1 Kenneth J. Crawford
Executive Director Facilities Services Killeen Independent School District 200 North W.S. Young Drive

, Killeen , Texas 76540

- 0967 kenneth.crawford@killeenisd.org

Dear Sir or Madam:

This petition is being submitted on behalf of the Killeen Independent School District, a government entity comprised of 6,600 employees and greater than 43,000 students across a 219 square mi le area

.

P ursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems,

and 14 C.F.R . Part 11, Kenneth J. Crawford, Facilities Executive Director for Killeen Independent School Distri ct , hereby petitions the Administrator to permit me to commercially operate the DJI Phantom 2, & 3 Series and the DJI Inspire

- 1 sUAS s in the National Airspace System (NAS), and for an exemption from the six requirements of 14 C.F.R §§ 61.113(a) & (b),

91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

This exemption will allow operation of Small Unmanned Aircraft System s ( sUAS ) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as we conduct such operations with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit trained Killeen Independent School District Facilities Inspectors and Prog ram Managers to conduct

“ commercial ” sUAS flight operations over Killeen Independent School District owned property and prospective property interests in support of the following areas:

1. School District Real Estate Documentation.

2. Land Management ( specific ally all land owned by the School
District )

. 3. Land Surv eying.

4. Geographic Referencing

. 5. Rooftop imaging , inspections, and documentation.

6. Response to or Document any physical external structural damage.

7. Campus documentation for Emergency Response Planning.2 Kil leen Independent School District states that all sUAS flights will occur over private or controlled access property and will do so with the property owner's consent and knowledge and that only people who have consented or otherwise have agreed to be within the sUAS ’ radius during filming and photography applications.

I, Kenneth J. Crawford, and my team of sUAS pilots and Visual Observers,

have successfully demonstrated the ability to safely and effective ly fly the
DJI Phantom Series 2, & 3 systems with a co mbined total of more than 150

sUAS flight hours for which I request authorization to use for all commercial in the interest of the Killeen Independent School District

. We will comply with local ordinances and laws regarding the operation of sUAS , and shal l
adhere to all weather and environmental restrictions or limitations in reference to the operations of sUAS

.

All flights will comply with federal, state, and local laws or ordinances regarding privacy.

The Killeen Independent School District is seeking th e exemption as we are committed to complying with all of the rules, guidelines, limitations, and future legislation set forth by the FAA. We agree to and will operate the

sUAS in the manner and for the purpose described. Without the exemption request gra nted, we will be limited to paying exorbitant costs which exceed $1,600 for manned flight operations over an already congested airspace . As stated in the Notice of Proposed Rulemaking Evaluation for Small Unmanned Aircraft Systems ( sUAS ) “drones pose a lo w level of pubic risk and that imposing all of those requiremen ts would be unduly burdensome.” By allowing the School District to operate its own

sUAS s over District Property, the public, our local community, and our fiscal resources will directly benefit

.

In consideration of the speed, weight, size, and limited operating area
associated with the sUAS and its operation, my operations meets the conditions of FMRA Section 333 and therefore, should not require an
airworthiness certificate in accordance with 1 4 C.F.R. Part 21, Subpart H. Accordingly, I request relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an
airworthiness certif icate.

We will document and maintain all maintenance records for the DJI

Phantom 2, & 3 sUAS s. Relief from certain requirements of Section 61.113(a) and (b), entitled Sport pilot privileges and limitations: Pilot in command, is requested by the Killeen In dependent School District to the3 extent necessary to allow trained, knowledgeable, skilled, with demonstrated proficiency to serve as a Pilot in Command (PIC) as demonstrated, by meeting air knowledge and skills requirements for small

sUAS platforms and ha ving safely conducted over 1 5 0 hours of recreational flights over the past eighteen months with no mishaps . As the
School District will operate the sUAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

1. Name And Address Of The Petitioner. The name and address of the Petitioner and point of contact is:
Kenneth J. Crawford
Executive Director Facilities Services Killeen Independent School District 200 North W.S. Young Drive
Killeen , Texas 76540

- 0967
2. The Specific Sections Of 14 C.F.R. From Which Killeen Independent
School District Seeks Exemption.

a. Killeen Independent School District Seeks Exemption from the Requirements Of Section 61.11 3(a) And (b). Section 61.113, entitled Sport pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part:

i. No person who holds a sport pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an
aircraft.
ii. A sport pilot may, for compensation or hire, act as PIC of an aircraft in connection with any busines s or employment if

— 1. The flight is only incidental to that business or employment; and

2. The aircraft does not carry passengers or property for compensation or hire.4 b. Killeen Independent School District Seeks Exemption From The Requirements Of Section 91.7 (a). Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

c. Killeen Independent School District Seeks Exemption From The Requirements Of Section 91.121.Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

d. Killeen Independent School District Seeks Exemption From The Requirements Of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: 9(a) No person may operate a civil aircraft unless it is in an airworthy condition.

iii. Each pe rson operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

-- 1. Below 18,000 feet MSL, to

-- 2. The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

3. If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate
available station; or

4. In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

v. No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or
alteration unless

— 1. (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]5 e. Killeen Independent School District Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states the following:

f. Killeen Independent School District Seeks Exemption From The Requirements Of Section 91.407(a )(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following:

g. Killeen Independent School District Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather
condi tions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. Each owner or operator of an aircraft

— iv. 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[.]

vi. Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

– 1. An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

2. An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.6 h. Killeen Independent School District Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section
91.417, entitled Maintenance records, subsec tions (a) and (b), state the following:

vii. Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) R ecords of the maintenance, preventive maintenance, and alteration
and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, an d appliance of an aircraft. The
records must include:

1. A description (or reference to data acceptable to the Administrator) of the work performed; and

2. The date of completion of the work performed; and

3. The signature, and certificate number of the person

app roving the aircraft for return to service. (2) Records containing the following information:

a. The total time in service of the airframe, each engine, each propeller, and each rotor.

b. The current status of life

- limited parts of each airframe, engine, propelle r, rotor, and appliance.

c. The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (continued on next page)7 3. The Extent Of Relief Killeen Independent School District Seeks And The

Reason Killeen Independent School District Seeks The Relief.

a. Extent Of Relief Killeen Independent School District Seeks And

The Reason Kil leen Independent School District Seeks Relief From Section 61.113(a) And (b).
i. Relief from Section 61.113(a) and (b) entitled Sport pilot privileges and limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a sport pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed sUAS flight operations for compensation or hire. (continued from previous page)

d. The current inspection status of the aircra ft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

e. The current status of applicable airworthiness directives (AD) and safety directives including, for
each, the me thod of compliance, the AD or safety
directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.
f. Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.
viii. The owner or operator shall retain the following records for the periods prescribed:

1. The records specified in paragraph (a)(1) of this section
shall be retaine d until the work is repeated or superseded by other work or for 1 year after the work is performed.

2. The records specified in paragraph (a)(2) of this section
shall be retained and transferred with the aircraft at the
time the aircraft is sold.

