# KEN SHAMRELL SHAMRELL AERIAL IMAG ERY
A DIVISION OF ALLISON SHAMRELL PHO TOGRAPHY, INC. 3251 Adams Ave, Suite C San Diego
, CA 92116 (619) 357

- 6625 Ken@AllisonShamrell.com

July 22 , 2015
U.S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 

### 20590

RE : Exemption Request to Sec tion 333 of the FAA Modernization & Reform Act of 2012 and Part 11 of Title 14, Code of Federal Regulations (14 CFR) from : Part 21, Subpart H; 45.23(b); 61.23(a)&(c); 61.101(e)(4)&(5); 61.113( a) ; 61.315(a); 91.7(a); 91.9(b)(2); 91.109; 91.119 (c) ; 91.121; 91.151(a) (1) ; 91.203( a)&(b); 91.405(a); 91.407(a)(1); 91.409(a) (1)& (2); 91.417(a)&(b).

Dear Sir or Madam,

I, Ken Shamrell, herewith known as the petitioner, am writing pursuant to the FAA Modernization & Reform Act of 2012 (henceforth known as the “Reform Act”) and 14 CFR Part 11 to request an exemption from the above referenced F ederal A viation R egulation s (F ARs) to allow for the operation of a small ultra lightweight unmanned aircraft system ( UAS ), a DJI Phantom 3 Professional, for commercial aerial photography and

v ideography purposes in the National Airspace System (NAS) regulated by the FAA.
The petitioner was a Naval Aviator for the U.S. Navy ( helicopter pilot #31260) and currently holds a commercial pilot’s license (#3601978) for both fixed

- wing single

- engine land and rotary aircraft , as well as instrument ratings for both fixed

- wing and rotary aircraft

. He also holds a current 2 nd class medical certificate (GX0720163) and has completed the DJI “New Pilot Experience ” introduction class taught by Drones Made Easy, a DJI authorized dealer in San Diego, CA . He is the business owner and operator of Shamrel l Aerial Imagery, a division of Allison Shamrell Photography, Inc., which is his wife’s professional photography business.

As d escribed fully below, the grantin g of this exemption would permit the operation of a small UAS under carefully

- crafted conditions in the NAS that would be a) limited, b) contr olled, c) predetermined, and d) safer than present industry standards of using conventional manned aircraft. Use of fixed

- wing aircraftand helicopters for aerial photography is cost

- prohibitive for smal l business owners, so granting this exemption would allow Shamrell Aerial Imagery to provide this service at a much lower cost. Approval of this exemption would thereby enhance NAS safety and fulfill the Secretary of Transportation’s (the FAA Administra tor’s) responsibilities to “ establish requirements for the safe operation of such aircraft systems in the national airspace system.” This will also enhance public awareness of the benefits and proper safety precautions of small UAS s by allowing qualified personnel with sufficient knowledge of airspa ces and the pilot ing of conventional manned aircraft to operate a small UAS safely and to teach others how to do so in a safe manner as well

. The operation will minimize ecological damage by utilizing an electrically powered aircraft that does not pollute the environment, and it will prom ote economic growth by allowing fellow business owners to afford aerial photography and videography services.
Commercial operation of a small UAS , as described herein, whi ch is equipped with a camera and sensors, would operate in the following manner:

• Aerial photography and/or video graphy for pub lic and/or private use to include p rofessional family portrait s essions (including pets and domesticated animals ), weddings, real estate, architecture, land surveying, engineering
, television, news gathering
, and other professional

- related activities.

• Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

• Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines
, and cell towers.

• Aerial photography and/or videography and/ or providing live video feed to assist with searc h and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it

.

• The ability to offer training to persons in dividually or belonging to private and/or public organizations ( to include educ ational groups) that have interests in the application of small UAS operations
, t o properly train potential UAS pilots in the appropriate safety precautions, f or educa tional reasons, and /or for the purpose of e nhancing safety of small UAS operations in the NAS as well as for the protection of persons and property.
Regulations from which the exemption is requested:

• 14 CFR Part 21 , S ubpart H

• 14 CFR § 45.23(b)

• 14 CFR § 61.23(a)&(c)

• 14 CFR § 61.101(e)(4)&(5)

• 14 CFR § 61.113(a)

• 14 CFR § 61.315(a)

