U.S. Department of Transportation July 14, 2015

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Vector UAS Services, LLC

Section 333 Petition to Operate

Small Unmanned Aircraft Systems

Prepared by:

Todd Janovsky - Owner

Vector UAS Services, LLC

5900 S 77th St.

Omaha, NE 68127

Cell: 605-201-7042

tj@vectoruasservices.com
Petition Summary

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95 

(2012), 126 Stat. 11 ("Section 333") and the Federal Aviation Administration's ("FAA") general 

exemption authority under 49 U.S.C. section 44701 (f), Vector UAS Services, LLC ("Petitioner") 

hereby petitions for exemptions from 14 C.F.R sections 61.113(a)-(b), 91.103(b)(1), 91.119(c), 

91.121, 91.151, 91.405(a), 91.407(a)(1), 91.409(a)(2}, and 91.417(a)-(b). 

The proposed exemption, if granted, would allow Petitioner to conduct commercial operations of 

small unmanned aircraft systems ("UAS") meeting or exceeding all of the operational and safety 

requirements Congress has set forth in Section 333. 

The models of UAS that may be used include the following:

-DJI Phantom 2 and 2 Vision+

-DJI Phantom 3

-DJI Spreading Wings S900

-DJI Inspire 1

-3DRobotics Solo

-SenseFly Exom

Petitioner is an aviation technology company that plans to exploit the capabilities of Unmanned 

Aerial Systems to offer a multitude of services, including: 

-Real Estate/Architecture

-Marketing

-Aerial Data Collection

-Surveying and Mapping

-Agriculture

-Aerial Filmmaking and Photography

- Energy systems inspections and asset management

-Construction site inspections and monitoring

-Industrial Surveying

Statutory Authority

Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a 

mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. 

Section 333(a) states that the FAA "shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the (comprehensive) plan and 

rule making required by section 332(b}(1) of this Act or the guidance required by section 334 of 

this Act." In Section 332(b}(1), Congress made it clear that Section 333 provides a mechanism 

for "expedited operation authorization" if several factors are met. Petitioner meets all 

requirements to permit FAA approval of commercial UAS operations. 
The Petitioner Requests Relief From the Following:

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).

The Petitioner has Supplied the Following Additional Information:

DJI Phantom 2, and 2 Vision+ User Manuals

DJI Phantom 3 User Manual 

DJI Spreading Wings S900 User Manual

DJI Inspire 1 User Manual

3DRobotics Solo User Manual

SenseFly Exom Technical Specifications

Unmanned Aircraft System

The petitioner states that all unmanned aircraft (UA) to be operated under this request are less 

than 55 lbs. fully loaded, fly at a speed of no more than 87 knots, carries neither a pilot nor 

passenger, and carries no explosive materials or flammable liquid fuels.

The petitioner describes that, in the event the UAS loses communications or its GPS signal, the 

UAS will have the capability to return to a pre-determined location within the private or 

controlled access property.

Petitioner's UAS will be identified by serial number, registered in accordance with 14 C.F.R. Part 

47, and have identification (N-Number) markings in accordance with 14 C.F.R. Part 45, Subpart 

C. Markings will be as large as practicable. 

Pre-Flight Inspection, Maintenance

Before each flight the PIC will perform a series of pre-flight and takeoff checks as defined by the 

manufacturer.

All UAS’s will be inspected and maintained per the manufacturer to ensure that they are in a 

condition safe for operation.

UAS Operating Parameters

The petitioner states that all flights will be operated within visual line of sight (VLOS) of pilot, in 

daytime VFR flight conditions and all operations will be conducted with the assistance of a 

second spotter/observer. The UAS flights will be limited to a maximum altitude of 400 feet AGL.

All operations shall be conducted in accordance with an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (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 

current COA.

Petitioner's UAS will remain clear and yield the right of way to all manned operations and 

activities at all times. Petitioner will not conduct UAS operations within 5 nautical miles of the 

geographic center of a non-towered airport unless a letter of agreement with that airport's 

management is obtained and the operation is conducted in accordance with a Notice to Airmen 

("NOTAM"). 

Pilot in Command (PIC)

The 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.

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, 

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.

Regarding Petitioner's requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will comply 

with the other applicable procedures and requirements stated in§ 91.103(a) and (b). Specifically, 

the PIC will take all actions including reviewing weather, flight battery requirements, aircraft 

performance data, and landing and takeoff distances before initiation of a flight. The PIC will 

also account for all relevant site-specific conditions in their preflight procedures.

Radio Frequencies

Radio frequencies used will be those allotted by the FCC for data transmission and vehicle 

control in unlicensed frequency bands. All devices used will comply with FCC usage and 

emissions regulations. 

Safety and Benefits of the UAS

The petitioner will be using the UAS in a variety of applications that generally require expensive 

full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer many benefits 

over the use of full-sized manned aircraft for electric power line inspection, oil/gas pipeline 

inspection, advanced agriculture, and film and still photography. Replacing significantly larger 
manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or 

crew creates a much greater margin of safety for the pilots and crew. 

By granting Petitioner's requested exemptions, the FAA will help drive development of safe and 

successful commercial UAS operations and will advance the public knowledge base for such 

operations. Petitioner is committed to promoting the UAS research efforts of policymakers 

including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS 

operations and serving as a resource for future UAS research operations. Thus, the FAA has good 

cause to grant this Petition. 

Conclusion

For the foregoing reasons, the exemptions requested herein should be granted and Petitioner 

should be permitted to conduct small UAS operations in accordance with its manuals and all 

other operating parameters deemed necessary and appropriate by the FAA. 

Sincerely,

Todd J. Janovsky

Owner

Vector UAS Services, LLC