Petition for Section 333 Exemption

Aviation Alternatives Inc.
Page 1 of 20 March 2, 2016

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

RE: Petition for Section 333 Exem ption FAA Modernization and R eform Act of 2012

Petitioner : Aviati on Alternatives Inc. Petitioner’s sUAS(s) Models : DJI Inspire 1; DJI Phantom 3 Pro fessional; DJI Phantom 4; senseFly eBee Petitioner’s sUAS(s) Operations : Aerial Research and Data Coll ection; Aerial Imagery; Aerial Photography; Aerial Videography; Aerial Mapping and Surveying; Regulations Requiring Exempti on : 14 CFR §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5) 14 C.F.R. § 61.113(a); 14 C.F.R. §61.315(a) 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c) 14 C.F.R. §91.121; 14 C.F.R. §91.151(a)(1) 14 C.F.R. §91.405(a); 14 C.F.R. §91.407(a)(1) 14 C.F.R. §§ 91.409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b)

To whom it may concern,

On behalf of Aviation Alternatives, Inc., (hereinafter “Aviatio n Alternatives’), a South Boston, Virginia, corporation specializi ng in aerial research and data collection, including aerial imagery, photography, videography, mapping and surveying, the undersigne d counsel for Aviation Alternatives hereby applies for Section 333 exemption pursuant to the FAA Modernization and Reform Act of 2012, Public Law 112-95 (P.L. 112-95), and 14 C.F .R. Part 11.Petition for Section 333 Exemption

Aviation Alternatives Inc.
Page 2 of 20 The operators of Aviation Altern atives understand the importanc e of safe flight operations and are acutely aware of the importance of complying with all Federal A viation Regulations (F.A.R.s). To that end, Charles Clayton Gross, III, and Robert George Potts, Jr., both of whom help operate Aviation Alternatives, hold cer tificates for the operation of m anned aircraft. As such, the operators of Aviation Alternatives will ensure that all sUAS flight opera tions are conducted in the safest possible manner. To that end, Aviation Alternatives will comply with any flight or atmospheric condition limitations imposed upon the ir commercial sUAS operat ions.

This petition will address the following topics, as they relate to Aviation Alternatives’ commercial sUAS flight operations: the nature of Aviation Alternatives’ co mmercial drone operations, as well as the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and se nseFly eBee for which Aviation Alternatives seeks exemption; Aviation Alternatives’ proposed s UAS flight operations and conditions; privacy concerns; publ ic interest and safety concer ns; and, the above specified F.A.R.s requiring exemption. Under Secti on 333(b)(1), Aviation Alternat ives’ petition will give the FAA

cause to issue a Certificate Of Waiver or Authorization by show ing that the size, weight, speed, operational capacity, proximity to airports and populated areas , and operations within the Visual Line of Sight of the Pilot in Command and Visual Observer of Av iation Alternatives’ DJI Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee neither creates a hazard to users of the National Airspace System or public nor poses a threat to nation al security.

Additionally, this petition will pr ove that Aviation Alternativ es’ flight operations for the commercial usage of the DJI Inspi re 1, Phantom 3 Professional, Phantom 4 and senseFly eBee provides an equivalent level of safety when compared to the F.A .R.s requiring exemption. To that end, this petition will highlight some of the numerous, granted petitions for Section 333 exemption for similar commercial operations of the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee.

Please refer to the “Table of Contents” beginning on page three (3) to assist your review of Aviation Alternatives’ petition for Section 333 exemption. If w e may provide additional insight or information regarding Aviation Alternatives’ petition, please d o not hesitate to contact The Ison Law Group at 863-712-9475 or IsonLawGroup@outlook.com.

Sincerely,

THE ISON LAW GROUP

Christ opher Ison, Esq.

EnclosuresPetition for Section 333 Exemption

Aviation Alternatives Inc.
Page 3 of 20 TABLE OF CONTENTS

I. Glossary of Terms ................................................................................4

II. Publishable Summary ................................................................................5

III. Petitioner’s Contact Information ..............................................................5

IV. Aviation Alternatives Inc. Overview ..............................................................6

V. Aviation Alternatives Inc. sUAS Models .....................................................6

a. DJI Inspire 1 Specifications .....................................................9

b. DJI Phantom 3 Professional Specifications ...........................................10

c. DJI Phantom 4 Specifications ............................................................12

d. senseFly eBee ...............................................................................13

VI. Proposed Flight Conditions and Operating Procedures ................................. 13

VII. Privacy .......................................................................................17

VIII. Public Interest and Safety .....................................................................17

IX. Regulations from Which Exemption is Requested ..........................................17

a. 14 CFR §§ 61.23(a) and (c): Medical Certificates Requirement an d Duration ...............17

b. 14 C.F.R. §§ 61.101(e)(4) and (5): Recreational Pilot Privilege s and Limitations ...............18

c. 14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations : Pilot in Command ......18

d. 14 C.F.R. §61.315(a): What Are The Privileges and Limits of My Sport Pilot Certificate? ... ................................................18

e. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness ...................................................19

f. 14 C.F.R. § 91.119(c): Mini mum Safe Altitude: General ..........................................19

g. 14 C.F.R. §91.121: Altimeter Settings ............................................................19

h. 14 C.F.R. §91.151(a)(1): Fuel Requirements For Flight In VFR Co nditions ...............20

i. 14 C.F.R. §91.405(a): Maintenance Required ...................................................20 j. 14 C.F.R. §91.407(a)(1): Operation After Maintenance,
Preventative Maintenance, R ebuilding, Or Alteration .. ................................20

k. 14 C.F.R. §§ 91.409(a)(1) and (2): Inspections ...................................................20

l. 14 C.F.R. 91.417(a) and (b): Maintenance Records ..........................................20Petition for Section 333 Exemption

Aviation Alternatives Inc.
Page 4 of 20 GLOSSARY OF TERMS

Aircraft : any contrivance invented, use d, or designed to navigate, or f ly in, the air (Title 49, United States Code (49 USC) § 40102).

