August 31

, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Exemption Request Pursuant To Section 333 of the FAA Modernization and Reform Act of 2012



## Name and Address of Pe titi oner

Michael and Shelly Diener

M & S Aerials LLC

1830 Carriage Dr

.

Victoria, MN 55386

( 612 ) 865

- 9216

mgdiener@gmail.com



## I n t roduc ti on

As set forth herein, to commercially operate small Unmanned Aircraft Systems (UAS) safely and legally in the

National Airspace System (NAS), Michael and Shelly Diener of M & S Aerials LLC, seek an exemption

from Federal Aviation Regulations pursuant to 14 C.F.R. and Section 333 of the FAA Modernization and

Reform Act of 2012.

Section 333 states that the FAA may issue a certificate of waiver upon a finding that a type of UAS, as a result

of its size, weight, speed, operational capacity, proximity to airports and populated areas, and operations

within visual line of sight do not create a hazard to users of the NAS or the public or pose a threat to national

security. The grant of such an exemption is consistent with Congress’ intent, reflected in Section 333, that

safe systems be permitted in the national airspace prior to the issuance of final regulations governing general

use of these systems.

Being “unmanned aircraft and associated elements, including communication links and the components that

control the unmanned aircraft that are required for the pilot in command to operate safely and efficiently in

the national airspace system,” M & S Aerial s ’ UAS meet the Section 33 1 definition of “small unmanned

aircraft.”

Section 332 provides for such integration of civil unmanned aircraft systems into our national airspace

system as it is in the public’s interest to do so. We would like to operate our small UAS(s) prior to the time

period by which the Reform Act requires the FAA to promulgate rules governing such craft, thereby providing

direct experience and valuable information for formal regulation.

M & S Aerials intends to use small UAS to provide aerial photography and videography services to

businesses, organizations and community members. See the Pu blic Benefit section of this d ocu ment for

more details. More specifically, we intend to:● E nable businesses to improve marketing and outreach through the use of state

- of

- the

- art aerial

photography and videography

 H elp to inspect buildings and structures, and map landscapes in a safe, cost

- effective

manner

 P rovide economic stimulus and public benefit by providing an effective means by

which companies or individuals can use up

- to

- date, high

- quality photos and videos to

learn about properties, neighborhoods and communities

 H elp communities realize economic benefit by encouraging public participation and

encouraging tourism; by showcasing community buildings and landscapes; and by

documenting community events in low

- cost ways not previously available to them

 I ncrease awareness/knowledge of the amenities of a local area by the general public

and by visiting tourists

 P rovide non

- profit organizations as well as schools and universities and local

municipalities ways to showcase facilities, document events, and educate the public

We understand that we are entitled to submit a Petition for Exemption if we believe that f ollowing a rule

will burden us, we can provide a level of safety at least equal to that provided by the rule, and our request is

in the public interest. Therefore we seek relief from the following sections of the current regulations:

14 CFR 21 subpart H Certification procedures; Airworthiness Certificates

14 CFR 45.23 Display of Marks

14 CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations

14 CFR 91.105 Flight crewmembers at stations

14 CFR 91.109 (a) Flight instruction

14 CFR 91.119 (c) Minimum safe altitudes

14 CFR 91.121 A ltimeter settings

14 CFR 91.151 (a) Fuel Requirements for Flight in VFR Conditions

14 CFR 91.203 Carrying Civil Aircraft Certification and Registration

14 CFR 91.405 (a) 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2) Maintenance required;

Operation after maintenance, preventive maintenance, rebuilding or alteration

14 CFR 91.417 (a) & (b) Maintenance Records

14 CFR 91.7 (a) Civil Aircraft Airworthiness

14 CFR 91.9 (b) Civil aircraft flight manual, marking, and placard requirements.

This application is similar to many which have received FAA approval. As stated in Exemption #11639, the

FAA has found that the enhanced safety achieved using an UAS with the specifications described by herein,

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 such exemption is in the

public interest. Since we are applying at a time when the FAA is using a “summary grant process” be

informed that while developing this request we reviewed, among others, exemptions #11636, #11639,

#11595, #11596, #11564, #11569, #11616 and # 12641

.

