January 9, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

C.F.R. Part 11, Focal Revolution, LLC (“Focal Revolution”), operators of small Unmanned Aircraft Systems 

(“sUAS”), seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below and discussed 

in Appendix A. 

The requested exemption would permit Focal Revolution commercial operation of AgEagle’s 2015 

AgEagle, DJI Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 (see 

details in Appendix B), in Precision Agriculture, survey/inspection, closed set cinematography, building 

inspection, public events, search and rescue, and commercial or residential real estate videography 

consisting of still photographs, video, and other data taken by onboard sensors. The 2015 AgEagle and 

DJI Inspire 1 use DroneDeploy software which produces high quality imagery and data that can be used 

independently – or in the case of surveying and thermal modeling, can be combined to produce 

precision charts, contour maps and determine the health of a crop. Applications for these sUAS include 

inspection of; mapping and surveying tasks in precision agriculture, crop scouting, crop insurance, 

hazard mitigation and in support of Federal Crop Management programs. Use of the 2015 AgEagle, DJI 

Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 for these 

inspections and surveying applications reduces the need to operate conventional aircraft, providing data 

more quickly, accurately, economically, safely, and with reduced environmental impact.

Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to currently authorized operations using manned aircraft 

and under conditions as may be modified by the FAA as required by Section 333. All sUAS will be 

registered in accordance with 49 U.S.C. 44103.

As described more fully below, the requested exemption would authorize Focal Revolution to perform 

Precision Agriculture, survey/inspection, closed set cinematography, building inspection, public events, 

search and rescue, and commercial or residential real estate videography using the 2015 AgEagle, DJI 

Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1, which are small in 

size and powered electrically by battery.
All sUAS will be operated under controlled conditions at low altitude (<400’ agl) in Class G airspace that 

is limited in scope, described more fully herein. The 2015 AgEagle and DJI Inspire 1 will have automated 

control features, as described below. All sUAS are designed to be operated by one person but flight 

operations generally involve two people, an operator and an observer. The operator is responsible for 

flying the sUAS, monitoring its status and flight dynamics while maintaining visual-line-of-sight (VLOS), 

and keeping the flight within the specified factory limits (in terms of wind, flight range, battery life, et 

cetera.) to ensure safe operations of the sUAS itself. The observer is responsible for monitoring the 

airspace for other aircraft and hazards and instructing the operator before and during flight as necessary 

to ensure safe launching and de-confliction with ANY aircraft or identified hazards. The operator also 

will be and individual who has passed the FAA approved or military equivalent ground training exam. 

Finally, the airspace in which the sUAS will operate will be disclosed to and approved, as needed, by the 

FAA in advance.

Focal Revolution respectfully submits that because these small, unmanned aerial systems will be used in 

lieu of comparatively hazardous operations now conducted with fixed and rotary wing conventional 

aircraft, the FAA can have confidence that the operations will achieve at least an equivalent-level or 

greater, of safety. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to 

“establish requirements for the safe operation of such aircraft systems in the national airspace system.”

The name, address and contact information of the applicant are:

Focal Revolution

Attn: David Wenzlick

PO Box 272

New Lothrop, MI 48460

+1 (517) 325-3976

david.wenzlick@focalrev.com

The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

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

14 C.F.R. 61.133(a)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b)(2) & (c);

14 C.F.R. 91.103;

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

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

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a).
Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set 

forth in this letter are appropriate, provide an equivalent level of safety, and are in the public interest. 

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Focal Revolution submits that grant of this exemption application for use of the 2015 AgEagle, DJI 

Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 in Precision 

Agriculture, survey/inspection, closed set cinematography, building inspection, public events, search and 

rescue, and commercial or residential real estate videography will advance the Congressional mandate 

in Section 333 of the Reform Act to accelerate the introduction of sUASs into the national airspace 

system (“NAS”) if it can be accomplished safely. This law directs the Secretary of Transportation to 

consider whether certain sUASs may operate safely in the NAS before completion of the rulemaking 

required under Section 332 of the Reform Act. In making this determination, the Secretary is required 

to determine which types of sUASs do not create a hazard to users of the NAS or the public or pose a 

threat to national security in light of the following:

 The sUASs size, weight, speed, and operational capability;

 Operation of the sUAS in close proximity to airports and populated areas; and

 Operation of the sUAS within visual line of sight of the operator.

Reform Act 333(a)(1). If the Secretary determines that such vehicles “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system.” Id. 333(c)

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

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

from the requirement that all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service:

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 44702-4471xx of this title if the 

Administrator finds the exemption is in the public interest.

49 U.S.C. 44701(f). See also 49 USC 44711(a); 49 USC 44704; 14 CFR 91.203(a)(1).

The grant of the requested exemption is in the public interest based on the clear direction in Section 333 

of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations; and the significant public benefit, 

including enhanced safety and cost savings associated with transitioning to sUASs for Precision 

Agriculture, survey/inspection, closed set cinematography, building inspection, public events, search and 

rescue, and commercial or residential real estate videography. Accordingly, the applicant respectfully 

requests that the FAA grant the requested exemption without delay.
Mandatory Operating Conditions

Grant of the exemption to Focal Revolution will be subject to the following mandatory conditions, which 

are based upon operating conditions set forth for operation of sUAS by public entities pursuant to 

Certificates of Authorization, with additional restrictions:

 All operations to occur in Class G airspace.

 Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts.

 Operations to be conducted over private or controlled-access property.

 Permission from land owner/controller required before commencing any flight.

 Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

 Aircraft to remain within Visual Line of Sight (VLOS).

 VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical miles (NM).

 Cylinder walls may be expanded by observer with ability to control aircraft.

 Operations to occur during daylight hours.

 Above Ground Level (AGL) altitude to be restricted to 400 feet.

 All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline 

azimuth of runway centerline measured from runway thresholds.

 Operator will file a NOTAM for each flight.

 All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

 All operations will include one pilot for flight control and one observer for VLOS enhancement of 

surrounding area near the aircraft.

Operator Requirements

Focal Revolution respectfully proposes that operator requirements should take into account the 

characteristics of the particular sUAS. Certain sUASs, such as the 2015 AgEagle, are characterized by a 

high degree of pre-programmed control and various built-in technical capabilities that limit the potential 

for operation outside of the operating conditions set forth above. The 2015 AgEagle sUAS also provides 

many built-in functional and safety features to assist the operator in safe and reliable operation 

powered by DroneDeploy risk-mitigation software.

The 2015 AgEagle provides two semi-autonomous flight modes using a point-and-click map and video 

interface.1

The user clicks on a map to direct the 2015 AgEagle to fly to the point on the map where the operator is 

pointing, or programmed flight plans may be entered for a series of waypoints or grid based area. 

Additional navigation aids including landing zones and flight areas may be designated to ensure the 2015 

 

1

AgEagle can submit under confidentiality the following documents in support of this exemption application for the 2015 AgEagle: 1) AgEagle 

2015 AgEagle User Guide which includes Safety and PreFlight Checklists; and 2) Training Manual.
AgEagle operates only within user-specified flight parameters. All flight operations are GPS controlled 

making the system easy to navigate, and the flight control system also employs a variety of sensors 

including sonar, barometric pressure, temperature, wind speed and others to ensure the high stability 

and reliability in challenging weather conditions. At all times during flight operations, the operator can 

intervene a programmed flight and take immediate control.

Using DroneDeploy’s software package, additional automated safety functions and safety enhancing 

features of the 2015 AgEagle include the following:

 Automated pre-flight system performance checks

 User pre-flight checklist

 “Hit the deck” mode can be activated by simply pushing a button on the controller which causes 

the aircraft to drop from its cruising altitude to 50 feet above the ground and circle there to 

avoid a collision with another aircraft.

 Automated condition or fault detection, warnings, and pre-defined responses to a number of 

flight and system conditions.

o High winds with system and user defined safety thresholds.

o Low battery with system and user defined safety thresholds.

o High temperature or other system safety thresholds.

o Lost-link communication

 Pre-defined responses include behavior such as attempting to re-establish radio communication, 

return to home position and hover, return to home position and land, or land in current 

position.

 In the case of lost GPS, a manual user flight mode is enabled which allows the operator to 

provide manual navigation inputs to assist in landing the vehicle.

Additional automated safety functions and safety enhancing features of the DJI Spreading Wings series 

S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 include the following:

 Auto-pilot detection of lost GPS or of insufficient satellites initiates a return home and land

 Low power on the sUAS triggers escalating alarms at Ground Control System (“GCS”) at 35% and 

10% levels

 If the auto-pilot detects a lost-link to the GCS for longer than 30 seconds, landing procedure 

begins

 The sUAS is inherently unstable, so auto-pilot fail will result in very rapid exit from flight

 Aircraft has an on-board failsafe

Given these safety features, Focal Revolution proposes that operators of the 2015 AgEagle, DJI 

Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 should not be 

required to hold a commercial or private pilot certification. Instead, operators should be required to:

 Have successfully completed, at a minimum, FAA private pilot ground instruction and passed the 

FAA Private Pilot written examination or FAA-recognized equivalents including commercial or 

private license and ground school issued from an ICAO recognized country;

 Have completed AgEagle’s authorized training program for operation and maintenance of their

sUAS.
Focal Revolution notes that the FAA has found that safety factors permitted operation of sUAS by 

operators with these qualifications in the case of operations pursuant to public COAs when the 

mandatory operating conditions specified above were present. See Federal Aviation Administration, 

Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 2013). 

The FAA has the statutory authority to grant exemptions to the requirements for and privileges 

associated with the grant of airmen’s certificates. 49 USC 44701 (f).

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix C to allow 

Precision Agriculture, survey/inspection, closed set cinematography, building inspection, public events, 

search and rescue, and commercial or residential real estate videography operations.

Approval of the exemption allowing commercial operations of the 2015 AgEagle, DJI Spreading Wings 

series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 for Precision Agriculture, 

survey/inspection, closed set cinematography, building inspection, public events, search and rescue, and 

commercial or residential real estate videography operations will enhance safety by reducing risk. 

Conventional aerial survey and inspection operations using manned aircraft involve very heavy aerial 

vehicles carrying significant quantities of combustible fuels, and a multi-person crew in piloting and 

observation roles. These operations require transit to and from the location of the activity, and often 

take place in congested environments and include close proximity to physical obstacles and/or presence 

of the general public. By contrast, sUAS are small and use battery for power, transported or carried 

to/from the area of activity, removes the need for airborne pilots/observers, and poses less risk to 

people and infrastructure on the ground.

