UNITED ST AT ES OF AMERI CA DEP AR TMENTOF TRANSPOR TA TI ON FEDERAL

A VI AT IO N ADMINISTRA TI ON WA SHI NGT ON, DC

Regulatory

Docket No. _______________

IN THE MA

TTER OF THE PETITION FOR EXEMPTI ON OF:

Shelby L Miller Airline T ransport Pilot

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TI TLE 14 OF THE CODE OF FEDERAL

REGULA

TI ONS SECTI ONS 61.1 13(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) CONCERNI NG COMMERCIA L OPERA TI ON OF A DJ I Phantom 3 UNMANNED AI RCRAFTSYSTEMS PURSUANTTO SECTI ON 333 OF THE F AA MODERNIZA

TI ON AND REFORM ACTOF 2012 (PUBLIC LA W 11 2

- 95)

Submitted on November 23 , 2015

Shelby Miller 1427 Winsor Dr

. Quincy , IL 62305 Slm0024@y ahoo.com (312)

- 972

- 4418TA BLE OF CONTENTS Page

GLOSSAR

Y OF ABBREVIA

TI ONS.......................................................................................................... .......3

SUMMAR

Y.

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

IN TRODUCTION AND INTERESTS OF PETITIONER......................................................4

BACK GROUND.....................................................................................................................5

BASI S FOR PETITION........................................................................................................... 5

NAME AND ADDRESS OF PETITIONER................................................................6

THE SPECIFI C SECTIONS OF 14 C.F .R. FROM WHI CH SHELBY L MILLER SEEKS EXEMPTI ON.........................

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

THE EXTENT O F REL IEF SHELBY L M ILLER SEEKS AND THE REASON SHELBY L MILLER SEEKS THE RELIEF...

..................... 9

THE REASON S WHY

GRANTING SHELBY

L MILLER REQUEST WOULD BE IN THE PUBLIC INTEREST

............................... ..............................10

THE REASONS WHY

GRANTING THE EXEMPTI ON WOULD NOT ADVERSEL

Y A FFECTSAFETY

................................................ ..............................12

CONCLUSION.................................................................................................... ...................19GLOSSAR Y OF ABBREVIA

TI ONS

AGL Above Ground Level AOI Area of Interest AT C Air T

raffic Control AT O Air T

raffic Organization AV Aerial V

ehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Av iation Administration FA R Federal Av iation Regulation GCS Ground Control Station GPS Global Positioning Sy stem LO L Loss of Link NAS National Airspace S ys tem NOT AM Notice to Airman PI C Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) SO Safety

Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft Sy stem VFR Vi sual Flight Rules VLOS Vi sual L ine of Site VMC Vi sual Meteorological Conditions VTOL Ve rtical T

akeof f and Landing DJI UA

V manufacturer ESC Electronic speed control FPV First Person V iew LI

- PO Lithium Poly mer battery RCV Radi o Controlled vehicle**SUMMAR Y** 

Shelby L ee Miller seeks exemption from the requirements of 14 C.F .R §§ 61.1 13(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 Sy stem pursuant to Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA). Th is ex emption will permit SHELBY L MI LLER to operate an Unmanned Aircraft Sy stem (UAS) for the commercial purpose of conducting ae ria l video and photography for coverage of events, film sets, news, scripted and unscripted television sets and landscape, search and rescue, structural inspections of bridges, pipelines, wells, power lines, cell towers, agricultural fields, enhanced real estate listings, and other building or structural inspections over certain areas of the United States

**INTRODUCTION AND INTERESTS OF**  **T HE PETITIONER** 

My name is SHELBY

L MI LLER

. I have been a licensed ( Airline Tr ansport Pilot ) since 2010 with knowledge of all current F AA regulations . My

flight experience cons ists of PI C of ERJ

- 170 and SI C of both the ERJ

- 170 and CL

- 65. I have also flown as PI C of BE

- 58, BE

- 36, and P A

- 28

- 161 small aircraft

. Along with airline and general aviation experience, Iam a 2 ye ar e xperienced expert operator of multiple ty

pes of RCV

A ircraft including quadc opters and g eneral fixed wing.

Th e objective of SHELBY L MILLER ’ is to provide high quality imaging & filming for coverage of events, film sets, news, scripted and unscripted television sets and landscape, search and rescue, structural inspections of bridges, pipelines, wells, power lines, cell towers, agricultural fields, enhanced real estate listings, and other buil ding or structural inspections. SHELBY L MI LLER will also pro vide knowledge of UAS and promote safe UAS operations.**BACKGROUND**

Unmanned Aircraft Sy ste ms: DJIPhantom 3 UAS SHELBY L MILLER seeks an exemption to operate a DJ I Phantom 3 for compensation or hire within the NAS. The DJ I Phantom 3 is a vertical takeof f and landing (VT OL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone s ystems. The DJ I Phantom 3 has a maximum gross weight of approximately 2 pounds 14 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 DJ I Phantom 3 UA

is equipped with four main rotors; driven b y Li thium Polymer battery powered electric motors.