3. A list of de fects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.8 ii. This relief is requested sin ce the limitations set forth in
Section 61.113(a) and (b) state that a sport pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment;

and (2) The aircraft does not carry passengers or property for compensation or hire.
iii. As set forth more fully below, Killeen Independent School
District submits that an equivalent level of safety will be
maintained because no PIC will be allowed to operate
the DJI Phantom 2 & 3 sUAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 2
& 3 sUAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels,
vehicles and structures.
iv. Further, Killeen Independent School District subm its that all flights of the DJI Phantom 2 & 3 sUAS s, conducted by the PIC pursuant to the grant of this Petition: (1) will be
incidental to the best interests of the Killeen Independent
School District ; and (2) will not carry passengers or property for compensation or hire.

b. Extent Of Relief Killeen Independ ent School District Seeks And

The Reason Killeen Independent School District Seeks Relief From Section 91.7(a).
i. Relief from Section 91.7(a) entitled Civil aircraft
airworthiness, is requested to the extent required to allow Killeen Independent School Dist rict to determine that t he
DJI Phantom 2 & 3 sUAS s are in airworthy condition prior to every flight by ensuring that the sUAS is in compliance with

the operating documents (i.e., the Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 &
3 Instruction Manual).
ii. Killeen Independent School District seeks the requested
relief because the DJI Phantom 2 & 3 sUAS s do not require
an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Killeen Independent School
Dist rict will ensure that the DJI Phantom 2 & 3 sUAS s are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log,

and DJI Phantom 2 & 3 Instruction Manual) prior to every flight, and further, determine that the aircraft are in9 condition for safe flight, as stated in the conditions and
limitations below.

c. Extent Of Relief Killeen Independent School District Seeks And
The Reason Killeen Independent School District Seeks Relief From
Section 91.121.
i. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Phantom 2
& 3 sUAS s, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data
link to downlink altitude informati on from the sUAS to the PIC at the ground control station (GCS).
ii. Since the FAA requires that any altitude information concerning sUAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Killeen Independent School District seeks the requested relief

because the DJI Phantom 2 & 3 sUAS ’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.
iii. Considering the limited altitude of the proposed operatio ns, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and
limitations stated below.
iv. As more fully set forth herein, an equivalent level of safety
will be maintained since the DJI Phantom 2 & 3 sUAS s are

e quipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight,

and provides the PIC with altitude information of the sUAS

on the heads

- up display of th e GCS.
d. Extent Of Relief Killeen Independent School District Seeks And
The Reason Killeen Independent School District Seeks Relief From Section 91.151(b).
i. Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested t o the extent required to allow flights of the battery powered DJI Phantom 2 & 3

sUAS s during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15 minutes to the first point of intended landin g and, assuming normal cruising speed, to fly after that for at
least 5 minutes.
ii. Killeen Independent School District seeks the requested
relief because without an exemption from Section 91.151(b), the flight time duration of t he battery powered
DJI Phanto m 2 & 3 sUAS s will severely constrain the10 practicality of any aerial video or still photo flight operations that Killeen Independent School District proposes to conduct pursuant to this Petition.
iii. Significantly, as set forth below, the technical specificat ions of the DJI Phantom 2 & 3 sUAS s, the DJI
Phantom 2 & 3 operating documents, and Killeen Independent School District’s proposed operating limitations, ensure that Killeen Independent School District will safely operate the battery powered DJI Phantom 2 & 3

sUAS s during daylight hours in visual meteorological conditions (VMC), under visual flight rules ( VFR), with enough battery power to fly for a total duration of 15 minutes to the first point of inten ded landing and, assuming normal cruising speed, to f ly after that for at least
5 minutes.

e. Extent Of Relief Killeen Independent School District Seeks And
The Reason Killeen Independent School District Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a) (1) & (a)(2), And 91.417(a) & (b).
i. Since Secti ons 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Killeen Independent School
District requests relief from these Sections because the DJI
Phantom 2 & 3 sUAS s do not require air worthiness
certificates.
ii. As set forth more fully below, the DJI Phantom 2 & 3 sUAS s meet the conditions of FMRA Section 333 for operation
without an airworthiness certificate.
iii. Accordingly, Killeen Independent School District will use
trained or manufactu re recognized technicians to perform maintenance, alterations, or preventive maintenance on

the sUAS s using the methods, techniques, and practices prescribed in the sUAS operating documents (i.e., the Monthly Maintenance Log, and DJI Phantom 2 & 3

Instruct ion Manuals).
iv. Furthermore, Killeen Independent School District will
document and maintain all maintenance records for the

DJI Phantom 2 & 3 sUAS s. 4. The Reasons Why Granting Killeen Independent School District’s Request Would Be I n The Public Interest; That Is, How It Would Benefit
The Public As A Whole.

a. Granting the present Petition will further the public interest by allowing Killeen Independent School District to safely, efficiently, and economically perform aerial video and photography of11 District

- owned Real Estate, Vacant Land, subdivisions, and Industrial property over cert ain areas of the United States, and readily available to conduct any District

- owned property or facility disaster survey.

b. Additionally, use of the DJI Phantom 2 & 3 sUAS s will decre ase congestion of the NAS, reduce pollution, and provide significant benefits to the economy.

c. Notably, the benefits of Killeen Independent School District’s proposed operation of the DJI Phantom 2 & 3 sUAS s will be realized without implicating any privacy issues.

d. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 2 & 3 sUAS s are battery powered and serve as a safe, efficient, and economical alternative to the manned
aircraft traditionally utilized to obtain aerial imagery. By red ucing
the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 2
& 3 sUAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of li fe and property in the air and on the ground.

e. The Public Will Benefit From The Safety And Efficiency Of The DJI
Phantom 2 & 3 sUAS s. Conducting aerial acquisitions with the DJI
Phantom 2 & 3 sUAS s, instead of manned aircraft, will greatly benefit the publi c by drastically reducing the substantial risk to life and property in the air and on the ground, which is usually
associated with traditional manned aircraft flight operations. Aside from the lack of flight crew members located onboard the aircraft, the D JI Phantom 2 & 3 sUAS s (weighing approximately 2 pounds 11 ounces, at their maximum gross weights with lengths
of 16 inches, and a width of 16 inches, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 4,450 pounds with a wingspan of approximately 37 feet, a length of 42 feet, and a fuel capacity
of 110 gallons, (these are the s pecif ications of a Bell Jet Ranger 206)).
f. Performing Aerial Video and Photography Operations With The

DJI Phantom 2 & 3 sUAS s Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 2 & 3 sUAS s are also an
economical alternative to u sing manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2
& 3 sUAS s will allow the School District to preserve limited fiscal resources for educational purposes rather than pay for manned flight in a congested airsp ace.12 g. No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Killeen Independent School District’s proposed operation of the DJI
Phantom 2 & 3 sUAS s will not implicate any privacy issues. Speci fically, the DJI Phantom 2 & 3 sUAS s will be operated only in compliance with operating documents (i.e., DJI Phantom 2 & 3
Instruction Manual ), which requires property owner involvement, and in accordance with the Federal Aviation Regulations, including th e minimum altitude requirements of 14 C.F.R. §

91.119.

5. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Killeen Independent
School District Seeks Exemption.

a. Reasons Why The DJI Phantom 2 & 3 sUAS s Meet The Conditions
Of The FAA Modernization and Reform Act of 2012 (FMRA)
Section 333.
i. In consideration of the size, weight, speed, and limited operating area associated with the un manned aircraft and its operation, Killeen Independent School District’s operation of the DJI Phantom 2 & 3 sUAS s meet the conditions of FMRA Section 333, and will not require an
airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Se ction 333 that p rovides authority for a

sUAS to operate without airworthiness certification and sets forth requirements for considering whether a sUAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security.13 ii. Specifically, FMRA Section 333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft sys tems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by
section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.

-- In making
the determina tion under subsection (a), the Secretary shall determine, at a minimum

— (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under
section 4 4704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary
determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.14 b. In seeking this exemption, Killeen Independent School District
submits that the DJI Phantom 2 & 3 sUAS s can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by:
i. the c haracteristics of the DJI Phantom 2 & 3 sUAS s ii. the sUAS pilot certification requirement
iii. the specific operating limitations over School District

owned property

. c. The Specifications Of The DJI Phantom 2 & 3 sUAS s Demonstrate
Its Safe Characteristics.
i. The DJI P hantom 2 & 3 sUAS s do not create a hazard to

users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

1. Web links to the Technical Specifications Of The DJI
Phantom 2 & 3 sUAS s are set forth by the DJI
Phantom 2 & 3 Specifications and Data Sheet, are provided at the end of this document

. 2. The DJI Phantom 2 & 3 sUAS s Autonomous Flight And Navigation Modes Enable The sUAS s To Remain

Within A Defined Operational Area. The DJI
Phantom 2 & 3 sUAS s may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational
modes of the DJI Phantom 2 & 3 sUAS s is provided in

the DJI Phantom 2 & 3 and the DJI Inspire User Manuals (web lin ks provided at the end of this document)

. 3. The DJI Phantom 2 & 3 sUAS s a re d esigned f or

a utomatic r eturn t o h ome p oint o r h over i n t he

e vent o f l oss o f t he c ontrol l ink o r n avigation. When the Control Link is lost, the DJI Phantom 2 & 3 sUAS s will remain s tationary, in flight, for 3 seconds or more.
If, after 3 seconds, the DJI Phantom 2 & 3 sUAS s do not reacquire control link data from the GCS, the

sUAS s will assume that the Control Link is lost and the

sUAS s will return to the home position (i.e., failsa fe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of
the Failsafe Functions of the DJI Phantom 2 & 3 sUAS and the DJI Inspire User Manuals respectively, can be found at the referenced links at the end of this

document

.15 4. The DJI Phantom 2 & 3 Safety Zones.

a. A recent firmware update provides Safety Zones whereby restrictions are self

- imposed by
the software in the sUAS . The restricted areas

are divided into Category A, and Category B. Category A is around larger airports like DFW and Love Field. Within 1.5 miles of this zone,

the sUAS will not take off. Between 1.5 miles and 5 miles, the maximum altitude is 35 feet. If flying within 320 feet this safety zone, a warning message will appear on the DJI Vision

app. C ategory B safety zone is around smaller airports. Within .6 miles of this zone, the sUAS will not take off. If flying within .6 miles this safety zone, a warning message will appear on the DJI Vision application.

b. A complete description of the “Flight

Restr iction of Restricted Areas” of the DJI
Phantom 2 & 3 GCS and flight control software is provided in the DJI Phantom 2 & 3
User Manual (web links provided at the end of this document)

. 5. F light o perations o f DJI Phantom 2 & 3 sUAS s a re l imited t o t he l ine o f s ight o f a c ertificated p ilot in

c ommand w ith a s afety o bserver.

a. Killeen Independent School District requests the exemption to the required use of certificated pilots who possess a current and
valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2
& 3 sUAS s. b. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 2 & 3 sUAS s Will Be

Conducted Pursuant To Specific Operating
Limitations.

6. In seeking this exemption, Killeen Indepe ndent
School District proposes to commercially operate DJI
Phantom 2 & 3 sUAS s for the special purpose of conducting aerial video and photography over
certain areas of United States, pursuant to the following specific operating limitations:16 a. Operations au thorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft sUAS s weighing less than 55 pounds maximum gross weight: DJI
Phantom 2 & 3 Unmanned Aircraft Systems.

b. Proposed operations of any other aircraft will require a new petition or a petition to amend
this grant.

c. sUAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

d. The sUAS s may not be flown at an indicated airspee d exceeding 20 knots.

e. The sUAS s must be operated at an altitude of
no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes repor ted to ATC must be in
feet AGL.
f. The sUAS s must be operated within visual line of sight (VLOS) of the PIC at all times.

g. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

h. All operations must utilize a safety observer (SO ). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC

must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the
duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.
i. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground

based obstacles/obstructions and is not permitted to operate the camera or other
instruments.17 j. The operating documents and the grant of exemption must be accessible during sUAS

o perations and made available to the Administrator upon request. If a discrepancy
exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations
contai ned in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or
revise its operating documents. It is the operator’s responsibility to track such r evisions and present updated and revised documents

to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or
revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s sUAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

k. Prior to each flight the PIC must inspect the

sUAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS , the aircraft is proh ibited from operating until the necessary maintenance has been performed

and the sUAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All
maintenance and alterations must be properly d ocumented in the aircraft records.18 l. Any sUAS that has undergone maintenance or
alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conduc ts the functional test flight must make an entry in
the aircraft records.

m. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

n. The operator must follow the sUAS manufacturer’s aircraft/ component, maintenance, overhaul, replacement, inspection, and life l imit requirements.

o. The operator must carry out its maintenance, inspections, and record keeping requirements, in ac cordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including

total time in service, description of work accomplished, and the signature of t he authorized person returning the sUAS to
service.

p. Each sUAS s operated under this exemption must comply with all manufacturer Safety
Bulletins.

q. The authorized person must make an entry in
the aircraft record of the corrective action taken against discrepa ncies discovered

between inspections.

r. The PIC must possess at least a sport pilot
certificate and at least a current third

- class
medical certificate or valid driver’s license issued by a state.19 s. The operator may not permit any PIC to operate unless the P IC meets the operator’s qualification criteria and demonstrates the ability to safely operate the sUAS in a manner
consistent with how the sUAS will be operated under the exemption, including evasive and

emergency maneuvers and maintaining appropriate dist ances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the

purposes of training the operator’s PICs are permitted under the terms of the exemption.

