UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. FAA

- 2007

- 0001

Docket Operations, M

- 30 U.S. Department of Transportation (DOT) 1200 New Jersey Avenue,

Room W12

- 140, West Building Ground Floor Washington, DC 20590

- 0001

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

PMT PROPERTIES

a Tennessee Limited Liability Commpany

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL
OPERATION OF DJI PHANTOM 2 VISION+ AND DJI INSPIRE 1 UNMANNED AIRCRAFT

SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on January 25, 2016

PMT PROPERTIES LLC c/o JOHN PEGRAM, MANAGER

188 Front Street Suite 116

- 18 Franklin, Tennessee

37064

615

- 586

- 12982 | P a g e TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS

................................ ................................ ........... 3

SUMMARY.

................................ ................................ ................................ ................. 4

INTRODUCTION AND INTERESTS OF PETITIONER

................................ .......... 4

BACKGROUND

................................ ................................ ................................ ......... 4

BASIS FOR PETITION.

................................ ................................ ............................... 5

A. NAME AND ADDRESS OF PETITIONER

... ... ... ... ... ... ... ... ... ... ... ... ... 6

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH

PMT PROPERTIES LLC EXEMPTION

... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 7

C. THE EXTENT OF RELIEF PMT PROPERTIES LLC SEEKS AND THE

REASON P MT PROPERTIES LLC

SEEKS THE RELIEF

................................ ................................ ........... ... ... ... . 1 0

D. THE REASONS WHY GRANTING PMT PROPERTIES LLC
REQUEST WOULD BE IN THE

PUBLIC INTEREST

... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . . 1 2

E. THE REASONS WHY GRANTING THE EXEMPTION

WOULD NOT ADVERSELY AFFECT SAFETY

... ... ... ... ... ... ... ... ... ... ... .. 1 4

THE REASONS WHY GRANTING AN EXEMPTION FROM

THE REQUIREMENTS OF 61.113( A ) AND ( B )

WOULD NOT ADVERSELY AFFECT SAFETY...

................................ .................... 2 0

CONCLUSION

................................ ................................ ................................ ........... 2 13 | P a g e GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System NOTAM

Notice to Airman

PIC Pilot in Command

Section 333 FAA Modernization and Reform Act of2012 (FMRA) SO Safety

Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAS Small Unmanned Aircraft System (under 55 pounds Gross Weight) VFR

Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions VTOL

Vertical Takeoff and Landing
DJI UAV manufacturer

ESC Electronic speed control

FPV First Person View

LI

- PO Lithium Polymer battery

RCV Radio Controlled vehicle4 | P a g e SUMMARY

PMT PROPERTIES LLC seeks exemption from the 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), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit PMT

PROPERTIES LLC to operate an Unmanned Aircraft System (UAS) for the commercia l purpose of conducting aerial video and photography for marketing, film sets, real estate photography,

comme rcials, special events, cinematography, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is JOHN PEGRAM, and I am the Manager and owne r PMT PROPERTIES, LLC. I also hold a Single engine land pilot certificate with high performance ratings, along with a 3 rd Class

Medical Certificate.

JOHN PEGRAM, is a Real Estate Broker, specializing in Land Acquisition, Land Development, Residential Community Development, New Home Construction, Commercial Development,

Commercial Sales and some Re

- Sale Residential Sales.

The objective of PMT PROPERTIES, LLC aerial video and photography operations is to provide hig h quality imaging directly associated with real estate, both commercial, and residential applications

. UAS High Definition videography and photography provides a client with a cle arer view of the property from vantage points once prohibited by manned flights. In addition, the aerial presentation offers a cost effective means of marketing, managing, improving construction costs. High Definition Aerial Videography serves the public a nd governing bodies by providing

an advance visual display which allows for more effective planning, and superior information

which lead to better informed decision.

