### May 19, 2015

Exemption No. 11624

Regulatory Docket No. FAA

– 20 15

– 0544

Mr. Eric Andelin

Vertical Information Services, Inc.

1226 East Cumberland Avenue, Unit 315

Tampa, FL 33602

Dear Mr. Andelin :

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 s d ated October 14, 2014 and March 19, 2015 , you petitioned the Federal Aviation

Administration (FAA) on behalf of Vertical Information Services, Inc. ( hereinafter petitioner

or operator ) for an exemption

. The exemption would all ow the petitioner to operate an

unmanned ai rcraft system (UAS) to conduct aerial photography, photogrammetry, and

videography

.

See Appendix A for the petition submitted to the FAA des cribing 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 Vision 2.

### 2

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

and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria

provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in

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

, C ertification procedures for products and parts, Subpart H

— Airworthiness

Certificate s , 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 No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352),

11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , 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 peti tioner 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 i nterest.

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.

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

delegated to me by the Administrator, Vertical Information Services, Inc. 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 condition s and limitations listed

below.

### 3

Conditions and Limitations

In this grant of exemption, Vertical Information Services, Inc. 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.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom

Vision 2 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

t he 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 ;

e lectronic 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. Thi s 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,

### 4

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 revisio ns 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 ope rator determines that any update

or revision would affect the basis upon which the FAA granted this exemption, then

the operator must petition for an amendment to its grant of exemption. The FA A’s

UAS Integration Office (AFS− 80) may be contacted if questi ons 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 UA S, 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal

G overnment. The PIC must also meet the flight revi ew requirements specified in

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

### 5

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

ability to safely opera te 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 cu rrency 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

(traini ng, 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,

training operations may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- buildin g 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 symbo l as denoted on the current

FAA

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

man agement 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 l ess 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 sign al, the UA must return to a

pre

- determined location within the pr i vate 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 5 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 cond ucted in accordance with an ATO

- issued COA. The

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

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

.

### 6

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 a nd 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law enforcement

official upon request.

24. The UA must remain clear and giv e 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, vehicle s, 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, vehic les 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 control led

- 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 FA A'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

.

### 7

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 a rea of proposed filming. The 3

- day

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 th e 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 PI Cs 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 e xemption, 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.

### 8

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

Sincerely,

/s/

John S. Duncan

Director, Flight Standards ServiceVERTX

– EXEMPTION RULEMAKING Page 1 of 

### 3

October 14, 2014

U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room w12

- 140

1200 New Jersey Avenue, SE.,

Washington, DC 20590

Submitted Electronically via the Federal Docket Management System (FDMS)

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

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, Vertical Information Services, Inc., (VERTX) seeks an exemption from Federal Aviation

Regulations (“FARs”) detailed below for the following described Unmanned Aerial System called in this

application th e VERTX System, which includes an Unmanned Aircraft (UA) and ground station

- based

equipment and crew:

THE UNMANNED AIRCRAFT (UA):

 A DJI Phantom Vision 2 lightweight (under 3 lb. gross weight), battery operated 4

- motor quad

copter that takes off and lands vertically

 An on

- board flight computer with GPS navigation and location ability that receives signals for

flight controls from a g round

- based transmitter/controller;

 An on

- board camera capable of capturing imagery in the form of full color, high definition still

photos and video

 A Rotor Pixel 2 Axis Gimbal to for independent camera orientation and stabilization

 An on

- board telemetry system that delivers flight data from the on

- board flight computer to the

on

- board radio transmitter including altitude AGL, horizontal and vertical speed, compass

direction of flight and direction back to its launch site

 A 5.8GHz on

- board radio transmitt er that transmits live video from the on

- board camera plus all

the flight data from the telemetry system described above

 A Flytrex, flight data logging system which records; telemetry, speed and operating temperature

THE GROUND STATION

- BASED PART OF THE SYSTEM:

 A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and

who controls the UA while in the air

 A 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight

 Ground Station DJI Vi sion App (Android Based) which receives and displays video and system

telemetry real time from the UA

 A Visual Observer (VO) is a person who provides a second pair of eyes to visually track the UA

while in flight.

