### . ' 

# ---

JAMES B.·REDNER ATTORNEY AT LAW 

### P.O. BOX 127 SAINTMARKS, FLORIDA 32355 

## -.. -·-
.. • .• .**~** 7 ,, .. :

- .I

Direct: (850)925-1618 Mobile: (850)228.:4300 Email: JBRedner@verizon.net September9, 2015 U.S. DepartmentofTransportation Docket Management System 1200NewJersey

### A veriue, SE Washington, DC 20590 Re: ·· Exemption Request Pursuant to Section 333 oftheFAA Modernization and · Reform Actof2012,49 U.S.C. 

### §44701(f),and Part 11 oftheFederal Aviation

_· Regulations 

## Dear Siror Madam: On behalf

# of Sawgrass _Mutual Insurance Company ("Sawgrass Mutual"), pursuant to Section · 333 ofthe FAA Modernization_and Reform Act of2012 (the "Reform Act") ("Section 333"), Subsection (f) of49 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 AppendixA 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?rethe use ofsUAS to improve catastropheresponse.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 inthe 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 oftime required to complete underwriting, claims inspections, and to pay claims, and (4) improvingthe efficiency ofSawgrassMutual'sbusinessoperations.



### . . 1 The Phantom already has been approved for commercial use in similar contexts. -See Exemption Nos. 11138, · 11153,11189,11191,11195,12030

- - 2

### The FAAhasgranted similarexemptions. See Exemption Nos. 11175, 11293, 12030 3The FAA has granted similarexemptions. See Exemption Nos. I I_l88, 11309, 1_2030September9, 2015 Page 2 ApplicantInformation The name ofthe applicant is: SawgrassMutual Insurance

### C~mpany The primary contactfor**t~is** application, with a copy to the undersigned at the address above, is: Mr. James Esse, President Sawgrass Mutual Insurance Company I000SawgrassCorporate Parkway, Suite 100 Sunrise, Florida 33323 Direct: (954) 376-6868 Email:jesse@sawgrassmtitual.com Exemptions Requested

.Sawgrass Mutual requests exemptions from the following regulations:

14 c:F.R. Part 21, SubpartH; 

### 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 ofthe sUAS

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

leader in sUAS. The Phantom has been authorizedto 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

.i·



## i 

# i I September9,2015 Page 3

Technical specificationsfor the Phantom are summarized

# in thetablebelo\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 DescentSpeed 2 m/s (4 knots) MaxFlight Speed 15·m/s (29 knots) HoverAccuracy: Vertical/Horizontal .8 m (2.6')/2.5 m (8.2') ControilerFrequency (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 grantsof 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 ofsight**~mel** below400 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 ofsafety. The following safety features are incorporated into the Phantom to ensure public safety and safe**integra~ion** in.to theNAS: · ·

. • Stability Control withAuto-Takeoffand Auto-Land: The automated flight-control system can take offand land automatically, and the system autocorrects the aircraft's position to adjustfor environmental disturbances such as wind.

. . . sThe Phantom Operating Documents are**~ttached** in Appendix C. The Phantom Operating Documents are available at http://wwv;•.dji.com/product/phantom-2-vision/download. ·September9, 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 communicatesthis 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" (apredetermined start location within the boundaries oftheprivately owned. property) ·for.complete situational awareness. It also illus.trates battery status and low

.battery warnings with estimatedtime to return "home"

### tp alertthe PIC and ensure thatthe aircraft does not powerdown unexpectedly during use.

• LED Flight Indicators: LED lights are mounted to the four rotor arins to visually indicate aircraft orientation (attitude) and status ofthe 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 preventthe sUAS from exceeding altitude limits and distancefrom "home."

• Flight.:limited Safety· Zones: The sUAS flight software comes loaded \vith a lisf of· ·restricted areas that are divided into one ofthree 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' proximityto 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 willautomatically return the sUAS to "home" ifcommunication between the controller and aircraft is lost. 'The sUAS will enter failsafe mode when connection with the controller is lostand will wait 3 seconds before either landing or returning to ahome 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. Ifthe aircraft is above the pre-set al.titude when loss oflink occurs, it will fly directly back to the home point.

### ·. September 9, 2015 .Page 5 ·

• .Loss ofGPS: Ifa loss ofGPS occurs, the PIC maintains positive control ofthe 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 ofunpredicted. obstacles oremergencies.

. · 

### Operator Requirements As a condition to ·the grant ofthe 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 ora 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 reviewrequirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated**o~** his or herpilotcertificate.