BACKGROUND

Unmanned Aircraft Sy stems: DJI Phantom 2 Vision +, DJI Inspire 1

PMT PROPERTIE S seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 2 Vision + and DJI Inspire I are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2 Vision+ has a maximum gross weight of approximately 2 pounds 7 ounces, while having a length of 16 inches’ width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approx imately 42 knots. The DJI Phantom 2 Vision + and DJI Inspire l UA’s are equipped with four main rotors; driven by electric motors powered by a Lithium Polymer battery.

The D JI Phantom 2 plus and DJI Inspire 1 UAS’s that will be operate d by JOHN PEGRAM, PM T

PROPERTIES LLC and registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Markings

.5 | P a g e BASIS FOR PETITION

Petitioner, PMT PROPERTIES,LLC , pursuant to the provisions of the Federal Aviation Regulations (14C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby pe titions the Administrator to commercially operate the DJI P hantom 2 Vision + and the DJI Inspire 1 UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.119, 91.121, 91.l51(b), 91. 405(a), 91.407(a)(I), 91.409(a)(l) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, PMT PROPERTIES LLC operation of DJI Phantom 2 and DJI Inspire 1 UAS’s meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, PMT PROPERTIES LLC requests relief from Sections 91.405(a), 91.407(a)(I), 91.409(a) (I) & (a)(2), and 91.417 (a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.

PMT PROPERTIES LLC submits that the requested relief is proper since an equivalent level of safety w ill be ensured. PMT PROPERTIES LLC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Mai ntenance Log, and DJI Phantom 2 Vision + and DJI Inspire 1 Instruction Manual). Furthermore, PMT PROPERTIES

LLC will document and maintain all maintenance records for the DJI Phantom 2 Vision + and DJI Inspire 1 UAS.

Relief from certain requir ements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by PMT PROPERTIES LLC to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as w ell as an airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the D JI Phantom 2 Vision + and DJI Inspire 1 UAS in a manner consistent with this exemption, in cluding evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

PMT PROPERTIES LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the D JI Phantom 2 and DJI Ins pire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, PMT PROPERTIES LLC submits that he will ensure that the DJI Phantom 2 Vision+ and DJI Inspire l UAS are in an airworthy condition, prior to eve ry f light, by determining that the UAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.6 | P a g e PMT PROPERTIES LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vison+ and DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2 Vis ion+ and DJI Inspire 1 UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, c ombined with PMT PROPERTIES LLC operation of the D JI Phantom 2 Vision+ and DJI Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, PMT PROPERTIES LLC seeks an exemp tion from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. PMT PROPERTIES LLC submits that safety will not be affected by operation of the D JI Phantom 2 and DJI Inspire 1 UAS’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 approximately 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 1 4 C.F.R. § 11.81, JOHN PEGRAM provides the following information in support of its petition for exemption:

A. Name and address o f The Petitioner.

The name and address of the Petitioner and point of contact is:

PMT PROPERTIES LLC
JOHN PEGRAM, MANAGER

188 Front Street Suite 116

- 18 Franklin, Tennessee

37064

615

- 586

- 1298 John@thepegramteam.com7 | P a g e B. T he Specific Secti ons of 14 C.F.R. from which PMT PROPERTIES LLC Seeks Exemption.

1. PMT PROPERTIES LLC Seeks Exemption from The Requirements of Section 61.1l3(a) and (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, Subsections (a) and (b) prescribe the following, in relevant part:

a. No person who holds a private 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.

b. A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

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

ii. The aircraft does not carry passengers or property for compensation or hire.

2

. PMT PROPERTIES LLC Seeks Exemption from The Requirements of Section 91.7(a).

Section 91.7, entitled civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. PMT PROPERTIES LLC Seeks Exemption from The Requirements of Section 91.121.

a. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by refe rence to an altimeter that is set, when operating

- Below 18,000 feet MSL, to

-

(i) The current reported altimeter setting of a station along the route and within
100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(l)(i) of this section, the current reported altimeter setting of an appropriate available

station;

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departu re.