• 14 CFR § 91.7(a)



### 2• 14 CFR § 91.9(b)(2)

• 14 CFR § 91.109

• 14 CFR § 91.119(c)

• 14 CFR § 91.121

• 14 CFR § 91.151(a)(1)

• 14 CFR § 91.203(a)&(b)

• 14 CFR § 91.405(a)

• 14 CFR § 91.407(a)(1)

• 14 CFR § 91.409(a)(1)&(2)

• 14 CFR § 91.417(a)&(b)
The petitioner plans to use a DJI Phantom 3 Professional. It is a battery

- operated quadcopter driven by electric motors (Model DJI 3510) with a maximum gross weight of 1280 grams ( ~2.82 lbs) , a maximu m airspeed of 16 m/s (~ 31.1 knots or

~ 35 .8 mph ), a maxi mum operating distance of 2000 meters (~1.2 miles) , and powered by a 4480 mAh 4S Lithium Polymer (LiPo) battery

. The dimensions are 40.36 cm x 40.36 cm x 19.05 cm ( 16 in x 16 in x 7.5 in ) with a diagonal size of 59.0 cm (~23.2 in) to include the propellers

. It includes a Sony 4K camera that allows for First Person View (FPV), a GPS receiver, a Vision Positioning System (VPS) , and software safety features that prevent the small UAS from flying in FAA ‘No F l y Z ones ’

. The DJI Phantom 3 Prof essional will be controlled by a C3 remote controller with an operating f requency of 2.400GHz

– 2.483GHz, and t he live video feed will have an op erating frequency of 2.4GHz ISM. It is able to provide real

- time flight dat a to the PIC via the DJI Pilot a pp, w hich furthe r increases situational awarenes s

. Both the aircraft’ s firm ware and DJI Pilot a pp are updatable to add additional capabilities and safety enhancements

. The DJI Phantom 3 Professional has the ability to hover and move along a vertical and horizontal plane simultaneously. Given its small size/weight and lack of combusti ble fuel, this small UAS will pose significantly less threat to the public compared to a much larger conventional manned aircraft, so thus it is much safer for the public

. The petitioner will always operate the small UAS in visual l ine of si ght (VLOS) within a predetermined area with sufficient preflight planning to ensure the safe operation for those involved in the flight activity as well as flying at a sufficiently safe distance a way from nonparticipants

.

Pilot in Command (PIC)

T he Pilot in Command of the small UAS shall hold at least a sport pilot certificate or higher, a 3 rd class medical certificate or valid U.S. driver’s license , shall have at least 10 total hours of UAS operations (5 of which in the respective make/model), and, when one i s available, attend the DJI New Pilot Experience course offered by the manufacturer or authorized dealer. The requirement for the UAS PIC to hold a sport pilot certif icate or higher for a conventional manned aircraft shall remain in effect unless the FAA rescinds this requirement. All other requirements listed here in shall c ontinue to stay in effect regardless

.



### 3OPERATING PARAMETERS

The petitioner agrees to adhere to the following limitati ons and conditions when conducting commercial operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM) :

• The UAS shall weigh less than 55 lbs including payload . The DJI Pha ntom 3 Pro fessional only weighs 1280g or 2.82 lbs

.

• The UAS shall have a maximum opera ting speed of no more than 87 knots (100 mph). The maximum recommended airspeed by the air craft manufacturer for the DJI Phantom 3 Pro fessional is 16 m/s (~31.1 knots or

~ 35.8 mph)

.

• The UAS shall be operated at an altitude of no more than 400 feet above ground level (AGL).

• The UAS shall be operated within visual line of sight (VLOS) of the PIC at all times using only unaided human vision ( other than corrective lenses )

.

• A ll operations shall utilize a visual observer (VO). T he UAS shall be operated within the VLOS of the PIC and VO at all times , and the PIC and VO shall be able to communicate verbally at all times during operation

. The PIC shall ensure that the VO is capable of performing th e duties and responsibilities required of the VO

.

• All operating documents shall be accessible during UAS operations and can be made available to the F AA A dministrator or any law enforcement offici al upon request

. Operating documents include this petition, the granted exemption letter
, and all documents needed to safely operate and fly the UAS . These documents shall be available to the PIC at the ground c ontrol point of the UAS any time the aircraft is operating.

