Armstrong, Flinders & Associates Realtors PLLC 

995 E Center 

Pleasant Grove, UT 

84062 

drew@utahrealestate.net 

December 8, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room Wl2Al40 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

ZDll J/Jl ILJ p 3: 5 Ll 

Re: Request for exemption under Section 333 from 14 CFR Part 21, Subpart H; 14 CFR 

6.1.113 (a) and (b); 14 CFR 61.23(a); 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 

91.15l(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(l); 14 CFR 91.409(a)(l) and (2); 14 CFR 

91.417 (a) and (b); 14 CFR 91.7(a) and (b) 

Dear Sir or Madam: 

In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 (the 

Reform Act) and 14 CFR Part 11, Armstrong, Flinders & Associates Realtors PLLC hereby 

applies for an exemption from the listed Federal Aviation Regulations (F ARs) to allow 

commercial use of its Small Unmanned Aircraft Systems (SUASs), so long as such operations 

are conducted within and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333. 

An exemption is being requested because (1) existing regulations will burden Armstrong, 

Flinders & Associates Realtors PLLC (2) Armstrong, Flinders & Associates Realtors PLLC can 

provide a level of safety that is equal to (or greater than) those provided by existing rules, and (3) 

the request is in the public interest. The FAA's authority to issue exemptions from operating 

rules, and the Secretary's authority granted by Section 333 ofP.L. 112A95, Special Rules for 

Certain Unmanned Aircraft Systems, provide an opportunity to authorize certain SUAS 

operations in the National Airspace System (NAS) prior to implementation of the SUAS rule. 

This incremental step will allow Armstrong, Flinders & Associates Realtors PLLC to safely and 

legally enter into the NAS. 
As described in detail below, the requested exemption would permit Armstrong, Flinders & 

Associates Realtors PLLC to operate SUASs under controlled conditions in airspace that is (I) 

limited (2) predetermined (3) controlled as to access, and (4) would provide safety enhancements 

to the already safe operations of those aircraft of similar size, weight, speed, and operating 

capability that have been granted entry into the NAS via the rules in Academy of Model 

Aeronautics (AMA) National Aircraft Safety Code. 

1 

Approval of this exemption would thereby 

greatly enhance safety and fulfill the Secretary of Transportation's (the Secretary) responsibilities 

to " ... establish requirements for the safe operation of such aircraft systems in the national 

airspace system" per Section 333 (c) of the Reform Act. 

Armstrong, Flinders & Associates Realtors PLLC is requesting exemption from the following 

regulations: 

14 CFR Part 21, Subpart H 

14 CFR 61.23 (a) 

14 CFR 61.113 (a) and (b) 

14 CFR 91.109 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a)(l) 

14 CFR 91.409 (a)(l) 

14 CFR 91.409 (a)(2) 

14 CFR 91.417 (a) and (b) 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 

333 (a) through (c) of the Reform Act. This law directs the Secretary to consider whether certain 

unmanned aircraft systems may operate safely in the NAS before completion of the rulemaking 

required under Section 332 of the Reform Act. In making this determination, the Secretary is 

required to determine which types ofUASs do not create a hazard to users of the NAS, to the 

public, or pose a threat to national security. 

Section 333 of the Reform Act grants the Secretary authority to determine (I) if an unmanned 

aircraft system, as a result of its size, weight, speed, operational capability, proximity to 

airports and populated areas, and operation within visual line of sight (VLOS) does not create 

a hazard to users of the NAS or the public or pose a threat to national security, and (2) whether 

a certificate of waiver, certificate of authorization, or airworthiness certification under 49 USC 

1 See Attached Academy of Model Aeronautics (AMA) National Aircraft Safety Code 
44704 is required for the operation of civil (non-governmental) UASs. Therefore, if the 

Secretary determines that such vehicles "may operate safely in the national airspace system, 

the Secretary shall establish requirements for the safe operation of such aircraft in the national . 2 airspace system". 

Overview of the petitioner 

Matthew Paul Flinders and John Andrew Armstrong are the sole members and manager of 

Armstrong, Flinders & Associates Realtors PLLC. Mr. Flinders and Mr. Armstrong are licensed 

real estate agents in the state ofUtah and are members of the National Association ofRealtors 

(NAR), the Utah Association of Realtors (UAR), the Utah Central Association of Realtors 

(UCAOR), the Realtors Land Institute (RLI). Mr. Flinders and Mr. Armstrong serve on various 

committees within several of these organizations including as the Tech Committee Chairperson 

for the Utah County Association of Realtors and is actively involved in all of them. Mr. 

Armstrong is the Chairperson of the Pleasant Grove City Planning Commission. 

Mr. Flinders obtained his sport private pilot and has logged over 50 hours of flight time as a 

civilian pilot beginning at age 16. Mr. Flinders and Mr. Armstrong have been flying remotely 

piloted aircraft for several years including the products manufactured and sold by Dn referenced 

herein. 

Overview of the request for exemption 

In an effort to reduce the time burden for this request and in hopes of streamlining the exemption 

process, Armstrong, Flinders & Associates Realtors PLLC has reviewed numerous requests and 

grants of exemption under Section 333. Armstrong, Flinders & Associates Realtors PLLC has 

used much of the language of these documents to create this request- especially, 1.) where the 

grants note that the petitioner neglected to address an important item, 2.) where relief was not 

necessary, and 3.) where relief was not granted. By synthesizing all of these elements, 

Armstrong, Flinders & Associates Realtors PLLC has attempted to craft an exemption request 

that will address every concern and meet every guideline and mandate previously set forth. This 

exemption should be granted on the basis of the precedent set by the FAA in granting similar 

Section 333 petitions, as well as on its own merit with regard to safety and intended operations. 

Operation Overview 

Armstrong, Flinders & Associates Realtors PLLC 's SUASs are quadcopters, manufactured by 

Dn and weighing 10 or fewer lbs. (including payload). The SUASs have the capability to hover 

and move in the vertical and horizontal planes simultaneously. They will operate only in visual 

line of sight (VLOS) and will operate only in controlled and limited airspace. They are capable of 

operating at speeds of up to 47lmots, but will be routinely operated at much lower speeds. They 

will routinely be operated below 200 feet AGL, and never above 400 feet AGL though is should 

be noted that they do have the capability to go higher which may be necessary (while flying 

within 400 feet AGL) as Utah's terrain is mountainous and rugged. Armstrong, Flinders & 

Associates Realtors PLLC 's exemption request would permit its commercial operation of SUAS 

2 See Attached Section 333 (c) of the Reform Act 
for aerial photography and videography in controlled and limited airspace. Aerial photography 

and videography services will be offered to homeowners, Realtors®, community event 

organizers, high school and other sporting teams and coaches, planning departments of local 

cities, resorts, home builders, home contractors, and/or home inspectors for use in, but not limited 

to, promotional videos, real estate marketing for agricultural, residential and commercial property, 

and inspections ofbuilding exteriors and shooting movies on closed sets. We will also be training 

EMS personnel and gathering news. All operations will be conducted with the written and/or oral 

permission of the property owner(s) or his/her agent(s) or on publically owned land with 

permission of those who are authorized to grant that permission. 

Operations will always be conducted in such a manner as to minimize hazards to persons or 

property on the ground. Such operations will ensure that the SUAS will "not create a hazard to 

users of the national airspace system or the public".

3 

Aircraft 

Armstrong, Flinders & Associates Realtors PLLC operates the Phantom 3 Professional 4 and 

the Inspire

5 

SUASs manufactured by DJI, a well known leader in quadcopter technology. They 

anticipate as time goes on that newer models of these same systems from DJI will be produced 

and anticipate that they will replace and upgrade equipment and aircraft to newer models as 

time goes on (that will at minimum carry the existing teclmology forward such as GPS Locks, 

Return To Home Capability, Battery Monitoring and failsafes etc.) 

DJI strives to bring new perspectives to aerial work and help companies accomplish operations 

safer, faster, and with greater efficiency. 

DJI has an unparalleled commitment to R&D, a culture of constant innovation, and a focus on 

transforming complex technology into safe and easy-to-use devices. 

The standard DJI quadcopter package includes the SUAS craft itself, camera, gimbal, propulsion 

system, flight control system, 5.8 GHz remote controller, and 2.4 GHz Wi-Fi communication 

system. The remote uses a 5.8 GHz frequency to prevent interference with the video/telemetry 

channel. This second channel allows for a constant connection with the DJI SUAS to monitor it 

via a smartphone or tablet that is attached to the remote controller. The DHI SUASes are about 1 

foot square in size. The larger units may be up to 24 inches per side. They have a maximum 

ascent speed of 21 knots, a maximum descent speed of 7. 7 knots, and a maximum flight speed of 

42 knots. (for the Inspire! which is the fastest of the DJI fleet at this time) While operating 

within VLOS, the remote control has a range of 6,000 feet. The total weight (including the 

payload) is at most 6.7 pounds. 

