April 20, 2015

Exemption No. 11395 Regulatory Docket No. FAA–2015–0162

Mr. Anthony M. Straw Managing Partner Straw Investment Group, LLC 19526 Clay Oak San Antonio, TX 78258

Dear Mr. Straw:

This letter is to inform you that we have gran ted your request for exemption. It transmits our decision, explains its basis, and gives you th e conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated January 22, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of Straw Investment Group, LLC (h ereinafter petitioner or operator) for an exemption. The exemption would allow the petiti oner to operate an unmanned aircraft system (UAS) to conduct aerial videogra phy and to augment real estate listing videos in various metropolitan areas.

See Appendix A for the petition submitted to the FAA describing 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.2

Airworthiness Certification

The UAS proposed by the petiti oner is a DJI Phantom 2.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, a nd limited operating area associated with the aircraft and its operation, the S ecretary of Transportation has de termined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates , 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 materi al respects to those pres ented 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

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA

− 2014

− 0382), and 11213 to Aeryon Labs, Inc. ( see Docket No.

FAA

− 2014

− 0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifica tions described by the petition er and carrying no passengers or crew, rather than a manned aircraft of signi ficantly greater proporti ons, carrying crew in addition to flammable fuel, gi ves the FAA good cause to find th at the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for re questing an exemption, I find that—

 They are similar in all material respects to relief previously re quested 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 situ ation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a gr ant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S. C. 106(f), 40113, and 44701, delegated to me by the Administrator, Straw Investment Group, LLC 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)3

and (b), to the extent necessary to allow the pe titioner to operate a UAS to perform aerial data collection. This exemption is subject to th e conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Straw Investme nt Group, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions an d 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 2when 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 restricti on. 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 th e 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 the visual line of sight (VLOS) of the PI C 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; electronic messaging or texting is not pe rmitted during flight operations. The PIC must be designated before the flight and ca nnot transfer his or her designation for the duration of the flight. The PIC must en sure that the VO can perform the duties required of the VO.

7. This 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 operating4

documents must be accessible during UAS operations and made available to the Administrator upon request. If a discre pancy exists between the conditions and limitations in this exemption and the pro cedures outlined in the operating documents,

the conditions and limitations herein ta ke precedence and must be followed. Otherwise, the operator must follow the pr ocedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and pr esent updated and revised documents to the Administrator or any la w enforcement official upon request. The operator must also present updated and revise d documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon wh ich the FAA granted this exemption, then the operator must petition for an amendmen t to its grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or flight characteristics, e .g., replacement of a flight cr itical component, must undergo a functional test flight prio r to conducting further opera tions 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 functi onal 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. Th e 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 UAS, 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 manu facturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exempti on must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pi lot 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 Federal5

government. The PIC must also meet the f light review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.

14. The operator may not permit any PIC to ope rate unless the PIC demonstrates the ability to safely operate the UAS in a ma nner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehi cles 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 e xperience-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 dur ing dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants 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 me teorological conditions (VMC). Flights under special visual flight rule s (SVFR) are not authorized.

16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facil ity Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the ai rport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less 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 signal, the UA must return to a pre-determined location within the pr ivate or controlled-access property.

19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a f light 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 fo r at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Author ization (COA). All operations shall be conducted in accorda nce with an ATO-issued COA. The6

exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted unde r the terms of the attached COA.

22. All aircraft operated in accord ance 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 th e safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 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 give wa y 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, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently pr otect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under su ch 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, vehicles or struct ures 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 es sential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/contro ller 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 FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be7

reported to the National Transportation Sa fety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for th e 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 ove r the area of proposed filming. The 3-day notification may be waived w ith 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 the person res ponsible for the on-s cene 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 obtain ed permission from property owners

and/or local officials to conduct the filming production event; the list of those who gave permission must be made av ailable to the inspector upon request;

g. Signature of exemption holde r or representative; and

h. A description of the flight activity, includi ng maps or diagrams of any area, city, town, county, and/or state over which film ing will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer th an 500 feet from pa rticipating 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 exemption, the UAS, the UAS PIC, and the UAS operations must comply with al l applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on April 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight St andards Service

## J anuary 22 , 2015

Federal Aviation Administration:

On behalf of Straw Investment Group, LLC (DBA “Randolph Housing Solutions”) I would like to formally submit for an exemption from part 21, subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.40 7(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). This proposed exemption would allow our operation of unmanned aircraft systems (UAS) for the purpose of aerial videography and to augment real estate listing vi deos in various metropolitan areas.

As found in Exemption No. 11138 (Trudeau), the FAA recently approved similar use of a PHANTOM 2 UAS.

