December 7, 2015

U.S. Department of Transportation

Docket Operations, M-30

1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

Re: Petition of Christopher Costello for an Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 to Operate an Unmanned Aircraft System

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) 

and 14 C.F.R. Part 11, Christopher Costello (“Petitioner”) hereby applies for an exemption from 

the Federal Aviation Regulations identified below to allow for the commercial operation of the 

following aircraft: 

 Yuneec Typhoon Q500

 Sense Fly eBee RTK

 3DR Solo

 3DR Iris

 Delair-Tech DT 18

 Precision Hawk Lancaster Hawkeye Mark III

 Microdrone MD4-200

 Aeryon Scout

 Aeryon Skyranger

 DJI Phantom 3

 DJI Inspire

 DJI S800/900/1000

 DJI Matrice

 Multirotor G4 Skycrane

 Lockheed Martin Indago

 QuadH2O Multirotors HexH2O

 Blade Chroma

 Ascent AeroSystems Sprite

 Trimble UX5

Where all equipment is being referenced they will be referenced as (“THE EQUIPMENT”).

Summary Grant Approval Request

The petitioner requests the agency issue a summary grant for this application. The 

EQUIPMENT has been approved on numerous petitions. In addition the petitioner is requesting 
to utilize the UAS/UAV for the same purposes as over 1,000 other exemptions that pertain to 

videography and photography.

I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED

Christopher Costello requests exemption from the following regulations:

 14 C.F.R Part 21, Subpart H;

 14 C.F.R Part 27;

 14 C.F.R § 45.11;

 14 C.F.R § 45.23(b);

 14 C.F.R. § 45.27(a);

 14 C.F.R § 61.113;

 14 C.F.R § 91.7(a);

 14 C.F.R § 91.9(b)(2);

 14 C.F.R § 91.9(c);

 14 C.F.R § 91.103;

 14 C.F.R § 91.109(a);

 14 C.F.R § 91.119;

 14 C.F.R § 91.121;

 14 C.F.R § 91.151(a);

 14 C.F.R § 91.203 (a) & (b);

 14 C.F.R § 91.405(a);

 14 C.F.R § 91.407(a)(l);

 14 C.F.R § 91.409(a)(2);

 14 C.F.R § 91.417 (a) & (b).

II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. 

Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft 

systems into the national airspace system.” Pursuant to Section 333 of the Reform Act, the FAA 

Administrator is to permit operation of an unmanned aircraft system where it does not create a 

hazard to users of the national airspace system (NAS) or the public or pose a threat to national 

security based on the following considerations:

 The size, weight, speed and operational capability;

 Operation in proximity to airports and populated areas; and

 Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant 

exemptions from the agency’s safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§ 

106(f), 44701-44716, et seq. A party requesting an exemption must explain the reasons why the 
exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety or 

how it would provide a level of safety at least equal to the existing rules. 14 C.F.R. § 11.81.

III. DESCRIPTION OF PETITIONER AND ITS SERVICES

Petitioner intends to utilize UAV's in order to provide aerial imaging, photography, videography 

and cinematography.

The contact information for the petitioner is as follows:

Christopher Costello

115 Country Side LN

Telford, PA 18969

IV. DESCRIPTION OF PROPOSED UAS OPERATIONS

Petitioner is requesting exemptions from applicable Federal Aviation Regulations (FARs) 

pursuant to Section 333 of the Reform Act to utilize UAS to conduct aerial operations for clients 

including aerial photography/videography services, with a wide variety of applications, to public 

and private individuals and businesses. These include but are not limited to utilities, railroad

transportation, pipeline transportation, oil-field services, petro/chemical/manufacturing, 

construction, agriculture, home and roof inspections, bridge inspections, power line inspections, 

inspections for real estate claims, education, surveying, flight training, commercial & residential 

real estate, surveying, land & property mapping, landscaping, news, law enforcement, 

advertising & marketing, utility infrastructure, search & rescue, and agriculture.

A. The Aircraft

Petitioner hereby applies for an exemption from the Federal Aviation Regulations identified 

below to allow for the commercial operation of the following aircraft: 

 Yuneec Typhoon Q500

 Sense Fly eBee RTK

 3DR Solo

 3DR Iris

 Delair-Tech DT 18

 Precision Hawk Lancaster Hawkeye Mark III

 Microdrone MD4-200

 Aeryon Scout

 Aeryon Skyranger

 DJI Phantom 3

 DJI Inspire

 DJI S800/900/1000

 DJI Matrice

 Multirotor G4 Skycrane
 Lockheed Martin Indago

 QuadH2O Multirotors HexH2O

 Blade Chroma

 Ascent AeroSystems Sprite

 Trimble UX5

Yuneec Q500 Typhoon 

The Q500 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground 

Control Station (GCS) utilizing electronic tablet or smart phone systems. The Q500 UAS is 

equipped with four main electric powered rotors driven by Lithium Polymer batteries.

It is manufactured by Yuneec, Inc. and has the manufacturer’s model designation Q500 

Typhoon. It is an advanced (sUAS) with state of the art safety features, GPS lock, altitude, 

position hold stabilization, smart mode, angle mode follow me and return to home mode. The 

ground station has telemetry with altitude, groundspeed, GPS location and battery life for both 

the transmitter and aircraft as well as an audible and vibration alert for aircraft low battery. 

Aircraft LED visual alert indicators for low battery, GPS loss, and communication loss. The 

UAS has a first person view on the controller that is not to be used for flight by the PIC. The 

UAS has the ability to link with a smartphone or tablet for video link separate from the on board 

display if needed. The UAS has separate radio frequencies for telemetry and video downlink and 

aircraft control. 

1. Aircraft

a. Dimensions 

i. Height 240mm (9.45 in) 

ii. Width 420mm (16.54 in) 

iii. Diagonal Length W\O Rotor Blades 565mm (22.2 in) 

iv. Propeller/Main Rotor Diameter 330mm (13.0 in) 

b. Flight Time up to 25 minutes

c. Weight with Battery and Payload 60.0 oz (1700g)

d. Weight without Battery and Payload 40.0 oz (1130g)

e. Battery 5400mAh 3S 11.1V LiPo (included)

f. Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter 

(included)

g. Transmitter 10-channel 2.4GHz with 5.8GHz video downlink (included)

h. 3 Flight Modes Smart (Follow Me and Watch Me), Angle and Home

i. Maximum Flying Height Default 122m (400ft) above Ground Level 

(Adjustable via the Typhoon GUI)

j. Maximum Rotation Rate 65°/s

k. Maximum Roll Angle 35°

l. Operating Temperature Range −5°C to 80°C

m. Radio Control Frequency Band 2.4GHz

n. Max. Descent Speed 2m/s

o. Max. Flight Speed 8m/s
2. Gimbal

a. Type CGO3

b. Weight 6.9oz (195g)

c. Focusing System Aerial Optimized Fixed Focus

d. Field of View 115°

e. Video Transmission Range

i. FCC Compliance: Up to 600m (1968.5 ft)

ii. CE Compliance: Up to 300m (984.252 ft) with ST10

f. Video Resolution

i. UHD: 4K at 30FPS, 2.7K at 30FPS, 2.5K at 30FPS

ii. FULL HD: 1080p at 24/25/30/48/50/60/120FPS

g. Photo Resolution 12 Megapixels

h. Storage (memory) microSD Class 10 ~ 4 to 128 GB

i. Control Angle Accuracy ±0.02°

j. White BalanceAutomatic or manual settings

k. Transmission Band 5.2GHz–5.8GHz

l. Input/Operating Voltage 12V

m. Working Temperature −10°C–50°C

n. Storage Temperature −20°C–60°C

o. Angular Vibration Range ±0.02°

p. Control Range

i. Pitch: between −90° and 0° 

ii. Yaw: between 0° and 360°

q. Microphone Yes

r. Camera Lens 0.6in (14mm)/f2.8 (1.4in/35mm)—No distortion

s. Sensor 1/2.3′′ CMOS

3. Personal Ground Station

a. Type ST10+

b. Operating System AndroidTM

c. Number of Channels 10

d. Control Transmission Range (Optimum Conditions)FCC Compliance: Up to 

800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) Warning: You Must 

Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times

e. Robust Radio Control Modulation Yuneec Protocol

f. Video Link Frequency Band 5.8GHz

g. Video Transmission Range (Optimum Conditions) FCC Compliance: Up to 

600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) Warning: You Must 

Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times

h. Flight Systems Telemetry Data On Screen Display Yes

i. LED Backlit LCD Screen Capacitive Multi-touch 5.5′′

j. Tactile (Vibrating) and Audible Feedback Yes

k. Built-in LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh

l. Screen Resolution 854 × 480px

m. Camera Settings White balance, light exposure, ISO, shutter speed, video 

resolution, FPS, record video, take pictures
The Q500 has been approved for commercial operations in Exemption Nos. 12360, 12730, 

12684, 12680, 12637, 12833, 12923, and 12697.

