Spet 22st, 2015

US Department of Transportation, Docket Operations West

Building Ground Floor, Room w12-140

1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of DDW INC for an Exemption Pursuant to Section 333 of the FAA Modernization and

Reform Act of 2012

Dear Gentlemen:

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

and 14 C.P.R. Part 11, DDW INC hereby applies for an exemption from the Federal Aviation

Regulations ("FARs") identified below, to allow commercial operations of small unmanned

aerial vehicles.

This exemption is made based on information outlined in this petition (Appendix A), as well as the

DDW INC Operational Limitations (Appendix B) and the DJI Phantom 2/3 Operators Manual V 1.4. The

DJI Phantom 2/3 UAS was selected because it has a proven capability for controlled flight as well as a

gyro stabilized flight mode, GPS aided navigation, a compass, blinking LED’s on the bottom, a failsafe

mode for returning home.

Specifically, the UAS is:

A lightweight (< 7.0 lb gross weight with all on-board equipment), battery operated 4- motor

rotorcraft in the form of a quadcopter that takes off and lands vertically, manufactured by DJI,

Model Phantom 2/3 , with the following equipment:

− An on-board flight computer with GPS navigation and location ability that receives

signals for flight controls from a ground-based transmitter/controller;

− An on-board camera capable of capturing imagery in the form of full color, high definition

still photos and video;

− An on-board telemetry system that delivers flight data from the on-board flight computer

to the on-board radio transmitter including altitude AGL, horizontal and vertical speed,

compass direction of flight and direction back to its launch site;

− A 600mW, 5.8GHz on-board radio transmitter that transmits live video from the on-board

camera plus all the flight data from the telemetry system described above;

The Ground Station Includes:

− A Pilot in Command (PIC) in operational control of a flight operation from

beginning to end and who controls the UAS while in the air;

− A 100mW, 2.4GHz radio transmitter/controller operated by the PIC to control the

UAS

while in flight;

− A radio receiver receiving live video and flight data from the on-board

camera and computer projects it all together onto a screen for the PIC to view

during flight;

− A Visual Observer (VO) is a person who provides a second pair of eyes to

visually track the UAS while in flight.
Proposed Operations

DDW INC intends to use UAS in three general areas. First, DDW INC seeks an exemption to perform

video filming and photographing by air for public and private use. Second, it will employ UAS’s to

inspect land, residential, commercial and industrial structures and property. Third, DDW INC seeks

permission to use UAS to offer training to persons, from both private and public entities, which are

interested in the safe operation of UAS.

Specifically, DDW INC will use UASs which are equipped with cameras and sensors, in order to engage

in the following commercial activities:

(a) Video filming by air and photographing for public and private purposes, including:

television, cinematography, advertising, promotions, public or news mass events.

(b) Video filming by air and photographing to support professional operations in

engineering, land surveying, architecture, real estate and other related professional

activities.

(c) Inspections by air of agricultural areas.

(d) Inspections by air of infrastructure such as bridges, highways, electrical installations,

dams, aqueducts, photovoltaic power stations, wind farms and pipes. These inspections will

only be done under contract with the owners or with any local government authority.

(e) Inspection by air of land and residential, commercial and industrial structures, only

under contract with the owners or with any local government authority.

(f) Inspections by air to detect sources of pollution and gas emissions, under contract

with the owners in the area or with any local government authority.

(g) Support provided to search and rescue operations and reconnaissance in cases of need,

emergency or natural disasters and only when government authorities have requested it by

contract or donation.

(h) DDW INC is passionate about offering training to persons, private and public entities,

which are interested in the safe use of UASs, for purposes of enhancing the skills and safety

controls which make the NAS safer and for the protection of persons and property.

Relevant Statutory Authority

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely

accelerate the integration of civil unmanned aircraft systems into the national airspace system."

Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft

systems to operate in the National Air Space ("NAS") where it is safe to do so based on the following

considerations:
• The UAS’s size, weight, speed and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's

safety regulations and minimum standards when the Administrator decides a requested exemption is

in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. §

44701(f) (permitting exemptions from §§ 44701(a), (b) and§§ 44702-44716,et seq.). A party

requesting an exemption must explain the reasons why the exemption: (1) would benefit the public as

a whole, and (2) would not adversely affect safety (or how it would provide a level of safety at least

equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption).

DDW INC Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act

DDW INC proposed operations in this Petition for Exemption qualify for expedited approval pursuant

to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are satisfied.

