate a UAS to perform training, research, demonstration, inspection, survey, and aerial data collection.

9/30/2015 www.yourprecision.com Page 1 of 4Precision Products is petitioning for exemption using the following UAS platforms that have been previously

approved: • DJI Phantom 2- Exemption 11398 • DJI Phantom 2 Vision - Exemption 11310 • DJI Phantom 2 Vision+ - Exemption 11398 • Flamewhee1550 - Exemption 11397 • DJI Phantom 3 Professional - Similar to Exemption 11310 • DJI Phantom 3 Advanced - Similar to Exemption 11398 • DJI Inspire — Exemption 12418

These UAS weigh less than 55 pounds, have a built- in capability to limit the height flown above the ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. Each system also has the failsafe function of the autopilot system, which means when the communication between the Main Controller and the transmitter is lost, the system will automatically trigger Return to Home Procedure and will land safely. This submission does not include the operating manuals for each model requested above, as they have been reviewed by the Administrator in granting previous exemptions. Copies of all operating manuals for the individual models listed will be submitted on request. The above specifications meet standards listed below: • Precision Products will only operate its UAVs in line of sight of a pilot and/or observer and will operate at sites that are a'sufficient distance' from populated areas. Such operations will insure that the UAVs will not create a hazard to users of the national airspace system or the public. • Precision Products will not operate UAVs within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD), unless a letter of agreement with that airport's management is obtained or otherwise permitted by a COA issued to Precision Products. • Maximum flight time for each operational flight will be 60 minutes. • Flights will be terminated at 25% battery power reserve should that occur prior to the 60 minute limit. • Each UAV will be programmed so that it will not be operated at an altitude of no more than 400 feet AGL. • Minimum crew for each operation will consist of a UAV Pilot and a Visual Observer. • The UAV PIC's (Pilot In Command) will have an airline transport, commercial, private, recreational, or sport pilot certificate and also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. • Each UAV listed above operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). • Each UAV will operate at speeds of no more than 55 knots. • Given the small size of the UAV and the restricted environment within which they will operate, our UAS operations adhere to the Reform Act's safety requirements. Additionally, the fact that the Precision Products pilots hold FAA Pilot certificates demonstrates that they have a high regard to safe operations with an understanding of FARs, pre-flight inspections, maintenance and repair, operations within airspace, as well as being trained to high safety standards. Under the requested exemption, Precision Products will ensure that all operators have completed a small unmanned aircraft systems (UAS) education and training program including all applicable regulations and guidance documents; including aeronautical background information such as charts, NOTAMS and Aircraft Circulars; Radio Communications Procedures; Human Factors and Crew Resource Management; Basic Small UAS Aerodynamics; Weather factors; Airmanship and Decision-making and Safe Operating Procedures.

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### Exemption Requests and Equivalent Level of Safety:

Precision Products requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the UAV Systems:

14 CFR 61.23 Medical Certificates The regulation provides that a person requires a first or second class medical certificate to act as a Pilot In Command of an aircraft for compensation or hire. Our proposed operations require that the PIC must hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.23 even though the intent of this application is to conduct a business. 14 CFR 61.101, 14 CFR 61.113, and 14 CFR 61.315 Pilot privileges and Limitations The regulation provides that no person that holds a Recreational Pilot, Sport Pilot, or Private Pilot certificate may act as a Pilot In Command of an aircraft for compensation or hire. Our proposed operations require that the PIC must hold at least airline transport, commercial, private, recreational, or sport pilot certificate. 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 91.109 Flight Instruction; Simulated instrument flight and certain flight tests The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." We have the ability to provide dual controls utilizing Futaba T8J transmitters or transmitters similar and/or exceeding the specifications of the Futaba T8J with a wireless link between the transmitters. One transmitter is designated the master transmitter and the other transmitter is designated as a slave. The PIC instructor, utilizing the master transmitter, will be at all times able to assume control of the UAS during flight testing and training.
14 CFR 91.119 Minimum safe altitudes: General The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the UAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained and careful pre-planned has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the 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 of the aircraft. The UAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UAS on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout. 14 CFR 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 is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service."

The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition, conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small

9/30/2015 www.yourprecision.com Page 3 of 4cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board

computer. All other maintenance will be performed by the manufacturer or their designated repair facility. 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.



### Request for Blanket COA Approval: On March 24, 2015, the FAA announced that it has implemented a new policy of granting "blanket" COAs to applicants requesting exemptions from the Federal Aviation Regulations under Section 333 of the FAA Modernization and Reform Act of 2012. The Applicant hereby requests a"blanket" COA that conforms to the terms set forth in https://www.faa.gov/news/updates/?newsld=82245 upon approval of Precision Products' exemption request.

If you should have any further questions or concern, please contact me

Sincerely,

Todd Jones

President - Owner

Precision Products, LLC.

Phone: 502.459.1300
Email: todd@yourprecision.com

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