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JAMES B.· REDNER 

ATTORNEY AT LAW 

P.O. BOX 127 

SAINT MARKS, FLORIDA 32355 

-.. -·- .. • .• . ~ 7 

,, .. : - .I 

Direct: (850) 925-1618 

Mobile: (850) 228.:4300 Email: JBRedner@verizon.net 

September 9, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey A veriue, SE 

Washington, DC 20590 

Re: ·· Exemption Request Pursuant to Section 333 ofthe FAA Modernization and · 

Reform Actof2012, 49 U.S.C. § 44701(f),and Part 11 ofthe Federal Aviation _ · 

Regulations 

Dear Sir or Madam: 

On behalf of Sawgrass _Mutual Insurance Company ("Sawgrass Mutual"), pursuant to Section · 

333 of the FAA Modernization _and Reform Act of 2012 (the "Reform Act") ("Section 333"), 

Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, we request an exemption. from the 

Federal Aviation Administration regulations listed below and discussed in Appendix A to allow 

Sawgrass Mutual and its affiliates and/or subsidiaries to conduct commercial operations with the 

Dfl Phantom 2 Vision+ ("Phantom")1 small· unmanned aircraft systems ("sUAS") ·for aerial 

photography and videography in connection with homeowner and private property insurance 

inspections for policyholders of Sawgrass Mutuah, and to conduct research and development 

· operations to expi?re the use of sUAS to improve catastrophe response.3 

. Conducting the requested sUAS operations - ~esidential and private property inspections and 

research and development - can be done safely within the National Airspace S~stem ("NAS") 

and is in the public interest for several reasons, which are detailed further herein and include: (1) 

. removing safety risks associated with requiring both underwriters and claims adjusters to access. 

and inspect potentially dimgerous areas, including slippery or unstable roofs, (2) reducing the 

. risks associated with performing inspections of catastrophe areas -with manned aircraft, (3) 

reducing the an1ount of time required to complete underwriting, claims inspections, and to pay 

claims, and (4) improving the efficiency ofSawgrass Mutual's business operations. 

. . 1 The Phantom already has been approved for commercial use in similar contexts. -See Exemption Nos. 11138, · 

11153,11189,11191,11195,12030 - -

2 The FAA has granted similar exemptions. See Exemption Nos. 11175, 11293, 12030 

3 The FAA has granted similar exemptions. See Exemption Nos. I I_l88, 11309, 1_2030 
September 9, 2015 

Page 2 

Applicant Information 

The name of the applicant is: Sawgrass Mutual Insurance C~mpany 

The primary contact for t~is application, with a copy to the undersigned at the address above, is: 

Mr. James Esse, President 

Sawgrass Mutual Insurance Company 

I 000 Sawgrass Corporate Parkway, Suite 100 

Sunrise, Florida 33323 

Direct: (954) 3 76-6868 

Email: jesse@sawgrassmtitual.com 

Exemptions Requested 

. Sawgrass Mutual requests exemptions from the following regulations: 

14 c:F .R. Part 21, Subpart H; 

14 C~F.R, 61.23(a) and (c); 

14 C.F.R. 61. IOI(e)(4) and (5); 

14 C.F.R. 61.113(a) and (b); 

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);. 

14 C.F.R. 91.405(a); 

14 C.F.R. 91.4_07(a)(1); 

14.C.F.R. 91.4Q9(a)(1) and (2); 

14 C.F.R. 91_.417(a) and (b). 

Ain\'Orthiness of the sUAS 

· The Phantom is a quadcopter with gimbal-mounted cameras manufactured by DJI, a market 

leader in sUAS. The Phantom has been authorized to conduct commercial operations, incl~ding 

propeJ1y inspections, under several Section 333 exemptions.4 

. . 4 The ·Phantom already has been approved for commercial use in similar contexts. See Exemption Nos. 11138, 

11153,11189,11191,11195,12030 . 
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September 9,2015 

Page 3 

Technical specifications for the Phantom are summarized in the table belo\v . 