3 Sec attached Rcfonn Act Section 333 (b) 

4 http://www.dji.com/product/phantom·3·pro 

5 http://www.dji.com/products/inspircl 
The DJI SUASes are equipped with advanced flight control systems. This provides for 

incredible ease of use and stability. Pilots can control the DJI SUAS's movements in many 

directions- including pitch (forward and backward), roll (left and right), elevator (up and 

down), and yaw (tum left or right). The flight control system can also provide Intelligent 

Orientation Control (IOC), failsafe, battery level warnings, and show the aircraft's current 

heading, direction, and approximate distance from home on the on-screen "radar." The built- in 

GPS system aids in stabilizing the aircraft and automatically and safely returns it back to its 

home point in the event that communication between the remote control and quadcopter are lost. 

The Inertial Measurement Unit (IMU) has a built-in inertial sensor and a barometric altimeter 

that measures both attitude (A TTl) and altitude. The inertial measurement tells the DJI SUAS 

how it's tilted. And the gyros tell it if it's rotating in any particular direction. 

Vision Positioning technology uses a specially designed camera as well as sonic waves to 

bring simplicity to flying indoors. This technology allows the Inspire and Phantom 3 UASs to 

hold their positions, stop when the controls are released, and respond to commands even when 

GPS is unavailable. 

The DJI SUAS's compass reads geomagnetic information and assist the Global Positioning 

System (GPS) to accurately calculate the position and height of the aircraft. The vertical 

hover accuracy is +/A 2.6 ft. The horizontal hover accuracy is +/A 8.2 ft. 

The DJI SUASes have LED flight indicators beneath each of its four rotor arms or at the end of 

the rotor booms. The LEDs illuminate to indicate the status of the flight control system and alert 

the PIC of any possible issues. They show the operator which end of the craft is the front and 

which end is the rear. 

Such highly advanced capabilities will ensure that the SUASs can be safely operated and "not 

create a hazard to users of the national airspace system or the public.'>6 7 

Equivalent Level of Safety 

In an effort to join the FAA in its mission to provide the safest, most efficient airspace system in 

the world and to minimize the risk to the NAS or to persons and property on the ground, 

Armstrong, Flinders & Associates Realtors PLLC agrees to be bound by the following limitations 

and conditions when conducting commercial operations under an FAA issued exemption: 

A. For the purposes of ensuring SUASs will be operated within the standards that the 

FAA has allowed in the AMA National Model Aircraft Safety Code: 

6 http://www.dji.com/product/phantom·3·pro/info#spccs 

7 https://www .dji.com/product/inspirc·l/info#spccs 
1. SUASs will not be flown: 

a. In a careless or reckless manner. 

b. At a location where SUAS activities are prohibited. 

2. SUAS pilots will: 

a. Yield the right of way to all human carrying aircraft. 

b. See and avoid all aircraft and a spotter must be used when appropriate. 8 

c. Not fly higher than 400 feet above ground level or within three (3) miles 

of an airport without notifying the airport operator. 

d. Not interfere with operations and traffic patterns at any airport, heliport 

or seaplane base except where there is a mixed use agreement. 

e. Not exceed a takeoff weight of 55 pounds (including payload). 

f. Ensure the aircraft is identified by affixing the owner's contact 

information to the outside of the SUAS. 

g. Not operate SUASs while under the influence of alcohol or while using 

any drug that could adversely affect the PIC's ability to safely control the 

aircraft. 

h. Not operate SUASs carrying pyrotechnic devices that explode or bum, or any 

device which propels a projectile or drops any object that creates a hazard to persons 

or property. 

3. SUASs will not be flown unless: 

a. The aircraft, control system and pilot skills have successfully demonstrated all 

maneuvers intended or anticipated prior to the specific event. 

b. An inexperienced pilot is assisted by an experienced pilot. 

8 AMA Document #540A through D 

http://www.modclaircraft.org/documcnts.aspx 
4. All pilots shall, to the max extent practical, avoid flying directly over 

unprotected people, vessels, vehicles or structures and shall avoid 

endangerment of life and property of others. 

5. A successful radio equipment ground-range check in accordance with 

manufacturer's recommendations will be completed before the first flight of a new 

or repaired model aircraft. 

6. SUASs must use the radio control frequencies currently allowed by the Federal 

Communications Commission (FCC). 

7. SUASs will not knowingly operate within three (3) miles of any pre-existing flying 

site without a frequency management agreement. 

9 

8. Excluding takeoff and landing, no SUASs may be flown outdoors closer than 25 feet 

to any individual, except for the PIC and the PIC's helper(s) located at the takeoff 

site. 

9. Under no circumstances may a pilot or other person interfere with a SUAS in 

flight while it is still under power, except to divert it from striking an individual. 

10. The PIC of the SUAS shall: 

a. Maintain control during the entire flight, maintaining visual contact without 

enhancement other than by corrective lenses prescribed for the pilot. 

b. Fly using the assistance of a camera or First Person View (FPV) only in 

accordance with the procedures outlined in AMA Document #550. 

c. Fly using the assistance of autopilot or stabilization system only in 

accordance with the procedures outlined in AMA Document #560. 

11. The flying area must be clear of all utility wires or poles and an SUA V will not be 

flown closer than 50 feet to any above ground electric utility lines. 

12. The flying area must be clear before the engine is started, except for PIC and the 

9 AMA Document #540A through D & 922-923 

http://www.modclaircraft.org/documents.aspx 
PIC's helper(s). 

B. In addition to the above rules outlined by the AMA National Model Aircraft Safety Code 

and in an effort to enhance the safety offered by the already safe operations mentioned 

above, Armstrong, Flinders & Associates Realtors PLLC also agrees to be bound by the 

following limitations and conditions: 

1. Flights will be operated within the VLOS ability of the PIC. 

2. Maximum total flight time for each operational flig4t will be 25 minutes. Flights 

will be terminated at 25% battery power reserve should that occur prior to the 25 

minute limit. 

3. The SUAS will only operate in controlled and limited airspace .. 

4. A briefing will be conducted in regard to the planned SUAS operations prior to each 

flight operation. It will be mandatory that all personnel who will be performing duties 

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

5. The PIC and the PIC's helper(s) will have been trained in operation ofSUAS and 

received up-to-date information on the particular SUAS to be operated. 

6. The PIC and the PIC's helper(s) will at all times be able to communicate by 

VOICe. 

7. If the SUAS loses communications or loses its GPS signal, the SUAS will have 

capability to return to a predetermined location within the security perimeter and 

safely land. 

8. The SUAS will have the capability to abort a flight in case ofunpredicted 

obstacles or emergencies. 

9. Flights will only be conducted on property for which the written and/or oral 

permission of the property owner( s) or his/her agents( s) has been granted or is held 

by the public and permission from those who manage the property has been obtained. 

10. Flights will always be conducted in areas that are clear of all people, except for 

the PIC and the PIC's helper(s) and or any persons under contract as employees or 

contracted individuals on a closed set. 

11. All flights will be conducted in daytime visual meteorological conditions (VMC) 
only and never during severe weather conditions. 

12. Flights will not occur in weather conditions that prevent the PIC from operating 

within visual line-of-sight (VLOS) at all times or in weather conditions that 

dramatically affect the UAS 's flight (e.g. high winds or rain). 

13. If an operation occurs in an area where people could inadvertently enter the area, an 

operational border will be established. The PIC's helper(s) will be responsible for 

keeping a safe perimeter around the operation. The operation will cease 

immediately and be rescheduled if it's impossible to establish a safe perimeter 

around the operation. The PIC and the PIC's helper will use traffic cones and 

caution tape to establish a safe perimeter in order to keep people from entering the 

operational border if necessary to keep the operation safe. 

14. The PIC will be responsible for logging all flights to ensure the comprehensive 

preventative maintenance plan can be followed, as described in the "Preventative 

Maintenance" section below. 

15. The SUAS will not be routinely operated in the proximity of any airports. In any 

cases where the SUAS must be operated within three (3) miles of an airport, the 

airport operator will be notified before the operation commences. 

The operation of SUASs, weighing less than 10 lbs., conducted in the strict conditions as 

outlined above, will provide an equivalent level of safety supporting the grant of exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 and 

allowing commercial operations. 

These lightweight aircraft operate at slow speeds, close to the ground, and in a small, 

controlled environment. As a result, they offer a much safer way to capture aerial 

photography and videography. Furthermore, the proposed operations represent a safety 

enhancement to the already safe operations that have been granted by the FAA for the 

establishment of the AMA National Model Aircraft Safety Code. 

Preflight Action Plan 

The PIC will follow a comprehensive pre-flight checklist to ensure that the SUAS is in a 

condition for safe flight. This plan will be improved as needed in order to ensure all known 

safety precautions and/or safety precautions suggested by the manufacturer are being 

accounted for. 

A. Pre-flight Inspection 
1. Check that the remote control, UAV's battery, range extender, and 

smartphone are all fully charged. 

2. Verify that the UAV's battery is not swollen or damaged in any way. Clean 

the contact needles and pads if necessary. 

3. Tum the motor shafts with your fingers and verify they are smooth without 

excessive play or binding. 