H owever, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate

th e sUAS with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

t. sUAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed
area of operations. Flights under special visual flight rules (SVFR) are not authorized.

u. The sUAS may not operate within 5 nautical miles of an airport refer ence 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

NOTAM as required by the operator’s COA. The letter of agreemen t with the airport management must be made available to the Administrator upon request.

v. The sUAS may not be operated less than 500
feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3
statute miles from the PIC.20 w. If the sUAS loses communications or loses its GPS signal, it must return to a pre

- determined location within the planned operating area
and land or be recovered in accordance with the operating documents.

x. The PIC must abort the flight in the event of unpred icted obstacles or emergencies in accordance with the operating documents.

y. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the sUAS with 25% battery power remaining.

z. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also re quire the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

aa. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

bb. Before conducting operations, the radio frequency spectrum used for operation and
control of the sUAS must comply with the

Federal Communications Commission (FCC)

or o ther appropriate government oversight agency requirements.21 cc. The documents required fewer than 14

C.F.R. 91.9 and 91.203 must be available to
the PIC at the Ground Control Station of the

sUAS any time the sUAS is operating. These

documents must be made ava ilable to the Administrator or any law enforcement official upon request.
dd. The sUAS must remain clear and yield the right of way to all manned aviation operations
and activities at all times.

ee. The sUAS may not be operated by the PIC from any moving device or vehicle.
ff. Flight operations must be conducted at least
500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles,

and structures unless:
i. Barriers or structures are present that

su fficiently protect nonparticipating persons from the sUAS and/or debris in
the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If
a situation arises where nonparticipating persons leave such protec tion and are within 500 feet of

the sUAS , flight operations must cease immediately and/or;
ii. The aircraft is operated near vessels,
vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC h as made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;
iii. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those pers ons per § 91.119(a).22 gg. All operations shall be conducted over sport or controlled

- access property with permission from the land owner/controller or
authorized representative. Permission from land owner/controller or authorized representative will be obtain ed for each flight

to be conducted.
hh. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's sUAS Integration Office (AFS

- 80) wit hin 24 hours.
ii. Accidents must be reported to the National Transportation Safety Board (NTSB) per
instructions contained on the NTSB Web site: www.ntsb.gov.
ii. Reasons Why An Exemption From The Requirements Of
Section 61.113(a) And (b) Would Not Adversely Affe ct Safety.

1. Killeen Independent School District submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no
PIC will be allowed to operate the DJI Phantom 2 &
3 sUAS s unless that PIC has demonstrated, by meeting minimum sUAS flight

- knowledge and skills requirements, that the PIC is able to safely operate

the DJI Phantom 2 & 3 sUAS s in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles

and structures.

2. Considering Killeen Independent School District’s proposed area of operations, and the operating
limitations set forth

- above; the parallel nature of sport pilot aeronautical knowledge requirements to

those o f commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 2 & 3
sUAS

, Killeen Independent School District submits that the additional manned airmanship experience
of a commercially cert ificated pilot would not correlate to the airmanship skills necessary for Killeen Independent School District’s specific proposed23 micro sUAS or small sUAS flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to sUAS , in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,
11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

3. Killeen Independe nt School District will not allow any PIC to operate the DJI Phantom 2 & 3 sUAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 2 & 3
sUAS training and currency requirements, that the PIC is able to safely o perate the DJI Phantom 2 & 3
sUAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC

must have accumulated and lo gged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total
time as a sUAS rotorcraft pilot (with a minimum of 5
hours of those hours as a sUAS pilot operating the
same make and model of sUAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

4. As in Exemption Nos. 11062, 11138, and 11153, prior

documented flight experience that was obtained in compliance with ap plicable regulations will ensure an equivalent level of safety during Killeen Independent School District’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance
with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consist ent with 14 CFR 61.51(b), 25 hours of total time as a sUAS rotorcraft pilot including at least 10 hours logged as

a sUAS pilot with a multi

- rotor sUAS . Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum o f 524 hours as a sUAS pilot operating the same make and
model of sUAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time

m ay be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25

hours of sUAS rotorcraft time.

5. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice

and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience building flights can also be conducted under the grant of exemption to accomplish the required f light time. During training, proficiency, and experience

building flights the PIC is required to operate the

sUAS with appropriate distances in a ccordance with

14 C.F.R 91.119 Exemption No. 11138 at page 15.

6. Accordingly, Killeen Independent School Distri ct will ensure safe operations by not allowing any PIC to operate the DJI Phantom 2 & 3 sUAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 & 3 sUAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
iii. Reasons Why An Exemption From The Requirements Of
Section 91.7(a) Would Not Adversely Affe ct Safety. The equivalent level of safety established by Section 91.7(a)
will be maintained because prior to every flight, Killeen Independent School District will ensure that the DJI
Phantom 2 & 3 sUAS is in an airworthy condition based upon the sUAS ’s c ompliance with its operating documents

and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from25 Section 91.7(a) specific to sUAS , in circumstances similar, in all material respects, to those presente d herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067,
11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
iv. Reasons Why an Exemption From The Requirements Of
Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.121 will

be maintained because the altitude information of the DJI
Phantom 2 & 3 sUAS s will be provided to the PIC via GPS equipment and a radio communications telemetry data link, wh ich downlinks from the sUAS to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Killeen Independent School
District’s operation of the DJI Phantom 2 & 3 sUAS s within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the sUAS s at ground level. The FAA has previously granted relief from Section 91.121 specific to sUAS , in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067,
11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

v. Reasons Why an Exemption From The Requirements Of
Section 91.151(b) Would Not Adversely Affect Safety. A grant of this exemption would ensure an equivalent level of safety estab lished by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom
2 & 3 sUAS s; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations.

1. Accordingly, Killeen Indep endent School District will

ensure that it will safely operate the battery powered DJI Phantom 2 & 3 sUAS s during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 15 minutes to the first point of intended landing a nd, assuming normal cruising speed, to fly after that for at least 5 minutes.

2. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 & 3 sUAS s; the limitations on the proposed flight operations; and26 the location of the propose d operations, will ensure

an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be

ensured as the DJI Phantom 2 & 3 sUAS s provide audible and visual warnings to the PIC at the GCS

when the sUAS s experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom Vision+

sUAS s will descend and land automatically.
Si gnificantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the sUAS

are considered.

3. Relief has been granted for manned aircr aft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to sUAS , in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811,
10808, 10673, 11042, 11062, 11063, 11064, 11065,
11066, 11067, 11080, 11109, 11110, 11136, 11138,
11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
vi. Reasons Why An Exemption From The Requirements Of
Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

1. In seeking this exemption, Killeen Independent
School District submits that the equivalent level of safety with regard to the regulatory ma intenance
and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a) (1) & (a)(2), and 91.417(a) & (b) will be met because Killeen Independent School District will use trained technicians to perform maintenance, alterations, or preventive maintenance on the sUAS s using the methods, techniques, and practices prescribed in the operating documents (i.e., the Aerial Operations Manual, Monthly Maintenance Log, and DJI
Phantom 2 & 3 Instruction Manual).27 2. Furthermore, Killeen Independen t School District will
document and maintain all maintenance records
for the DJI Phantom 2 & 3 sUAS s. Since the DJI
Phantom 2 & 3 sUAS s will be inspected as prescribed by the operating documents, Killeen Independent
School District will maintain the equiv alent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI
Phantom 2 & 3 User Manual links are provided at the
end of this document for reference.

3. Likewise, the exemption sought will not adversely
affect safe ty because Killeen Independent School
District will use trained technicians to perform maintenance, alterations or preventive
maintenance on the sUAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemp tion sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI
Phantom 2 & 3 sUAS s will be performed by trained
technicians. Maintenance will be documented and
maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the
technical charac teristics and operating limitations of

the sUAS are considered. In consideration of Killeen Independent School District’s proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 2 & 3 sUAS s, Killeen Independent School District submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to sUAS in circumstan ces similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,
11067, 11080, 11109, 11110, 11112, 11136, 11138,
11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).28 vii. The FAA May Prescribe Any Oth er Conditions For Safe Operation. In accordance with Section 333 of the FAA
Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Killeen Independent School District requests that the FAA prescribe special condition s for the intended operation of

the DJI Phantom 2 & 3 sUAS s, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by

14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the sUAS for t he limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire.

