# MINTZ LEVIN

Jonathan T. Cain 

### I 202 585 3508 

### I jtcain@mintz.com

BY HAND Docket Operations, M-30 United States Department ofTransportation 1200 New JerseyAve., SE West Building Ground Floor, Room W12-140 Washington, DC 20590-0001 March 25, 2015 701 Pennsylvania Avenue, N.W. Washington, D.C. 20004 202-434-7300 202-434-7400 fax www.mintz.com

Re: Petition for Exemption PursuantTo Section 333 ofthe FAA Modernization and Reform Act of2012

Dear Sir or Madam: Petitioner, Unmanned Aerial Systems Development, Inc., is a Massachusetts corporation doingbusiness as UAS Development ("UASD"). This firm is legal counsel to Petitioner. We are writingpursuantto the FAA Modernization and Reform Act of2012 (the "Reform Act") and the procedures contained in 14 C.F.R. § 11.81, to requestthat UASD, an owner and operator ofsmall unmanned aircraft, be exempted from the Federal Aviation Regulations ("FARs") listedbelow so that UASD may operate its lightweight unmanned aircraft systems ("UAS") commercially in airspace regulated bythe Federal Aviation Administration ("FAA"). Introductory Statement
UASD is a pioneerin capturinghigh definition feature film quality aerial cinematographywith UASs. UASD has demonstrated its abilityto carry a feature film quality camera system, the Blackmagic Design 4kProduction camera, on a stable UAS platform.
UASD has been operatingits lightweight UASs non-commerciallyin controlled and regulatory compliantvenues without significant incident overthe lastyear. UASD would now like authorization to fly and operate its UASs commerciallyin the United States, primarilyto capture aerial cinematography, conductresearch on UAS safetyprotocols and to continue our development ofenhanced platforms and systems for broaderUAS industrial applications.
USAD was founded bythree partners, two from the cinematography and production industry and one from an electronics manufacturing and mechanical engineering background. Its chiefengineer and pilot has over 15 years offlight experience in manned

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

BosTON 1 LONDON 1 Los ANGELES 1 NEw YORK 1 SAN DIEGO 1 SAN FRANCisco 1 STAMFORD 1 WASHINGTONMintz, Levin, Cohn,Ferris, Glovsky andPopeo, P.C. 

### Unmanned Aerial Systems Development, Inc. March 25, 2015 Page 2

aircraft as a licensed private pilot and on numerous unmanned airframes. UASD has documented operating standards, robusttechnical assessment and research. Its flight operations crew's certification and experience has enabled UASD to secure comprehensive commercial liability and operations insurance through a major U.S. underwriter.
UASD's UASs are among the most advanced remote control aircraft being used for these purposes. The airframe is described in detail in the Flight Operations Manual ("FOM") thataccompanies this Petition. In summary, the airframe is based upon a Cortex 1000mm quadcopter manufactured byCarbonCore, Ltd. ofReading, England entirely ofaircraft grade carbon fiber materials, fastened with stainless steel fittings. UASD builds the remainder ofthe UAS and integrates the motors, navigation and flight control systems, power systems, radio controls and gimbaled camera payload atits facility in Holliston, Massachusetts. The central hub ofthe unit consists oftwo layers ofcarbon fiber sheets layered to provide a protective housing for the flight control systems as well as the power distribution and motor controls. These layers also form the mounting structure for the four carbon fiber spars, to which the eight brushless propulsion motors are mounted. The motors, navigation, power, radio and flight control systems UASD employs are industry proven and are used in a broad array ofUASs. The performance histories ofthese systems are well documented and regularly updated, allowing for continual assessment and refinementthrough UASD's own flight experience and many other users. Granting UASD commercial UAS operations authority as outlined in this Petition would permitto operate its UAS in tightly controlled and limited airspace separated from persons not involved in the operations. Currently, similar lightweight, remote controlled UASs are legally operated by amateurs with no flight experience, safety plan or controls in place to prevent accidents. UASD's experienced remote control pilots, technicians and safety crew, operatingunder documented procedures will provide an enhanced level of safety.
To date, the FAA has granted exemptions to a select group ofpetitioners. Petitioner contends thatUASD's operations, under similar mission parameters, are equivalentin effect to those ofthe currently authorized operators. With operations headquartered in the northeastern section ofthe United States, UASD's authorization would allow them to serve a region ofthe countrywith significant film production industrydemand at a greater economic benefitto potential clientele and would further introduce a diversity ofproviders to the broader market, furthering the economic benefit to the industries to be served. Granting UASD's request comports with the Secretary ofTransportation's (FAA Administrator's) responsibilities to not onlyintegrate UASs into the national airspace system, butto "

