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 Manual s 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 oramended 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 largermanned 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