Sensefly eBEE

The Sensefly eBee is a small (37.8 inches wingspan) and ultra-light (maximum take-off weight 

of 1.7 pounds) platform made of flexible foam that performs pre-programmed precision aerial 

mapping missions thanks to the on-board GPS and the related flight management software 

(eMotion) that allows the operator to safely and efficiently plan a mission, and then monitor it in 

real-time. Thanks to the embedded camera, protected by a foam envelope, the eBee takes a 

collection of high-definition still images that are used later to generate maps and contour lines of 

the surveyed area. The four main characteristics of the Sensefly eBee are:

1. Very light weight

The eBee is so light that the operator can launch it by hand and let it land on almost any

surface without requiring a parachute or landing net (belly land). Its low impact energy (38 J 

in case of a controlled emergency landing) also significantly reduces the risk of hazardous 

situations. Finally, the wings of the eBee are detachable and made of flexible foam with no 

sharp or hard edges and almost no internal strengthening structure.

2. Electric-powered

The eBee is electric powered. A brushless engine technology makes it silent and reliable. The 

propeller is attached with a rubber band to the body of the plane so that it can easily flex 

away in case of contact with any object.

3. Semi-automatic flight

The artificial intelligence incorporated within the eBee autopilot system continuously

analyzes data from the Inertial Measurement Unit and from the onboard GPS and takes care 

of all the aspects of the flight under the supervision of the operator.

4. Option for manual control

Additionally, the eBee provides an override capability that allows the operator to take manual 

actions during the flight (Go to Home, Go Land, Hold and Resume the mission) and also 

suspend automated operations and take manual control of the aircraft should it become

necessary to respond emergent circumstances, thanks to the remote controller provided with 

the system. 

Technical Specifications

A. Hardware

a. Weight (inc. supplied camera)Approx. 0.73 kg (1.61 lb)

b. Wingspan 96 cm (38 in)

c. Material EPP foam, carbon structure & composite parts

d. Propulsion Electric pusher propeller, 160 W brushless DC 

motor

e. GNSS/RTK receiver L1/L2, GPS & GLONASS

f. Battery 11.1 V, 2150 mAh

g. Camera (supplied) WX (18.2 MP)

h. Cameras (optional) S110 RGB, S110 RE, S110 NIR

i. Carry case dimensions 55 x 45 x 25 cm (21.6 x 17.7 x 9.8 in)
B. Operation

a. Maximum flight time 40 minutes

b. Nominal cruise speed 40-90 km/h (11-25 m/s or 25-56 mph)

c. Radio link range Up to 3 km (1.86 miles)

d. Maximum coverage (single flight) 8 km /3 mi (at 974 m/3,195 ft altitude AGL)

e. Wind resistance Up to 45 km/h (12m/s or 28 mph)

f. Ground Sampling Distance (GSD) Down to 1.5 cm (0.6 in) per pixel

g. Relative orthomosaic/3D model accuracy 1-3x GSD

h. Absolute horizontal/vertical accuracy (no GCPs) Down to 3 cm (1.2 in)/5 cm 

(2 in)

i. Multi-drone operation Yes (inc. mid-air collision avoidance)

j. Automatic 3D flight planningYes

k. Linear landing accuracy Approx. 5 m (16.4 ft)

The eBEE has been approved for commercial operations in Exemption Nos. 12710, 12673, 

12656, 12647, 12619, 12571, 12577, and 12697.

3DR SOLO

The SOLO is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground 

Control Station (GCS) utilizing electronic tablet or smart phone systems. The SOLO UAS is 

equipped with four main electric powered rotors driven by Lithium Polymer batteries. 

Specifications: 

1. General

a. Weight: 3.3 lb / 1.5 kg. 

b. With Solo Gimbal and GoPro: 4 lb

2. Performance

a. Maximum Speed: 55 mph / 88.5 km/h

b. Maximum Altitude: 400' / 121.9 m AGL

c. Flight Time: Up to 25 minutes

3. Flight Control System

a. Model: Pixhawk 2

b. Software: APM flight control software and GPS

4. Handheld Transmitter

a. Display: Color Screen for menu and live flight telemetry

b. Battery: Lithium-polymer Capacity: 5200 mAh . Voltage: 14.8 VDC Life: Up to 4 

hours

c. The 3DR Solo remote controller has an operating frequency of 2.4 GHz for 

telemetry and control.

d. Maximum transmission distance: up to 2,500 ft (outdoors and unobstructed)

5. Mobile App

a. System Requirements: Wi-Fi enabled iOS or Android mobile device

b. Wi-Fi Range: Up to 2640' / 805 m (depending on environment)

6. FPV and Monitoring

a. Video Downlink Latency: 180 ms
b. Connectivity: 1 x HDMI output on Transmitter

7. Components

a. Rotors: 4 x 10 x 4.5" / 25.4 x 11.4 cm self-tightening props

b. Motors Velocity Constant: 880 kV

c. Gimbal Compatibility: Solo Gimbal for HERO3+ and HERO4 GoPro Camera

8. Flight Battery

a. Model: Solo Battery Voltage14.8 VDC

b. Lithium-polymer Capacity 5200 mAh

The 3DR Solo has been approved for commercial operations in Exemption Nos. 12462, 12494, 

12441, 12544, 12433, and 11935.

3DR IRIS

The IRIS is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground 

Control Station (GCS) utilizing electronic tablet or smart phone systems. The IRIS UAS is 

equipped with four main electric powered rotors driven by Lithium Polymer batteries. 

1. Performance

a. Payload Capacity Up to 14.1 oz 1400 g

b. Flight Time - Typically 16 to 22 minutes (depending on payload weight and other 

factors)

2. Flight Control System

a. Processor - 32-bit Pixhawk with Cortex M4 CPU

b. GPS - uBiox GPS with integrated magnetometer

c. Receiver - 3DR Radio, 915 MHz

3. Components

a. Rotors 2 x CCW: 9.5 x 4.5" I 24.1 x 11.4 em tiger motor multi-rotor; selftightening counterclockwise rotation and 2 x CW: 9.5 x 4.5" I 24.1 x 11.4 em 

tiger motor multi-rotor; self-tightening clockwise rotation

b. Motors - 4 x920 KV

c. Mount - Integrated GoPro camera mount with vibration dampener

d. Flight Battery - 3S 5100 mAh LiPo

4. Telemetry Radio

a. Frequency - 915 MHz (FCC complaint

b. Transmit Power - Up to 100 mW at 20 dBm (adjustable)

c. Receiver Sensitivity - 25mA

d. Receive Sensitivity - -117 dBm

e. Protocol - MAVLink

f. Transmission Method 2-way full-duplex communication through adaptive TOM 

Frequency Hopping Spread Spectrum {FHSS)

g. Parallel/Serial Translation - UART interface {3.3 VDC) I transparent serial link

h. Error Correction - Corrects up to 25% of bit errors

i. Firmware - Open-source SIK firmware

j. Software Requirements - Configurable through Mission Planner and APM 

Planner
k. Compatible Devices - Android tablet with OTG (on the go) support and Windows 

desktop computer

l. Connectivity

i. Per Radio (Two Included):

ii. 1 x Micro-USB port

iii. 1 x 6-pin DF13 connector

iv. 1 x RP-SMA for antenna

m. Power Requirements - 3.7 to 6 VDC {from USB or DF13 connector)

n. Dimensions - 1.1 X 2.2 X 0.5" /26.7 X 55.5 X 13.3 mm

5. General

a. Dimensions

i. Height: 3.9" /100 mm

ii. Motor-to-Motor Dimension: 21.7" /550 mm

b. Weight - With Battery: 2.8 lb /1.3 kg

The 3DR IRIS has been approved for commercial operations in Exemption Nos. 12539, 12833, 

12579, 12580, 11494A, 12569, 12544, 12488, 12495, 12496, 12461, and 12204.

DELAIR DT-18

The DT-18 was conceived and manufactured by Delair-Tech. Over ten DT-18 have been sold to 

date. Globally, the DT-18 has completed 521 flights for a total of 231 flight hours and 12,600 km 

covered.

The DT-18 is hand launched and lands on its belly. It typically lands with a 5m precision. Every

aspect of the landing is automatic. It is the first and only UAS certified by the Direction Generale 

de l’Aviation Civile (DGAC) for flight beyond line of sight (BLOS) up to 15km from the base 

station in the French civilian airspace (Scenario S4). However, flights pursuant to the requested 

exemption will be operated within visual line of sight (VLOS) of the pilot in command (PIC).3

The DT-18 is equipped with six control surfaces. It has one aileron on each wing, one flap on 

each wing, and two ruddervators located on the empennage. The flaps are only used on landing. 

They are also automatically deployed in case of an over speed to act as speed brakes.

1. Type of Motors Brushless, outrunner

2. Cruise Speed 31 mph (50 km/h)

3. Max speed 49.7 mph (80 km/h)

4. Power 4S 8900mAh Li-Po, 270W Max Power

5. Weight 4.4 lbs (2kg)

6. Maximum Endurance 120 minutes

7. Wingspan 5.9 ft/1.8m

8. Fuselage length 3.9 ft/1.2 m

9. Takeoff/landing Hand or catapult/belly or net

10. Wind resistance 31 mph (50 km/h)

11. C2 range 25 mi/40 km (857 MHz)

12. Data link range 9.3mi/15 km (5.8 Ghz)
The DT-18 Ground Control Station (GCS) serves as the operator interface, coordinating the

mission and communication functions including mission planning, near real-time mission

progress, video display, and function monitoring.