## Extent of Relief and Reason for Seeking Relief; why t he e xemption w ould n o t

a dversely a ffect s afety, or how the e xemption would p rovide a l evel of s afe t y e qual

to e xisting r u l e

Part 21 Airworthiness Certification; Subpart H Certification procedures for products and parts,

Airworthiness Certificates

This section outlines requirements for the issue of design and production approvals, airworthiness

certificates, and other airworthiness approvals. We seek relief from this rule because the size, weight and

enclosed operational area of our UAS, as described elsewhere in this document, permit exemption from

Part 21 because our UAS meet and exceed an equivalent level of safety pursuant to Section 333 of the

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under

both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Therefore, relief from 14 CFR part

21, and any associated noise certification and testing requirements of part 36, is not necessary.

Instead of following this requirement, we will as outlined in this document, as per our Flight

Operations and Procedures Manual and Training Manual (currently in development), M & S Aerials seeks to

uphold the same level or exceeded level of safety as described in Part 21 of 14

C.F.R. Therefore this exemption will not adversely affect safety or will provide a level of safety equal to

the existing rule.

14 CFR 45.23 Display of Marks

This section outlines regulations requiring specific location(s) and size of aircraft marks. We seek relief from

this rule because, given the size of our UAS, and the lack of cabin, cockpit or pilot station, t wo inch lettering

is difficult to place on such small aircraft.

Instead of following this requirement, we will mark the UAS in lettering that is as large as practicable by

placing an N number registered with the FAA on its fuselage so that the PIC, VO, or other observers will see

the markings. This exemption will therefore not adversely affect safety or will provide a level of safety equal

to the existing rule.

14 CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations

This section describes regulations concerning certification of pilots. We seek relief from this rule because

the risks associated with the operation of a UAS are lesser than and often uncorrelated with the risks

associated with the commercial and private aircraft operations contemplated by Part 61 when drafted. The

skills required to fly large, manned aircraft are substantially different from the skills required to remotely

operate a small UAS. Also, manned aerial vehicles weighing significantly more than small drones (such as

ultralight vehicles)

, as well as small UAS legally operated by hobbyists, operate without the need for pilot

certification.

Requiring a private or commercial pilot certificate would provide no appreciable safety benefit and would

needlessly impose an undue burden of time and cost on M & S Aerials

, most particularly in light of the FAA’s

Small UAS Notice of Proposed Rulemaking which proposes that small UAS pilots be considered ‘operators’

required to meet certain requirements that do not include pilot’s license.Instead of following this requirement, to minimize risk and maximize safety, all UAS operations will be

controlled and limited, and all flights will be planned and coordinated prior to operations:

 P rior to operations, M & S Aerials’ PIC(s) will go through a documented process of dedicated

ground school and flight lessons in accordance with manufacturer and industry guides.

 A ll PIC’s will only operate the UAS as stated in this document and in our Flight Operations and

Procedures Manual, flying at altitudes well below the permissible limits for other civil aircraft, and

within a geographical envelope under the control of M & S Aerials ’ clients, the PIC will be

designated before a flight and will not transfer control at any time during a flight.

 M & S Aerials’ PICs will comply with upcoming FAA Operator Certification and R esponsibilities once

they are finalized.

This exemption will therefore not adversely affect safety or will provide a level of safety equal to the

existing rule. More information about pilot safety can be found in the Operation of the Unmanned Aircraft

to Minimize Risk to the NAS, People and Property section of this document.

14 CFR 91.105 Flight crewmembers at stations

This section outlines regulations for flight crewmembers inside an aircraft. We seek relief from this rule

because there is no flight crew onboard a small UAS.

Instead of following this requirement, in keeping with the direction of the regulation, the PIC of the UAS and

VO will be at their respective crewmember stations on the ground during takeoff and landing as well as the

complete duration of the flight. By instituting this procedure this exemption will therefore not adversely

affect safety or will provide a level of safety equal to the existing rule.

14 CFR 91.109 (a) Flight Instruction

This section provides that no person may operate a civil aircraft (except a manned free balloon) that is being

used for flight instruction unless that aircraft has fully functioning dual controls. We seek relief from this rule

because UAS do not have fully functioning dual controls.