...establish requirements for the safe operation ofsuch aircraft systems [UASs] in the national airspace system" under Section 333(c) ofthe Reform Act. Further,Mintz, Levin, Cohn,Ferris, Glovsky andPopeo, P.C. Unmanned Aerial Systems Development, Inc. March 25, 2015 Page 3

UASD will conductits operations in compliance with the protocols described herein or as otherwise established bythe FAA.
Forthese reasons, and in consideration ofthe information provided below, UASD respectfullyrequests the FAA grantthis Petition

. 

### .L UASD's Contact Information

-- 14 C.F.R. § 11.81(a):
Unmanned Aerial Systems Development, Inc. 24Water St Holliston, MA 01746 Telephone: 617-823-9327 Attn: JeffreyAdams Email: jadams@uasdevelopment.com
Jonathan T. Cain MINTZ LEVIN 701 Pennsylvania Ave. NW Washington, DC 20004 Telephone: 202-434-7300 Email: jtcain@mintz.com
.2_. Specific Sections ofTitle 14 ofthe CFR From Which UASD Requests Exemption14 C.F.R. § 11.81(b):

14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR § 45.27(a); 14 CFR § 61.113; 14 CFR § 91.7 (a); 14 CFR §§ 91.9 (b)(2) & (c); 14 CFR § 91.103; 14 CFR § 91.109(a); 14 CFR § 91.119(c); 14 CFR § 91.121; 14 CFR § 151(a); 14 CFR §§ 91.203(a) & (b); 14 CFR § 91.405(a); 14 CFR § 407(a)(1); 14 CFR § 409(a)(2); 14 CFR §§ 417(a) & (b).Mintz,**Le~** Cohn,Ferris, Glovsky andPopeo, P.C. Unmanned Aerial Systems Development, Inc. March 25,2015 Page 4**~** The Extent ofReliefUASD Seeks and the Reason It Seeks Such Relief- 14 C.F.R. § 11.81(c):

UASD submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seekingrelieffrom currently applicable FARs operatingto prevent UASD's contemplated commercial cinematic, photographic and research flight operationswithin the national airspace system. The Reform Act in Section 332 provides for such integration ofcivil unmanned aircraft systems into our national airspace system as it is in the public's interestto do so. UASD's lightweight UASs meetthe definition of"small unmanned aircraft" as defined in Section 331 and therefore the integration ofUASD's lightweight UASs are expresslycontemplated bythe Reform Act. Through this Petition, UASD seeks to operate its lightweight UASs priorto the time the FAA promulgates final regulations governing such operations pursuantto the Reform Act.
The Reform Act specifies the factors to be considered in determiningthetypes of UASs that may operate safely in our national airspace system. These factors include:
The weight, size, speed and overall capabilities ofthe UAS; Whetherthe UAS will be operated near airports or populated areas; and, Whetherthe UAS will be operated byline ofsight.
112 P.L. 95 § 333 (a). Each ofthese factors compels the exemption soughtbyUASD.
UASD's UASs utilize eight counter-rotating propellers for extreme balance, control and stability. The combined "wheels up" weight (including airframe, gimbal and payload) is approximately 35 pounds. The operational gross weightvaries slightly depending upon the equipment selected for each mission, butwill never exceed 55 pounds. Each ofUASD's small unmanned aircraft is designed to primarilyhover in place and operate at airspeeds less than 50 knots. They carryno pilot, passenger, explosives or inflammable materials. They are capable ofvertical and horizontal flight and operate onlywithin the unaided line ofsight ofthe remote control pilot in command. In addition to the remote control pilot, UASD uses a secondaryvisual spotter for redundant observation ofthe airframe and the surrounding area as well as a ground service technician, such that, at minimum, three UASD personnel govern the safe flight ofanyUASD aircraft at all time during active operations. Utilizing batterypower, flights generally lastbetweenten and thirty minutes. UASD does not operate its UASs with less than twentyfive percentbatterycapacity. Safety systems in place include a GPS mode that allows UASD's UASs to hover in place if communication with the radio control pilot is lost temporarily, then return to a predetermined sterile area and slowly descend to the ground ifpilot control is notMintz,Levin, Cohn,Ferris, Glovsky andPopeo, P.C.
Unmanned Aerial Systems Development, Inc. March 25, 2015 Page 5

