August 28 th , 2015

U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave, SE Washington, DC 20590
**Exemption Request Pursuant To Section 333 of the FAA Modernization Reform Act of 2012**  Name and Address of Petitioner Stephen Marshall, Owner Quad City

UAS Services, LLC 3513 N. Sharon Dr. Prescott Valley , AZ 86314 (928) 925

- 3829 Stephenmarshall2013@gmail.com

**Introduction** As set forth herein, to commercially operate small Unmanned Aircraft Sy stems (UAS) safel y and legally in th e National Airspace S ys tem (NAS), Stephen Marshall of Quad City UAS Services, LLC, Prescott Valley , Arizona, seeks an exemption from Federal Aviation Regulations pursuant to 14 C.F.R. and Section 333 of the FAA Modernization and Reform Act of 2012. Sectio n 333 states that the FAA may issue a certificate of waiver upon a finding that a type of UAS, as a result of its size, weight, speed, operational capacity , proximity to airports and populated areas, and operations within visual line of sight do not create a hazard to users of the NAS or the public or pose a threat to national security . The grant of such an exemption is consistent with Congress’ intent, reflected in Section 333, that safe s ys tems be permitted in the national airspace prior to the issuance o f final regulations governing general use of these sy stems. Being “unmanned aircraft and associated elements, including communication links and the components that control the unmanned aircraft that are required for the pilot in command to operate safel y and efficiently in the national airspace s ys tem,” Quad City UAS Services’ UAS meet the Section 331 definition of “small unmanned aircraft.”Section 332 provides for such integration of civil unmanned aircraft s ys tems into our national

airspace sy stem as it is in the public’s interest to do so. We would like to operate our small UAS(s) prior to the time period by which the Reform Act requires the FAA to promulgate rules governing such craft, thereb y providing direct experience and valuable information for formal regulation. Quad City

UAS Services intends to use small UAS to provide aerial photograph y and videograph y services to businesses, organizations and community members. See the Public Benefit section of this document for more details. More specificall y, we intend to:  Enable businesses to imp rove marketing and outreach through the use of state

- of

- the

- art aerial photograph y and videograph y  Help to inspect buildings and structures, and map landscapes in a safe, cost

- effective manner  Provide economic stimulus and public benefit b y providing an ef fective means by

which companies or individuals can use up

- to
- date, high

- quality photos and videos to learn about properties, neighborhoods and communities  Help communities realize economic benefit b y encouraging public participation and encouraging touris m; by

showcasing community

buildings and landscapes; and by documenting community events in low

- cost way s not previously available to them  In crease awareness/knowledge of the amenities of a local area b y the general public and by visiting tourists  Provide non - profit organizations as well as schools and universities and local municipalities way s to showcase facilities, document events, and educate the public  Aid in search and rescue operations and accident investigations We understand that we are entitled t o submit a Petition for Exemption if we believe that f ollowing a rule will burden us, we can provide a level of safety at least equal to that provided by the rule, and our request is in the public interest. Therefore we seek relief from the following sections of the current regulations: 14 CFR 21 subpart H

- Certification procedures; Airworthiness Certificates 14 CFR 45.23

- Display

of Marks 14 CFR 61.113 (a) & (b) Private Pilot Privileges and L imitations 14 CFR 91.105 Flight crewmembers at stations 14 CFR 91.109 (a) Flight instruction 14 CFR 91.119 (c) Minimum safe altitudes 14 CFR 91.121

- Altimeter settings 14 CFR 91.151 (a)

- Fuel Requirements for Flight in VFR Conditions 14 CFR 91.203 Carrying Civil Aircraft Certification and Registration 14 CFR 91 .405 (a) 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2) Maintenance required; Operation after maintenance, preventive maintenance, rebuilding or alteration 14 CFR 91.417 (a) & (b) Maintenance Records 14 CFR 91.7 (a)