Instead, flight control is accomplished through the use of a control box that communicates with the aircraft

via radio communications. The FAA has approved exemptions for flight training without fully functional dual

controls for a number of aircraft and for flight instruction in experimental aircraft. This exemption will

therefore not adversely affect safety or will provide a level of safety equal to the existing rule.

14 CFR 91.119 (c) Minimum safe altitudes: General.

This section establishes minimum altitudes for operation of civil aircraft. We seek relief from this rule

because the services we intend to provide for the public good may require photo or video images captured

from an altitude of less than 500 feet.

Instead of following this requirement, all UAS flights will be conducted with within visual line of sight and

with prior permission from the owner of the property or municipality. All persons, vessels, vehicles, not

directly involved with the operation will be notified and cleared of the area where UAS operations will be

conducted. Given our policies of advance notice and access restricted area, and given the size, weight,

maneuverability and speed of our UAS, we will maintain an equivalent or higher level of safety of that

described in this rule.14 CFR 91.121 Altimeter settings

This section defines regulations for altimeter settings. We seek relief from this rule concerning altimeter

settings because: our UAS has no altimeter settings. Instead, electronic GPS downlinks telemetry data in

real time to the PIC’s ground

- based on

- screen display as to the altitude (AGL) of the UAS above the takeoff

location.

This exemption will not adversely affect safety, as our PIC will provide a level of safety equal to the existing

rule by confirming the altitude of the launch site shown on the GPS altitude indicator prior to each flight.

14 CFR 91.151 (a) Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended

landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.” We seek relief from this rule because our UAS runs on

battery instead of fuel, most of our UAS flights last less than the 30 minute reserve requirement, and we do

not fly at night.

Instead of following this requirement, an equivalent level of safety will be achieved by following the UAS

manufacturer’s operating documents with regard to battery voltage. To ensure safety and maintain

adequate communication between radio cont r ol and the UAS, our PIC will not begin a flight with a battery

holding less than 75% charge; and will not begin a flight unless (considering wind and forecast weather

conditions) there is enough power to fly to the intended landing point at normal cruising speed and land

the UAS with no less than 30% of battery power. A landing sequence will be initiated at the 30% warning

and the UAS automatically initiates landing sequence at 15% charge while still under PIC control.

Through implementation of these procedures, this exemption will not adversely affect safety or will

provide a level of safety equal to the existing rule.

14 CFR 91.203 Carrying Civil Aircraft Certification and Registration

This regulation pertains to display of airworthiness certification within an aircraft. We seek relief from this

rule because our small UAS each weigh less than 10 pounds, and are operated without an onboard pilot.

There are passengers or crew; and no cabin or cockpit entrance upon which to display certificates.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where

the PIC will have immediate access to them, and be able to provide them upon request.

14 CFR 91.405 (a) Maintenance required; 14 CFR 91.407 (a) (1) Operation after maintenance,

preventive maintenance, rebuilding, or alteration; 14 CFR 91.409 (a) (2) Inspections; and

14 CFR 91.417 (a) & (b) Maintenance records

We seek relief from these 4 rules because these regulations only apply to aircraft with an airworthiness

certificate, and will not, therefore, apply to M & S Aerials’ UAS. We seek relief also because the FAA has

not developed maintenance standards for UAS that would allow an UAS operator to meet the part 91

maintenance requirements. In particular, there are no individuals authorized by the FAA to approve a UAS

for return to service or to conduct the initial airworthiness and annual return to service inspections as

required.

Instead of following these requirements, we will:

 P erform preventive and required maintenance on each aircraft as per the owner’s manuals. I nspect our UAS before and after each flight as per our Flight Operations and Procedures Manual to

ensure that the UAS is in a condition for safe flight.

 C onduct a test flight on each aircraft following any major repairs.

 P roperly note all discrepancies, maintenance, and alterations in a Maintenance Log.

Therefore this exemption would not adversely affect safety or would provide a level of safety equal to the

existing rule. More information about maintenance procedures can be found in the Operation of the

Unmanned Aircraft to Minimize Risk to the NAS, People and Property section of this document.

14 CFR 91.7 (a) Civil aircraft airworthiness

This section states that “no person may operate a civil aircraft unless it is in an airworthy condition.” We

seek relief from this rule based on the fact that M & S Aerials’ UAS will not require an airworthiness

certificate in accordance with 14 CFR part 21, Subpart H. Based on the fact that an airworthiness certificate

will not be issued, exemption from § 91.7(a) is not necessary.