.. 

DJI Phantom 2 Vision+ 

Size -1 foot x I foot .. 

Total Weight · 1242 g (2.74lbs) 

Max Ascent Speed 6 m/s (12 knots) 

Max Descent Speed 2 m/s (4 knots) 

Max Flight Speed 15·m/s (29 knots) 

Hover Accuracy: Vertical/ Horizontal .8 m (2.6') /2.5 m (8.2') 

Controiler Frequency (Main Channel) 5.725-5.825 GHz (FCC Compliant) 

Controller Range 800 m (.Smiles) 

Communications (Second Channel) 2.4 GHz Wi-Fi (No Interference) 

DJI provides a comprehensive suite of training manuals, maintenance procedures and user's 

. guides for the Phantom.s Collectively, these documents will be referred to as the Phantom's 

"Operating Documents." PICs will be required to comply with all maintenance and inspection 

procedures outlined in the Operating Documertts. 

Operating Conditions 

Sawgrass Mutual requests an exemption subject to the conditions listed in Appendix B, which 

are similar to the operating conditions required for the FAA's previous grants of exemptions 

under Section 333. In accordance with the conditionsapproved in previous exemption grants, 

Sawgrass Mutual is requesting authority to operate the Phantom within visual line of sight ~mel 

below 400 feet AGL, except as provided by FAA Air Traffic Control via COA. These operating 

conditions,_ along with those listed in Appendix B, and the sUAS safety features listed belo\v 

provide an equivalent level of safety. 

The following safety features are incorporated into the Phantom to ensure public safety and safe 

integra~ion in.to the NAS: · · 

. • Stability Control with Auto-Takeoff and Auto-Land: The automated flight-control system 

can take off and land automatically, and the system autocorrects the aircraft's position to 

adjust for environmental disturbances such as wind. 

. . . 

s The Phantom Operating Documents are ~ttached in Appendix C. The Phantom Operating Documents are available 

at http://wwv;•.dji.com/product/phantom-2-vision/download. · 
September 9, 2015 

Page4 

• Intelligent Orientation Control CIOC) and .Inertial Measurement Unit CiMU): The built-in 

inertial sensor and barometric altimeter measures orientation and altitude·, respectively, 

and communicates this data back to the controller. 

• Live Map and Radar with Failsafe & ·Battery Warnings: The controller dis.plays a live 

map and radar 'to show the aircraft's recent flight path, heading, bearing and distance 

from "home" (a predetermined start location within the boundaries ofthe privately owned. 

property) ·for.complete situational awareness. It also illus.trates battery status and low 

. battery warnings with estimated time to return "home" tp alert the PIC and ensure that the 

aircraft does not power down unexpectedly during use. 

• LED Flight Indicators: LED lights are mounted to the four rotor arins to visually indicate 

aircraft orientation (attitude) and status of the flight control system_, alerting the PIC of . 

possible issues. 

• Maximum Height and Radius· Limits: Before beginning flight, the PIC may set a 

maximum altitude and di~tance that prevent the sUAS from exceeding altitude limits and 

distance from "home." 

• Flight.:limited Safety· Zones: The sUAS flight software comes loaded \vith a lisf of· 

·restricted areas that are divided into one of three categories: category A, category B, -or 

no fly. Category A areas include major international airports; Category B is comprised of 

smalier. airports; and the no-fly zones are sensitive national security areas such as· the 

White House. Each restricted area is comprised of a no-fly zone in which the sUf\S 

cannot be operated and awarning zone surrounding the no-fly zone in whi<;:h the PIC is 

alerted to the sUAS' proximity to a restricted area. Category A areas also include larger 

restricted-altitude zones in which the sUAS will only fly below a certain altitude. 

Additional details regarding the safety zones can be found in the Phantom manual, 

attached as Appendix C. 

• Loss of link: The built-in GPS system that aids in stability control will automatically 

return the sUAS to "home" if communication between the controller and aircraft is lost. 