• If the UAS has undergone any main tenanc e or alterations that affect its operation or flight characteristics, then a functional test flight shall be conducted prior to any further commercial operations. The functional test flight shall abide by all regulations specified herein and shall be conducted in such a manner that it will not pose an undue hazard to persons and property.

• The operator shall be responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

• Pr ior to each flight, the PIC shall conduct a thorough pre flig ht inspection and determine that the UAS is in a condition for safe flight

. In accordance with the DJI Phantom 3 Pro fessional user manual, the preflight checklist items will at a minimum inc lude : 1. Remote controller, intelligent f light b attery, and mobile device are fully charged

. 2. Propellers are mounted correctly & firmly. 3. Micro

- SD card has been inserted, if necessary.



### 44. Gimbal is f unctioning properly

. 5. Motors can start & are functioning properly. 6. The DJI Pilot app is successfully connected to the aircraft.

• The PIC shall follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection , and life limit requirements for the aircraft and aircraft components.

• The PIC shall comply with all manufacturer safet y bulletins while operating the UAS

.

• A PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman certificate or a valid U.S. driver’ s license, and will take and pass all necessary certifications /courses currently or in the future being approved by the FAA for commercial use.

• The operator shall only allow a PIC to operate the UAS if that PIC can demonstrate the ability to safely operate the UAS in a manner consistent with how the UAS will be operated un d er this exemption , including evasive & emergency maneuver s and maintaining appropriate distances from persons, vess els, vehicles, an d structures.

• UAS operations shall only be conducted during daytime visual meteorological conditions (VMC)

. The P IC shall not fly during night, which is defined in 14 CFR § 1.1 as “the time between the end of evening civil twilight and the beginning of morning civil twilight.”

• The majority of operations shall take place outside of 5 nautical miles (nm) from the geographic center or Airport Reference P oint (ARP) of a tower

- controlled or

- uncontrolled airport as denoted in the current FAA Airport/Facility D irector y (AFD). However, if operations a re to be within 5 nm of an ARP of a tower

- controlled or

- uncontrolled airpor t but outside 1.5 nm , the PIC shall notify the respective airport of the location, estimated flight time, duration, elevation, and any other pertinent information. Under these conditions, t he a ltitude will also be restricted on a sliding scale starting at 6 6 feet AGL at 1.5 nm and increasi ng to a height of 400 feet AGL at 5 nm

. Operations shall not take place with in 1.5 nm of an ARP. The DJI P hantom 3 Professional has built

- in software for all FAA regulated ‘No Fly Zones’ to prevent any possible flights occurring within these No Fly Z ones. The PIC shall continuously check for updates by the manufacturer to the aircraft’s firmware and DJI Pilot app to stay current on all No Fly Zones and any enhanced safety features.

• The UAS shall only operate in w eather that allows for an operating distance of 500 feet or greater below any clouds, an operating distance of 2,000 feet or greater horizontally from any clouds, and when visibility is greater than 3 statute miles from the PIC.

• If the UAS loses communications or loses its GPS signal, the UAS shall return to a safe pre determined location and land autonomously

.



### 5• The PIC shall abort the flight in the event of unpredicted obstacles or emergencies.

• The PIC shall only begin a flight if there is enough available power for the UAS to conduct the intended operation and to operate after that for at least 5 minutes . The maximum flight time for the DJI Phantom 3 Pro fessional is ~23 minutes, so flights shall be terminated at 25% battery power reserve to allow for at least 5 minutes of reserve power . The DJI Phantom 3 Pro fessional has built

- in software to automatically land the aircraft if the battery gets too low.

• The petitioner shall apply for an Air Traffic Organization (ATO) Certificate of Waiver or Authorization (CO A) upon receiving this exemp tion and shall conduct operations in compliance with said COA.

• The UAS shall b e identified by serial number and registered with the FAA in accordance with 14 CFR Part 47 to include as large as practicable identification (N

- Number) markings in accordance

w

ith 14 CFR Part 45, Subpart C.

• The UAS shall remain clear and give way to all manned aviation operations and activities at all times.

• The UAS shall not be opera ted by the PIC from any moving device or vehicle.