4

. PMT PROPERTIES LLC 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: (b) No person may begin a flight in a rotorcraft under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20

minutes.8 | P a g e 4. PMT PROPERTIES LLC Seeks Exemption from The Requirement of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a) states the following: Each owner or operator of an aircraft:

a. 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

5. PMT PROPERTIES LLC Seeks Exemption from The Requirements o f Section 91. 407(a)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration;

a. Subsection (a)(1), states the following: No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- It has been approved for return to service by a person authorized under §43.7 of this chapter

7. PMT PROPERTIES LLC Seeks Exemption from The Requirements of Sections 91.409(a)(1) And 91.409(a)(2).

a. Section 91.409, entitled Inspections, s ubsection (a), states the following:

i. 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.

8. PMT PROPERTIES LLC Seeks Exemption from The Requirements of Sections 91.417(a) And 91.417(b).

a. Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

i. 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) Records 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 ai rcraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

(a) A description (or reference to data acceptable to the Administrator) of the work performed; and9 | P a g e (b) The date of completion of the work performed; and

(c) The signature, and certificate number of the person approving the aircraft

for return to service.

Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each

rotor.

(ii) The current status of life

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

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspec tion status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety

directives in cluding, for each, the method 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.

(vi) Copies of the forms prescribed by § 43.9(d) of th is chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

b. The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of th is section shall be retained until the work is repeated or superseded by other work or for I 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 defects 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.10 | P a g e C. The Extent of Re lief PMT PROPER TIES LLC Seeks and The reason PMT PROPERTIES LLC

Seeks the Relief.

1. Relief from Section 61.113(a) And (b):

a. Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in

command , is requested to the extent necessary to allow a PIC holding a private 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 UAS flight operations for compensation or hir e. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private 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. As set forth more fully below, PMT PROPERTIES LLC submits that an equivalent level of safety will be maintained because no PIC will be all owed to operate the DJI Phantom 2Vision + UAS or DJI Inspire 1 UAS 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 Vision + or DJI Inspire 1 UAS in a manne r 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. Further, PMT PROPERTIES LLC submits that all flights of the DJI Phantom 2 Vision + and DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to PMT PROPERTIES LLC ’s business; and (2) will not carry passengers or property for compensation or hire.

b. Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow PMT PROPERTIES LLC to determine that the DJI Phantom 2 and DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., PMT PROPERTIES LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision + and DJI Inspire 1 Instruction Manual). PMT PROPERTIES LLC seeks the requested relief because the DJI Phantom 2 and DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. The refore, PMT PROPERTIES LLC will ensure that the DJI Phantom 2 Vision + and DJI Inspire 1 UAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 User Manuals; prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.
Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS).

Since the F AA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), PMT PROPERTIES LLC seeks the requested relief because the DJI Phantom 2 Vision + and DJI Inspire 1 UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of11 | P a g e

safety will be maintained since the DJI Phantom 2 and DJI Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, wh ich automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with

altitude information of the UA on the heads

- up display of the GCS.

c

. Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom 2 Visio n + and DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of approximately15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes PMT PROPERTIES LLC. seeks the requested relief because without an exemption from Section 91.151 (b), the flight time duration of the battery powered DJI Phantom 2 Vision + and DJI Inspire 1 UAS will severely constrain t he practicality of any aerial video or still photo flight operations that proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 2 Vision + and DJI Inspire 1 UAS, the DJI Phantom 2 Vision + and DJI Inspire 1 operating documents, and the operating limitations proposed by, PMT PROPERTIES LLC ensure that PMT PROPERTIES LLC will safely operate the battery powered DJI Phantom 2 Vison +and DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total

duration of 13 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

d. Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft

with an airworthine ss certificate PMT PROPERTIES LLC requests relief from these Sections because the DJI Phantom 2 Vision + and DJI Inspire 1 UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, PMT PROPERTIES LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e PMT PROPERTIES LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual).
Furthermore, will document and maintain all maintenance records for t he DJI Phantom 2 Vision + and DJI Inspire 1 UAS.12 | P a g e D. The Reasons Why Granting PMT PROPERTIES LLC Request Would Be in The Public

Interest : That Is, How It Would Benefit the Public as A Whole.