Approval is Warranted Based on the UAS Size, Weight, Speed, and Operational Capability

DDW INC will employ the DJI Phantom 2/3 quadcopters for the operations specified in this Petition for

exemption. The Phantom 2/3 UASs have a maximum take-off weight of less than 7 pounds, the flight

speed will not exceed 87 Kts (100 mph), and it will not be flown in controlled airspace or at an altitude

that exceeds 400 feet AGL. All flights will be flown in such a way that they can be safely terminated

with a reserve battery power of 25% of the battery's maximum charge. The DJI Phantom 2/3 UAS do

not carry any flammable propellant or fuel. The Phantom 2/3 UAS also has an integrated GPS system

that calculates the UAS’s position and height and relays that information via a secure connection to the

operator. Additionally, the Phantom 2/3 UAS contain a failsafe mode if its connection to the remote

control is lost, and this system permits the UAS to return to a predetermined location and land

without injury or damage.

Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations Manual.

The DDW INC Operations Limitations and the DJI's operator's manual contain all of the procedures and

limitations necessary to successfully perform the operations specified in this Petition for Exemption.

Public Interest

The public interest will be served by granting DDW INC Petition for Exemption. Congress has

established a national policy that favors early integration of UASs into the NAS in controlled, safe

working environments such as those proposed in this Petition. In addition, the public also has an

interest in reducing the hazards associated with alternate methods of conducting similar operations.

Currently operations are conducted using teams that physically climb onto structures using ladders,

using low flying helicopters or aircraft, or simply not available by traditional means. By using UAS,

exposure to physical hazards will be reduced of conducting the operation while remaining safely on

the ground.
Additionally, DDW INC's intended uses for the UAS’s have identifiable safety benefits that include

reducing the danger and emissions associated with full size helicopters, UAS have no fuel to ignite or

explode, no crew, adds a greater degree of flexibility, which supplements the current capabilities

offered by manned aircraft, and public interest for a ground impact for of a small lightweight UAS is

further minimized from an ecological and safety standpoint.

Federal Register Summary

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

Register, should it be determined that publication is needed:

DDW INC seeks an exemption from the following rules:

Parts 21; §§ 45.23(b); 27; 61.113(a) and (b); 61.3; 91.7(a); 91.9(b)(2); 91.103; 91.109; 91.119;

91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and

(b) of Title 14, Code of Federal Regulations (14 CFR).

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

owners from the substantial hazards associated with performing equivalent work with

conventional aircraft, rotorcraft, or other methods.

Conclusion

DDW INC Petition for Exemption satisfies the criteria articulated in Section

333 of the Reform Act of 2012 including weight, speed, operating capabilities, proximity to airports and

populated areas, operation within visual line of sight and national security. Additionally, the Petition

provides more than adequate justification for the grant of the requested exemptions to permit DDW

INC to operate the selected UAS for the operations specified herein.

Granting the exemption will benefit the public interest as a whole in several ways, including (1)

significantly improving safety and reducing risk by alleviating human exposure to danger, and

(2) improving the quality of services and decreasing operating costs compared with

conventional flight operations.

Very Respectfully,

Michael Sanders

900 Meadow Lane

P.O. Box 99

Gardner, CO 81040
Appendix A

The regulations from which the exemption is requested are listed below. Beside each

regulation number is the page of the attached Appendix A upon which each may be found

together with our proposed equivalent level of safety for each regulation:

Parts 21,§§ 45.23(b); 27, 61.113(a) and (b) 61.3; 91.7(a); 91.9(b)(2); 91.103; 91.109; 91.119;

91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and

(b) of Title 14, Code of Federal Regulations (14 CFR).

Exemptions Requested

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authority, by its terms, includes exempting civil aircraft, as the term is defined under§ 40101 of the

Act, including UASs, from its safety regulations and minimum standards when the Administrator

decides a requested exemption is in the public interest.

DDW INC seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 27, 45, 61 and

91 for purposes of conducting the requested operations using a UAS. Listed below are the specific

sections of 14 C.F.R. for which exemption is sought:

14 C.F.R. Part 21, Subpart H - Airworthiness Certificates

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

Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft

normally used for the same application. (Regulatory Docket No. FAA- 2014-0352). These criteria are

met, and therefore no exemption is needed.

Equivalent Level of Safety

The UAS selected by DDW INC is safe when taking into account their size, weight, speed, and

operational capability. The UAS weigh less than 7 pounds and will be flown at less than 87 Kts (100

mph) and completely outside controlled airspace. Additionally, the UAS carry neither pilots nor

passengers, carry no explosive materials and or flammable liquid fuels, and operate exclusively

within the parameters stated in the Operator’s Manual and Operations Limitations.