reestablished. The flight crewhas the abilityto remotely engage the autonomous "return to home" function in the eventthe pilot in command is unable to fulfill his flight responsibilities.
UASD will not operate its UASs near active airports and conducts its operations over areas from which persons not engaged work related to the mission are excluded. To date, UASD has only conducted test flights ofits fleet on private property, cordoned offareas under the direct control ofUASD sponsors or research partners. UASD only operates its UASs in predetermined areas and onlyin compliance with established industry safety protocols. UASD adheres to all ofthe recommendations ofthe FAA in regards to model aircraft as well as those ofthe Aeronautical Modelers Association. To further these accepted standards, UASD has drafted, researched and applied its own comprehensive operations manual that is regularly reviewed by all operators and crew and enforced throughout all operations.A copy ofthis proprietary document is included and incorporated herein.
14 CFR Part 21. Subpart Hand 14 CFR Part 27: In consideration ofthe size, weight, speed and limited operating area ofthe UAS, Petitioner submits that equivalent or higher level ofsafety will be achieved than would be possible with a certificated aircraft. Accordingly, Petitionerrequests that itbe relieved ofthe obligation to complywith the certification procedures and airworthiness standards ofPart 21, subpart Hand Part 27.
14 CFR § 45.27(a): Assumingthat Petitioner's UAS is relieved ofthe certification requirement ofPart 21, Petitioner requests that, given the size ofthe UAS, it also be relieved ofthe marking requirements ofsection 45.27(a).
14 CFR § 61.113: Petitionerrequests relieffrom the regulation prohibiting a private pilot acting as pilotin command from conducting operations for compensation or hire. The fundamental requirement for the pilotin command ofa UAS to hold an airman's certificate is to ensure that such pilots are familiar with the national airspace system and the regulations governing operations in such airspace. The airspace knowledge requirements to hold a private pilot certificate are not materially different from those required ofa commercial pilot. The regulations proposed bythe FAA for the operation ofunmanned aircraft in the national airspace system acknowledge this fact and propose that a private pilot may command a UAS for compensation. Furthermore, as setforth in its Flight Operations Manual, Petitioner will conduct commercial operations onlywith pilots in command who hold a private pilot certificate, a third-class medical, and who have demonstrated minimum flight hours commandingunmanned aircraft, including minimums for time in the specific aircraft used by Petitioner. A commercial pilot's license does not ensure competency or proficiency in remote control piloting skills, whereas UASD'sMintz, Levin, Cohn,Ferris, Glovsky andPopeo, P.C.
Unmanned Aerial Systems Development, Inc. March 25, 2015 Page 6
pilotvetting and training programs will. Finally, grant ofan exemption from section 61.113 is consistentwith the FAA's decision in Grant ofExemption to Astraeus Aerial, No. 11062 (Sept. 25, 2014) and the rationale provided therein.
14 CFR § 91.7(a): Petitioner requests exemption from this requirement on the ground that no airworthiness certificate will be issued for the UAS, and thus no FAA regulatory standard exists for determiningthe airworthiness ofthe aircraft. An equivalent level ofsafetyis assured by Petitioner's compliance with the preflight inspection requirements setforth in its Flight Operations Manual. In addition, Petitioner is not seeking exemption from section 91.7(b), which imposes upon the pilotin command the dutyto ascertain thatthe UAS is in flightworthy condition before each flight.
14 CFR §§ 91.9(b)(2) & (c): The UAS is not certificated and does have an approved flight manual, placards and markings. The aircraft is not large enough to carry such a manual, and no pilot or passengers to read placards or other markings. An equivalentlevel ofsafety may obtained byhaving a copy ofthe Flight Operations Manual readily available to the pilot in command atthe ground control station for the UAS. Petitioner requests exemption from the requirements ofthese sections. The FAA has previouslyissued exemptions to this regulation in Exemption Nos. 8607,8737,8738,9299, 9299A,9565,9565B,10167,10167A,10602,10700and 32827.
14 CFR § 91.103: The requirements ofthis section are not applicable to Petitioner's proposed flight operations in that it does not operate in IFR conditions, from runways, or with an approved flight manual containingtakeoffand landing distances. Petitioner has established an equivalentlevel ofsafetybyrequiring in its Flight Operations Manual that its pilotin command evaluate all relevant flight conditions, batterycharge requirements, and potential obstructions to the flight plan. Petitioner requests that itbe exempted from this requirement.
14 CFR § 91.109(a): Petitionermay conducttraining operations using its aircraftto train newpilots to operate the aircraft. The UAS does nothave on-board flight controls. Petitionerwill conducttraining flights solely in dedicated training sessions in space at locations isolated from persons not involved in the trainingflight. This provides an equivalentlevel ofsafetyto the availability offully-functional dual controls.
14 CFR § 91.119(c): Petitioner requests exemption from the requirement in section 91.119(c) thatthe UAS may not be operated less than 500 feet above the surface or closerthan 500 feet to any person, vessel, vehicle or structure. The regulations proposed for operations ofa UAS limit operations to 400 feet orless above groundMintz, Levin, Cohn,Ferris, Glovsky andPopeo, P.C. 