'The sUAS will enter failsafe mode when connection with the controller is lost and will 

wait 3 seconds before either landing or returning to a home point to land, depending on 

·whether the sUAS is operating in GPS mode. When in non-GPS mode, the sUAS 

automatically lands after 3 seconds. In GPS mode, the aircraft automatically returns to 

. home and lands. When flying back to home, the aircraft first will ascend to pre-set 

.altitude to avoid obstacles. If the aircraft is above the pre-set al.titude when loss of link 

occurs, it will fly directly back to the home point. 
·. 

September 9, 2015 

.Page 5 · 

• .Loss of GPS: If a loss of GPS occurs, the PIC maintains positive control of the airc-raft 

and ~an either land the sUAS, hover in place until ·GPS is reacquired, or continue the 

flight. Additionally, the sUAS has the ability· to abort a flight in the event of unpredicted. 

obstacles or emergencies. . · 

Operator Requirements 

As a condition to ·the grant of the exemption, Sawgrass Mutual will require that the PIC hold 

either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC 

will. also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by 

a state, the District o~ Colombia, P~erto Rico, a terri_tory, a possession, or the Federal 

government. The PIC will meet the flight review requirements specified in 14 CFR § 61.56 in an 

aircraft in which the PIC is rated o~ his or her pilot certificate. 

· At the conclusion of the training, the PIC will be able to safely operate the sUAS in a manner 

consistent. with how the sUAS will be operated under this exemption, inc;luding evasive and 

- emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and 

structures. This training will include the following, to the extent necessary for the operations: 

I) Perform an appropriate number of flights with the Phantom to obtain complete 

operational proficiency. 

2) . Successfully learn and demonstr~te all· relevant flight maneuvers described m the 

·Phantom 2 Vision Pilot Training Guide. 

3) .Study and be knowledgeable of all relevant sections of the Phantom's User's Manual, 

Safety .Guidelines, Battery Safety Guidelines, and other relevant applicable mariuals, 

updates, alerts, warnings and safety bulletins provided by DJI for the Phantom· . .-

· 4) Study and be knowledgeable of all relevant sections of the Guide for the Phantom 2 

Vision & Vision+.6 

5) Understand and demonstrate relevant evasive maneuvers outlined in the "Always be. 

Prepared for the Worst" scenarios outlined in the Guide to the Phantom 2 Vision & 

Vision+. 

All training flights will be conducted over private or controlled-access property. Training flights_ 

will be logged for each PIC in tr~ining in a manner consistent with 14 CFR § 61.51 (b). 

6 The Guide to the Phantom 2 Vision & Vision+ contains maintenance information and technical and safety-related' 

guidelines: It is included· in· Appendix C. The Guide to the Phantom 2 Vision and Vision+ is· also available at 

https://www.dropbox:com/s/mv8dlhohc3mceym/DJI%20Phantom%20Vision%20?ummary%20Guide.pdf?dl=O. 
I. 

September 9, 2015 

Page 6 

Sawgrass Mutual respectfully submits that the operator qualificati'ons take into account the. 

operating conditions and characteristics of the sUAS. 

PubJic Interest 

Sawgrass Mutt.tal respectfully submits that using sUAS to inspect roof tops in lieu of requiring its 

employees, contractors or .independent claims adjusters to access.and visually inspect roofs and 

to conduct research and development into catastrophe support operations offers a net safety 

benefit and will achieve an enhanced level of safety, as mandated under Section 333(c) of the 

Reform Act Approval of this application also will benefit the p~blic/ interest by providing faster 

and more cost-efficient insurance claims processing and insurance underwriting. - -

Inspection operations over· catas~rophe areas with conventional manned aircraft involve very 

heavy aircraft, tra~siting to the ·operational - location, carrying· signi~cant quantities of . 

combustible _fuels, and a multi-person crew in piloting and observation roles. By contrast, the 

Phantom sUAS weighs less than three poul}ds, uses a battery for power, is carried to and from 

the area of activity, thereby obviating the need for airborne pilots and observers, and poses iess 

of a risk to people and infrastructure on the ground, as well as to other aircraft. 

