1 

## Henry H. Perritt, Jr. Attorney at Law

1131 Carol Lane Glencoe, IL 60022 hperritt@gmail.com (312) 504

- 5001

6 J uly 2015

Hon. Michael Huerta
Administrator
Federal Aviation Administration U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Summary Exemption Request under Section 333 of the FAA Reform Act and Part 11
of the Federal Aviation Regulations from certain parts of the FARs

.

Dear Administrator H uerta :

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the

“ Reform Act ” ) and 14 C.F.R. Part 11, Octofilms, LLC

, a California limited liability

company (“ Octofilms ” or the “Petitioner”)

, hereby applies for a summary exemption
from t he listed Federal Aviation Regulations (“FARs”) to allow it to opera te small Unmanned Aircraft Sy stem s (“sUAS”) for aerial data collection

, , including, but not
limited to commercials, music videos, events, and constr uction site and building videos ; training in sUAS operations; and closed

- set motion picture and television production

, under the conditions and limitations set forth in this Petition.

T he requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is ( 1) limited

, ( 2) predetermined

, and (3 ) would provide safety enhancements to the already safe operations presently using manned helicopter s and airplanes . Approval of this exemption would thereby enhance safe ty and fulfill the FAA Administrator’s2

responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant is:

Octofilms, LLC
Attn: Shane Latham
2021 Grismer Ave

. #30 Burbank, CA 91504

Correspondence should be directed to:

Henry H. Perritt, Jr. Attorney at Law
1131 Carol Lane Glencoe, IL 60022 hperritt@gmail.com (312) 504

- 5001

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. § 45.23(b)

14 CFR § 61. 3

14 C.F.R. § 91.7 (a)

14 CFR § 91.9 (b) (2)

14 C.F.R. § 91.103

14 C.F.R. § 91.109

14 C.F. R. § 91.119

14 C.F.R. § 91.121

14 CFR § 91.151 (a)

14 CFR § 91.203 (a) & (b)3

14 CFR § 91.205(b)

14 CFR § 91.215

14 CFR § 91.405 (a)

14 CFR § 407 (a) (1)

14 CFR § 409 (a) (2)

14 CFR § 417 (a) & (b)

Appendix 1 describes the FARs from which an exemption is requested and summarizes the justification for each requested exemption.

Th e Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the
Reform Act , which directs the Secretary of T ransportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required unde r Section 332 of the Reform Act. In making this determination, the Administrator m ust determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximi ty to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a).

I f the Administrator determines that such vehicles “may operate safely in the national airspace system, the Secretary shall e stablish requirements for the safe operation of such aircraft in the national airspace system.” Id. § 333(c) (emphasis added).

The Secretary has delegated his aviation authority to the Administrator of the FAA.

The Federal Aviation Act expressly grants the FAA th e authority to grant exemptions from its regulatory requirements for civil aircraft, a term defined under § 40101 of the Act, which includes sUASs

. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any4

sections 44702

- 44716 of th e Federal Aviation Act if Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 CFR §91.203 (a) (1).

Octofi lms, LLC, is a California limited liability company ( CA Secretary of State entity

no. 201514210029 ). It provides a variety of photographic, video, gimbal, and recording
systems to collect digital imagery. Octofilms use s the latest in brushless gimbal
techn ology to ensure imagery that is the most stable, and highest quality possible. Based in the Los Angeles area

, Octofilms and its proprietor, Shane Latham,
have worked with more than 600 companies , including NBC, National Geographic

, Nike, GMC, Chevy, Corvette
, BMW, Sheraton Hotels & Resorts, Coldwell Banker, Encore, DefJam Recordings, and Red Bull

.
Octofilms has been operating for 3 1/2 years and has been a leader in its industry in helping pave the way for safe operation of drones

. Octofilms is spons ored by both DJI and 3DR and has been called upon these companies to test and give feedback on their drones before they hit the market.

Shane Latham, the proprietor of Octofilms has been flying RC helicopters and d rones , including many multicopters, for o ver 14 years

. He has over 14,000 flights with no crashes or injuries

.

Octofilms and Latham have been asked to speak at several panels in the drone industry to discus s working in the TV/Film industry and safety and holds classes on how to operate drones sa fely

.

Octofilms is covered with $ 5 million in liability insurance with no claims filed

.