National Airspace System (NAS) : the common network of U.S. airs pace; air navigation facilitie s, equipment and services, airpor ts or landing areas; aeronautical charts, information and services; rules, regulations and procedur es, technical information, and m anpower and material.

Operational Control : with respect to a flight, means the exercise of authority ove r initiating, conducting or terminati ng a flight (14 CFR § 1.1).

Pilot in Command (PIC) : the person who has final authority and responsibility for the operation and safety of the flight; has been designated as PIC before or during the flight; and holds the appropriate category class and type-rating, if appropriate, for the conduct of the flight (14 CFR § 1.1).

Small Unmanned Aircraft System (sUAS) : an unmanned aircraft and associated elements, including communication links and the components that control t he unmanned aircraft, that are required for the pilot in command to operate safely and efficie ntly in the national airspace system (P.L. 112-95, Section 331), weighi ng less than 55 pounds, inclu ding payload.

UAS Certificate of Waiver or Authorization (COA) : an authorization issued by the Air Traffic Organization to an operator for a specific unmanned aircraft ac tivity.

Visual Line of Sight (VLOS) : unaided (corrective lenses and/or sunglasses excepted) visual contact between a pilot in command and an unmanned aircraft suf ficient to maintain safe operational control of the aircr aft, 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 o r on the ground.Petition for Section 333 Exemption

Aviation Alternatives Inc.
Page 5 of 20 PUBLISHABLE SUMMARY

Pursuant to 14 C.F.R §11.81(f), should the FAA require a publis hable summary for the Federal Register , Aviation Alternatives, Inc. (hereinafter Aviation Alternative s), submits the following

information:

Aviation Alternatives seeks exemption from the following Federa l Aviation Regulations (F.A.R.s):

14 CFR §§ 61.23(a) and (c); 14 C. F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. §61.315(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. §91.121; 14 C.F.R. §91.151(a)(1); 14 C.F.R. §91.405(a); 14 C.F.R. §91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b).

Aviation Alternatives seeks exemption from the above listed F.A .R.s for the purpose of commercially operating Small Unma nned Aircraft Systems (sUAS), to wit: the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee. Aviation Alternatives intends to commercially operate these sUAS models for aerial research and data collection, including aerial imagery, photography, videography, mapping and surveying. As su ch, this petition will prove that

Aviation Alternatives’ flight operations for the commercial usa ge of these sUAS models provides an equivalent level of safety whe n compared to the F.A.R.s requ iring exemption.

In support of this petition, Aviation Alternatives notes that t he FAA has already granted numerous exemptions for similar commercial operators of the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee. To that end, Aviation Alternative s’ petition will highlight some of the numerous, granted petitions for Section 333 exemption for s imilar commercial operations of the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and sense Fly eBee.

Under Section 333(b)(1) of the F AA Modernization and Reform Act of 2012, Aviation Alternatives’ petition will give the FAA good cause to issue a Certificate Of Authorization by showing that the size, weight, speed, operational capacity, pro ximity to airports and populated areas, and operations within the Visual Line of Sight of the Pi lot in Command and Visual Observer

of Aviation Alternatives’ sUAS m odels neither creates a hazard to users of the National Airspace System or public nor poses a threat to national security. To t hat end, Aviation Alternatives seeks exemption from the above specified F.A.R.s as Aviation Alternat ives’ flight operations provide an equivalent level of safety when compared to the F.A.R.s to be e xempted. Aviation Alternatives will adhere to any flight or atmo spheric condition limitation i mposed by the FAA.

PETITIONER’S CONTACT INFORMATION

Petitioner: C ounsel for Petitioner: Summer L. Nix, Owner The Is on Law Group Aviation Alternatives, Inc. 2073 US Hwy 92 West, Suite 104

4131 Birch Elmo Road Winter Have n, FL 33881 South Boston, VA 24592 P hone: 863-712-9475

Phone: 434-753-2764 Email: IsonLawGr oup@outlook.comPetition for Section 333 Exemption

Aviation Alternatives Inc.
Page 6 of 20 AVIATION ALTERNATIVES, INC., PET ITION FOR SECTION 333 EXEMPTION

Aviation Alternatives, Inc.

Overview

Aviation Alternatives, Inc., (hereinafter “Aviation Alternative s”) is a South Boston, Virginia, based corporation specializing in aerial research and data coll ection, including aerial imagery, photography, videography, mapping and surveying. Aviation Alter natives provides services to

individuals and businesses in n eed of LiDAR imaging vis-à-vis s UAS operation. A few examples of Aviation Alternatives’ commercial sUAS practices include pro viding LiDAR imagery for preconstruction surveys of propert ies, travel corridors, or floodp lains. Moreover, Aviation Alternatives’ commercial sUAS operations will also benefit indi viduals and businesses after natural disasters by using aerial LiDAR technology to survey fi re damage, flood damage, or any other type of damage as a resu lt of a natural disaster.

As detailed below, Aviation Alternatives will only permit comme rcial sUAS flight operations of the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and sense Fly eBee by certificated airmen, holding at the bare minimum a sport pilot certificate. Currentl y, Aviation Alternatives employs Mr. Charles Clayton Gross, III, and Mr. Robert George Potts, Jr ., who are certificated airmen. Mr. Gross is a commercially certi ficated pilot (Certificate #367478 6) with 10,000 hours of flight time. Additionally, Mr. Potts is a certificated private pilot (Certif icate #3290995) with 500 hours of flight time. Consequently, Mr. Gross and Mr. Potts, on behalf o f Aviation Alternatives, understand safe flight operations and will ensure that Aviation Alternativ es practices and employs safe flight principles during all co mmercial sUAS operations.

Based upon Aviation Alternatives’ intended use and proposed fli ght operations and conditions limitations, Aviation Alternatives would like an exemption from the following Federal Aviation Regulations (F.A.R.s) to commerc ially operate the DJI Inspire 1 , Phantom 3 Professional, Phantom 4, and senseFly eBee: 14 CFR §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. §61.315(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. §91.121; 14 C.F.R. §91.151(a)(1); 14 C.F.R. §91.405(a); 14 C.F.R. §91.40 7(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); and 14 C .F.R. 91.417(a) and (b).