4. Verify that the propellers are mounted correctly. Propellers with a black top 

should be mounted on the mount shafts that have a black dot. Propellers with a 

silver top should be mounted on the mount shafts that have a silver dot. Each 

propeller should spin all the way down onto the motor shaft. Prop Locks will be 

used if suggested by the manufacturer. 

5. Run finger along the edge of edge blade to check for any rough edges. 

6. Flex both side of the propellers' blades to check for hairline cracks where the 

blades connect in the center of the propeller. 

7. Verify that the landing gear is secure (not cracked/broken/loose). 

8. Verify that the compass and compass cable are firmly attached to the 

landing gear. 

9. Verify that the Micro SD card has been inserted and formatted. 

10. Verify that the damping absorbers are not broken and/or worn. 

11. Verify that the anti drop pins are in place and locked. 

12. Remove the Gimbal guard and camera lens cap. 

13. Verify that the camera is secure and clean. Inspect the camera ribbon cables 

for tears and/or signs of wear. 

14. Verify that the UAV's GPS is enabled and is able to establish at least a 11 satellite 

lock if operation is outdoors. Or that the ultrasonic positioning system is operational 

for operation in a large enclosed building such as a commercial warehouse or an 

enclosed soundstage or set. 
15. Set the smartphone to do-not-disturb mode to prevent distractions while 

flying. 

16. Set the smartphone or tablet to airplane mode to prevent the Wi-Fi connection or 

Data from connecting mid-flight. 

17. Verify that the smartphone' s audio is ori to ensure the low battery warning 

and other alarms can be heard. 

B. Power Up 

1. VerifY that S1 and S2 are in the top position on the remote control. 

2. Power on the equipment in the following sequential order: 

a. Range Extender (if in use: "System" is blinking green; "Power" is solid 

green) 

b. Remote Control (2 beeps to indicate it's in ATA mode) 

c. Insert and start the UA V's battery. 

3. Watch the UAV's LED startup sequence for abnormal indications. The rear LEDs 

should blink green for at least 10-15 seconds to indicate that it locked onto 11 + satellites 

and has marked the home point (for use by the failsafe feature). 

4. Calibrate the UAV's compass. 

5. Place the UAV on an open, flat ground with the battery indicators facing towards 

the PIC at least 10 feet away. 

C. Dll GO Application 

1. Connect the smartphone Wi-Fi to the range extender if so equipped. 

2. Launch the "Dll GO" application on the smartphone. 

a. Verify that the Wi-Fi and Lightbridge connections are working and the home 

point has been established. 

b. Verify the number of satellites is 11 +. 
c. Verify the WiFi and Lightbridge signal strengths. 

d. Verify that the UAV, Remote Control, Tablet computer and range extenders 

(if in use) batteries are reporting a full charge. 

e. Verify that both the PIC's and UAV's location is the same before 

taking off to ensure the home point has been accurately marked. 

f. Verify the location of the UAV in the "Flight Radar". If it's not in the 

correct position/direction and/or shows a distance of"N/A", it did not 

mark the home point. 

g. Use the "Find my UAV" feature to ensure the blue (home point location) 

and red (UA V location) dots are in the same location on the screen. 

d. Ready to Fly 

1. Verify that the remote control antennas are perpendicular to the ground 

(pointing skyward). 

2. Verify that the front, flat face of the range extender (if in use) is pointed toward 

theUAV. 

3. Verify that the rear LEDs are still slowly blinking green and still connected to 

11 + satellites. 

4. Start the UAV's motors using the Take Off command on the remote control/tablet. 

5. Verify that the motors are functioning normally, are not making any unusual 

noises, and are all spinning at the same spe~d. 

6. Verify that the area is still clear of obstructions, people, power lines, etc. 

7. Take off and hover at about 6-8 feet above the takeoffpoint to verify that the UAV 

has a solid GPS lock. If any abnormalities are noticed (drifting, flying in circles, 

etc.), land immediately and repeat the "Pre-flight Inspection/Calibration" and 

"Power Up" sequences. 

8. Verify that the UAV holds a steady position while yawing 360 degrees. 

9. Verify that the UAV's responds appropriately to all controls yaw 
left/right, pitch forward/backward, roll left/right, and throttle up/down. 

Preventative Maintenance 

A comprehensive preventative maintenance plan will be followed in order to ensure the 

SUAS's software is up-to-date, the batteries are in good health, and the aircraft itself is 

always ready for safe flight

10

. 

Pilot in Command (PIC) Qualifications 

All PICs for Armstrong, Flinders & Associates Realtors PLLC will hold, at a minimum, a sport 

pilot license and a Driver's License. Although the SUAS is similar in size, weight, speed, and 

operating capability as those currently allowed to be flown for hobby/recreation, holding the PIC 

to the same certification standards as for manned flight will provide an equivalent level of 

safety. Since there are currently no established standards for either private or commercial SUAS 

pilot certificates, requiring a private pilot certificate and a third-class medical will ensure 

knowledge of airspace regulations and hazards to flight. Additionally, in order to ensure that 

PICs for Armstrong, Flinders & Associates Realtors PLLC possess the necessary familiarity and 

experience with the SUASs to be flown, we propose that our PICs be required to complete the 

following prior to the first commercial operation: 

E. Perform 30 flights or log 15 hours of flight time (the greater of the two) with the DJI 

UA V to be used. 

F. Successfully learn and demonstrate all flight maneuvers in the "Phantom Pilot 

Training Guide". 11 

G. Study and be familiar with all sections of the user's manual for each UA V 12fuat is used in. 

a commercial manner. 13 

Public Interest 

Granting this exemption would benefit the public as a whole. SUASs offer a strong equivalent 

level of safety, a reduction in environmental impacts, and are free from the harmful emissions 

associated with the manned aircraft that are currently used for aerial photography and 

videography. Due to the size of the SUAS and the controlled and limited airspace in which the 

SUASs will operate, approval of this application presents no risk to the public. Furthermore, the 

public will be able to legally acquire aerial photography and videography to use in, but not 

limited to, advertising homes for sale, advertising uninhabited home lots, use of photos and 

video as an aid when researching homes for sale on the market, or safely accessing high and/or 

awkward areas of a home's exterior to assess damage that needs to be repaired. Allowing 

friends and family members to see athlete and student athlete competitions. Allowing cities to 

10 See tile Attached "Preventative Maintenance" document 

11 See attached "Phantom Training Guide" 

n See attached "Phantom 3 User Manual" 0 See attached "Inspire I" User Manual 
retain and attract commercial business and to document new building projects within the city. 

Documenting traffic patterns. And filming closed set motion pictures or television footage 

where the photography angles would otherwise not be obtainable. 

National Security 

By requiring its PICs to hold a private pilot license, Armstrong, Flinders & Associates Realtors 

PLLC can ensure that national security concerns are addressed and mitigated. Pilots holding an 

FAA issued private or commercial pilot certificate are subject to security screening by the 

Department of Homeland Security. As previously determined by the Secretary, the requirement 

to have an airman certificate ameliorates security concerns over civil SUAS operations 

conducted in accordance with Section 333. 

Requested Exemptions 

Armstrong, Flinders & Associates Realtors PLLC requests exemption from the following 

regulations: 

Airworthiness Certificates 

14 CFR Part 21, Subpart H 

Subpart H establishes the procedural requirements for the issuance of airworthiness 

certificates as required by FAR 91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by Armstrong, Flinders & Associates Realtors 

PLLC, an exemption from Part 21 Subpart H meets the requirements of an equivalent 

level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation 

Act (49 USC 44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration 

of the size, weight, speed, operational capability, and proximity to airports and populated 

areas of the particular SUAS. In all cases, an analysis of these criteria demonstrates that 

the SUAS operated without an airworthiness certificate, in the restricted environment and 

under the conditions proposed, will be at least as safe, or safer, than a conventional 

aircraft operating with an airworthiness certificate without the restrictions and conditions 

proposed. 

Private pilot privileges and limitations: Pilot in command 

14 CFR 61.113 (a) and (b) 

These regulations limit private pilots to non-commercial operations. Because the SUAS 

will not carry a pilot or passengers; due to the SUAS's size, weight, speed, and 

operational capabilities; and since operations will occur in controlled and limited 

airspace, the proposed operations can achieve the equivalent level of safety of current 

operations that currently require a commercial pilot's license simply with the possession 

of a private pilot license. Furthermore, since there are no standards for 
0 

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permission and the PIC makes a suitable safety assessment of the risk of operating closer 

to those objects. The operator or visual observer must ensure that non-participating 

persons remain under appropriate protection at all times. 

Altimeter settings 

14 CFR 91.121 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set " ... to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the SUAS itself it may not 

have a barometric altimeter the ipad used as part of the control system will, additionally a 

GPS altitude read out can be used to establish altitude. An equivalent level of safety will 

be achieved by the operator by confirming the altitude of the launch site shown on the 

GPS altitude indicator before flight and by frequently referencing the AGL altitude 

readout on the screen via the telemetry link onboard the SUAS. 

Fuel Requirements for Flight in VFR Conditions 

14 CFR 91.151 (a) 

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 nonnal 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." 

The battery powering the SUAS provides approximately 25 minutes of powered flight. 