The GCS consists of a laptop and mission planning/execution software (SolApp), a case with a 

built-in joystick and slider, a back-up controller, a steerable command and control link antenna, 

and a steerable data link antenna.

The SolApp program conducts mission planning for the DT-18, with complete route planning to 

include waypoints, identify No-Fly zones, and take into consideration the terrain height. All of 

the takeoff and landing is planned in SolApp. The mission planning information is up-loaded to 

the DT-18 prior to flight. SolApp also has the ability to change and upload all mission planning 

during flight via the Command and Control link. As part of the mission execution, SolApp has a 

check-list that confirms the following:

 DT-18 assembly

 Internal sensor (magnetometer, GPS, etc) calibration

 Payload functionality

 Weather inputs

 Carrying case controller (joystick and slider) calibration

 Antennae placement and calibration

 Uploading of mission information to DT-18

 During flight, SolApp provides complete management of the DT-18 mission. 

 The following

is provided during flight to the operator:

o Moving map showing the location of the DT-18

o Speed

o Heading

o Altitude

o Climb rate

o Link status

o Battery status

o All safety systems and alarms

The DT-18 system operates under autopilot during missions, or can be controlled by the joystick 

and slider built into the GCS. The joystick and slider operate through the command control link 

of the GCS. The DT-18 system also includes a back-up controller, which operates on a separate 

link from the GCS. The operator can bypass the DT-18 autopilot with the back-up controller.

The command and control and data link antennae are part of the GCS. The two antennae are

mounted on a motorized steerable mount that will automatically track the location of the DT- 18. 

The main command and control link between the DT-18 and the GCS operates at a frequency of 

915 MHz (ISM Band). This link provides all the DT-18 flight information back to the GCS and 

provides any updates to the mission from the GCS to the DT-18. The DT-18 uses the XBee-Pro 

900HP Modem, which has FCC regulatory approval. The data link on the DT-18 allows for the 
payload information to be transmitted in near real-time between the DT-18 and the GCS. The 

data link operates at a frequency of 5.8 GHz.

The DELAIR has been approved for commercial operations in Exemption No. 11524.

The HAWKEYE

The Precision Hawk Hawkeye Lancaster MK-III UAS is a single electric motor fixed wing 

aircraft. Wing span is 1.5 m and power is delivered with a 28 cm propeller. Power source is a 

12.6 volt, Lithium-Polymer battery with a 3900 mah capacity. Payload will be various cameras 

and sensors. Gross weight will remain below 6 lbs regardless of payload. Flight is controlled by 

two (2) on board computers with one dedicated to vehicle control and stability with the second 

computer dedicated to mission control and vehicle status monitoring. The aircraft is equipped 

with a global positioning system (GPS), Inertial Measurement Unit (IMU), and Compass that 

work in unison to stabilize the aircraft and render safety features. The aircraft can be 

programmed to not fly above 400 feet AGL and to not fly outside of a pre-determined flight 

zone. These systems will also initiate the failsafe function. If the aircraft loses the signal from the 

transmitter, the GPS system will automatically initiate the failsafe mode and fly the aircraft back 

to a pre-determined location and land automatically.

The HAWKEYE has been approved for commercial operations in Exemption Nos.11273, 11573, 

11551, and 11345.

MD4

The microdrones md4-200 UAV is a miniaturised VTOL aircraft (Vertical Take Off and 

Landing). It can fly by remote control or automatically using our GPS Waypoint navigation 

software.

The md4-200 aerial vehicle consists of a carbon fiber body, boasts a flying time of 30 minutes 

and can carry a load of up to 250 g. Rain, snow and dust pose no particular problem for 

microdrones UAVs.

The ultra-lightweight robust and weather–resistant carbon fibre body enables the md4-200 to 

reach an operating height of up to 1000 meters - ideal for aerial photography and aerial 

inspections.

1. Technical Specifications

a. Vehicle mass: 800g

b. Payload mass (recommended): 150g

c. Payload mass (maximum): 250g

d. Maximum take-off weight: 1100g

e. Battery: 4S LiPo, 14.8V, 2300mAh

f. Climb rate: 7.0 m/s

g. Cruising speed: 8.0 m/s

h. Peak thrust: 15.5N
i. Endurance:

i. up to 30 min

ii. Endurance can always vary with wind/weather, payload and age of battery

iii. with 150g payload the average is 15min

j. Flight radius:

i. max. 500m on C&C

ii. max. 6000m on WP

k. Service ceiling: 2000m ASL

2. Operational Conditions

a. Temperature range: -10..40°C

b. Humidity: max 90% r.H.

c. Wind tolerance:

i. steady pictures up to 4 m/s 

ii. max. up to 8 m/s

d. Dimensions

i. Diameter: 540mm

ii. Height: 230mm

The MD4 has been approved for commercial operations in Exemption No. 11171A.

Aeryon SCOUT and RANGER

The Scout and Sky Ranger are quad-copter type vertical takeoff and landing small UAS, with 

four rotors mounted on booms and four legs. Payloads are mounted underneath the fuselage on a 

gimbal mount. Communications use common frequencies and are digitally encrypted, which 

reduces the risk of hijacking and video interception.

The aircraft are controlled with a tablet based interface, reducing pilot fatigue and workload. The 

aircraft are piloted by the use of a stylus, pointing to an area on a moving map display. Altitude 

is controlled by using a slider bar on the touch screen interface to command the aircraft to climb 

or descend.

The system is fully stabilized and GPS guided. Custom or commercially available map data in 

several formats may be used for operator orientation. The aircraft can be flown real-time by the 

operator or pre-programmed to fly a series of GPS waypoints. While the aircraft is flying its preprogramed flight path, the operator always has full control of the vehicle and can change its 

flight path or altitude immediately. Flight information such as position, altitude, environmental 

conditions, signal link strength, GPS signal strength, battery voltage, and other flight data is 

displayed to the operator in real time.

The aircraft itself is constantly monitoring environmental and system conditions and will alert 

the operator to any abnormalities. The aircraft have many built in failsafe mechanisms that will 

allow return to the point of origin and vertical landing if an emergency condition exists.

The aircraft and payloads are gyro stabilized, allowing for exceptional imaging and resolution 

quality at safe distances from infrastructure, which is essential for safe and effective inspections. 
The aircraft have a quick-change payload interface with common interfaces including USB and 

Ethernet, which allows custom payloads to be developed.

The system is able to detect the type of payload connected, and configure it and operate it 

appropriately. The payload capacity of the system is 250 g (0.55 pounds).

Offered payloads include gimbal-mounted digital still and video cameras, a near IR camera for 

remote sensing, a FLIR night-vision camera, and a stabilized 10x Optical

Zoom camera.

Aeryon Scout Technical Specifications

• Deployment: Vertical Take-off and Landing

• Operation: Range 1 Mile

• Operational Duration: Up to 20 Minutes

• Operational Velocity: Up to 30 mph

• Wind Limits: Up to 30 mph (Gusts up to 50 mph)

• Dimensions: 31.5 in. x 31.5 in x 7.9 in

• Max Weight: 3.4 pounds

• Power Source: 11.1V Intelligent LiPo Battery

Aeryon Sky Ranger Technical Specifications

• Deployment: Vertical Take-off and Landing

• Operation Range: 2 Miles

• Operational Duration: Up to 50 Minutes

• Operational Velocity: Up to 30 mph

• Wind Limits: Up to 40 mph (Gusts up to 55 mph)

• Dimensions: 40 in. x 40 in. x 9.3 in.

• Max Weight: 5.3 pounds

• Power Source: 14.8V Intelligent LiPo Battery

Command and Control Systems

The Aeryon Ground Control Station allows the operator simultaneous control over aircraft and 

payloads. The touch screen control allows for quick navigation and data entry while the display

screen provides all essential flight data to the operator. Telemetry data is transmitted to the 

command station at least once per second.

Displayed on GCS:

• Position

• Navigation Route

• Altitude

• Heading

• Battery voltage and time remaining

• GPS signal strength

• Radio link strength

• Aircraft status to include error messages or failures
• Date/time

• Sensor position and orientation relative to sUAS

On-board Flight Instruments – The sUAS is equipped with an Inertial Navigation System (3-axis 

gyroscope, magnetometer, GPS receiver, and static pressure sensor) and a sonar sensor for 

precision AGL altitude measurement.

On–board computer systems – The sUAS is equipped with on-board computer systems to 

monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate 

(control, telemetry, etc.).

On-board guidance and navigation equipment – The sUAS can operate autonomously; it does not 

require any input from ground-based equipment, or from the pilot to hover in place.

Frequency Allocations – 900 MHz and 2.4 GHz.

Fly away protection – To prevent a “fly away” or other potentially dangerous situations, the 

aircraft employs a system of fail-safes that will either return the aircraft to its home origin point 

or land the aircraft in its present position.

Takeoff and Landing – The sUAS has vertical lift autonomous launch and recovery. A

Landing Zone (“LZ”) is designated by the operators and identified in the GCS software.

For launch procedures the aircraft will take off and hover 3 meters directly above the LZ and 

hold until further operator instruction is given. The aircraft will automatically adjust for wind 

during this period.