Aviation Alternatives, Inc., sUAS Models

Aviation Alternatives’ requested exemption from the above speci fied F.A.R.s will allow for the use of the DJI Inspire 1, Phantom 3 Professional, Phantom 4, an d senseFly eBee for commercial operations pertaining to aerial research and data collection, a s well as aerial imagery, photography, videography, mapping and surveying within the United States of America. These sUAS models are either similar to, or the same as, sUAS models for which th e FAA has already granted exemptions for similar commerci al flight operations (as detaile d below).

Given the ease of operation, unique safety features, and PIC si tuational awareness programs of these sUAS models, Aviation Alternatives’ requested exemption f rom various F.A.R.s will neither adversely affect the public’s s afety nor create a hazard to use rs of the National Airspace System (NAS) or pose a threat to national security. Moreover, Aviation Alternatives’ use of these sUASPetition for Section 333 Exemption

Aviation Alternatives Inc.
Page 7 of 20 models for the above described commercial operations will repla ce the need for fixed winged or rotorcraft aircraft with reg ards to these services.

By replacing fixed winged or rotorcraft aircraft with sUAS mode ls, the public will benefit in several ways. For example, the use of these sUAS models provide s significant reductions in the risk of injury to property or person should the sUAS require an emergency landing. These sUAS models are lightweight, powered by batteries, and carry no pass engers. By comparison, fixed winged or rotorcraft aircraft, which weigh thousands of pounds, carry flammable fuels, and passengers, have been known to cau se serious injury or death to passengers and bystanders during emergency landings. The use of these particular sUAS models for aerial research and data collection, including aerial i magery, photography, videography, mapping and surveying will substantially benef it the public from a safety standpoint.

DJI Inspire 1 and Phantom 3 Professional, Phantom 4

The DJI Inspire 1, Phantom 3 Pr ofessional, and Phantom 4 are qu ad-copter sUAS models capable of providing hover flight in both the vertical and horizontal p lanes. As such, these sUAS models provide excellent maneuverabili ty and ease of cont rol for the P IC. The ease with which a PIC can control these sUAS models is evidenced by the fact that both sU AS models are commercially available for RC hobbyists, requi ring no training or experience prior to flight.

In part, the DJI Inspire 1, Phantom 3 Professional, and Phantom 4 are easy to control because they provide excellent situational aw areness for the PIC. These sUAS models allow the PIC to

determine the exact altitude of the sUAS via GPS technology and monitoring. In addition, these sUAS models incorporate the use of DJI’s Pilot App which provid es an incredible wealth of information that will supplement the PIC’s situational awarenes s while operating either sUAS. As such, the DJI Pilot App provides the following information: cur rent flight mode, GPS signal strength, system status, battery level indicator, remote contro ller signal strength, flight telemetry (height, distance, and airspeed), and area map. By enhancing th e PIC’s situational awareness, the PIC will be able to focus on safe flight operations, thereby re ducing the likelihood of an incident which would lead to property da mage or injury to persons.

Aviation Alternatives’ primary objective with each commercial f light is the safe return of the sUAS without injury to property or person. To further that obje ctive, the DJI Inspire 1, Phantom 3 Professional, and Phantom 4 incorporate unique operating modes that provide for the safe return of the sUAS should the PIC experience a loss of signal connecti vity between the sUAS model’s

transmitter and receiver. Moreove r, these sUAS models also inco rporate three safe modes in such a situation: Failsafe, Return t o Home, and Dynamic Home Point.

In addition to the above safety features, the new DJI Phantom 4 boasts ActiveTrack, TapFly, and a unique Obstacle Sensing System. ActiveTrack allows the Phanto m 4 to track a moving subject without a separate GPS tracker. In order to activate this featu re, the PIC simply taps on the mobile device screen inside the DJI GO app to select the subject to be tracked. The aircraft will lock on the subject and start tracking it automatically from a safe dis tance. To that end, TapFly allows the PIC to fly in any dire ction with a tap of the finger, without a remote controller. And, as one might guess, with Obstacle Avoidance turned on, the aircraft will aut omatically avoid obstacles, slow down or hover when required, prov ided that the scene is bright enough ( < 300 lux) or not tooPetition for Section 333 Exemption

Aviation Alternatives Inc.
Page 8 of 20 bright ( > 10,000 lux). With the Obstacle Avoidance system enga ged, the Phantom 4 is equipped will constantly scan for obstacles in front of it, allowing it to avoid collisions by going around, over or hovering.

The FAA has already granted numerous petitions for Section 333 exemption to commercial sUAS operators of the DJI Inspire 1 a nd Phantom 3 Professional. Belo w is sampling of granted Section 333 petitions for the commercial operation of the DJI Inspire 1 and Phantom 3 Professional, as well as the petitioner’s propose d commercial usage of the sUAS:

Exemption

Number Regulatory

Docket Number Flight Operation

11399A FAA-2015-0147 Aerial Photogr aphy/Videography for Real Es tate Services

11845 FAA-2015-0806 Aerial Photogr aphy/Videography for Real Est ate Services

12042 FAA-2015-1552 Aerial Pho tography/Videography

12046 FAA-2015-1534 Aerial Pho tography/Videography 11802 FAA-2015-1050 Aerial Photogr aphy/Videography for Real Est ate Services

11977 FAA-2015-1478 Aerial Vide ography/Photogrammetry 11953 FAA-2015-1407 Aerial Mappi ng/Inspection/Photography 11711 FAA-2015-0777 Aerial Photography/Photogrammetry 11938 FAA-2015-1390 Aerial Photography/Video 11172A FAA-2014-0787 Aerial Photogr aphy and Wildlife Preservati on

11899 FAA-2015-1249 Aerial Photo graphy/Videography/Mapping 1306A FAA-2014-1023 Aerial Photogram metry/Inspection/Analysis

senseFly eBee

Unlike the DJI Inspire 1 and Phantom 3 Professional, Phantom 4, the senseFly eBee is a fixedwing sUAS that allows for autonomous flight via a data link. Th e eBee has a 38 inch wingspan and has a maximum take-off weight of 1.7 pounds. Owing to the l ightweight of the eBee is the fact that the platform is make of flexible foam that has no sharp or hard edges. To that end, the eBee is easily hand launched and can land on almost any surface without requiring a parachute or landing net when belly landing.