Granting the present Petition will further the public interest by allowing PMT

PROPERTIES LLC to safely, efficiently, and economically perform aerial video and photography of construction sites, rea l estate, and landscape over certain areas of the United

States.

Additionally, use of the D JI Phantom 2 Vision + and DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, crashes and accidents caused by pilot error and provide significan t benefits to the economy. Notably, the benefits of PMT PROPERTIES LLC proposed operation of the D JI Phantom 2 and DJI Inspire 1 UAS will be realized without conflicting with or violation of any privacy issues.

1. The Public Will Benefit from Decreased Conges tion of The NAS.

The DJI Phantom 2 Vision and DJI Inspire 1 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, a n exemption allowing the use of a DJI Phantom 2 Vision+ or DJI Inspire 1
UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermor e, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom

2 Vision+ and DJI Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public W ill Benefit from The Safety and Environmentally friendly renewable energy DJI Phantom 2 Vision + and DJI Inspire 1 UAS. Conducting aerial media acquisitions with the DJI Phantom 2 Vision + and DJI Inspire

1 UAS, instead of manned aircraft, wi ll greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the D JI Phantom 2 Vision + and DJI In spire 1 UAS produce no air pollution, and is the most viable environmentally conscious alte rnative to the cabin class, six

- cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography which burn approximately 20

- 30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 Vision + and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminate noise pollution, as the UAs are propelled by battery powered electric motors,

rather than an internal combustion engine. By using the D JI Phantom 2 Vision + and DJI Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircra ft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 2 and DJI Inspire 1 UAs (weighing approximately 2 pounds 14 ounces and 6 pounds 7.5 ounce s respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 1613 | P a g e

inches and 17.7 inches respectively, and with no fuel on board), has less physical potential for collateral damage to life and property on t he ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations with The DJI Phantom 2 Vision +
and DJI Inspire 1 UAS Will Benefit the Economy.

In addition to being safe and efficient, the D JI Phantom 2 Vision + and DJI Inspire 1 UAS are

also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the D JI Phantom 2 Vision + and DJI Inspire 1 UAS will allow United States based companies, such as PMT PROPERTIES LLC to remain competitive and contribute to growth of t he U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Pha ntom 2 Vision+ and DJI Inspire 1 UAS utilizes technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS, companies such as can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 2 Vision + and DJI Inspire 1 UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States

and abroad.

4. There Are No Privacy Issues.
Similar to the manned aerial media acquisition flig ht operations that have been conducted for decades, proposed operation of the DJI Phantom 2 Vison + and DJI Inspire 1 UAS would not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision + and DJI Inspire 1 UAS will be operated only in compliance with operating documents (i.e., PMT

PROPERTIES LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual) which requires property owner

involvement as well as local law enforcement notificati on, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. §

91.119.14 | P a g e E. The Reasons Why Granting the Exemption Would Not Adversely Affect Safety, Or How the Exemption Would Provide a L evel of Safety at Least Equal t o That Provided by The Rule from

PMT PROPERTIES LLC Seeks Exemption.

1. Reasons Why The DJI Phantom 2 vision + and DJI Inspire 1 UAV Meet the Conditions of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333:

2. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, operation of the DJI Phantom 2 Vision + and DJI Inspire 1 UAS meet the conditions of FMRA Section 333, and will not require an

air worthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the N AS or the public, or otherwise pose a threat to national security. 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 systems 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 determination under subsection (a), the Secretary shall determine, at a minimum

c. 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 use rs of the national airspace system or the public or pose a threat to national security; and whether a
certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for t he operation of unmanned aircraft systems identified under paragraph (J).

d. 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 Secre tary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.15 | P a g e In seeking this exemption, PMT PROPERTIES LLC submits that the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the D JI Phantom 2 and DJI Inspire 1 UAS, (b) the pilot certification requirement and (c) the specific operating limitations.

i. The Specifications of The D JI Phantom 2 Vis ion + and DJI Inspire 1 UAS

Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision + and DJI Inspire 1 UAS 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.

ii. Technical Specifications of The DJI Phantom 2 Vision + and DJI Inspire 1 UAS.