That would make it impossible to meet the 30 minute reserve requirement. Given the 

limitations on the SUAS's proposed flight area and the location of its proposed 

operations within a predetermined area, the reserve requirements are not appropriate for 

these aircraft being used in these applications. 

An equivalent level of safety can be achieved by limiting flights to 25 minutes or 25% of 

battery power (whichever occurs first). This restriction would be more than adequate to 

return the SUAS to its planned landing zone from anywhere in its limited operating area. 

Additionally, both SUAS proposed herein provide low battery warnings at 30% capacity 

that indicate the PIC must effect the SUAS 's return to the launch point. The UAS also 

provides critical low battery warnings at 10% battery capacity indicating that the UA will 

begin to descend and land automatically. Finally, similar relief from 14 CFR 91.151 (a) 

was granted in Exemption Nos. 8811, 10808, and 

10673 for daytime VFR conditions. 

Maintenance Inspections 

14 CFR 91.405(a); 14 CFR 91.407(a)(l); 14 CFR 91.409(a)(l); 14 CFR 91.409(a)(2); 
14 CFR 91.417(a) and (b) 

These regulations require that an aircraft operator or owner "shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in Part 43 of this chapter. .. ," and others shall inspect or maintain the aircraft 

in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply. Maintenance will be accomplished by the 

operator pursuant to the aforementioned Dll user manual and guide. An equivalent 

level of safety will be achieved because these small SUASs are very limited in size, 

will carry a small payload, and operate only in restricted areas for limited periods of 

time. If mechanical issues arise, the SUAS can land immediately and will be operating 

from no higher than 400 feet AGL. As outlined in the aforementioned Pre-flight Action 

Plan, the operator will ensure that the SUAS is in working order prior to initiating 

flight and perform maintenance as required. Moreover, the operator is the person most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. 

Civil Aircraft Airworthiness 

14 CFR 91.7(a) and (b) 

These regulations require that an "no person may operate a civil aircraft unless it is in an 

airworthy condition" and "the pilot in command of a civil aircraft is responsible for 

detennining whether that aircraft is in condition for safe flight. The pilot in command 

shall discontinue the flight when unairworthy mechanical, electrical, or structural 

conditions occur." 

Even though these aircraft will not require airworthiness certificates, the PIC of the 

SUASs will still be responsible for determining if they are in an airworthy condition prior 

to flight. An equivalent level of safety can be achieved by adherence to the operating 

documents contained herein in order to determine if the aircraft is in an airworthy 

condition in accordance with 91.7(a). Also, compliance with 91.7(b) can be accomplished 

in the same manner that any private pilot (as required herein) would comply if the 

aircraft in question did have an airworthiness certificate. 

In accordance with 14 CFR Part 11, the following summary is provided for publication in the 

Federal Register: 

The applicant seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 

14 CFR 61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; (a); 14 

CFR 91.405 (a); 14 CFR 91.407 (a)(l); 14 CFR 91.409 (a)(l); 14 CFR 91.409 (a)(2); 14 

CFR 91.417 (a) and (b) to commercially operate small unmanned aircraft systems (55 
lbs. or less) in order to safely and legally capture aerial photography and videography for 

homeowners, film makers, Realtors®, community event organizers, home builders, 

home contractors, coaches, city officials, and/or home inspectors for use in, but not 

limited to, promotional videos, real estate marketing for agricultural, residential and 

·commercial property, and inspections of building exteriors. 

The operation of SUASs conducted in the strict conditions outlined above, will provide an 

equivalent and/ or greater level of safety supporting the grant of the exemptions requested 

herein, including exempting the applicant from the requirements of Part 21 and allowing 

commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, 

and in a sterile environment, and as a result, are far safer than existing operations conducted 

with helicopters operating in close proximity to the ground, people, or other buildings in the 

vicinity. 

Given the small size of the SUASs involved, the slow speed at which they must be operated in 

order to capture photos and videos, and the restricted environment within which they will 

operate, Armstrong, Flinders & Associates Realtors PLLC demonstrates that its SUASs can be 

operated with an equivalent level of safety in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of SUASs to commence immediately. Also, due to the 

requirement that PICs hold at least a sport pilot license and a driver's license until further 

regulation is developed by the FAA which specifically addresses UA V piloting certification by 

the FAA, approval of this application presents no threat to national security. Given the clear 

direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, 

the strong equivalent level of safety surrounding the proposed operations, the significant public 

benefit- including enhanced safety, reduction in environmental impacts, no emissions, ability to 

legally obtain aerial photography and videography services- the grant of the requested 

exemptions is in the public interest. Accordingly, Armstrong, Flinders & Associates Realtors 

PLLC respectfully requests that the FAA grant the requested exemption without delay. 
Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, speed, 

operating capability, proximity to airports and populated areas, operation within visual line of sight, 

public safety, and national security provide more than adequate justification to grant Armstrong, 

Flinders & Associates Realtors PLLC the requested exemption, allowing for commercial operations 

as described herewith. 

Sincerely, 

Realtors 

ff;~~ PLLC 
.· #2 &#J H.R.658-62 

(e) USE OF DESIGNEES.-The Administrator may use designees 

to carry out subsection (a) to the extent practicable in order to 

minimize the burdens on pilots. 

(D REPORT TO CONGRESS.-

(1) IN GENERAL.-'-Not later than 1 year after the date 

of enactment of this Act, and annually thereafter, the Administrator shall submit to the Committee on Transportation and 

Infrastructure of the House of Representatives and the Committee on Commerce, Science, and Transportation of the Senate 

a report on the issuance of improved pilot licenses under this 

section. 

(2) EXPIRATION.-The Administrator shall not be required 

to submit annual reports under this subsection after the date_ 

on which the Administrator has issued improved pilot licenses 

under this section to all pilots. 

Subtitle B-· Unmann:ed Aircraft Systems 

SEC. 331. DEFINITIONS. 

In this subtitle, the following definitions apply: 

(1) ARCTIC.-The term "Arctic" means the United States 

zone of the Chukchi Sea; Beaufort Sea, and Bering Sea north 

of the Aleutian chain. 

(2) CERTIFICATE OF WAIVER; CERTIFICATE OF AUTHORIZATION.-The terms "certificate of waiver" and "certificate of 

authorization" mean a Federal Aviation Administration grant 

of approval for a specific flight operation. 

(3) PERMANENT AREAS.-The term "permanent areas" 

means areas OQ land .or water that provide for launch, recovery, 

and operation of small unmanned aircraft. · 

(4) PUBLIC UNMANNED AIRCRAFT SYSTEM.-The term "public 

unmanned aircraft system" means an unmanned aircraft 

system that meets the qualifications and conditions required 

for operation of a public aircraft (as defined in section 40102 

of title 49, United States Code). 

(5) SENSE AND AVOID CAPABILITY.-The term "sense and 

avoid capability" means_ the capability of an unmanned aircraft 

to remain a safe distance from and to avoid collisions with 

other airborne aircraft. 

(6) SMALL UNMANNED AIRCRAFT.-The term "small 

unmanned aircraft" means an unmanned aircraft weighing less 

than 55 ,pounds. 

(7) TEST RANGE.-The term "test range" means a defined 

geographic area where research and development are conducted. 

(8) UNMANNED AIRCRAFT.-The term "unmanned aircraft" 

means an aircraft that is operated without the possibility of 

direct human intervention from within or on the aircraft. 

(9) UNMANNED AIRCRAFT SYSTEM.-The term "unmanned 

aircraft system" means an 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. 
H.R.658-63 

SEC. 332. INTEGRATION OF CIVIL UNMANNED AIRCRAFT SYSTEMS 

INTO NATIONAL AIRSPACE SYSTEM. 

(a) REQUIRED PLANNING FOR INTEGRATION.-

(1) COMPREHENSIVE PLAN.-Not later than 270 days after . the date of enactment of this Act, the Secretary of Transportation, in consultation with representatives of the aviation 

industry, Federal agencies that employ unmanned aircraft systems technology in the national airspace system, and the 

.unmanned aircraft systems industry, shall develop a comprehensive plan to safely accelerate the integration of civil 

unmanned aircraft systems into the national airspace system. 

(2) CONTENTS OF PLAN.-The plan required under paragraph (1) shall contain, at a minimum, recommendations or 

projections on-

(A) the rulemaking to be conducted under subsection 

(b), with specific recommendations on how the rulemaking 

will-· 

(i) define the acceptable standards for operation 

and certification of civil unmanned aircraft systems; 

(ii) ensure that any civil unmanned aircraft system 

include.s a sense and avoid capability; and 

(iii) establish standards and requirements for the 

operator and pilot of a civil unmanned aircraft system, 

including standards and requirements for registration 

and licensing; 

(B) the best methods to enhance the technologies and 

subsystems necessary to achieve the safe and routine operation of civil unmanned aircraft systems in the national 

airspace system; 

(C) a phased-in approach to the integration of civil 

unmanned aircraft systems into the national airspace 

system; 

· (D) a timeline for the phased-in approach described 

under subparagraph (C); 

(E) creation of a safe 

(F) airspace designation for cooperative manned and 

unmanned flight operations in the national airspace 

system; 

(G) establishment of a process to develop certification, 

flight standards, and air traffic requirements for civil 

unmanned aircraft systems at test ranges where such systems are subject to testing; 

(H) the best methods to ensure the safe operation 

of civil unmanned aircraft systems and public unm.anned 

aircraft systems simultaneously in the national airspace 

·system; and 

(I) incorporation of the plan into the annual NextGen 

Implementation Plan document (or any successor document) of the Federal Aviation Administration. 