1. FMRA Section 333 sets forth the requirements for considering whether a sUAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such sUAS to operate without
airworthiness certification in accordance with any requirements that must be established for the safe operation of the sUAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI
Phantom 2 & 3 sUAS s, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to

the novel or unusual design features of the aircraft. Section 21.16, enti tled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not co ntain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the produc t. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16.29 2. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. §21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of

the DJI Phantom 2 & 3 sUAS s, which contain such safety sta ndards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

6. A Summary That Can Be Published In The Federal Register, stating: The
Rules From Which Killeen Independent School District Seeks Exemption: Killeen Independent School District seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

a. A Brief Description Of The Nature Of The Exemption Killeen Independent School District Seeks: This exemption will permit Killeen Independent School District to commercially operate an

Small Unmanned Aircraft System ( sUAS ) for the purpose of capturing video and/or photographs of the following activities:
i. School District Real Estate Documentation.
ii. Land Management (specifically all land owned by t he School District).
iii. Land Surveying.
iv. Geographic Referencing.

v. Rooftop imaging, inspections, and documentation.
vi. Response to or Document any physical external structural damage.
vii. Campus documentation for Emergency Response Planning.

b. Any Additional Information, Views, Or Arguments Available To Support Killeen Independent School District’s Request.
i. This Petition is made pursuant to the FAA Modernization
and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certa in sUAS may operate safely in the NAS. As such, Killeen Independent School District’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.
ii. FMRA Section 333 sets forth the requiremen ts for considering whether a sUAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to30 national security; and further, provides the authority for

such sUAS to operate without airworthiness certification.
iii. As discussed in d etail above, Killeen Independent School
District will operate the DJI Phantom 2 & 3 sUAS s safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

7. CONCLUSION

a. As set forth herein, and based on the proposed Department of Transportation, Federal Aviation Administration, Notice of Proposed Rulemaking Regulatory Evaluation, Small Unmanned Aircraft Systems, 14 CFR Part 107 dated February 2015, Killeen Independent School District seeks an exe mption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and
Reform Act of 2012 (FMRA), which will permit safe operation of

the DJI Phantom 2 & 3 sUAS s commercially, without an airworthiness certificate, for the limited purpose of cond ucting
aerial video and photography over certain areas of the United

States.
b. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform
Act of 2012, while also advancing the interests of the public, by allowing Killeen Independent School District to safely, efficiently, and economically operate the DJI Phantom 2 & 3 sUAS s commercially within the NAS.

8. WHEREFORE, in accordance with the Federal Aviation Regulations and
the FAA Modernizatio n and Reform Act of 2012, Section 333, Killeen Independent School District respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom 2 & 3 sUAS s commercially for the purpose of conducting aerial video and photography over
certain areas of the United States.

Dated: October 1, 2015 Respectfully submitted, Kenneth J. Crawford
Executive Director Facilities Services Killeen Independent School District 200 North W.S. Young Drive
Killeen , Texas 76540

- 0967 Mobile: ( 254) 36 6

- 0074
Email: kenneth.crawford@killeenisd.org31 References:

A. DJI Phantom 2 Specifications User Manual Link: http://download.dji

innovations.com /downloads/phantom_2/en/PHANTOM2_User_Man ual_v1.4_en.pdf

B. DJI Phantom 2 Specifications Data Sheet Link : http://www.dji.com/product/phantom

- 2

- vision/spec

C. DJI Phantom 3 Specifications Use r Manual Link: http://download.dji

innovations.com/downloads/phantom_3/en/Phantom_3_Profession al_User_Manual_v1.4_en_0915.pdf

D. D JI Phantom 3 Specifications Data Sheet Link: http://www.dji.com/product/phantom

- 3/spec

Appendices:

A. Killeen Independent School District

, small sUAS Flight Guidelines, Procedures, and Operationa l Checks

B. DJI Phantom Knowledge and Skills Test Score Results32 

# Killeen	Independent	School	District

Appendix	A

small sUAS Flight	Guidelines ,	Procedures,	and	Operational	Checks



## Pre

- Flight

1. Weather: Carefully	check	the	latest	weather	and	wind	forecasts	for	th e	area that	will	be	surveyed	prior	to	submission	of	flight	request	and	NOTAM,	upon
ATC	pre

- flight	coordination,	and	visually	immediately	prior	to	flight.	Be	aware and	mindful	of	the	effects	terrain	and	altitude	may	have	on	wind	direction, speed,	or	flight operations. Windfinder provides	a	great	resource	for	wind	speed forecasts	of	many	locations	near	which	flight	operations	may	occur.



### 2. Hazards: Prior	to	flight,	the	PIC	will	make	every effort	to	ensure	that	flight
operations	will	not	pose	any	undue	risk	to	the	personnel	directly	involved	with the	effort	and	to	members	of	the	public	who	are	not	directly	involved.	Likewise, make	every	effort	to	ensure	that	operations	will	not	pose	any	und ue	risk	to	any property	in	the	area.



### a. Controlled	Airspace flights	shall	be	performed	only	with	permission	of

- RA

- and	in	constant	communication	with	all	required	parties	and agencies	and	the	controlling	authority	of	the	airspace.	The	controlling authority	m aintains	the	right	to	abort	any sUAS / sUAS flights	regardless of	the	stage	the	operation	is	in.	Comply	with	all	federal,	state,	and	local laws,	ordinances,	covenants,	and	restrictions	as	they	relate	to

sUAS / sUAS operations.	Formally	request	permission	from local government	and	local	communities	before	flying	over	their	airspace whenever	possible	or	required.	Likewise,	request	permission	from	both local	government	and	local	communities	to	take	aerial photographs/videos.	For	high

- quality,	professional	mapping, flying	at 300	meters	is	often	necessary.	If	these	levels	exceed	the	legal	altitude limits	in	the	country	of	operation,	seek	formal	permission	whenever possible	and	notify	the	nearest	airport	operator	of	the	intended	flight plan


### b. Airspace: Ensure	that	all	o perations	take	place	at	least three ( 3 )	miles (or	the	minimum	distance	required	by	local	regulations)	from	any controlled	airspace	such	as	an	airport	or	active	airfield.	Prior	to	taking off,	be	sure	to	scan	the	skies	for	any	signs	&	sounds	of	aircraft. Wh en flying, apply	the	“see	and	avoid”	as	you continue	to	look	for	aircraft. If you	spot	or	hear	any, immediately	land	your sUAS / sUAS .		Referencing the	“Don’t	Fly	Drones	Here”	web	page	(link:33 https://www .mapbox.com/drone/no

- fly/ )	provides	initial	location	checks for	areas	that	require	a	COA	or	prohibit	commercial	drone	flight
operations.