• The operator shall obtain verbal/written consent of all persons involved with the planned operation of the UAS , and a ll flight operations sha ll be conducted at least 500 feet away from all nonparticipating persons, vessels, vehicles, and structures unless:

o Barriers or structures are present that sufficiently protect nonparticipating persons from the UAS and/or deb ris in the event of an accident and the operator will ensure that nonparticipating persons re main under such protection.

o The owner/controller of an y vessels, vehicles , or structures has granted permission for operating closer to those objects and the PIC has made a n independent safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, operator trainees
, or essential persons are not considered nonparticipating persons

. The PIC shall only operate in reasonably safe environmen ts that are strictly controlled and are away from power lines, elevated lights
, and airports.

• Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office (AFS

- 80) within 24 hours. Accidents will also be rep orted to the National Transportation Safety Board (NTSB) per their instructions.



### 6EXEMPTION REQUESTS
14 CFR Part 21, Subpart H: Airworthiness Certificates
This regulation establishes the procedural requirements for the issuance of airworthiness certific ates as required by FAR §91.203(a) (1). The Federa l Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement f or an airworthiness certificate upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS

. In all cases, an analysis of these criteria demonstrates that the small UAS operated witho ut an airworthiness cert ificate in the restricted environment and under the conditions pr oposed will be at least as safe or safer than a conventional manned aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate but without the restrictions and conditions proposed herein

. Thus, given the size and limited operating area associated with the aircraft to be utilized by the petitioner, an exemption from 14 CFR Part 21
, Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act.

The small UAS to be operate d hereunder is less than 55 lbs (

~ 2.82 lbs ) fully loaded, carries neither a pilot
nor passenger s , carries no explosive materials or flammable liquid fuel s, and operates exclusively in carefully monitored ar ea s

. Unlike other civil aircraft, operations under this exemption will be tightly controlled and overseen by the operator , will abide by the restrictions and conditions propose d herein, and will comply with lo cal public safety requirements. These safety enhancements provide a greater degree of safety to the public and property owners than conventional manned operations conducted with airworthiness certificates issued under 14 CFR Part 21, Subpart H. Lastly, application of these same criteri a demonstrates that there is no credible threat to nat ional security posed by the small UAS due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and its inability to carry a substantial external load.

14 CFR § 45.23 (b): Display of M arks

This regulation requires visible marks to include the Roman capital letter "N" followed by the registration number , the size to be at least 3 inches high, and to be displayed on limited, restricted
, or light

- sport category aircraft or experimental or provi sionally certificated aircraft. T he operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable

. Even though the small UAS will have no airworthiness certificate ( via an exemption to 14 CFR Part 21, Subpart H ) , an exemption will be needed for this regulation as the small UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Also, g iven the size of the small UAS
, the 3 inch registration number and 2 inch “Experimental” lettering requirements will be impossible. However, both the registration number and t he word “Experimental” will be placed on the fus elage as large as practicable in compliance with §45.29 (f). The equivalent level of safety will be



### 7provided by having the small UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer
, and others working with the UAS wil l see its identification

.

14 CFR § 61. 2 3(a)&(c) : Medical C ertificates
Section (a) of t his re gulation requires different levels of medical certificates depending on the desired type of flying . Section (c) allows for either a medical certificate or valid U.S. driver’s license if exercising the privileges of a sport pilot certificate . I f the person uses a U.S. driver’s license
, then they must comply with that person’s restrictions or limitations imposed, have been found eligible for t he issuance of at least a 3 rd class airman medical certificate at the time of the most recent application, not have had his or her most recently issued medical certificate suspended or revoked, and not know or have a reason to know of any medical condition that would make that person unable to operate a light

- sport aircraft in a safe manner.
This application’s operational conditions specify that the PIC of the small UAS shal l hold at least a sport pilot certificate or higher and also possess a valid medical certificate or U.S. driver’s license. Since the training requirements listed herein are the same as a conventional manned aircraft pilot, then an equivalent level of saf ety can be achieved and thus the medical certificate requirements for operating a small UAS should be the same to hold eithe r a valid medical airman certificate or U.S. driver’s license. Therefore, an exemption is requested for this regulation.