The requested exemption would support an a pplication for a commercial Certificate of Authorization to

use the above described VERTX System to support aerial photography for aerial mappingVERTX

– EXEMPTION RULEMAKING Page 2 of 

### 3

(photogrammetry) and video documentation for the public good. Typical applications would include:

new and exis ting construction, transportation and utilities, land development, environmental mitigation

projects and so forth.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on

combustible fuel; it oper ates at lo wer altitudes (under 4 00’) with no people on board thereby reducing

current risk levels and enhancing public safety. With a small payload a nd maximum flight time of only 22

minutes, this is offers little or no risk to national security. In addition the UA has its own built in flight

restrictions in special areas ie: airports, which limit flight in these areas. More information can b e found

on page 38 of the UA’s User’s M anual.

Low level oblique photos and video from several angles are far more effective t han ground

- based

imagery for displaying the characteristics of large, complex properties with several buildings and large

trees. The applicants in the past have chartered 2

- seat full

- sized helicopters for this purpose, which has

proven more costly than ma ny potential clients have been able to afford. The benefits of reduced cost

and improved quality of presentation from the UA will be valuable to and benefit many buyer s and

sellers of real property.

Additionally, we request that we be allowed to use our sy stem to benefit first responders nearby who

might require assistance, including fire fighters, the police, the sheriff, et al., while remaining subject to

all limitations cited i n this application as we do so

The VERTX System will be operated in the field with both a PIC and a VO in accordance with FAA Policy N

8900.227 Section 14 "Operational Requirements for UAS" and w ith the following Restrictions:

a) No flight will be made with a UA Gross weight exceeding 55 pounds;

b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed of

no more than 25 knots and no further 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

by voice at all times during a flight oper ation;

d) The PIC must have accumulated and logged, in a manner consistent with 14 CFR §

e) 61.51 (b), 10 hours of total time as a UA rotorcraft pilot and at least 5 hours logged as a UA pilot

with a similar UA type;

f) All required permits will be obtained from state and local government prior to operation;

g) The VERTX System will not be operated over densely populated areas;

h) The VERTX System will not be operated at air shows;

i) The VERTX System will not be operated over an y open

- air assembly of people;

j) The VERTX System will not be operated over heavily trafficked roads;

k) The VERTX System will not be operated within 5 NM of an airport or heliport;

l) The VERTX System will not be operated over properties smaller than two acres in size;

m) Operations will be restricted to day only and weather conditions equivalent to VFR; (m) The PIC

will brief the VO and property owner about the operation and risk before the first flight at each

new location;

n) No flight may be made without a Pre

- F light Inspection by the PIC before each operation to

ascertain that the UA is in a condition safe for flight (see Appendix A)

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel

Qualifications. Additionally, the PIC and VO will per form maintenance on the system and will complete a

course of maintenance instruction as part of their initial training.VERTX

– EXEMPTION RULEMAKING Page 3 of 

### 3

We submit that the combination of the UA's light weight, flight performance and ability, fully qualified

flight crew and strict operation under the 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 of safety than manned aircraft performing the same mission.

The name and contact information of the applicant is:

Vertical Information Services, Inc.

Attn: Eric Andelin

Ph: 813.992.6612

Email: info@vertisx.com

The regulations from which the ex emption 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 Part 21 Addendum Page 1

- 14 CFR 91.203 Addendum Page 1

- 14 C F R 45.23, 45.29 Addendum Page 2

- 14 CFR 91.9 Addendum Page 2

- 14 CFR 61.113, 61.133 Addendum Page 2

- 14 C F R 91.109, 91.119, 91.12 1 Addendum Page 3

- 14 CFR 91.151 Addendum Page 4

- 14 CFR Subpart E (91.401

- 91.417) Addendum Page 4

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

I am p r e p a r e d to m odi f y o r a mend a n y p a rt of t his r e qu e st t o satis f y t h e n ee d for a n e quival e nt lev e l

of s a f e t y

. P le a se c onta c t us a t a n y t i me if y ou r e quire a ddi t ional info r mation or c la r ifi c a t i on. I look

fo r w a rd to w o r ki n g with y o ur o f f ic e

.

S inc e r e l y

,

Eric Andelin, MBA, CP

Vertical Information Services, Inc.

