_=. 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 4 
Precision 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. 

9/30/2015 www.yourprecision.com Page 2 of 4 
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 4 
cracks, 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 

9/30/2015 www.yourprecision.com Page 4 of 4