Navigation System – Specific maps, such as air sectional and geographic maps, can be 

downloaded to the display screen and overlaid with GPS positional data. Waypoints can be 

created before and during flight operation creating specific locations and sequences for the 

aircraft.

Redundant Systems – The sUAS combines the input from a multitude of sensors.

Even though the data from all sensors is required for optimal system performance, a single 

sensor malfunction is likely to result in degraded performance rather than leading to a 

catastrophic failure.

Emergency Procedures and System Failures

Engineered Failsafe Mechanisms

Lost Communications

The sUAS does not need constant signal from the tablet to continue flying. Communication 

outages are detected by the system and are reported to the pilot. During the communication 

outage the aircraft will hover in place, climb to a pre-set safe altitude, and then fly to its takeoff 
location. If communication is still not established the aircraft will descend slowly and make a 

landing at the point of takeoff. All of this is accomplished without input from the operator.

If the aircraft receives interference or another overpowering signal, the system will simply go 

into its lost communication procedure as stated above. It will climb to a safe altitude, fly home 

and land.

Communications Data Security

All communication links are encrypted. The communication system and protocol is designed in 

such a way that control of the aircraft cannot be taken over by accident. The video feed is also 

encrypted. Any unauthorized person attempting to receive the video would see a scrambled 

picture.

Battery Life

The battery voltage and flight time remaining are displayed to the operator throughout the flight. 

When 3 minutes of flight time is remaining, a warning is given to the operator. If the operator 

does not bring the aircraft home, the system will return home (takeoff point at a safe transit 

altitude) on its own. The sUAS is equipped with an intelligent battery monitoring system that 

will allow it to leave its present position and fly home with reserve battery power to make a safe 

landing under current environmental conditions.

Ignition Source Resistant

The aircraft are equipped with a sealed LiPo battery pack and is operated by 4 brushless electric 

motors. The brushless motors, by their design, do not spark or arc while being operated. The 

operating temperature of the motors and the battery is extremely low.

Potential Component Failures

The aircraft have highly engineered systems monitoring software. Examples include battery

health and temperature, voltage going to the motors, GPS accuracy, magnetic anomalies, 

vibration sensing, and yaw detection. There is a warning prior to any major failure, giving time 

to safely manage the situation. If the failure is considered “non-fatal,” it will return home and 

land. If it is considered “fatal,” it will set down immediately at its present position. Automatic 

pre-flight checks prevent the UAS from taking off if problem conditions are present.

Defined “No Fly Zones”

The navigation software allows for preplanning No Fly Zones which can allow the operator to 

maintain clearance from any “prohibited areas.” The Scout and Sky Ranger will operate with 

geo-fencing. This technology allows the operator to effectively put a GPS based perimeter 

around the area of operations which will keep the aircraft in a designated “operational box” 

regardless of normal or emergency operations. The geofence is custom designed and can be 

adjusted based on each location of operation.

Visual Line-of-Sight Loss

All flight operations will be conducted with the sUAS within visual sight of the pilot. If for some 

reason the pilot’s view becomes obstructed and line-of-sight is lost, the aircraft will hover in 

position until line-of-sight is reestablished.
The SCOUT and RANGER have been approved for commercial operations in Exemption Nos. 

11209, 11240, 11265, 11252, 11259, 11436, 11576, 11673, 11665, 11830, 11230A, 12077, 

11447B, 12140, 12387, 12195, 13076, 12658, and 11534.

Phantom 3

Petitioner will operate the DJI PHANTOM 3 (the “PHANTOM”) manufactured by DJI 

Innovations. The PHANTOM is a battery operated quadcopter with a maximum flight time of 25 

minutes. The vehicle weighs approximately 2.82 pounds with a maximum takeoff weight of 

approximately 3 pounds. It has fixed landing gear, vibration dampers, small frame air incline and 

minimalized gimbal mount, which allows for a 94 degree of view from the camera. Although the 

vehicle’s ground speed has a maximum of 35 mph, it will be operated between 2 and 25 miles 

per hour, and it will operate at or below 400 feet AGL. 

The PHANTOM’s manufacturer specifications are shown in the Appendix of the Quick Start 

Guide and the USER Manuals for each airframe. 

The UAV/UAS/UA which Petitioner will be operating is the DJI Phantom 3. The inherent safety 

features, sophistication, programmability, GPS navigation, return home capability, airport 

vicinity no-fly feature and restricted altitude feature, as well as differentiating radio frequency

(rf) for aircraft controller/receiver and for the camera make this a much safer UAV for the 

purposes of this petition. This is a radio controlled UAVs that has the capacity for software 

upgrades. It is light, less than 3 pounds including battery and camera. Incorporated into the 

programming of the PHANTOM is an automatic return home feature that automatically directs 

the craft back to point of take-off should communication with the transmitter be lost. The 

Phantom has a cruising speed of 15 knots, with a maximum speed of 29 knots. Maximum flight 

time is 25 minutes. Gross weight is 2.82 pounds. 

The PHANTOM has a communication link between the camera and aircraft allowing the 

operator or Pilot in Command (PIC) to monitor battery level, altitude (AGL), distance from PIC, 

camera imagery, and also control camera angle. The software for the PHANTOM allows the 

operator or PIC to set maximum altitude AGL for each flight, allowing customization of flights 

to no higher than 100 feet, 150 feet, or 250 feet AGL as examples. The 400 foot maximum AGL

is by default programmed into the UAV's software pre-flight to insure compliance with FAA 

standards adding to the safety capabilities of this UAV. This UAV is programmed to remain in 

position when controls are released, maintaining altitude and GPS location. 

The PHANTOM has an altitude and radar monitoring function that allows the operator more 

precise determination of height, direction of flight and distance from the operator/PIC. The 

operator/PIC can monitor GPS lock status while the UAV is in flight, with the ability to 

anticipate loss of GPS locking so the operator/PIC can land the UAV as a precaution.
The Inspire

Petitioner will operate the the DJI INSPIRE 1 (the “INSPIRE”) manufactured by DJI

Innovations. The INSPIRE is a battery operated quadcopter with a maximum flight time of 18 

minutes. The vehicle weighs approximately 6 pounds with a maximum takeoff weight of 

approximately 9 pounds. It has retractable landing gear, vibration dampers, small frame air 

incline and minimalized gimbal mount which allows for a 94 degrees of view from the camera. 

Although the vehicle’s ground speed has a maximum of 49 mph, it will be operated between 2 

and 35 miles per hour, and it will operate at or below 400 feet AGL. 

The INPIRE’s manufacturer’s specifications are shown in the Appendix of the Quick Start Guide 

and the USER Manuals. 

The UAV/UAS/UA which Petitioner will be operating is the DJI Inspire 1. The inherent safety 

features, sophistication, programmability, GPS navigation, return home capability, airport 

vicinity no-fly feature and restricted altitude feature, as well as differentiating radio frequency

(rf) for aircraft controller/receiver and for the camera make this a much safer UAV for the 

purposes of this petition. This is a radio controlled UAVs that has the capacity for software 

upgrades. It is light, less than 10 pounds including battery and camera. Incorporated into the 

programming of the INSPIRE is an automatic return home feature that automatically directs the 

craft back to point of take-off should communication with the transmitter be lost. The Inspire has 

a cruising speed of 15 knots, with a maximum speed of 42 knots. Maximum flight time is 18 

minutes.

The INSPIRE has a communication link between the camera and aircraft allowing the operator 

or Pilot in Command (PIC) to monitor battery level, altitude (AGL), distance from PIC, camera 

imagery, and also control camera angle. The software for the INSPIRE allows the operator or 

PIC to set maximum altitude AGL for each flight, allowing customization of flights to no higher 

than 100 feet, 150 feet, or 250 feet AGL as examples. The 400 foot maximum AGL is by default 

programmed into the UAV's software pre-flight to insure compliance with FAA standards adding 

to the safety capabilities of this UAV. This UAV is programmed to remain in position when 

controls are released, maintaining altitude and GPS location. 

The INSPIRE has an altitude and radar monitoring function that allows the operator more precise 

determination of height, direction of flight and distance from the operator/PIC. The operator/PIC 

can monitor GPS lock status while the UAV is in flight, with the ability to anticipate loss of GPS 

locking so the operator/PIC can land the UAV as a precaution. 

Spreading Wings S800/S900/S1000

The SPREADING WINGS is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) 

with a Ground Control Station (GCS) utilizing electronic laptop, tablet, or smart phone systems. 

The DJI SPREADING WINGS has a maximum gross weight of approximately 8.2kg, while 

having a length of 0.9m, a width of 0.9m, a height of 0.6m, and a maximum speed of 

approximately 20 knots. The DJI SPREADING WINGS UAS is equipped with six main electric 

powered rotors driven by Lithium Polymer batteries. The multi-rotor can carry a payload of up 
to 13 pounds, and has been operated with a payload of high-resolution DSLR cameras, infrared 

cameras, and video cameras for photography, videography, geospatial analysis and 

photogrammetry.