· At the conclusion ofthe 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 extentnecessary 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 PilotTraining Guide. 3) .Study and be knowledgeable of all relevant sections ofthe Phantom's User's Manual, Safety .Guidelines, Battery Safety Guidelines, and other relevant applicable mariuals, updates, alerts, warnings and safety bulletins providedby DJIfor 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 flightswill be conducted overprivate orcontrolled-accessproperty. Training flights_ will be logged for each PIC in**tr~ining** in a mannerconsistent with 14 CFR § 61.51(b).

6The 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. operatingconditions and characteristics ofthe sUAS. PubJic Interest SawgrassMutt.tal respectfully submits that using sUAS to inspectrooftops in lieu ofrequiring 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 ofsafety, as mandated under Section 333(c) ofthe Reform Act Approval ofthis application also will benefit the

### p~blic/interest by providing faster and more cost-efficientinsurance claimsprocessingand 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 weighsless than three poul}ds, uses a battery for power, is carried to and from the area ofactivity, thereby obviating the need for airborne pilots and observers, and poses iess ofa risk to people and infrastructure on the ground, as well as to otheraircraft. Additionally, no national security issue is raised by the grant ·ofthe 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 ofthe 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 ofusing sUAS for aerial, insurance-related inspections. Accon:iingly, the applicant respectfuily requests thatthe FAA grant the requested exemption without delay.

. -

· ·Privacy Concerns The pr.oposed operations will take place only over private orcontrolled-access propertyand 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. ·

7Pursuant to 49 U.S.C. § 44701(f), the "Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any ofsections44702-44716 ofthis title ifthe Administrator finds the.exemption is in the public interest."'· September9, 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: DocketNo.: 

### No. FAA-2015- Petitioner: Sawgrass Mutual Insurance Company Sectionof 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

. 'I.

I September9, 2015 Page 8 APPENDIXA EXEMPTIONREQUESTAND EQUIVALENTLEVEL OFSAFETY SHOWINGSUNDERAPPLICABLE RULES SUBJECTTOEXEMPTION

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

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

### 14 C.F.R. Part21, SubpartH: Ainvortbiness Certificates

. . Tile 14, Part 21, Subpart H of the Code of Federal Regulations establishes the procedural requirements for the issuance ofairworthiness 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 ofan equivalent level ofsafety 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 ofthe 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 ofNOTAMs. The lack offlammable fuel and the fact that the aircraft will be. carried to the·location an9 not flown there all establish an equivalent level ofsafety. The sUAS provides at least an equivalent level of_safety to that ofsuch 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 ofa transport pilot certificate to hold a first-class medical certificate, the privileges ofa commercial pilot certificate to hold a secondclass medical certificate, and the-privileges ofa private orrecreational pilotcertificate to hold aSeptember 9, 2015

.Page 9

third-class medical-certificate. Section 61.23(c) requires a person to hold a medicat·certificate or U.S. driver'sJicense when exercising the privileges·ofa sport pilot certificate in a light-sport aircraft otherthan a glider·orballoon.· · · The operations proposed_here.in \yill provide an equivalent levei ofsafety by complying with the conditions and limitatiOI).S of this exemption. The FAA has found that these conditions and limitations provide an equivalent level ofsafety.in numerous previous exemptions including, but not limited to, ExemptionNumbers 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): Whatare the privileges and limits ofmy sportpilot certificate Section 61.101(e)(4) prohibits a recreational pilot from acting as pilot in command ofan aircraft for compensation or hire. Section 61.101(e)(5) prohibits a recreational pilot from acting as pilot in command ofan 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 ofrecreational and sport pilot certificates are subjectto 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.PilotPrivileges 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 orproperty belongingto others on board. The area·ofoperation 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·acommercial pilot certificate operating a conventional-aircraft. The proposed operations will achieve at"least an equivalent level ofsafety. ·
8SeeExemptionNos.ll310, 11311; 11312,11313,11315.!· September9, 2015 ·Page 10



### 14 C.F.R. 

### §91.7(a): Civil AircraftAinvorthiness 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 notissued

.. As the FAA**ha~** done with previous exemption grants,9 airworthiness will be ensured and an equivalent level ofsafety will be achieved by**complianc~** with the Operating Documentspriorto every flight. 

### 14.C.F.R. 

### §91.119(c): Minimum SafeAltitudes 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 of500. 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 ofsafety 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/controllerorauthorized representative priorto each operation. 

