September 18, 2015

U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE, Washington, DC 20590

RE: A Petition for Exemption Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012

Dear gentleperson: Satori Realty Advisors, Inc. 54052 Alton Pkwy #A303 Irvine, CA 92604 www.satori-realty.com (949) 273-0966

Satori Realty Advisors, Inc. (dba. Satori Advisors), a California corporation in good legal standing (hereinafter, "Petitioner"), hereby seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft Systempursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit Petitionerto operate an Unmanned Aircraft System (UAS) for the commercial purpose ofconducting aerial video and still photography over certain areas ofthe United States. The exemption is basedupon information outlined in this petition, Petitioner's enclosed Unmanned Aerial Systems Guidelines, the DJI UAS manufacturers manuals and guides, and any other requirements established by the FAA pursuantto Section 333 ofthe Reform Act. In closing, you are invited to contact me anytime atyour convenience should you have any questions. Thankyou for your invaluable time and consideration. Yours very sincerely and respectfully submitted,

# ~ Executive Managing Director Satori Realty Advisors, Inc.UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory DocketNo:

IN THE MATTER OF THE PETITION FOREXEMPTION OF: Gary J. Clayman and Satori Realty Advisors, Inc. (dba. Satori Advisors) FORAN EXEMPTION SEEKINGRELIEF FROMTHE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l),

91.409(a)(l) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 3 PROFESSIONAL UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAAMODERNIZATIONAND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on September 18th, 2015 Gary J Clayman Executive ManagingDirector

Satori Realty Advisors, Inc. 5405 Alton Pkwy#A303 Irvine, California 92604 (949) 273-0966

### TABLE OF CONTENTS

INTRODUCTIONAND INTERESTS OF PETITIONER

...............................................................

### ! BACKGROUND

......................................................................................................................2 BASISFORPETITION

............................................................................................................3 NAMEAND ADDRESS OFTHEPETITIONER

..........................................................................4 THE SPECIFIC SECTIONS OF 14 C.F.R.FROMWHICHPETITIONERSEEK EXEMPTION

.........................................................................................................................

### 5 THEEXTENT OFRELIEFPETITIONERSEEKS

### AND THEREASON PETITIONER SEEKS THERELIEF
..............................................................................................................8 A SUMMARY THAT CANBEPUBLISHED INTHEFEDERALREGISTER, STATING: THERULESFROMWHICHPETITIONERSEEKSEXEMPTION

...........................................27 ANYADDITIONAL INFORMATION, VIEWS, ORARGUMENTS AVAILABLE TO SUPPORTPETITIONER'S REQUEST

....................................................................................27 CONCLUSION

.....................................................................................................................27 GLOSSARY OF ABBREVIATIONS

........................................................................................29 APPENDICES

.......................................................................................................................30 EXHIBITA

....................................................................................................................31 EXHIBITB
....................................................................................................................32 ExHIBIT

## c....................................................................................................................33 EXHIBITD
....................................................................................................................34 EXHIBIT E
....................................................................................................................351of35 INTRODUCTIONAND INTERESTS OF PETITIONER The contact information for Petitioner is as follows: Gary J. Clayman Executive Managing Director Satori Realty Advisors, Inc. 5405 Alton Pkwy#A303 Irvine, California 92604 (949) 273-0966 gary.clayman@satori-realty.com Petitionerpossesses over20-years in providing its clientele with complex real estate advisory and valuations throughout the United States; Petitioner is recognized throughout the United States as an expert in the areas ofcost segregation, valuation, and in the analysis of: Highest & BestUse, site selection, competitive market, buy versus lease, litigation support, and financial modeling (Argus). Throughoutthe course of20-years, Petitionerhas been required-pursuantto the terms ofPetitioner's engagement lettersto produce complex real estate (interior and exterior) photography and video utilizing state ofthe arttechnology. Petitionerhas over 2 years recreational/hobby experience in all aspects ofaerial video andphotography. The objective ofPetitioner's aerial video and photography operations is to provide high quality imaging for a variety ofcommercial, residential uses, private andpublic, specifically targeting: 

# • Aerial acquisitions used in the analysis of: 

## • Site selection 

## • Competitive market 

## • Highest & BestUse 

## • Surveys 

## • Encroachments 

## • Topography 

## • Mapping 

## • Litigation Support
• Aerial acquisitions used for physical inspections ofprivate andpublic structures2of35 • Demonstration (and training) flights
• Infomercial filming
• News gathering
• Real Estate Marketing
• Real Estate Valuations (ofcommercial, residential and public real estate)
• Litigation Support
• Search and Rescue
• Wildlife surveys • And/or any otherrelated entities/activities that can utilize the safe and efficient operation ofthe UAS Petitioner's goal is to operate in an accident-free environmentby:

• Ensuring for the propertraining on the latest safety procedures for the UASs operate as well as Petitioner's safety procedures outlined in the Operations Manual.
• Being proactive when performing pre-flight operations and identifying any potential safety hazards.
• Demonstrating the ability to identify and appropriately eliminate hazards and risks to the aircraft as well as persons involved in the flight.



### BACKGROUND Unmanned Aircraft Systems: DJI Phantom 3 Professional UASs Petitioner, seeks an exemption to operate DJI systems for compensation orhire within the NAS. The DJI Phantom 3 Professional (hereinafter, "PHANTOM 3") UASs is a vertical takeoffand landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing an iOS (Apple) or Android handheld device. The PHANTOM 3 has a maximum gross weight ofapproximately 2 pounds 12 ounces, while having a length of 16 inches width of 16 inches, height of8 inches, and a maximum speed of approximately 29 knots. The PHANTOM 3 UAs is equipped with four main rotors; driven by Lithium Polymerbattery powered electric motors.3of35 BASIS FOR PETITION Petitioner, pursuant to the provisions ofthe Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the PHANTOM 3 UASs in the National Airspace System (NAS), and for an exemption from the 6 requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). In consideration ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Petitioner operation ofPHANTOM 3 UASs meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Petitioner requests relieffrom Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Petitioner submits thatthe requested reliefis proper since an equivalent level of safety will be ensured. Petitioner will use experienced personnel ortechnicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and PHANTOM 3 Instruction Manual). Furthermore, Petitionerwill document and maintain all maintenance records for the PHANTOM 3 UASs. Relieffrom certain requirements ofSection 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by Petitionerto the extent necessary to allow a Pilot in Command (PIC) not holding a certificate, or an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, thatthe PIC is able to safely operate the PHANTOM 3 UASs in a manner consistentwith this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.4of35 Petitioner seeks relieffrom Section 91.7(a), entitled Civil aircraft airworthiness, because the PHANTOM 3 UASs do not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, Subpart H. As such, Petitioner submits that he will ensure thatthe PHANTOM 3 UASs are in an airworthy condition, priorto every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and PHANTOM 3 Instruction Manual), andthatthe aircraft are in a condition for safe flight. Petitioner also seeks an exemption from the requirements ofSection 91.121, entitled Altimeter Settings, as the PHANTOM 3 UAs will not have a typical barometric altimeter onboard. However, altitude information ofthe PHANTOM 3 UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combinedwith Petitioner's operation ofthe PHANTOM 3 UASs within visual line ofsight, at orbelow 400 feet AGL, will ensure a level ofsafety equivalentto Section 91.121. Additionally, Petitioner seeks an exemption from the requirements ofSection 91.151 (b), entitled Fuel requirements for flight in VFR conditions. Petitioner submits that safety will notbe affected by operation ofthe PHANTOM 3 UAs during daylighthours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration ofapproximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly afterthat for at least 4.5 minutes. In accordance with 14 C.P.R. § 11.81, Petitionerprovides the following information in support ofits petition for exemption:
NAME AND ADDRESS OFTHE PETITIONER The name and address ofthe Petitioner and point ofcontactis: Gary

### J. Clayman Executive Managing Director Satori Realty Advisors, Inc. 5405 Alton Pkwy #A3035of 35 Irvine, California 92604 Email:gary.clayman@satori-realty.com (949) 273-0966

THE SPECIFIC SECTIONS OF 

### 14 C.F.R. FROMWHICH PETITIONER SEEK EXEMPTION 

### 1. Petitioner Seeks Exemption From The Requirements Of Section 61.113(a) and (b). Section 61.113, entitled Private pilotprivileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) ofan aircraft that is carrying passengers orproperty for compensation or hire; nor may thatperson, for compensation orhire, act as PIC ofan aircraft. (b) A private pilot may, for compensation orhire, act as PIC ofan aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carrypassengers orproperty for compensation orhire. 

