DRONE AIR IMAGERY, LLC

- SECTION 333 EXEMPTION REQUEST Page 1 of 

### 3

November 18, 2015

U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room w12

- 140

1200 New Jersey Avenue, SE.,

Washington, DC 20590

Submitted Electronically via the Federal Docket Management System (FDMS)

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

Aviation Regulations

Dear Sir or Madam

On Behalf of., Drone Air Imagery, LLC., and Pursuant to Section 333 of the FAA Modernization and

Reform Act of 2012 and 14 C.F.R. Part 11, I Gary Parker, President and CEO, am seeking an exemption

from Part 21 Subpart H ; and Sections 91.203 (a) (1)

, 45.23 (b) , 91.7 (a), 91.9, 61.113, 61.133, 91.109,

91.119, 91.1 21, 91.151, and (91.401

- 91.417 ) Subpart E, of Title 14, Code of Federal Regulations (14

CFR). This proposed exemption would allow for the operation of our unmanned aircraft (UA ) :

3DRobotics X8+

THE UNMANNED AIRCRAFT (UA):

 The UA is lightweight (under 55l b. gross weight), battery operated multi

- r otor copter that take s

off and land vertically and has the ability to hover in one location during flight.

THE UA INCLUDE S :

 An on

- board flight computer with GPS navigation and location ability that rece ives signals for flight

control from a grou nd

- based transmitter/controller.

 An on

- board camera or sensor package used to document physical and/or environmental

conditions of structures and the natural environment.

 An on

- board telemetry system that de livers flight data from the on

- board flight computer to the

on

- board radio transmitter including altitude AGL, horizontal and vertical speed, compass

direction of flight and direction back to its launch site

.

 A 2.4 GHz on

- board radio transmitter that transm its live video from the on

- board camera plus all

the flight data from the telemetry system described above

.

THE GROUND STATION PART OF THE SYSTEM:

 A Pilot in Command (PIC) i n operati onal control of a mission from beginning to end, and who

controls the UA while in the air

.

 A 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight.

 Ground Station (computer, tablet or smart phone based app) which receives and displays video

and system telemetry real time from the UA

.

 A Visual Observer (VO), a person who provides a second pair of eyes to visually track the UA while

in flight.DRONE AIR IMAGERY, LLC

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P ILOT IN COMMAND (PIC) AND VISUAL OBSERVER (VO) :

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 P ersonnel

Qualifications. Additionally, the PIC and VO will per form maintenance on the system and will complete a

course of maintenance instruction as part of their initial training.

I submit that the combination of the UA’s light weight, flight performance and ability, fully qualified

flight crew and strict operation under the guide lines established in 8900.227, and under all of the

Restrictions listed above, the FAA can have full confidence that the operation wil l have an equivale nt or

greater level of safety than manned aircraft performing the same mission.

INTENDED USE / PUBLIC GOOD: 14 CFR § 11.81(d)

The requested exemption would allow us to use the UA for aerial image acquisition to support various

mapping and surveying applic ations as well as video doc umentation for the public good. Typical

applications would include, but are not limited to:

 Real Estate Photography

 Travel and Tourism Photography

 Aerial Mapping

 Infrastructure Inspections

 Construction Site Monitoring

The inhe rent ability of the UA to capture imagery from a low altitude inc luding oblique photos and video

from several angles is far more effective than ground

- based imagery for displaying the characteristics of

bui ldings, sites and properties, areas where consiste nt monitoring is needed. Further, UA’s can access

locations not accessible to conventional aircraft due to their own flight restrictions. The applicant serves

the local population capturing event photography to support tourism and outreach. The applicant h as also

been asked to produce maps from aerial imagery that public entities use for promotion of new

development within the community . These images and other products produced from my UA are used to

better the local economy and promote local business.

PUBLIC SAFETY :

UA’s are powered by batteries, they are smaller, lighter and more maneuverable than larger aircraft

running on combustible fuel; they operate at lower altitudes (under 400’) with no people on board

thereby reducing current risk levels and e nhancing public safety. With a small payl oa d and maximum flight

time of approximately 20 minutes. UA’s offer little or no risk to national security due to their size, payload

capacity and flight duration

.