We will operate a UAS, the DJI PHANTOM 2, which is comprised of an unmanned aircraft (UA or PHANTOM), an
attached GoP ro Hero 3+ camera and a transportable ground

station.

The PHANTOM 2 is a quad

- copter with a maximum gross weight of about 3 pounds. It is equipped with four rotors that are driven by electric motors powered by batteries. The UA has a maximum airspeed of 3 0 knots. We will operate the UA over various metropolitan areas, primarily around Indianapolis, IN, to enhance academic community/ business awareness and augment real estate listing videos.

UAS Operating Parameters

We will abide by the following addition al operating conditions under this exemption, which ensures a level of safety at least equal to existing rules:

• Operate UAS below 300 feet and within a radius distance

## of 1000 feet from the controller to aid in direct line of sight visual observation;

• Obtain permission from the owner/controller of any vessels, vehicles and structures when operations may be conducted closer than 500 feet to any such vessels, vehicles or structures; we will conduct a safety assessment of the risk of operating closer to those objects and determine that it does not present an undue hazard;

• Operate the UAS for 5

- 10 minutes per flight; • land U A S prior to the manufacturer’s recommended minimum level of battery power;

• Operate UAS during daylight hours only within visual line of sight (VLOS);

• Use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost;

• Conduct all operations under the flight safety protocols (includ ing posting a warning sign reading: “Attention Aerial Photography in Progress

– Remain Back 150 feet”) contained in the operating documents and will actively analyze flight data and other sources of information to constantly update and enhance safety proto cols;

• Contact respective airports if operations will be within 5 miles to advise them of his estimated flight time, flight duration, elevation of flight and other pertinent information;

• Always obtain all necessary permissions prior to operation;

•Ha ve procedures in place to abort flights in the event of safety breaches or potential danger;

• Only operate in safe environments that are strictly

## controlled, are away from power lines, elevated lights, airports and densely populated areas (defined by are as depicted in “yellow” on VFR charts and through obtaining information regarding congested areas from the local Flight Standards District Office (FSDO);

• Conduct extensive preflight inspections and protocols, during which safety carries primary importan ce (reference PHANTOM Flying Flow Chart and User Manual).

UAS Pilot in Command (PIC)

Anthony Straw, our Chief Pilot, holds a FAA Commercial Pilot license and Airline Transport Pilot Rating, first

- class medical certificate, multi

- engine instrument rating, is a current Air Force Instructor Pilot, and has substantial flight time in numerous types of aircraft. Given his flight background and experience, he has the knowledge required to ensure the high level of safety required by current regulations. Any other pilots who would conduct flights will

hold a minimum of a FAA Private Pilot License and third

class medical.

Regarding UAS operational training, we have flown numerous practice flights in remote areas as hobbyists simulating flights for future commercial use to gain
familiarization with the characteristics of the UAS’ performance under different temperature and weather

conditions.

Any PIC operating our UAS will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25

hours of total ti me as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. The PIC will also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of

## UAS to be used for operations. In addition to the hour requirements, the PIC will accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes) prior to any flight.

Specific Exemptions Requested

Given the size, weight, speed, and limited operating area

associated wi th the UA, we feel an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203(a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112

- 95 (Section 333).

We request an exemption from § 45.23 Marking of the aircraft because the UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further,

the two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless of this, we can mark the UAS in the largest possible lettering by placing the word “Experimental” on its fuselage a s required by § 45.29(f) so that anyone will see the markings.

We request an exemption from § 91.7(a) which prohibits the operation of an aircraft without an airworthiness certificate, since there is currently no certificate applicable to our operation, t his regulation is inapplicable.

We request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections since they only apply to aircraft with an airworthiness certificate. However, as a safety precaution we wil l perform a preflight inspection of the UAS before each flight as outlined in the attached operating documents.

## We request an exemption from § 91.9(b)(2) which requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board the aircraft and given its size, this regulation is inapplicable. We believe an equivalent level of safety will be achieved by maintaining a safety/flight manual with the UAS ground station.

We request an exemption from § 91.119 which prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters to be operated at lower altitu des in certain conditions. We will not operate our UAS above the altitude of 300 feet above ground level (AGL) and will also only operate in safe areas away from the public and traffic, thus “providing a level of safety at least equivalent to or below thos e in

relation to mini

- mum safe altitudes.” Given the size, weight, maneuverability, and speed of the UAS, an equivalent or higher level of safety will be achieved.

We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the U AS utilizes electronic GPS

with a barometric sensor.