While the eBee employs a manual control option for the PIC whic h allows the operator to take manual control during the flight, the senseFly eBee also utiliz es eMotion technology – an integrated software package that allows the PIC to plan a mappi ng flight through an easy-to-use interface. Upon launching the eBee, eMotion’s wireless connecti on with the sUAS tracks its position, monitors the progress of the mapping flight and sends commands to the sUAS if necessary. However, similar to t he DJI Inspire 1 and Phantom 3 Professional, Phantom 4, the senseFly eBee utilizes several failsafe features to ensure a sa fe flight. For example, as a precautionary measure, the eBee has been programmed with a seri es of emergency maneuvers: Land low; Abort landing; Roll; Fast climb; and Fast descent.

Additionally, the senseFly eBee will warn the PIC with a yellow “ACK WARNING” button for in-flight warnings and a red “CRI TICAL FAILURE” button for crit ical failures. To that end, there are numerous in-flight warnings that the eBee can tell the PIC, such as: Failure occurred; Low battery; Drone flight log malf unction; Flight controller malfun ctions; Camera sync malfunction;Petition for Section 333 Exemption

Aviation Alternatives Inc.
Page 9 of 20 Camera power malfunction; Baromet er malfunction; Motor malfunct ion; Battery malfunction; Airspeed malfunction; Low airspeed; Overspeed; Ground sensor ma lfunction; Wings detection malfunction; Temperature out of working levels; Above working a rea ceiling; Out of working area radius; Far outside of working ar ea; Poor GPS coverage; Data up link lost; Ground Proximity detected; Ground proximity not detected landing precision decre ased; Back wind; Strong wind; Cannot maintain altitude; and Pitch or Roll instability. Moreov er, there are numerous critical failure warnings that the eBee can tell the PIC, such as: Loss of GPS signal; Empty battery; INS Malfunction; Motor malfunction; and CPU overload.

The FAA has already granted numerous petitions for Section 333 exemption to commercial sUAS operators of the senseFly eBee. B elow is a sampling of granted Section 333 petitions for the commercial operation of the senseFly eBee, as well as the petit ioner’s proposed commercial usage

of the sUAS:

Exemption

Number Regulatory

Docket Number Flight Operation

11166 FAA-2014-0790 Agriculture Analysis; High-resolution Aerial Imagery 11263 FAA-2014-0727 Mapping and P recision Agriculture 11285 FAA-2014-1015 Aerial Mapping a nd Surveying Applications 11331 FAA-2015-0019 Mapping and Survey Applications 11801 FAA-2015-1019 Forensic Engineer ing and Fire Investigation Applications 11523 FAA-2015-0335 Mapping and Survey Applications

sUAS Model Specs

DJI Inspire 1 Specifications

Aircraft Weight (Battery Inc luded): 2935 grams Hovering Accuracy (P Mode): Ve rtical: 0.5m; Horizontal: 2.5m Max Angular Velocity: Pitch: 300 ֯ /s; Yaw: 150 ֯ /s Max Tilt Angle: 35 ֯ Max Ascent Speed: 5 m/s Max Descent Speed: 4 m/s Max Speed: 22 m/s (ATTI mode , no wind) Max Flight Altitude: 4500 m Max Wind Speed Resistance: 10 m/s Max Flight Time: Approximatel y 18 minutes

Motor Model: DJI 3510 Propeller Model: DJI 1345 Indoor Hovering: Enable d by default Operating Temperature Range: -10 ֯ C to 40 ֯ C Diagonal Distance: 559 to 581 mm

Dimensions: 438x451x301mm

GimbalPetition for Section 333 Exemption

Aviation Alternatives Inc.
Page 10 of 20 Model: ZENMUSE X3 Output Power (with Camera): Static: 9W; In Motion: 11W Operating Current: Station: 750mA; Motion: 900mA Angular Vibration Range: ±0.03 ֯ Mounting: Detachable Controllable Range: Pitch: -90 ֯ to +30 ֯ ; Pan: ±320 ֯ Mechanical Range: Pitch: -125 ֯ to +45 ֯ ; Pan: ±330 ֯ Max Controllable Speed: Pitch: 120 ֯ /s; Pan: 180 ֯ /s

Camera

Name: X3

Model: FC350

Total Pixels: 12.76M

Effective Pixels: 12.4M Image Max Size: 4000x3000 ISO Range: 100-3200 (video) 100-1600 (photo)

Remote Controller

Name: C1 Operating Frequency: 5.725~5.825GHz; 2.400~2.483GHZ Transmitting Distance: 2km (Outdoor and Unobstructed)

EIRP: 10dBM@900, 12dBm@5.8G, 20dBm@2.4G Video Output Port: USB, Mini-HDMI Power Supply: Bu ilt-in battery Charging: DJI Charger Dual User Capability: Host-a nd Slave connection

Mobile Devise Holder: Tablet or Smart Phone Output Power: 9W Operating Temperature Range: -10 ֯ C to 45 ֯ C Charging Temperature Range: 0-40 ֯ C Battery: 6000 mAh LiPo 2S

Charger

Model: A11- 100P1A Voltage: 26.3V

Rated Power: 100W

Battery (Standard)

Name: Inte lligent Flight Battery

Model: TB47 Capacity: 4500mAh Voltage: 22.2V Battery Type: LiP o 6S High voltage battery Energy: 99.9Wh Net Weight: 570g Operating Temperature Range: -10 ֯ C to 40 ֯ C Charging Temperature Range: 0-40 ֯ CPetition for Section 333 Exemption