Additionally, no national security issue is raised by the grant ·of the requested exemption due to 

the sUAS' small size and load-carrying capacity, as. well as its operational limitations and ·Jack of 

flammable fueL All P!Cs will have _been screened by the Department of Homeland Security.: 

The grant of the requested exemption is in the public interest based on the clear direction in 

Section 333 and- 49 U.S.C. -§ 4470l(f),7 the equivalent and enhanced level of safety- of. t_he 

proposed operations, the significant public benefit, an<) the cost savings to be realized as a result 

of using sUAS for aerial, insurance-related inspections. Accon:iingly, the applicant respectfuily 

requests that the FAA grant the requested exemption without delay. . -

· · Privacy Concerns 

The pr.oposed operations will take place only over private or controlled-access property and only 

after obtaining written or verbal consent from. the individual ·Who owns or controls the property 

or is the property owner's. authorized representative before each flight. No privacy issues are 

raised by this application. · 

7 Pursuant to 49 U.S.C. § 44701(f), the "Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the Administrator 

finds the.exemption is in the public interest." 
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September 9, 2015 

Page 7 

Federal Register Summary 

Pursuant to 14 C.F.R. § 11.81 (f), the following summary is provided for publication in the 

Federal Register;should·the FAA determine that publication is needed: 

Docket No.: No. FAA-2015-

Petitioner: Sawgrass Mutual Insurance Company 

Section of 14 CFR: Part 21, Subpart H, § 61.23(a) and (c), § ~1.1 01 (e)(4) and (5), § 6l.l-13(a) 

-and (b),§ 61.315(a), § 91}(a), §"91.l19(c), § 91.121, § 91.15l(a), § 9L405(a), § 91.407(a)(l), § 

91.409(a)(1) and (2), and §91.417(a).and (b). 

Description of Relief Sought: · Sawgrass Mutual ·respectfully seeks an exemption to conduct 

resi~ential building and private property insurance-related, aerial inspections using a small 

unmanned aircraft (55 pounds or less). 

cc: Mr. James Esse, President_ 

Sa,vgrass Mutual InsuranceCompany 

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September 9, 2015 

Page 8 

APPENDIX A 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION 

. Sawgrass Mutual requests an exemption from the following regulations as well as any additional 

regulations that the .FAA deems necessary to the operation of the DJI Phantom Vision 2+.sUAS: 

14 C.F.R. Part 21, Subpart H: Ainvortbiness Certificates 

. . 

Tile 14, Part 21, Subpart H of the Code of Federal Regulations establishes the procedural 

requirements for the issuance of airworthiness certificates as required by § 9l.l03(a)(l). Given 

the size arid weight of the aircraft, the operating conditions, design safety features, and the 

proposed conditions and limitations, it is unnecessary to go through the certificate of 

.airworthiness process uhder Part 21 Subpart H to achieve or exceed current safety levels. Such 

an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 

333. Section 333 authorizes the FAA to exempt aircraft from the requirement for an 

·airworthiness certificate, upon consideration of. the size, weight, speed, operational capability, 

and proxiri1ity to ~irports and populated areas of the sUAS involved. · 

In this case, an analysis of these criteria demonstrates that the sUAS ·operated without an 

·airworthiness certificate, under the conditions proposed herein, will be at -least as safe, or safer, 

than ·a conventional. aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The 

Phantom weighs 2. 74 pounds. It will not carry a pilot, passenger or flammable fuel. It will 

operate exclusively within a: controlled area pre-disclosed and in compliance with the conditions 

set forth herein. Unlike o_ther civil manned aircraft operations, operations under this exemption 

\viii be tightly controlled and monitored by the PIC and visual observer, pursuant to the · 

conditions set forth in Appendix B, the Operating Documents, and local public safety 

requirements. The FAA -will have advance notice of all operations; to the extent required, 

through the filing of NOT AMs. The lack of flammable fuel and the fact that the aircraft will be. 

carried to the ·location an9 not flown there all establish an equivalent level of safety. The sUAS 

provides at least an equivalent level of _safety to that of such operations being conducted with 

conventionaL aircraft that would be· exponentially larger and· which would be carrymg 

passengers, cargo,' and flan1mable fuel. 