Phone: 813.992.6612

Add e ndum cont a in i n g Ex e mp t ion R e qu e sts a nd Equiv a lent L e v e l of S a f e t y

App e ndix A

– F l i g ht M a nu a l

App e ndix B

– User ’ s Man ua l for UA (DJI Phantom 2 Vision)VERTX

- A DDENDUM

- EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Page 1 of 

### 4 A D DEN D UM

EXE M P TION RE Q UE S TS A N D EQUI V AL E NT L EVEL OF S A F ETY

Vertical Information Services, Inc., r e qu e sts a n e x e mp t ion f r om t he f ol l owing re g u l a t i ons a s w e ll a s

a n y a ddi t ional r e g ulations that m a y t e c hnic a l l y a pp l y t o the op e r a t i on of the VERTX S y ste m :

14 C F R P a r t 2 1, Subp a r t H: Ai r w o r thi n e ss C e r ti f ica te s

This pa r t est a bl i shes the p r o ce du r e s for the is s u a n c e of a n a irwo r th i n e ss c e rtifi ca te. W hi l e the

F AA c ont i nu e s to w o rk to d e v e lop ai r w o rthin e ss s t a nd a rds f or U nmann e d A e ri a l S y s t e m s , I r e qu e st an

e x p e rime n tal ce rtifi c a te be is s u e d f o r t he VERTX S y stem und e r e i ther or b o th of the following

pro v is i ons:

21.191 E x p e rime n tal ce r t ific a tes.

E x p e rime n tal ce rtifi ca tes a re is s u e d f o r the f ol l o w ing pur p oses:

(a) R e s e arch a n d d

e v e l o p m e n t. T e st i ng n e w a ir c r a ft d e s i g n c on c e pts, n e w a ir c r a ft e quip m e nt,

n e w a ir c r a ft ins t a l l a t i ons, n e w a ir c r a ft o p e r a t i n g t e c hniques, or n e w u s e s for a ir c r a ft.

(b) Sh ow in g c o m p l

ia n c e wi t h regul

a t i o n s. Cond u c t i ng f l i g ht t e sts a nd oth e r op e r a t i ons to show

c omp l ian c e with t he a i rw o r th i n e ss r e g ulations i n c lud i ng fl i g hts t o show c o mp l ian c e f or is s u a n c e

of t y pe a nd suppl e ment a l t y pe ce rtifi c a tes, f l i g hts t o subs t a nt i a te m a jor d e s i g n c h a n g e s, a nd

fli g hts t o show c omp l ia n c e with t he f un c t i on a nd r e l i a bi l i t y re q uir e ments o f the r e g ulations.

S ince the e x p e ri m e ntal c e rtifi ca te ca n be u s e d for c om m e r c ial pu r po s e s su c h a s ma r k e t sur v e y s, s a les

d e monstr a t i ons, a n d c usto m e r c r e w tr a in i n g

, we would e x p ec t t h a t an e x p e rime n tal ce rtifi c a te w ould

pe r m i t our c om m e r c i a l purpose a s w e l l

.

The a ir c r a ft will not c a r r y p e rsons or pro p e r t y , w i ll not c a r r y f u e l, a nd will on l y f l y und e r stri c t

op e r a t i on a l r e quir e ments. Co m bined w i t h the UA ’ s l i g ht w e i g h t , b e i n g c o n stru c ted p r i m a ri l y of ca rbon

fi b e r a nd plasti c

, I pro p ose th a t t he UA will be a t le a st as s a f e , if not s a f e r, th a n a c onv e nt i on a l l y

ce rtifi c a t e d a ir c r a ft p e r fo r m i n g the s a me mission.

I f a n e x p e rime n tal a i r wo r th i n e ss c e rtifi ca te is not a ppro p ri a te f o r this applic a t i on, then I r e qu e st an

e x e mp t ion of 14 C F R P a rt 21, Subp a rt H, a nd the r e q uir e ment f or a irworthiness ce rtifi c a te in g e n e r a l,

cit i ng the e quival e nt l e v e l of sa fe t y out l ined in the p r e vious p a ra g raph.