Aviation Alternatives Inc.
Page 11 of 20 Max Charging Power: 180W

DJI Phantom 3 Professional Specifications

Aircraft: Weight: 1280 g Maximum Ascent Speed: 5 m/s Maximum Descent Speed: 3 m/s Maximum Speed: 16 m/s Maximum Flight Altitude: 6000 m Maximum Flight Time: 23 minutes (Approximately) Operating Temperature Range: 0 ֯ C to 40 ֯ C

GPS: GPS/GLONASS

Gimbal: Controllable Range: Pitch: -90 ֯ to +30 ֯

Vision Positioning: Velocity Range: <8 m/s (Altitude 2 m) Altitude Range: 30 cm – 300 cm Operating Range: 30 cm – 300 cm Operating Environment: Surf ace w/Clear Pattern and Adequate Lighting (Lux > 15)

Camera:

Sensor: S ony Exmor 1/2.3” Operating Temperature Range: 0 ֯ C to 40 ֯ C

Remote Controller: Operating Frequency: 2.400 GHz – 2.483 GHz

Maximum Transmission Distance: 2 km (outdoors and unobstructed) Operating Temperature Range: 0 ֯ C to 40 ֯ C Battery: 6000 mAh LiPo 2S

Mobile Device Holder: Tablets and smart phones Transmitter Power (EIRP): FCC: 20 dbm; CE: 16 dbm Working Voltage: 1.2 A @ 7.4 V

Charger: Voltage: 17.4 V

Rated Power: 57 W

Intelligent Flight Batte ry (PH3-4480 mAh 15.2V) : Capacity: 4480 mAh Voltage: 15.2 V Battery Type: LiP o 4S Energy: 68 WhPetition for Section 333 Exemption

Aviation Alternatives Inc.
Page 12 of 20 Net Weight: 365 g Operating Temperature: -10 ֯ C to 40 ֯ C Max Charging Power: 100 W

DJI Phantom 4

Specifications

Aircraft: Weight (including Battery): 1380g Max Ascent Speed: 6 m/s Max Descent Speed: 4 m/s Max Speed: 20 m/s Max Service Ceiling Above Sea Level: 6000m (19,685 ft) Max Flight Time: Appr x. 28 min Operating Temperature Range: 32 ֯ to 104 ֯ F (0 ֯ to 40 ֯ C) Satellite Systems: GPS / GLONASS Hovering Accuracy: Vertical:

+/- 0.1m

Horizontal:

+/- 0.3m

Obstacle Sensing System: Obstacle Sensory Range: 0.7 -15 m (2-49 ft) Operating Environment: Surf ace with clear pattern and adequate lighting (lux > 15)

Camera:

Sensor: 1/ 2.3” Effective pixels: 12M

Lens: FOV ISO Range: 8s t o 1/8000s Max Image Size: 4000x3000 Still Photography Modes: Single Shot

Burst S hooting: 3/5/7 frames

Auto E xposure Bracketing Time-lapse

HDR Video Recording Modes: UDH; FHD; HD

Gimbal: Controllable Range: Pitch -90 ֯ to +30 ֯

Vision Positioning System: Velocity Range: ≤ 10 m/s ( 2 m above ground ) Altitude Range: 0 – 10 m (0-33 feet) Operating Range: 0 – 10 m (0-33 feet) Operating Environment: Surf ace with clear pattern and adequate lighting (lux > 15)Petition for Section 333 Exemption

Aviation Alternatives Inc.
Page 13 of 20 Remote Controller: Operating Frequency: 2.400 GHz to 2.483 GHz

Max Transmission Distance: FCC Compliant: 5k (3.1 mi) Operating Temperature: 32 ֯ to 104 ֯ F (0 ֯ to 40 ֯ C) Battery: 6000 mAh LiPo 2S Transmitter Power (EIRP): FCC: 23 dBm Operating Voltage: 7.4 @ 1.2A

Intelligent Flight Batte ry (PH3-4480 mAh 15.2V) : Capacity: 5350 mAh Voltage: 15.2 V Battery Type: LiP o 4S Energy: 81.3 Wh Net Weight: 462 g Operating Temperature: -10 ֯ C to 40 ֯ C Max Charging Power: 100 W

senseFly eBee Specifications

Aircraft: Weight: 0.69 kg (1.52 lbs) Wingspan: 96 cm (38 in) Material: EPP foam, car bon structure & composite parts Propulsion: Electric pusher propeller, 160 W brushless DC motor Battery: 11.1 V, 2150 mAh Camera: WX ( 18.2 MP) or S110 RGB, thermoMAP

Operation: Maximum Flight Time: 50 minutes Nominal Cruise: 40-90 km/h (11-25 m/s or 25-56 mph) Radio Link Range: Up t o 3 km (1.86 mi) Maximum Coverage: 12 sq km/4.6 sq mi Wind Resistance: Up t o 45 km/h (12 m/s or 28 mph) Linear Landing Accuracy: Apprx. 5 m (16.4 ft)

Proposed Flight Conditions and Operating Procedures

Aviation Alternatives’ primary objective with every flight is t he safe return of the above specified sUAS models without injury to property or person. In order to o btain this desired objective, Aviation Alternatives will abide by the following flight and at mospheric conditions limitations when performing commercial fli ght operations with the DJI Inspi re 1, Phantom 3 Professional, Phantom 4, and senseFly eBee:

1. Aviation Alternatives will not ope rate the sUAS models when wei ghing more than 55 pounds, including payload.Petition for Section 333 Exemption

Aviation Alternatives Inc.
Page 14 of 20 2. Aviation Alternatives will not operate the sUAS models at a spe ed exceeding 87 knots (100 miles per hour). Aviation Alternatives will use eith er groundspeed or calibrated airspeed to determine compliance with the 87 knot sp eed restriction.

3. Aviation Alternatives will not operate the sUAS models at an al titude of more than 400 feet above ground level (AGL). Aviation Alternatives will m onitor altitude in feet AGL via GPS technology and monitoring.