3DRobotics models have their own built in failsafe functionality which will cause the UA to return to its

take

- off location and land b efore the battery becomes empty, or the system loses communication.DRONE AIR IMAGERY, LLC

- SECTION 333 EXEMPTION REQUEST Page 3 of 

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SUMMARY GRANT REQUEST :

This request follows many others using similar systems and process tha t have be en granted previously. I

am requesting the FAA issue a summary grant of exemption as this request would not set a precedent

.

 The reasons stated by the FAA for granting Exemption Nos. 13207, 1 3004 , 1 2557 , 1 2369

, 12366

and 1 2026 also apply to this request

.

 A grant of exemption would be in the public interest (See above)

.

THE REGULATIONS FROM WHICH THE EXEMPTION S ARE BEING REQUESTED

Beside each regulation number is the page of the attached Addendum upon which each may be found

together with a proposed equiva lent level of safety for each regulation:

- 14 CFR Part 21 Subpart H Addendum Page 1

- 14 CFR 91.203 (a) (1) Addendum Page 1

- 14 C F R 45.23 (b) Addendum Page 1

- 14 CFR 91.7 (a) Addendum Page 2

- 14 CFR 91.9 Addendum Page 2

- 14 CFR 61.113, 61.133 Addendum Page 2

- 14 C F R 91.109, 91.119, 91.12 1 Addendum Page 3

- 14 CFR 91.151 Addendum Page 3

- 14 CFR Subpart E (91.401

- 91.417) Addendum Page 4

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1) Addendum Page 4

I am p r e p a r e d to m odi f y o r a mend a n y p a rt of t his r e qu e st t o satis f y t h e n ee d for a n e quival e nt lev e l of

s a f e t y

. P le a se c onta c t us a t a n y t i me if y ou r e quire a ddi t ional info r mation or c la r ifi c a t i on. I am the primary

point of contact for this request and look fo r w a rd to w o r ki n g with y o ur o f f ic e

.

Sincerely,

Gary Parker

Phone: 512

- 508

- 4628

Email: gary@droneairimagery.com

Add e ndum C ont a in i n g Ex e mp t ion R e qu e sts a nd Equiv a lent L e v e l of S a f e t y

App e ndix A

– F l i g h t Operations/Procedures

App e ndix B

– User ’s Man ua l sDRONE AIR IMAGERY, LLC

- EXEMPTION REQUEST AND LEVEL OF SAFETY Page 1 of 

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EXE M P TION RE Q UE S TS A N D EQUI V AL E NT L EVEL OF S A F ETY

I

, Gary Parker

, r e qu e st a n e x e mp t ion f r om t he f ol l owing re g u l a t i ons a s w e ll a s a n y a ddi t ional

r e g ulations that m a y t e c hnic a l l y a pp l y t o the op e r a t i on s of the 3DRobotics X8+

14 C.F.R. Part 21, Subpart H: Airwo rthiness Certificates 14 C.F.R. 91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedura l requirements for the issuance

of airworthiness certific ates as required by FAR 91.203( a) (1).

Given the size and limited operating area associated with the UA to be utilized by the Petitioner, an

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11

and Section 333 of the FMRA. The Federal Aviation Act (49 U.S.C.44701 (f)) and Section 333 of the FMRA

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon

consideration of the size, weight, s peed, operational capability, and proximity to airports and populated

areas of the particular UA. In all cases, an analysis of these criteria demonstrates that the UA operated

without an airworthiness certificate, in the restricted environment and under th e conditions proposed will

be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed. The UA to be operated

hereunder is less than 55 lbs. fully loaded, is by definition unmanned and carries neither a pilot nor

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a

limited flight area. Unlike other civil aircraft, operations under this exem ption will be tightly controlled

and monitored by the Operator and will also remain within the requirements of, and in compliance with,

local public safety requirements. These safety enhancements, which already apply to civil aircraft provide

a greater deg ree of safety to the public and property owners than conventional operations conducted

with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same

criteria demonstrates that there is no credible threat to na tional security posed by the UA due to its size,

speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and

inability to carry a substantial external load.

14 C.F.R. 45.23 (b). Marking of the Aircraft

The regul ation requires; When marks include on ly the Roman capital letter "N" and the registration

number is displayed on limited, res tricted or light

- sport category aircraft or experimental or provisionally

certificated a ircraft, the operator must also display on that aircraft near each entrance to the cabin,

cockpit, or pilot stat ion, in letters not less than 2 inches nor more than 6 in ches high, the words "limited,"

"restricted," "light

- sport," "experimental," o r "provisional," as applicable.