14 C.F.R. § 61.23 (a) & (c) 

Section 61.23(a) requires a person exercising the privileges of a transport pilot certificate to hold 

a first-class medical certificate, the privileges of a commercial pilot certificate to hold a secondclass medical certificate, and the-privileges of a private or recreational pilot certificate to hold a 
September 9, 2015 

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third-class medical-certificate. Section 61.23(c) requires a person to hold a medicat·certificate or 

U.S. driver's Jicense when exercising the privileges ·of a sport pilot certificate in a light-sport 

aircraft other than a glider·or balloon.· · · 

The operations proposed_ here.in \yill provide an equivalent levei of safety by complying with the 

conditions and limitatiOI).S of this exemption. The FAA has found that these conditions and 

limitations provide an equivalent level of safety .in numerous previous exemptions including, but 

not limited to, Exemption Numbers 11213, 11252, 11275, 11277, and 11278. · 

14 C.F.R. § 61.101_ (e)(4) & (5): Recreation Pilot Privilege and Limitations; 14 C.F.R. § 

6i.315(a): What are the privileges and limits of my sport pilot certificate 

Section 61.101(e)(4) prohibits a recreational pilot from acting as pilot in command of an aircraft 

for compensation or hire. Section 61.101(e)(5) prohibits a recreational pilot from acting as pilot 

in command of an aircraft in furtherance of a business. Section 61.315(a) authorizes persons 

holding a sport pilot certificate to act as pilot in command of a light-sport aircraft. As with . 

previous Section 333 exemptions,s an equivalent level of safety is established because (1} the 

aeroriauti.cal -knowledge requirements that would be applicable to sUAS operations for a 

recreational pilot and sport pilot certificate were substantially similar as those for a private pilot· 

certificate; (2) holders of recreational and sport pilot certificates are subject to security screening. 

by the· Departm~nt of Homeland Security; and (3) risk was mitigated through conditions and 

limitations regarding PIC training. 

14 C.F.R. §§ 61.113(a) & (b): Commercial .Pilot Privileges 

Sections 61.113(a) & (b) -limit private 'pilots· to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the sUAS is remotely controlled 

with no passengers or property belonging to others on board. The area ·of operation is controlled 

and restricted, ·and all flights are planned and coordinated in advance as set forth in the Operating· 

Documents.· In conjunction with the PIC's. required training, the level of-safety provided by the 

requirements included in the Operating Documents meets or exceeds that provided by. a single 

individual holding·a commercial pilot certificate operating a conventional-aircraft. The proposed 

operations will achieve at"least an equivalent level of safety. · 

8SeeExemptionNos.ll310, 11311; 11312,11313,11315. 
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September 9, 2015 

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14 C.F.R. § 91.7(a): Civil Aircraft Ainvorthiness 

Section 91. 7(a) prohibits an indiyidual from operating a civil aircraft unless it is in an airworthy 

condition, No FAA standard exists for determining an aircraft's airworthiness when an 

.air\vorthiness certificate is not issued .. As the FAA ha~ done with previous exemption grants,9 

airworthiness will be ensured and an equivalent level of safety will be achieved by complianc~ 

with the Operating Documents prior to every flight. 

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

Section 91.119 establishes. safe altitudes for operation of civil aircraft. Specifically, Section 

91.119( c) limits aircraft flying over areas other than congested areas to an altitude of 500. feet 

above the surface, except over open water or sparsely populated areas. ln those cases, the 

aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. 