DJI Spreading Wings S800

1. Specifications 

a. Frame Diagonal Wheelbase 800mm 

b. Frame Arm Length 350mm 

c. Frame Arm Weight (with Motor, ESC, Propeller) 356g 

d. Center Frame Diameter 240mm 

e. Center Frame Weight 550g 

f. Landing Gear Size 460mm(Length)×425mm(Width)×320mm(Height) (Top 

width: 155mm) 

g. Retractable Landing Gear Weight (Including Battery Tray) 1050g 

2. Motor 

a. Stator Size 41×14mm 

b. KV 400rpm/V 

c. Max Power 500W 

d. Weight (with Cooling Fan) 158g 

3. ESC 

a. Current 40A OPTO 

b. Voltage 6S LiPo 

c. Signal Frequency 30Hz ~ 450Hz 

d. Drive PWM Frequency 8KHz 

e. Weight (with Radiators) 35g 

4. Foldable Propeller (1552) 

a. Material Engineering plastic Size 15×5.2 inch 

b. Weight 13g 

5. Flight Parameters 

a. Takeoff Weight 6.0Kg ~ 8.0Kg 

b. Total Weight 3.7Kg 

c. Power Battery LiPo (6S、10000mAh~15000mAh、15C(Min)) 

d. Max Power Consumption 3000W Hover 

e. Power Consumption 800W(@ Takeoff Weight 6.7Kg) 

f. Hover Time Max: 20 min (@15000mAh & 6.7KgTakeoff Weight) 

g. Working Environment Temperature -10 ~ +40 C

The DJI S800 has been approved for commercial operations in Exemption Nos. 11252 and 

11225.

DJI Spreading Wings S900 

1. Aircraft 

a. Diagonal Wheelbase – 900mm 

b. Frame Arm Length – 358mm 

c. Frame Arm Weight – 316g 

d. Center Frame Diameter – 272mm 
e. Center Frame Weight – 1185g 

2. Propulsion 

a. Stator Size – 41x14mm 

b. kV – 400rpm/V 

c. Max Power – 500W 

d. Weight (witch Cooling Fan) – 158g 

3. ESC 

a. Working Current – 40A 

b. Working Voltage – 6S LiPo 

c. Signal Frequency (Hz) – 30~450 

d. Drive PWM Frequency – 8kHz 

e. Weight (with Radiators) – 35g 

4. Propeller 

a. Size 15x5.2 inch 

b. Weight – 13g 

5. Flight Parameters 

a. Takeoff Weight Minimum – 3.3kg 

b. Takeoff Weight Maximum – 8.2kg 

c. Power Battery – LiPo 6S 10Ah – 20Ah 15C(Min) 

d. Max Power Consumption – 3kW 

e. Hover Power Consumption – 1kW 

f. Approximate Flight Time – 20 min. 

g. Working Environment Temperature – -10C ~ +40C 

h. Hover Accuracy (Ready to Fly) – Vertical: 0.8m Horizontal: 2.5m 

i. Max Yaw Angular Velocity – 200deg/s 

j. Max Tilt Angle – 35deg 

k. Max Ascent Speed – 6m/s 

l. Max Descent Speed – 2 m/s 

m. Max Flight Speed – 15m/s (NOT RECOMMENDED)

The DJI S900 has been approved for commercial operations in Exemption Nos. 11224, 11240, 

11250, 11256, 11279, 11280, 11295 and 11305.

DJI Spreading Wings S1000

1. Frame

a. Diagonal Wheelbase 1045mm

b. Frame Arm Length 386mm

c. Frame Arm Weight (Including Motor, ESC, Propeller ) 325g

d. Center Frame Diameter 337.5mm

e. Center Frame Weight (With Landing Gear Mounting Base, Servos) 1330g

f. Landing Gear Size 460mm (Length) ×511mm (Width) ×305mm (Height), (Top 

width: 155 mm)

2. Motor

a. Stator Size 41×14mm

b. KV 400rpm/V

c. Max Power 500W
d. Weight(With Cooling Fan) 158g

3. ESC

a. Working Current 40A

b. Working Voltage 6S LiPo

c. Signal Frequency 30Hz ~ 450Hz

d. Drive PWM Frequency 8KHz

e. Weight(With Radiators) 35g

4. Foldable Propeller (1552/1552R)

a. Material High strength performance engineered plastics

b. Size 15×5.2inch

c. Weight 13g

5. Flight Parameters

a. Takeoff Weight 6.0Kg ~ 11.0Kg

b. Total Weight 4.2Kg

c. Power Battery LiPo (6S、10000mAh~20000mAh、15C(Min))

d. Max Power Consumption 4000W

e. Hover Power Consumption 1500W (@9.5Kg Takeoff Weight)

f. Hover Time 15min (@15000mAh & 9.5Kg Takeoff Weight)

g. Working Environment Temperature -10 °C ~ +40 °C

6. Gain Value Settings 

a. For A2 Flight Controller 

i. Basic: Roll 120%, Pitch 120%, Yaw 120%

ii. Attitude: Roll 170%, Pitch 170%, Vertical 120%

b. For WooKong-M Flight Controller 

i. Basic: Roll 180%, Pitch 180%, Yaw 120%

ii. Attitude: Roll 180%, Pitch 180%, Vertical 120%

The DJI S1000 has been approved for commercial operations in Exemption Nos. 11280, 11279, 

11278, 11863, 11260, 11253, 11228, 11160, and 11161.

The DJI MATRICE

The MATRICE is a battery operated quadcopter with a maximum flight time of 18 minutes. The 

vehicle weighs approximately 5.3 pounds with a maximum takeoff weight of approximately 7.5 

pounds. 

The MATRICE is a fully customizable and programmable flight platform. It is equipped with 

DJI’s easy-to-fly technology and optimized for easy programming through the DJI SDK. The 

MATRICE has guidance which is a revolutionary visual sensing system. With a powerful 

processing core, integrated visual cameras, ultrasonic sensors, and the most advanced computer 

vision algorithms in the world. Guidance includes five sensor modules and one central processor. 

Guidance continuously scans the nearby environment and detects obstacles in real time. When 

used with a DJI flight controller, it can tell your flight system to automatically avoid collision, 

even at high speeds. Guidance’s vision positioning system is effective at altitudes of up to 65 

feet (20 meters). DJI’s new N1 flight controller keeps the MATRICE stable and responsive.
The MATRICE has an upgraded version of the respected DJI E800 electric propulsion system. 

Four powerful, brushless motors and four lightning fast Electronic Speed Controllers are 

integrated into the platform, providing complete control during flight. The MATRICE has an 

enhanced GPS with a foldable mount helps track the MATRICE’s position in real time, while 

enabling faster satellite acquisition, more accurate position holding and flight planning.

The SKYCRANE

The SKYCRANE is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a 

Ground Control Station (GCS) The SKYCRANE is equipped with the latest MULTIROTOR 

flight-control, which allows an unprecedented flight and image stability. This is ensured by a 32-

bit processor of the MULTIROTOR flight-control with about 10 times more computing capacity, 

the most modern hardware components and a referenced GPS system.

Substantially enhanced is the flight performance by the newly developed engines. Brushless 

motors made by Plettenberg as well as individually designed three-blade rotors with winglets 

enable the most effective and silent uplift ever in this class.

Incomparable flight stability, due to the latest 32-bit dual-processor technology, which corrects 

the flight position 512 times per second and enables secure drone flight. No-Panic-Function 

allows the UAV keeps its current position and place.

 Technical range 2,000 meter min.

 Autopilot with 250 meter flight radius, position hold, coming home, automatic altitude 

control

 Brushless gears from Plettenberg with handcrafted three-blade rotors

 Light and unbreakable full carbon frame

 Two-way data telemetry with language assistance

 High performance flight battery (2 units)

 Attitude control 512 times per second Yes

 Automatic treble control 24-bit barometric Yes

 Autonomous flight max. 500 waypoints Optional

 Auto start / auto landing assistant Optional

 Battery redundancy Yes

 Cantilever beam plug system Optional

 Camera suspension Optional

 Digital option port (for future applications) Yes

 Digital RC transmitter pilot Optional

 Dimension Ø 114 cm, H. 50cm

 Drive redundancy Yes

 Emergency Landing Yes

 Device hull insurance Europe Optional

 Flight Control MULTIROTOR G4 Dual 32 bit Yes

 Flight Control redundancy Optional
 Flight data log 128 bit

 Flight training and flight practice certificate Optional

 GPS flight assistant (position Hold, Coming Home) Yes

 Inspection (12 months, 25 flight lines, 350 starts) Optional

 L1 GPS Yes

 Live-View 5.8 GHz Diversity Yes

 Max. airspeed 40-50 km/h

 Max. Flight time (ideal) 12 Minutes

 Max. Take-off weight (ideal) 12000 g

 Pack size 97x97x 25cm (demontiertes Gimbal)

 Payload (incl. camera suspension and flight battery) 6500 g

 Servo connectors 6

 Wind stable up to 10-15 m/s

The INDAGO

The INDAGO is manufactured by Lockheed Martin. The INDAGO ‘s autopilot has a high 

degree of pre-programmed control and various built-in technical capabilities that strictly limit the 

potential for operation outside of the operating conditions set forth in the exemption application. 

Hands-on experience with the INDAGO are a far more effective guarantee of flight safety than a 

commercial pilot certificate would be, until the FAA UAS Pilot Certificate requirements catch up 

to the SUAS technology. 

The INDAGO‘s autopilot has an all-digital software platform with advanced features previously 

restricted to full size unmanned aircraft. Automated features and advanced fly-safe controls 

enable safe, reliable operation, as well as advanced networking capabilities and system 

extensibility. 