Even though the UA will have no airworthiness certificate, an exemption may be needed as the UA will

have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed.

Given the size of the UA, two

- inch lettering will be impossible.

Th e FAA has issued the following e xemptions to this regulation to Exemptions No s. 10700, 8738, 10167

and 10167 A.DRONE AIR IMAGERY, LLC

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14 C.F.R. 91.7(a): Civil aircraft airworthiness.

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

As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no

FAA regulatory standard will exist for de termining airworthiness. Given the size of the aircraft and the

requirements contained herein for the use of safety check lists prior to each flight, an equivalent level of

safety will be provided.

14 C F R 91.9 Civil air c r a f t f l ig h t m a nu al, m a r k i n g, a n d p laca r d re qu ir e m e n ts.

This r e g u l a t i on p r ovides that no p e rson m a y op e ra te a n a ir c r a ft unless a c u r r e nt, app r o v e d fli g h t manu a l

i s in t he a ir c r a ft. We a ssu m e that the intent of this r e quir e ment is to ensu r e that fl i g ht manu a l

i n f o r mation i s a v a i l a ble to the a ir c r e w while op e r a t i n g the a i r c r a ft. We re qu e st an e x e mp t ion t o th i s

r e quir e ment sin c e the a i r c r a ft is not on l y too small t o ca r r y do c u m e ntation; t he do c ument a t i on would

not be a v a i l a ble to the c rew during f l i g ht ope r a t i on s

.

To obtain a n e quival e nt l e v e l of s a f e t y a nd m e e t t he in t e nt of 91.9, we pr o pose that c u r r e nt, a ppro ve d

U A F l i g ht Operations/Procedures ( App e ndix A) must be a v a i l a ble to the c rew a t the g rou n d station

a n y t i me the a ir c r a

ft is i n, or p re p a ring fo r

, f l i g ht.

T he FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299,

9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 C F R 61.113 P r iva t e p i l ot p r iv i leg e s a n d l i m ita t io n s: P i l ot in C o m m a n d a n d 61.133 C o m m e rc ial p i l ot

p r iv i l e g e s a n d l i m ita t io n s.

The r e g ulation provid e s t h a t no pe r son th a t ho l ds a p riv a te pilot ce rtif i ca te m a y ac t as pilot i n c om m a nd

of a n a i r c r a ft f or c ompens a t i on or h i r e

. S ubp a ra g r a ph (b) a l l ows a priv a te pilot to a c t a s pilot in command

of a n a ir c r a ft in c onn e c t i on with a n y busin e ss or e m p l o y ment if: (1) T h e fli g ht i s on l y inci d e ntal to t h a t

bus i n e ss or e mp l o y ment; and ( 2) The a ir c r a f t does not c a r r y p a sse n g e rs o r p r op e r t y f o r c ompens a t i on or

hi r e

.

Our pro p osed o p e r a t i ons r e quire that the P I C must e i t h e r

1. Hold a Private or Sport Pilot C e rtifi ca te is s u e d b y the F AA, a nd h a ve l o g g e d 5 hou r s of f l i g ht

e x p e ri e n c e in t his t y

p e of U A , or

2. M ee t t he re qui r e ments of 8900.227 p a ra 16 ( c ) ( 2 ) ( c ) " Op e r a t i ons without a pi l ot c e rtifi ca t e " in

which the P I C is r e qu i r e d to complete " F AA p r ivate pi l ot g round ins t ruct i on" a nd p a ss " the F AA

P riv a te P i lot w ritten e

x a m i n a t i on." S ince the r e a r e c u r r e nt l y no me a ns a va i l a ble for the pilot

of a U A to g a in t he e

x p e ri e n c e in a n e quival e nt c a t e g o r y a nd c lass in ord e r to a pp l y f o r a private

p i l ot ' s l i ce nse, we pro p ose to g e n e r a te a n e quiva l e n t l e v e l of s a f e t y b y r e quiri n g our p i l ots t o

c omp l e te, a t a min i mu m

, F AA private pi l ot ground ins t ru c t i on a nd p a ss t he F AA Private P i l ot

w r i t ten e x a m i n a t i on in add i t i on to c omp l e t i ng the p r i v a te p i lot re quir e ments. S ince t he a ir c r a ft

c a nnot c a r r y p a sse n g e rs o r p r op e r t y , we f e e l that we me e t t he in t e nt of 61.113 S ubp a ra g r a ph