Operations under this exemption will be closely controlled and monitored by the operator and will

be conducted in compliance with local public safety requirements, to provide security for the area

of operation. DDW INC will also provide the FAA with advance notice of all operations via

NOTAMS and coordination with the local FSDO. In all cases, the UAS operated under the proposed

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

airworthiness certificate without the restrictions and conditions of the proposed UAS operations.

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

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

category rotorcraft. To the extent the DDW INC UAS would otherwise require certification under
Part 27, we seek an exemption from Part 27's airworthiness standards for the same reasons

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

14 C.F.R. §§45.23(b), Display of marks; general

These regulations provide that each aircraft must display "N" and the aircraft's registration number in

letters at least 2 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in

letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UAS does not

have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration

number assigned to it by the FAA.

DDW INC proposes to achieve an equivalent level of safety by including the word "EXPERIMENTAL"

as large as practicable on the top of the aircraft, where the PIC, VO and others in the vicinity of the

aircraft while it is preparing for launch will be able to see the designation. Finally, the ground station

will display a high contrast flag or banner that contains the words "Unmanned Aircraft Ground

Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the

ground station, the banner should be visible to anyone that observes the aircraft and chooses to

investigate its point of origin.

In a previous Grant of Exemption, Regulatory Docket No. FAA-2014-0352, ​the FAA determined that

exemption from these requirements was warranted provided that the aircraft "have identification

(N-Number) markings in accordance with 14 C.F.R part 45, Subpart C if the markings are as large as

practicable."

14 CFR § 61.113 (a) and (b); 61.3 (c,2-v): Private Pilot Privileges and Limitations, Medical

Certificate

In addition, DDW INC seeks exemption from 14 C.F.R § 61.113, which restricts private pilot certificate

holders from flying aircraft for compensation or hire, and which would also require a second class

medical certificate. The purpose of this section is to ensure the skill and competency of any PIC where the

aircraft is carrying passengers or cargo for hire. In this case, while the UAS will be operated as part of a

commercial operation, it carries neither passengers nor cargo. In the Grant of Exemption in FAA Docket

No. FAA-2014-0352, the FAA determined that the unique characteristics of UAS operation outside of

controlled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC

to have a commercial pilot certificate and class II medical certificate. Additionally, instead of having a

second or third class medical, we suggest that the PIC exercise the privileges similar to that of a sport

pilot, requiring only a valid US driver’s license.

Equivalent Level Of Safety

Petitioner seeks to ensure safe operation by ensuring that any PIC is thoroughly versed in airspace and

communication issues pertaining to all aircraft operators but also in the unique aspects of UAS flight. The

owner of DDW INC does not have a commercial pilot’s license, however, the experience obtained beyond

a private pilot certificate in pursuit of a commercial pilot certificate in manned flight does not necessarily

aid a pilot in the operational environment proposed. To that end, DDW INC will require a PIC to have a

minimum of a private pilot’s license and adhere to the flight limitations listed in Appendix C.

We find that the combination of aeronautical knowledge, UAS airmanship skills, and verification through

remaining current is a sufficient method to evaluate a pilot’s qualifications, given that operations will be

conducted within the limitations outlined in this petition.
14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

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

condition to be operated. The FAA has stated (Regulatory Docket No. FAA-2014-0352) that no

exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft

Given its size, configuration, and load capacity, the Phantom 2/3 has no ability to carry such a manual

on the aircraft, not only because there is no pilot on board, but because there is simply no room or

capacity to carry such an item on the aircraft.

Equivalent Level Of Safety

The safety related purpose of this manual requirement can be equally satisfied by maintaining the

Phantom 2/3 manual at the ground control point where the pilot flying the Phantom 2/3 will have

immediate access to it. Accordingly, we request an exemption from § 91.9(b) (2)'s flight manual

requirements, on the condition that the Phantom 2/3 flight manual be available at the control point

during each operation.

14 C.F.R. § 91.103: Preflight Action

DDW INC seeks an exemption from 14 C.P.R.§ 91.103, which requires a PIC to become familiar with

specific information before each flight, including information contained in the FAA- approved Flight

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely

conduct the flight, an exemption is requested to the extent that an FAA- approved Flight manual is

required.

Equivalent Level Of Safety

An equivalent level of safety will be provided by following the Aircraft Operations Manual and flight

manual provided by the manufacturer. The PIC will take all required preflight actions- including

performing all required checklists and reviewing weather, flight requirements, battery charge,

landing and takeoff distance, aircraft performance data, and contingency landing areas- before

initiation of flight. The Operator's Manual and Operational Limitations will be kept at the ground

station with the operator at all times.