Additionally, no national security issue is raised by the grant of the requested exemptions. Given the 

size, load carrying capacity, speed at which it operates, and the fact that it carries no explosives or other 

dangerous materials, the 2015 AgEagle, DJI Spreading Wings series S1000+, S1000, DJI Phantom 2, 

Phantom 3, and DJI Inspire 1 pose no threat to national security.

The operation of the 2015 AgEagle, DJI Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 

3, and DJI Inspire 1 for Precision Agriculture, survey/inspection, closed set cinematography, building 

inspection, public events, search and rescue, and commercial or residential real estate videography 

operations in accordance with the strict conditions outlined above, will provide an equivalent level of 

safety supporting the grant of the exemptions requested herein, including exempting Focal Revolution 

from the requirements of Part 21.

The 2015 AgEagle, DJI Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 

1’s satisfaction of the criteria set forth in Section 333 of the Reform Act (i.e. size, weight, speed, 

operating capabilities, operation within VLOS and lack of proximity to airports, populated or areas of 

national security) and demonstrated equivalent level of safety as it relates to the requirement for FAA 

pilot certification, provide more than adequate justification for the grant of the requested exemptions 

allowing Focal Revolution commercial operation of the 2015 AgEagle, DJI Spreading Wings series 

S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 for Precision Agriculture, survey/inspection, 
closed set cinematography, building inspection, public events, search and rescue, and commercial or 

residential real estate videography operations.

In conclusion, the safe operation of the 2015 AgEagle, DJI Spreading Wings series S1000+, S1000, DJI 

Phantom 2, Phantom 3, and DJI Inspire 1 is of utmost concern and safety remains paramount. Focal 

Revolution intends to operate within the spirit of all applicable FAA regulations and will adhere to any 

further refinements.

Best Regards,

David Wenzlick

Focal Revolution

APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES 

SUBJECT TO EXEMPTION

Focal Revolution requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of the 2015 AgEagle, DJI Spreading Wings series 

S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1:

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

14 C.F.R. 91.203(a)(1)

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR § 91.203(a)(1). Given the size of the aircraft (7.5 lbs.) and 

the limited operating area associated with its utilization, it is unnecessary to go through the certificate of 

airworthiness process under 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 of the 

Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the sUAS 

involved. In this case, an analysis of these criteria demonstrates that the 2015 AgEagle, DJI Spreading 

Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 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 2015 AgEagle, DJI 

Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 weighs less than 50

lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate 

exclusively within an area pre-disclosed and in compliance with conditions set forth herein. Operations 

under this exemption will be tightly controlled and monitored by both the operator, pursuant to the 

conditions set forth above, and by local public safety requirements. The FAA will have advance notice of 
all operations through the filing of NOTAMs. Receipt of the prior permission of the land owner, the size 

of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not 

flown there all establish the equivalent level of safety. The 2015 AgEagle, DJI Spreading Wings series 

S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 provides at least an equivalent, and most 

likely exceeds, level of safety to that of such operations being conducted with conventional manned 

aircraft that would be significantly larger and would be carrying additional personnel, cargo, and 

flammable fuel.

14 C.F.R. 45.23 & 91.9(c): Marking of the Aircraft

Regulation 45.23 provides:

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman 

capital letter “N” (denoting United States registration) followed by the registration number 

of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital 

letter.

(b) When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the 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.

Regulation 91.9(c) provides:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter.

The 2015 AgEagle, DJI Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 

1 has no entrance to the cabin, cockpit, or pilot station on which the markings can be placed. Given the 

size of the sUAS, two inch lettering will be impossible.

14 C.F.R. 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; 

Commercial Pilot Privileges and Limitations.

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft 

that carries a pilot, passengers, and cargo, the 2015 AgEagle, DJI Spreading Wings series S1000+, S1000, 

DJI Phantom 2, Phantom 3, and DJI Inspire 1 in this case is remotely controlled with no passengers or 

property of others on board. Section 61.133(a) requires an individual with a commercial pilot’s license 

to be pilot in command of an aircraft for compensation or hire. Focal Revolution respectfully proposes 

that operator requirements should take into account the characteristics of the particular sUAS.

Flight safety is a priority, no matter the operating environment or project. The 2015 AgEagle, DJI 

Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 offers superior 

safety over manned aircraft by removing the need for people to be onboard in potentially dangerous 
situations. With multiple built-in safety features, the AgEagle platform leads other sUAS with respect to 

safety.

 Intelligent fault handling: The system automatically detects potential issues – with configurable 

automated response behavior such as a return-home-and-land routine.

 Automatic pre-flight checks: The system self-calibrates all of its sensors and performs self-tests 

prior to takeoff to check for errors.

 No-fly zones: The system has the ability to set up visual no-fly zones.

 Self-monitoring: Monitoring battery levels, in-flight wind speeds, and other system and 

environmental conditions are automatically handled by the system.

 Battery communication: Battery minutes and flight time are displayed at all times. The system 

will return home and land automatically if user-configurable limits are reached.

