The	extent	of	relief	you	seek,	and	the	reason	you	seek	

relief;

14	C.F.R.	§	61.113:	Private	Pilot	Privileges	and	Limitations

Verascan	Inc.	seeks	exemption	from	14	CFR	§	61.113,	which	restricts	private	pilots	

from	flying	aircraft	for	compensation	or	hire	and	would	also	require	a	second	class	

medical	certificate.	The	purpose	of	Part	61	is	to	ensure	that	the	skill	and	competency	

of	any	PIC	matches	the	airspace	in	which	the	PIC	will	be	operating,	as	well	as	

requiring	certifications	if	the	pilot	is

carrying	passengers	or	cargo	for	hire.	While	the	UAS	will	be	operated	as	part	of	a	

commercial	operation,	they	carry	neither

passengers	nor	cargo.	In	the	Grant	of	Exemption	in	FAA	Docket	No.	FAA-2015-0986,	

the	FAA	determined	that	the	unique	characteristics	of	UAS	operation	outside	of	

controlled	airspace	did	not	warrant	the	additional	cost	and	restrictions	attendant	

with	requiring	the	PIC	to	have	a	commercial	pilot	certificate	and	a	class	II	medical	

certificate.	The	FAA	has	also	determined	that	the	required	knowledge	for	a	

commercial	pilot	covers	the	same	fundamental	principles	as	a	private	pilot.	The	FAA	

has	also	granted	exemptions	allowing	operations	by	people	who	hold	an	airline	

transport,	commercial,	private,	recreational,	or	sport	pilot	certificate	with	a	current	

FAA	airman	medical	certificate	or	a	valid	U.S.	driver's	license	issued	by	a	state	or	the	

Federal

Government.	The	PIC	must	also	meet	the	flight	review	requirements	specified	in	14	

CFR	§	61.56.	See	FAA	Exemption	No.	11374.	Verascan	will	ensure	the	PIC	will	meet	

the	requirements	listed	in	the	above	paragraph.	Verascan	will	also	ensure	the	PIC	

will	have	completed	the	manufacturers'	training	guidelines	outlined	in	the	Manuals.	

The	FAA	stated	in	its	grant	of	an	exception	to	Astraeus	Aerial	the	"the	FAA	considers	

the	overriding	safety	factor	for	the	limited	operations	proposed	by	the	petitioner	to	

be	the	airmanship	skills	acquired	through	VAS-specific	flight	cycles,	flight	time,	and	

specific	make

and	model	experience,	culminating	in	verification	through	testing."	The	restrictions	

Verascan	has	placed	on	its	UAS	operations	meet	or	exceed	the	restrictions	similarly	

imposed	on	Astraeus	Aerial	in	FAA	Docket	No.	F	AA-20	14-0352	and	those	listed

in	the	FAA's	"summary	grant"	process.	

14	C.F.R.	§	91.7(a):	Civil	Aircraft	Airworthiness

Verascan	seeks	an	exemption	from	14	C.P.R.§	91.7(a),	which	requires	that	a	civil	

aircraft	be	in	airworthy	condition	to	be	operated.	The	FAA	has	stated	that	no	
exemption	is	required	to	the	extent	that	the	requirements	of	Part	21	are	waived	or	

found	inapplicable.	Accordingly,	Verascan	requests	that	the	requirements	for	

Section	91.7	be	treated	in	accordance	with	FAR

Part	21	Subpart	H.	See	Grant	of	Exemption	No.	11062

14	C.F.R.	§	91.121:	Altimeter	Settings

This	petition	seeks	an	exemption	from	14	C.F.R.	§	91.121,	which	requires	a	person	

operating	an	aircraft	to	maintain	cruising	altitude	or	flight	level	by	reference	to	an	

altimeter	that	is	set	to	the	elevation	of	the	departure	airport.	The	UASs	proposed	

here	use	both	barometricpressure	sensors	and	GPS	to	determine	altitude	but	do	not	

have	the	ability	to	set	in	a	current	altimeter	setting.	An	exemption	is	required	to	the	

extent	that	the	UAS	does	not	have	a	barometric	altimeter	setting.	The	altitude	of	the	

UAS	is	monitored	by	the	PIC	on	the	ground	control	station	and	by	the	visual	

observer.