The DJ I Phantom 3 UA

that will be operated b y S HELBY L MILLER will be 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, I dentification and Registration Mark ings.

**BASIS FOR PETITION**

Petitioner, SHELBY

L MILLER , pursuant to the provisions of the Federal Av iation Regulations (14 C.F .R. § 1 1.61) and the F

AA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraf t Sy stems, hereby

petitions the Administrator to commercially operate the DJIPhantom 3 UASs in the National Airspace S ys tem (NAS), and for an exemption from the requirements of 14 C.F .R §§ 61.1 13(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).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, SHELBY L MILLER, operation o f DJ I Phantom 3 UASs 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

, SHELBY

L MILLER requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), a s these sections set forth requirements for maintenance that onl y apply to aircraft with an airworthiness certificate.

SHELBY L MILLER submits that the requested relief is proper since an equivalent level of safet y wi ll be ensured. SHELBY

L MI LLER will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance L og, and DJ I Phantom 3 Instruc tion Manual) . Furthermore, SHELBY L MILLER will document and maintain all maintenance records for the DJ I Phantom 3 UAS

. Relief from certain requirements of Section 61.1 13(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested b y S HELBY L MILLER to the extent necessary to allow a Pilot in Command (PI C) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, b y meeting minimum flight

- hour and currency requirements, that the PI C is able to safely operate the DJ I Phantom 3 UAS in a manner consistent with thisexemption, including evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and structures.

SHELBY L MILLER seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJ I Phantom 3 UAS do es not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, S ubpart H. As such, SHELBY L MILLER submits that he will ensure that the DJ I Phantom 3 UAS is in an airworth y condition, prior to every flight, by determining that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJ I Phantom 3 In struction Manual), an d that the aircraft is in a condition for safe flight.

SHELBY L MILLER also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJIPhantom 3 UA will not have a t ypical barometric altimeter onboard. However, a ltitude information of the DJ I Phant om 3 UA will be provided to the PI C via Global Positioning Sy stem (GPS) equipment and radio communications telemetry data link, which downlinks from the UA

to the GCS for active monitoring of the flight path. This altitu de information, co mbined with SHELBY

L M ILLER operation of the DJ I Phantom 3 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safet y equivalent to Section 91.121.

Additionally

, SHELBY

L MILLER seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in V FR conditions. SHELBY L M ILLER submits that safety will not be af fected b y operation of the DJ I Phantom 3 UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fl y for a total duration of approximately

15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes.

In accordance with 14 C .F .R. § 1 1.81, SHELBY L MILLER provides the following information in support of its petition for exemption:

**A. Name and**  **Addr ess**  **of the**  **Petitioner**

**.** The name and address of the Petitioner and point of contact is: SHELBY L MILLER 1427 W IN SOR DR QUINCY , IL 62305 (312)

- 972

- 44418 Email: SLM0024@Y

AHOO.COM

**B. The**  **Specific Sections of**  **14 C.F .R. f**  **ro m Which SHELBY** 

**L MILLER**  **Seeks Exemption. 1.**  **SHELBY L**  **MILLER Seeks Exemption Fr**  **om The Requir**  **ements Of Section 61.1 13(a)**  **And (b).**  Section 61.1 13, 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 (PI C) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PI C of an aircraft. b. A private pilot may

, for compensation or hire, act as PI C of an aircraft in connection with any business or employ

ment if

— i. Th e flight is onl y incidental to that business or employment; and ii. The aircraft does not carry passengers or property

for compensation or hire. **2. SHELBY** 

**L MILLER**  **Seeks Exemption Fr om** **The Requir ements Of Section 91.7(a).**  Section 91.7, entitled civil aircraft a irworthiness, subsection (a), stat es the following: (a) No person may

operate a civil aircraft unless it is in an airworthy condition. **3. SHELBY** 

**L MILLER**  **Seeks Exemption Fr om** **The Requir ements Of Section 91.121.**  Section 91.121, entitled Altimeter settings, s ubsection ( a), states the following, in part:

a. Each person operating an aircraft shall maintain th e cruising altitude or flight level of that aircraft, as the case may be, by reference 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

n autical miles of the aircraft; ii. If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an ap propriate 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 departure. **4. SHELBY** 

**L MILLER**  **Seeks Exemption Fr om** **The Requir ements Of Section 91.1**  **51(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 r otor craft under VFR condi tions unless (considering wind and for ecast weather conditions) ther e is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly afte r that for at least 20 minutes. **5. SHELBY** 

**L MILLER**  **Seeks Exemption Fr om** **The Requir ement Of Section 91.405(a).**  Section 91.405, entitled Maintenance required, subsection (a), s tates 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 sec tion, have discrepancies repaired as prescribed in part 43 of this chapter[.] **6. SHELBY** 

**L MILLER**  **Seeks Exemption Fr om** **The Requir ements**  **Of Section 91.407(a)**  Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteratio n, subsection (a)(1), states the following: (a) No person may operate any

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service b y a person authorized un der § 43. 7 of this chapter [.] **7. SHELBY** 

**L MILLER**  **Seeks Exemption Fr om** **The Requir ements Of Sections 91.409(a)(1)**  **And 91.409(a)(2).** Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, n o 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 forreturn to service b y a person authorized by § 43.7 of this chapt er; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter

. **8. SHELBY** 

**L MILLER**  **Seeks Exemption Fr om** **The Requir ements Of Sections 91.417(a)**  **And 91.417(b).** Section 91.417, entitled Maintenance record s, subsections (a) and (b), state the following:

a. Except for work performed in accordance with §§ 91.41 1 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: 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 aircraft (including the airframe) and each engine, propeller, rotor, and applian ce of an aircraft. The records must include

— i. A description (or reference to data acceptable to the Administrat or) of the work performed; and ii. The date of complet ion of the work performed; and iii. The signature and certificate number of the person approving the aircraft for return to service. Records containing the following information:

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

. 2. The current status of life

- limited parts of each airframe, engine, propeller
, rotor, and appliance. 3. The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. 4. The current inspection 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. 5. The current status of applicable airworthiness directives (AD) and safet y directives includ ing, for each, the method of compliance, the AD or safet y directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. 6. Copies of the forms prescribed b y § 43.9(d) of this 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: i. The records specified in paragraph (a)(1) of thi s section shall be retained until the work is repeated or superseded b y other work or for 1 ye ar after the work is performed. ii. The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the ai rcraft is sold. iii. A list of defects furnished to a registered owner or operator under § 43.1 1 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

**C. The Ex tent Of Relief SHELBY**  **L MILLER**  **Seeks And**  **The Reason SHELBY L**  **MILLER Seeks** **The Relief.**

**1. Ex**  **tent Of Relief SHELBY L**  **MILLER Seeks**  **And The Reason SHELBY**  **L MILLER**  **Seeks Relief Fr**  **om Section 61.1**  **13(a) And (b).**  Relief from Section 61.1 13(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PI C 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 currenc y requirements, to c onduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in S ection 61.1 13(a) and (b) state that a private pilot may

, for compensation or hire, act as PI C of an aircraft in connection wi th an y business or employ

ment if: (1) The flight is only incidental to that business or employ ment; and (2) The aircraft does not carry passengers or prop erty for compensation or hire. As set forth mor e full y below, SHELBY L MILER submits that an equivale nt level of safet y will be maintained because no PI C will be allowed to operate the DJ I Phantom 3 UAS unless that PI C has met certain flight

- hour and currency requir ements, demonstrating that the PIC i s able to safel y operate the DJIPhantom 3 in a manner consistent with the operations specifications a s described in this exemption, including evasive and emergency maneuvers, as well as maintain ing appropriate distances from people, vessels, vehicles and structures. Further, SHELBY

L MILLER submits that all flights of the DJ I Phantom 3 UAS , conducted b y the PI C pursuant to the grant of this Petition: (1) will be incidental to SHELBY L MILLER ' business; and (2) will not carry passengers or property

for compensation or hire. **2. Ex**  **tent Of Relief SHELBY L**  **MILLER Se**  **eks And**  **The Reason SHELBY L**  **MILLER Seeks**  **Relief Fr om** **Section 91.7(a).** Relief from Section 91.7(a) entitled Civil aircraft airw orthiness, is requested to the extent required to allow SHELBY L MILLER to determine that the DJ I Phantom 3 UAS is in airworth y condition prior to every flight by ensuring that the UAS is in compliance with the operati ng documents (i.e., SHELBY L MILLER Aerial Operations Manual, Monthly Maintenance L og, and DJIPhantom 3 Instruction Manual). SHELBY L MILLER seeks the requested relief bec ause the DJ I Phantom 3 UAS do es not require an airworthiness certificate in

acco rdance with 14 C.F .R. Part 21, Subpart H. Therefor e, SHELBY L MILLER will ensure that the DJ I Phantom 3 UAS is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Lo g, and DJIPhantom 3 Instruction Manual) prior to every flight, and further, determine that the airc raft is in condition for safe flight, as stated in the conditions and limitations below