Additional automated safety functions and safety enhancing features of the 2015 AgEagle include the 

following:

 Auto detection of lost GPS warns the pilot and initiates an immediate landing.

 Low battery on the 2015 AgEagle triggers a Non-Fatal Warning alarm to return home, land and 

replace the battery.

 Very low battery on the 2015 AgEagle triggers a Fatal Error Alarm and initiates an emergency 

high speed descent landing.

 If the 2015 AgEagle detects a lost-link to the base station the vehicle will perform its pre-defined 

Non-Fatal Condition Response.

Additional automated safety functions and safety enhancing features of the DJI Spreading Wings series 

S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 include the following:

 Auto-pilot detection of lost GPS or of insufficient satellites initiates a return home and land

 Low power on the sUAS triggers escalating alarms at Ground Control System (“GCS”) at 35% and 

10% levels

 If the auto-pilot detects a lost-link to the GCS for longer than 30 seconds, landing procedure 

begins

 The sUAS is inherently unstable, so auto-pilot fail will result in very rapid exit from flight

 Aircraft has an on-board failsafe

Given these safety features, Focal Revolution proposes that operators of the 2015 AgEagle, DJI 

Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 should not be 

required to hold a commercial or private pilot certification. Instead, operators should be required to:

 Have successfully completed, at a minimum, FAA private pilot ground instruction and passed the 

FAA Private Pilot written examination or FAA-equivalents including ICAO issued commercial, 

private license and ground school;

 Have completed AgEagle’s training program for operation of the sUAS.

Focal Revolution notes that the FAA has found that safety factors permitted operation of sUASs by 

operators with these qualifications in the case of operations pursuant to public COAs where the 

mandatory operating conditions specified above are present. See Federal Aviation Administration, 

Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 2013). 
The FAA has the statutory authority, granted at 49 U.S.C. 44701(f) to waive the pilot requirements for 

commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by allowing 

operation of the 2015 AgEagle, DJI Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, 

and DJI Inspire 1 without a private pilot’s certificate or a commercial pilot’s certificate, under the 

conditions set forth herein.

The risks associated with the operation of the 2015 AgEagle, DJI Spreading Wings series S1000+, S1000, 

DJI Phantom 2, Phantom 3, and DJI Inspire 1 (given their size, speed, operational capabilities, and lack of 

combustible fuel) are so diminished from the level of risk associated with private pilot operations or 

commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), 

that allowing operations of the sUAS as set forth above meets or exceeds the present level of safety 

provided under 14 C.F.R. 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to 

operate the aircraft under 61.133(a).

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

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. 

Should the exemption be granted allowing commercial operation of the 2015 AgEagle, DJI Spreading 

Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 without an airworthiness 

certificate, no standard will exist for airworthiness of the 2015 AgEagle, DJI Spreading Wings series 

S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1.

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

This regulation provides:

No person may operate a U.S.-registered civil aircraft...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by 21.5 of this chapter, unless there 

is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual 

material, markings, and placards, or any combination thereof.

Given the size and configuration of the 2015 AgEagle, DJI Spreading Wings series S1000+, S1000, DJI 

Phantom 2, Phantom 3, and DJI Inspire 1, it has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry 

such an item on the aircraft.

The equivalent level of safety will be achieved by keeping the flight manual at the ground control point 

where the pilot flying the sUAS will have immediate access to it.

14 C.F.R. 91.103: Preflight Action.

This regulation requires each pilot in command to take certain actions before flight to insure the safety 

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption 
will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. 91.109(a) & 91.319(a)(1): Flight Instruction.

These regulations provide that no person may operate a civil aircraft (except a manned free balloon) 

that is being used for flight instruction unless that aircraft has fully functioning dual controls.

The 2015 AgEagle, DJI Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 

1 are remotely piloted aircraft and by design, do not have fully functioning dual controls. Flight control 

is accomplished through the use of a control box that communicates with the aircraft via radio 

communications. If instruction is accomplished through a training program, an equivalent level of safety 

will be assured. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 

5778K & 9862A. The equivalent level of safety will be achieved by the manufacturer providing the 

training as outlined, and through the use of experienced and qualified pilots familiar with the 2015 

AgEagle, DJI Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1.

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits 

aircraft flying over areas other than congested areas to an altitude of 400 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer 

than 400 feet to any person, vessel, vehicle, or structure.

As set forth herein, the 2015 AgEagle, DJI Spreading Wings series S1000+, S1000, DJI Phantom 2, 

Phantom 3, and DJI Inspire 1 will never operate at higher than 400 feet AGL. It will, however, be 

operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. 

Because aerial survey, mapping and inspection work must be accomplished at relatively low altitudes 

and at altitudes less than 400 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with which the 

2015 AgEagle, DJI Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 1 is 

built. Also, no flight will be taken without the permission of the land owner or those who control the 

land. Because of the advance notice to the landowner, all affected individuals will be aware of the 

flights. Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far more 

than 50 lbs. and carrying flammable fuel, any risk associated with these operations will be far less than 

those currently allowed with conventional aircraft operating at or below 400 feet AGL. Indeed, the lowaltitude operations of the sUAS will maintain separation between these sUAS operations and the 

operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. 91.151(a): 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 after that for at least 

30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The 2015 AgEagle batteries provide approximately 40 minutes of powered flight. Without an exemption 

from 14 CFR 91.151, the sUASs flights would be limited to approximately 20 minutes in length. Given the 

limitations on its proposed operations and the location of those proposed operations, a longer time 

frame for flight in daylight VFR conditions is reasonable.