### 2. Petitioner Seeks Exemption From The Requirements OfSection 91.7(a). Section 91.7, entitled Civil Aircraft Airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition. 

### 3. Petitioner Seeks Exemption From The Requirements OfSection 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude orflight level ofthat aircraft, as the case may be, by reference to an altimeterthat is set, when operating: (1) Below 18,000 feet MSL, to: (i) The currentreported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft;6of35 (ii) Ifthere is no station within the area prescribed in paragraph (a)(l)(i) ofthis section, the currentreported altimeter setting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure. 

### 4. Petitioner Seeks Exemption From The Requirements OfSection 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) Noperson may begin a flight in a rotorcraft under VFR conditions unless (considering windand forecast weather conditions) there is enoughfuel tofly to the first point of intended landingand, assuming normal cruising speed, tofly after that for at least 20minutes. 

### 5. Petitioner Seeks Exemption From The Requirement OfSection 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator ofan aircraft: (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter[.] 

### 6. Petitioner Seeks Exemption From The Requirements OfSection 91.407(a)(l) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(l), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless: (1) Ithas been approved for return to service by a person authorized under § 43.7 ofthis chapter[.] 

### 7. Petitioner Seeks Exemption From The Requirements OfSections 91.409(a)(l) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the following:7of 35 

### (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had: (1) An annual inspection in accordance with part43 ofthis chapter and has been approved for return to service by a person authorized by§ 43.7 ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. 8. Petitioner Seeks Exemption From The Requirements OfSections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state following: (a) Except for work performed in accordance with § § 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section: (1) 

### Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 1 

### 00-hour, annual, progressive, and otherrequired or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include: (i) A description (or reference to data acceptable to the Administrator) ofthe work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor. (ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofall items installed on the aircraft which are required to be overhauled on a specified time basis.8of35 (iv) The current inspection status ofthe aircraft, includingthe time since the last inspection required bythe inspectionprogram under whichthe aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by§ 43.9(d) ofthis chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owneror operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) ofthis section shall be retained until the work is repeated or superseded by otherwork orfor 1 year afterthe work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owneror operatorunder§ 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

THE EXTENT OFRELIEF PETITIONER SEEKSANDTHEREASON PETITIONER SEEKSTHERELIEF 

### 1. Extent OfReliefPetitionerSeeks And TheReason Petitioner Seeks Relief From Section 61.113(a) And (b). Relieffrom Section 61.113(a) and (b) entitled Private pilotprivileges and limitations: Pilot in command, is requested to the extentnecessary to allow a PIC notholding any pilot certificate, or a current and valid airman medical certificate, but who has metcertain flight-hour and currency requirements, to conductthe proposed UAS flight operations for compensation orhire. This reliefis requested since the limitations setforth in Section 61.113(a) and (b) state that a private pilotmay, for compensation orhire, act as PIC ofan aircraft in9of 35 connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers orproperty for compensation orhire.
As set forth more fully below, Petitioner submits that an equivalent level ofsafety will be maintained because no PIC will be allowed to operate the PHANTOM 3 UAS unless that PIC has metcertain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate the PHANTOM 3 in a manner consistentwiththe operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Petitioner submits that all flights ofthe PHANTOM 3 UASs, conducted by the PIC pursuantto the grant ofthis Petition: (1) will be incidental to Petitioner's business; and (2) will not carry passengers orproperty for compensation orhire. 

### 2. Extent OfReliefPetitioner Seeks And The Reason Petitioner Seeks Relief From Section 91.7(a). Relieffrom Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Petitionerto determine thatthe PHANTOM 3 UASs are in airworthy condition priorto every flight by ensuringthatthe UAS is in compliance with the operating documents (i.e., the Petitioner Aerial Operations Manual, Monthly Maintenance Log, and DJI PHANTOM 3 Professional Instruction Manual).
Petitioner seeks the requested reliefbecause the PHANTOM 3 UASs do not require
an airworthiness certificate in accordance with 14 C.F.R. Part21, Subpart H. Therefore, Petitionerwill ensure thatthe PHANTOM 3 UASs are in airworthy condition based upon its compliance with operating documents (i.e., Monthly Maintenance Log, and DJI PHANTOM 3 Professional Instruction Manual) priorto every flight, and further, determine thatthe aircraft are in condition for safe flight, as stated in the conditions and limitations below. 

### 3. Extent OfReliefPetitioner, Seeks From Section 91.121.10 of35 Relieffrom Section 91.121, entitled Altimeter settings, may be required to allow flight operations ofthe PHANTOM 3 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Petitioner seeks the requested reliefbecause PHANTOM 3 UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or altitude, before each flight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 91.121 is soughtto the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level ofsafety will be maintained since the PHANTOM 3 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established priorto each flight, and provides the PIC with altitude information ofthe UA on the heads-up display ofthe GCS. 4. Extent OfReliefPetitioner Seeks And The Reason Petitioner Seeks Relief From Section 91.151(b). Relieffrom Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights ofthe batterypoweredby the PHANTOM 3 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the firstpoint of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Petitioner seeks the requested reliefbecause without an exemption from Section 91.151(b), the flight time duration ofthebattery powered PHANTOM 3 UAs will severely constrain the practicality ofany aerial video or still photo flight operations that Petitioner proposes to conduct pursuantto this Petition. Significantly, as set forth below, the technical specifications ofthe PHANTOM 3 UASs, the PHANTOM 3 operating documents, and Petitioner's operating limitations,
ensure thatPetitionerwill safely operate the battery powered PHANTOM 3 UAs during11 of35 daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery powerto fly for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least4.5 minutes. 

### 5. Extent OfReliefPetitioner Seeks And The Reason Petitioner Seeks Relief From Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

### (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Petitioner requests relieffrom these Sections because the PHANTOM 3 UASs do not require airworthiness certificates. As set forth more fully below, the PHANTOM 3 UASs meetthe conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, Petitioner will use trained technicians to perform maintenance, alterations, orpreventive maintenance onthe UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the PetitionerAerial Operations Manual, Monthly Maintenance Log, and PHANTOM 3 Instruction Manual). Furthermore, Petitioner will document and maintain all maintenance records for the PHANTOM 3 UASs.

THE REASONSWHY GRANTING PETITIONERREQUEST WOULD BE IN THE PUBLIC INTEREST; THAT Is, HOWITWOULD BENEFIT THE PUBLIC ASA WHOLE Granting the present Petition will further the public interest by allowing Petitionerto safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas ofthe United States. Additionally, use ofthe PHANTOM 3 UASs will decrease congestion oftheNAS, reduce pollution, and provide significantbenefits to the economy. Notably, the benefits ofPetitioner's proposed operation ofthe PHANTOM 3 UASs will be realized without implicating any privacy issues. 

### 1. ThePublicWill BenefitFrom Decreased Congestion OfThe NAS. The PHANTOM 3 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial12 of35 imagery. Byreducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa PHANTOM 3 UAS wouldreduce the amount ofmanned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety oflife andproperty in the air and onthe ground. Furthermore, by reducing the number ofmanned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The PHANTOM 3 UAs do not require an airport to takeoffor land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraftthatmust be handled by airtraffic control during the ground, takeoff, departure, arrival, and landing phases offlight operations. 