14 C F R 91.203 ( a) & (b) Civil air cr a f t: C e r ti f ica t io n s r e qu ir e d

. The r e g ulation provid e s t h a t an a irw o rthin e ss c e rt i fi ca te, with t he re g is t r a t i on number a ss i g n e d to the

a ir c r a ft a nd a r e g is t rat i on ce rtifi ca te must be a bo a rd the a i r c raft. A ddi t ional l y , subp a ra g r a ph (b)

pro v ides that the a ir w o r th i n e ss c e rtifi c a te be " d isp la y e d a t t he ca bin o r co c kpit e ntr a n c e so that it is

l e g i b le to p a sse n g e rs or c r e w

. "

At a ma x i m um g ross we i g ht of 3 lbs., the U A is t oo sm a ll to c a r r y d o c ument a t i on, do e s not h a ve a n

e ntr a n c e

, a nd is not c a p a ble of c a r r y i n g p a sse n g e rs o r c r e w. To o b tain a n e quival e nt

lev e l of s a f e t y a nd me e t t he in t e nt of 9 1 .203, I p ropose that do c uments d e e med a ppro p ri a te f o r th i s

ai rc r a ft b y the F AA will be c o

- loc a ted with t he c rew a t t he g round c on t rol station and a v a i l a ble f o r

insp ec t i on u p on r e qu e st. I n or d e r to i d e nt if y the a ir c r a ft, I p r opose that the info r mation found on

a i r wo r th i n e ss and r e g is tr a t i on ce rtifi c a tes be p e rm a n e nt l y a f f i x e d to t he a ir c r a ft via pla c a rd c on t a in i ng

the f ol l owi n g info r mation plus t he wo r d “ E XPE R I MEN T A L ” toVERTX

- A DDENDUM

- EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Page 2 of 

### 4

s a t i s f y the r e quir e m e nt of 14 C F R 45.2 3 , whi c h f ol l ows i m medi a te l y a ft e r the p r opos e d pla c a rd

d e s c ription b e low:

EXPE R I MEN T A L

Man u f a c tu r e r: D J I North America

94403, 2655 Campus Dr,

San Mateo, CA 94403

Model: Phantom 2 Vision

I f f ound ple a s e c ont a c t: 813.992.6612

14 C F R 45.23 D is p lay of m a r k s; g e ne r al a n d 45.29 S ize of m a r k s.

Th e se r e g u l a t i ons provide that e a c h a ir c r a ft must disp la y " N " a nd the a ir cr a ft ' s re g is t r a t i on

number in l e t t e rs a t l ea st 3 inch e s hi g h. Addit i on a l l y , the a i r c raft must disp la y the wo r d

" EXPE R I MEN T A L " i n l e t t e rs a t l ea st 2 i n c h e s h i g h n e a r the e ntr a n c e to t h e ca bin, c o c kpi t , or pi l ot

s t a t i on. The UA do e s not h a ve a n e ntr a n c e i n whi c h the w o r d " EXP E R I MEN T A L " ca n b e pla ce d, a nd

m a y not have a r e g is t r a t i on number a s si g n e d to i t b y t h e F A A

.

I pro p ose to ac hie v e a n e quival e nt l e v e l of s a fe t y b y includi n g the w o r d " EXPE R I MEN T A L " in the

pl aca rd on the top of the a ir c r a ft, a s shown a bov e , wh e re the P I C, V O a nd othe r s in t he vicini t y of the

a i r c r a ft w h i l e it is p re p a ring for lau n c h will be a ble to s e e t h e d e si g n a t i on. Addit i on a l l y , I f e el t h a t the

p e rm a n e nt pl a ca rd discuss e d in t he pr e vious p a ra g r a ph will pro v ide the a ir c r a f t ' s r e g is tr a t i on

info r mation a t the g rou n d statio n

. F inal l y

, I will disp la y a t t he g r ound station a hi g h c ont r a st fl a g or

b a nn e r t h a t cont a ins the w o r ds "Unm a nn e d A ir c raft G r ound S tation" in l e t t e rs 3 in c h e s hi g h or

g r ea t e r. Sin c e t he a ir c r a ft will op e r a te w i t hin 3/4 NM of the g round station, the b a nn e r should be

vis i ble to a n y one that obs e rv e s the a ir c r a ft a nd c hoos e s to investi g a te its point of o r i g in.

14 C F R 91.9 Civil air c r a f t f l ig h t m a nu al, m a r k i n g, a n d p laca r d re qu ir e m e n ts.

This r e g u l a t i on p r ovides that no p e rson m a y op e ra te a n a ir c r a ft unless a c u r r e nt, app r o v e d fli g ht

manu a l i s in t he a ir c r a ft. I a ssu m e that the intent of this r e quir e ment is to ensu r e that fl i g ht manu a l

i n f o r mation i s a v a i l a ble to the a ir c r e w while op e r a t i n g the a i r c r a ft. I re qu e st an e x e mp t ion t o th i s

r e quir e ment sin c e the a i r c r a ft is not on l y too small t o ca r r y do c u m e ntation; t he do c ument a t i on

would not be a v a i l a ble to the c rew during f l i g ht ope r a t i on s

.