( b ) e v e n tho u gh the intent of th i s ap p l i ca t i on is to c ondu c t a business.DRONE AIR IMAGERY, LLC

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14 C F R 91.109 F l i g h t I n st r u c tion; S i m u lat e d i n st r u me n t f l i g h t and c e r tain f l i g h t te sts

The r e g ulation stat e s that " No p e rson m a y op e r a te a c iv i l air c r a ft th a t i s be i ng used for f l i g ht instru c t i on

unless that a ir c r a ft h a s ful l y fun c t i oning du a l c ontrols."

The UA’s g roun d

- b a s e d c ontrol station c o nsi s ts of a small h a nd

- h e l d r a dio t r a nsm i t t e r a nd while it does

not of f e r a se c ond s e t of " c ontro l s " , both t he student a nd i nstru c tor ca n, a nd wil l , op e r a te the si n g le s e t

of c ontrols si m ul t a n e ous l y

. W i t h both student a nd instru c tor h a ving " h a nds

- o n " the c ontrols d u r ing

f l i g ht, we f

e e l t h a t t his t ec hnique m ee ts t he i ntent 91.109 a nd p r ovides a n e quiva l e nt le v e l of s a f e t y

.

14 C F R 91.119 M i n i m u m sa f e altitu d e s: G e ner al.

The re g ulation stat e s that ov e r sp a r s e l y popu l a ted a r e a s t h e a ir c r a ft ca nnot be op e r a t e d c loser than 500

fee t t o a n y p e r s on, v e ssel, v e hicl e , or st r u c tur e

. S ince the a ir c r a ft will be op e r a t i n g a t a ma x i m um of 4 00

fee t A G L

, we c a nnot comp l y w i t h th i s r e quir e m e nt.

I n o rd e r to pr o vi d e a n e q uival e nt l e v e l of s a f e t y The UA ’s will not be op e r a ted ov e r c ong e sted a r e a s o r

ov e r a n y o p e n a ir a ssemb l y o f p e rsons with out prior approval. Any property owner affected w i l l be

b r i e f e d on the e x

p ec ted r oute of flight a nd the a ssoci a ted risks to p e rsons a n d p r op e r t y on the g roun d

. The a ir c r a ft will be o p e rated a t a low a l t i t ude a l l o win g , if a pow e r unit f

a i l s, an e me r g e n c y land i ng

without undue h a z a rd to pe r sons or p r op e r t y on the su r f a c e

. Th e r e

f o re, we maintain t h a t due to the

sm a ll si z e of the UA, the h a z a rd to p e rsons, v e hicl e s and stru c tur e s is m i ni m a l comp a r e d to mann e d

a ir c ra ft, whi c h should be c ons i d e r e d in g r a nt i ng the e x e mp t ion.

14 C F R 91.121 A lt i m e ter S e t ting s

.

The r e g ulation r e quir e s t h a t air c r a ft sh a ll mainta i n c ruising a l t i t ud e s b y r e f e r e n c e to an a l t i m e ter s e t t ing

a v a i l a b l e with i n 100 NM of the a i r c raft.

The UA will a lw a y

s f l y b e low 4 00 fee t A G L a nd will n o t ne e d to m a in t a in c r uis i ng a l t i t ud e s in o r d e r to

p re v e nt c onfli c t with other a ir c r a ft. An A bove G r ound L e v e l a l t i m e ter me a s u r e ment a bove the t a k e o f f

point is t r a nsm i t t e d via ra dio f r o m t he UA’S on

- bo a rd c o m puter to t he disp la y s c r e e n h e ld b y the P I C,

p rovi d ing a c onst a n t l y up d a ted A G L r ea dout.

14 C F R 91.151 F u e l r e q u ir eme n ts f or f l i g h t in VFR c o nd itio n s.

The r e g ulation provid e s t h a t no pe r son m a y b e g in a f l i g ht i n a n a irpl a ne u n d e r d a y

- V F R c ondi t ions unless

the r e is enou g h fu e l t o f l y to t he fi r st po i nt of in t e nd e d la n ding a nd to f l y a ft e r that f or a t l ea st 30 m i nutes.