### Unmanned Aerial Systems Development, Inc. March 25, 2015 Page 7

level. Petitioner's operations will all be conducted in "sterile" areas where only persons involved in the filming operation will be permitted. Petitioneris not seeking exemption from sections 91.119(a) or (b). Petitioner's request is consistent with Order 8900.1 V3, C8, S1, which permits operations for motion picture and television filming belowthe altitudes specified in section 91.119(c). Petitioner further requests relieffrom the 500 foot horizontal separation requirementto permit operations within 200 feet horizontally from persons, vessels, vehicles and structures involved in the filming activity. The FAA has found that such separation is sufficientto protectnon-participating persons in the event ofan accident.
14 CFR § 

### 91.121: Petitioner requests relieffrom the barometric altimeter setting requirement on the grounds thatthe GPS based digital altimeter readoutprovided to the pilot in command through the telemetric feed from the UAS to the pilot's control station provides an equivalentlevel ofsafety. The digital altimeter provides continuous altitude above ground, which is consistentwith the proposed regulatory requirementthat all flights be conducted below 400 feet AGL. The digital altimeter is specified to have vertical accuracy of± 0.5 meters underthe anticipated flight conditions.
14 CFR § 

### 151(a): Petitioner requests exemption from the fuel requirements for VFR conditions consistentwith the FAA's prior grant ofexemptions for similar aircraft and operations granted in Exemption Numbers 10650, 10808 and others for daytime VFR operations. Petitioner's Flight Operations Manual provides thatflights will be terminated when batterycharge reaches 25%. The proposed operational limitation provides a level ofsafety equivalentto thatprovided bythe regulation.
14 CFR §§ 

### 91.203(a) & 

### (b): Petitioner's UAS will nothave an airworthiness certificate issued to it, and itwill have no pilot or passengers. Petitioner requests that itbe relieved ifthe requirementto display airworthiness certificate, special flight authorization and registration certificate. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167 Aand 10700.
14 CFR §§ 

### 91.405(a): 407(a)(1): 409(a)(2) and 14 CFR 417(a) & 

### (b): Petitioner should be relieved ofthe maintenance requirements contained in Part 91 because the UAS has notbeen issued an airworthiness certificate. UASD conducts an extensive maintenance program thatinvolves regular software updates and curative measures for any damaged hardware. Further, UASD adheres to a stringent "active use time" based componentmaintenance and replacement protocol, minimizingthe potential for component failure due to wear issues. Petitioner intends to maintain written records ofall such actions. Petitioner submits thatits proposed maintenance program provides a level ofsafety equivalentto thatprovided toMintz, Levin, Cohn,Ferris, Glovsky andPopeo, P.C. Unmanned Aerial Systems Development, Inc. March 25, 2015 Page 8

certificated aircraft under the maintenance regulations from which reliefis requested.
UASD's operation ofits fleet ofsmall unmanned aircraftwill not"create a hazard to users ofthe national airspace system orthe public." 112 P.L. 95 § 333 (b). Given the small size and weight ofUASD's UASs, combined with their operation in cordoned offand wellcontrolled film production areas, UASD's fleet falls within Congress's contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UASs into the national airspace system. Indeed, UASD's UASs have a demonstrable safety record and do not pose anythreatto the general public or national security. Further, UASD will file comprehensive flight/operations plans with the regional FAA offices and will complyin any additionally requested information or documentation for requisite notice to airmen.