To obtain a n e quival e nt l e v e l of s a f e t y a nd m e e t t he in t e nt of 91.9, I pr o pose that a c u r r e nt, a ppro ve d

U A F l i g ht Ma n u a l ( App e ndix A) must be a v a i l a ble to the c rew a t the g rou n d station a n y t i me the a ir c r a ft

is i n, or p re p a ring fo r

, f l i g ht.

14 C F R 61.113 P r iva t e p i l ot p r iv i leg e s a n d l i m ita t io n s: P i l ot in C o m m a n d a n d 61.133

C o m m e rc ial p i l ot p r iv i l e g e s a n d l i m ita t io n s.

The r e g ulation provid e s t h a t no pe r son th a t ho l ds a p riv a te pilot ce rtif i ca te m a y ac t as pilot i n

c om m a nd of a n a i r c r a ft f or c ompens a t i on or h i r e

. S ubp a ra g r a ph (b) a l l ows a priv a te pilot to a c t a s pilot

in command of a n a ir c r a ft in c onn e c t i on with a n y busin e ss or e m p l o y ment if: (1) T h e fli g ht i s on l y

inci d e ntal to t h a t bus i n e ss or e mp l o y ment; and ( 2) The a ir c r a f t does not c a r r y p a sse n g e rs o r p r op e r t y

f o r c ompens a t i on or hi r e

.VERTX

- A DDENDUM

- EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Page 3 of 

### 4

Our pro p osed o p e r a t i ons r e quire that the P I C must e i t h e r

1. Hold a Private P i l ot C e rtifi ca te is s u e d b y the F AA, a nd h a ve l o g g e d 10 hou r s of f l i g ht

e x p e ri e n c e in t his t y p e of U A

.

2. M ee t t he re qui r e ments of 8900.227 p a ra 16 ( c ) ( 2 ) ( c ) " Op e r a t i ons without a pi l ot c e rtifi ca t e "

in which the P I C is r e qu i r e d to complete " F AA p r ivate pi l ot g round ins t ruct i on" a nd p a ss " the

F AA P riv a te P i lot w ritten e x a m i n a t i on." S ince the r e a r e c u r r e nt l y no me a ns a va i l a ble for the

pilot of a U A S to g a in t he e x p e ri e n c e in a n e quival e nt c a t e g o r y a nd c lass in ord e r to a pp l y f o r

a c om m e r c ial p i l ot ' s l i ce nse, I pro p ose to g e n e r a te a n e quiva l e n t l e v e l of s a f e t y b y r e quiri n g

our p i l ots t o c omp l e te, a t a min i mu m

, F AA c om me r c ial pi l ot ground ins t ru c t i on a nd p a ss t he

F AA Com m e r c ial P i l ot w r i t ten e x a m i n a t i on in add i t i on to c omp l e t i ng the p r i v a te p i lot

re quir e ments. S ince t he a ir c r a ft c a nnot c a r r y p a sse n g e rs o r p r op e r t y , I f e e l that we me e t t he

in t e nt of 61.113 S ubp a ra g r a ph ( b ) e v e n tho u gh the intent of th i s ap p l i ca t i on is to c ondu c t a

business.

14 C F R 91.109 F l i g h t I n st r u c tion; S i m u lat e d i n st r u me n t f l i g h t and c e r tain f l i g h t te sts

The r e g ulation stat e s that " No p e rson m a y op e r a te a c iv i l air c r a ft th a t i s be i ng used for f l i g ht

instru c t i on unless that a ir c r a ft h a s ful l y fun c t i oning du a l c ontrols."

The VERTX S y stem g roun d

- b a s e d c ontrol station c o nsi s ts of a small h a nd

- h e l d r a dio t r a nsm i t t e r a nd

while it does not of

f e r a se c ond s e t of " c ontro l s " , both t he student a nd i nstru c tor ca n, a nd wil l , op e r a te

the si n g le s e t of c ontrols si m ul t a n e ous l y

. W i t h both student a nd instru c tor h a ving " h a nds

- o n " the

c ontrols d u r ing f l i g ht, I f e e l t h a t t his t ec hnique m ee ts t he i ntent 91.109 a nd p r ovides a n e quiva l e nt

le v e l of s a f e t y

.