The in t e nt i on of th i

s pa r a g r a ph is to provi d e a n e n e r g y r e s e r v e a s a s a f e t y buf f e r f o r d e l a y s to l a ndi n g

. Each U A is batt e r y op e r a ted a nd the m a x i m um dur a t i on o f f l i g ht f rom a sin g l e b a t t e r y c h ar g e is 22

m i nutes with a 20% re s e rv e

. S ince the a i r c raft will n e v e r f l y mo r e than 3⁄4 NM f

r om t he point of intend e d

landi n g , a f ull b a t t e r y c h ar g e a t l a un c h will e nsure that w e me e t the re s e r v e e n e r g y r e qui r e ment of th i s

pa r a g ra ph. W

e re qu e st a n e x e mp t ion t o the w o r d "fu e l " a nd a sk for a n e quival e nt in t e rp re tation wi t h the

w o r d "en e r g y ".

14 C F R S ubp a r t E ( 9 1.401

- 91.417)

- M ai n t e n a n ce , P re v e n tive M ai nt e n a n ce , Alt e r a t io n sDRONE AIR IMAGERY, LLC

- EXEMPTION REQUEST AND LEVEL OF SAFETY Page 4 of 

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The r e g ulation provid e s t h a t t he op e r a t o r is p r i m a r i l y re spons i ble f o r maintaining the a ir c r a ft in a n

a irwo r t h y c ondi t ion, i n c lud i ng c omp l ia n c e wi t h P a rt 39 a nd 43. P a ra g r a phs 91.407 a nd 91.409 re quire

that the a i r c raft be " a ppro v e d for return to se r vice b y a p e rs o n a uthori z e d und e r 43.7" a ft e r m a in t e n a n c e

a nd insp ec t i on.

I t i s our intention t h a t t he P I C p e r fo r m m a in t e n a n c e a nd inspe c t i on of the a i r c raft a nd " be a uthori z e d to

app r ove the a i r c r a

ft f or r e turn to se r v ic e ." As p r ovided in the P r e

- F l i g ht C h ec kl i st in App e ndix A, the P I C

will e nsure that the a i r c raft is i n a n a irwo r t h y c on d i t ion prior to e v e r y fli g ht

. Mainten a n c e p e r f o r med b y

t h e P I C is l i m i t e d to r e p a iring small c r a c ks, r e pl a c ing a p r o p e l l e r, c h ec ki n g e le c tri c a l conn e c t i ons a nd

upd a t i ng soft w a re a nd f

irmw a re f o r the on

- b o a rd c ompu t e r. All o t h e r mainten a n c e will be p e r f o r med b y

t h e m a nu f ac tu r e r or their d e si g n a ted r e p a ir f a c i l i t y . The P I C will do c ument wo r k p e r f o r med in acc o rd a n c e

wi t h 91.417. We fee l t h a t d ue to t he si z e

, c onstru c t i on, a nd simp l ici t y of the a i r c r a ft, the P IC ca n e nsure

a n e quiva l e nt l e v e l of sa

fe t y

.

8900.227 P a r ag r a p h 16( c ) ( 4) P I C Me d ical. And P a r a g r a p h 16( e ) ( 1 ) Ob s er v e r Me d ical.

This po l i c y pro v ides that both t he P I C a nd VO m u st have a v a l i d F AA s e c o n d

- c lass medi ca l ce rtifi c a te

issued und e r P a rt 67 in ord e r to pe r f o r m a s a pilot or o b s e rver.

The UA’s ma

x i m um g ross w e i g ht are each less than 55 l bs., are constru c ted primarily of, plastic and

carbon fiber. T

he P I C is not on boa r d. B oth t he P I C a nd the V O a re r e quir e d to be in V LO S . Giv e n t h e

unl i k e l y e v e nt t h a t bo t h the P I C a nd VO b ec ome m e dic a l l y in c a p ac i t a ted while the a ir c r a ft is i n fli g ht, t he

UA will re turn a utono m o us l y to t he si t e of laun c h i ng a nd l a nd without c r e w in t e rv e nt i on. Th e r e f o r e

,

r e quiri n g the P I C a nd VO to me e t t he s a me m e d i ca l r e quir e m e nts a s commercial pilot carrying passengers

in a l a r g e a i r c r a

ft is a n u nn ece ss a r y burd e n.