An equivalent level of safety will be achieved for each activity through the guidance from our Flight

Operations and Procedures Manual, pilot training, and operational risk management

.

14 CFR 91.9 (b) Civil aircraft flight manual, marking, and placard requirements

This section requires an aircraft flight manual in the aircraft. We seek relief from this rule based on the small

size of our UAS and the fact that our UAS carries no onboard pilots or passengers. Given its size and

configuration there is no room or capacity in our UAS to carry such an item. This regulation is therefore

inapplicable.

An equivalent level of compliance will be achieved by keeping our versions of these documents at the ground

control point where the PIC will have immediate access to them, and be able to provide them upon request.

## Public Benefit: how our request would benefit the public as a who l e

Granting M & S Aerials the ability to operate small UAS safely and legally in the National Airspace System

will have the following positive economic and societal impacts on local communities, businesses,

organizations and community members:



###  B enefit local business marketing by offering state

- of

- the

- art 

### aerial photography and videography

 H elp to inspect buildings and structures, and map landscapes in a safe, cost

- effective manner

 P rovide economic stimulus and public benefit by providing an effective means by which companies or

individuals looking to relocate to an area can use up

- to

- date, high

- quality photos and videos of real

estate properties to learn about properties, neighborhoods and communitie s

 H elp communities realize economic benefit by encouraging public participation and encouraging

tourism by showcasing community buildings and landscapes and by documenting community events

in low

- cost ways not previously available to them

 I ncrease awareness/knowledge of the amenities of a local area by the general public and by visiting

tourists

 P rovide non

- profit organizations as well as schools and universities and local municipalities ways

to showcase facilities, document events, and educate the public

All of the above services:

 A re otherwise unavailable to the public, given the UAS’s the ability to:

o S afely capture images from 0 to 400 feet.

o create images that are more up

- to

- date and more closely defined than Google

o Earth

- type satellite images.

o C reate images at prices lower than that of traditional helicopter and airplane

photography and videography.

 I ncrease safety of and reduce risk to the public and the NAS by:

o R eplacing large manned helicopter and airplane flights with small UAS flights, thereby

reducing air and noise pollution as well as the dangers inherent in flying aircraft loaded with

crewmembers and combustible fuel close to people and property.

o O ffering safer ways to inspect tall structures and remote locations, e.g. removing the

physical risk of climbing on a roof or structure to inspect it.

 R educe environmental pollution and reliance on fossil fuels by replacing fueled aircraft flights with

battery

- operated UAS flights.



## Operation of the Unmanned Aircraft to Minimize Risk to the NAS, People and

Proper t y

Concerning our commercial UAS flight operations, we take seriously our obligation to clearly define

operational borders, and implement operational risk management procedures to ensure the public safety

of persons and property both in the air and on the ground.

Meeting or exceeding COA requirements to perform commercial operations in low

- risk, controlled

environments, our UAS will be operated: D uring daytime Visual Flight Rules (VFR) conditions and visual meteorological conditions (VMC).

 W ithin visual line of sight (VLOS) of the Pilot in Command (PIC) or the Visual Observer (VO), in

accordance with the statutory Section 333(b)(1) mandate.

 I n such a manner that the PIC and VO are able to communicate verbally at all times; and that the VO

can assist the PIC with seeing and avoiding other air traffic and other ground

- based

obstacles/obstructions.

We will not operate our UAS:

 A t altitudes exceeding 400 feet AGL

 I n winds exceeding 25 knots.

 F rom any moving vehicle or device.

 A t airspeeds greater than the maximum recommended by the manufacturer.

 L ess than 500 feet below or less than 2000 feet horizontally from a cloud or when visibility is less than

3 statute miles from the PIC.

 U nless (considering wind and forecast weather conditions) there is enough available power for the

UAS 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.

 N ear areas where general public is within 200 feet; or directly over any person except authorized M

& S Aerials personnel and consenting inspection personnel, unless operations nearer to the PIC do

not present an undue hazard to those persons; or unless the owner/controller of any vessels,

vehicles 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.

 N ear power lines, wind turbines, or elevated lights; or within areas of airspace restrictions such as the

one imposed by the National Park Service.