14 C F R 91.119 M i n i m u m sa f e altitu d e s: G e ner al.

The re g ulation stat e s that ov e r sp a r s e l y popu l a ted a r e a s t h e a ir c r a ft ca nnot be op e r a t e d c loser

than 500 fee t t o a n y p e r s on, v e ssel, v e hicl e , or st r u c tur e

. S ince the a ir c r a ft will be op e r a t i n g a t a

ma x i m um of 400 fee t A G L

, I c a nnot comp l y w i t h th i s r e quir e m e nt.

I n o rd e r to pr o vi d e a n e q uival e nt l e v e l of s a f e t y The UA will not be op e r a ted ov e r c ong e sted a r e a s o r

ov e r a n y o p e n a ir a ssemb l y o f p e rsons. Any property owner affected w i l l be b r i e f e d on the e x p ec ted

r oute of flight a nd the a ssoci a ted risks to p e rsons a n d p r op e r t y on the g roun d

. The a ir c r a ft will be

o p e rated a t a low a l t i t ude a l l o win g , if a pow e r unit f a i l s, an e me r g e n c y land i ng without undue h a z a rd

to pe r sons or p r op e r t y on the su r f a c e . Th e r e f o re I maintain t h a t due to the sm a ll si z e of the UA, the

h a z a rd to p e rsons, v e hicl e s and stru c tur e s is m i ni m a l comp a r e d to mann e d a ir c ra ft, whi c h should be

c ons i d e r e d in g r a nt i ng the e x e mp t ion.

14 C F R 91.121 A lt i m e ter se t ting s

. The r e g ulation r e quir e s t h a t air c r a ft sh a ll mainta i n c ruising a l t i t ud e s b y r e f e r e n c e to an a l t i m e ter

s e t t ing a v a i l a b l e with i n 100 NM of the a i r c raft.

The UA will a lw a y s f l y b e low 400 fee t A G L a nd will n o t ne e d to m a in t a in c r uis i ng a l t i t ud e s in o r d e r to

p re v e nt c onfli c t with other a ir c r a ft. An A bove G r ound L e v e l a l t i m e ter me a s u r e ment a bove the t a k e o f f

point is t r a nsm i t t e d via ra dio f r o m t he UA on

- bo a rd c o m puter to t he disp la y s c r e e n h e ld b y the P I C,

p rovi d ing a c onst a n t l y up d a ted A G L r ea dout.VERTX

- A DDENDUM

- EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Page 4 of 

### 4

14 C F R 91.151 F u e l r e q u ir eme n ts f or f l i g h t in VFR c o nd itio n s.

The r e g ulation provid e s t h a t no pe r son m a y b e g in a f l i g ht i n a n a irpl a ne u n d e r d a y

- V F R c ondi t ions

unless the r e is enou g h fu e l t o f l y to t he fi r st po i nt of in t e nd e d la n ding a nd to f l y a ft e r that f or a t l ea st

30 m i nutes.

I fee l t he in t e nt i on of th i s pa r a g r a ph is to provi d e a n e n e r g y r e s e r v e a s a s a f e t y buf f e r f o r d e l a y s to

l a ndi n g . T h e U A is batt e r y op e r a ted a nd the m a x i m um dur a t i on o f f l i g ht f rom a sin g l e b a t t e r y c h ar g e is

18 m i nutes with a 20% re s e rv e

. S ince the a i r c raft will n e v e r f l y mo r e than 3/4NM f r om t he point of

intend e d landi n g , a f ull b a t t e r y c h ar g e a t l a un c h will e nsure that w e me e t the re s e r v e e n e r g y

r e qui r e ment of th i s pa r a g ra ph. W e re qu e st a n e x e mp t ion t o the w o r d "fu e l " a nd a sk for a n e quival e nt

in t e rp re tation wi t h the w o r d "en e r g y ".

14 C F R S ubp a r t E ( 9 1.401

- 91.417)

- M ai n t e n a n ce , P re v e n tive M ai nt e n a n ce , Alt e r a t io n s

The r e g ulation provid e s t h a t t he op e r a t o r is p r i m a r i l y re spons i ble f o r maintaining the a ir c r a ft in a n

a irwo r t h y c ondi t ion, i n c lud i ng c omp l ia n c e wi t h p a rt 39 a nd 43. P a ra g r a phs 91.407 a nd

91.409 re quire that the a i r c raft be " a ppro v e d for return to se r vice b y a p e rs o n a uthori z e d und e r

43.7" a ft e r m a in t e n a n c e a nd insp ec t i on.