Octofilms customers operate in a highly competitive environment, in which use of the latest video capture, digital signal processing, and wireless technologies are cruc ial for success. They recognize that drone

- captured video imagery represents a new tool that must be added to their capabilities. Few firms in the industry are as well

- equipped as
Octofilms to meet this need

. Pending promulgation of the FAA's final rule for small unmanned aircraft system s, Octofilms needs to remain competitive by demonstrating to its customers the capabilities of sUAS when they are tied into existing production and communication5

infrastruct ure s . This must be done in a real

- world commercial setting, in which the drone imagery is intended for integration into the finished package.

Few competing firms in southern California are as well

- equipped as the Petitioner to
offer sUAS training and co mmercial aerial data collection

.

The Petitioner has been advised by counsel that t hese activities are not now permissible
unless i t obtain s special permission from the FAA. A top priority for television networks stations to find drone operators that understand television workflow and can integrate their work product into it. Octofilms is far better position ed than the usual

app licant for a section 333 exemption to meet this n e ed. Working with its customers i n a commercial context, Octofilms can help the industry refine the specific technology applications that will provide the best support for aerial photography and videography

.

Octofilms ’s competition comprises not only the m any drone operators who have
obtained section 333 exemption s, many of which will engage in aerial photography ; i t also comprises many other operators who do not have section 3 33 exceptions or other approvals. If Octofilms is shut out of this market because of i ts commitment to follow
the law while this irregular competition flourishes , the result will be bad for both economic growth and aviation safety.

Petitioner also notes and has read the congressional mandate in secti on s 332 and 333 of
the FA A Revitalization and Reform Act of 2012 that the FA A move quickly to
accommodate the economic and societal benefits that can result from widespread deployment of sUAS technology. A ccordingly, Petitioner applies for authorization

un der the Federal Aviation Act , and the FAR s rules to undertake the following activities for commercial purposes. Unless the Petition is granted, Petitioner will be at a significant competitive advantage if it , as it prefers, complies with FAA policy.



### Vehicl e s
The Petitioner will fly the following sUAS:

 Cinestar 8 with A2 flight c ontroller:

 DJI Inspire

 DJI Phantom

 DJI Phantom 36

 DJI S900 with A2 flight controller

 DJI S800 with A2 fl ight controller

 3Drobotics Solo

All of these vehicle s have built in capability to limit the height they fly above the ground, to limit the distance the fly from the operator, and to exclude them from class B, C, and D airspace. T he vehicle s also have the built

- in capability to return to the
launchin g point if the wireless control link is interrupted or if t he operator attempts to
exceed any of the height, radius, or airspace limitations programmed into it

. The FAA has granted section 333 exemptions for these vehicles . See, e.g. First Flight Photogra phy, LLC, Exemption No. 11260, Regulatory Docket No. FAA−2014−0736 (as amended 14 April 2015) ( DJI Spreading Wings S1000; DJI Inspire ).

Appendix 2 provides specifications for the vehicles.



### Flight profiles

The Petitioner will program its aircraft so that th ey will not fly abo ve 400 feet above ground level, or more than 1500 feet away from the operator

. The operator will carefully preflight the vehicle before each mission to assure that its c ompass and GPS system are properly calibrated and that the return

- to

- home feature, altitude, and radius
limitations work.

The operator will operate its vehicles on aerial data collection, aerial photography and videography

, training, and closed

- set motion picture and television production

missions only under the following circumstances:

1. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

2. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude will be reported in feet AGL.

3. The UA will be operated within visual line of sight (VLOS) of the PIC at all times. The PIC will use human vision unaided by any device other than corr ective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S.
driver’s license.7

4. All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC will be able to communicate orally at all times; electronic messaging or texting will not occur during flight operations. The PIC will be des ignated before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the duties required of the VO.

5. The requested exemption and all documents needed to operate the UAS and
conduc t its operations in accordance with the conditions and limitations of t he requested grant of exemption are hereinafter referred to as the operating documents. The operating documents will be accessible during UAS operations
and will be made available to t he Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations will take precedence and be followed. Otherwise, the oper ator will follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents, and track such revisions and present updated and revised documents to the Administrator or any law enforcement official

upon request.
6. If the operator determines that any update or revision would affect the basis upon which the FAA granted the requested exemption, the operator will petition for an amendment to its grant of exemption.

7. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight prior to conducting further operations under the requested exemption. Functional test flights will only be conducted by a PIC with a VO and will remain at least 500 feet from other people. The functional test flight will be conducted in such a manner so as not to pose an undue hazard to persons and property.