14 CFR § 61. 101 (e)(4)&(5) : Recreat ional Pilot Privileges & Limitations
This regulation prevents a recreational pilot from acting as the PIC of an aircraft for compensation or hire or in furtherance of a business. The intent of this regulation is to prevent non

- com mercial pilots from op erating conventional ma n ned aircraft for commercial purposes. It does not refer to u nmanned aircraft

s

ystems and the qualifications to fly a small UAS for business purposes should be considerably less than the requirements for conventional manned aircraft since small UAS s are so much smaller in size, weight, and speed a nd thus pose a significantly less risk to persons or property on the surface

. The main reason the petitioner is submitting this exemption request is to all ow for the commercial use of a small UAS for business

- related operations , so thus an exemption is requested for this particular regulation.

14 CFR § 61. 113 (a) : Private Pi lot Privileges and Limitations

– Pilot in Command
This regulation states that no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire ; nor may that person, for compensation or hire, a ct as PIC of an aircraft

. An equivalent level of saf ety can be achieved by current r egulations because the petitioner ’s small UAS do es not carry any pilots, passengers , or property. The proposed operational conditions herein require that the PIC must hold at least a s port pilot c ertificate or higher with either a 3 rd class medical c ertificate



### 8issued by the FAA or a valid U.S. driver’s license

. Also, t he risks attendant to the operation of a small UAS is far less than the risk levels inherent in the commercial activities outlined in 14 CFR § 61. The intent of this application is to conduct a business, but t he operation an d limitations set forth in the FOM will equate to the safe operation of the small UAS

.

14 CFR § 61. 315 (a) : Sport Pilot Certificate Privileges
This regulation allows a person holding a sport pilot certificate to act as PIC of a light

- sport aircraft, but does not a llow them to fly for compensation or hire or in furtherance of a business. S ince the operational conditions specified herein requires the PIC of the small UAS to hold at least a sport pilot c ertificate or higher and the intent of this application is to conduct a business, an exempt ion is requested for this regulation. An equivalent level of safety can be met by requiring the small UAS ’s PIC to undergo the same level of training as a fully qualified pilot of a conventional manned aircraf t
, and the risks associated with flying a small UAS is far less than those associated with conventional manned aircraft due to the size, weight, and speed of the UAS

.

14 CFR § 91.7 (a) : Ci vil Aircraft Airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in an airworthy condition. As there will be no airworth iness certificate issued for this aircraft (via an exemption to 14 CFR Part 21, Subpart H)

, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness and thus this regulation is not applicable

. Given the size of the aircraft and the use of safety check lists prior to each flight
, an equivalen t level of safety will be achiev ed.

14 CFR § 91.9(b)(2): Civil Aircraf t Flight Manual, Marking, & Placard Requirements
This regulation states that n o person may operate a U.S.

- reg istered civil aircraft unless cu rrent, approved flight manual material, markings, and placards reside in side the aircraft. The intent of this regulation is to have flight manual information readily available to the aircrew while operating the aircraft. Given the size and configuration of the small UAS , an exemption is requested since it i s unable to carry people or documentation on board the aircraft

. However, in order t o obtain an equivalent level of safety and meet the intent of this regulation, the UAS operating documents (to include the flight manual) will be readily available to the P IC at the ground control point at all times during pr eflight and while conducting operational flights

.

14 C F R §91.109: Flight Instruction
This regulation provides that no person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls. By their design, small UAS s and remotely piloted



### 9aircraft (RPA) do not have fully functional dual controls. Flight control is accomplished through the use of

a single control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight t raining without fully functioning dual controls for a number of aircraft and for flight instruction in experimental aircraft. Since neither a pilot nor passengers will be carried in the small UAS and the size and speed of this aircraft is drastically smaller than a conventional manned ai rcraft , an equivalent level of safety can be accomplished by conducting flig ht instruction at a controlled RPA field and with the instructor standing directly next to the student at the controls.