### 2. The PublicWill BenefitFrom The Safety And Efficiency OfThe PHANTOM 3 UASs. Conducting aerial acquisitions withthe PHANTOM 3 UASs, instead ofmanned aircraft, will greatly benefitthe public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the PHANTOM 3 UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour ofleaded aviation fuel. PHANTOM 3 UAs, while reducing the carbon footprint ofaerial acquisitions, also eliminate noise pollution, as the UAs are propelled bybattery powered electric motors, ratherthan an internal combustion engine. By using the PHANTOM 3 UASs to perform aerial acquisitions, the substantial risk to life and property inthe air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack offlight crew members located on boardthe aircraft, the PHANTOM 3 UAs (weighing approximately 2 pounds 12 ounces, at their maximum gross weights with lengths and widths of 16 inches, and with no fuel on board), has less physical potential for collateral damage to life andproperty onthe ground, and in the air,13 of35 compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of34 feet, and a fuel capacity of 180 gallons). 

### 3. Performing AerialVideo and Photography OperationsWith The PHANTOM 3 UASs Will BenefitTheEconomy. In addition to being safe and efficient, the PHANTOM 3 UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation ofthe PHANTOM 3 UASs will allow United States based companies, like Petitioner, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost ofaviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in orderto remain competitive. Operating the battery powered PHANTOM 3 UASs is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, butprovides such flexibility without the high operational cost ofa traditional manned aircraft. By operating the PHANTOM 3 UASs, companies such as Petitioner, canremain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performance ofU.S. companies, through commercial use ofthe PHANTOM 3 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.


### 4. ThereAre No Privacy Issues. Similarto the manned aerial acquisition flight operations thathave been conducted for decades, Petitioner's proposed operation ofthe PHANTOM 3 UASs will not implicate any privacy issues. Specifically, the PHANTOM 3 UASs will be operated only in compliance with operating documents (i.e., the Petitioner's Aerial Operations Manual, Monthly Maintenance Log, and PHANTOM 3 Instruction Manual) which requires14 of35 property owner involvement as well as local law enforcementnotification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

THE REASONSWHY GRANTING THEEXEMPTION WOULDNOT ADVERSELY AFFECT SAFETY, ORHOW THE EXEMPTIONWOULD PROVIDEA LEVEL OF SAFETYAT LEAST EQUAL TO THAT PROVIDEDBYTHE RULE FROMWHICH PETITIONERSEEKSEXEMPTION 1. 

### Reasons Why The PHANTOM3 UAs MeetThe Conditions OfTheFAA Modernization and Reform Act of2012 (FMRA) Section 333. In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Petitioner operation ofthe PHANTOM 3 UASs meet the conditions ofFMRA Section 333, and will notrequire an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.--Notwithstandingany other requirement of this subtitle, andnot later than 180 days after the date of enactment of thisAct, the Secretary of Transportation shalldetermine 

### if certain unmannedaircraftsystems may operate safely in the nationalairspace system before completion of theplan and rulemaking required by section 332 of thisActorthe guidance required by section 334 of thisAct. (b) Assessment ofUnmannedAircraftSystems.--In making the determination under subsection (a), the Secretary shalldetermine, ata minimum- (1) which types of unmannedaircraftsystems, 

### if any, as a result of theirsize, weight, speed, operational capability,proximity to airports andpopulated areas, andoperation within visual line of sightdo not create a hazardto users of the nationalairspace system or thepublic orposea threat to nationalsecurity; and (2) whethera certificate of waiver, certificate of authorization, orairworthiness certification undersection 44704 of title 49, United States Code, is required15 of35 for the operation of unmannedaircraftsystems identified underparagraph (1). (c) Requirements for Safe Operation.--Jfthe Secretary determines under this section that certain unmannedaircraftsystems may operatesafely in the nationalairspace system, the Secretary shallestablish requirements for the safe operation of such aircraftsystems in the nationalairspace system. In seekingthis exemption, Petitioner submits that the PHANTOM 3 UASs can operate safely in the NAS pursuantto FMRA Section 333, as demonstrated by: (a) the characteristics ofthe PHANTOM 3 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations. 

### (a) The Specifications OfThePHANTOM 3 UASs DemonstrateIts Safe Characteristics. The PHANTOM 3 UASs do not create a hazard to users ofthe NAS orthe public, or otherwise pose a threatto national security considering its size, weight, speed, and operational capability.
1. 

### Technical Specifications OfThePHANTOM 3 UASs. The technical specifications ofthe PHANTOM 3 UASs are set forth by the PHANTOM 3 Specifications, attached hereto as ExhibitA.


### 2. The PHANTOM3 UASs Autonomous FlightAnd Navigation Modes EnableThe UASs To Remain Within A Defined OperationalArea. The PHANTOM 3 UASs may be operated in both manual and fully autonomous flight modes. A complete description ofthe flight and navigational modes ofthe PHANTOM 3 UASs is provided at pages 39-47 ofthe PHANTOM 3 User Manual, attached hereto as Exhibit B. 

### 3. The PHANTOM3 UASs Are Designed ForAutomatic Return To Home Point OrHoverIn The Event OfLoss OfThe ControlLinkOr Navigation. When the Control Link is lost, the PHANTOM 3 UAs will remain stationary, in flight, for 3 seconds ormore. If, after 3 seconds, the PHANTOM 3 UAs do notreacquire16 of35 control link data from the GCS, the UAs will assume thatthe Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoffposition and shutdown.
A complete description ofthe Failsafe Functions ofthe PHANTOM 3 UAS are set forth atpage 14 ofthe PHANTOM 3 User Manual, attached hereto as Exhibit B.


### 4. The PHANTOM 3 GCS And Its Operation. A complete description ofthe operation and specifications ofthe PHANTOM 3 GCS and flight control software is provided at pages 35 through 39 ofthe PHANTOM 3 UserManual. PHANTOM 3 User Manual is attached hereto as Exhibit B. 

### (b) Flight Operations OfPHANTOM3 UASs Are Limited To TheLine OfSight OfA Pilot in Command With A Safety Observer. Petitionerwill only utilize pilots who have at least 20 hours flight time to act as a pilot in command (PIC) ofthe PHANTOM 3 UASs. Additionally, a safety observer will assist all pilots during flight time. 