8. The operator will maintain and inspect the UAS to ensure that it is in a condition for safe operation.

9. Prior to each flight, the PIC will conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection will account for8

all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft will not be operated until the necessary maintenance has been performe d and the UAS is found to be in a condition for safe flight.

10. The operator will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft
components.
11. Each UAS operated under the r equested exemption will comply with all manufacturer safety bulletins.

12. All PICs will hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will also hold a current FAA airman medical
certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in
an aircraft in which the PIC is rate d on his or her pilot certificate.

13. The operator will not permit any PIC to operate unless the PIC demonstrates the ability to operate the UAS safely in a manner consistent with how the UAS will be operated under this exemption, including evasive and emerge ncy maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’ s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability safely to operate the UAS in a manner consistent with how the UAS will be operated under this exemption will occur under the terms of the requested exemption. Training operations will 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 will operate the UA w ith appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

14. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC). Flights under sp ecial visual flight rules (SVFR) are not authorized.

15. The UA will not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for9

airports not denoted with an ARP, the center of t he airport symbol as denoted on
the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport m anagement will be made available to the Administrator or any law enforcement official upon
request.
16. The UA will 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.

17. If the UAS loses communications or loses its GPS signal, the operator will cause
the UA to return to a pre determined location within the private or controlled

access property.
18. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

19. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve

pow er recommended by the manufacturer if greater.

20. All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder will apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the COA attached to the requested exemption

. 21. All aircraft operated in accordance with this exemption will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR pa rt 45, Subpart C. Markings will be as large as practicable.

22. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be
available to the PIC at the Ground Control Stat ion of the UAS any time the aircraft is operating.

23. These documents will be made available to the Administrator or any law
enforcement official upon request.

24. The UA will remain clear and give way to all manned aviation operations and
activities at all times

.10

25. The UAS will not be operated by the PIC from any moving device or vehicle.

26. All Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that suff iciently protect nonparticipating persons from the UA and/or debris in the event of an accident. The
operator will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations will cease immediately in a manner ensuring the safety of nonparticipating persons’
and
b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those o bjects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

27. The PIC, VO, operator trainees

, or essential persons are not considered nonparticipating persons under th e requested exemption.

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

- 80) within 24 hours

. Accidents will be reported to the National Transportation Safety Board (NTSB) according to instructions contained on the NTSB Web site: www.ntsb.gov

. 29. Further to protect the interests of the operators of other aircraft and of persons and property on the ground, Petitioner will maintain liability insurance coverage for all of its sUAS operations.

For closed

- set motion picture and television production, th e Petitioner will adhere to
the following limitations :

30. The operator will have a motion picture and television operations manual (MPTOM).

31. At least 3 days before aerial filming, the operator of the UAS affected by this exemption will submit a written Plan of Activities to the local Flight Standards 7 District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

- day not ification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:11

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of ex emption;

c. Name and phone number of the person responsible for the on

- scene operation of the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or repre sentative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

32. Flight operations may be co nducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in the grant of exemption, the UAS, the UAS PIC, and the
U AS operations will comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the
Reform Act relating to size, weight, speed, oper ating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security. The Petition justifies grant of the requested exemptions allow the Petitioner to obtain aerial photography with its sUAS

.

Grantin g the petition would be in the public interest because:12

1. The Congress of the United States has determined that early accommodation of sUAS into the National Airspace System advances the public interest. The Committee Report leading the House to adopted H.R. 658 said:

"The successful integration of unmanned aircraft systems (UAS) into the National Airspace System (NAS) can support more than 23,000 high

- paying jobs in the United States. . . . The absence of a plan to integrate UASs into the NAS is a
barrier t o such job creation . . . ." 1

Granting the Petition represents a step toward such integration, in the absence of a comprehensive regulatory regime for sUAS, and thus would serve the Congressional goal and the public interest.

2. Granting the Petition would f acilitate the c reation, display, and public distribution
of art

, long recognized as advancing the public interest. They are at the core of the
activities that the First Amendment to the United States Constitution seeks to promote and to protect from gover nmental restrictions.