14 CFR § 91. 119 (c) : Minimum Safe Altitudes
This regulation establishes safe altitudes for operation of civil aircraft , specifically stating th at the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure over sparsely populated areas

. Helicopters may be operated at less than the minimums if each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA and the operation can be conducted without hazard to persons or property on the surface.
Since the typical missio n of the small UAS would be for photography/ videography purposes or the survey of persons, vessels, vehicles, or structures, it would be necessary for the small UAS to operate closer than 500 feet in order to obtain useable footage. The small UAS is a rotorcraft similar to a helicopter and will never operate higher than 400 feet AGL
, unless th e structure to survey i s higher than 400 feet AGL and in this case the small UAS will not operate higher than 200 feet above the highest point on the structu re. Operations will only be flown when careful ly preplanned flight paths have been prepared and performed. In addition, the small UAS will only fly over individuals who are aware of the planned flight operations and have given verbal or written consent

. The aircraft will be operated at a low enough altitude to allow for safe separation fr om conventional manned aircraft and to allow for an emergency landing without undue hazard to persons or property on the surface should a power unit fail. Therefore, due to the small size
, weight, and speed of the UAS and the functions to be performed , an exemption is requested to allow for closer operation tha n specified in § 91.119 since an equivalent level of safety can be obtained due to the fact that the hazard s to persons and property are minimal compared to conventional manned aircraft.

14 CFR § 91.121: Altimeter Settings
This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set to the elevation of the departure airport or an appropriate altimeter sett ing available before departure and within 100 nm

. Although t he DJI Phantom 3 Professional does have a barometer, it primarily utilizes GPS and its Vision Positi oning System (VPS) to determ ine its height above the ground and uses the barometer as a backup . However, a n equivalent level of safety can be achieved because an AGL altimeter measurement is constantly transmitted via radio from the small UAS ’s onboard computer to the display screen held by the PIC to provide real

- time flight data monitoring
, including a constantly updated AGL readout.



### 1014 C FR § 91.151(a) (1) : Fuel Requirements for Flight in VFR Conditions
This regulation prohibits an individual from beginning “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 afte r that for at least 30 min utes .” The intent of this regulation is to provide a safety reserve in case of delays prior to landing.

The small UAS is battery operated and provides a maximum flight time of approximately 23 minutes

. The batt ery level indicator is transmitted to the main controller and is constantly updated on the display screen to provide real

- time flight data monitoring with an estimated remaining flight time based on the current battery level

. The small UAS utilizes LiPo 4 S 4480 mAh intelligent flight batteries with an advanced power management system that triggers failsafe modes if the battery depletes to a point that may affect the safe return of the aircraft

. Users are advised to return home or land the aircraft immediately when prompted of a low battery level. The small UAS will automatically land if the current battery level can only support the aircraft long enough to descend from its current altitude. The small UAS will also not be able to takeoff unless a s ufficient battery level is available prior to takeoff.
An exemption is requested from this regulation since the small UAS cannot even fly for the length of time specifi ed for the 30 minute reserve, its distance is limited to 2 km from the PIC, and the inte lligent flight batteries provide real

- time battery level monitoring while also having failsafe modes that can automatically land the aircraft if the battery level gets too low, so thus an equivalent level of safety can be achieved

.

14 CFR §91.203(a)& (b): C ivil Aircraft

– Certifications Required

This regulation states that no person may op erate a civil aircraft unless ( a) it has an appropriate and
current airworthiness certificate and (b) the airworthiness certificate is displayed at the cabin or cockpit

en trance so that it is legible to passengers or crew.

The small UAS fully loaded weighs no more t han 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the small UAS

. Also, via an exemption to 14 CFR Part 21, Subpart H , there will be no airworthiness requirement and thus this regulation is not applicable. An equivalent level of safety will be achieved by obtaining an exemption to Section 333 via this petition
, obtaining a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization (ATO) prior to conducting operations in the NAS, and registering the UAS with the FAA in accordance with Part 47. These documents will be ke pt at the ground control point where the pilot flying the UAS will have imm ediate access to them.

14 CFR Part 91, Subpart E [ §91.405 (a)

, 407 (a)(1) , 409 (a)(1)&(2) , 417 (a)&(b)] : Maintenance, Preventative Maintenance, & Alterations
These regulations require that an aircraft operator or owner “shall have that aircr aft inspected as prescribed in S ubpart E of this part and shall between required inspections, except as provided in