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 the sUAS operates. The fact that it 

carries no pilot, passenger, or cargo also enhances its safety. Additionally, limiting flights to 20 minutes 

would greatly reduce their utility. In the unlikely event that the sUAS should run out of fuel (battery 

power), it would simply land. Given its weight and construction material, the risks are less than 

contemplated by the current regulation.

Focal Revolution believes that an equivalent level of safety can be achieved by maintaining 10 minutes 

of reserve fuel, which, allowing 30 minutes of flight time, would be more than adequate to return the 

sUAS to its planned landing zone from anywhere in its operating area.

14 C.F.R. 91.203(a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

(a) ... no person may operate a civil aircraft unless it has ... an appropriate and current airworthiness 

certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph 

(a) of this section or a special flight authorization issued under 91.715 is displayed at the cabin 

or cockpit entrance so that it is legible to passengers and crew.

The 2015 AgEagle, DJI Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI Inspire 

1 fully loaded weigh no more than 50 lbs. As such, there is no ability or place to carry certification and 

registration documents or to display them on the sUAS. In addition, there is no pilot on board the 

aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the sUAS will have immediate access to them. The FAA has issued numerous 

exemptions to this regulation. A representative sample of other exemptions includes Exemption Nos. 

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections.

Section 91.405(a) requires that an aircraft operator or owner “shall have 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 as prescribed in 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 air worthiness 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.

The 2015 AgEagle is nearly maintenance free, DroneDeploy’s software performs automatic pre-flight 

checks and the failure of any check will prevent take-off. Checks which cannot be done by the system 

will be performed by a qualified person prior to each flight and at predefined intervals as part of the 

Maintenance Schedule in the User Manual.

Pre-flight checklist includes:

1. Visual inspection of the airframe.

2. Visual inspections of rotor integrity.

3. Check charge of all batteries (aerial vehicle, command station, radio repeater station).

An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external 

payload, will operate only in restricted predetermined areas and is not a complex mechanical device.

The operator of 2015 AgEagle will ensure that the sUAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance that is performed. Moreover, the 

operator 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 level of safety.

The 2015 AgEagle’s Maintenance guidelines ensure an equivalent level of safety to the maintenance 

requirements in Part 91. In addition, any component failure detectable by the system will be reported to 

the control station and will cause the UAV to perform a Fatal Condition Response (FCR) or Non-Fatal 

Conditioned Response (NFCR), depending on the type of failure.

Maintenance of the DJI Spreading Wings series S1000+, S1000, DJI Phantom 2, Phantom 3, and DJI 

Inspire 1 will be accomplished by Focal Revolution pursuant to the manuals provided by DJI. An 

equivalent level of safety will be achieved because the sUAS is small in size, will carry no external 

payload, will operation only in restricted predetermined areas and is not a complex mechanical device. 

Focal Revolution will ensure that the sUAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance that is performed. Moreover, the operator 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 level of safety. In addition, should a mechanical issue arise, the 

aircraft will either return to its launch site or immediately land.
APPENDIX B

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

2015 AgEagle2

The 2015 AgEagle can carry payloads up to 2.5 pounds. The 2015 AgEagle flies at a maximum wind 

threshold of 43 M.P.H. for sustained winds and wind gusts up to 55 M.P.H. What is unique about the 

2015 AgEagle is the system automatically compensates for wind versus relying on the operator’s ‘sense 

of feel’ for what the impact of the wind is at the altitude the system is flying. The end result is a system 

capable of gathering high quality aerial intelligence at much higher wind thresholds. A trait that is 

imperative for many aerial inspection operations.

The 2015 AgEagle has an operational range of up to 20 statute miles (17.38 Nautical Miles).

All flight operations are GPS controlled making the system extremely easy to navigate. At any point if the 

operator is not explicitly commanding the system to move, the system automatically holds its GPS 

position (i.e. GPS hold for reliable location hover). Camera positioning is also GPS controlled allowing for 

the most sophisticated camera targeting available. The flight control system employs not only GPS 

positioning but a variety of sensors including sonar, barometric pressure, temperature, wind speed and 

others to ensure the most stability of any system in its class - regardless of the wind.

Powered by DroneDeploy, the 2015 AgEagle can be operated in both semi and fully autonomous flight 

modes. Creating preplanned flight paths to fly in autonomous mode is as simple as clicking on the map 

to create a preplanned flight path. In semi-autonomous mode, the operator clicks on the map and the 

AgEagle 2015 AgEagle automatically flies to the point on the map where the operator is pointing. Premission waypoints, Landing zone points and flight area dimensions can all be entered during preflight 

ensuring the 2015 AgEagle operates only within specified parameters.