The DJI Phantom 2 and DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibits A and B, set the technical specifications of the D JI Phantom 2 Vision+ and DJI Inspire 1 UAS forth.

iii. The DJI Phantom 2 Vision + and DJI Inspire 1 UAS Autonomous Flight and Navigation Modes Enable The UAS to Remain Within A Defined Operational

Area.

The DJI Pha ntom 2 Vision + and DJI Inspire 1 UAS 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 Vision + and DJI Inspire 1 UAS is provided at pages 25

- 35 of the DJI Phantom 2 Vision + and pages 12

- 16 a nd 45

- 50 of the DJI Inspire I User
Manuals, attached hereto as Exhibit C and D.

iv. The DJI Phantom 2 Vision + and DJI Inspire 1 UAS Are Designed for Automatic

Return to Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Contr ol Link is lost, the DJI Phantom 2 Vision + and DJI Inspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2

vision + and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs

will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI Phantom 2 Vision + UAS are s et forth at pages 27 and 28 and for the DJI Inspire 1 at pages 13 through 15 of the DJI

Phantom 2 vision + along with complete DJI Inspire 1 User Manuals, attached hereto as

Exhibit C and D.

v. The DJI Phantom 2 Vision + and DJI Inspire 1 Ground Control Station (“GCS”) And

Its Operation.

A complete description of the operation and specifications of the DJI Phantom 2 and DJI Inspire 1 GCS and flight control software is provided at pages 32 through 44 of the DJI

Phantom 2 V ision + User Manual and pages 23 through 33 of the DJI Inspire 1 User Manual. DJI Phantom 2 Vision + and DJI Inspire 1 User Manuals are attached hereto as

Exhibits C and D.16 | P a g e

vi. Flight Operations of DJI Phantom 2 Vision +and DJl Inspire 1 UAS Are Limited to The

Line of Sight of a Certificated Pilot in Command with A Safety Observer.

vii. PMT PROPERTIES LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phanto m 2 Vision + and DJI Inspire 1 UAS. Additionally, a safety observer will assist all pilots during flight time.

viii. Flights of DJI Phantom 2 Vision + and DJI Inspire 1 UAS Will Be Conducted

Pursuant to Specific Operating L i mi t at i o n s

. In seeking this exemption, PMT PROPERTIES LLC proposes to commercially operate DJI Phantom 2 and DJI Inspire 1 UAs for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating

limitations :

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS (s) weighing less

than 55 pounds’ maximum gross weight: DJI Phantom 2 Vision + and D JI Inspire

1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

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

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made an d approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any

device other than corrective lens es, as specified on the PIC's FAA

- issued airman

medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (S O) is permitted as long as SO maintains visual on UAV.

7. 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 designat ed 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.

8. The SO must not perform any other duties beyond assisting the P IC 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 | P a g e 9. The operating documents and the grant of exemption must be accessible during UAS oper ations 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 contained 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 tr ack such revisions 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 th at 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 UAS Integration Office (AFS

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

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition f or safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibite d from operating until the necessary maintenance has been performed and the UAS 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 documen ted in the

aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. 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 docume nts.

13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance w ith 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 the authori zed person returning the UAS to

service.

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discove red between inspections18 | P a g e 1 7

. The PIC must possess at least a private pilot certificate and at least a current t

hird

- class medical certificate. determination under subsection (a), the Secretary shall determine, at a

minimum

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 airspac e system or the public or pose a threat to national security; and
whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned a ircraft systems identified under paragraph (J). 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 requi rements for the safe operation of such aircraft systems in the national airspace system. closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

17. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA

- pub lished 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 agreement with the airport management must be made available to the Administrator upon request.

18. The UA 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.

19. If the UA loses communications or loses its GP S 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.

20. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance wi th the operating documents.