4. Aviation Alternatives will only operate the sUAS models within VLOS of the PIC at all times. Aviation Alternatives will require the PIC to be able to use human vision unaided by any device othe r than corrective lenses, as s pecified on the PIC’s

FAA-issued airman medical certi ficate or U.S. driver’s license.

5. Aviation Alternatives requires the utilization of a visual obse rver (VO) on all commercial sUAS flights. The sUAS models will be operated withi n VLOS of the

PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintain s VLOS capability. Aviation Alte rnatives requires

that the VO and PIC be able to c ommunicate verbally at all time s. Aviation Alternatives does not permit el ectronic messaging or texting du ring flight operations. Aviation Alternatives requires the sUAS PIC to be d esignated before the flight and does not allow transfer of his or her designatio n during the flight. The

PIC must ensure that the VO ca n perform the duties required of the VO.

6. Aviation Alternatives requires that all operating documents (de fined as the granted exemption and all documents needed to operate the UAS model and conduct its operations in accordance with all grants conditions and limitat ions) must be accessible during sUAS operations and made available to the Adm inistrator upon reasonable request.

7. Aviation Alternatives will require a functional test should any sUAS model undergo maintenance or alterations that affect that sUAS model’s operat ion or flight characteristics, e.g., replacement of a flight critical compone nt, must undergo a functional test flight prior to conducting further operations u nder this exemption. Aviation Alternatives requires that all function flights be con ducted by a PIC with

a VO and remain at l east 500 feet from othe r people. Aviation A lternatives further requires that the functional test flight be conducted in such a manner so as to not pose an undue hazard to persons and property.

8. Aviation Alternatives will be r esponsible for maintaining and i nspecting the sUAS

model to ensure that the sUAS m odel is in a c ondition for safe operation.

9. Aviation Alternatives requires that, prior to each flight, the PIC conduct a pre-flight inspection and determine whether th e sUAS model is in a conditi on for safe flight. Aviation Alternatives requires that the pre-flight inspection m ust account for all potential discrepancies, e.g., inoperable components, items, or equipment. Should the inspection reveal a condition that affects the safe operati on of the sUAS model,Petition for Section 333 Exemption

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Page 15 of 20 Aviation Alternatives prohibits the aircraft from operating unt il the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight.

10. Aviation Alternatives requires co mpliance with the component ma nufacturer’s maintenance, overhaul, replacem ent, inspection, and life limit requirements for the components that combine to assemble the sUAS models.

11. Aviation Alternatives requires compliance with all sUAS model m anufacture’s safety bulletins for the sUAS model.

12. Aviation Alternatives requires all sUAS model PICs to hold eith er an airline transport, commercial, private, recreational, or sport pilot ce rtificate. Further, Aviation Alternatives requires the PIC to also hold a current F AA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal Governme nt. The PIC must also meet the flight review requi rements specified in 14 CFR § 61.56 in an aircraft

in which the PIC is rated on hi s or her pilot certificate.

13. Aviation Alternatives prohibits any PIC to operate the sUAS mod el unless the PIC demonstrates the ability to safely operate the sUAS model in a manner consistent with how the sUAS will be operated under this petition for exem ption, including evasive and emergency maneuvers and maintaining appropriate dis tances from persons, vessels, vehicles and st ructures. To that end, Aviatio n Alternatives requires the PIC’s qualificat ion flight hours and currency to b e logged in a manner consistent with 14 CFR § 61.51(b).

14. Aviation Alternatives prohibits flight operations of the sUAS m odels during night, as defined in 14 CFR § 1.1. All flight operations will be condu cted under visual meteorological conditions (VMC). Av iation Alternatives will not allow the sUAS model to be flown during special visual flight rules (SVFR).

15. Aviation Alternatives will not operate the sUAS model within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the ce nter of the airport symbol as denoted on the current FAA-published aeronautical cha rt, unless a letter of agreement with that airport’s management is obtained or othe rwise permitted by a COA issued to the exemption hol der. Aviation Alternatives wil l make the letter of agreement with the airport management available to the Admin istrator or any law enforcement official upon request.

16. Aviation Alternatives will oper ate the sUAS model at least 500 feet below and/or no more than 2,000 feet horizontal ly from a cloud. Aviation Alt ernatives will not operate the sUAS model when visi bility is less than 3 statute m iles.Petition for Section 333 Exemption

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Page 16 of 20 17. Aviation Alternatives requires the sUAS model to return to a pr e-determined location within the private or controlled-access property shoul d the sUAS model lose communications or lose its GPS signal.

18. Aviation Alternatives requires the PIC of any sUAS model to abo rt the flight in the event of unpredicted obstacles or emergencies.

19. Aviation Alternatives prohibits t he PIC of any sUAS model from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the sUAS model to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommend ed by the manufacturer if greater.

20. Aviation Alternatives requires that all documents used to ensur e safe operation and flight of the sUAS model and any documents required under 14 CF R §§ 91.9 and

91.203 to be available to the PIC at the Ground Control Station of the sUAS model any time the aircraft are operating. Aviation Alternatives will make these documents available to the Administrator or any law enforcement official upon reasonable request.

21. Aviation Alternatives requires th at during all flights, the sUA S model PIC remain clear and give way to all manne d aviation operations and activi ties at all times.

22. Aviation Alternatives prohibits the PIC of any sUAS model from operating the sUAS model from any moving device or vehicle.

23. Aviation Alternatives requires all flight operations of all sUA S models to be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and

structures unless:

a. Barriers or structures are present that sufficiently protect no nparticipating persons from the sUAS and/or debris in the event of an accident . Aviation Alternatives will ensure that nonp articipating persons remain u nder such protection. If a situation arises where nonparticipating person s leave such protection and are within 500 f eet of the sUAS, Aviation Altern atives requires flight operations to cease immediately in a manner ens uring the safety of nonparticip ating persons; and

b. The owner/controller of any vesse ls, vehicles or structures has granted permission for operating closer to those objects and the PIC ha s made a safety assessment of the risk of operating closer to those obje cts and determined that it does not present an undue hazard.