(3) DEADLINE . ....:...The plan required under paragraph (1) 

shall provide for the safe integration of civil unmanned aircraft 

systems into the national airspace system as soon as practicable, but not later than September 30, 2015. . (4) REPORT TO CONGRESS.-Not later than 1 year after 

the date of enactment·of this Act, the Secretary shall submit 

to Congress a copy of the plan required under paragraph (1). 
H.R.658-64 

(5) ROADMAP.-Not later than 1 year after the date of 

enactment of this Act, the Secretary shall approve and make 

available in print and on the Administration's Internet Web 

site a 5-year roadmap for the introduction of civil unmanned 

aircraft systems into the national airspace system, as coordinated by the Unmanned Aircraft Program Office of the Administration. The Secretary shall update the roadmap annually. 

(b) RULEMAKING.-Not later than 18 months after the date . on which the plan required under subsection (a)(1) is submitted . to Congress under subsection (a)(4), the Secretary shall publish 

in the Federal Register-

(1) a .final rule on small unmanned aircraft systems that 

will allow· for civil operation of such systems in the national 

airspace system, to the extent the systems do not meet the 

requirements for expedited operational authorization under section 333 of this Act; 

(2) a notice of proposed rulemaking to implement the recommendations of the plan required under subsection (a)(1), 

with the final rule to be published not later than 16 months 

after the date of publication of the notice; and 

(3) an update to the Administration's most recent policy 

statement on unmanned aircraft systems, contained in Docket 

No. FAA-2006-25714. 

(c) PILOT PROJECTS.-

(1) ESTABLISHMENT.-Not later than 180 days after the 

date of enactment of this Act, the Administrator shall establish 

a program to integrate unmanned aircraft systems into the 

national airspace system at 6 test ranges .. The program shall 

terminate 5 years after the date of enactment of this Act. 

(2) PROGRAM REQUIREMENTS.-ln establishing the program 

under paragraph (1), the Administrator shall-

(A) safely designate airspace for integrated manned 

and unmanned flight operations in the national airspace 

system; 

(B) develop certification standards and air traffic 

requirements for unmanned flight operations at test 

ranges; 

(C) coordinate with and leverage the resources of the 

National Aeronautics and Space Administration and the 

Department of Defense; 

(D) address both civil and public unmanned aircraft 

systems; 

(E) ensure that the program is coordinated with the 

Next Generation Air Transportation System; and 

(F) provide for verification of the safety of unmanned 

aircraft systems and related navigation procedures before 

integration into the national airspace system. 

(3) TEST RANGE LOCATIONS.-ln determining the location 

of the 6 test ranges of the program under paragraph (1), the 

Administrator shall-

(A) take into consideration geographic and climatic 

diversity; 

(B) take into consideration the location of ground infrastructure and research needs; and 

(C) consult with the National Aeronautics and Space 

Administration and the Department of Defense. 
H.R.658-65 

(4) TEST RANGE OPERATION.-A project at a test range 

shall be operational not later than 180 days after the date 

on which the project is established. 

(5) REPORT TO CONGRESS.-

(A) IN GENERAL.-Not later than 90 days after the 

date of the termination of the program under paragraph 

(1), the Administrator shall submit to the Committee on 

Commerce, Science, and Transportation of the S~nate and 

the Committee on Transportation and Infrastructure and 

the Committee on Science, Space, and Technology of the 

House 9f Representatives a report setting forth the 

Administrator's findings and conclusions concerning the 

projects. 

(B) ADDITIONAL CONTENTS.-The report under subparagraph (A) shall include a description and assessment of 

the progress being made in establishing special use airspace 

to fill the immediate need of the Department of Defense-

(i) to develop detection techniques for small 

unmanned aircraft systems; and 

(ii) to validate the sense and avoid capability and 

operation of unmanned aircraft systems. 

(d) EXPANDING USE OF. UNMANNED AIRCRAFT SYSTEMS IN 

ARCTIC.-

(1) IN GENERAL.-Not later than 180 days after the date 

of enactment of this Act, the Secretary shall develop a plan 

and initiate a process to work with relevant Federal agencies 

and national and international communities to designate 

permanent areas in the Arctic where small unmanned aircraft 

may operate 24 hours per day for research and commercial 

purJ>oses. The plan for operations in these permanent areas 

shall include the development of processes to facilitate the 

safe operation of unmanned aircraft beyond line of sight. Such 

areas shall enable over-water flights from the surface to at 

least 2,000 feet in altitude, with ingress and egress routes 

from selected coastal launch sites. 

(2) AGREEMENTS.-To implement the plan under paragraph 

(1), the Secretary may enter into an agreement with relevant 

national and international communities. 

(3) AIRCRAFT APPROVAL.-Not later than 1 year after the 

entry into force of an agreement necessary to effectuate the 

purposes of this subsection, the Secretary shall work with relevant national and international communities to establish and 

implement a process, or may apply an applicable process 

already established, for approving the use of unmanned aircraft 

in the designated permanent areas in the Arctic without regard 

to whether an unmanned aircraft is used as a public aircraft, 

a civil aircraft, or a model aircraft. 

rSEC. 333~ SPECIAL RULES FOR CERTAIN lJNMANNED AIRCRAFT SYS-

~TEMS., 

(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. 
H. R..658-66 

·1h) ASSESSMENT OF UNMANNED ArRCRAFI' SYSTEMS.-In making 

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

(1) 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 ;:t hazard to users of the 

national airspace system or the public or pose a threat to 

national security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44 704 of title 

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

unmanned aircraft systeins identified under paragraph (1). 

'(c) REQUffiEMENTS 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. 

SEC. 334. PUBLIC UNMANNED AIRCRAFI' SYSTEMS. 

(a) GuiDANCE . ..,--Not later than 270 days after the date of enactment of this Act, the . Secretary of Transportation shall issue guidance regarding the operation of public unmanned aircraft systems 

to-

(1) expedite the issuance of a certificate of authorization 

process; 

(2) provide for a collaborative process with public agencies 

to allow for an incremental expansion of access to the national 

airspace system as technology matures and the necessary safety 

analysis and data become available, and until standards are completed and technology issues are resolved; 

(3) facilitate the capability of public agencies to develop 

and use test ranges, subject to operating restrictions required 

by the Federal Aviation Administration, to test and operate 

unmanned aircraft systems; and 

(4) provide guidance on a public entity's responsibility when 

operating an unmanned aircraft without a civil airworthiness 

certificate issued by the Administration. 

(b) STANDARDS FOR OPERATION AND CERTIFICATION.-Not later 

than December 31, 2015, the Administrator shall develop and implement operational and certification requirements for the operation 

of public unmanned aircraft systems in the national airspace 

system. 

(c) AGREEMENTS WITH GoVERNMENT AGENCIES.-

(1) IN GENERAL.-Not later than 90 days after the date 

of enactment of this Act, the Secretary shall enter into agreements with appropriate government agencies to simplify the 

process for issuing certificates of waiver or authorization with 

respect to applications seeking authorization to operate public 

unmanned aircraft systems in the national airspace system. 

(2) CONTENTS.-The agreements shall-

(A) with respect to an application described in paragraph (1)- · 

(i) provide for an expedited review of the application; 
H.R.658-67 

(ii) require a decision by the Administrator on 

approval or disapproval within 60 business days of 

the date of submission of the application; and 

(iii) allow for an expedited appeal if the application 

is disapproved; 

(B) allow for a one-time approval of similar operations 

carried out during a fixed period of time; and 

(C) allow a government public safety agency to operate 

unmanned aircraft weighing 4.4 pounds or less, if operated-

(i) within the line of sight of the operator; 

(ii) less than 400 feet above the ground; 

(iii) during daylight conditions; 

(iv) within Class G airspace; and 

(v) outside of 5 statute miles from any airport, 

heliport, seaplane base, spaceport, or other location 

with aviation activities. 

SEC. 335. SAFETY STUDIES. 

The Administrator of the Federal Aviation Administration shall · carry out all safety studies necessary to support the integration 

of unmanned aircraft systems into the national airspace system . 

. SEC. 336. SPECIAL RULE FOR MODEL AIRCRAFT. 