- Civil Aircraft Airworthiness 14 CFR 91.9 (b) Civil aircraft flight manual, marking, and placard requirements.This application is similar to many which have received FAA approval. As stated in Exemption #11639, the FAA has found that the enhanced safety achieved using an UAS with th e specifications described by herein, and carrying no passengers or crew, rather than a manned aircraft of significantl y greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that such exemption is in the public interest. Since we are appl yi ng at a time when the FAA is using a “summary grant process” be informed that while developing this request we reviewed, among others, exemptions #11636, #11639, #115 95, #11596, #11564, #11569, #11616 , #12640, and #12641 **Exte nt of Relief and Reason for Seeking Relief; Why the Exemption would not**  **Adversely Affect Safety, or How the Exemption would Provide a Level of Safety Equal to Existing Rule**  **Part 21 Airworthiness Certification; Subpart H Certification procedures for product s and**  **parts, Airworthiness Certificates** This section outlines requirements for the issue of design and production approvals, airworthiness certificates, and other airworthiness approvals. We seek relief from this rule because the size, weight and enclosed operational area of our UAS, as described elsewhere in this document, permit exemption from Part 21 because our UAS meet and exceed an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the a irworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Therefore, relief from 14 CFR part 21, and any associated noise certification and testing requirements of part 36, is not necessary

. Instead of following this requirement, we will as outlin ed in this document, as per our Flight Operations and Procedures Manual and Training Manual (currently in development), Quad Cit y UAS Services seeks to uphold the same level or exceeded level of safet y as described in Part 21 of 14 C.F.R. Therefore this exemption will not adversel y affect safety

or will provide a level of safety equal to the existing rule. **14 CFR 45.23 Display of Marks** This section outlines regulations requiring specific location(s) and si ze of aircraft marks. We seek relief from this rule because, given the size of our UAS, and the lack of cabin, cockpit or pilot station, two

- inch lettering is difficult to place on such small aircraft. Instead of following this requirement, we will mark th e UAS in lettering that is as large as practicable b y placing an N number registered with the FAA on its fuselage so that the PI C, VO, or other observers will see the markings. This exemption will therefore not adversel y affect safety or will provide a lev el of safety equal to the existing rule.**14 CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations**

This section describes regulations concerning certification of pilots. We seek relief from this rule because the risks associated with the operation of a UAS are lesser than and often uncorrelated with the risks associated with the commercial and private aircraft operations contemplated by Part 61 when drafted. The skills required to fl y large, manned aircraft are substantially

different from the skills required to remotel y operate a small UAS. Also, manned aerial vehicles weighing significantly more than small drones (such as ultralight vehicles) as well as small UAS legally operated b y hobb yi sts, operate without th e need for pilot certification. R equiring a private or commercial pilot certificate would provide no appreciable safety benefit and would needlessl y impose an undue burden of time and cost on Quad City UAS Services , most particularl y in light of the FAA’s Small UAS Notice of Propose d Rulemaking which proposes that small UAS pilots be considered ‘operators’ required to meet certain requirements that do not include pilot’s license. Instead of following this requirement, to minimize risk and maximize safety , all UAS operations will be c ontrolled and limited, and all flights will be planned and coordinated prior to operations:  Prior to operations, Quad City UAS Services ’ PI C(s) will go through a documented process of dedicated ground school and flight lessons in accordance with manufacturer and industry

guides.  All PI C’s will only

operate the UAS as stated in this document and in our Flight Operations and Procedures Manual, fl yi ng at altitudes well below the permissible limits for other civil aircraft, and within a geographical envelope un der the control of Quad City UAS Services ’ clients.  The PI C will be designated before a flight and will not transfer control at any time during a flight.  Quad City

UAS Services ’ PI Cs will comply with upcoming FAA Operator Certification and Responsibilities once they are finalized. This exemption will therefore not adversely affect safet y or will provide a level of safety equal to the existing rule. More information about pilot safety can be found in the Operation of the Unmanned Aircraft to Minimize Risk to the NAS, People and Property section of this document. **14 FR 91.105 Flight crewmembers at stations**  This section outlines regulations for flight crewmembers inside an aircraft. We seek relief from this rule because there is no flight crew onboard a small UAS. Instead of following this requirement, in keeping with the direction of the regulation, the PIC of the UAS and VO will be at their respective crewmember stations on the ground during takeoff and landing as well as the complete duration of the flight. By instituting this procedure this exemption will therefore not adversel y affect safety or will provide a level of safety equal to the existing rule.**14 FR 91.109 (a) Flight Instruction** 