Because the aerial photography and videography work must be accomplished at altitudes less 

than 500 feet AGL an exemption is required. The equivalent level of safety will be achieved 

giveri the sUAS' size, weight, speed, and proposed operating conditions. The sUAS operations 

will be· conducted· over private or controlled-access property with consent granted by the 

property owner/controller or authorized representative prior to each operation. 

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

Section 91.121 requires each person operating an aircraft to maintain crmsmg altitude by. 

re(erence to an altimeter that is set "to the elevation of the departure airport or.an appropriatealtimeter setting available before departure." The Phantom's Inertial Measurement Units have 

barometric altimeters, but they cannot be set to the elevation of the departure location. Rather, 

upon. initialization, the sUAS calibrate its positions without user input and transmits a single 

altitude measurement to the ground .station.· Thus, an exemption is required. An equivalent level 

of safety will be achieved by the operator, pursuant to the Operating Documents, confirming the 

altitude ofthe.launch site shown on the altitude indicator_ before each flight. · 

14 ~.F.R. § 9L151(a): Fuel Requirements for Flight in VFRConditions 

This regulation prohibits an individual from beginning "a flight_ ·in an airplane under VFR. 

c.onditions 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 111inutes; or (2) At night, to fly after that for at least 45 minutes." 

· 9 See Exemption Nos. 11156, 11158, 11159. · 
September 9, 2015 

Page 1"1 

· The Phantom batteries provide approximately 25 minutes of powered flight. Without an 

·exemption from 14 C.F.R. § 91.151, the Phantom'sflights would not be allowed. Given the 

limitations on its proposed operations, allowing· the sUAS to oper~te without the required reserve 

Juel is reasonable and is consistent with prior exemptions. to· An equivalent level of safety will be 

achieved because operating the sUAS without 30 minutes of reserve fuel does not engender the 

type of risks that Section 91.151 (a) was meant to prevent given the size and speed at which thesUAS operat~s. In the unlikely event that a sUAS. should run out of battery_ power; it would 

s_imply la~d. ·Given the sUAS's weight and construction material, the risks are less than 

contemplated by the cuFrent regulation. Sawgrass Mutual will require the UAS to return home 

and land when the battery reaches ~0% ·capacity. · 

14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2), and. 91.417(a) & (b): Maintenance 

Inspections 

Section 91.405(a) requires that an aircraft operator or owner "shall hav·e that aircraft inspected as 

·prescribed in subpart E of this part and shall between required inspections, except as provided in · 

paragraph (c) of this seCtion, have 'discrepancies· repaired a·s prescribed i~ part 43 of this 

chapter." Section 91.407 similarly makes reference to requirements in . Part 43. ·section . 

91.409(a)(2) requires an annual inspection for the issuance of· an airworthiness certificate._ -

Section 91.417(a) requires the owner or operator to _keep ·records showing certain maintenance 

Work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and 

records of approval of the aircraft for return to service._- · 

An equivalent level of safety will be achieved by complying with the Operating Documents' 

maintenance and inspection requirements because the sUAS will carry no external payload and 

will operate only_ in restricted, predetermined areas. In addition, the PIC will ensure that the 

sUAS is in working order prior to initiating flight, perform requ_ired maintenance, and keep a log 

of any maintenance that is performed. Moreover, the PIC_ is the person most familiar with the 

aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an 

equivalent !~vel of safety. -

10 See Exemption I 0673 (allowing Lockheed Martin'Corporation to operate without_ compliance with 91.151 (a)); see 

_·also Exemptions 2689F, 5745, I 0673 and I 0808. 
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Page 12 

APPENDIX B 

SA WGRASS MUTUAL OPERATING LIMITATIONS 

1) Operations authorized by the grant of exemption are limited to the following aircraft: DJI 

Phantom 2-Yision+, which weighs 2. 74 pounds. 

2) The DJl Phantom 2 Vision+ shall not be flown ara speed exceeding -15 m/s. · 

3) The sUAS will not be operated at an altitude greater than 400 feet AGL. · All altitudes 

reported to ATC shall be ~n feet AGL. 