21. 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 UA with 25% battery power

r emaining.

22. 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 require the operator to request a Notice to

Airman (NOTAM) not more than 72 hours19 | P a g e 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.

23. 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 i n accordance with 14 C.F .R. part 4 5, Subpart C. Markings must be as large as practicable.

24. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversig ht agency requirements.

25. 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 UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

26. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.

27. The UAS may not be operated by the PIC from any moving device or vehicle.

28. Flight operations must be conduc ted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

person s from the UA 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 protection and are within 500 feet of the UA, fligh t operations must cease immediately and/or;

b. 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 has made a safety assessment of the risk of oper ating closer to those objects and determined that it does not present an undue
hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

29. All operations shall be conducted over private or controlled

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

30. Any incid ent, 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 UAS Integration Office (AFS

- 80) w ithin 24 hours.

Accidents must be reported to the National Transportation Safety Board (NTSB) per

instructions contained on the NTSB Website: www.ntsb.gov.20 | P a g e Reasons Why an Exemption from The Requirements of Section 61.113(a) And (b) Would Not Adversely Affect Safety.

PMT PROPERTIES LLC 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 Vision + and DJI Inspire 1 UAS 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 Vision + or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuver s and maintaining appropriate distances from people, vessels, vehicles and structures. Considering PMT PROPERTIES LLC’s proposed area of operations, and the operating

limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 2 Vision + or DJI Inspire 1
UAS, PMT PROPERTIES LLC submits that the additional manned airmanship expe rience of a commercially certificated pilot would not correlate to the airmanship skills necessary for

PMT PROPERTIES LLC specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circums tances 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, 1115 6, 11158, 11159, 11160, 11161). PMT PROPERTIES LLC

will not allow any PIC to operate the DJI Phantom 2 Visio + or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 2 or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safe ly operate the DJI Phantom 2 or DJI Inspire 1 UAS 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 logged, in a manner consistent with 14 C.F.R. § 61.51 (b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under th e exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062,11138, and 11153, prior documented flight experience that was obtained in compl iance with applicable regulations will ensure an equivalent level of safety during PMT PROPERTIES LLC’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations wo uld 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 consistent with 14 CFR 61.51 (b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a

multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a min imum of 5 h ours as a UAS pilot operating the same make and model of UAS 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 may be i ncluded in the 1021 | P a g e

hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for cur rency 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 night time. During training, proficiency, and
experience

- building flights the PIC is required to operate the UA with appropriate distances

in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15. Accordingly, PMT PROPERTIES LLC will ensure safe
operations by not allowing any PIC to operate the DJI Phantom 2 or DJI Inspire 1 U AS unless that PTC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision + or DJI Inspire 1UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.

CONCLUSION

PMT PROPERTIES LLC seeks an exemption 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 and DJI Inspire 1sUAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional

mandate of the FAA Modernization and Reform Act of 2012, while also a dvancing the interests of the public, by allowing PMT PROPERTIES LLC to safely, efficiently, and economically operate the DJI Phantom 2 and DJI Inspire 1sUAS commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and t he FAA Modernization and Reform Act of 20 12,

Section 333, PMT PROPERTIES LLC 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit PMT PROPERTIES LLC operate the DJI Phantom 2 Vision

+ and DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated:

January 25, 2016

Submitted by:

PMT PROPERTIES LLC

John D. Pegram, Manager22 | P a g e EXHIBIT A

DJI PHANTOM 2 VISION +

TECHNICAL SPECIFICATIONS

PMT PROPERTIES LLC only utilizes safe and reliable UAS. DJI is an industry leader in small UAS

p roduction. DJI UAS are complete with leading edge and proven software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also he set to limit flight to no higher than a predetermin ed and set altitude as well as limit flight to a predetermined and set

distance. In addition, DJI software provides

real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

DJI Phantom 2

1.1 Aircraft

1.1.1 Supported Battery

- DJI 5,200mAh 2S LiPo Battery

1.1.2 Weight (Battery & Propellers Included)

- 2 lbs 11.81 oz (1,242g)

1.1.3 Hover Accuracy (Ready to Fly)

- Vertical: .8m; Horizontal: 2.5m

1.1.4 Max Yaw Angular Velocity 200°/s

1.1.5 Max Tilt Angel 35°

1.1.6 Max Ascent / Descent Speed: As cent 6m/s Descent 2m/s

1.1.7 Max Flight Speed

- 15m/s (NOT RECOMMENDED)

1.2 Gimbal

1.2.1 Working Current

- Static: 750mA; Dynamic: 900mA

1.2.2 Control Accuracy

- ±O.03°

1.2.3 Controllable Range

- Pitch: 90° to 0°

1.2.4 Maximum Angular Speed Pitch: 90°/s

1.3 Camera 1.3. 1 Operating Temperature Range 32°F

- 104°F (O°C to 40°C)

1.3.2 Sensor Size 1⁄2. 3 "

1.3.3 Effective Pixels: 14 Megapixels

1.3.4 Resolution 4384x3288px

1.3.5 HD Video Recording: 1080p 30 & nop

1.3.6 Recording Field of View: 110°/85°23 | P a g e EXHIBIT B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

PMT PROPERTIES LLC only utilizes safe and reliable UAS. DJI is an industry leade r in small UAS production. DJI UAS are complete with leading edge and proven software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set

distance. In addition, DJI software provides

real

- time altitude and location information to the PIC via the lin ked monitor (smart phone/tablet devices)

DJI Inspire 1

1.1 Aircraft

1.1.1 Model

- T600

1.1.2 Weight (Battery Included)

- 6 lbs 7.52910z (2,935g)

1.1.3 Hovering Accuracy (GPS Mode)

- Vertical: 0.5m; Horizontal: 2.5m

1.1.4 Max Angular Velocity: Pitch: 300 °/s ; Yaw : 150 °/s

1.1.5 Max Tilt Angle: 35°

1.1.6 Max Ascent Speed: 5m/s

1.1.7 Max Descent Speed: 4m/s

1.1.8 Max Speed: 22m/s (ATTI mode, no wind

- NOT RECOMMENDED)

1.1.9 Max Flight Altitude 4,500m MSL

1.1.10 Max Wind Resistance: 10m/s

1.1.11 Max Flight Time

- Approximately 18 minutes

1.1.12 Motor Model: DJI 3510

1.1.13 Propeller Model: DJI 1345

1.1.14 Operating Temperature Range: 14 ° F to 104 ° F (

- 10 ° C to 40°C) 1.1.15

Dimensions 438x451x201 mm 17.25” x 17.76 " x 7.9"

1.2 Gimbal

1.2.1 Model: ZENMUSE X3

1.2.2 Output Power (with camera): Static: 9W; In Motion: 11 W

1.2.3 Operating Current

- Static: 750mA; In Motion: 900mA

1.2.4 Angular Vibration Range

- ±0.03 °

1.2.5 Mounting

- Detachable

1.2.6 Controllable Range: Pitch:

- 90 ° to +30°; Pan: ±320°

1.2.7 Mechanical Range: Pitch:

- 125 ° to +45°; Pan: ±330°

1.2.8 Max Controllable Speed: Pitch: 120°/s; Pan: 180°/s

1.3 Transmitter

1.3.1 Name

- CI

1.3.2 Operating Frequency 5.728 to 5.850 GHz; 2.400

- 2.483GHz

1.3.3 Communicating Distance (unobstructed): 3.1 miles

1.3.4 Output Power

- 9W

1.3.5 Operating Temperature Range

- 14 ° F to 104 ° F (

- 10°C to 40°C)

1.3.6 Battery 4,500mAh 2S or optional 5,700mAh LiPo 2S

All specifications can be found in the attached user manual or at https://dl.djicdn. com/downloads/inspire_1/en/Inspire%20_1_User_Manual__V1.8.pdf