This section provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has full y functioning dual controls. We seek relief from this rule because UAS do not have full y functioning dual controls. Instead, flight control is accomplishe d through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without full y functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. This exemption will therefore not adversely affect safety or will provide a level of safety equal to the existing rule. **14 CFR 91.119 (c) Minimum safe altitudes: General.** This section establishes minimum altitudes for operation of civil aircraft . We seek relief from this rule because the services we intend to provide for the public good may require photo or video images captured from an altitude of less than 500 feet. Instead of following this requirement, all UAS flights will be conducted with w ithin visual line of sight and with prior permission from the owner of the property or muni cipality . All persons, vessels, vehicles, not directl y involved with the operation will be notified an d cleared of the area where UAS operations will be conducted. G iven our policies of advance notice and access restricted area, and given the size, weight, maneuverability

and speed of our UAS, we will maintain an equivalent or higher level of safet y of that described in this rule. **14 CFR 91.121 Altimeter settings** Thi s section defines regulations for altimeter settings. We seek relief from this rule concerning altimeter settings because: our UAS has no altimeter settings. Instead, electronic GPS downlinks telemetry data in real time to the PI C’s ground

- based on

screen display as to the altitude (AGL) of the UAS above the takeoff location. This exemption will not adversel y affect safety, as our PI C will provide a level of safet y equal to the existing rule by confirming the altitude of the launch site shown on the GPS alt itude indicator prior to each flight.**14 CFR 91.151 (a) Fuel Requirements for Flight in VFR Conditions**

This regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day , to fl y after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes .” We seek relief from this rule because our UAS runs on battery instead of fuel, most of our UAS flights last less than the 30 minute reserve requirement, and we do not fl y at n ight. Instead of following this requirement, an equivalent level of safety wi ll be achieved b y following the UAS manufacturer’s operating documents with regard to battery voltage. To ensure safety and maintain adequate communication between radio contol and the UAS, our PI C will not begin a flight with a battery holding less than 75% charge; and will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fl y to the intended landing point at normal cruising speed and land the UAS with no less than 30% of battery po wer. A landing sequenc e will be initiated at the 30% warning and the UAS automatically initiates landing sequence at 15% charge while still under PI C control. Through implementation of these procedures, this exemption will not adversely affect safet y or will provide a level of safet y equal to the existing rule. **14 CFR 91.203 Carrying Civil Aircraft Certification and Registration** This regulation pertains to display of airworthiness certification within an aircraft. We seek relief from this rule because our small UAS each weigh l ess than 10 poun ds, and are operated without an onboard pilot. There are passengers or crew; and no cabin or cockpit entran ce upon which to display certificates. An equivalent level of safety will be achieved by keeping these docume nts at the ground contro l point where the PIC will have immediate access to them, and be able to provide them upon request.**14 CFR 91.405 (a) Maintenance required; 14 CFR 91.407 (a) ( 1) Operation after** 

**maintenance, preventive maintenance, rebuilding, or alteration; 14 CFR**  **91.409 (a) (2) Inspections; and**  **14 CFR 91.417 (a) & (b) Maintenance records** We seek relief from these 4 rules because these regulations only appl y to aircraft with an airworthiness certificate, and will not, therefore, apply to Quad City

UAS Services UAS. We seek relief also because the FAA has not developed maintenance standards for UAS that would allow an UAS operator to meet the part 91 maintenance requirements. In parti cular, there are no individ uals authorized by

the FAA to approve a UAS for return to service or to co nduct the initial airworthiness and annual return to service inspections as required. Instead of following these requirements, we will:  P erform preventative and required maintenance on each aircraft as per the owner’s manuals.  Inspect our UAS before and after each flight as per our Flight Operations and Procedures Manual to ensure that the UAS is in a condition for safe flight.  W ill conduct a test flight on each aircraft following any major repairs.  W ill properly

note all discrepancies, maintenance, and alterations in a Maintenance Log. Therefore this exemption would not adversel y affect safety or would provide a level of safety equal to the existing rule. More information about mainte nance procedures can be found in the Operation of the Unmanned Aircraft to Minimize Risk to the NAS, People and Property section of this document. **14 CFR 91.7 (a) Civil aircraft airworthiness** This section states that “no person may operate a civil aircraft unless it is in an airworth y condition.” We seek relief from this rule based on the fact that Quad City UAS Services ’ UAS will not require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H. Based on the fact that an airworthiness certificate will not be issued, exemption from § 91.7(a) is not necessary