### 14 C.F.R. 

### §91.121: AltimeterSetting 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 ofthe 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 ofthe departure location. Rather, upon.initialization, the sUAS calibrate its positions without user input and transmits a single altitude measurementto the ground.station.·Thus, an exemption is required. An equivalent level ofsafety 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): FuelRequirements for Flightin 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 ofintended landing and, assuming normal cruising speed- (1) During the day, to fly afterthat for.at least 30 111inutes; or(2) At night, to fly afterthat for at least45 minutes."

· 9 See Exemption Nos. 11156, 11158, 11159.·September9, 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 sUASto**oper~te** withoutthe requiredreserve Juel is reasonable and is consistent with priorexemptions.to·An equivalent level ofsafety will be achieved because operating the sUAS without 30minutes ofreserve fuel does not engender the type ofrisks 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 ofbattery_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 "shallhav·e that aircraft inspected as ·prescribed in subpart E ofthis 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·anairworthiness 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 Part43, orlicensed pilots and records ofapproval ofthe 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 orderprior to initiating flight, perform requ_ired maintenance, and keep a log ofany 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** ofsafety.

-

10See Exemption I0673 (allowing Lockheed Martin'Corporation to operate without_compliance with 91.151(a)); see _·also Exemptions 2689F, 5745, I0673 and I0808.'.

i i September 9, 2015. Page 12

APPENDIX B SAWGRASSMUTUAL OPERATING LIMITATIONS 1) Operations authorized by the grant ofexemption 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 thePIC 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 ofexernptjon must be accessible during UAS operations and made available to the Administrator upon request. Ifa conflict existsbetween 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'sresponsibility to track such revisions and present ·updated and revised documents to the Administrator upon request. Sawgrass Mutual must also present updated and revised documents ifit petitions for an extension oramendmentto this grant ofexemption. 7) Prior to each flight the PIC must inspect the sUAS to ensure thatit is in a condition for safe.flight. The PIC shall not operate the aircraft ifthe inspection reveals a conditionthat 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, ifutilized, must be·included in the preflight inspection. All maintenance and alternations must be properly

· documentedin 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 ofthe flight. The requirements : and procedures for a functional test flight and aircraft record entry sha11 be included in the
·Operator'sManual. ·

9) The pre-flight inspection must account for all discrepancies, e.g. inoperable components, items, orequipinent, not**alrea~y** covered in the relevant**secti~ns** ofthe 0perating Documents. I0) 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 ofwork accomplished, and the signature ofthe 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 orher 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 orderto fulfill his or her**dutie~.** A record oftraining and qualification must be documented and made· available upon request by the Administrator. Flights for the purposes oftraining 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 wasobtained in compliance with applicable regulations_may satisfy this requirement.September9, 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 bySawgrass Mutual's COA. The letter ofagreement with the airport management must be made available to the Administrator upon request. 17)**Th~** sUAS _may not be operated less than 500 feet below or less than 2,000 feet horizontallyfrom a cloud orwhen**~isibility** is**les~**than 3**?t~tute** miles from the PIC. 18) Ifthe sUAS loses communications or loses its GPS signal, the sUAS must return to a**pre~** determined location within the private orcontrolled-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 willbe prohibited from beginning a flight unless (considering wind and forecast weatherconditions) there is enough powerto·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 ATO-issued COA. ·The exemption holder may apply for a new or amended COA ifit intends to conduct operations that cannotbe.conducted under**th~** terms ofthe 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 47, 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 controlofthe sUAS must comply

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

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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 ofthe ·sUAS any time the. aircraft is operating. These documents shall be made available to theAdministratororany law enforcement"official upon request.

. . 25)

. The sUAS must remain clear and yield the right ofway to all ot}ier manned operations

. and activities at all times. 26) The**sU.~S** may not be operated from any moving device orvehicle. 27) The sUAS may not be operate<:J overcongestedordenselypopulated 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/controllerofany 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 closerto those objects and determined that it does notpresent an undue hazard.

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

defined in the Operating Documents are permitted ifthose operations do notpresent an. undue**h~ard** to those persons per§ 91.119(a) as determined bythe PIC. 30) All operations must be**~onducted** over private orcontrolled-access property. 31) Any incident, accident, or flight operation that transgresses the lateral or vertical

· boundaries ofthe 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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APPENDIXC DJl PHANTOM2 VISION+OPERATING DOCUMENTS