Creative photography and video art fall well within the First Amendment’s protections. "Entertainment, as well as political and ideological speech, is protected; motion pictures, programs broadcast by radio and television, and live

en tertainment, such as musical and dramatic works fall within the First Amendment guarantee. " 2

1 H. R. Rep. 112

- 29 on H.R. 658, 112th Cong., 1st Sess. at 116. The House

- Senate Conference Committee on the FAA Modernization and Reform Act of 2012 recommended amendments to H.R. 658 in lieu of amendments adopted by the Senate. Conference Report to Accompa ny H.R. 658, H.R. Rep. 112

- 381, 112th Cong., 2d Sess., at p. 1 (Feb. 1, 2012).

2 Schad v. Borough of Mount Ephraim, 452 U.S. 61, 65 (1981); White v. City of Sparks, 500 F.3d 953, 956 (9th Cir. 2007) (holding that self

- expression through painting is protec ted by the First Amendment; rejecting city's argument that protection requires a political message); Hoffman v. Capital Cities/ABC, Inc., 255 F.3d 1180 (9th Cir. 2001) (reversing judgment for plaintiff; use of photograph of actor as part of fashion article was protected by First Amendment despite commercial purpose); Edme v. Internet Brands, Inc., 968 F. Supp.2d 519, 529

- 530 (E.D. N.Y. 2013) (denying summary judgment on statutory right of publicity claim; "newsworthy" broadly construed to allow public to13

3. Granting the petition would enable Petitioner to demonstrate the commercial viability of creating art with new aeronautical technology Commercial creative art is protected as well as non

- commercial art. 3 The Patents and Copyrights Clause of the United States Constitution and the copyright statute’s protection of visual art and
audiovisual works embod y the proposition that more creative effort with respect to
these kinds of work will be exerted when the creators are allowed to be paid for their works, thus increasing the production of artistic works.

4. Granting the petition will allow the petitioner to respond to economic incentives to

increase its creative production . The result will be an increase in the stock of artistic photography, including video for public enjoyment.

5. The rules from which Petitioner seeks exemption artificially and irrationally limit the effective use of new technologies to enhance art and enter tainment , thereby subverting the public interest.

6. Granting the Petition will fulfill the FAA’s own declaration that encouraging new aviation technologies advances the public interest. The FAA itself has recognized the public interest in its role of "Encouraging and developing civil aeronautics, including new aviation technology." 4 Granting the Petition will enhance FAA fulfillment of that commitment, thereby serving the public interest. Air commerce flourishes in the United States because of the rapid pace of innovation in aeronautical and associated technologies, followed by their commercialization and their introduction of the marketplace. The drone technology that the Petitioner uses exemplifies the latest innovative leap forward in aeronautical technolog y

. Preventing it from using this in air commerce subverts achievement of th e goal.

7. Granting the Petition will fulfill the Congressional determination that integrating sUAS technology into the NAS serves the public interest. Section 330 of the FAA Modernization and Reform Act of 2012, specifically recognizes the advantages to air commerce obtainable from the deployment of sUAS technologies. It mandated

be nefit from visual images); Hill v. Public Advocate of the United States, 35 F.Supp.3d
1347 (D. Colo. 2014) (holding that photograph of gay marriage was within First Amendment protection desp ite its use for political purposes; discussing how access to photograph advances the public interest).

3 White, 500 F.3d at 956

- 957.

4 FAA, Safety: The Foundation of Everything We Do, http://www .faa.gov/about/safety_efficiency/

.14

several steps by the FAA to accelerate the availability of these technologies in the National Airspace System, thereby representing a congressional determination that the public inte rest is served by making these technologies more widely available at the earliest practicable date. The Petition represents a way for the FAA to move incrementally, while still satisfying its congressional mandate and meeting its obligation to enhance the public interest by making new technologies available by allowing the use of sUAS technologies in a manner that protects the public and the rest of the aviation community from significant risk.

8. The commercial activities by Petitioner proposed in the Petitio n represent contributions to new forms of air commerce, thereby fulfilling the FAA’s statutory
mandate under the 2012 Act.

9. Granting the Petition will enhance aviation safety, thereby advancing the public
interest. The Petitioner has committed itself in the Petition to safety practices that reduce or eliminate hazards to aircraft in the National Airspace System and to persons and property on the ground. Many others are flying sUAS without regard to these hazards. Granting the Petition will offer the Petition er up as an example of how the FAA is willing to accommodate the new technology when it is constrained by appropriate limitations to enhance safety. It will also allow the Petitioner to be a role model for safe commercial sUAS operations.