### (c) Flights OfPHANTOM3 UASs WillBe Conducted PursuantTo Specific OperatingLimitations. In seeking this exemption, Petitioner proposes to commercially operate PHANTOM 3 UASs for the special purpose ofconducting aerial video and photography overcertain
areas ofUnited States, pursuantto the following specific operating limitations:
1. Operations authorized by this grant ofexemption will be limitedto the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: PHANTOM 3 Unmanned Aircraft Systems. Proposed operations ofany other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose ofaerial video and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.17 of35 4. The UA must be operated at an altitude ofno more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device otherthan corrective lenses, as specified on the PIC's FAA-issued airman medical certificate. 6. The use offirst person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging ortexting is notpermitted during flight operations. The PIC must be designated before the flight and cannottransfer his or her designation for the duration ofthe flight. The PIC must ensure that the SO canperform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permittedto operate the camera or other instruments. 9. The operating documents and the grant ofexemption mustbe accessible during UAS operations and made available to the Administratorupon request. Ifa discrepancy exists between the conditions and limitations contained in the grant ofexemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update orrevise its operating documents. Itis the operator's responsibility to track such revisions and present updated and revised documents to the Administratorupon request. The operator must also present updated and revised documents ifit petitions for extension or amendment to the grant ofexemption. Ifthe operator determines that any update orrevision would affect the basis upon which the FAA granted the exemption, thenthe operator must petition for amendmentto its grant of exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates orrevisions to the operating documents. 10. Priorto each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station mustbe included in the preflight18 of35 inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affectthe UAS operation orflight characteristics, e.g. replacement ofa flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraftrecords. 12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections ofthe operating documents. 13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul componentparts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature ofthe authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 17. The PIC must have completed at least 25 hours offlight time. 18. The operatormay not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with howthe UAS will be operated underthe exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. §61.51(b). Flights for the purposes oftraining the operator's PICs are permitted under the terms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Ifflight at night is required, a special request will be made atthe FAA office19 of35 closesttoproposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 2 nautical miles ofan airportreference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required bythe operator's COA. The letter ofagreementwiththe airport managementmust be made availableto the Administratorupon request. 21. The UA may not be operated less than 400 feet below or less than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 22. Ifthe UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land orbe recovered in accordance withthe operating documents. 23. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies in accordance withthe operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weatherconditions) there is enough powerto fly at normal cruising speed to the intended landingpoint and land the UAwith 25%batterypowerremaining. 25. The operatormust obtain an AirTraffic Organization (ATO) issued Certificate of Waiver orAuthorization (COA) priorto conducting any operations underthe grant ofexemption. This COAwill also require the operatorto request a Notice to Airman (NOT AM) notmore than 72 hours in advance, but not less than 48 hours priorto the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class ofairspace, altitude level andpotential transponderrequirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.P.R. part 47, andhave identification (N-Number) markings in accordance with 14 C.P.R. part 45, Subpart C. Markings mustbe as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA mustcomply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC atthe Ground Control Station ofthe UAS any time the UAS is operating. These documents mustbe made available to the Administrator or any law enforcement official upon request.20 of35 29. The UA must remain clear and yield the right ofway to all manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device orvehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons otherthan the PIC, SO, operatortrainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are presentthat sufficiently protect nonparticipating persons from the UA and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted permission and the PIC has made a safety assessment ofthe risk of operating closerto those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do notpresent an undue hazard to those persons per§ 91.119(a). 32. All operations shall be conducted overprivate or controlled-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 2. Reasons Why An Exemption From The Requirements OfSection 61.113(a) And (b) Would Not Adversely Affect Safety. Petitioner submits that the equivalent level ofsafety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the PHANTOM 3 UASs unless thatPIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the PHANTOM 3 UAS in a manner21 of35 consistentwiththe exemption, including evasive and emergen((y maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Petitioner's proposed area ofoperations, and the operating limitations set forth-above; the parallel nature ofaeronautical knowledge requirements to those of commercial pilotrequirements (See ExemptionNo. 11062); and the airmanship skills necessary to safely operate the PHANTOM 3, Petitioner submits thatthe additional manned airmanship experience ofa commercially certificatedpilotwould not correlate to the airmanship skills necessary for Petitioner's specific proposed flight operations.
The FAA has previously granted relieffrom Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).
Petitionerwill not allow any PIC to operate the PHANTOM 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements orthe PHANTOM 3 UAS training and currency requirements, thatthe PIC is able to safely operate the PHANTOM 3 UAS in a mannerconsistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. 

### § 61.51(b), 25 hours oftotal time as a UAS rotorcraftpilot (with a minimum of 5 hours ofthose hours as a UAS pilotoperating the same make and model ofUAS to be used for operations under the exemption). In addition to the hourrequirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).
As in ExemptionNos. 11062, 11138, and 11153, priordocumented flight experience thatwas obtained in compliance with applicable regulations will ensure an equivalent level ofsafety during Petitioner's proposed operations. The Administratorhas held that22 of35 prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:
In ExemptionNo. 11062, the FAA required thatpriorto conducting operations for the purpose ofmotion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51 (b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Priorto operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilot operating the same make and model ofUAS to be used for operations underthe exemption. Forclarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours ofmulti-rotor time and the 10 hours may be included in the total 25 hours ofUAS rotorcraft time. In addition to the hourrequirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conductthe petitioner'sproposed operations. The FAA also finds thatprior documented flight experience that was obtained in compliance with applicable regulations would satisfY this requirement. Training, proficiency, and experiencebuilding flights can also be conducted under the grant ofexemption to accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Petitionerwill ensure safe operations by not allowing any PIC to operate the PHANTOM 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the PHANTOM 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 3. Reasons Why An Exemption From The Requirements OfSection 91.7(a) Would Not Adversely Affect Safety. The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every flight, Petitionerwill ensure that the PHANTOM 3 UAS is in an airworthy condition based upon the UAS's compliance with its operating documents and
as stated in the conditions and limitations herein. Additionally, the FAA has previously23 of35 grantedrelieffrom Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11062, 11063, 11064, 11065,11066,11067,11080,11109,11110,11112,11136,11138,11150,11153,11156, 11157, 11158, 11159, 11160, 11161). 

### 4. ReasonsWhyAn ExemptionFrom TheRequirements OfSection 91.121 Would NotAdversely Affect Safety. The equivalent level ofsafety establishedby Section 91.121 will be maintained because the altitude information ofthe PHANTOM 3 UAs will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring ofthe flight path and altitude. This altitude information, combinedwith Petitioner's operation ofthe PHANTOM 3 UAs within visual line ofsight, atorbelow400 feet AGL, will ensure a level ofsafety equivalentto Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Priorto each flight, a zero altitude initiationpoint is automatically establishedby the UASs at ground level.
The FAA has previously granted relieffrom Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).


### 5. Reasons WhyAn ExemptionFrom TheRequirements OfSection 91.151(b) Would NotAdversely Affect Safety. A grant ofthis exemption would ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b) as a resultof(1) the technical specifications ofthe PHANTOM 3 UASs; (2) the limitations on the proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, Petitioner will ensure that itwill safely operate the batterypoweredPHANTOM 3 UAs during daylighthours in VFR conditions, with enough batterypowerto fly for a total duration of 13.5 minutes to the first pointofintended landing and, assuming normal cruising speed, to fly afterthat for at least4.5 minutes.24 of35 Here, as in ExemptionNo. Ill09, the technical specifications ofthe PHANTOM 3 UASs; the limitations on the proposed flight operations; andthe location ofthe proposed operations, will ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the PHANTOM 3 UASs provide audible and visual warnings to the PIC at the GCS whenthe UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the PHANTOM 3 UASs will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Reliefhas been granted for manned aircraftto operate at less than the minimums prescribed in Section 91.151, including ExemptionNos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relieffrom Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 8811, 10808, 10673, 11042, 11062,11063,11064,11065,11066,11067,11080,11109,11110,11136,11138,11150, 11153,11156,11157,11158,11159,11160, 11161). 6. Reasons Why An Exemption From TheRequirements OfSections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) &(b) Would NotAdversely Affect Safety. In seeking this exemption, Petitioner submits that the equivalent level ofsafety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because Petitionerwill use trained technicians to perform maintenance, alterations, orpreventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the PetitionerAerial Operations Manual, Monthly Maintenance Log, and PHANTOM 3 Instruction Manual). Furthermore, Petitionerwill document and maintain all maintenance records for the PHANTOM 3 UASs. Since the PHANTOM 3 UASs will be inspected as prescribed by the operating documents, Petitionerwill maintain the equivalent level ofsafety established by Sections25 of35 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy ofthe PHANTOM 3 UserManual is attached hereto as Exhibit B; a copy ofthe PHANTOM 3 UAS Maintenance LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety because Petitioner will use trained technicians to perform maintenance, alterations orpreventive maintenance onthe UAS using the methods, techniques, andpractices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe PHANTOM 3 UASs will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered.
In consideration ofPetitioner's proposed operating limitations, the operating documents, and the technical aspects ofthe PHANTOM 3 UASs, Petitioner submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted reliefspecific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,11067,11080,11109,11110,11112,11136,11138,11150,11153,11156,11157, 11158,11159,11160, 11161).
7. The FAA May Prescribe Any Other Conditions For Safe Operation. In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Petitioner requests thatthe FAAprescribe special conditions for the intended operation ofthe PHANTOM 3 UASs, which contain such safety standards that the Administrator finds necessary to establish a26 of35 level ofsafety equivalentto that established by 14 C.F.R. Part21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation ofthe UAs for the limitedpurpose ofconducting aerial video and photography over certain areas ofthe United States for compensation orhire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, orotherwise pose a threatto national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements thatmustbe established for the safe operation ofthe UAS in the NAS. Likewise, the Administratormay prescribe special conditions pursuantto 14 C.F.R.§21.16, for operation ofthe PHANTOM 3 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel orunusual design features ofthe aircraft. Section 21.16, entitled Special Conditions, states the following:
Ifthe FAA finds that the airworthiness regulations ofthis subchapter do not contain adequate orappropriate safety standards for an aircraft, aircraft engine, orpropeller because ofa novel orunusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 ofthis chapter and contain such safety standards for the aircraft, aircraft engine orpropeller as the FAA finds necessaryto establish a level ofsafety equivalentto that established in the regulations. See 14 C.P.R.§ 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.P.R.§ 21.16, the FAA may prescribe special conditions for Petitioner's intended operation ofthe PHANTOM 3 UASs, which contain such safety standards thatthe Administrator finds necessary to establish a level ofsafety equivalentto that established by 14 C.F.R. Part21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b).27 of35 A SUMMARYTHAT CANBE PUBLISHED INTHE FEDERALREGISTER, STATING: THE RULES FROMWHICH PETITIONER SEEKSEXEMPTION Petitionerseeks exemptionfrom the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and91.417(a) & (b). 