The 2015 AgEagle includes many advanced safety features that make it the safest choice for both urban 

and non-urban environments. Built-in intelligent fault handling allows the 2015 AgEagle to detect a 

system fault while in the air, and to automatically fly back to its take-off location and land. Faults that 

can be detected include: loss of communication; pre-set wind thresholds exceeded; and low battery 

levels. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the 

system cannot enter areas deemed unsafe or unnecessary to fly over. And before every take-off 

automated flight checks ensure the system is flight ready before it takes off.

The 2015 AgEagle can be operated entirely by a touch-screen, map based interface. This means the 

operator only needs to command the system where to go, and the system does all the flying for the 

operator. Maps can be saved and flight plans can be made or recalled.

 

2

All system specifications are from manufacturer.
2015 AgEagle Operating Manual - System user manual available upon request.

2015 AgEagle Continued...

Physical Characteristics:

Measurements – 56” wingspan x 6.5” long

Weight (without payload but with batteries) – 7 lbs.

Weight with payload (T/O weight) – 7.5 lbs.

Fuel – Batteries

Landing style/type – Belly landing

Propulsion System

 Engines – The 2015 AgEagle is powered by 1 electric brushless DC motor.

 Batteries – Lithium polymer batteries are self-contained high duration systems with SMART 

intelligence on-board. This includes cycle charge times, locations, GPS antenna, chemical 

management, and real-time data feeds to ensure maximum flight duration and sub-system 

safety processes. Charging is done in the included AgEagle Battery charger and can be charged 

via standard wall outlet, or via a vehicle.

Performance Characteristics:

 Maximum Altitude – 400’ AGL

 Maximum Endurance – 40 minutes

 Maximum Range – VLOS (Visual Line of Sight)

 Weather Minimums – NA

 Winds Maximum – 40 MPH

 Minimum Ceiling – VLOS (Visual Line of Sight)

 Minimum Visibility – VLOS (Visual Line of Sight)

 Icing Conditions – No icing conditions

 Precipitation – No visible moisture

Maintenance - The UAS is nearly maintenance free, it performs automatic pre-flight checks and the 

failure of any check will prevent take-off. Checks which cannot be done by the system will be performed 

by a qualified person prior to each flight.

Preflight Checklist:

 Visual inspection of the airframe

 Visual inspections of rotor integrity

 Check charge of all batteries (aerial vehicle, command station, radio repeater station)

Reliability - The system is designed for maximum reliability and to maintain performance over its life.
The only components experience routine wear are rotors, batteries, motors, and legs. Battery and motor 

conditions are monitored by the system with deviations reported to the operator.

2015 AgEagle Continued...

Contact with other objects during flight may cause other components, particularly rotors, and motor 

arms, to become damaged. Damaged components are likely to be detected during the full visual 

inspection of the airframe performed before each flight. Structural damage affecting flight 

characteristics will be detected by on-board sensors.

The UAV system detects numerous conditions which may make flying unsafe, such as reduced GPS 

accuracy, magnetic anomalies, low battery charge, battery cell imbalances, and temperature 

fluctuations. Automatic pre-flight checks prevent the sUAS from taking off if such conditions are present; 

or, if the condition is detected during flight, the system will trigger a Fatal Conditioned Response.

Command and Control Systems - The 2015 AgEagle Ground Control station allows the operator 

simultaneous control over aircraft and payloads. The touch screen control allows for quick navigation 

and data entry while the display screen provides all essential flight data to the operator. Telemetry data 

is transmitted to the command station at least once per second.

Displayed on GCS:

 sUAS Position

 Navigation Route

 sUAS Tail Number

 sUAS Position

 sUAS Altitude

 sUAS Heading

 North Seeking Arrow

 Range to Target

 Calculated Target Position

 Date/Time

 Sensor Heading and Orientation Relative to sUAS

On-Board Flight Instruments - The sUAS is equipped with an Inertial Navigation System (3-axis 

gyroscope, 3-axis magnetometer, GPS receiver, and static pressure sensor) and a sonar sensor for 

precision AGL altitude measurement.

On-Board Computer Systems - The sUAS is equipped with on-board computer systems to monitor 

(sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry, 

etc.).

Frequency Allocations - 900 MHz, 2.4 GHz, 5.8 GHz, 1,700 – 2,100 MHz, custom

Flight Termination Link – To prevent a “fly away” or other potentially dangerous situation a flight 

termination link is available to the operator at the GCS.
2015 AgEagle Continued...

Takeoff and Landing - The 2015 AgEagle has vertical lift autonomous launch and recovery. A Landing 

Zone “LZ” is designated by the operators and identified in the GCS software.

Navigation System - Specific maps can be downloaded to the display screen (such as air sectional and 

geographic maps) which are overlaid with GPS positional data. Waypoints can be created before and 

during flight operation creating specific locations and sequences for the aircraft.

Redundant Systems - The sUAS combines the input from a multitude of sensors. Even though the data 

from all sensors is required for optimal system performance, a single sensor malfunction is likely to 

result in degraded performance rather than leading to a catastrophic failure.

Emergency Procedures and System Failures

Failure Handling - The sUAS has extensive failure detection and handling capabilities. All failures are 

deeded to be either fatal or non-fatal. Failures classified as fatal result in a Fatal Condition Response 

(FCR); and failures classified as non-fatal result in a Non-Fatal Condition Response (NFCR).

Sensor Failure - Failure of on-board flight instruments/sensors will degrade the sUAS performance and 

will result in either a FCR or a NFCR, depending on their severity.