4. How UASD's RequestWill Benefitthe Public As AWhole: Granting UASD's Petition furthers the public interest. First, Congress has alreadypronounced through passage ofthe Reform Act thatitis in the public's interestto integrate commercially flown UASs into the national airspace system. Granting UASD's Petition will further that goal. Second, UASD conducts research into safe UAS operations everytime itflies one of its UASs. Flight data, visual inspections, recorded observations and flight analyses are compiled to further enhance current safety protocols. Allowing UASD to log more flight time under the diverse conditions ofreal world situations will serve to enhance its research and its abilityto further refine current operational safety standards. Third, the public has an interest in reducing the inherentrisk ofdanger and fossil fuel emission associated with current aerial cinematic capture methods, namely, full size helicopters. UASD's UASs are batterypowered and produce zero emissions during operations. Further, there is no liquid fuel onboard the vehicle to ignite and potentially explode in the event ofa crash. Additionally, the likelyphysical impactresulting from a lightweight UAS crash is far less than that ofa full size helicopter. The public's interest is furthered byminimizing ecological and crash impacts bypermitting motion picture capture through UASD's lightweight UASs. Fourth, UASD is workingto establish a jointresearch program withthe robotics department ofWorcester Polytechnic Institute to research advancement ofautonomous vehicle operations, most notably in the areas ofcollision avoidance, inertial guidance, autonomous multi-vehicle operations (swarm flights) and other "NextGen" UAS systems and standards. Aletter from WPI supportingthis petition is attached. UASD also has initiated plans to partnerwith numerous local technology companies and atleast one internationally recognized engineering &technical university to provide an operationalMintz, Levin, Cohn,Ferris, Glovsky andPopeo, P.C.
Unmanned Aerial Systems Development, Inc. March 25, 2015 Page 9

testbed for advanced systems development. Our operational experience and flight data can provide related systems researchers and advanced degree candidates in aeronautical & robotics engineeringwith a platform to explore, develop and defend their research, studies and theses. Granting UASD's exemption request substantiallyfurthers the public's interest in ways known and currentlyunknown. 5.., Reasons WhyUASD's Exemption Will NotAdverselyAffect Safety Or How The Exemption Will Provide a Level ofSafetyAt Least Equal To Existing Rule:

UASD's exemptionwill not adversely affect safety. Quite the contrary, for the
reasons previously stated, permittingUASD to log more flight time in FAA controlled airspace will allow UASD to innovate and implement new and novel, as ofyet undiscovered safetyprotocols. In addition, UASD submits the following representations of enhancements to current aerial motion picture capture techniques: UASD's UASs weigh less than 55 pounds complete with feature length motion picture quality cameras like the Red Dragon; UASD only operates its UASs below400 feet; UASD's UASs only operate for 10-30 minutes per flight; UASD lands its UASs when they reach 25% batterypower; UASD's remote control pilots operate UASD's UASs byunaided visual line of sight; UASD's remote control pilots have access to onboard dynamic video guidance to augmentvisual line ofsight observation; UASD staffs each flight with a remote control FAA licensed pilot in command, a spotter (co-pilot) and a payload technician with communication systems enabling real time communication betweenthem;

• UASD employs FAA licensed pilot(s) who also possess a minimum of 3rd class medical certification;

• UASD conducts regimented, companywide systems and protocol training programs, with specific focus on the array offlight units and rigging configurations that maybe employed;

• UASD's pilots have complete authorityto abort any flight or refuse at any time to execute an operational request, particularlyin regard to any flight safetyparameter such as vehicle limitations, weather conditions, inherent danger ofmission, or any such potential hazard to operating standards; UASD's UASs are programmed to switch to an autonomous GPS flight modeMin12, Levin, Cohn,Ferris, Glovsky andPopeo,P.C. Unmanned Aerial Systems Development, Inc. March 25, 2015 Page 10
wherebytheyhover and then return to a sterile area and slowlyland if communication with the remote control pilot is lost or ifbatterypower falls below 25%; UASD's autonomous "returnto home" protocol can be initiated manuallyin the eventthatthe PIC can no longer fulfill his flight obligations; UASD actively analyzes flight data and other sources of information to constantlyupdate and enhance safety protocols;