4) The sUAS must be: operated wit}:lin visual line ·of sight 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, as specified on the PIC's FAA-issued airman medical certificate. 

5) All operations must use a YO. The YO and PIC must be able to communicate. verbally at . 

. all tiines. The PIC must be designated before the flight The PIC must ensure that _the YO can 

perform the functions prescribed in the Operating Documents. 

6) The Operating Documents and this grant of exernptjon must be accessible during UAS 

operations and made available to the Administrator upon request. If a conflict exists between the· 

conditions and limitations in the exemption and the procedures outlined in the Operating 

Documents, the conditions and limitations in the exemption take precedence and must· be 

followed. Otherwise, Sawgniss Mutual must follow the procedures as outlined in its Operating· 

Documents. SawgrassMutual may update or revise its Operating Documents. -It is Sawgrass 

Mutual's responsibility to track such revisions and present ·updated and revised documents to the 

Administrator upon request. Sawgrass Mutual must also present updated and revised documents 

if it petitions for an extension or amendment to this grant of exemption. 

7) Prior to each flight the PIC must inspect the sUAS to ensure that it is in a condition for 

safe. flight. The PIC shall not operate the aircraft if the inspection reveals a condition that affects 

the safe operation of the sUAS until the necessary maintenance _has been performed and the 

sUAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must 

be· included in the preflight inspection. All maintenance and alternations must be properly 

· documented in the aircraft records. 
September_ 9, 2015 

Pa:ge 13 . 

. · 8) Any sUAS that has ·undergone maintenance or alterations that affect the sUAS operation 

or flight chara-cteristics (e.g., replacement of a flight· critical component) must undergo a · 

functional test flight in accordance with the Operator's Manual. The PIC who conducts· the 

functional test flight must make an entry in.the aircraft records of the flight. The requirements 

: and procedures for a functional test flight and aircraft record entry sha11 be included in the 

· Operator's Manual. · 

9) The pre-flight inspection must account for all discrepancies, e.g. inoperable components, 

items, or equipinent, not alrea~y covered in the relevant secti~ns of the 0perating Documents. 

I 0) Sawgrass Mutual must fo11ow · DJI's aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. · 

II) Sawgrass Mutual mus·t carry out its maintenance, inspections, and . .record-keeping 

requirements, in accordance with the Operating Documents. Maintenance, inspection, alterations, 

and status of replacement/overhaul component parts must be noted In the aircraft records, 

including total time in service, description of work accomplished, and the signature of the person 

authorized to return the sUAS to service. 

12) Each sUAS operated under this exemption must comply with a11 manufacturer Safety 

Bu11etins. · · · · 

13) . The PIC must hold either an airline transport, commercial, private, recreational, or sport 

pilot ·c_ertificate. The PIC_ must also hold a_ current FAA airman medical certificate· or a valid 

U.S. driver's license issued by a state, the District of Colombia, Puerto. Rico, a territory, a 

possession, or the Federal government. The PIC must also meet the tligh_t review. requirements 

specified:in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot_ certificate. 

14). Sawgrass Mutual may not permit any PIC to operate unless-the PIC meets the operator's _ 

qualification criteria and de_monstrates the ability to safely operate the sUAS in a manner 

· consistent with ·how the sUAS will be operated under this exemption, including evasive and 

emergency rpat:~euvers and maintaining appropriate distances from· persons, vessels, vehicles and 

. structureS. II PIC _qualification flight hours and currency must be logged in a manner consistent 

with 14 C.F.R. § 61.51(b). The PI<:;: must ensure that the VO is trained appropriately in order to 

fulfill his or her dutie~. A record of training and qualification must be documented and made· 

available upon request by the Administrator. Flights for the purposes of training the operator's 

PICs and VOs (training, proficiency, and experience-building), are permitted under the terms of 

this exemption. How~ver, tra{ning operations may only be conducted during dedicated training 

sessiOns. During training, proficiency, and experience-building flights, all persons not essential -

11 Prior documented flight experience that was obtained in compliance with applicable regulations _may satisfy this 

requirement. 
September 9, 2015 

Page 14 

for flight operations are considered nonparticipants; and the. PIC must operate the sUAS an 

appropriate distance from nonparticipants in accordance with these operating· conditions. 