 The system will be flown in manual mode at all times.

 Flight time and battery minutes are displayed at all times. The system will return home 

and land automatically if user-configurable limits are reached 

 Flight safety is a priority, no matter the operating environment or project. SUAS offer 

superior safety over manned aircraft by removing the need for people to be onboard in 

potentially dangerous situations. With multiple built-in safety features, SUAS platforms 

are comparable to manned operations with respect to safety 

 The INDAGO automatically detects potential issues - with configurable automated 

response behavior such as a return-home and automatic-landing routines 

 The INDAGO self-calibrates all of its sensors and performs required failsafe pre-flight 

tests prior to takeoff to check for errors 

 The INDAGO has the ability to automatically return to base in a loss of link situation so 

the aircraft can’t fly horizontally or vertically beyond the pre-planned flight area 

 The INDAGO has battery minutes and flight time displayed at all times. The system will 

return home and land automatically if user-configurable limits are reached 

 The INDAGO auto-detects a loss of GPS, warns the pilot and initiates a landing based on 

user specified timelines 

 Low battery on the INDAGO triggers a return to base for landing and battery replacement 
 If the INDAGO detects a loss-of-link with the Ground Control Station the vehicle will 

return to base and perform an automatic landing at the takeoff point or other user defined 

return home point

The HexH2O

The HexH2O RTF (“HEX”) is manufactured by HEX H2O Multirotors with the Naza-M V2 

Flight Control System manufactured by DJI Innovations. The HexH2o has an epoxy fiber/carbon 

fiber waterproof body that buoys and also utilizes DJI motors and props. 

The HEX is a battery operated hexcopter with a maximum flight time of 25 minutes. The vehicle 

weighs approximately 7 pounds with a maximum takeoff weight of approximately 10.4 pounds. 

It has buoyancy aids to either side of the hull, vibration dampers, and minimalized gimbal mount, 

which allows for a 110 degree of view from the camera. Although the vehicle’s ground speed has 

a maximum of 25 mph, it will be operated between 2 and 5 miles per hour, and it will operate at 

or below 400 feet AGL. 

The UAV/UAS/UA which Petitioner will be operating is the HexH2O. The inherent safety

features, sophistication, programmability, GPS navigation, return home capability, and restricted 

altitude feature, as well as differentiating radio frequency (rf) for aircraft controller/receiver and 

for the camera make this a much safer UAV for the purposes of this petition. This is a 

professional grade radio controlled UAVs that has the capacity for software upgrades. It is light, 

less than 12 pounds including battery and camera. Incorporated into the programming of the 

HEX is an automatic return home feature that automatically directs the craft back to point of 

take-off should communication with the transmitter be lost. The HEX has a cruising speed of 15 

knots, with a maximum speed of 29 knots. Maximum flight time is 25 minutes. Gross weight is 

10.4 pounds. 

The HEX has a communication link between the camera and aircraft allowing the operator or 

Pilot in Command (PIC) to monitor battery level, altitude (AGL), distance from PIC, camera 

imagery, and also control camera angle. The software for the HEX allows the operator or PIC to 

set maximum altitude AGL for each flight, allowing customization of flights to no higher than 

100 feet, 150 feet, or 250 feet AGL as examples. The 400 foot maximum AGL is by default 

programmed into the UAV's software pre-flight to insure compliance with FAA standards adding 

to the safety capabilities of this UAV. This UAV is programmed to remain in position when 

controls are released, maintaining altitude and GPS location. 

The HEX has an altitude and radar monitoring function that allows the operator more precise 

determination of height, direction of flight and distance from the operator/PIC. The operator/PIC 

can monitor GPS lock status while the UAV is in flight, with the ability to anticipate loss of GPS 

locking so the operator/PIC can land the UAV as a precaution. 

The HEX features a waterproof carbon fiber body that floats and features extra props in the event 

that if one fails, the aircraft can remain flying. In addition, the UAV features an internal fan and 

exterior-mounted heat sink to prevent overheating.
Blade Chroma

1. Motor to Motor Distance: 15.7 in (400mm)

2. Rotor Type: Quadcopter

3. Prop Diameter: 10.2 in (260mm)

4. Approximate Flight Time: 30 minutes

5. Battery: 11.1V 3S 5400mAh Li-Po

6. Height: 9.50 in (242mm)

7. Weight: 45.9 oz (1.3 kg)

8. Motor Type: 4 × 780Kv Brushless Outrunner

9. Control Link: 2.4GHz

10. Video Link: 5.8GHz

11. Video Link Range: 1,970 ft (600m)

12. Satellite Navigation System: GPS, GLONASS

13. Completion Level: Ready-to-Fly

Sprite

1. Fully autonomous autopilot with GPS, including waypoint navigation, "follow me", and 

return to home

2. 2-axis stabilized gimbal compatible with GoProTM

3. Real-time telemetry

4. Fully enclosed, compact, ultra-durable

5. Users can define geo-fencing and altitude limits through Sprite's flight control system

6. Dimensions & Performance

a. Airframe is constructed mostly of injection molded ABS

b. Length: 13.2 inches (350mm)

c. Diameter: 3.8 inches (100mm)

d. Weight: 2.6 lbs. (1,200g) with battery and standard camera

e. Displacement: 215 cu. in. (3,520 cc)

f. Endurance: approximately 10-12 minutes on a 11.1v LiPo battery (gearing, blade 

and motor optimization is ongoing)

g. Speed: up to 10 m/sec

h. Range: 10 minutes at 10 m/sec = 6km under autonomous flight

i. Signal range: depends on equipment. Typically 2km +/-, up to 50km possible 

with long range gear

j. Telemetry link is available in both 433MHz and 915MHz. The optional 

transmitter for conventional, manual flight control is a 2.4GHz system.

The Trimble UX5

The Trimble UX5 aerial imaging rover follows a pre-programmed path where takeoff, flight, and 

landing require minimal human intervention. If required, the crew operating the aircraft from the 

ground can intervene to change the flight path or to land. In some cases, such as communications 

failure or loss of GPS signal, a pre-programmed intervention is automatically activated to reestablish signal loss or to terminate the flight early and complete a safe landing. The UX5 aerial 

imaging rover holds a camera that takes aerial images over the defined area. 
The UX5 is a fixed-wing aircraft, weighs less than 6 pounds fully loaded, flies at a maximum 

speed of no more than 74.5 knots indicated airspeed (KIAS), and a cruise speed of 49 KIAS, 

carries neither a pilot nor passenger, carries no flammable fuels, and operates exclusively within 

a pre-disclosed area. In addition, the UX5 has a semi-autonomous navigation and control system

comprised of a Ground Control Station (GCS) and auto-pilot system. All flights are preprogrammed with precise global positioning system (GPS) guidance and do not require human 

intervention

Hardware

Type. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Fixed wing

Weight. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.5 kg (5.51 lb)

Wingspan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 m (3.28 ft)

Wing area. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 dm

Dimensions . . . . . . . . . . . . 100 cm x 65 cm X 10.5 cm (39.37 in x 25.59 in x 4.13 in)

Material. . . . . . . . . . . . . . . . EPP foam; Carbon frame structure; Composite elements

Propulsion. . . . . . . . . . . . . . . . . . . . Electric pusher propeller; brushless 700 W motor

Battery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14.8 V, 6000 mAh

Camera. . . . . . . . . . . . . . . . . . . . . . 24 MP mirrorless APSC with custom 15 mm lens

Controller. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Trimble Tablet Rugged PC

Operation

Endurance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 minutes

Range . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 km (37.28 mi)

Cruise speed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 kmh (50 mph)

Maximum ceiling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5000 m (16,404 ft)

Pre-flight system setup time. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 minutes

Take off Type. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Catapult launch

Angle. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 degrees

Landing Type. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Belly landing

Angle. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 degrees

Landing space (L x W)

Typical . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 m x 6 m (66 ft x 20 ft)

Recommended. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 m x 30 m (164 ft x 98 ft)

Weather limit . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 kmh (40.39 mph) and light rain

Communication & control frequency. . . . . . . . . . . . . . . . . . . . . . . . . 2.4 GHz (FHSS)

Communication & control range. . . . . . . . . . . . . . . . . . . . . . . . Up to 5 km (3.10 mi)

Considering the programmability and safety features of these UAVs, it serves as the best option 

to protect the Public and NAS for the purposes of this petition. 

Similarities, Distinctions and Differences 

Christopher Costello is using UAVs that have the capability for taking off and landing at a single 

point, identical to a helicopter. There are no runways, aided take off apparatuses, nor routes that 

need to be flown to operational areas, thus allowing for a reduced and more confined area of 

flight. 
The motors, rotors, propellers, body/frame, landing pads, etc. for the UAVs utilized in this 

petition are not complicated. Engineering and design allows layman maintenance. Pre-flight 

inspections for cracks, damage or other physical conditions that could hamper safe flight will be 

conducted prior to any and all missions. Post flight inspections will also be conducted in order to 

aid in identifying flight conditions that may cause stress to propellers, landing gear, etc. 

Thorough inspection of the UAVs shall be conducted and flight response tested should a hard 

landing or crash occur insuring that the UAVs can operate in a safe manner before conducting 

any further missions. 