24. Aviation Alternatives will operate all sUAS models flights over private or controlled-access property with p ermission from the property ow ner/controller or authorized representative. Aviation Alternatives will obtain pe rmission from thePetition for Section 333 Exemption

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Page 17 of 20 property owner/controller or aut horized representative prior to each flight to be

conducted.

PRIVACY

Aviation Alternatives’ commercial operational use of the DJI In spire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee will not implicate any privacy con cerns. Since Aviation Alternatives will only commercially operate the sUAS models at the request of the property and/or business owner(s), Aviation Alte rnatives will have the express consent and permission of the property and/or business owner(s) prior to flying over private property. Aviation Alternatives’ use of these sUAS models poses no greater privacy concerns than the use of traditional fixed wing or rotorcraft aircraft for similar commercial operations. Should A viation Alternatives’ commercial sUAS activity require aerial based photographic or videographic imagery, images taken will be of

individuals who have consented to being photographed/filmed or otherwise have agreed to be in the area where aerial photographic or videographic imagery will take place.

PUBLIC INTEREST AND SAFETY

Unlike traditional fixed wing or r otorcraft aircraft, the use o f the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee for commercial opera tion promotes public interest and safety. Whereas traditional fixed wing or rotorcraft aircra ft are large, heavy, noisy, require flammable fuels and manned operators (placing the pilot’s life in jeopardy should there be an emergency), these sUAS models are small, light, quite, and do n ot require flammable fuels or a manned operator (i.e. not riski ng human life for the purpose of operation).

The use of Aviation Al ternatives’ sUAS mode ls also benefits the public from a safety perspective

since these sUAS models do not run on fossil fuels. Because the se sUAS models are battery powered, their use over the traditional fixed wing or rotorcraf t aircraft will be more environmentally and ecologically friendly. In addition to the n on-use of flammable fuels, given the extreme lightness of these sUAS models, should an emergency result in a forced landing, injury to property or persons would be negligible compared to the cata strophic injury to property or persons that would result in an e mergency landing of a traditio nal fixed wing or rotorcraft aircraft.

Apart from the added safety benef its of sUAS fli ght operations, the use of these sUAS models for the above noted commercial applications creates new economic op portunities that could fuel the continued growth of aviation and aviation related interests. Co nsequently, the public will benefit

from the use of sUAS models for c ommercial purposes as companie s like Aviation Alternatives will provide new jobs and ec onomic opportunities, fueling innov ation and creativity.

REGULATIONS FROM WHICH EX EMPTION IS REQUESTED

14 CFR §§ 61.23(a) and (c): Medical Certificates Requirement an d Duration

Aviation Alternatives requests exemption from 14 CFR §§ 61.23(a ) and (c) which provides for certain flight operations requiring medical certificates. Aviat ion Alternatives’ petition for exemption provides an equivalent level of safety in that Aviati on Alternatives would require a DJI Inspire 1, Phantom 3 Pr ofessional, Phantom 4, and senseFly eBee to hold either a c urrent medicalPetition for Section 333 Exemption

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Page 18 of 20 certificate, of any class, or a valid U.S. Driver’s License. Av iation Alternatives’ petition for exemption provides an equivalent level of safety as provided in 14 C.F.R. §§61.23(a) and (c).

14 C.F.R. §§ 61.101(e)(4) and (5): Recreational Pilot Privilege s and Limitations; 14 C.F.R. § 61.113(a): Private Pilot Privileg es and Limitations: Pilot in C ommand; and 14 C.F.R. §61.315(a): What Are The Privileges and Limits of My Sport Pilo t Certificate?

Aviation Alternatives requests exemption from 14 C.F.R. §§ 61.1 01(e)(4) and (5) which prohibits recreational pilots from receiving compensation for hire or pro viding flight services in furtherance of a business, respectively. In addition, Aviation Alternatives requests exemption from 14 C.F.R. §61.113(a), which prohibits a certif icated private pilot from r eceiving compensation or flying for hire when acting as PIC; and from 14 C.F.R. §61.315(a), which p rovides the holder of a sport pilot certificate may only act as pilot in command of a light-sport a ircraft.

Aviation Alternatives’ petition for exemption provides an equiv alent level of safety in that Aviation Alternatives requires the DJI Inspire 1, Phantom 3 Pro fessional, Phantom 4, and senseFly eBee PIC, at the bare minimum, to hold the privileges of a spor t pilot certificate under 14 C.F.R. §61 Subpart J, hold either a medi cal certificate or valid U.S. Driver’s License, and to demonstrate proficiency in the PIC’s ability to safely operate the sUAS mod els in a manner consistent with how the sUAS will be operated under this petition for exemption

.

Distinct comparisons between the commercial activities of Aviat ion Alternatives and other businesses operating traditional, manned, fixed wing or rotorcr aft aircraft expose the unnecessary limitations placed upon sport, recreational and private certifi cated pilots when considering PIC privileges of commercial sUAS f light operations. Whereas requir ing pilots of traditional, manned, fixed wing and rotorcraft aircraf t to hold commercial and Airli ne Transport Pilot (ATP) ratings ensures that the pilots possess the necessary skills, training and experience to safely transport persons and/or cargo from the poi nt of departure to the intende d point of destination, the same correlation for sUAS pilots and should not apply to the sUAS fl ight operations of Aviation

Alternatives.

In the case of Aviation Alternatives’ sUAS flight operations, n o persons or third-party cargo will be carried by the sUAS models during Aviation Alternatives’ aer ial based commercial operations. Unlike traditional fixed wing or rotorcraft aircraft, which mus t traverse over a greater distance, greater amount of property, and a greater amount of people in o rder to get from the point of departure to the intended point o f destination, Aviation Altern atives’ sUAS will only fly over property authorized by Aviation Alternatives’ clients. In other words, the sUAS models will not have to originate flight from a different location and traverse over the properties of disinterested parties in order to fulfill the purpose of Aviation Alternative s’ commercial flight operations. As such, the risk of injury to disinterested parties is substantia lly decreased by the use of a sUAS for aerial based commercial applica tions described within this peti tion.