### c. Launch	&	Landing	Sites: The	selection	of	launch	and	landing	sites	is based	first	and	foremost	on	safety	and	thus	depen dent	on	the	following:

i. Site	is	away	from	nonessential	participants,	utility	wires,	and poles;

ii. Ability	to	maintain	adequate	buffer	zones	between	aircraft	and personnel;

iii. Minimize	departures	and	landings	over	populated	areas;

iv. Take

- off	site	should	be	chosen	to take	into	account	local topography,	ensuring	a	visible	line	of	sight	towards	the sUAS at

all	times.

v. Typically	the	landing	site	is	the	same	as	the	launch	site.	However, an	alternative	landing	site	should	be	identified	if	the	primary landing	site	becomes	un usable	or	unsafe.	To	this	end launch/landing	sites	should	be	selected	based	on	the	availability of	an	alternative	landing	site;

vi. The	availability	of	a	mission	“abort	site”	is	not	required	but

recommended.

vii. An	abort	site	is	one	where	the sUAS may	be	“dumped” in	the event	of	an	emergency	situation.

viii. If	landing	site	includes	other	flight	staff	announce	out	loud	“Clear Prop”	before	starting	aircraft	power.


### d. Safety	Software: sUAS s	increasingly	have	a	number	of	failsafe	options in	case	of	failures	or	unexpected	situa tions.	These	often	include	using methods	of	stabilization	and	an	automated	Return/Home	option.	Other

features	include	fail

- recovery	software	and sUAS parachute. Make	sure

to	test	these	fail

- safe	mechanisms	before	you	start	flying.	Do	not	fly

without	thes e	failsafe	mechanisms.



### e. Mission Flight Plan: The	mission	plan	shall	contain	all	actions	and contingencies	for	the	mission	planned.	Any	limiting	factors	in	the	flight environment	may	alter	the	intended	operation	and	modify	the	mission plan	accordingly.	Conti ngency	planning	should	include	safe	routes	in	the event	of	a	system	failure,	degraded	performance,	or	lost	communication
link,	if	such	a	failsafe	exists. Mission	plans	will	also	include	a	flight	plan when	flying	large sUAS s	and/or	when	flying	complex	miss ions.	Complex missions	include	areas	that	have	several	ongoing sUAS projects;	are	in dense	urban	areas	and	or	close	to	airports.	Small sUAS s,	especially	when

flown	line

- of

- site,	do	not	require	formal	flight	plans.	Mission	plans	and flight	plans	should	be	s hared	with	other	operators	when	flying	complex

missions.


### f. Public	Awareness: Pro

- actively	raise	public	awareness	about	intended34 flight	plans/paths	so	as	to	avoid	scaring	local	communities	and passersby.	Consider	using	flyers,	local	radio	and	newspapers	for

d isseminating	this	information,	particularly	when	flying	complex missions.	Meet	with	the	local	community	to	propose	and	discuss	the flight	plan	whenever	possible.	In	addition,	explain	the	technology	and ask	for	their	authorization	before	flying.	Ideally,	gi ve	something	back	to the	community	whenever	possible	(training,	printed	maps,	etc). Team

up a	local	operator	who	has	experience	in	the	country,	speaks	the language	and	understands	the	culture.



### g. Camera	&	Settings: Ensure	that	the	camera	settings	are	appropr iate	to your	mission.	Make	sure	the	camera	batteries	are	fully	re

- charged	and that	there	is	sufficient	memory	on	the	proper	speed	SD	card	to	record the	footage	for	your	mission.	Remember	to	start	the	video	or	photos before	launching	your sUAS (you’d	be	sur prised	how	easy	that	step	is	to overlook).


### h. Insurance: Make	every	effort	to	secure	individual	insurance	and	assume all	liability	for	your	actions. sUAS NGOs	and	companies	who	collaborate with	our	network	are	also	required	to	secure	insurance.



### i. Obvious	but	fo r	the	Record: Do	not	operate sUAS s	while	under	the influence	of	alcohol	or	while	using	any	drug	that	could	adversely	affect the	ability	to	safely	control	the	model.



### 3. Aircraft	Checks: Conduct a	thorough	inspection	of	the sUAS airframe	bef ore flight :



### a. Transmi tter	firmware	up	to	date?


### b. Check	condition	of	props	(run	finger	along	leading	and	trailing	edges,	flex

both	blade s	to	check	for	hairline	cracks,	chips ,	looseness	and	any

deformation )	and	ensure	prop	nuts	are	tight.



### c. Check all	control	surfaces	for	signs	of	d amage,	loose	hinges,	and	overall condition;	Looking	over	the	wing/rotors	to	ensure	they	are	in	good structural	condition	and	properly	secured


### d. Check	motor	shafts	have	no	free	play	(missing	E	clip?	Loose	bel l	housing screw?	Bad	bearings?). Check the	motor/e ngine	and	mounting	system to	make	sure	it	is	firmly	attached	to	the airframe.



### e. Checking	the	landing legs for	damage and secure	attachment (s) as required.


### f. Check	motor s	move	freely	when	spun	by	hand.



### g. Check	all	electrical	connections

i. plugged	in	and	secured	to the	airframe

ii. Check	condition	of	battery	spade	connectors	and	data	pin s	(level, free	movement,	clean).

iii. Confirm	full	battery charge (on

- board	battery	indicator	=	full

green )

. Verify	all full	charge	of transmitter,	on

- boar d	aircraft	and35 camera	batteries.


### h. C heck	camera	mounts	are	secure	(an d	any	other	attachments)	and	SD

card	is	inserted.



### i. T ransmitter sticks	positioned full	up (GPS	on

- IOC	off)

. 

### j. Turn	on	transmitter.


### k. Turn	on sUAS

. 

### l. DJI	Vision	Application:

i. Battery	indicator	reflects	time	of	available	flight	(gre en	bar)

– return	to	point	of	origin	at	yellow	indicator	bar).

ii. Flight	timer	warning ala rm	ON	and	volume	set	to	maximum

iii. Monitor	brightness	set	to	maximum.



### m. Compass	cable	tightly	connected.



### n. Calibrate	DJI	GPS	each	change	of	point	of	origin	location (Critical	Ta sk)

– set	return	to	home.



### o. When	powered	up	and	idling	confirm	no	unusual	noise	or	vibration	from

motors.



### p. Confirm	visual	display	in	DJA	Application	indicates:

i. Battery	Level	Reading

ii. Location	of sUAS to	GCS

iii. Altitude	reads	“0”	at	ground	level.

iv. Indicated	Air	Spe ed	reads	“0”	when	stationary	on	ground.

v. Camera	elevation	and	depression	fully	functions	and communicates	with	the	camera	gimbal	control	by	moving	the

camera.



### q. Confirm	surrounding	area	is	clear	of:

i. Persons	at	ground	level

ii. Horizontal	hazards	(vegetation,	powe r	lines,	structures)

iii. Other	aircraft	(manned	or	unmanned)



### r. Take	off	and	hover

- check	all	stick	controls in	stabilization	mode	to

ensure the	control	surfaces	move	towards	the	correct	positions and mitigate	potential	“ fly	away. ”

i. Rotate	on	“X”	axis	360°

ii. Check	ya w	“Y”	axis	360°

iii. Check	“Z”	axis	(up	and	down).