Airframe Failure - If airframe is damaged in ways that impacts flight characteristics, the sUAS will behave 

similar to if an on-board flight instrument failed.

Navigation System Failure – In a navigation system failure, degraded GPS will result in FCR or NFCR‘s 

depending on failures.

Power Failure – A complete battery failure which results in power loss to the sUAS will result in 

degraded flight performance.

Low Battery Condition - Operator will be alerted of a low battery condition and will land the aircraft as 

soon as able.

Line of Sight Loss - All flight operations will be conducted with the sUAS within visual sight of the pilot. If 

the pilot’s view becomes obstructed and line-of-sight is lost, the pilot may instruct the UAS to hover in 

place until line-of-sight is reestablished, to return to the take-off position, or to land at the current 

position.

Security – The system and communication links are encrypted by the manufacturers proprietary 

software.
DJI Spreading Wings S1000+3

Frame:

Diagonal wheelbase: 1045mm

Frame Arm Length: 386mm

Frame Arm Weight: 325g (including motor, ESC, propeller)

Center Frame Diameter: 337mm

Center Frame Weight: 1520g (with landing gear mounting base, servos)

Landing Gear Size: 460mm length x 511mm width x 305mm height

Motor:

Stator Size: 41x14mm

KV: rpm/v

Max Power: 500W

Weight: 158g (with cooling fan)

Electronic Speed Control:

Working Current: 40A

Working voltage: 6S LiPo

Signal Frequency: 30Hz – 450Hz

Drive PWM Frequency: 8 KHz

Weight: 35g (with radiators)

Foldable Propeller:

Material: High strength performance engineered plastics

Size: 15x5.2Inch

Weight: 13g

Flight Parameters:

Takeoff Weight: 6-11Kg

Total Weight: 4.4Kg

Power Battery: LiPo (6S, 10000mAh & 9.Kg Takeoff Weight)

Working Environment Temperature: -10C - +40C

Gain Value Settings:

For A2 Flight Controller: Basic: Roll 120%, Pitch120%, Yaw 120%

Attitude: Roll 170%, Pitch 170%, Vertical 170%

For WooKong-M Flight Controller: Basic: Roll 130%, Pitch130%, Yaw 120%

Attitude: Roll 180%, Pitch 180%, Vertical 120%

 

3

All system specifications are from manufacturer.
DJI Spreading Wings S10004

Frame:

Diagonal wheelbase: 1045mm

Frame Arm Length: 386mm

Frame Arm Weight: 325g (including motor, ESC, propeller)

Center Frame Diameter: 337.5mm

Center Frame Weight: 1330g (with landing gear mounting base, servos)

Landing Gear Size: 460mm length x 511mm width x 305mm height

Motor:

Stator Size: 41x14mm

KV: 400rpm/V

Max Power: 500W

Weight: 158g (with cooling fan)

Electronic Speed Control:

Working Current: 40A

Working voltage: 6S LiPo

Signal Frequency: 30Hz – 450Hz

Drive PWM Frequency: 8 KHz

Weight: 35g (with radiators)

Foldable Propeller:

Material: High strength performance engineered plastics

Size: 15x5.2Inch

Weight: 13g

Flight Parameters:

Takeoff Weight: 6-11Kg

Total Weight: 4.2Kg

Power Battery: LiPo (6S, 10000mAh & 9.Kg Takeoff Weight)

Max Power Consumption: 4000W

Hover Power Consumption: 1500W (@9.5Kg Takeoff Weight)

Hover Time: 15min (@15000 mAh & 9.5Kg Takeoff Weight)

Working Environment Temperature: -10C - +40C

Gain Value Settings:

For A2 Flight Controller: Basic: Roll 120%, Pitch120%, Yaw 120%

Attitude: Roll 170%, Pitch 170%, Vertical 170%

 

4

All system specifications are from manufacturer.
For WooKong-M Flight Controller: Basic: Roll 130%, Pitch130%, Yaw 120%

Attitude: Roll 180%, Pitch 180%, Vertical 120%

DJI Phantom 25

General Features –

 Ready to Fly, Multifunctional Quad-rotor System

 Customized H3-2D and H3-3D Gimbal Support

 Precision Flight and Stable Hovering

 25min Flight Time & Smart Battery

 Auto Return-to-Home & Landing

 Advanced Power Management

 Intelligent Orientation Control (IOC)

 Easy Battery Replacement

 Self-tightening Propeller

 Video Downlink Support

 CAN-Bus Expansion Module

Aircraft –

 Weight (Battery & Propellers Included)

o 1000g

 Hover Accuracy (Ready to Fly)

o Vertical: 0.8m;

o Horizontal: 2.5m

 Max Yaw Angular Velocity

o 200 degrees/second

 Max Tilt Angle

o 35 degrees

 Max Ascent/Descent Speed

o Ascent: 6m/s;

o Descent: 2m/s

 Max Flight Speed

o 15m/s (not recommended)

 Diagonal Length

o 350mm

 Flight Time

o 25 minutes

 Take-off Weight

o <1300g

 Operating Temperature

o -10C ~ 50C

 Supported Battery

o DJI Smart Battery

 Battery Type

o 3S LiPo

 Battery Capacity

 