Users of the Nati onal Airspace System are confronted by mushrooming threats
from sUAS flown in defiance of the FAA’s ban. Unless the FAA shows some flexibility to accommodate lawful and safe operation of sUAS for legitimate commercial purposes, the level of defiance will i ncrease, intensifying the hazards to manned aircraft and to persons and property on the ground.

The Petition to use a UAS for aerial data collection and its proposed limitations are similar in all material respects to those approved by the FAA in Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642)

, 11310 to
Col in Hinkle ( see Docket No. FAA

- 2014

- 0608) , and 11657 to Fresh Cut Above (see
Docket No. FAA

– 2015

– 0547) . In those grants the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the
Petitioner and c arrying no passengers or crew, rather than a manned aircraft of15

significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, 11213

, 11310 , and 11657 also apply to the situation presented by this Petition.

Respectfully submitted,

Henry H. Perritt, Jr.
Counsel for Octofilms, LLC16 

## Appendix 1

FAR section Subject Justification 14 CFR § 45.23(b) Requirement to display registration number on vehicle Insufficient space on vehicle

14 CFR Part 21 Aircraft certification requirements and procedures Designed for manned aircraft; not suitable for off

- the

- shelf sUAS 14 CFR § 61. 3 Requirement for pilot certificate Part 61 requirements designed for manned aircraft, not sUAS; petition describes training for sUAS operator 14 CFR § 91.7 (a) Airworthines s requirement Designed for manned aircraft; not suitable for off

- the

- shelf sUAS 14 CFR § 91.9 (b) (2) Requirement for manual to be available in the cockpit No one aboard to read manual

14 CFR § 91.103(b) Requirement for crew members to be onboard Unmanned vehicle

14 CFR § 91.109 Requirement for dual controls during flight
instruction No one aboard to operate controls

14 CFR § 91.119 Minimum altitudes for safe flight Safety requires operation below these altitudes 14 CFR § 91.121 Altimeter settings No one aboard to read altimeter 14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 14 CFR § 91.203 (a) & (b) Requirement for registration and airworthiness certificates to be onboard No one aboard to read certificates

14 CFR § 9 1.205(b) Cockpit instrument s No one aboard to read17 requirement instruments 14 CFR § 91.215 Transponder requirement Vehicle has insufficient useful load; will be operated below ATC radar coverage 14 CFR § 91.405 (a) Inspection requirements Designed for manned aircraft; not suitable for off

- the

- shelf sUAS 14 CFR § 91.407(a) (1) Inspection approval requirements Designed for manned aircraft; not suitable for off

- the

- shelf sUAS 14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned aircraft; not suitable for off

- the

- shelf sUAS 14 CFR § 91.417 (a) & (b) Maintenance records requirements Designed for manned aircraft; not suitable for off

- the

- shelf sUAS1819 

## Appendix 2
Vehicle specifications

DJI Phantom

Basic Parameters Operating Temperature

- 10°C ~ 50°C

Power Consumption 3.12W

Take

- Off Weight <1200g

Hovering Accuracy (GPS Mode) Vertical: 0.8m Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle
45°

Max Ascent / Descent Speed 6m/s

Max Flight Velocity 10m/s

Diagonal Distance (Motor Center To Motor Center)
350mm

Phantom Prop Guard Weight(Single):18.7g Size(Single): Angle(155.0°) Radius(112.32mm) Whole Size with Four Prop Guards: 575.5mm

ESC Sound Introduction Ready ♪1234567

Throttle Stick Is Not At Bottom
BBBBBB...

Input Signal Abnormal20 B

—— – B

——

– B...

Input Voltage Abnormal
BB

— BB

— BB

— BB...

Charger & Battery Parameters Charger AC Input
100

- 240V

Charge Current 1A/2A/3A

Current Drain For Balancing 200mA

Power 20W

Battery Type LiPo

TX Parameters Working Frequency 2.4GHz ISM

Control Channels 7 Channels

Communication Distance
1000m

Receiver Sensitivity ( 1%PER )
>

- 100dBm

Power Consumption Of TX < 20dBm

Working Current /Voltage 52 mA@6V

AA Battery 4 Required21



## DJI Phantom 3

Aircraft Weight (Including Battery And Propellers) 1280 g

Diagonal Size (Including Propellers)
590 mm

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s

Hover Accuracy

 Vertical: +/

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

- 0.5 m

 Horizontal: +/

- 1.5 m Max Speed 16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level
6000 m