W e pro p ose th a t t he m i ni m um m e dic a l r e quir e m e nts for the P I C a nd VO b e vis i on c o r re c ted to

20/20 and a v a l i d, st a te i

s sued d r ive r '

s l i ce n s e . The 20/20 v i

sion r e quir e me n t wi l l ensu r e that the P I C and

VO see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.DRONE AIR IMAGERY, LLC

– APPENDIX A

– FLIGHT OPERTIONS/PRO CEDURES AP P E N DIX A

– F LIG H T OPERATIONS/PROCEDURES

The UA will be operated under the following flight restrictions.

OPERATIONAL F L I G HT RE S TRI C T I ONS

The UA will be operated in the field with both a PIC and a VO in accordance with and with the following

Restrictions:

 All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed of

no more than 25 knots and no further than 3/4 NM from the PIC;

 All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate

by voice at all times during a flight operation;

 The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), 10

hours of total time as a UA rotorcraft pilot and at least 5 hours logged as a UA pilot with a similar

UA type;

 The UA will not be operated over densely populate d areas; without prior approval;

 The UA will not be operated over any open

- air assembly of peop le; without prior approval;

 The UA will not be operated within 5 NM of an ai rport or he liport; without prior approval;

 Operations will be restricted to day only and weather conditions equivalent to VFR;

 The PIC will brief the VO and property owner about the operation and risk before operation ;

 No flight will be made without a Pr e

- Flight Inspection by the PIC before each operation to

ascertain that the UA is in a condition safe for flight

.

P RE

- F L I G HT CHECKLI S T

Prior to operation preflight checklists provided by the manufacturer of the UA’s will be followed. Below

is such an example.

1. Remote Controller, Batteries , Range Extender and smartphone /tablet are fully charged.

2. Propellers are mounted correctly.

3. Damping absorbers are in good condition, not broken or worn.

4. Camera lens cap has been removed.

5. Memory/Storage card has been inserted if necessary.

6. Gimbal is functioning as normal.

7. Motors can start and are functioning as normal.

8. Smart phone/tablet can connect and communicate with UA and/or payload

.

TAKE OFF/LANDING PROCEDURES

Manufacturer recommended Takeoff and Landi ng procedures will be followed. The following is an

example of such procedures:

Place the UA on ground with the battery level indicator facing you.

1. Power on base station.

2. Power on the remote controller.

3. Power on the payload ( Camera/ Sensor Package ).DRONE AIR IMAGERY, LLC

– APPENDIX A

– FLIGHT OPERTIONS/PRO CEDURES

4. Power o n the aircraft.

5. Connect the base station to the UA

.

6. Ensure the base station is communicating/receiving data from the UA and payload.

7. Confirm GPS satellite lock.

8. Push the throttle stick up slowly to lift the aircraft off the ground.

9. Verify remote controller and UA are operating normally.

10. Proceed with mission.

11. When landing, be sure to be hovering over a level surface.

12. Pull down on the throttle stick gently to descend and land.

13. After landing the aircraft on the ground, keep the throttle stick at its lowest position until

the motors stop.

FAILSAFE FUNCTION

The UA will enter Failsafe mode when the connection from the remote controller is lost. The flight contro l

system will automatically control the aircraft to return to home and land to reduce injuries or damage.

The following situations would make the aircraft fail to receive a signal from the remote controller and

enter Failsafe mode:

1. If the drone loses GPS signal in a flight mode that requires GPS (loiter, auto, return

- to

- launch,

guided), it lands automatically, as indicated by a blinking blue

- and

- yellow status LED and a high

high

- high

- low tone. For best GPS

- signal strength, always fly outside in an open are a.

2. If the drone loses contact with the RC transmitter, it lands automatically, as indicated by a

blinking yellow status LED. If it loses RC signal during a mission, it returns to the launch point

before landing.

3. If the battery reaches 25% charge, the dron e lands automatically, as indicated by a blinking

yellow status LED and a quick repeating tone. If the battery runs low during a mission, the drone

returns to the launch point before landing.DRONE AIR IMAGERY, LLC

– APPENDIX B

– USERS MANU AL AP P E N DIX B

– USER’S MANUAL 3DRobotics X8+

The current User’s Manual for the 3DRobotics X8+ can be downloaded via the following link

.

Drone Air Imagery, LLC’s, intends to keep a copy of the User’s Manual with the UA at all times

.

3DRobotics X8+ User’s Manual

Upon request these will be provided