Like the Astraeus Petition, Petitioner requests waiver or exemption for markings due to the small 

size of the fuselage for THE EQUIPMENT. 

Petitioner requests modification, waiver or exemption and clarification (within reason) 

concerning the Section 91.119 prohibition of flight in congested areas. Petitioner requests waiver 

for this condition to allow reasonable and responsible operations in congested areas of 

subdivisions and neighborhoods. 

In compliance with Section 90.151 (a) THE EQUIPMENT are battery operated UAVs/UASs

with battery level monitoring capability. Fully charged battery flight time is rated at 18-120

minutes, with videos/photos taking much less time to record. Operator or PIC is warned when 

battery level is low. 

Petitioner requests waiver/exemption from Section 91.203 (a) since posting of special flight 

authorization would not be possible since THE EQUIPMENT has no cabin and are not large 

enough to carry a certificate. 

B. Petitioner’s Proposed Operations Demonstrate an Equivalent Level of Safety

1. General Description of Proposed Flight Operations

Petitioner proposes to operate within the limitations and performance specifications listed in the 

USER MANUALS, which are summarized below. These limitations provide for at least an 

equivalent, or higher, level of safety for operations under the current regulatory structure because 

the proposed operations represent a safety enhancement to the protocols.

The proposed operations do not create any hazard to users of the national airspace system or pose 

a threat to national security. THE EQUIPMENT are battery operated quadcopters and fixed-wing 

aircraft with a maximum flight time of 18-120 minutes. THE EQUIPMENT weighs 

approximately 8–25 pounds. It has vibration dampers and small frame air incline. THE 

EQUIPMENT’s ground speed is a maximum of 25-56 mph but it will be operated between 2 and 

25 miles per hour, and it will operate at or below 200 feet AGL. 

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. THE 

EQUIPMENT carries no fuel, and therefore the risk of fire following an incident or accident due 

to fuel spillage is eliminated. Compared to manned aircraft, the unmanned aircraft being 
operated by the petitioner reduces the risk to participating persons in close proximity to the 

aircraft due to the limited size, weight, operating conditions, and design safety features of THE 

EQUIPMENT.

The FAA has determined that the risk of not having an electronic means to monitor and 

communicate with other aircraft, such as transponders or sense and avoid technology, is 

mitigated by placing limits on altitude, requiring stand-off distance from clouds, permitting 

daytime operations only, requiring that the aircraft be operated within visual line of sight, and 

requiring THE EQUIPMENT to yield right of way to all other manned operations. Additionally, 

the operator will request a NOTAM prior to operations to alert other users of the 

NAS. See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 13.

The petitioner’s aircraft has the capability to operate safely after experiencing certain in- flight 

failures, as specified in the USER MANUAL regarding Return to Home (RTH) specifically low 

battery RTH and failsafe RTH. The aircraft is also able to respond to a lost-link event with a precoordinated, predictable, automated flight maneuver.

2. Reasons why the exemption would not adversely affect safety or how the 

exemption would provide a level of safety at least equal to the existing rule. 

Given the small size involved, the restricted environment within which they will operate, the 

procedures listed below, and pilot certification requirements, Petitioner proposed operations 

using THE EQUIPMENT would “not create a hazard to users of the national airspace system or 

the public or pose a threat to national security.” Reform Act Section 333(b) (1).

1. The aircraft will be identified by serial number, registered with the FAA, and 

have identification (N-Number) markings as large as practicable.

2. Flights will be operated within visual line of sight of the pilot in command (PIC).

3. Prior to each flight, a zero altitude initiation point will be established and 

confirmed for accuracy by PIC.

4. Maximum flight time for each operational flight will be approximately 15-20 

minutes.

5. The aircraft will be safely landed with no less than the greater of (a) 20% battery

life remaining or (b) three minutes of flight time remaining.

6. The aircraft will be operated during daylight and in VFR conditions.

7. Flights will be operated at a lateral distance of at least 50 feet from any persons or 

property not associated with the operation who have not given prior permission.

8. Flights will be limited to a groundspeed of 5-25 mph.

9. Minimum crew for each flight will consist of a PIC and an Observer.

10. The PIC will possess at least a sport pilot certificate and a valid state driver’s 

license. 

11. Prior to the flight, a Mission Plan will be created setting forth the limitations for 

the flight as well as contact information for the PIC.

12. The flight operations will yield the right of way to other manned aircraft 

operations.
13. All persons who are not involved with flight operations will be required to stay 50

feet from the edge of the flight operation perimeter. 

14. Petitioner will provide NOTAM details to the FAA 24 hours prior to each flight.

15. All required permissions and permits will be obtained from territory, state, county

or city jurisdictions prior to flight.

16. Prior to commencing operations, Petitioner will obtain a Certificate of Waiver or 

Authorization (COA) from the FAA if flying above 200 feet AGL.

17. If the aircraft loses communications, it will have the capability to return to a predetermined location within the operational area and land.

18. If the aircraft loses its GPS signal it will have the capability of being flown 

manually to a predetermined location within the operational area and land.

19. The flight will be aborted in case of unpredicted obstacles or emergencies.

20. Each flight will be recorded in an Operations Log Book.

24. Maintenance on the aircraft will be recorded in a Maintenance Log Book.

3. Flight Recovery, Lost Communications, and Lost GPS Procedures

The flight recovery, lost communications, and lost GPS procedures are fully documented in the 

User Manuals.

V. SPECIFIC FAR EXEMPTIONS REQUESTED

Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, 

and 91 for purposes of conducting the requested operations. Listed below are (1) the specific 

FAR sections for which exemption is sought, and (2) the operating procedures and safeguards 

that Petitioner has established which will ensure a level of safety better than or equal to the rules 

from which exemption is sought. See 14 C.F.R. § 11.81 (e).

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. 

§ 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the 

Reform Act that the UASs selected provide an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met, and therefore no 

exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA 2014-

0352 at 13-14, 22. If, however, the FAA determines that there are some characteristics of THE 

EQUIPMENT that fail to meet the requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety: THE EQUIPMENT are safe when taking into account its size, 

weight, speed, and operational capability. THE EQUIPMENT weighs approximately 2.6-25 

pounds and either will be flown at speeds of 5-25 miles per hour, and in visual line of sight of the 

operator. THE EQUIPMENT does not carry pilots, passengers, explosive materials, or 

flammable liquid fuels. THE EQUIPMENT will be operated within the parameters of the User

Manuals.
Petitioner will also provide the FAA with advance notice of all operations via a NOTAM and 

coordination with the local Flight Standards District Office (FSDO). The proposed operations 

will be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness 

certificate without the restrictions and conditions proposed here. 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent THE EQUIPMENT would otherwise require certification 

under Part 27, Petitioner seeks an exemption from Part 27’s airworthiness standards for the same 

reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

C. 14 C.F.R. § 45.11: Marking of Products

—prescribes, in pertinent part, that the manufacturers of aircraft, engines and propellers mark 

such aircraft, engines, or propellers with an approved fireproof identification plate.

Petitioner requests an exemption from 14 CFR 45.11. The Identified

System, due to its small size, does not have room for fireproof identification plates to be placed

in it. 

D. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and 

Identification Requirements

14 C.F.R. §45.23(b), Markings of the Aircraft states:

When marks include only the Roman capital letter “N” and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” 

“restricted,” “light-sport, “experimental,” or “provisional,” as applicable.

14 C.F.R. § 45.27(a) states:

Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

14 C.F.R. § 91.9(c) states:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft “have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C if the markings are “as large as 

practicable.” See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 14.
Equivalent Level of Safety: Petitioner will mark all THE EQUIPMENT with their N- Number in 

a prominent spot on the fuselage with markings that are as large as practicable.

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Petitioner seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying 

aircraft for compensation or hire and would also require a second class medical certificate. The 

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in 

which the PIC will be operating, as well as requiring certifications if the pilot is carrying 

passengers or cargo for hire.

While THE EQUIPMENT will be operated as part of a commercial operation, they carry neither 

passengers nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA 

determined that the unique characteristics of UAS operation outside of controlled airspace did 

not warrant the additional cost and restrictions attendant with requiring the PIC to have a 

commercial pilot certificate and a class II medical certificate. The FAA has also determined that 

the required knowledge for a commercial pilot covers the same fundamental principles as a 

private pilot.

The PIC will possess at least a sport pilot certificate, a valid US driver’s license, and will have 

completed a Basic Operator Course for THE EQUIPMENT.

The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the 

overriding safety factor for the limited operations proposed by the petitioner to be the airmanship 

skills acquired through UAS-specific flight cycles, flight time, and specific make and model 

experience, culminating in verification through testing.” See Exemption No. 11062, Docket No. 

FAA 2014-0352, at p. 18. The proposed operations can achieve an equivalent level of safety by 

requiring the knowledge and experience in THE EQUIPMENT operations described above.

The restrictions Petitioner has placed on THE EQUIPMENT operations meet or exceed the 

restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA-2014-0352. 

Petitioner will operate in restricted areas (the sites) away from persons and property not involved 

in the operation. The aircraft will be flown based on VLOS at or below 400 feet AGL, so as to 

accommodate flight operations on specified sites. A NOTAM will be issued at least 24 hours 

before the flight is to occur, and the flight will be coordinated with the applicable FSDO.