### 11

### DJI Phantom 3 Professional

GENERAL FEATURES

• Ready

- to

- fly

• 3

- axis camera stabilization

• Precision flight & stable hovering

• GPS/GLONASS positioning & auto return home

• Onscreen real

- time flight parameters

• High Definition 4k Camera

• Camera tilt control

• Film straight down

• Supports Adobe DNG RAW

• Adobe lens profile support

• Camera param eter setting

• Album synchronization

• FAA no

- fly zones locked out via installed software

AIRCRAFT SPECS

• Weight (including battery & propellers): 1280 g

• Diagonal Size (including propellers): 590 mm

• Max Ascent Speed: 5 m/s

• Max Descent Speed: 3 m/s

• Ho ver Accuracy

o Vertical: +/

- 0.1 m (when the Vision Positioning System is active) or +/

- 0.5 m

o Horizontal: +/

- 1.5 m

• Max Speed: 16 m/s (ATTI mode, no wind)

• Max Altitude Above Sea Level: 6000 m

• Operating Temperature: 0°C

– 40°C

• GPS Mode: GPS/GLONASS

VISION POSITIONING SYSTEM

• Max Velocity: Less than 8 m/s (when 2 m above ground)

• Operating Range: 30 cm

– 300 cm

• Operating Environment: Surface with clear pattern & adequate lighting (Lux > 15)

REMOTE CONTROLLER

• Operating Frequency: 2.400 GHz

– 2.483 GHz

• Max Distance: 2000 m (outdoors & unobstructed)

• Video Output Port: USB

• Operating Temperature: 0°C

– 40°C



### 13• Battery: 6000 mAh LiPo 2S

• Mobile Device Holder: For tablet or phone

• Receiver Sensitivity (1%PER):

- 101 dBm + 2 dBm

• Transmitter Power (EIRP)

o FCC: 20 dBm

o CE: 16 dBm

• Working Voltage: 1.2 A @ 7.4 V

INTELLIGENT FIGHT BATTERY

• Capacity: 4480 mAh

• Voltage: 15.2 V

• Battery Type: LiPo 4S

• Energy: 68 Wh

• Net Weight: 365 g

• Max Flight Time: ~23 minutes

• Operating Temperature:

- 10°C

– 40°C

• Max Charging Power: 100 W

• Battery Charger

o Voltage: 17.4 V

o Rated Power: 100 W

CAMERA

• Sensor: Sony EXMOR 1/2 .3” effective pixels: 12.4 M (total pixels: 12.76 M)

• Lens: FOV 94 ° 20 mm (35 mm format equivalent)

, f/2.8, focus at infinity

• ISO Range: 100

- 3200 (video), 100

- 1600 (photo)

• Shutter Speed: 8s

- 1/8000s

• Image Max Size: 4000 x 3000

• Still Photography Modes

o Single

- s hot

o Burst Shooting: 3/5/7 shots

o Auto Exposure Bracketing (AEB): 3/5

o Bracketed Frames at 0.7EV Bias

o Time

- lapse

• Video Recording Modes

o UHD: 4096x2160p @ 24/25 fps , 3840x2160p @ 24/2 5/30 fps

o FHD: 1920x1080p @ 24/25/30/48/50/60 fps

o HD: 1280x720p @ 24/25/30/48/50/60 fps

• Supported SD Card Types: Micro SD (Class 10 or UHS

- 1 rating, 64 GB max capacity)

• Max Bitrate of Video Storage: 60 Mbps

• Supported File Formats

o FAT32/exFAT



### 14o Photo: JPEG, DNG

o Video: MP4, MOV (MPEG

- 4 AVC/H.264)

• Operating E nvironment Temperature: 0°C

– 40°C

• Gimbal

o Controllable Range: Pitch

- 90 ° to +30°

o Stabilization: 3

- axis (pitch, roll, yaw)

APP/LIVE VIEW

• Mobile App: DJI Pilot

• EIRP: 100mW

• Live View Working Frequency: 2.4 GHz ISM

• Live View Quality: 720P @ 30fps (depending on conditions & mobile device)

• Latency: 2 20 ms (depending on conditions & mobile device)

• Required Operating Systems

o iOS 8.0 or later

o Android 4.1.2 or later

• Recommended Devices

o iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air ( WiFi

- only ) , iPad Air ( WiFi +Cellular ) , iPad Mini 2 ( WiFi

- only ) , iPad Mini 2 ( WiFi + Cellular ) , iPad Air 2 (WiFi

- only), iPad Air 2 (WiFi + Cellular), iPad Mini 3 (WiFi

- only), iPad Mini 3 (WiFi + Cellular)

o Android: Samsung S5, Note 3, Sonly Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 Min i



### 15