### A BriefDescription OfTheNatureOfTheExemption Petitioner Seeks: This exemption willpermitPetitioner to commercially operate an Unmanned AircraftSystem (UAS)for thepurpose of conductingaerialvideo and photography over certain areas of the United States.

ANY ADDITIONAL INFORMATION, VIEWS, ORARGUMENTS AVAILABLE TO SUPPORT PETITIONER'SREQUEST This Petition is made pursuantto the FAA Modernization and Reform Actof2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine if certain UAS may operate safely in the NAS. As such, Petitioner's request for exemption may be granted pursuantto the authority ofFMRA Section 333 and 14 C.F.R. Part 11, as set forth above.
FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threatto national security; and further, provides the authority for such UAS to operate without airworthiness certification.
As discussed in detail above, Petitioner will operate the PHANTOM 3 UASs safely in the NAS, without creating a hazardto users ofthe NAS, orthe public, orotherwise pose a threat to national security.

CONCLUSION As set forth herein, Petitioner seeks an exemption pursuantto 14 C.F.R. 

### § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe PHANTOM 3 UASs commercially, without an airworthiness28 of35 certificate, for the limitedpurpose ofconducting aerial video andphotography over certain areas ofthe United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate ofthe FAA Modernization and Reform Actof 2012, while also advancing the interests ofthe public, by allowing Petitioner to safely, efficiently, and economically operate the PHANTOM 3 UASs commercially withinthe NAS. WHEREFORE, in accordance withthe Federal Aviation Regulations andthe FAA Modernization and Reform Act of2012, Section 333, Petitionerrespectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permitPetitionerto operate the PHANTOM 3 UASs commercially for the purpose ofconducting aerial video and photography overcertain areas ofthe United States.
Dated: September 18, 2015 Respectfully submitted, Gary 

### J Clayman Satori Realty Advisors, Inc. (dba. Satori Advisors) 5405 Alton Pkwy #A303 Irvine, California 92604 (949) 273-0966 gary.clayman@satori-realty.com29 of35 GLOSSARY OFABBREVIATIONS AGL AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS NOT AM PHANTOM3 PIC Section 333 

## so SOP 

### VA UAS VFR VLOS VMC VTOL Above Ground Level Area ofInterest AirTraffic Control Air Traffic Organization Aerial Vehicle Code ofFederal Regulations Certificate ofAuthorization Federal AviationAdministration FederalAviationRegulation Ground Control Station Global Positioning System Loss ofLink National Airspace System Notice to Airman 

### Dn Phantom 3 Professional PilotInCommand FAAModernization and Reform Act of2012 (FMRA) Section 333 Safety Observer Standard Operating Procedures Unmanned Aircraft Unmanned Aircraft System Visual FlightRules Visual Line ofSite Visual Meteorological Conditions Vertical Takeoffand Landing30 of35 APPENDICES



### ExhibitA- DJI PHANTOM 3 Professional Specifications Data Sheet ExhibitB- DJI PHANTOM 3 Professional Manufacturer's UserManual Exhibit C- Petitioner'sMonthly Maintenance Log ExhibitD- Petitioner's Unmanned Aerial Systems Guidelines Exhibit E- Petitioner's Certificate ofLiability Insurance 

### The above Appendices are submitted as Confidential Documents under 14 C.F.R. § 11.35(b) and exempt from disclosure under the Freedom oflnformation Act, 5 U.S.C. 

### § 552 et seq., and any other requirements established bythe FAA pursuantto Section 333 ofthe Reform Act31 of35 EXHIBIT

### A

DJI PHANTOM 3 Professional TECHNICAL SPECIFICATIONS

Petitioneronly utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enablingthe user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than apredetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location information to the PIC via the linked monitor (smartphone/tablet devices): 1.1 DJI PHANTOM 3 Professional 1.1.1 Aircraft 1.1.1.1 SupportedBattery

- DJI 4480mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Included)

- 2lbs 12oz 1280g 1.1.1.3 HoverAccuracy (Ready to Fly)- Vertical: 0.1m; Horizontal: 1m 1.1.1.4 MaxFlighttime

- Approximately 23 minutes 1.1.1.5 Max TiltAngel

- 35° 1.1.1.6 MaxAscent Speed

- 5m/s 1.1.1.7 Max Descent Speed

- 3m/s 1.1.1.8 MaxFlight Speed-16m/s {NOT RECOMMENDED) 1.1.1.9 Operating Temperature

-

## ooc -40°C 1.1.1.10 Max FlightAltitude

- 6000m 1.1.1.11 GPS Mode

- GPS/GLONASS 1.1.2 Gimbal 1.1.2.1 Controllable Range

- Pitch: -90° 

### +30° 1.1.3 Camera 1.1.3.1 Sensor- Sony EXMOR 112.3" 1.1.3.2 Lens- FOV 94° 20mm (35mm format equivalent) f/2.8 1.1.3.3 Effective Pixels- 12.4M 1.1.3.4 Resolution- 4384x3288 1.1.3.5 HD Video Recording- 4K, 1080p & 720p 1.1.3.6 Image Max Size- 4000 x 3000 1.1.4 Remote Controller 1.1.4.1 Operating Frequency

- 2.400GHz

- 2.483GHz 1.1.4.2 Communication Distance (unobstructed)

- 2000m 1.1.4.3 Battery- 6000 mAh LiPo 2s 1.1.4.4 TransmitterPower- FCC: 20dbm CE: 16 dbm 1.1.4.5 Working Voltage -1.2A @7.4 V32 of 35 EXHIBITB


### DJI PHANTOM 3 Professional Manufacturer's UserManual

can be found at 

### http:/ /www.dji.com/product/phantom-3/downloadEXHIBITC

Petitioner's Monthly Maintenance Log

MONTHLY MAINTENANCE LOG (Month: September Year: 2015) Date Date Discovered Addressed Issue: Description and Maintenance Performed Maintenance Performed by: Firmware Updates 9/7/2015 9/7/2015 Phantom 3 Professional Firmware vl.4.0010 GaryJ. Clayman Airframe Engines Propellers Camera/Gimbal Landing Gear Vibration/Dampening Other:

33 of3534 of35 EXHIBITD

Petitioner's Unmanned Aerial Systems Guidelines


### Submitted as Confidential Documents under 14 C.P.R.§ 11.35(b) and exempt from disclosure under the Freedom ofInformation Act, 5 U.S.C. § 552 et seq., and any other requirements established by the FAA pursuant to Section 333 ofthe Reform ActPage 1of9 