(a) IN GENERAL.-Notwithstanding any other provision of law 

relating to the incorporation of unmanned aircraft systems into 

Federal Aviation Administration plans and policies, including this 

subtitle, the Administrator of the Federal Aviation Administration 

may not promulgate any rule or regulation regarding a model 

aircraft, or an aircraft being developed as a model aircraft, if-

(1) the aircraft is flown strictly for hobby or recreational 

use· 

'(2) the aircraft is operated in accordance with a communitybased set of safety guidelines and within the programming 

of a nationwide community-based organization; 

(3) the aircraft is limited to not more than 55 pounds 

unless otherwise certified through a design, construction, 

inspection, flight test, and operational safety program administered by a community-based organization; 

(4) the aircraft is operated in a manner that does not 

interfere with and gives way to any manned aircraft; and 

(5) when flown within 5 miles of an airport, the operator 

of the aircraft provides the airport operator and the airport 

air traffic control tower (when an air traffic facility is located 

at the airport) with prior notice of the operation (model aircraft 

operators flying from a permanent location within 5 miles of 

an airport should establish a mutually-agreed upon operating 

procedure with the airport operator and the airport air traffic 

control tower (when an air traffic facility is located at the 

airport)). 

(b) STATUTORY CONSTRUCTION.-Nothing in this section shall 

be construed to limit the authority of the Administrator to pursue 

enforcement action against persons operating model aircraft who 

endanger the safety of the national airspace system. 

(c) MODEL AIRCRAFT DEFINED.-In this section, the term "model 

aircraft" means an unmanned aircraft that is-

(1) capable of sustained flight in the atmosphere; 
' .. 

H.R.658-68 

(2) flown within visual line of sight of the person operating· 

the aircraft; and 

(3) flown for hobby or recreational purposes. 

Subtitle C-Safety and Protections 

SEC. 341. AVIATION SAFETY WHISTLEBLOWER INVESTIGATION OFFICE. 

Section l06 (as amended by this Act) is further amended by 

adding at the end·the following: 

"(t) AVIATION SAFETY WHISTLEBLOWER INVESTIGATION 

OFFICE.-

"(1) ESTABLISHMENT.-There is established in the Federal 

Aviation Administration (in this subsection referred to as the 

'Agency') an Aviation Safety Whistleblower Investigation Office 

(in this subsection referred to as the 'Office'). 

"(2) DIRECTOR.-

"(A) APP(HNTMENT.-The head of the Office shall be 

the Director, who shall be appointed by the Secretary of 

Transportation. 

"(B) QUALIFICATIONS.-The Director shall have ademonstrated ability in investigations and knowledge of or 

experience in aviation. · "(C) TERM.-The Director shall be appointed for a term 

of5 years. . "(D) V ACANCIES.-Any individual appointed to fill a 

vacancy in the position of the Director occurring before 

the expiration of the term for which the individual's predecessor was appointed shall be appointed for the remainder 

of that term. 

"(3) COMPLAINTS AND INVESTIGATIONS.-

"(A) AUTHORITY OF DIRECTOR.-The Director shall-

"(i) receive complaints and information submitted 

by employees of persons holding certificates issued 

under title 14, Code of Federal Regulations (if the 

certificate holder does not have a similar in-house 

whistleblower or safety and regulatory noncompliance 

reporting process) and employees of the. Agency concerning the possible existence of an activity relating 

to a violation of an order, a regulation, or any other 

provision of Federal law relating to aviation safety; 

"(ii') assess complaints and information submitted 

under clause (i) and detern:line whether a substantial 

likelihood exists that a violation of an order, a regulation, or any other provision of Federal law relating 

to aviation safety has occurred; and 

"(iii) based on fmdings of the assessment conducted 

under clause (ii), make recommendations to the 

Administrator of the Agency, in writing, regarding further investigation or corrective actions. 

"(B) DISCLOSURE OF IDENTITIES.-The Director shall 

not disclose the identity of an individual who submits a 

complaint or information under subparagraph (A)(i) 

unless-

"(i) the individual consents to the disclosure in 

writing; or 
~~,=A=~ .. I 

SINCE 1936 

AMA INDOOR RIC GUIDELINES 

1. Define the flying area. 

2. Select a flight line (where pilot will stand when flying). 

3. Behind the flight line, designat~ a "pit area'' (where assembly, repairs, etc. 

are done). · 

4. Make it known to all that an area behind the "pits" is the place that 

spectators will be (spectators could enter the pit area at the fliers 

discretion.). 

5. At no time should spectators venture into an active flying area, and fliers 

should enter only to retrieve a model after clearing it with any other active 

fliers. · 

6. A frequency control system must be employed. 

D:\PDF\#525.doc 
Set-Back Distances For Sport Pylon Racing 

Events thpt meet this criteria are automatically granted the site set-back waiver. 

Amended by EC on October 31, 2009 ... (noted in italics) 

1. Club 40 racing 

Aircraft: Sport designed aircraft originally manufactured for .46 size engines. 

Acceptable aircraft include, but are not limited to: World Models Sky Raider Mach II and LA Racer, 

Airborne models T-34 or Super Sports, Sig 4 Star 40, Hobbico Avistar 40 or HAN 9 Arrow. Other 

airframes may be allowed if they meet our criteria. No "quickie" style planes are allowed. Only 

aircraft/engine/propeller combinations that average 100 mph or less will be allowed. 

Engines: NO purpose designed racing engines (Jett, Nelson etc.) will be allowed in this class. 

Mufflers: Engines must use stock mufflers designed for the engine. NO modifications allowed (i.e. 

removing baffle, drilling out stinger etc) 

Carburetor: Engines must use the carburetor designed for and included with the engine. Engine must 

be capable of sustained idle and transition to full throttle. 

2. Sport Quickie .25 

Aircraft: Any "quickie 500" airframe (or equivalent), ARF or built to plans; Global AT-6 "Texan" ARF 

or similar "sport" aircraft. 

Engines: Sport .25 size engines. Examples would include: OS FX, OS LA, Magnum, GMS, Norvel and 

Thunder Tiger. NO purpose designed racing engines (Jett, Nelson etc.) will be allowed in this class. 

Mufflers: Engines must use stock mufflers designed for the engine. NO modifications allowed (i.e. 

removing baffle, drilling out stinger etc) 

Carburetor: Engines must use the carburetor designed for and included with the engine. Engine must 

be capable of sustained idle and transition to full throttle. 

These airframe/engine combinations fly at airspeeds below 100 mph. The breakout speed will be 

detennined by a 400 ft course at 64.8 seconds. If the speed is any faster the aircraft is not qualified for 

Club 40 and Sport Quickie .25 racing. 

Aircraft with AVERAGE airspeeds in excess of 100 mph will be required to fly by the set backs 

imposed on general pylon racing and will not be flown on this smaller course. 

Other events using models powered by 4-stroke or electric with an overall weight under six (6) 

pounds can also use these distances for club sport racing purposes. 
Course requirements: (NOTE: the distances shown in parenthesis are absolute minimum 

distances, you should strive to use the maximum distances your field will allow. 

The minimum distance from pylon line to pilots will be (125) ft 

The minimum distance from Dead line (no fly zone) to pilots will be (50) ft. 

The minimum distance from pylon line to officials is (150) ft. 

The minimum distance from pylon line to spectators is (275) ft. 

The minimum distance from Dead line (no fly zone) to spectators is· (200) ft. 

ALL PERSONS within 275 ft. of the pylon line during flight operations will be required to wear a 

hard hat. 

Only pilots and helpers (callers) or race officials involved in the current heat will be allowed with-in 

(150) ft. of the pylon line during flight operations . 

....,._-:-p-1

--L-. -- Pylon to pylon= 400ft. (approx.) 'YJOn me • • l 

1 (75) ft. 1 

- Dead Line (no fly zone) + 

Take off I Landing area 

(125) ft. I Hard Hats 

required 

Pilot line within 275 ft. 

1 (150) ft. 

1 

Lap counters 

Cut 

Pit Area 275 

Pylon 

ft. 

line 

" M:NIMUM 

to spectators 

~ I Cut 

Judge Judge 

Spectator line 
Academy of Model Aeronautics 

5161 East Memorial Drive Muncie, Indiana 47302 

(800) 435-9262- Membership Services 

www.modelaircraft.org 

~ 4• __J 

~;; 5a' '! ~# ~; ~ ",,= 1' AM 

ACADEMY OF 

MODEL AERONAUTICS 

11SEE AND AVOID" GUIDANCE 

A. General: 

1. The primary means to avoid collisions between all aircraft flying within our National Airspace System 

(NAS) is "See and Avoid." 

2. Vigilance must be maintained by each person operating an aircraft (whether model or manned) so as to 

"see and avoid" other aircraft. 

3. Model aircraft must avoid manned aircraft. Our privilege to fly model aircraft in the NAS depends on our 

commitment to remain "well clear" of manned aircraft. 

4. Simply avoiding an actual collision is not enough. A "near miss" is not acceptable. 

5. Unless flying at a mixed-use site where manned and model aircraft routinely share airspace through 

their own site-specific rules, model aircraft must fly sufficiently far away from manned aircraft so as not to 

create a collision hazard. 

6. Model aircraft flying must not only be safe, it must be perceived to be safe by the greater manned 

aviation community. Modelers must continually demonstrate thelr respect for the safety of manned 

aircraft by remaining vigilant and well clear. 

7. Whenever a potential conflict arises between model aircraft and manned aircraft, the pilot of the model 

aircraft must always give way to the manned aircraft. 