### s. Conduct	flight	per	flight	plan.



## In

- Flight

1. Basics:

a. If	flying	manually,	always	keep	your	fingers	on	the	controller/transmitter.

b. Always	fly	the sUAS in	Line	Of	Sight	(LOS)	from	the	Ground	Control

Station.36 c. Climb	t o	a	safe	altitude	away	from	potential	hazards	and	to	reduce	noise pollution.	Keep	aircraft	at	a	safe	operating	distance	from	people,	electric utility	lines	and	buildings.	If	the sUAS must	be	flown	over	buildings	or people,	use	a	lightweight sUAS and	mainta in	a	safe	altitude	for	recovery and	make	every	effort	to	minimize	exposure.



### 2. Spotter: Use	a	spotter	or	visual	observer	whenever	possible	and	appropriate.



### 3. Laws:

a. The	PIC	will	maintain	a	see	and	avoid	manned	aircraft	operations	at	all times	prior	to	and	durin g	flight.

b. Do	not	fly sUAS s	within	five	miles	(or	whatever	is	defined	by	local	laws) of	any	private/commercial	airport/helipad	or	a	pre

- existing sUAS flying site	without	a	frequency

- management	agreement.

c. Do	not	interfere	with	operations	and	traffic	patterns at	any	airport, heliport	or	seaplane	base	except	where	there	is	a	written	mixed

- use agreement.

d. Respect	altitude	limits	as	stated	by	local/national	laws.



### 4. Landing:

a. Regardless	of	whether	of	a	manual	or	automated sUAS landing,	scan landing	area	for	potentia l	obstruction	hazards.

b. Announce	out	loud	“Preparing	to	Land!”

c. Carefully	land	the	aircraft	away	from	obstructions	and	people.



## Post

- Flight

1. 

### Shutting	Down:

a. Turn the power	off	to	the	aircraft	and/or	disconnect/remove	the battery(ies).

b. Turn	off	the	transmitter and	range	extender	system.

c. Turn	the	power	off	to	the	photo	equipment.

d. Visually	check	aircraft	for	signs	of	damage	and/or	excessive	wear.

e. Secure	the	aircraft.



### 2. Check	pictures: Verify	that	the sUAS camera	actually	took	the	pictures.	If	not,	or of	bad	qual ity,	consider	redoing	the	mission	with	a	spare	set	of	batteries.



### 3. Logs: Keep	a	detailed	logbook	of	all	flights.



### 4. Information	Sharing: Request	permission	from	local	communities	to	share	the resulting	imagery,	either	privately	or	publicly	for	humanitarian	purp oses.	Freely share	imagery	with	local	communities	whenever	possible.	Consider	printing	the imagery	on	banners	as	these	are	much	more	durable	than	paper.



### 5. Aircraft	Checklist:

a. Weekly	or	every	ten	(10)	flights	(whichever	occurs	sooner):

i. Visual	inspection	of	sh ell	and	other	plastic	components	for cracking/damage	(landing	skids, camera	mounting	plates,	etc.);37 ii. Check	tightness	of	motor	retaining	screws	and	shell	ret aining screws	(both	2.0mm	hex);

iii. Clean	data	spring	pins	and	battery	contact	pads	with	alcohol	and

swab or	proprietary	electrical	contact	cleaner	and	cycle	spring pins	several	times	to	check	for	spring	weak ness	and	full unimpeded	travel;

iv. Plug	in	to	Vision	Assistant	and	check	tx	&	IMU	calibration	state and	all	battery	cells	have	good	bala nce	(repeat	for	all batteries);

v. Check	batteries	for	number	of	cycles	and	discharge	per	DJI recommendations	if	required.

b. Monthly	or	every	forty	(40)	flights (whichever	occurs	sooner):

i. Remove	upper	shell	and	check	state	of	all	wiring

- plugs	fully
seated,	condition	of	all	solde r	joints,	condition	of	visible	circuit boards	and	wiring	runs,	internals	generally	c lean	and	no debris/loose	items.

ii. Remove	motors	and	check	security	of	E	clips,	condition	of	bearings and	general	visual	inspection.

iii. Remove	rubber cover	from	Vision	camera	ser vo

- mounting	point and	check	tightness	of	the	small	cross

- head	screw.

c. General Maintenance : To	ensure	that	your	aircraft	continues	to	offer optimal	performance	and	to	ensure	flight	safety,	it	is	recommended	that comprehensive	maintenance	be	performed	after every	200	flights	or	50 flight	hours.	This	manual	is	intended	to	help	users	maintain	their	aircraft and	maximize	its	continued	reliability.

i. Smart	Battery

1. Check	the	battery	for	damage	and	deformities.	If	there	are any	signs	of	damage	to	the	battery,	stop	us ing	it	and discharge	the	battery	to	10%	or	below	for	disposal.	Do	not disassemble	the	battery	for	any	reason.

2. Check	the	battery	pins	and	rub	them	clean	with	an	eraser	if any	residue	is	observed.	This	will	help	to	ensure	a	more

reliable	connection.

3. Check	th e	metal	battery	power	connectors	for	damage.	If the	connectors	appear	burnt,	try	to	clear	them.	This	can	be done	by	inserting	a	piece	of	sandpaper	(1mm	thick)	into the	connectors	to	polish	the	metal.

4. Check	the	contact	pins	in	the	battery	compartment	to

ens ure	that	the	pins	are	clear.	They	should	be	able	to establish	easy	contact	with	the	battery	connectors	and

should	not	be	bent.

5. Check	the	electrodes	on	the	battery.	If	they	appear	burnt, polish	them	with	sandpaper.	If	there	is	serious	erosion,

send	the	batt ery	in	for	repairs.

6. Check	the	plastic	components	of	the	battery	bracket	to	see38 it	is	in	good	condition	and	that	all	screws	are	secure.	This prevents	the	battery	from	becoming	loose	during	flight.

7. Check	the	power	cables	between	the	arms	and	the	center plate ,	if	the	cables	are	worn,	contact	DJI	to	arrange	repairs.

8. For	long

- term	storage,	please	refer	to	the	“Intelligent Flight	Battery	Safety	Guidelines”	and	check	the	battery once	a	month	to	prevent	the	battery	cell	from	being damaged.

9. Run	the	DJI	Pilot	App	to confirm	that	all	battery	cells	are	at similar	voltage	levels	and	stay	at	the	same	level	when	the battery	is	fully	charged.	If	all	cells	maintain	voltage	levels above	3.7V	but	any	cell	is	0.2V	higher	or	lower	than	the others,	contact	DJI	for	analysis.	You	c an	also	check	the battery	cell	warning	history.	If	any	warning	is	reported,

contact	DJI.

ii. Aircraft

1. Confirm	that	all	the	screws	are	still	adequately	tightened.

2. Check	the	aircraft	for	breaks	or	damage.	If	there	is	any reason	to	believe	that	detectable	damage might	affect flight	safety,	consult	with	DJI	Support.

3. Check	the	pads	on	the	bottom	of	landing	gears.	If	they	are loose,	replace	or	secure	them	with	502	glue.

4. Ensure	that	there	are	no	obstructions	on	or	around	the

GPS	module	or	around	the	antennas	on	the	la nding	gear. Remove	any	obstacles	(such	as	tapes,	decals	or	stickers with	conductive	material)	that	might	affect	or	block	the signal.

iii. Motors

1. Check	the	rotors	to	confirm	that	they	have	not	become

loose.