## Preface An upsurge in commercial unmanned aerial vehicle (UAV) activity and an ever increasing number ofmanufacturers and operators has led to the establishment ofthese guidelines for Unmanned Aerial Systems (UAS). Since the terms Unmanned Aerial Vehicle, Unmanned Aircraft System and Remotely Piloted Aircraft (RPA) are often used synonymously, this document will use the term UAS to standardize and describe all unmanned aircraft systems. The intent ofthese guidelines is to considerthe entire system, notjustthe vehicle when operating UAS. The UAS has four subsystems: aircraft, data links (control and return), ground control equipment, and the pilot/operator. In general, UAS operations can occur within visual line ofsight (VLOS), extended visual line ofsight (EVLOS) (within electronic line ofsight ofthe ground control station), orbeyond visual line ofsight (BVLOS). UAS may be controlled manually by apilot or autonomously through use ofprogramming and autopilot and canvary in size from those weighing less than a poundto some the size of a commercialjet. Regardless ofthe size, the basic guidelines outlined below should be considered. They are not an exhaustive list nor should they be consideredthe only source to reference. All UAS operators should ensure their UAS operations meet all applicable legal requirements and are consistentwith industry guidance. Although many ofthe elements in these UAS guidelines can be incorporated directly into a Safety Management System, they do not constitute a complete SMS. The UAS operator should maintain a comprehensive SMS that seamlessly integrates UAS operations. These guidelines are intended to provide information for personnel seeking UAS services or those desiring informationto help manage service providers operating a UAS. They will be kept underreview and updated and changed as necessary. 

## General Operating Rules 1. UAS should be operated in accordance with all applicable local, state and federal regulatory requirements, including Section 333 ofthe FAAModernization and Reform Act of2012 "Special Rules for Certain Unmanned Systems". a. Operating documents: Operators should maintain documentation ofsystem operating certification, flight operations manual for each operation atthe pointof control ofthe UAS operation. b. All UAS operations should avoid overflight ofpersonnel not involved in the operation. c. In situations where manned aircraft pose apotential conflict with UAS operations, manned aircrafthave the right-ofway and UAS operations should be terminated until the potential conflict has passed. 2. All UAS should be in airworthy condition and have a continuing airworthiness program to conductflight operations in the National Airspace System (NAS). All UAS should bePage 2of9 accepted as airworthy by the FAA. In cases where there are no applicable regulatory standard available to determine airworthiness, the operator should assert an equivalent level ofsafetyto manned aircraft will be providedthrough adherence to maintenance and safety checklist usage standards prescribed in this document in addition to compliance with manufacturer guidance. 3. Essential elements ofa continuing airworthiness program include a maintenance training program, unique skills ormaintenance practices relating to their aircraft and a process to report applicable data relating to the maintenance ofan operation. 

## Operations 1. All UAS operations should be controlled by a Pilot in Command (PIC). Completely autonomous UAS operations should notbe conducted. A PIC may control more than one UAV, depending onthe level ofautonomy. 2. Supplemental Pilots. Supplemental pilots are those pilots assigned UAS flight duty to augmentthe PIC. It is common for operators to have both an internal and an external UAS pilot. The supplemental pilot can assume either ofthesepositions. 3. RecentPilotExperience. The operator should provide a process that ensures thatpilots maintain an appropriate level ofrecentpilot experience for the positionthey are assigned in the UAS being operated. 4. Visual Line ofSight (VLOS).
a. Operatingwithin Visual Line ofSightmeans thatthe PIC orvisual observer is able to maintain direct, unaided (other than corrective lenses) visual contactwith the unmanned aircraft, which is sufficientto monitor its flight path in relation to other aircraft, persons, vessels, vehicles and structures for the purpose ofavoiding collisions. VLOS operations are normally accepted outto a maximum distance of one-halfnautical mile horizontally and 400 ft. vertically from the UAS pilot. 5. ExtendedVisual Line ofSight (EVLOS).

a. EVLOS operations are operations where the PIC is still able to comply with his collision avoidance responsibilities, butthe need for the remote pilotto maintain direct visual contactwith the unmanned aircraft is addressed via other methods or procedures. It is importantto note, however, that collision avoidance is still achieved through 'visual observation' (by the PIC and/or UAS Observers.) All UAS operations should occur within VLOS, orEVLOS range. Operations beyond visual line ofsight are notrecommended unless an approved method ofaerial separation and collision avoidance exists and the operations are in accordance with the FAA'srequirements. b. The operator should submit a safety case including a risk assessment for the EVLOS operation. Factors taken into consideration should include:Page 3of9 1. The procedures for avoiding collisions. ii. Aircraft size and configuration. iii. Aircraft color and markings. iv. Aircraft aids to observation. v. Meteorological conditions and visibility, including background conditions (cloud/blue sky).
c. The use ofdeployed observers. d. Operating range limits

- suitable radio equipment should be fitted in orderto be able to effect positive control overthe unmanned aircraft at all times. e. Contingency plans for loss oflink event. 6. UAS operations (including night operations) should utilize one or more trained visual observers to assist the PIC with see-and-avoid responsibilities by scanning the area around the aircraft for intrudertraffic and assisting the PIC with navigational awareness. The visual observer(s) should have a reliable method ofinstantaneous communications with the PIC such as two-way radios. Cellularphones are not considered reliable for this purpose, butmay be utilized on a case-by-case basis. The PIC and visual observer(s) together should have a view ofthe areathat is sufficientto allow enough time for the PIC to de-conflict as required. 7. Spacing multiple visual observers and/or antennae's in a linear manner ("daisy chaining") to increase operational distance beyond should generally be avoided; however, operations involving "daisy chaining" observers/antennae may be permitted ifan acceptable safety case is presented by the operator demonstrating the risks are sufficiently managed. These operations would normally fall under Extended Visual Line ofSight (EVLOS) orBeyond Visual Line ofSight (BVLOS) regulations. EVLOS operations are normally beyond a distance of500 meters horizontally and 400 ft. vertically from the Remote Pilot.

a. When multiple visual observers are being used, it is important for the PIC to know which visual observer(s) have direct visual contact on the aircraft. 8. Visual observers should: a. Be in communication with PIC either within speaking distance or with a portable radio. b. Be trained in areas such as aviation terminology, Visual Flight Rules (VFR), airspace requirements and applicable aviation regulatory requirements. c. Keep the pilot informed ofpossible hazards (power lines, crane/venting booms, birds, other aircraft, approaching workboats (when working underneath facility), and weather conditions. d. Meet any medical orphysical requirements mandated by the appropriate civilian regulatory authority. e. Be designated as such andnot share in any other duties associated withthe flight. f. Be briefed on lost communications procedures prior to the flight. 9. Weather ObservationPage 4of9 a. A reliable method ofdetermining wind speed, ceiling and visibility should be used. b. Weather observations should be taken near enough to the operationthat it is certain thatthey are valid; for example, an airport's observations can beused if the airport is within several miles andthe conditions appearto be uniform. c. Ceiling may be determined by the temperature/dewpoint spread. 10. Night Operations a. Night operations may be considered ifthe operatorprovides a safety case and sufficient mitigationto avoid collision hazards atnight. External pilots and observers should be in place 15 minutespriorto night operations to ensure dark adaptation. 11. Experience/currency: The UAS operators shouldprovide documentation showingthe pilots maintain an appropriate level ofrecent pilot experience inthe UAS being operated or in a flight simulation training device (FSTD). At a minimum, the PIC should conduct three takeoffs (launch) andthree landings (recovery) in the specific UAS withinthe previous 30 days, or as prescribed by the operator/applicant'srecurrenttraining and currency program. This does not apply whenthe PIC is notrequired to be involved in the launch andrecovery ofthe UAS operation. 12. All operators should have a flight operations manual approved by a competent authority: at a minimum, the manual should include procedures and checklist information for preflight, in flight, postflight, emergencyprocedures, and limitations. The operations manual should also include information on aircraft systems andperformance. 13. Notificationto otherpotential users ofthe airspace and appropriate regulatory authorities should be issued with ample time for those operators/regulatorsto plan appropriately. Ensure no simultaneous operations between UAS and manned aircraft are planned in same area. The following shouldtake place priorto operations.

a. Notify local airspace users. Include at least: i. Date andtime range. ii. Precise location. m. Altitude range. IV. Aircrafttype and description (whatto look for). v. Contact information to coordinate, de-conflict and exchange other information. b. All UAS operations should include a pre-flight brief. The briefing should include ata minimum: I. Mission overview 

### n. Hazards unique to the mission (including potential sources ofinterference) m. ATC notifications IV. Identify any special airspace and restrictions. (i.e. VFRcorridors, TFRs, etc.)Page 5of9 

### v. De-conflictionplans for intruding aircraft. VI. 

### Weather (current and forecast ceiling, visibility and winds). VII. 

### Mission altitude. vm. Lost Link, divert and flight termination procedures.

ix. Identification ofany public or residential areas near flight path and pnvacy concerns. x. Flighttime and battery requirements. XI. 