Operating Temperature 0°C to 40°C

GPS Mode GPS/GLONASS

Camera Sensor Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

ISO Range
100

- 3200 (video) 100

- 1600 (photo)

Shutter Speed
8s

- 1/8000s

Image Max Size
4000 x 3000

Still Photography Modes

 Single Shot

 Burst Shooting: 3/5/7 shots22  Auto Exposure Bracketing (AEB): 3/5

 Bracketed Frames at 0.7EV Bias

 Time

- lapse Video Recording Modes

Phantom 3 Professional

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

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60

Phantom 3 Advanced

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60 Supported SD Card Types Micro SD Max capacity: 64 GB. Class 10 or UHS

- 1 rating required

Max Bitrate Of Video Storage

Phantom 3 Professional 60 Mbps

Phantom 3 Advanced 40 Mbps

Supported File Formats

 FAT32/exFAT

 Photo: JPEG, DNG

 Video: MP4, MOV (MPEG

- 4 AVC/H.264) Operating Temperature 0°C to 40°C23

Gimbal Controllable Range
Pitch

- 90° to +30°

Stabilization
3

- axis (pitch, roll, yaw)

Vision Positioning Max Velocity Less than 8 m/s (when 2 m above ground)

Altitude Range
30 cm

- 300 cm

Operating Range
30 cm

- 300 cm

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

Remote Controller Operating Frequency 2.400 GHz

- 2.483 GHz

Max Distance 2000m (outdoors and unobstructed)

Video Output Port USB

Operating Temperature 0°C

- 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder
For tablet or phone

Receiver Sensitivity (1%PER)

- 101 dBm ±2 dBm

Transmitter Power (EIRP)

 FCC: 20 dBm

 CE: 16 dBm Working Voltage 1.2 A @7.4 V

Battery Charger Voltage24 17.4 V

Rated Power

Phantom 3 Professional

 100 W

Phantom 3 Advanced

 57 W25

Intelligent Flight Battery Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Max Flight Time Approximately 23 minutes

Operating Temperature

- 10°C to 40°C

Max Charging Power 100 W

App / Live View Mobile App DJI Pilot

EIRP 100mW

Live View Working Frequency 2.4GHz ISM

Live View Quality 720P @ 30fps (depending on conditions and mobile device)

Latency 220ms (depending on conditions and mobile device)

Required Operating Systems

 iOS 8.0 or later

 Android 4.1.2 or later Recommended Devices

 iOS : iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi

- Fi + Cellular, iPad mini 2, iPad mini 2 Wi

- Fi + Cellular, iPad Air 2, iPad Air 2 Wi

- Fi + Cellular, iPad

mini 3, and iPad mini 3 Wi

- Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus

 Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini

 *Support for additional Android devices available as testing and development continues26



## DJI Inspire 1

Aircraft Model T600 Weight (Battery Included) 2935 g Hovering Accuracy (GPS Mode) Vertical: 0.5 m Horizontal: 2.5 m Max Angular Velocity Pitch: 300°/s Yaw: 150°/s Max Tilt Angle 35° Max Ascent Speed 5 m/s Max Descent Speed 4 m/s Max Speed 22 m/s (ATTI mode, no wind) Max Flight Altitude 4500 m Max Wind Speed Resistance 10 m/s Max Flight Time Approximately 18 minutes
Motor Model DJI 3510 Propeller Model DJI 1345 Indoor Hovering Enabled by default Operating Temperature Range

- 10° to 40° C Diagonal Distance 559 to 581 mm
Dimensions 438x451x301 mm

Gimbal Model ZENMUSE X3 Output Power (With Camera) Static: 9 W In Motion: 11 W Operating Current Station: 750 mA Motion: 900 mA27 Angular Vibration Range ±0.03° Mounting Detachable Controllable Range Pitch:

- 90° to +30° Pan: ±320° Mechanical Range Pitch:

- 125° to +45° Pan: ±330° Max Controllable Speed Pitch: 120°/s Pan: 180°/s

Camera Name X3
Model FC350
Total Pixels 12.76M
Effective Pixels 12.4M Image Max Size 4000x3000 ISO Range 100

- 3200 (video) 100

- 1600 (photo) Electronic Shutter Speed 8s

- 1/8000s
FOV (Field Of View) 94°
CMOS Sony EXMOR 1/2.3”
Lens 20mm (35mm format equivalent)f/2.8 focus at ∞ 9 Elements in 9 groups Anti

- distortion Still Photography Modes Single shoot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0 .7EV Bias Time