I t i s my intention t h a t t he P I C p e r fo r m m a in t e n a n c e a nd inspe c t i on of the a i r c raft a nd " be a uthori z e d

to app r ove the a i r c r a ft f or r e turn to se r v ic e ." As p r ovided in the P r e

- F l i g ht C h ec kl i st in App e ndix A, the

P I C will e nsure that the a i r c raft is i n a n a irwo r t h y c on d i t ion prior to e v e r y fli g ht and in addit i on c o n du c t

det a i l e d insp ec t i ons a ft e r e v e r y two ho u rs of f l i g ht. Mainten a n c e p e r f o r med b y t h e P I C is l i m i t e d to

r e p a iring small c r a c ks, r e pl a c ing a p r o p e l l e r, c h ec ki n g e le c tri c a l conn e c t i ons a nd upd a t i ng soft w a re a nd

f irmw a re f o r the on

- b o a rd c ompu t e r. All o t h e r mainten a n c e will be p e r f o r med b y t h e m a nu f ac tu r e r or

their d e si g n a ted r e p a ir f a c i l i t y . The P I C will do c ument wo r k p e r f o r med in acc o rd a n c e wi t h 91.417. I

fee l t h a t d ue to t he si z e

, c onstru c t i on, a nd simp l ici t y of the a i r c r a ft, the P IC ca n e nsure a n e quiva l e nt

l e v e l of sa fe t y

.

8900.227 P a r ag r a p h 16( c ) ( 4) P I C Me d ical. a n d P a r a g r a p h 16( e ) ( 1 ) Ob s er v e r Me d ical.

This po l i c y pro v ides that both t he P I C a nd VO m u st have a v a l i d F AA s e c o n d

- c lass medi ca l ce rtifi c a te

issued und e r p a rt 67 in ord e r to pe r f o r m a s a pilot or o b s e rver.

The UA ma x i m um g ross w e i g ht i s 3 lbs., it is constru c ted of plastic a nd the P I C is not on boa r d. B oth t he

P I C a nd the V O a re r e quir e d to be in V LO S . Giv e n t h e unl i k e l y e v e nt t h a t bo t h the P I C a nd VO b ec ome

m e dic a l l y in c a p ac i t a ted while the a ir c r a ft is i n fli g ht, t he UA will re turn a utono m o us l y to t he si t e of

laun c h i ng a nd l a nd without c r e w in t e rv e nt i on. Th e r e f o r e

, r e quiri n g the P I C a nd VO to me e t t he s a me

m e d i ca l r e quir e m e nts a s commercial pilot carrying passengers in a l a r g e a i r c r a ft is a n u nn ece ss a r y

burd e n.

W e pro p ose th a t t he m i ni m um m e dic a l r e quir e m e nts for the P I C a nd VO b e vis i on c o r re c ted to

20/20 and a v a l i d, st a te i s sued d r ive r ' s l i ce n s e . The 20/20 v i sion r e quir e me n t wi l l ensu r e that the P I C

and VO n see and avoid air traffic; a licensed driver is medically qualified to operate a much larger

vehicle.VERTX

- APPENDIX A

- FLIGHT OPERATIONS/PROCEDURES Page 1 of 

### 2 AP P E N DIX A

– F LIG H T OPERATIONS/PROCEDURES

F L I G HT RE S TRI C T I ONS

(a) No f l i g ht wi l l be m a de w i t h a UA G r oss w e i g ht e x cee di n g 55 pounds;

(b) All ope ra t i ons must oc c u r in F AA Class G a i rsp a c e a t no m o r e than 40 0 ' AG L

, a t an a irsp ee d of n o

more than 25 knots a nd no f u r ther t h a n 3/4 NM f rom the P IC;

(c) All ope ra t i ons must u t i l i z e a visual obse r v e r ( V O ). The VO a nd P I C must be a ble to c om m unic a te

v e r b a l l y a t a ll t i mes du r ing a f l i g ht o p e r a t i on;

(d) In the event of op e r a t i ons ov e r p riv a te pro pe r t y, every effort will be made to notify and gain

p e rmi s sion of the p r op e r t y own e r;