Extent	and	Reason	for	Which	Relief	is	Sought:	The	FAA	has	stated	that	an	equivalent	

level	of	safety	can	be	achieved	if	the	aircraft	will	be	operated	at	or	below	400	feet	

AGL	and	within	visual	line-of	sight	in	addition	to	GPS	based	altitude	information	

relayed	in	real	time	to	the	operator.	See	Grant	of	Exemption	No.	11062,	p.	20-21.	As	

the	attached	Manuals	indicate,	the	UAS	will	be	operated	at	or	below	400	feet	AGL	

and	otherwise	comply	with	the	limitations	in	the	Grant	of	Exemption	No.	11062.	

14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions

Verascan	requests	an	exemption	from	14	C.F.R.	§	91.15l(a)'s	fuel	requirements	for	

flight	in	VFR	conditions.	Section	91.151	states:

(a)	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	fly	after	that	for	at	least	30	minutes;	or	(2)	At	night,	to	fly	after	that	for	at	

least	45	minutes.	Here,	the	technological	limitations	on	the	UAS	battery	power	

means	that	no	meaningful	flight	operations	can	be	conducted	while	maintaining	a	

30	minute	reserve.	The	aircraft	are	battery	powered	with	a	maximum	flight	time	of	

approximately	24	minutes	for	the	Phantom	2.	The	PIC	will	ensure	that	before	each	

flight,	there	is	enough	available	power	for	the	UAS	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.

Extent	and	Reason	for	Which	Relief	is	Sought:	The	FAA	has	stated	that	an	equivalent	

level	of	safety	is	provided	if	the	UAS	flight	is	conducted	under	daytime	VFR	flight	

conditions	using	VLOS,	and	terminated	with	at	least	25%	reserve	battery	power	still	

available.	See	Grant	of	Exemption	No.	11062.	The	FAA's	"summary	grant"	process	

provides	that	the	PIC	is	prohibited	from	beginning	a	flight	unless	there	is	enough	

available	power	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.	See	FAA	Exemption	No.	11374	(FAA	Docket	No.	2015-0091	at	p.	5).	The	

Manuals	here	provide	that	the	PIC	will	ensure	that	before	each	flight,	there	is	

enough	available	power	for	the	UAS	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.	

14	C.F.R.	§§	91.405(a),	91.407(a)(l),	91.409(a)(1)(a)(2);	91.417(a)	and	(b):	

Maintenance	Inspections

Verascan	seeks	an	exemption	from	the	maintenance	inspection	requirements	

contained	in	14	C.P.R.§	91.405(a),	91.407(a)(l),	91.409(a)(2);	91.417(a)	and	(b).	

These	regulations	specify	maintenance	and	inspection	standards	in	reference	to	14	

C.P.R.	Part	43.	See,	e.g.,	14	C.P.R.§	91.405(a)	(stating	that	each	owner	or	operator	of	

an	aircraft	"[s]hall	have	the	aircraft	inspected	as	prescribed	in	subpart	E	of	this	part	

and	shall	between	required	inspections	...	have	discrepancies	repaired	as	prescribed	

in	part	43	of	this	chapter").	An	exemption	from	these	regulations	is	needed	because	

Part	43	and	these	sections	only	apply	to	aircraft	with	an	airworthiness	certificate,	

which	the	UAS	proposed	here	will	not	have.

Extent	and	Reason	for	Which	Relief	is	Sought:	An	equivalent	level	of	safety	will	be	

achieved	because	maintenance	and	inspections	will	be	performed	in	accordance	

with	the	Manuals.	This	includes	maintenance,	overhaul,	replacement,	and	preflight	

inspection	requirements.	See	Exemption	No.	11062	(FAA	Docket	No.	2014-0352,	

atp.	14-15)	and	Exemption	No.	11374	(FAA	Docket	No.	2015-0091,	at	p.	4).		

Verascan	will	follow	the	UAS	manufacturer's	maintenance	requirements.	As	

provided	in the	attached	Operations	Manual,	flights	will	not	be	conducted	unless	a	

flight	operations	checklist	is	performed that	includes	all	of	the	aircraft's	

components.