Consequently, Aviation Alternativ es’ requirement that the sUAS PIC hold, at least, a sport pilot certificate provides an equivalent level of safety to the requi rement that a commercial or ATP rated pilot transport persons and/or cargo for hire in manned aircraf t.Petition for Section 333 Exemption

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Page 19 of 20 14 C.F.R. § 91.7(a): Civil Ai rcraft Airworthiness

Aviation Alternatives requests an exemption from 14 C.F.R. §91. 7(a) which prohibits the operation of civil aircraft unles s it is in airworthy condition . As there will be no airworthiness certificate issued for Aviation Alternatives’ DJI Inspire 1, Ph antom 3 Professional, Phantom 4, and senseFly eBee models, no standard will exist for determinin g airworthiness. In any event, Aviation Alternatives’ proposed Flight Conditions and Operating Procedure will ensure an equivalent level of safety with 14 C.F.R. §91.7(a).

14 C.F.R. § 91.119(c): Minimum Safe Altitude: General

Aviation Alternatives requests an exemption from 14 C.F.R §91.1 19(c) which provides that except when necessary for takeoff or landing, no person may operate an aircraft below an altitude of 500 feet above the surface. Furthermore, this section provides that an aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structu re. Aviation Alternatives’ petition requests that the DJI Inspire 1, Phantom 3 Professional, Phanto m 4, and senseFly eBee be flown at an altitude no higher than 400 feet AGL and, when complying with the conditions set forth in §23(b) of Aviation Alternatives’ Flight Conditions and Operatin g Procedures, at distances closer than 500 feet from any person, vess el, vehicle, or structure.

The requirement that the sUAS models maintain 400 feet or less AGL helps ensure that signal connectivity between the transmitter and receiver will not be l ost. In addition, this height restriction

ensures that the PIC will be able to maintain VLOS while simult aneously limiting the possibility

of the sUAS models’ interference with other NAS traffic. Moreov er, this requirement ensures at least 100 feet of vertical separation between sUAS commercial o perators and manned aircraft operating within the NAS.

Traditional principles requiring a 500 foot AGL minimum for fix ed-wing or rotorcraft aircraft stemmed from a desire to protect the public should the need for a forced landing arise due to an unforeseen emergency situation or loss of power. These same con cerns are not present with Aviation Alternatives’ sUAS models as they are extremely lightw eight and small. Any injury to property or person would be negligible when compared to the cat astrophic damage that a fixed wing or rotorcraft aircraft would inflict due to a forced landi ng. Consequently, Aviation Alternatives’ Flight Conditions a nd Operating Procedures provid e for an equivalent level of safety when compared to 14 C.F.R §91.119(c).

14 C.F.R. §91.121: Altimeter Settings

Aviation Alternatives requests exemption from 14 C.F.R. §91.121 which provides guidelines for the use of altimeter settings wh ile operating an aircraft. Avia tion Alternatives’ petition for exemption provides an equivalent level of safety such that the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee PIC will be able to determine the AGL height of the sUAS model due to GPS technology. The AGL height of the sUAS wi ll be displayed for the PIC during all flight operations. As such, the PIC will be able to maintain the requirement that the sUAS models fly no higher than 400 feet AGL during all flight o perations.Petition for Section 333 Exemption

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Page 20 of 20 14 C.F.R. §91.151(a)(1): Fuel Requi rements For Flight In VFR Co nditions

Aviation Alternatives requests exemption from 14 C.F.R. §91.151 (a)(1) which provides that no person may begin a flight in an airplane under VFR conditions w ith less than 30 minutes of reserve fuel. Aviation Alternatives’ petition for exemption provides an equivalent level of safety due to Aviation Alternatives’ prohibition against the PIC from beginni ng a flight unless (considering wind and forecast weather conditions) there is enough available power for the sUAS model to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the ma nufacturer if greater.

Given the design and technology of the DJI Inspire 1, Phantom 3 , and senseFly eBee, Aviation

Alternatives’ PIC will have acce ss to all relevant information concerning the sUAS model’s battery

life. The PIC will be able to make an accurate determination as to whether the PIC can comply

with Aviation Alternatives’ “fue l” requirements for each flight . Consequently, Aviation Alternatives’ Flight Conditions a nd Operating Procedures provid e for an equivalent level of safety when compared to 14 C.F.R §91.151(a)(1).

14 C.F.R. §91.405(a): Maintenanc e Required; 14 C.F.R. §91.407(a )(1): Operation After Maintenance, Preventative Maint enance, Rebuilding, Or Alteratio n; 14 C.F.R. §§ 91.409(a)(1) and (2): Inspections ; 14 C.F.R. 91.417(a) and (b): Maintenance Records

Aviation Alternatives requests exemption from the following F.A .Rs: 14 C.F.R. §91.405(a), which provides the owner or operator of aircraft shall have the aircr aft inspected pursuant to Subpart E of 14 C.F.R; 14 C.F.R. §91.407(a)(1), which provides that no pe rson may operate any aircraft having undergone preventive maintenance unless approved for ret urn to service by a person authorized under §43.7; 14 C.F.R. §§91.409(a)(1) and (2), which provides that no person may operate an aircraft within the preceding 12 calendar months unl ess an annual inspection has been performed; and 14 C.F.R. §§91.417(a) and (b), which provides fo r the recording of an aircraft’s

maintenance if the aircraft hol ds an airworthiness certificate.

Aviation Alternatives’ petition fo r exemption provides an equiv alent level of safety since Aviation Alternatives requires compliance with the sUAS manufacturer’s m aintenance, overhaul, replacement, inspection, and life limit requirements for the DJ I Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee. Due to the nature of a sUAS, comp liance with certain maintenance requirements under Subpart E of 14 C.F.R. are either impossible or cost prohibitiv e to implement when applied to a sUAS. As such, Aviation Alternatives should b e exempt from these regulations as Aviation Alternatives’ Flight Conditions and Operating Proce dures provide for an equivalent level of safety when compared to these F.A.R.s.