We request an exemption from § 91.151(a) Fuel requirements for flight in VFR conditions. The UAV is 100% electric and two low battery alerts are issued

- per the operating documents, the UAV will be lan ded at the first alert. Also, our flights will last only 5

- 10 minutes each, and
the UAS has an automated function which results in immediate landing when a low battery is detected. The PIC will not begin a flight unless (considering wind and forecast

weath er conditions) there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, land the UA with 30% battery power remaining.

## Public Interest

Aerial videography for geographical awareness and for real

estate marke ting has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has been cost

- prohibitive. By granting this exemption we would be able to provide this

service at a much lower cost. Further , our small UAS will pose no threat to the public given its small size and lack of

combustible fuel when com

- pared to larger manned aircraft. Additionally, the operation of our UAS will minimize eco

logical damage and promote economic growth by providing information to companies looking to relocate or build in the

metro areas we service.

Summary

We will comply with all of the following conditions and limitations should this grant of exemption be provided:

1) Operations will be limited to the following aircraft described in the operating documents which is a quad

- rotor aircraft weighing less than 3 pounds: PHANTOM 2 Un

manned Aircraft System.

2) The UA will not be flown at an indicated airspeed exceeding 30 knots.

3) The UA will be operated at an altitude of no more than 300 feet above ground level (AGL), as indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be in feet AGL.

4) The UA will be operated within visual l ine of sight (VLOS) of the Pilot In Command (PIC) at all times.

5) All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight (VLOS) of the

## VO at all times. The VO and PIC will be able to communicate

verbal ly at all times. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the functions prescribed in the operating documents.

6) The operating do cuments will be accessible during UAS operations and made available to the Administrator upon request. Any revisions to the operating documents will be presented to the Administrator upon request.

7) Prior to each flight, the PIC will inspect the UAS to e nsure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated until the necessary maintenance has been performed and the UAS is found to be in a condition for

safe flight. The Ground Control Station will be included in the preflight inspection. All maintenance and alterations will be properly documented in the aircraft records.

8) Any UAS maintenance or alterations that affect the UAS operation or flight characteri stics, e.g. replacement of a flight critical component, will undergo a functional test flight. The PIC who conducts the functional test flight will make an entry

in the aircraft records.

9) The pre

- flight inspection section in the operating

documents will account for all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

10) We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement,

ins pection, and life limit requirements.

11) We will carry out maintenance, inspections, and record keeping requirements, in accordance with the operating

## documents. Maintenance, inspection, and alterations will be noted in the aircraft records, including to tal flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service.

12) Each UAS operated will comply with all manufacturer Safety Bulletins.

13) An authorized person will make an entry in the airc raft record of the corrective action taken against discrepancies discovered between inspections.

14) UAS operations will be conducted by a PIC possessing at least a private pilot certificate and at least a current third

class medical certificate. The PIC will 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.

15) Prior to operations conducted for the purpose of aerial videography/cinematography and augmenting real es tate listing videos (or similar operations), the PIC will have ac

cumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a mul ti

- rotor UAS.

16) Prior to operations conducted for the purpose of aerial videography/cinematography and augmenting real estate listing videos (or similar operations), the PIC will have ac

cumulated and logged, in a manner consistent with 14 CFR 61.51(b) , a minimum of 5 hours as UAS pilot operating the make and model of the UAS to be used in operations. The PIC will accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

17) The PIC will not operate the UAS for the purpose of aerial videography/cinematography and augmenting real

## estate listing videos (or similar operations), unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a

manner consistent with the operating documents, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

18) UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will be conducted under visual meteorological conditions (VMC).

19) The UA will not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

published aeronautical chart.

20) The UA will not be operated less 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.

21) If a UA loses communications or loses its GPS signal, it will return to a predeter mined location within the planned operating area and land or be recovered in accordance with the operating documents.

22) The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance with the operating

documents.

23) The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining.

24) We will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations, and also request a Notice to

## Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.

25) Before conduct ing operations, the radio frequency spectrum used for operation and control of the UA will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

26) The documents required under 14 CFR 91.9 and 91.203
will be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents will be made available to the Administrator or any law enforcement official upon request.

27) The UA will remain clear and yiel d the right of way to all manned aviation operations and activities at all times.

28) The UAS will not be operated by the PIC from any moving device or vehicle.

29) The UA will not be operated over congested or densely populated areas.

30) Flight operat ions will be conducted at least 500 feet from all nonparticipating per

- sons, vessels, vehicles, 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 a ccident. We will 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 and/or;

b. The aircr aft is operated near vessels, vehicles or structures where the owner/controller of such vessels,

## vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and deter

- mined that i t does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

31) All operations will be conducted over private or

controlled

- access p roperty with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

32) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board ( NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

Respectfully,

Anthony M. Straw

Managing Partner, Straw Investment Group, LLC

830

- 313

- 8306