8. The pilot of a model aircraft must never assume the pilot of a manned aircraft can see the= model or will 

perform any maneuver to avoid the model's flight path. 

9. Visual Line of Sight is required by the Safety Code. It means that visual contact with the aircraft must be 

maintained without enhancement other than by corrective lenses prescribed for the model aircraft pilot. 

All RC flying must remain clear of clouds smoke or any other obstruction to the line of sight. 

10. "Blue Sky" is a term used to explain the method used to increase separation between a model and a 

manned aircraft in the same vicinity. The modeler should maneuver the aircraft in such a way as to 

increase the amount of blue sky perceived between the model and the manned aircraft. By increasing the 

blue sky separation, the question about depth perception is taken out of the equation and the modeler 

need not worry whether the model is closer to him than the manned aircraft or further away. Increasing 

the blue sky between the model and the manned aircraft automatically increases separation between 

them. 

Academy of Model Aeronautics 5161 East Memorial Drive Muncie, Indiana 47302 

(800) 435-9262 I Membership Services I www.modelaircraft.org 
Academy of Model Aeronautics 

5161 East Memorial Drive Muncie, Indiana 47302 

(BOO) 435-9262 - Membership Services 

www.modelaircraft.org 

d& 

~~(~~"'~\V~t~~~~ ffi\M~ AC.ADEMY OF 

MODEL AERONAUTICS 

11. A modeler should never place any con"sideration for the well-being of the model aircraft above the 

safety of manned aircraft. Maneuvering to avoid the conflict may require that the model aircraft be 

sacrificed. 

12. Free flight models should not be launched with relatively low altitude manned 

aircraft in sight and downwind or headed downwind from the launch site. 

B. Spotters: 

1. Before a flight, the pilot must insure that the spotter understands his/her duties 

and expectations. 

2. A spotter should be used to assist in monitoring the surrounding airspace for manned aircraft whenever 

a flight is expected to exceed 400 feet above the ground and that operation is expected to be in proximity 

to known manned aircraft traffic such as at a mixed-use facility or within three miles of an airport. The 

spotter must have sufficient visual acuity and be m~ture enough to take this responsibility very seriously. 

3. A spotter should also be prepared to assist his/her pilot in the event that another model aircraft or 

spectators become endangered or in turn are perceived to be a danger to the pilot or the pilot's model 

aircraft. 

4. If a model aircraft pilot experiences what he or she considers a near miss with a manned aircraft, that 

model aircraft pilot should notify AMA Headquarters with a written report of the incident, including action 

taken by the model aircraft pilot to avoid the manned aircraft. This report is intended to help the modeler, 

the club, and the AMA capture as much detail as possible so that it may be used to assist all parties in 

recalling the particulars ofthe incident at a later time. Call 1-800-435-9262 (1-800-IFLYAMA) extension 230 

or 251 for assistance with this report. 

Academy of Model Aeronautics 5161 East Memorial Drive Muncie, Indiana 47302 

(800) 435-9262 I Membership Services 1 www.modelaircraft.org 
{€t 

Academy of Model Aeronautics 

A~~ 5161 East Memorial Drive 

Muncie, Indiana 47302 · 

(7.65) 287-1256- Business 

(765) 29g:.4249 -.Fax · 

(BOO) 435-9262 -, Membership Services 

http://www.modelaircraft.org · SINCE 1936 

Procedure.for RF lnt~rference Testing between Model Sites 

Scope - This procedure outlines the method for performing testing for radio interference 

between ·sites for RC modeling. ~ctivities .. This test is required when the sites involved do not 

meet the ·standards described in item 5 in the Radio control section ofthe AMA National Model 

Aircraft Safety Code . 

. Equipment 

. . ' 

J. Poweredaircraft,ready to fly, complete with a transmitter and a payload capacity large 

enough to carry a: second receiver, battery pack and a "glitch" counter. A high wing .49 size .· 

trainer style aircraft will work well. 

2. Test receiver (FM) on a frequency other than the RC aircraft and controlling transmi~er. 

3. Test transmitter (FM) on the same frequency as the test receiver. . 

4. Interfering transmitter (FM) on the same frequency (preferably the same brand and style) as 

the test. receiver and test transmitter. . . 

5. · Airborne battery pack for the test receiver. Capacity should be a minimum of 250mAH. 

6. Glitch detector. 

7. Handi-talkies capable of a 3 mile range for communication between the sites, or cell phones. 

8. GPS receiver. . . 

Personnel 

1. Pilot 

2. . Helper for flying the aircnift. 

3. Flightline.communicator for handling the communications at the flightline. 

4. Person for holding the test transmitter. . 

5. Observer for locating the aircraft at the test flying pattern location (if practical). 

6. Person for holding the Interfering transmitter at the second site location. 

7. Communicator at the second site location. · 

Procedure 

.. - . ' . . 

1. Using the GPS receiver, perform a distance check between the sites to determine the distance 

between the sites. Contip.i.le with the _procedure if minimum distance isn't met. Use the center of 

the flightline for each endpoint between the two sites. 

2. Using the.GPSreceiver, locate theobserver betwet;:n 1700 feet and 2000 feet away from the 

.flightline of.the .first site, along the imaginary line connecting the two .flightlines. The observer 

should have a handi-talkie or cell phone to communicate with the first site. Note: If the terrain or 
---------------------------------~---~-------~-

t. I ... 

If, at the conclusion of all the tests, a count of 50 or more (after subtracting the calibration 

count) is found this should be considered enough glitching so as to possibly lose control of 

the aircraft. If this count is reached, a frequency management agreement between clubs or 

individuals is required. · 
I -

From the 2011 Official AMA National Model Aircraft Safety Code 

Radio Control Section, #5: 

RC model aircraft will not operate within three (3) miles of any pre-existing flying site without a frequencymanagement agreement. 

A frequency-management agreement may be an allocation of frequencies for each site, a day-use 

agreement between sites, or testing which determines that no interference exists. A frequencymanagement agreement may exist between two or more AMA chartered clubs, AMA clubs and individual 

AMA members, or individual AMA members. Frequency-management agreements, including an 

interference test report if the agreement indicates no interference exists, will be signed by all parties and 

copies provided to AMA Headquarters 

Variations for AMA Frequency Management Agreements: 

1st Party I 2nd Party 

AMA chartered club AMA chartered club 

AMA chartered club Club not affiliated with AMA 

AMA chartered club Individual AMA member· 

Individual AMA member Individual AMA member 

Individual AMA member Individual not affiliated with AMA 

There can be more than 2 parties involved in a Frequency Management Agreement. Be sure to assign the 

designated frequencies to all parties ahd inform all involved members (i.e. post the assignments at the 

flying site). 

Please note, that only officers of the chartered club can sign the Frequency Management Agreements on 

behalf of the club. 

Note: 

Once a Frequency Management Agreement is in place it does not have to be renewed on a yearly basis. 

It is valid until one or both parties (if AMA chartered club) disband, relocate, or sell the property. The 

agreement is only valid for the specific parties named, which means if a club disbands and another AMA 

chartered club/individual member uses the flying site, a new Frequency Management Agreement will have 

to be created, signed by all parties involved, and copies sent to AMA HQ. 

Participants in the Frequency Management Agreement are responsible for informing any guest flying at 

the site about the agreement and enforcing that only frequencies assigned for that particular site are used! 

Important: 

The Frequency Management Agreement requirement is waived on a provisional basis for club(s) 

operating exclusively on 2.4 GHz. However, the club will have to submit a 2.4 GHz agreement to AMA. 

• Individual AMA member means that the individual is using the specific property for RC Flying unrelated to any club 

affiliation he or she might have, within proximity of another party. 

Q:\Special SeNices\Documents\FORMS\#923 Frequency Management Agreement. doc 1212009/SM 
Preventative Maintenance Checklist 

(Text mainly from Pull_ Up) 

EVERY WEEK or EVERY 10 FLIGHTS, WHICHEVER SOONER: 

-Check for damage, wear and crack on all the parts. 

-Check tightness of motor retaining screws and shell retaining screws in case some needed to be tightened up a bit. 

-.Check motors move freely when spun by hand; 

-Turn motors shafts with your fingers and verify they are smooth without excessive play or binding (missing E clip? 

Loose bell housing screw? Bad bearings?). 

-Check batteries for number of cycles and discharge per DJI recommendations if required (Number of cycles can be 

found in Vision Assistant): 

-Charge and discharge the batter)' completely once ever-t 20 charge/discharge cycles. To discharge: when you 

come back from a flight and the % is fairly low, just hold it off in a hover at about a foot or two off the ground -it 

goes fairly quickly -when you get to 8%; ease off the throttle and lands it at about 7%. If you land and let it idle, 

it takes forever. Then recharge it to maximum capacity. This power cycling procedure will optimize the battery. 

- For long term storage, place the battery with only a 40-50% charge in a strong battery box. Discharge and charge 

the battery once every 3 months to keep it in good condition. Charge amount should be varied in these 

maintenance charges- (40%-59%)-0%-100%-(40%-50%). 

-Purchase a new battery after your current battery has been discharged over 300 times. Completely discharge a 

batte,.Y prior to disposal. Please dispose of batteries properly. 