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in 

airworthy condition to be operated. The FAA has stated that no exemption is required to the 

extent that the requirements of Part 21 are waived or found inapplicable. Accordingly, Petitioner 

requests that the requirements for Section 91.7 be treated in accordance with FAR Part 21 

Subpart H. See Grant of Exemption No. 11062, p. 19.
G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 

14 C.F.R. §§ 91.203(a) and (b): Carrying Civil Aircraft Certification and 

Registration

Pursuant to 14 C.F.R. § 91.9(b)(2):

(b)No person may operate a U.S.-registered civil aircraft -

...

(2)For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or 

any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a)Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following:

(1)An appropriate and current airworthiness certificate.

(b)No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under § 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

Petitioner does not request an exemption from this section but instead notifies the FAA that, in 

accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight 

manual, registration certificate and other documentation will be kept at the control station with 

the PIC during flight. The Chief Counsel’s Office has held that for all UAS operations, this 

alternate method constitutes full compliance with the regulations. See also Grant of Exemption 

No. 11062, pp. 19-20, and Grant of Exemption No. 8607.

H. 14 C.F.R. § 91.103: Preflight Action

Petitioner seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar 

with specific information before each flight, including information contained in the FAAapproved Flight Manual on board the aircraft. The aircraft will not have a Flight Manual on 

board. The PIC will take all actions including reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation of flight. Under 

these circumstances, the FAA has stated that no exemption is required. See Grant of Exemption 

No. 11062, p. 20. An exemption is requested to the extent that an FAA-approved Flight Manual 

is required.

Equivalent Level of Safety: An equivalent level of safety will be provided by following the User 

Manuals. The PIC will take all required preflight actions - including performing all required 

checklists and reviewing weather, flight requirements, battery charge, landing and takeoff 
distance, aircraft performance data, and contingency landing areas - before initiation of flight. 

The User Manuals will be kept at the ground station; with the operator at all times.

I. 14 C.F.R. § 91.109(a): Flight Instruction

Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “[n]o person may

operate a civil aircraft (except a manned free balloon) that is being used for flight instruction 

unless that aircraft has fully functioning dual controls.” UASs and remotely piloted aircraft, by 

their design, do not have functional dual controls. Instead, flight control is accomplished through 

the use of the A2 Flight Control System/Ground Control Station (GCS) that communicates with 

the aircraft via radio communications.

Equivalent Level of Safety: When flight instruction is performed, no pilots will be on the aircraft 

and the GCS will be a safe distance from the aircraft and the public, causing no safety hazard. 

Given the size and speed of THE EQUIPMENT, an equivalent level of safe training can still be 

performed without dual controls because no pilot or passengers are aboard the aircraft, and all 

persons will be a safe distance away in the event that the aircraft experiences any difficulties 

during flight instruction. These flights will comply with the provisions in the User Manuals. 

Accordingly, Petitioner proposed method of operation provides superior levels of safety.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas

Petitioner requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet 

to any person, vessel, vehicle, or structure. The FAA has already determined that relief from 

Section 91.119(c) is warranted for UAS operations in uncongested areas with similar flight 

restrictions as those imposed by Aerial Media International. See Grant of Exemption No. 11062, 

p. 20-21.

Equivalent Level of Safety: Compared to flight operations with rotorcraft weighing far more 

than the maximum weights proposed herein, and given the lack of flammable fuel, any risk 

associated with these operations is far less than those that presently exist with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of THE 

EQUIPMENT, as well as the locations where it is operated. In order to avoid any risk to aircraft, 

flight operations will be restricted to 400 feet AGL or below. As set forth in the User Manuals 

and herein, THE EQUIPMENT will be operated at sites, away from persons or structures not 

involved in the operation. All persons who are not involved with Petitioner operations will be 

required to be at least 50 feet from the flight operation perimeter. 

K. 14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport. THE EQUIPMENT use both barometric pressure sensors and 

GPS to determine altitude but do not have the ability to set in a current altimeter setting. An 

exemption is required to the extent that THE EQUIPMENT do not have a barometric altimeter 
setting. The altitude of the aircraft is monitored by the PIC on the ground control station and by

the visual observer.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety can be 

achieved if the aircraft will be operated at or below 400 feet AGL and within visual line-of-sight 

in addition to GPS based altitude information relayed in real time to the operator. See Grant of 

Exemption No. 11062, p. 20-21. As the User Manuals indicate, THE EQUIPMENT will be 

operated at or below 400 feet AGL and comply with the limitations in the Grant of Exemption 

No. 11062.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Petitioner requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in 

VFR conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the 

first point of intended landing and, assuming normal cruising speed –

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

(2) At night, to fly after that for at least 45 minutes.

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering 

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

landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

Here, the technological limitations on THE EQUIPMENT battery power means that no 

meaningful flight operations can be conducted while still maintaining a 30 minute reserve. The 

aircraft is battery powered with a maximum flight time of between 18-25 minutes. Petitioner 

proposes that the maximum flight time for each operational flight will be 18-25 minutes. The 

aircraft will be safely landed with no less than the greater of (a) 20% battery life remaining or (b) 

three minutes of flight time remaining.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety is provided if 

the UAS flight is conducted under daytime VFR flight conditions using VLOS, and terminated 

with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21-

22. The User Manuals providing an equivalent level of safety by safely landing with no less than 

the greater of (a) 20% battery life remaining or (b) three minutes of flight time remaining and 

otherwise complying with the flight restrictions above.

M. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and 

(b): Maintenance Inspections

Petitioner seeks an exemption from the maintenance inspection requirements contained in 14 

C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify
maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 

91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ... have discrepancies 

repaired as prescribed in part 43 of this chapter”). An exemption from these regulations is needed 

because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which 

THE EQUIPMENT will not have.

Equivalent Level of Safety: An equivalent level of safety will be achieved because maintenance 

and inspections will be performed in accordance with the Manuals. This includes maintenance, 

overhaul, replacement, and inspection requirements for the aircraft and procedures to document 

and maintain maintenance records for the aircraft. This also includes preflight inspection 

procedures. See Exemption No. 11062, Docket No. FAA 2014- 0352, at p. 14-15.

As provided in the Manuals, flights will not be conducted unless a flight operations checklist is 

performed that includes all of the aircraft’s components. The Manuals also set requirements for 

maintenance log books and record keeping as well as routine and post-flight maintenance. The 

Manuals set requirements for both annual maintenance and preventative maintenance.

VI. PUBLIC INTEREST

Granting Petitioner petition for exemption furthers the public interest. National policy set by 

Congress favors early integration of UAS into the NAS in controlled, safe working environments 

as proposed in this petition. By granting this petition, the FAA will fulfill Congress’s intent of 

allowing UAS to operate safely in the NAS before completion of the rulemaking required under 

Section 333 of the Reform Act.

Petitioner will operate in a manner that will ensure the public’s safety and will set the example 

for others to emulate. It is well established that UAS provide an additional tool for the 

filmmaking industry, adding a greater degree of flexibility, which supplements the current 

capabilities offered by manned aircraft.

VII. PRIVACY

All flights will be conducted in accordance with any federal, state or local laws regarding 

privacy. All flights will occur over private or controlled access property with the property 

owner’s prior consent and knowledge. Images or video taken of individuals will have consented 

to being filmed or otherwise they will be made anonymous.

VIII. NATIONAL SECURITY 

Given the small size of the UAS involved and the restricted environment within which they will 

operate, our petition presents no national security issue. Furthermore, the security screening 

conducted by the Transportation Security Administration of certificated airmen satisfies the 

statutory requirement of Section 333 for operations to not pose a threat to national security.
IX. SUMMARY FOR FEDERAL REGISTER

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in order to conduct aerial operations for 

clients including aerial photography/videography services, with a wide variety of applications, to 

public and private individuals and businesses. These include but are not limited to utilities, 

railroad transportation, pipeline transportation, oil-field services, petro/chemical/manufacturing, 

construction, agriculture, home and roof inspections, bridge inspections, power line inspections, 

inspections for real estate claims, education, surveying, flight training, commercial & residential 

real estate, surveying, land & property mapping, landscaping, news, law enforcement, 

advertising & marketing, utility infrastructure, search & rescue, and agriculture: 14 C.F.R Part 

21, Subpart H; 14 C.F.R Part 27; 14 C.F.R § 45.11; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 

14 C.F.R § 61.113; 14 C.F.R § 91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 

91.103; 14 C.F.R § 91.109(a); 14 C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a); 14 

C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 

91.409(a)(2); 14 C.F.R § 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the operator, the general public and 

property owners from the hazards associated with operating UAS through deliberate planning, 

risk mitigation, and flight operations.

X. CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, speed, 

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

sight, and national security considerations - provides more than adequate justification for the 

grant of the requested exemptions to permit Petitioner to operate THE EQUIPMENT.

Granting the requested exemption will benefit the public interest as a whole in many ways, 

including (1) significantly improving safety and reducing risk by alleviating human exposure to 

danger; (2) improving the quality of services Petitioner can provide to its customers; and (3) 

decreasing the risks of unmanned aircraft interfering with manned aircraft

Respectfully submitted,

 By: /s/ Christopher Costello