### Minimum voltage requirements. XII. 

### Frequencies to be used. 14. Immediately priorto each launch, the PIC should: a. Perform a pre-flight inspection/checklist. b. Visual inspection ofairframe condition. c. Run system diagnostics. d. Conduct engine run test. e. Check battery, sensors, etc. f. Verify communications with the visual observer(s) and confirm thatthere is no conflicting air traffic. 15. The use ofcell phones and otherelectronic devices during flight operations should be restricted to communications pertinentto the operational control ofthe UA and any required communications with Air Traffic Control. Cell phones should not be used as the primary means ofcommunications between visual observers and pilots. 16. All UAS operations should be conducted with "sterile cockpitprocedures" during critical phases offlight. These include: taxi and ground operations involving aircraft movement, take-offand landing, as well as all other flight operations in which safety or mission accomplishment might be compromised by distractions. 1

7. Lost Link Procedures a. There are many acceptable approaches to satisfy lost link requirements. The intent ofany lost link procedure is to ensure airborne operations remain predictable. b. Lost link procedures should comply with any regulatory requirements and the lost link solution will need to comply with the last Air Traffic Control (ATC) clearance ifapplicable. c. The appropriate ATC facility should be notified immediately ifapplicable d. Lost link procedures should avoid flight over any populated areas and hazards, as well as any frequently travelled flight paths. e. The time and duration ofeach lost link event should be recorded by the operator and reported through the incident reporting process. f. The designated return site should be clear ofany personnel and hazards in the event ofan immediate lost link return to base and landing.Page 6of9 

## Maintenance 1. A maintenance program should be in place to ensure the airworthiness ofany UAS being utilized. Maintenance be performed in accordance with manufacturerrecommendations. The program should, at a minimum: a. Have a maintenance policy and a procedures manual. b. Include a pre-flight and post flight inspection ofthe vehicle and have an associated logbook to track inspections. c. Include a pre-flight and post flight inspection ofthe ground control station. d. Incorporate a logbook to track flight hours and any inspection replacementtimes and life limited items. (i.e. batteries, rotors). e. Software and hardware changes should be documented as a partofthe maintenance procedures. f. Maintain a record ofmalfunctions (i.e. loss oflink), anomalies and damaged parts. g. Maintenance training and evaluationprogram for each operated system. h. A quality assurance (QA) program should be utilized as apart ofthe overall safety management system (SMS). i. Include both field and depot level maintenance intervals. 2. Itis highly recommended that all UAS operators provide the following information: a. A Continuing Airworthiness Program. b. A maintenance training program. c. Any unique skill sets ormaintenance practices relating to the UAS. d. A process to report any applicable data relating to the operation and maintenance ofthe UAS. 

## Training 1. All training programs should comply, orbe consistent withmanufacturer's recommended trainingprograms. 2. UA V pilots should meet applicable training and testing requirements for each class or type ofUAS they will operate. 3. The training program should be appropriate for each aircrew role, the environment and mission the operator is expectedto perform. 4. The training program at a minimum should cover currency, evaluation, emergency procedure proficiency, systems knowledge and specializedtasks. 

## Communications 1. The communications control links are essential with all UAS operations. UAS should be operated in a reliable radio frequency environmentthat minimizes the probability oflostPage 7of9 link andRadio Frequency (RF) interference with nearby systems. UAS operators should have a valid communications planthat considers: a. Every effort is made to ensure positive control ofthe UAS at all times. b. At a minimum, sources ofpossible radio frequency (RF) interference such as microwave antennas and high voltage lines should be identified and assessedprior to commencing operations. c. Safe recovery ofthe vehicle in the event ofloss oflink. 

## Hazard Identification and Safety 1. The UAS operators should have an incidentreporting systemthattracks and reports all mishaps, potential mishaps, control link events, and near misses. This system should provide for analysis and improvements made as a partofthe operator's Safety Management System (SMS). All mishaps, incidents and anomalies should be tracked internally and reported to the civilian aviation authorities when necessary. 2. Appropriate air traffic control should be immediately notified in the event ofany emergency, loss ofcommand link, loss ofvisual contact, orany othermalfunctionthat would impact safety oroperations. 3. Consideration should be given towards using UAS with redundant controls, automatic flight termination and/or flight recovery systems when operatingnearpopulated areas or sensitive infrastructure. 

## Emergency Response Planning 1. A formal emergency response plan should be in place for all flight operations. An incidentresponse checklist, approved as part ofthe flight operations manual, should be followed in the event ofan incident oraccident. 

## Battery Handling 1. All UAS operators should have a battery safety programthat includes: a. Documentation with appropriate Safety Data Sheets included in the aircraft flight manual, battery tracking systems and battery log books. b. Battery storage and chargingplans. c. Battery inspection procedures and requirements. d. Procedures for thermal runaway, determination ofbatterypackcapacity. e. Recommendedprocedures for safe transportation ofthe batteries that are compliantwith applicable regulations and work site requirements. 

## Additional ConsiderationPage 8of9 The following are used bythe FAA's Unmanned Aircraft Systems (UAS) Integration Office and many UAS organizations to describe relevant differences between UAS operations and those of manned aircraft. Otherorganizations, such as the International Civil Aviation Organization (ICAO) and RTCA, Inc., have also developed acronyms and definitions which may differ from those used by the Federal Aviation Administration (FAA). Aviation safety inspectors (ASI) may wish to referto the currentversion ofiCAO Circular 328, Unmanned Aircraft Systems (UAS) and RTCA Guidance D0-304, Guidance Material and Considerations for UnmannedAircraft Systems, until harmonization ofterminology is achieved. I. Aircraft. A device used or intendedto be used for flight in the air, including unmanned aircraft (UAS). 2. Airworthiness. A condition in whichthe UAS (including the aircraft, airframe, engine, propeller, accessories, appliances, and control station (CS)) conformsto its type certificate (TC), ifapplicable, and is in condition for safe operation. 3. CongestedArea. A congested area is determined on a case-by-case basis. The determination shouldtake into consideration all circumstances, not only the size ofan area and the number ofhomes or structures (e.g., whetherthe buildings are occupied or people are otherwise present, such as on roads). 4. Daisy-Chaining. The use ofmultiple, successive observers to extendthe flight ofa UAS beyond the direct visual line-of-sight ofany otherpilot in command (PIC) orVO. 5. Due Regard. A phase offlight wherein an aircraft commander ofa State-operated aircraft assumes responsibility to separate his orher aircraft from all other aircraft. 6. External Pilot. A 

### VAS pilotwho flies from outside a control station with direct visual contactwith the aircraft. 7. Flight Termination. The intentional and deliberate process ofperforming controlled flight into terrain (CFIT). Flighttermination should be executed in the eventthat all other contingencies have been exhausted, and further flight ofthe aircraft cannot be safely achieved, or otherpotential hazards existthatrequire immediate discontinuation offlight. 8. Flyaway. An interruption or loss ofthe control link, orwhenthe pilot is unable to effect control ofthe aircraft and, as a result, the UA is not operating in a predicable orplanned manner. 9. Internal Pilot. A 

### VAS pilotwho flies from inside a control station without direct visual contactwith the aircraft. I0. LostLink. The loss ofcommand-and-control link contact with the remotelypiloted aircraft such thatthe remote pilot can no longer manage the aircraft's flight. 11. Non-Cooperative Aircraft. Aircraftthat do not have an electronic means ofidentification (i.e

.., a transponder) aboard orthathave inoperative equipment because ofmalfunction or deliberate action. 12. Observer. A trained personwho assists a UAS pilot in the duties associated with collision avoidance and navigational awareness through electronic orvisual means. Collision avoidance includes, but is not limited to, avoidance ofothertraffic, clouds, obstructions, terrain and navigational awareness. A visual observer (VO) is a trained person who assists the UAS pilot by visual means in the duties associated with collision avoidance. A VO includes the OPA pilotwhen the OPA is being operated as a UAS. 13. Off-Airport. Any location used to launch orrecover aircraft that is not considered an airport (e.g., an open field).Page 9of 9 14. Pilot in Command (PIC). The person who has final authority and responsibility for the operation and safety offlight, has been designated as PIC before or during the flight, and holds the appropriate category, class, and type rating, ifapplicable, for the conduct ofthe flight. The responsibility and authority ofthe PIC as described by§ 91.3 apply to the UA PIC. The PIC position may rotate duties as necessary with equally qualified pilots. The individual designated as PIC may change during flight. (NOTE: The PIC can only be the PIC for one aircraft at a time. For an OPA, the PIC should meet UAS guidance requirements for training, pilot licensing, and medical requirements when operating an OPA as a UAS.) 15. Safety Risk Management (SRM). A formalized, proactive approach to system safety. SRM is a methodology that ensures hazards are identified; risks are analyzed, assessed, and prioritized; and results are documented for decision-makers to transfer, eliminate, accept, or mitigate risk. 16. Scheduled Maintenance (Routine). The performance ofmaintenance tasks atprescribed intervals. 17. Supplemental Pilot. Pilots assigned UAS flight duties to augment the PIC. It is common for operators to have both an internal and an external UAS pilot. The supplemental pilot can assume either ofthese positions. The supplemental pilot may also assume duties of the PIC ifthe specified qualifications are met. 18. Unmanned Aircraft (UA). A device used or intended to be used for flight in the air that has no onboard pilot. This device excludes missiles, weapons, or exploding warheads, but includes all classes ofairplanes, helicopters, airships, and powered-lift aircraft without an onboard pilot. UAs do not include traditional balloons (referto 14 CFRpart 101), rockets, and unpowered gliders. 19. Unmanned Aircraft System (UAS). An UA and its associated elements related to safe operations, which may include control stations (ground-, ship-, or air-based), control links, support equipment, payloads, Flight Termination Systems (FTS), and launch/recovery equipment. 20. Unscheduled Maintenance (Non-routine). The performance ofmaintenance tasks when mechanical irregularities occur. 21. Visual Line ofSight (VLOS). Unaided (corrective lenses and/or sunglasses exempted) visual contact between a PIC or a VO and a UA sufficientto maintain safe operational control ofthe aircraft, know its location, and be able to scan the airspace in which it is operating to see and avoid other air traffic or objects aloft or on the ground.35 of35 EXHIBITE

Petitioner's Certificate ofLiability Insurance


### Submitted as Confidential Documents under 14 C.P.R.§ 11.35(b) and exempt from disclosure under the Freedom ofInformation Act, 5 U.S.C. § 552 et seq., and any other requirements established by the FAA pursuantto Section 333 ofthe Reform Act**-~** 

## CERTIFICATE OF LIABILITY INSURANCE I DATE (MM/DDIYYYY) ACORD 8**~** 02/26/2015 PRODUCER THIS CERTIFICATE IS ISSUED AS MATTER OF INFORMATION AGENT CRAIG MAUK ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE 8801 CENTRAL AVE. STE D MONTCLAIR, CA 91763 HOLDER. THIS CERTIFICATE DOES NOT AMEND, EXTEND OR PHONE: 909-626-7275/FAX: 909-626-7807 ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW.

# I~ \ INSURERS AFFORDING COVERAGE NAIC# INSURED INSURER A: State Farm General Insurance Company 25151 25151 Satori Realty Advisors, Inc. dba Satori Advisors INSURER 8: 5405 ALTON PKWY #A303 INSURER C: IRVINE, CA 92604 INSURER D INSURER E: COVERAGES

THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. AGGREGATE LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. INSR ADD'L POLICY EFFECTIVE POLICY**EXPI~~N** LTR INSRD TYPE OF INSURANCE POLICY NUMBER DATE IMM/DDIYYl DATE IMM/DD/ LIMITS A X**~ERAL** LIABILITY 92-C7-H194-5 02/18/2015 02/18/2016 EACH OCCURRENCE $ 1,000,000 X PMMERCIAL GENERAL LIABILITY**~~~~~iJ9E~~~~?encel** $ 300,000

- CLAIMS MADE 

# D OCCUR

- MED EXP IAnv one oersonl $ 5,000 PERSONAL & ADV INJURY $ 1,000,000


# - GENERAL AGGREGATE $ 2,000,000



# - GENtAGGREGATE UMfTAPPUES PER: PRODUCTS- COMP/OPAGG $ 2,000,000**~** .nPRO- POLICY JECT nLOC A X A!!IOMOBILE LIABILITY 262 0593-A03-75B 02/18/2015 02/18/2016 COMBINED SINGLE LIMIT (Ea accident) $ X ANY AUTO '---

- ALL OWNED AUTOS BODILY INJURY $ 100,000 (Per person) SCHEDULED AUTOS

- HIRED AUTOS BODILY INJURY $ 300,000 f-- (Per accident) f-- NON-OWNED AUTOS PROPERTY DAMAGE $ 100,000 f-- (Per accident)
GARAGE LIABILITY AUTO ONLY- EA ACCIDENT $ R-ANYAUTO OTHER THAN EAACC $ AUTO ONLY: AGG $ DSS/UMBRELLA LIABILITY EACH OCCURRENCE $ OCCUR 

## D CLAIMS MADE AGGREGATE $ $ 

# R
DEDUCTIBLE $ RETENTION $ $ WORKERS COMPENSATION AND IWCSTATUJ lOTH- TORY LIMITS ER EMPLOYERS' LIABILITY ANY PROPRIETOR/PARTNER/EXECUTIVE E.L. EACH ACCIDENT $ OFFICER/MEMBER EXCLUDED? E.L. DISEASE- EA EMPLOYEE $ Ifyes, describe under SPECIAL PROVISIONS below E.L. DISEASE- POLICY LIMIT $ OTHER

DESCRIPTION OF OPERATIONS I LOCATIONS I VEHICLES I EXCLUSIONS ADDED BY ENDORSEMENT I SPECIAL PROVISIONS

CERTIFICATE HOLDER

132849 03-13-2007 CANCELLATION SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE THE EXPIRATION DATE THEREOF, THE ISSUING INSURER WILL ENDEAVOR TO MAIL ...1Q_ DAYS WRITTEN NOTICE TO THE CERTIFICATE HOLDER NAMED TO THE LEFT, BUT FAILURE TO DO SO SHALL IMPOSE NO OBLIGATION OR LIABILITY OF ANY KIND UPON THE INSURER, ITS AGENTS OR REPRESENTATIVES. AUTHORIZED REPRESENTATIVE Craig Mauk: All rights reserved

### IMPORTANT

Ifthe certificate holder is an ADDITIONAL INSURED, the policy(ies) must be endorsed. A statement on this certificate does not confer rights to the certificate holder in lieu ofsuch endorsement(s). If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s).

DISCLAIMER
The Certificate of Insurance on the reverse side ofthis form does not constitute a contract between the issuing insurer(s}, authorized representative or producer, and the certificate holder, nor does it affirmatively or negatively amend, extend or alterthe coverage afforded bythe policies listed thereon.

ACORD 25 (2001/08)