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

DDW INC seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "no person may

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

unless that aircraft has fully functioning dual controls." UAS and remotely piloted aircraft, by their

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

use of a device that communicates with the aircraft via radio communications.

Equivalent Level Of Safety
Given the size and speed of the UAS employed by DDW INC, an equivalent level of safe training can still

be performed without dual controls because no pilot or passengers are aboard the UAS, and all persons

will be a safe distance away in the event that the UAS encounters any difficulties during flight

instruction. In addition, we will conduct flight training at predetermined training sites. These training

flights will be conducted in a sterile area and will otherwise comply with the provisions in the Operator’s

Manual. The FAA has stated (Regulatory Docket No. FAA-2014-0352) that no exemption is required.

14 C.F.R. § 91.119: Minimum Safe Altitudes

DDW INC requests an exemption from the minimum safe altitude requirements of 14

C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may

not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or

structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a

helicopter to operate at less than those minimum altitudes when it can be operated "without

hazard to persons or property on the surface," provided that "each person operating the

helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

Equivalent Level Of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights

proposed herein, and given the lack of flammable fuel, any risk associated with these

operations is far less than those that presently exist with conventional aircraft. An equivalent

level of safety will be achieved given the size, weight, and speed of the UAS, as well as the

location where it is operated. In order to avoid any risk to aircraft, flight operations will be

restricted to 400' AGL or below.

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

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

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

elevation of the departure airport or barometric pressure. An exemption is required to the extent

that the UAS do not have a barometric altimeter, but rather a GPS altitude read out.

Equivalent Level Of Safety

The FAA has stated that an equivalent level of safety can be achieved if the UAS will be operated at 400'

AGL or below and within visual line-of-sight in addition to GPS based altitude information relayed in real

time to the operator. See Grant of Exemption to Astraeus Aerial, Docket No. FAA- 2014-0352. As the

attached Operations Manual indicates, the chosen UAS meets these requirements, and a zero altitude

initiation point will be obtained prior to flight.

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

DDW INC requests an exemption from 14 C.F.R. § 91.15l(a)'s fuel requirements for flight in

VFR conditions. Section 91.151 states:

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

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

intended landing and, assuming normal cruising speed -

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

(2) At night, to fly after that for at least 45 minutes.
Here, the technological limitations on UAS battery power means that no meaningful flight

operations can be conducted while still maintaining a 30 minute reserve. DDW INC proposes

that all flights comply with this requirement by mandating that the aircraft be safely landed

with no less than 25% of battery life remaining.

Equivalent Level Of Safety

The FAA has stated that an equivalent level of safety is provided if the UAS flight is terminated

with at least 25% reserve battery power still available. See Grant of Exemption to Astraeus

Aerial, Docket No. PAA-2014-0352. The Operations Manual conforms to this limit, providing an

equivalent level of safety.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned to

the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph

(b) provides that the airworthiness certificate be "displayed at the cabin or cockpit

entrance so that it is legible to passengers or crew."

At a maximum gross weight of less than 7 pounds, the UAS is too small to carry documentation, does not

have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of

safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by

the FAA will be co-located with the crew at the ground control station and available for inspection upon

request. The FAA has stated (Regulatory Docket No. FAA-2014-0352) that no exemption is required.

14 C.F.R. ​91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) ​Maintenance

Required

DDW INC seeks an exemption from the maintenance inspection requirements contained in 14

C.P.R.§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify

maintenance and inspection standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.P.R. §

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

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

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

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

UASs will not have.

Equivalent Level Of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be

performed in accordance with the Operator's Manual. As provided in the Operator's Manual,

flights will not be conducted unless a flight operations checklist is performed that includes all of

the aircraft's components.
Appendix B

Operational Limitations

1. The unmanned aircraft system (UAS) will weigh less than 7 pounds, including energy source(s) and

equipment.

2. The UAS will not be flown at a ground speed exceeding 87 kts (100 mph).

3. Flights will be operated at an altitude of no more than 400 feet above ground level (AGL), as

indicated by the procedures specified in the operator’s manual. All altitudes reported to ATC must

be in feet AGL.

4. The UAS will be operated within visual line of sight (VLOS) of the PIC at all times. This requires the

PIC to be able to use human vision unaided by any device other than corrective lenses.