. An equivalent level of safety will be achieved through the guidance from our Flight Operations and Procedures Manual, pilot training, and operational risk management for each activity. **14 CFR 91.9 (b) Civil aircraft flight manual, marking, and placard requirements** This section requires an aircraft flight manual in the aircraft. We seek relief from this rule based on the small size of our UAS and the fact that our UAS carries no onboard pilots or passengers. Given its size and configuration there is no room or capacity in our UAS to carry s uch an item. This regulation is therefore inapplicable. An equivalent level of compliance will be achieved by keeping our ver sions of these documents at the ground control point where the PIC will have immediate access to th em, and be able to provide them upon request.**Public Benefit: how our request would benefit the public as a whole**

Granting Quad City

UAS Services the ability to operate small UAS saf el y and legally in the National Airspace Sy stem will have the following positive economic and societal impacts on local communities, businesses, organizations and community members:  benefit local business marketing b y offering state

- of

- the

- art aerial photography and videograph y  help to inspect buildings and structures, and map landscapes in a safe, cost

- effective manner  provide economic stimulus and public benefit b y providing an effective means b y which companies or individuals looking to relocate to an area can use up

- to
- date, high

- qualit y photos and videos of real estate properties to learn about properties, neighborhoods and communities  help communities realize economic benefit by encouraging public participation and encouraging tourism by

showcasing community

buildings and landscapes and by documenting community events in low

- cost way s not previously available to them  increase awareness/knowledge of the amenities of a local area by the general public and by visiting tourists  provide non - profit organizations as well as schools and universities and local municipalities in way s to showcase facilities, document events, and educate the public  aid in search and rescue operations and a ccident investigations All of the above services:  are otherwise unavailable to the public, given the UAS’s the ability to: o S afely capture images from 0 to 400 feet. o C reate images that are more up

- to
- date and more closely defined than Google Earth

ty pe satellite images. o C reate images at prices lower than that of traditional helicopter and airplane photograph y and videography.  Increase safet y of and reduce risk to the public and the NAS by: o R eplacing large manned helicopter and airplane flights with small UAS flights, thereb y reducing air and noise pollution as well as the dangers inherent in flying aircraft loaded with crewmembers and combustible fuel close to people and property. o O ffering safer way s to inspect tall structures and remote locations, e.g. removing the phy sical risk of climbing on a roof or structure to inspect it.  R educe environmental pollution and reliance on fossil fuels by replacing fueled aircraft flights with battery

- operated UAS flights.**Operation of the Unmanned Aircraft to Minimize Risk to the NAS, People and**

**Property** Concerning our commercial UAS flight operations, we take seriously our obligation to clearly define operational borders, and implement operational risk management procedures to ensure the public safety of persons and property both in the air and on the ground. While Quad City UAS Services currentl y provides photograph y and videograph y services in Northern Arizona, we may at times contract with clients throughout the U.S. Our area of intended operations include a range of population areas, from urban to rural, with som e areas, especiall y coastal ones, experiencing seasonal increases and decreases in activity from both people and aircraft. Our operations will take into account these variations in populations and activities. My rotorcraft experience (Commercial Pilot Roto rcraft enables me to apply operational risk management techniques when assessing situations where the safety of the general population and the NAS are concerned. Meeting or exceeding COA requirements to perform commercial ope rations in low

- risk, controlle d environments, our UAS will be operated: ● D uring daytime Visual Flight Rules (VFR) conditions and visual meteorological conditions (VMC). ● W ithin visual line of sight (VLOS) of the Pilot in Command (PI C) or the Visual Observer (VO), in accordance with the statutory Section 333(b)(1) mandate. ● In such a manner that the PI C and VO are able to communicate verbally at all times; and that the VO can assist the PI C with seeing and avoiding other air traffic and other ground

- based obstacles/obstructions. We will not operate our UAS: ● At altitudes exceeding 400 feet AGL ● In winds exceeding 25 knots. ● F rom any

moving vehicle or device. ● At airspeeds greater than the maximum recommended b y the manufacturer. ● L ess than 500 feet below or less than 2000 feet horizontall y fro m a cloud or when visibility is less than 3 statute miles from the PI C. ● Unless (considering wind and forecast weather conditions) there is enough available power for the UAS to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater. ● N ear areas where general public is within 200 feet; or directl y over an y person except authorized Quad City