5

All system specifications are from manufacturer.
o 5200mAh, 11.1V

DJI Smart Battery –

 Charging Environmental Range

o 0C to 40C

 Discharging Environmental Range

o -20C to 50C

2.4GHz Remote Control –

 Operating Frequency

o 2.4GHz ISM

 Communication Distance (Open Area)

o 1000m

 Receiver Sensitivity (1%PER)

o -97dBm

 Working Current/Voltage

o 120 mA@3.7V

 Built-In LiPo Battery Working Current/Capacity

o 3.7V, 2000mAh

DJI Phantom 36

Aircraft –

 Weight (Battery & Propellers Included)

o 1280g

 Diagonal Length (Including Propellers)

o 350mm

 Max Ascent/Descent Speed

o Ascent: 5m/s;

o Descent: 3m/s

 Hover Accuracy

o Vertical: +/- 0.1m (when Vision Positioning is active) or +/- 0.5 m

o Horizontal: +/- 1.5 m

 Max Flight Speed

o 16m/s (ATTI Mode, no wind)

 Max Altitude Above Sea Level

o 6000m

 Operating Temperature

o 0C to 40C

Camera –

 GPS Mode

o GPS/GLONASS

 Sensor

o Sony EXMOR 1⁄2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

 Lens

 

6

All system specifications are from manufacturer.
o FOV 94 degree 20mm (35mm format equivalent) f/2.8

 ISO Range

o 100-3200 (video) 100-1600 (photo)

 Shutter Speed

o 8s – 1/8000s

 Image Maximum Size

o 4000 x 3000

 Still Photography Modes

o Single shot

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 Phantom 3 Pro

 UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60

o Phantom 3 Advanced

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60

 Supported SD Card Types

 Micro SD

 Max Capacity: 64 GB Class 10 or UHS-1 rating required

 Max Bitrate of Video Storage

 Phantom 3 Pro

o 60 Mbps

 Phantom 3 Advanced

o 40 Mbps

 Supported File Formats

 FAT32/exFAT

 Photo: JPEG, DNG

 Video: MP4, MOV (MPEG-4 AVC/H.264)

 Gimbal

o Operating Temperature

 0C to 40C

o Controllable Range

 Pitch -90 degrees to +30 degrees

o Stabilization

 3 axis (pitch, roll, yaw)

o Max Velocity

 Less than 8 m/s (when 2m above ground)

 Vision Positioning

o Altitude Range

 30cm – 300cm

o Operating Range

 30cm – 300cm
o Operating Environment

 Surface with clear pattern and adequate lighting (Lux > 15)

 Remote Controller

o Operating Frequency

 2.400 GHz – 2.483 GHz

o Maximum Distance

 2000m (outdoors and unobstructed)

o Video Output Port

 USB

o Operating Temperature

 0C to 40C

o Battery

 6000 mAh LiPo 2S

o Mobile Device Holder

 For tablet or phone

o Receiver Sensitivity

 -101 dBm +/- 2dBm

o Transmitter Power (EIRP)

 FCC: 20 dBm

 CE: 16 dBm

o Working Voltage

 1.2 A @ 7.4 V

o Voltage

 17.4 V

 Battery Charger

o Phantom 3 Pro

 100w

o Phantom 3 Advanced

 57w

o Capacity

o 4480 mAh

o Voltage

o 15.2 V

o Battery Type

o LiPo 4S

o Energy

o 68 Wh

o Net Weight

o 365g

o Maximum Flight Time

o Approximately 23 minutes

o Operating Temperature

o -10C to 40C
DJI Inspire 17

Weight (Battery Included)

 2935 g

Hovering Accuracy (GPS Mode)

 Vertical: 0.5m

 Horizontal: 2.5m

Maximum Angular Velocity

 Pitch: 300 degrees/s

 Yaw: 150 degrees/s

Maximum Tilt Angle

 35 degrees

Maximum Ascent Speed

 5 m/s

Maximum Descent Speed

 4 m/s

Maximum Speed

 22 m/s (ATTI mode, no wind)

Maximum Flight Altitude

 4500 m

Maximum Wind Speed Resistance

 10 m/s

Maximum Flight Time

 Approximately 18 minutes

Motor Model

 DJI 3510

Propeller Model

 DJI 1345

Indoor Hovering

 Enabled by default

Operating Temperature Range

 -10C to 40C

Diagonal Distance

 559 to 581 mm

Dimensions

 438x451x301 mm

 

7

All system specifications are from manufacturer.
APPENDIX C

SUMMARY OF FOCAL REVOLUTION SECTION 333 EXEMPTION REQUEST

Focal Revolution provides pursuant to Part 11, a summary of its exemption application to allow 

commercial operation of the 2015 AgEagle, DJI Spreading Wings series S1000+, S1000, DJI Phantom 2, 

Phantom 3, and DJI Inspire 1 small unmanned system in: Precision Agriculture, survey/inspection, closed 

set cinematography, building inspection, public events, search and rescue, and commercial or residential 

real estate videography operations. An exemption is requested from the following regulations:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

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

14 C.F.R. 61.133(a)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b)(2) & (c);

14 C.F.R. 91.103;

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

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

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a).