·Warning: If current battery level is over 75% (4 Leds On/Flashing), the battery should be turned on before 

charging. 

EVERY MONTH or EVERY 40 FLIGHTS. WHICHEVER SOONER: 

• Link the Phantom to the RC & Vision Assistant Software and check for Updates, Remote Control Sticks & IMU 

Calibration state and 'if all battery cells have good balance (repeat for all batteries). 

-Clean data spring pins and battery contact pads with alcohol and swab or proprietary electrical contact cleaner and 

cycle spring pins several times to check for spring weakness and full unimpeded travel; 

- Check the Battery life: 

Battery life 

When the baltery 1is powored o:t. press and hold the-Gircular Powor Button for 5 seconds to check batler_,11i:o. Battery 

Lo·o!Of, lndlcators will shoN light up and thO BatterY Power Indicators will blink lor 10 SOC<ll'lds. All lights will <hen tum of1. 

For deta~s. please see below. 

BaucryUfc 

LEO I LED2 LEOO LED4 Current battery life 

0 0 0 0 90%-100% 

0 0 0 n ao~o-90% 

0 0 0 0 70%-80% 

0 0 n ' 0 60%-70% 

0 0 0 0 50%-60,-. 

0 n 0 0 40%-50% 

0 0 0 0 30%-40% 

n 0 0 0 20%-30% 

0 0 0 0 Loss than 20% 

&, When, batter li:e reaches 0. it is no longm -operationaL 

ONCE/TWICE A YEAR OR WHEN YOU FEEL IT MIGHT BE NECESSARY (like after a major crash): 

- Remove upper shell and check state of all wiring -plugs fully seated, condition of all solder joints, condition of 

visible circuit boards and wiring runs, internals generally clean and no debris/loose items. 

-Remove motors and check security of E clips, condition of bearings and general visual inspection. 

-Check this out for a more visual description: How to do preventative maintenance checks. hints and tips 

Page 45 
PHANTOM ·PILOT TRAINING GUID'E 

Earning Your Stripes 

Learn More: www.dji.com 
_&CAUTION 

This product is riot suitable for people under the age of 18. Please carefully read the "Quick 

Start Guide", "User Guide", disclaimer, and fully watch the "Quick Start Videos" before 

using the PHANTOM. Users should 'make every effort to fly regularly in order to improve 

their flight skills as an advanced level pilot ( ***) . Please fly safely and responsibly. 

Please follow these guide'lines prior to flying your Phantom: 

QAiways turn on the Remot~ Controller prior to turning on the Phantom. 

@ Toggle Sl_ 52 to the top. 

8 Be sure there are no distractions when you're flying. 

C. When starting your training, be sure you are in a very large open area. Be aware of your 

surroundings; Always fly in areas void of obstacles and away from traffic and people. 

@t Before actually taking off, be sure you have calibrated the compass and you have full 

GPS satellite reception (Slow Continuous Green Flashing). 

" Never fly over 400 feet. 

fj During training, stay behind your imaginary barrier and never fly behind yourself. 

G) When in doubt, gently pull down on the throttle stick and land. 

0 DO NOT PANIC. 

/ 

The aircraft camera should face AWAY from the pilot before takeoff. 

CAUTION 

DO NOT fly the Phantom within a radius of 2 meters. 

FORBIDDEN 

DO NOT touch the propellers after the Phantom has been started. @ 

NO TOUCH 
Basic Flight Maneuvers ( *) . o Take off and land with battery facing .you. 

Hover in one spot keeping battery facing you, make 

sure to control Left/Right/Forward/Back movement. 

Rotate left, rotate right but try to keep the battery 

pointed at yourself. 

@S 

.® 
Basic Flight Maneuvers ( * ) 

Slowly fly forward/back/left/right with back of 

Phantom pointed at yourself. 

Fly forward to a spot 20-30 feet away. 

Then fly back keeping the battery pointed at yourself. 

Mark a spot (B) on the ground lOft away from the Phantom's 

take off point. Hover arid fly towards that spot and land at 

the spot (B). Then go' back into a hover and bring the Phantom 

back to its original position (A) and land again. 

e• 

' \ ' 

' ' ' \ 

\ ' ' \ 

' ' \ '0 \ ' C.\ \ 

~ ' \ ' \ 

~\ 

eA 
Basic Flight Maneuvers ( * ) 

Fly left lOft away from your take-off point, then fly right 

lOft from your take-off point all while keeping battery 

pointed at yourself. 

3 meters 3 meters 

Then, while keeping the camera pointed forward, 

fly a 4 point square box formation going clockwise. 

Be sure to be in control and stop and hover in place 

at each point before proceeding to the next point. 

i 

i 

' ------------·tl·-----------

Do the same as above but fly the 4 point box formation 

counter-clockwise. Be sure to be in control and stop 

and hover in place at each point before proceeding 

to the next point. 

, 

i ., 

, 

, 

, 

, 

i , ' ''- 0 '· -· . \ ~~ tJ ,· .. ).• 

' 

,' j 

-----------~-----------
Skilled Flight Maneuvers ( * * ) 

D In a hover, starting with the battery pointed at yourself, 

rotate 360 degrees clockwise. 

In a hover, starting with the battery pointed at yourself, 

rotate 360 degrees counter-clockwise. 

Starting with the battery pointed at yourself, go into a hover. 

Then rotate the Phantom 90 degrees facing left, and fly a 4 

point square box formation going clockwise. Be sure to be in 

control and stop and hover in place at each point before 

proceeding to the next point. 
Skilled Flight Maneuvers ( * * ) 

Starting with the battery pointed at yourself, go into a hover. 

Then rotate the Phantom 90 degrees facing right, and fly a 4 

point square box formation going counter-clockwise. 

Be sure to be in control and stop and hover in place at each 

point before proceeding· to the next point. 

I , 

• 

, 

I 

I 

I 

J 

, 

I , 

, 

f \ . 

.... :·--~~ 

_______ ,... _________ ~-

With the battery pointed at yourself, fly a circle. Try to 

keep the altitude and also the circle as uniform as possible. 

Hover with the camera pointed at yourself and try to keep 

the Phantom in one place. 
Advanced Flight Maneuvers ( * * * ) 

a 

EJ 

EJ 

Fly a circle and keep the camera pointed towards you. 

Be sure to keep the altitude the same and the circle as 

uniform as possible . 

.. _ .. ------- •• 

Fly a 4 point square box clockwise while keeping the camera 

facing in your direction. 

I 

-

, 

I , 

, 

I 

, 

.. 

Fly a 4 point square box counter-clockwise while keeping 

the camera facing in your direction. 

--r;\c~~~- -- 'f~'»"=:::_;;v.,_"r-

_____ /i£\ ...., ____ ;~~ ...,. , \ 

, \ 

, \ 

,I \ 

I ~·' ,' . ltJ,;..... , "'>~,, ·-:! I 

, ... l 

,' \ \ 

.. -------_.,.....- ---------· 
Advanced Flight Maneuvers <* * *) ~~ Fly a 4 point square box clockwise and rotate the 

phantom in the direction of travel. 

3@ 

, 

• S>®$ \ 

. - - - - -- - -- -· ~~ Fly a circle counter-clockwise and keep the camera pointed 

in the direction of travel. Be sure to keep the altitude the 

same and the circle as uniform as possible. 

------- ~~~ 

~~~ 

m Fly a circle counter-clockwise with the camera point~d at the 

center of the circle. Be sure to keep the altitude the same 

and the circle as uniform as possible. 

~~~~~.............. ~~~~-·-- ~-------
Advanced Flight Maneuvers <* * *) 

Fly a figure 8 without rotating the Phantom. Be sure to keep 

the altitude the same and the circle as uniform as possible. 

Fly a Figure 8 with the camera of the Phantom pointed in the 

direction of travel. Be sure to keep the altitude the same and 

the circle as uniform as possible. 

Fly Figure 8 patterns while experimenting with different orientations. 

For example, camera always pointed in a given direction or opposite/ 

left/right the direction of travel, etc. Be sure to keep the altitude the 

same and the circle as uniform as possible. 
Emergency Situations 

a 

EJ 

Return Home & Land Mode 

Be sure you are in a large open area. Before you take off, 

make sure you have a good GPS lock by ensuring your LED 

indicators are flashing Green. Fly the Phantom at least SOft 

away from your take off point. Turn off the Remote Controller. 

The Phantom will enter it's failsafe Return· To-Home Mode. 

Let the Phantom finish it's routine and land itself within 2 meters 

of the take off point. 

• 15 meters 

Intercepting Return Home & Land Mode 

Be sure you are in a large open area. Before you take off, make 

sure you have a good GPS lock by ensuring your LED indicators 

are flashing Green. Fly the Phantom SOft away from your take 

off point. Turn off the Remote Controller. The Phantom will 

enter it's failsafe Return· To-Home Mode. When the Phantom 

is returning home, you can intercept RTH Mode by switching 

the Sl Switch from the top position to the middle or lower 

position, then continue flying the Phantom . 

• I 15 meterS 
www.dji.com