• UASD only operates in quarantined areas that are strictly controlled, are awayfrom airports and congested areas;
• UASD has procedures in place to mark and secure the active launch 

### & recovery zone, with barriers and signage to preventunauthorized access to the area; UASD conducts extensive briefings prior to flight, during which safety carries primary importance;

• UASD always obtains all necessary permissions and permits priorto operation; and,

• UASD has procedures in place to abort flights in the event of safety breaches or potential hazardous conditions.
UASD's safetyprotocols provide a level ofsafety atleast equal to existing rules, and in nearly everyinstance, greaterthan existing rules. It is importantto note that absentthe integration ofcommercial UASs into our national airspace system, helicopters arethe primarymeans ofaerial motion picture capture. While the safetyrecord ofsuch helicopters is remarkable, it is far safer to operate a batterypowered lightweight UAS. First, the potential loss oflife is diminished because UASs carry no people on board and UASD only operates them in uncongested areas. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is nil. Third, the small size and extreme maneuverability of UASD's UASs allow our remote control pilots to avoid hazards. Lastly, given their small size and weight, even when close enough to capture unique images, UASD's UASs need notbe so close to the subjects or individuals they are filming. Accordingly, UASD's UASs have operated and will continue to operate at and above current safetylevels.
6. A SummaryThe FAA May Publish in the Federal Register:
Section 14 CFR: 14 CFR Part 21, Subpart H; Part 27; § 45.27(a); § 61.113; § 91.7 (a); §§ 91.9 (b) (2) & (c);§ 91.103; § 91.109(a); § 91.119(c); § 91.121; § 151(a); §§ 91.203(a) & (b);§ 91.405(a); § 407(a) (1); § 409(a)(2); §§ 417(a) & (b). Description ofreliefsought: Unmanned Aerial Systems Development, Inc. is seeking an exemption pursuantto Section 333 ofthe FAA Modernization and Reform Act ofMintz,Levin, Cohn,Ferris, Glovsky andPopeo, P.C.
Unmanned Aerial Systems Development, Inc. March 25, 2015 Page 11

2012 to operate commercially a small unmanned aerial vehicle (55 pounds orless) in motion picture and television filming operations and to conductresearch for additional commercial applications for unmanned aerial vehicles. 

### Summary Granting UASD's petition will reduce current risk levels in motion picture and television filming and enhance safety ofsuch operations. Currently, motion picture image capture relies primarily on the use oflarge scale, manned aircraftrunning on combustible fuel. UASD's craft do not contain potentiallyexplosive fuel, are smaller, lighter and more maneuverable than conventional motion picture aircraft. UASD operates at lower altitudes, at slower speeds than conventional manned aircraft and in controlled access areas. There are no people on board UASD's UASs and therefore the likelihood ofdeath or serious bodily injuryis significantly limited. UASD's operation ofits UASs, weighting less than 55 pounds and traveling at speeds lower than 50 knots in cordoned offareas will provide at least an equivalentlevel ofsafety as that achieved under current FARs. Accordingly, Petitionerrespectfully requests thatthe FAA grantits exemption without delay.

Attachments: Photographs 1-7 Sincerely,

Jonathan T. Cain Counsel to UnmannedAerial Systems Development, Inc.

UASD Flight Operations Manual for Aerial Cinematography UASD EmergencyAction Plan Checklist (blank form) UASD In-Flight EmergencyAction Plan Incident DebriefReport (blank form) UASD Daily Mission Criteria Report (blank form) UASD Pre-Flight Checklist (blank form) UASD Battery Charging Manual

40564993v.lSupporting Visual Graphics:

1. elevation view with controllers

2. 3/4 overhead view3. 7/8 overhead view4. UAV airborne (at test facility) with production grade camera system mounted into 3 axis gimbal.

5. Test flight facility (Sept 16, 2014). Preflight systems check w/ pilot in command, Matt Greenway and flight operations manager, JeffAdams.6. and 7. Demonstration flight for robotics industry executives. (Sept 16, 2014)