- lapse Video Recording Modes UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 Max Bitrate Of Video Storage 60 Mbps Supported File Formats FAT32/exFAT Photo: JPEG, DNG28 Video: MP4/MOV (MPEG

- 4 AVC/H.264) Supported SD Card Types Micro SD Max capacity: 64 GB. Class 10 or UHS

- 1 rating required. Operating Temperature Range 0° to 40° C

Remote Controller Name C1 Operating Frequency 922.7~927.7 MHz (Japan Only) 5.725~5.825 GHz 2.400~2.483 GHz Transmitting Distance (Outdoor And Unobstructed) 2 km
EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G Video Output Port USB, mini

- HDMI Power Supply Built

- in battery Charging DJI charger Dual User Capability Host

- and

- Slave connection
Mobile Device Holder Tablet or Phone
Max Mobile Device Width 170mm Output Power 9 W Operating Temperature Range

- 10° to 40° C Storage Temperature Range Less than 3 months:

- 20° to 45° C More than 3 months: 22° to 28° C Charging Temperature Range 0

- 40° C Battery 6000 mAh LiPo 2S

Charger Model A14

- 100P1A Voltage 26.3 V
Rated Power 100 W

Battery (Standard) Name Intelligent Flight Battery
Model29 TB47 Capacity 4500 mAh Voltage 22.2 V Battery Type LiPo 6S High voltage battery Energy 99.9 Wh Net Weight 570 g Operating Temperature Range

- 10° to 40° C Storage Temperature Range Less than 3 months:

- 20° to 45° C More than 3 months: 22° C to 28° C Charging Temperature Range 0° to 40° C Max Charging Power 180 W

Battery (Optional) Name Intelligent Flight Battery
Model TB48 Capacity 5700 mAh Voltage 22.8 V Battery Type LiPo 6S Energy 129.96 Wh Net Weight 670 g Operating Temperature Range

- 10° to 40° C Storage Temperature Range Less than 3 months:

- 20 to 45° C More than 3 months: 22° to 28° C Charging Temperature Range 0° to 40° C Max Charging Power 180 W

Vision Positioning Velocity Range Below 8 m/s (2 m above ground) Altitude Range 5

- 500 cm Operating Environment Brightly lit (lux > 15) patterned surfaces30 Operating Range 0

- 250 cm

DJI Pilot App Mobile Device System Requirements iOS 8.0 or later Android 4.1.2 or later Supported Mobile Devices * Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi

- Fi + Cellular, iPad mini 2, iPad mini 2 Wi

- Fi + Cellular, iPad Air 2, iPad Air 2 Wi

- Fi + Cellular, iPad mini 3, and iPad mini 3 Wi

- Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus. * Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini *Support for additional Android devices available as testing and de velopment continues



## DJI Spreading Wings S80031

Frame Diagonal Wheelbase
800mm

Frame Arm Length
350mm

Frame Arm Weight (Including Motor, ESC, Propeller ) 356g

Center Frame Diameter
240mm

Center Frame Weight 550g

Landing Gear Size 460mm(Length)×425mm(Width)×320mm(Height) (Top width: 155mm)

Retractable Landing Gear Weight(Including Battery Tray) 1050g

Flight Parameters Takeoff Weight 6.0Kg ~ 8.0Kg

Total Weight 3.7Kg

Power Battery LiPo (6S

、 10000mAh~15000mAh

、 15C(Min))

Max Power Consumption 3000W

Hover Power Consumption 800W(@ Takeoff Weight 6.7Kg)

Hover Time Max: 20 min (@15000mAh&6.7Kg Takeoff Weight)

Motor Stator Size
41×14mm

KV 400rpm/V32 Max Power 500W

Weight(With Cooling Fan) 158g

ESC Current 40A OPTO

Voltage 6S LiPo

Signal Frequency 30Hz ~ 450Hz

Drive PWM Frequency 8KHz

Weight(With Radiators) 35g

Foldable Propeller(1552) Material Engineering plastic

Size 15×5.2 inch

Weight 13g



## DJI Spreading Wings S90033

Frame Diagonal Wheelbase
900mm

Frame Arm Length
358mm

Frame Arm Weight (Including Motor, ESC, Propeller ) 316g

Center Frame Diameter
272mm

Center Frame Weight (With Landing Gear Mounting Base, Servos) 1185g

Landing Gear Size 460mm(Length)×450mm(Width)×360mm(Height)