 N ear airports, heliports, or military bases; more specifically:

 I n accordance with the statutory Section 333 mandate regarding proximity to airports, we will stay

certain distances away from airports or heliports: 5 NM from an airport having an operational

control tower; or 3 NM from airport w/ a published instrument flight procedure, but not operational

tower; or 2 NM from an airport w/out published instrument flight procedure or an operational

tower; or 2 NM from a heliport with a published instrument flight procedure.

o We will 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 symbol as denoted on the current

o 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 airport management will be made available to the

Administrator or any law enforcement official upon request.

● If we intend to conduct operations in controlled airspaces which have existing requirements we will

n otify Flight Standards District Offices (FSDOs) prior to operations

– such as motion picture and

television filming, or pipeline and power line patrol

– we will contact the local FSDO and comply

with their procedures, such as filing a NOTAM as per their request.Our Flight Operations and Procedures Manual will include procedures for:

 C onducting a preflight safety risk assessment to determine that the UAS is in a condition for safe flight,

i.e. completing a preflight inspection checklist to ensure the UAS’s airworthiness. If the inspection

reveals a condition that affects the safe operation of the UAS and/or the Ground Control Station, the

aircraft will be prohibited from operating until the necessary maintenance has been performed and

the UAS is found to be in a condition for safe flight.

 M aintaining a Flight Log (noting UAS flight time, Control Unit operation time, incident reports

, etc .);

and making said Log available to the FAA if requested.

 C onducting initial and ongoing training of PICs and VOs, to include classroom training, and training,

proficiency and experience

- building flights; all persons not essential for flight operations will be

considered nonparticipants, and the PIC will operate the UAS with appropriate distance from

nonparticipants in accordance with 14 CFR 91.119.

 E valuating the operational abilities of PICs and VOs on a regular basis.

 M aintaining and repairing the aircraft to ensure that it is in a condition for safe operation by:

o F ollowing the UAS manufacturer’s maintenance, overhaul, replacement inspection, and life

limit requirements and safety bulletins for the aircraft and its components.

o I nstalling firmware updates provided by the manufacturer.

o K eeping a Maintenance Log noting all maintenance, inspection, alterations, and status of

replacement/overhaul component parts in the aircraft records, including total time in service,

description of work, and signature of the authorized person returning the UAS to service; and

making said Log available to the FAA if requested.

o V erifying condition of flight batteries and calibrating the Inertial Measurement Unit (IMU)

using manufacturer software.

o C onducting a functional test flight on any UAS that has undergone maintenance or alterations

that affect the UAS operation; said functional test flight will be conducted by a PIC with a VO

and so as to not pose an undue hazard to persons and property; and recorded in the aircraft

records.

 P rocedures that ensure that the planned operation can be completed safely, such as:

o C hecking local sectional (air) charts, NOTAM (notice to airmen), etc. prior to the flight.

o C onducting a pre

- flight visual survey of the area to consider characteristics of the area of

intended operation(s) and the associated potential hazards regarding proximity to populated

areas.

o R emaining clear and giving way to all manned aviation operations and activities at all times.

o A borting a flight and landing the UAS at the nearest and safest ground point in the event of

safety breaches, potential danger, unpredicted obstacles or emergencies.

o using a fresh, fully

- charged battery with each flight as a safety precaution, to ensure

o S afety and maintain adequate communication between radio cont r ol and the UAS; and not

operating our UAS at or below manufacturer recommend minimum charge levels for

operation.

Also:

 Flight operations will be performed only at the request of and with the authorization and permission

of clients (property owner/controller) or their authorized representatives.

 Caution signs will be placed at the site of aerial operations to warn people that aircraft operations

are in progress

 Our Client Agreements will reserve us the right to decline a photo shoot if conditions of the

location (e.g. proximity of power lines) may cause unacceptable risk; and to reschedule a photo

shoot if weather conditions such as precipitation or wind speed become a factor. The operating documents for our UAS, and any revisions, will be accessible during UAS operations and

made available to the Administrator or law enforcement official upon request.

 We carry comprehensive general liability insurance coverage and an additional insurance policy

specifically covering our UAS.