UAS Services personnel and consenti ng inspection personnel, unless operations nearer to the PI C do not present an undue hazard to those persons; or unless the owner/controller of an y vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it d oes not present an undue hazard near power lines, wind turbines, or elevated lights; or within areas of airspace restrictions such as the one imposed by the National Park Service.● N ear airports, heliports, or military bases; more specificall y: o In accordance with the statutory Section 333 mandate regarding proximity to airports, we will stay

certain distances away

from airports or heliports: 5 NM from an airport having an operational control tower; or 3 NM from airport w/ a published instrument flight procedure, but not operational tower; or 2 NM from an airport w/out published instrument flight procedure or an operational tower; or 2 NM from a heliport with a published instrument flight procedure. o We will not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory

(AFD) or for airports not denoted with an ARP, the center of the airport s ymbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management will be made avail able to the Administrator or an y law enforcement official upon request.  If we intend to conduct operations in controlled airspaces which have existing requirements to notify

Flight Standards District Offices (FSDOs) prior to operations

– such as motion picture and television filming, or pipeline and power line patrol

– we will contact the local FSDO and comply with their procedures, such as filing a NOTAM as per their request **Our Flight Operations and Procedures Manual, will include procedures for:**  C ond ucting a preflight safety

risk assessment to determine that the UAS is in a condition for safe flight, i.e. completing a preflight inspection checklist to ensure the UAS’s airworthiness. If the inspection reveals a condition that affects the safe operation of the UAS and/or the Ground Control Station, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.  M aintaining a Flight Log (noting UAS flight time, Control Unit operation time, incident reports, etc.); and making said Log available to the FAA if requested.  conducting initial and ongoing training of PICs and VOs, to include classroom training, and training, proficiency

and experience

- building flights; all persons not essential for flight operations will be considered nonparticipants, and the PI C will operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR 91.119.  E valuating the operational abilities of PI Cs and VOs on a regular basis.  maintaining and repairing the aircraft to ensure that it is in a condition for safe operation by : o F ollowing the UAS manuf acturer’s maintenance, overhaul replacement inspection, and life limit requirements and safety bulletins for the aircraf t and its components. o Installing firmware updates provided by the manufacturer. o K eeping a Maintenance Log noting all maintenance, inspection, alterations, and status of replacement/overhaul component parts in the aircraft records, including total time in s ervice, description of work, and signature of the authorized person returning the UAS to service; and making said Log available to the FAA if requested. o V erifying condition of flight batteries and calibrating the Inertial Measurement Unit (IMU) using manuf

acturer software.o C onducting a functional test flight on an y UAS that has undergone maintenance or alterations that affect the UAS operation; said functional test flight will be conducted by a PIC with a VO and so as to not pose an undue hazard to persons and property; and recorded in the aircraft records. ● P rocedures that ensure that the planned operation can be completed safely, such as:

o C hecking local sectional (air) charts, notam (notice to airmen), etc. prior to the flight. o C onducting a pre

- flight visual survey of the area to consider characteristics of the area of intended operation(s) and the associated potential hazards regarding proximity to populated areas. o R emaining clear and giving way to all manned aviation operations and activities at all times. o Aborting a flight and landing the UAS at the nearest and safest ground point in the event of safety breaches, potential danger, unpredicted obstacles or emergencies. o U sing a fresh, fully

- charged battery with each flight as a sa fet y precaution, to ensure safet y and maintain adequate communication between radio contol and the UAS; and not operating our UAS at or below manufacturer recommend minimum charge levels for operation. Also: ● Flight operations will be performed onl y at the request of and with the authorization and permission of clients (property owner/controller) or their authorized representatives. ● Caution signs will be placed at the site of aerial operatio ns to warn people that aircraft operations are in progress. ● Our Client Agreements will reserve us the right to decline a p hoto shoot if conditions of the location (e.g. proximity

of power lines) may

cause unaccep table risk; and to reschedule a photo shoot if weather conditions such as precipitation or wind speed be come a factor. ● The operating documents for our UAS, and an y revisions , will be accessible during UAS operations and made available to the Administrator or law enforcement official upon request. ● We will carry comprehensive general liability insurance cov er age and an additional insurance policy specificall y covering our UAS. **Summary for Federal Register** Stephen Marshall of Quad City UAS Services LLC , Prescott Valley , Arizona, seeks exemption from Federal Aviation Regulations pursuant to 14 C.F.R. and Section 333 of the F AA Modernization and Reform Act of 2012 for the purpose of commerciall y operating small Unmanned Ai rcraft Sy stems (UAS) safel y and legally in the National Airspace S ys tem. Specificall y, Quad Cit y UAS Services seeks relief from the following sections of the current regulations: 14 CFR 21 subpart H

- Certification procedures; Airworthiness Certific ates; 14 CFR 45.23

- Display of Marks ; 14 CFR 61.113 (a) & (b) Private Pilot Privileges and Lim itations ; 14 CFR 91 .105 Flight crewmembers at stations ; 14 CFR 91.109 (a) Flight instruction ; 14 CFR 91.119 (c) Minimum safe altitudes ; 14 CFR 91.121

- Altimeter settings ; 14 CFR 91.151 (a)

- Fuel Requirements for Flight in VFR Conditions ; 14 CFR 91.203 Carrying Civil A ircraft Certification and Registration ; 14 CFR 91.405(a) 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2)Maintenance require d; Operation after maintenance, preventive maintenance, rebuilding or

alteration; 14 CFR 91.41 7 (a)&(b ) Maintenance Records; 14 CFR 9 1.7 (a)

- Civil Aircraft Airworthiness ; 14 CFR 91.9 (b) Civil aircraft flight manual, marking, and placard requirements. Quad City

UAS Services intends to use small UAS to provide aerial photo graph y and videograph y services to businesses, organizations an d community members. More specifically , we intend to: ● enable businesses to benefit through the use of state

- of

- the

- art visual marketing materials ● help to inspect buildings and structures, and map landscapes in a safe, cost

- effective manner ● provide ec onomic stimulus and public benefit by providing an effective means by which companies or individuals can use up

- to
- date, high

- quality photos and videos to learn about properties, neighborhoods and communities ● H elp communities realize economic benefit b y encouraging public participation and encouraging tourism; b y showcasing community buildings and landscapes; and by documenting community events in low

- cost way s not previously available to them ● Increase awareness/knowledge of the amenities of a l ocal are a b y the general public and by visiting tourists ● P rovide non

- profit organizations as well as sch ools and universities and local municipalities way s to showcase facilities, document events, and educate the public ● A id in search and rescue operations and accident investigators. The enhanced safety achieved using an UAS with the specifications de scribed herein, and carryi ng no passengers or crew, rather than a manned aircraft of significantly gre ater proportions, carryi ng crew in addition to flammable fuel, should give the FAA good cause to fin d that such exemption is in the public interest. By granting this requ est for exemption, the FAA will facilitate the smooth integration of UAS into the NAS. **Additional Information Design Characteristics, Aircraft**  **Performance and Performance Limitations, and Conditions of UAS to be O**  **perated** UAS Described Below ● Utilize 4 counter

- rotating propellers for balance, control and stability ● Are equipped with GPS to maintain geospatial orientation and position ● U se Return Home safety technology and Auto Landing feature if UAS loses transmitter signal ● are controlled primarily through FCC approved RF spectrum transmitter/controller/receivers; and FCC approved RF spectrum EIRP with transmitting pow er of 100 mW for dedicated wifi transmitter/receiver between sUAS, Range Extender att ached to transmitter and mobile viewing device displaying operational telemetry and video/photography

functions. ● S end real time video and telemetry information is trans mitted back to a ground control station, allowing PIC to monitor battery level, GPS signal str ength, altitude (AGL), distance from PIC, camera imagery , and control camera angle. ● H ave failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude can be preprogrammed by the PIC. ● H ave audible and visual sequential low battery warnings set at 30% charge and 15% charge remaining. The S UAS automatically initiates landing sequence at 15% charge while still underPI C control. The onboard flight controller will warn the p ilot via telemetry and external lighting cues before reaching a low battery state. An auto matic termination of flight and landing will be initiated when the battery reaches a predetermin ed low state. **DJI Phantom 3 Professional** ● Gross weight of less than 3 pounds including camera and battery ● Cruising speed of 15 knots, with a maximum speed of 31 knots and maximum altitude of 6000m ● Maximum flight time of 23 minutes ● FCC compliant Radio Frequency (RF) spectrum 2.400 GHz2.483 GHz ● M anual available at http://www.dji.com/product/phantom

- 3/download