(e) The P I C must h a ve a c c u mu l a ted a nd logged, in a mann e r c onsistent with 1 4 C F R § 61.51 (b ) , a

m i ni m um of 100 f l i g ht c y c l e s and 25 hou r s o f tot a l t i m e a s a U A r oto r c r a ft pilot and a t le a st t e n

hou r s logg e d a s a UA pi l ot wi t h a si m i l a r U A t y p e ;

(f) All r e quir e d p e rmits will be obtain e d f r om s t a te a n d loc a l g o v e rnm e nt prior to ope ra t i on; (g)

(g) The VERTX S y stem will n o t be op e r a ted o v e r d e nse l y populat e d a re a s;

(h) The VERTX S y stem will n o t be op e r a ted a t air sho w s ;

(i) The VERTX S y stem will n o t be op e r a ted o v e r a n y o p e n

- a ir a ssemb l y o f people

(j) The VERTX S y stem will n o t be op e r a ted o v e r h ea vi l y tr a f f ic k e d ro a ds;

(k) The VERTX S y stem will n o t be op e r a ted with i n 5 NM of a n a irpo r t o r h e l i port;

(l) The VERTX S y stem will be re str i c ted to d a y on l y operations a nd w e a ther c ondi t ions equiv a lent to

V F R; (n) The P I C will bri e f t h e V O a nd p r op e r t y o wn e r a b out t he op e r a t i on a nrisk b e fo r e t h e fi r st

fl i g ht at e ac h n e w l o ca t i on;

(m) No f l i g ht m a y be m a de w i t hout a su cce ssful P r e

- F l i g ht I nsp e c t ion b y the P IC b e fo r e e ac h op e r a t i on

to as c e rt a in t h a t t he UA is i n a c ondi t ion sa f e f o r f l i g ht.

P RE

- F L I G HT CHECKLI S T

1. Remote Controller, smart battery, Range Extender and smartphone are fully charged.

2. Propellers are mounted correctly.

3. Damping absorbers are in good condition, not broken or worn.

4. Camera lens cap has been removed.

5. Micro

- SD card has been inserted if necessary.

6. Gimbal is functioning as normal.

7. Motors can start and are functioning as normal.

8. DJI VISION App can connect to the camera.

TAKE OFF/LANDING PROCEDURES

Place the PHANTOM 2 VISION on ground with the battery level indicator facing you.

1. Power on the remote controller.

2. Power on the range extender.

3. Switch the camera to the “WIFI ON” position.

4. Power on the aircraft by turning on th e intelligent battery

5. Connect the mobile device to the PHANTOM 2 VISION, run the DJI VISION App to enter the

camera preview page.

6. Wait until the LED flight indicator starts to slowly blink green/yellow. This means the aircraft is

initializing and entering the “Ready to Fly”/“Ready to Fly (non

- GPS).” state. Then proceed toVERTX

- APPENDIX A

- FLIGHT OPERATIONS/PROCEDURES Page 2 of 

### 2 execute the CSC command to start motors.

7. Push the throttle stick up slowly to lift the aircraft off the ground.

8. When landing, be sure to be hovering over a level surface. Pull down on the throttle stick

gently to descend and land.

9. After landing the aircraft on the ground, keep the throttle stick at its lowest position for

about 3 to 5 seconds which will automatically stop the motors.

FAILSAFE FUNCTION

The aircraft will enter Failsafe mode when the connection from the remote controller is lost. The flight

control system will automatically control the aircraft to return to home and land to reduce injuries or

damage. The following situations would make the aircraft fail to receive a signa l from the remote

controller and enter Failsafe mode:

1. The remote controller is powered off.

2. The aircraft has flown out of the effective communication range of the remote controller.

3. There is an obstacle obstructing the signal between t he remote controlle r and the aircraft,

essentially reducing the distance the signal can travel.

4. There is interference causing a signal problem with the remote controller.

Failsafe works differently depending on the mode the aircraft is in when Failsafe mode is initiated

w hether it is in the Ready to Fly or Ready to Fly (non

- GPS) mode.

Ready to Fly (non

- GPS)

---- Automatic landing

The flight control system will try to keep the aircraft level during descent and landing. Note that the

aircraft may be drifting during descent and landing process.

Ready to Fly

---- Automatic go home and land

The flight control system will automatically control the aircraft to fly back to the home point and

land.