2. Detach	the	propellers	and	start	the	motors.	Listen

care fully.	If	there	is	any	abnormal	noise,	please	replace	the motors.	This	may	be	a	sign	that	the	bearings	have	been

worn	out.

3. Detach	the	propellers	and	start	the	motors.	Carefully examine	the	edge	of	the	rotor	and	confirm	that	the	shaft	is perfectly	centered on	the	motor.	Check	for	any	abnormal or	excessive	vibration.	If	any	problems	are	detected, contact	DJI	Support	to	order	replacement	motors.

4. Check	for	deformities	by	confirming	that	the	gap	between

the	motor	and	motor	base	is	even.	If	not	contact	DJI
Suppor t	to	order	replacement	motors.

5. Ensure	that	the	screws	used	to	secure	the	motor	base	are tight	and	the	plastic	components	around	the	motors	are	in39 good	condition.	If	not	please	tighten	the	screws	and contact	DJI	to	repair	any	broken	plastic	components.

iv. Prop ellers

1. Check	the	propellers.	If	there	is	any	bending,	breakage	or cracking	on	a	propeller,	do	not	use	it.

2. Attach	the	propeller	to	the	motor,	turn	on	the	aircraft,	and place	it	on	the	ground.	Stand	1	meter	away	from	the aircraft	and	observe	the	rotating	pro pellers.	If	you	can	see two	distinct	propeller	outline	layers,	when	looking	at	a spinning	propeller	from	the	side,	this	propeller	is	damaged

and	should	not	be	used.

v. IMU

1. Open	DJI	Pilot	app	to	check	the	condition	of	the	IMU	and perform	an	advanced	IMU	calibr ation.	Please	place	the
aircraft	in	a	cool	environment	and	on	a	flat,	stable	surface (if	the	landing	gear	is	damaged,	support	the	aircraft	with four	objects	of	equal	height).	Do	not	touch	the	craft	during

the	calibration.

2. Turn	on	the	aircraft	and	listen	fo r	any	abnormal	noise	or

vibration	from	the	fan	located	on	the	front	of	the	aircraft. If	any	irregularity	is	detected,	replace	the	fan.

vi. Control	and	Video	Transmission	System

1. Check	the	4	antennas	on	the	landing	gear	to	ensure	that they	are	secure.	Also	check for	any	bending	or	damage.

2. Check	the	antennas	of	the	remote	controller	for	damage.

3. Check	the	neck	strap	for	damage	or	wear,	replace	if

necessary.
vii. Gimbal	and	Camera

1. Confirm	that	the	gimbal	is	able	to	properly	stabilize	itself.	If its	stabilizing	performanc e	deteriorates,	contact	DJI	to
arrange	repairs.

2. Listen	for	any	abnormal	noise	from	the	fan	when	the gimbal	is	turned	on.	This	may	indicate	unusual	vibration and	the	fan	should	be	replaced.

3. Check	rubber	vibration	dampers	for	positioning	and	tears.

4. Check	two plastic	security	pins	for	positioning	and placement

viii. Vision	Positioning	System

ix. Check	the	lens	of	the	camera.	If	any	dirt	or	residue	is	detected, gently	clean	the	lens.

x. Check	for	and	remove	objects	that	might	block	the	sensors.

xi. Ensure	that	the	Vision	Positi oning	System	is	securely	installed	on

the	aircraft.

xii. Detach	the	propellers	and	turn	on	the	aircraft.	Hold	the	aircraft	1

-40 2	meters	above	a	surface	with	rich	patterns,	under	good	lighting conditions.	Change	the	Flight	Mode	switch	to	P	Mode	on	the

controller	a nd	check	the	DJI	Pilot	app.	If	the	app	displays	an

altitude	value	and	indicates	that	P

- OPTI	mode	is	active,	the	Vision Positioning	System	should	function	normally.41 

## Endnotes

1. This	text	is	sourced	directly	from	Gene	Robinson	(2012).	First	to	Deploy:

Unmanne d	Aircraft	for	Search	&	Rescue	and	Law	Enforcement. http://www. sUAS news.com/first

- to

- deploy



### 2. This	text	is	sourced	directly	from	Gene	Robinson	(2012).	First	to	Deploy:

Unmanned	Aircraft	for	Search	&	Resc ue	and	Law	Enforcement. http://www. sUAS news.com/first

- to

- deploy



### 3. Ackerman,	Evan,	“Every	Quadrotor	Needs	This	Amazing	Failsafe	Software,” IEEE	Spectrum,	March	4,	2014, http://spectrum.ieee.org/automaton/robotics/aerial

- robots/every

- quadrotor

needs

- this

- amazing

- failsafe

- software#.UxdDHIzx33Y.hackernews.



### 4. “ DIY	parachute	deploy	mechanism	for	Multicopt er,”	DIY
Drones,	August	11,	2013, http://diydrones.com/forum/topics/diy

- parachute

deployment

- mechanism

- for

- multicopter

. 

### 5. This	text	is	sourced	directly	from	G ene	Robinson	(2012).	First	to	Deploy:

Unmanned	Aircraft	for	Search	&	Rescue	and	Law	Enforcement. http://www. sUAS news.com/first

- to

- deploy



### 6. This	text	is	sourced	directly	from	Gene	Robinson	(2012).	First	t o	Deploy:

Unmanned	Aircraft	for	Search	&	Rescue	and	Law	Enforcement. http://www. sUAS news.com/first

- to

- deploy



### 7. Drawn	from	DroneAdventures	best	practices.



### 8. T aken	from	DroneAdventures	best	practices.



### 9. Drawn from	DroneAdventures	best	practices.



### 10. This	text	is	sourced	directly	from	Gene	Robinson	(2012).	First	to	Deploy:

Unmanned	Aircraft	for	Search	&	Rescue	and	Law	Enforcement. http://www. sUAS news.com/first

- to

- deploy



### 11. Academy	of	Model	Aeronautics,	“	Document	#540

- D	‘See	and	Avoid’ Guidance,”	August	2012, http://www.modelaircraft.org/files/540

- D.pdf.



### 12. Academy	of	Model	Aeronautics,	“Document	#922	Procedur e	for	RF Interference	Testing	between	Model	Sites,” http://www.modelaircraft.org/files/922.pdf ; Academy	of	Model	Aeronautics,

“Document	#923	From	the	2011	Official	AMA	National	Model	Aircraft	Saf ety Code,” http://www.modelaircraft.org/files/923.pdf



### 13. This	text	is	sourced	directly	from	Gene	Robinson	(2012).	First	to	Deploy:

Unmanned	Aircraft	for	Search	&	Rescue	and	Law	Enforcement. http://www. sUAS news.com/first

- to

- deploy



### 14. This	text	is	sourced	directly	from	Gene	Robinson	(2012).	First	to	Deploy:

Unmanned	Aircraft	for	Search	&	Rescue	and	Law	Enforcement. http://www. sUAS news.com/first

- to

- deploy42 

# DJI Phantom

Ground School Test

This knowledge

- based test reflects Kenneth J. Crawford successfully exceeded the 80% correct answer criteria with a final resulting grade of 99%. Prior to flight operations, a ll operators will successfully pass this test.

The link to this test is: http://p3groundschool.s3.amazonaws.com/p3quiz/html5.html