## Summary for Federal Reg i s t er

Michael and Shelly Diener of M & S Aerials LLC, Victoria, Minnesota, seek exemption from Federal Aviation

Regulations pursuant to 14 C.F.R. and Section 333 of the FAA Modernization and Reform Act of 2012 for the

purpose of commercially operating small Unmanned Aircraft Systems (UAS) safely and legally in the

National Airspace System.

Specifically, M & S Aerials se eks relief from the following sections of the current regulations:

14 CFR 21 subpart H

- Certification procedures; Airworthiness Certificates; 14 CFR 45.23

- Display of

Marks; 14 CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations; 14 CFR 91.105 Flight crewmembers

at stations; 14 CFR 91.109 (a) Flight instruction; 14 CFR 91.119 (c) Minimum safe altitudes; 14 CFR 91.121

- Altimeter settings; 14 CFR 91.151 (a)

- Fuel Requirements for Flight in VFR Conditions; 14 CFR 91.203

Carrying Civil Aircraft Certification and Registration; 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1), 14 CFR

91.409 (a) (2) Maintenance required; Operation after maintenance, preventive maintenance, rebuilding

or alteration; 14 CFR 91.417 (a)&(b) Maintenance Records; 14 CFR 91.7 (a)

- Civil Aircraft Airworthiness;

14 CFR 91.9 (b) Civil aircraft flight manual, marking, and placard requirements.

M & S Aerials intends to use small UAS to provide aerial photography and videography services to

businesses, organizations and community members. More specifically, we intend to:

 E nable businesses to benefit through the use of state

- of

- the

- art visual marketing materials

 H elp to inspect buildings and structures, and map landscapes in a safe, cost

- effective manner

 P rovide economic stimulus and public benefit by providing an effective means by which

companies or individuals can use up

- to

- date, high

- quality photos and videos to learn about

properties, neighborhoods and communities

 H elp communities realize economic benefit by encouraging public participation and

encouraging tourism; by showcasing community buildings and landscapes; and by

documenting community events in low

- cost ways not previously available to them

 I ncrease awareness/knowledge of the amenities of a local area by the general public and by

visiting tourists

 P rovide non

- profit organizations as well as schools and universities and local municipalities ways

to showcase facilities, document events, and educate the public

The enhanced safety achieved using an UAS with the specifications described herein, and carrying no

passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying cre w in

addition to flammable fuel, should give the FAA good cause to find that such exemption is in the public

interest. By granting this request for exemption, the FAA will facilitate the smooth integration of UAS into

the NAS.

## Add iti ona l I nforma ti on

Design Characteristics, Aircraft Performance and Performance Limitations, and

Conditions of UAS to be operated

All three UAS described below:

 Use 4 counter

- rotating propellers for balance, control and stability

 E quipped with GPS to maintain geospatial orientation and position

 R eturn Home safety technology and Auto Landing feature if UAS loses transmitter signal

 C ontrolled primarily through FCC approved RF spectrum transmitter/controller/receivers; and FCC

approved RF spectrum EIRP with transmitting power of 100 mW for dedicated Wi

- Fi

transmitter/receiver between sUAS, Range Extender attached to transmitter and mobile viewing

device displaying operational telemetry and video/photography functions.

 S end real time video and telemetry information is transmitted back to a ground control station,

allowing PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC,

camera imagery, and control camera angle.

 H ave failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the

onboard flight controller and maximum altitude can be preprogrammed by the PIC.

 A udible and visual sequential low battery warnings set at 30% charge and 15% charge remaining. The

sUAS automatically initiates landing sequence at 15% charge while still under PIC control. The

onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching

a low battery state. An automatic termination of flight and landing will be initiated when the battery

reaches a predetermined low state.

DJI Inspire 1

 Gross weight of less than 7 pounds including camera and battery

 Cruising speed of 15 knots with maximum speed of 42 knots and maximum altitude of 4500m

 Maximum flight time of 18 minutes

 FCC compliant Radio Frequency (RF) spectrum 5.725~5.825 GHz and 2.400~2.483 GHz

 M anual available at http://download.dji

innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

D JI Phantom 3 Professional

 Gross weight of less than 3 pounds including camera and battery

 Cruising speed of 15 knots, with a maximum speed of 31 knots and maximum altitude of 6000m

 Maximum flight time of 23 minut e s

 M anual available at http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf