UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION

 FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. ___________________

Docket Operations, M-30

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

ANNAPOLIS ASCENT, LLC

c/o NICHOLAS A. KIRALY, MANAGER

3597 FONTRON DRIVE

EDGEWATER, MARYLAND 21037

240.338.1313

ANNAPOLIS ASCENT, LLC IS SEEKING RELIEF FROM

THE REQUIREMENTS OF THE FAA REFORM ACT AND

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS
GLOSSARY OF ABBREVIATIONS

AGL- Above Ground Level

AOI- Area of Interest

ATC- Air Traffic Control

ATO- Air Traffic Organization

AV- Aerial Vehicle

CFR- Code of Federal Regulations

COA- Certificate of Authorization

FAA- Federal Aviation Administration

FAR- Federal Aviation Regulation

GCS- Ground Control Station

GPS- Global Positioning System

NAS- National Airspace System

NOTAM- Notice to Airman

PIC- Pilot In Command

Section 333- FAA Modernization and Reform Act of2012 (FMRA)

SO- Safety Observer

SOP- Standard Operating Procedures

UA- Unmanned Aircraft

UAS- Unmanned Aircraft System

sUAS- Small Unmanned Aircraft System (under 55 pounds Gross Weight)

VFR- Visual Flight Rules

VLOS- Visual Line of Site

VMC- Visual Meteorological Conditions

VTOL- Vertical Takeoff and Landing

ESC- Electronic speed control

FPV- First Person View

LI-PO- Lithium Polymer battery

RCV- Radio Controlled vehicle
Regulations from which the exemption is requested,

SECTIONS C.F.R. §§ :

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (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)

Description of Type, Make and Models of sUAV/UAS Requested: Annapolis Ascent, LLC is seeking an 

exemption to commercially operate 10 sUAVs makes and models as follows:

DJI -F450 156.

DJI -F550 157.

DJI - Inspire 1 

DJI - Matrice 100 

DJI - Phantom 2 

DJI - Phantom 3 

DJI - Spreading Wings S800 162.

DJI - Spreading Wings S900 163.

DJI - Spreading Wings S1000 164.

DJI - Spreading Wings S1000+
1. Reasons Why The DJI series of sUAV Meet The Conditions Of

The FAA Modernization and Reform Act of 2012 (FMRA) Section 333:

2. In consideration of the size, weight, speed, and limited operating area associated with

the unmanned aircraft and its operation, Annapolis Ascent, LLC’s

operation of the DJI series sUAS detailed on page 5 meet the conditions of

FMRA Section 333, and will not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to

operate without airworthiness certification and sets forth requirements for considering

whether a UAS will create a hazard to users of the NAS or the public, or otherwise

pose a threat to national security. Specifically, FMRA Section 333 states the

following, in part:

a. In General. --Notwithstanding any other requirement of this subtitle, and not

later than 180 days after the date of enactment of this Act, the Secretary of

Transportation shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of the plan

and rulemaking required by section 332 of this Act or the guidance required

by section 334 of this Act.

b. Assessment of Unmanned Aircraft Systems. --In making the determination

under subsection (a), the Secretary shall determine, at a minimum.

Which types of unmanned aircraft systems, if any, as a result of their

size, weight, speed, operational capability, proximity to airports and

populated areas, and operation within visual line of sight do not create

a hazard to users of the national airspace system or the public or pose a

threat to national security; and whether a certificate of waiver,

certificate of authorization, or airworthiness certification under section

44704 of title 49, United States Code, is required for the operation of

unmanned aircraft systems identified under paragraph (J).

c. Requirements for Safe Operation. --If the Secretary determines under this
section that certain unmanned aircraft systems may operate safely in the

national airspace system, the Secretary shall establish requirements for the

safe operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Annapolis Ascent, LLC submits that the DJI

sUAS series detailed on page 5 can operate safely in the NAS pursuant to FMRA Section

333, as demonstrated by: (a) the characteristics and capabilities of the DJI series

sUAS, (b) the pilot certification requirement and (c) the specific operating limitations.

The Specifications Of The DJI sUAS series Demonstrate Its Safe Characteristics. 

The DJI sUAS series do not create a hazard to users of the

NAS or the public, or otherwise pose a threat to national security considering its

size, weight, speed, and operational capability.

The DJI sUAS series Autonomous Flight And

Navigation Modes Enable The sUAS To Remain Within A Defined

Operational Area.

The DJI sUAS series may be operated in both manual and

fully autonomous flight modes. 

The DJI sUAS series Are Designed For Automatic

Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI UAs will

remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI

UAs do not reacquire control link data from the

GCS, the UAs will assume that the Control Link is lost and the UAs will return to

the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff

position and shutdown. A complete description of the Failsafe Functions of the

DJI UAS series are set forth on the official DJI.com/UserManuals. 
Annapolis Ascent, LLC will only utilize certificated pilots who possess a current and valid airman medical 

certificate to act as a pilot in command sUAS. Additionally, a safety observer will assist all pilots during 

flight time.

These limitations and conditions to which Annapolis Ascent, LLC agrees to be bound when

conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be

terminated at 25% battery power reserve should that occur prior to the 20 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200

feet above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer, and

the Camera Operator.

6. sUAS pilot will be an FAA licensed airman with at least a sport or recreational certificate

and a valid driver’s license. The observer will also hold a valid driver’s license.

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS

Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. the Aerial

Coordinator), that person can also be designated as PIC.

8. The sUAS will only operate within a confined “Sterile Area” as defined in the Manual.

Section C of the Manual requires the establishment of a “Security Perimeter” for the flight

operations area.

9. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s

production activities. It will be mandatory that all personnel who will be performing duties within

the boundaries of the safety perimeter be present for this briefing.

10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the

requested exemption, with the appropriate Flight Standards District Office.

11. The operator will obtain the consent of all persons involved in the filming and ensure that

only consenting persons will be allowed within 100 feet of the flight operation, and this radius
may be reduced to 30 feet based upon an equivalent level of safety determination, as required

by Section F of the Manual. With the advanced permission of the relevant FSDO, operations at

closer range can be approved. (See Section B in the Manual Appendix B)

12. The operator will submit a written Plan of Activities to the local FSDO with jurisdiction over

the area of proposed filming. The three-day notification may be waived with the concurrence of

the FSDO.

13. Pilot and observer will have been trained in operation of sUAS generally and received upto-date

information on the particular sUAS to be operated as required.

14. Observer and pilot will at all times be able to communicate by voice.

15. Written and/or oral permission from the relevant property holders will be obtained.

16. All required permissions and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

17. If the sUAS loses communications or loses its GPS signal, the sUAS will have capability to

return to a pre-determined location within the Security Perimeter and land.

18. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or

emergencies.
DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Annapolis Ascent, LLC only utilizes safe and reliable sUAS. DJI is an

industry leader in small UAS production. DJI sUAS are complete with leading edge and proven

software enabling the user to set parameters which will not allow flight into controlled airspace.

Parameters can also be set to limit flight to no higher than a predetermined and set altitude as

well as limit flight to a predetermined and set distance. In addition, DJI software provides

real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet

devices)

DJI Inspire 1

1.1 Aircraft

1.1.1 Model -T600

1.1.2 Weight (Battery Included) -6 lbs 7.52910z (2,935g)

1.1.3 Hovering Accuracy (GPS Mode) -Vertical: 0.5m; Horizontal: 2.5m

1.1.4 Max Angular Velocity: Pitch: 300°/s; Yaw: 150°/s

1.1.5 Max Tilt Angle: 35°

1.1.6 Max Ascent Speed: 5m/s

1.1.7 Max Descent Speed: 4m/s

1.1.8 Max Speed: 22m/s (ATTI mode, no wind-NOT RECOMMENDED)

1.1.9 Max Flight Altitude 4,500m MSL

1.1.10 Max Wind Resistance: 10m/s

1.1.11 Max Flight Time -Approximately 18 minutes

1.1.12 Motor Model: DJI 3510

1.1.13 Propeller Model: DJI 1345

1.1.14 Operating Temperature Range: 14°F to 104°F (-10°C to 40°C)

1.1.15 Dimensions 438x451x201 mm 17.25” x 17.76" x 7.9"

1.2 Gimbal

1.2.1 Model: ZENMUSE X3

1.2.2 Output Power (with camera): Static: 9W; In Motion: 11 W

1.2.3 Operating Current -Static: 750mA; In Motion: 900mA
1.2.4 Angular Vibration Range -±0.03 °

1.2.5 Mounting -Detachable

1.2.6 Controllable Range: Pitch: -90°to +30°; Pan: ±320°

1.2.7 Mechanical Range: Pitch: -125°to +45°; Pan: ±330°

1.2.8 Max Controllable Speed: Pitch: 120°/s; Pan: 180°/s

1.3 Transmitter

1.3.1 Name-CI

1.3.2 Operating Frequency 5.728 to 5.850 GHz; 2.400-2.483GHz

1.3.3 Communicating Distance (unobstructed): 3.1 miles

1.3.4 Output Power -9W

1.3.5 Operating Temperature Range -14°F to 104°F (-10°C to 40°C)

1.3.6 Battery 4,500mAh 2S or optional 5,700mAh LiPo 2S

All specifications can be found in the attached user manual or at

https://dl.djicdn.com/downloads/inspire_1/en/Inspire%20_1_User_Manual__V1.8.pdf