Motor Stator Size
41×14mm

KV 400rpm/V

Max Power 500W

Weight( With Cooling Fan) 158g

ESC Working Current 40A

Working Voltage 6S LiPo

Signal Frequency 30Hz ~ 450Hz

Drive PWM Frequency 8KHz

Weight(With Radiators) 35g

Foldable Propeller (1552/1552R) Material34 High strength performance engineered plastics

Size 15×5.2inch

Weight 13g

Flight Parameters Takeoff Weight 4.7Kg ~ 8.2Kg

Total Weight 3.3Kg

Power Battery LiPo (6S

、 10000mAh~15000mAh

、 15C(Min))

Max Power Consumption 3000W

Hover Power Consumption 1000W (@6.8Kg Takeoff Weight)

Hover Time 18min (@12000mAh& 6.8Kg Takeoff Weight)

Working Environment Temperature

- 10 °C ~ +40 °C

Gain Value Settings For A2 Flight Controller Basic: Roll 110%, Pitch 110%, Yaw 120% Attitude: Roll 220%, Pitch 220%, Vertical 120%

For WooKong

- M Flight Controller Basic: Roll 160%, Pitch 160%, Yaw 160% Attitude: Roll 190%, Pitch 190%, Vertical 100%



## DJI Spreading Wings S1000

Frame Diagonal Wheelbase 1045mm Frame Arm Length 386mm35 Frame Arm Weight (Including Motor, ESC, Propeller ) 325g
Center Frame Diameter 337.5mm Center Frame Weight (With Landing Gear Mounting Base, Servos) 1330g Landing Gear Size 460mm (Length) ×511mm (Width) ×305mm (Height), (Top width: 155 mm)

Motor Stator Size 41×14mm
KV 400rpm/V
Max Power 500W Weight(With Cooling Fan) 158g

ESC Working Current 40A Working Voltage 6S LiPo Signal Frequency 30Hz ~ 450Hz Drive PWM Frequency 8KHz Weight(With Radiators) 35g

Foldable Propeller (1552/1552R) Material High strength performance engineered plastics
Size 15×5.2inch Weight 13g

Flight Parameters Takeoff Weight 6.0Kg ~ 11.0Kg Total Weight 4.2Kg Power Battery LiPo (6S

、 10000mAh~20000mAh

、 15C(Min)) Max Power Consumption 4000W Hover Power Consumption 1500W (@9.5Kg Takeoff Weight)
Hover Time 15min (@15000mAh & 9.5Kg Takeoff Weight) Working Environment Temperature36 - 10 °C ~ +40 °C

Gain Value Settings For A2 Flight Controller Basic: Roll 120%, Pitch 120%, Yaw 120% Attitude: Roll 170%, Pitch 170%, Vertical 120% For WooKong

- M Flight Controller Basic: Roll 180%, Pitch 180%, Yaw 120% Attitude: Roll 180%, Pitch 180%, Vertical 120% 

## 3Drobotics Solo

Cameras: Compatible with GoPro® HERO3, 3+ and 4; optimized for HERO3+ and 4

Streaming video quality: 720p

Flight time: 25 minutes; 20 minutes with payload*

Range: .5 miles** (.8 km)

Max speed: 55 mph (89 km/h)

Max ascent speed: 10 m/s in st abilize mode; “fly” mode spec forthcoming

Max descent speed: ditto

Max payload: 420 g

Max altitude: 400 ft per FAA regulation, user adjustable (122 m)

Motors: 880 kV

Propellers: 10′′ diameter 4.5′′ pitch self

- tightening (24 cm diameter 144 cm pitch)

Autopilo t: Pixhawk 2

Software: APM:Copter

Communication: 3DR Link secure WiFi network

Frequency: 2.4 GHz

Weight: 3.3 lbs. (1.5 kg) / 3.9 lbs. (1.8 kg) with GoPro® and Solo Gimbal

Dimensions: 10 in. tall (25 cm), 18 in. (46 cm) motor

- to

- motor37

Flight battery: Lithiu m polymer 5200 mAh 14.8 Vdc

Battery charge time: ~1.5 hours

Controller battery: 2600 mAh 7.2 Vdc rechargeable lithium ion

App requirements: iOS 8.0 or later / Android 4.3 or later

*Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style and pilot skill. Listed flight time applies to elevations less than 2,000 ft
above sea level.

**Depending on environmental conditions.