5. All operations will utilize a visual observer (VO). The VO may be used to satisfy the VLOS

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to

communicate verbally at all times.

6. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the

inspection reveals a condition that affects the safe operation of the 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, if utilized, will be included in the preflight

inspection. All maintenance and alterations will be properly documented in the aircraft records.

7. If the UAS has undergone maintenance or alterations that affect the UAS operation or flight

characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight in

accordance with the operator’s manual. The PIC who conducts the functional test flight will make an

entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test

flight and aircraft record entry will be added to the operator’s manual.

8. The operator will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul,

replacement, inspection, and life limit requirements. When unavailable, aircraft

maintenance/component/overhaul, replacement, and inspection/maintenance requirements will be

established and identified in the operator’s manual. At a minimum, requirements for the following

will be included in the operator’s manual:

a. Actuators / Servos;

b. Transmission (single rotor);

c. Powerplant (motors);

d. Propellers;

e. Electronic speed controller;
f. Batteries;

g. Mechanical dynamic components (single rotor);

h. Remote command and control;

i. Ground control station (if used); and

j. Any other components as determined by the operator;

9. The Pilot In Command (PIC) will possess at least a private pilot certificate and at least a valid driver’s

license. The PIC will also meet the flight review requirements specified in 14 CFR §

61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

10. Prior to operations the PIC will have accumulated and logged, in a manner consistent with 14 CFR §

61.51(b), a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at

least ten hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). Prior

documented flight experience that was obtained in compliance with applicable regulations may

satisfy this requirement. Training, proficiency, and experience-building flights can also be

conducted to accomplish the required flight cycles and flight time.

11. Prior to operations the PIC will have accumulated and logged, in a manner consistent with 14 CFR §

61.51(b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized

for operations and three take-offs and three landings in the preceding 90 days. Training,

proficiency, experience-building, and take-off and landing currency flights can be conducted to

accomplish the required flight cycles and flight time.

12. The UAS may not be operated directly over any person, except authorized and consenting

personnel, below an altitude that is hazardous to persons or property on the surface in the event

of a UAS failure or emergency.

13. The operator will ensure that no persons are allowed within 500 feet of the area except those

consenting. This provision may be reduced to no less than 200 feet if it would not adversely affect

safety.

14. The UAS will abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operator’s manual.

15. Each UAS operation will be completed within 30 minutes flight time or with 25% battery power

remaining, whichever occurs first.

16. The operator will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or

Authorization (COA) prior to conducting any operations. This COA will also require the operator to

request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours

prior to the operation.

17. All aircraft operated in accordance will be identified by serial number, registered in

accordance with 14 CFR part 47, and have identification (N- Number) markings in

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.
18. Each UAS operated will comply with all manufacturer's Safety Bulletins.

19. The radio frequency spectrum used for operation and control of the UA will comply with the Federal

Communications Commission (FCC) or other appropriate government oversight agency requirements.

20. At least three days before scheduled flight, the operator will submit a written Plan of Activities

to the local FSDO with jurisdiction over the area of proposed flight area. The 3- day notification

may be waived with the concurrence of the FSDO. The plan of activities must include at least the

following:

a. Dates and times for all flights;

b. Name and phone number of the operator

c. Make, model, and serial or N-number of UAS to be used;

d. Name and certificate number of UAS PIC involved

e. A statement that the operator has obtained permission from property owners and/or

local officials to conduct the flight operations; the list of those who gave permission must be

made available to the inspector upon request;

f. Signature of exemption-holder or representative; and

g. A description of the flight activity, including maps or diagrams of any area, city, town,

county, and/or state over which flights will be conducted and the altitudes essential to

accomplish the operation.

21. The documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the

Ground Control Station of the UAS any time the aircraft is operating.

22. The UA will remain clear and yield the right of way to all other manned operations and activities at

all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities,

hang gliders, etc.).

23. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will

be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules

(SVFR) are not authorized.

24. The UAS will not be operated by the PIC from any moving device or vehicle.

25. The UAS will not be operated less than 500 feet below or less than 2,000 feet horizontally from a

cloud or when visibility is less than 3 statute miles from the PIC.

26. The UAS will not operate in Class B, C, or D airspace without written approval from the FAA. The

UAS may not operate within 5 nautical miles of the geographic center of a non- towered airport 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 NOTAM as required by

the operator’s COA. The letter of agreement with the airport management must be made available to

the Administrator upon request.

27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of
t

heoperational areaasdefinedbytheapplicableCOAwill bereportedtotheFAA’sUAS Integration

Office(AFS-80)within24hours.