IS) Operations may. not be conducted during night, as defined in 14 C. F :R. § 1. 1. All 

operations must be conducted under visual met~orological conditions ("VMC"). Flights under 

special visual flight rules ("SVFR")" are not authorized. 

16) The· sUAS may not operate within 5 nautical miles of an airport reference 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 by Sawgrass Mutual's COA. The letter of agreement with the airport management 

must be made available to the Administrator upon request. 

1 7) Th~ sUAS _may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when ~isibility is les~ than 3 ?t~tute miles from the PIC. 

18) If the sUAS loses communications or loses its GPS signal, the sUAS must return to a pre~ 

determined location within the private or controlled-acce_ss. property. · 

19) The PIC must abort the flight in the event of unpredicted obstacles or emergenCies in 

accordance .with the Operator's Manual. .- · 

20) · The PIC will be prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to· fly at normal cruising speed to the intended landing 

point and Ian~- the UA with 30% battery power remaining in accordance with the Operating · 

Documents. 

0 0 • 

21) All operations shall be. conducted in accordance with an A TO-issued COA. ·The 

exemption holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be.conducted under th~ terms of the attached COA. 

22) All aircraft opera~ed in accordance with the -requested exemption must be identified by 

serial number, registered in accordance with· 14 C.F.R. Part 4 7, and have identification (NNumber) markings in accordance with 14 C.F.R. Part 45, Subpart C: Markings shall be as large 

as practicabl~ . 

. 23) The radio frequency spectrum used for operation and control of the sUAS must comply 

with Federal Communication Commission (FCC) or other appropriate. government oversight 

agency requirements. 

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Septemqer 9, 2015 · 

Page 15 

24) The documents required wi.der 14 C.F.R. §§ 91.9 and 91.203 must be available to the PIC 

at·the Ground Control Station of the ·sUAS any time the. aircraft is operating. These documents 

shall be made available to the Administrator or any law enforcement" official upon request. 

. . 

25) . The sUAS must remain clear and yield the right of way to all ot}ier manned operations . 

and activities at all times. 

26) The sU.~S may not be operated from any moving device or vehicle. 

27) The sUAS may not be operate<:J over congested or densely populated areas. 

28) Flight operations must be conducted at least 500 feet from all nonparticipating persons; 

vessels, vehicles, structures, and public access roads unless: · · 

a. Barriers 9r structures are present that sufficiently protect nonparticipating persons 

from the. sUAS and/or debris in the event of an accident. . The operator must ensure that . 

nonparticipatrng persons remain under such· protection. If a situation . arises where· 

nonparticipating ·persons leave such protection and are within 500 feet of the sUAS, flight 

operations must cease immediately and/or; . 

b." · The.owner/controller of any vessels, vehicles .or structures has granted permission 

for operating closer to those objects and the PIC has ~ade a safety assessment o.f the risk of 

operating closer to those objects and determined that it does not present an undue hazard. 

· 29) Operations nearer than 500 feet to the PIC, YO, operatqr trainees or essential persons as 

defined in the Operating Documents are permitted if those operations do not present an. undue 

h~ard to those persons per§ 91.119(a) as determined by the PIC. 

30) All operations must be ~onducted over private or controlled-access property. 

31) Any incident, accident, or flight operation that transgresses the lateral or vertical 

· boundaries of the operational area as defined· by the applicable COA shall be reported to th~· 

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 

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September 9, 2015 

Page.l6 

APPENDIXC 

DJl PHANTOM 2 VISION+ OPERATING DOCUMENTS