The s UAS

The Petitioner currently operates one model of aircraft: the DJI Phantom 3

Professional . The market for aerial imagery is rapidly evolving, and there are market forces which pressure vendors to constantly upgrade equipment. These facts, combined with the length of time it takes to receive a grant of exemption,

may make it difficult to operate in the market with current equipment: by the time

the exemption for the specific aircraft is granted, those aircraft may very likely be

outdated and/or obsol ete. Therefore, The Petitioner requests that any exemption granted extend not only to aircraft currently owned by The Petitioner , but also to

any future sUASs owned by The Petitioner that meet the following criteria:

1. The sUAS is manufactured by DJI.

2. The sUAS weighs no more than 10 lbs. at takeoff. 3. The sUAS has GPS capability which aids its flight.

or 1. The sUAS has already been approved for commercial use by a published FAA

Grant of Exemption. E.g. the SenseFly eBee permitted in Exemption No. 111 36,

Advanced Aviation Solutions.

Without abandoning the above request, The Petitioner explicitly requests the exemption allow th e operation of the DJI Phantom 3 Professional. This

sUAS is battery

- operated multirotor aircraft weighing less than 10 lbs.

R espectively, the sUAS employed by The Petitioner has the following specifications:

Airframe: DJI Phantom 3 Flight Control System: The built

- in flight control system contains the MC (main controller), GPS + GLONASS processor, IMU (inertial measurement unit) and compass. The MC is the brains of the system, receiving thousands of bits of data each second and translating that data for optimal flight stability. The GPS processor now includes the capability to receive signals from the Russian

- built

GLONASS satell ites, which improves positioning accuracy and quicker satellite acquisition. The IMU contains a 6

- axis gyroscope as well as an accelerometer.

Max takeoff weight: 2.9 lbs. Max flight speed: 31 knots Max ascent/descent speed: 16.4 ft/sec; 9.8 ft /sec

Batter y type: PH3

- 4480 mAh

- 15.2V

The Phantom 3 Professional has a sophisticated failsafe function. The Phantom

3 Professional continuously estimates the amount of battery power required to fly

the aircraft back to the Home Point. Once this level of battery powe r is reached, a message will appear within the flight control program alerting the operator. The

Petitioner will always attempt to return the aircraft to the Home Point when thismessage appears. If no action is taken, the aircraft will automatically fly u p to a

pre

- set altitude, then fly to the Home Point and land (this is the return

- to

- home function or RTH). Additionally, the flight software will automatically conduct an RTH if the signal from the remote controller is lost for more than three seconds.

B efore each flight, the operator will inspect the area where the flight will take place and note the tallest obstruction. The operator will then set the failsafe altitude to a height greater than the tallest object in the area.

This sUAS has a limited rang e due to the physical limitations of the transmissions from the remote controller. In field conditions, this limited range is generally not greater than 1,000

- 1,200 meters or roughly 3,300

- 3,900 feet. The sUAS has the capability for a maximum altitude to b e set prior to each flight. This is a separate setting from the maximum altitudes which are unchangeable and are set by the manufacturer from the factory. Using GPS data to determine altitude, the sUAS will not violate either of these altitude limit parame ters. The Phantom 3

Professional sUAS has the ability to conduct a pre

- programmed, automated flight pattern from takeoff to landing. The aircraft will take off from a designated point and fly in a straight line to various wa ypoints in sequence. It is this automated flight function which allows the sUAS to take geo

- referenced photographs for survey

- grade photogrammetry and other analytics.