. **3. Ex**  **ten t Of Relief SHELBY**  **L MILLER**  **Seeks And**  **The Reason SHELBY L**  **MILLER Seeks**  **Relief Fr**  **om Section 91.121.**  Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJ I Phantom 3 UAS, which utilizes a barometric pre ssure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA

to the PI C at the ground contr ol station (GCS). Since the F AA requires that an y altitude information concerning UAS operations be repor ted to air traf

fic control (A

TC) in feet above groun d level (AGL), SHELBY L MILLER seek s the requested relief because the DJ I Phantom 3 UA

’s altimeter may

be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, b efore 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 full y set forth herein, an equivalent level of safet y will be maintained since the DJIPhantom 3 UA

is equipped with a barometric pressure sensor and GPS equipment, which automatically

ensures that a ground level pressure setting will be established prior to eachflight, and provides the PIC with altitude information of the UA on the heads

- up display

of the GCS. **4. Ex**  **tent Of Relief SHELBY L**  **MILLER Seeks**  **And The Reason SHELBY**  **L MILLER**  **Seeks Relief Fr**  **om Section 91.151(b).**  Relief from Section 91.151(b) entitled Fuel requirements fo r flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJ I Phantom 3 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 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. SHELBY L MI LLER seeks the requested relief because without an exe mption from Section 91.151(b), the flight time duration of the battery powered DJIPhanto m 3 UA will severel y constrain the practicality of any aerial video or stil l photo fli ght operations that SHELBY L MILLER proposes to conduct pursuant to this Petition. Significantly

, as set forth below, the technical specifications of th e DJ I Phantom 3 UAS , the DJI Phantom 3 ope rating documents, and SHELBY L MI LLER proposed operating limitations, ensure that SHELBY

L MI LLER will safel y operate the battery powere d DJIPhantom 3 UA during daylight hours in visual meteorological conditions ( VMC), under visual flight ru les (VFR), with enough battery power to fl y for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fl y after that for at least 4.5 minutes. **5. Ex**  **tent Of Relief SHELBY L**  **MILLER Seeks**  **And The Reason SHELBY**  **L MILLER**  **Seeks Relief Fr**  **om Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),**  **And 91.417(a) & (b).** Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) onl y apply to aircraft with an a ir

worthiness certificate, SHELBY L MILLER requests relief from these Sections because the DJ I Phantom 3 UAS do es not require airworthiness certificates. As set forth more full y below, the DJ I Phantom 3 UAS meet s the conditions of FMRA Section 333 for operation without an airworthine ss certificate. Accordingly

, SHELBY

L MILLER will use trained techn icians to perform maintenance, alterations, or pre ventive maintenance on the UAS usin g the methods, techniques, and practices prescribed in the UAS ope rati ng documents (i.e., SHELBY L MILLER Aerial Operations Manual, Monthly

Maintenance Log, and D JIPhantom 3 Instruction Manual) . Furthermore, SHELBY L MILLER will document and maintain all maintenance rec ords for the DJ I Phantom 3 UAS

.

**D. The Reason**  **s Why**  **Granting SHELBY L**  **MILLER Request**  **Wo uld Be In**  **The Public Inter est:**  **That Is, How It Wo**  **uld Benefit The Public**  **As A**  **Whole.**

Granting the present Petition will further the public intere st by allowing SHELBY

L MI LLER to safely

, ef ficiently , and economicall y pe rf

orm aerial coverage of events, film sets,
news, scripted and unscripted television sets and landscape, search and rescue, structural inspections of bridges, pipelines, wells, power lines, cell towers, agricultural fields, enhanced real estate listings, and other bui lding or structural inspection over certain areas of the United States. Additionally

, use of the DJIPhantom 3 UAS will decrease congestion of the NAS, reduce pollution, crashes and accidents caused b y pilot error and provide significant bene fits to the economy

. Notably , the benefits of SHELBY L MI LLER ’ proposed operation of the DJ I Phantom 3 UAS will be realized without implicating an y privacy issues.

**1. The Public Will Benefit Fr**  **om Decr**  **eased Congestion Of The NAS.**  The DJ I Phantom 3 UA

is batte ry powered and serve s as a safe, ef ficient, and economicalalternative to the manned aircraft traditionally utilized to obtai n aerial imagery . By reducing the amount of manned aircraft needed to p erform aerial acquisitions, an exemption allowing the use

o f a DJ I Phantom 3 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safet y of life and propert y in the air and on the ground. Furthermore, b y reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJ I Phantom UA do es not require an airport t o takeof f or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions w ould result in fewer aircraft that must be handled b y air traf

fic control during the ground, takeof f, departure, arrival, and landing phases of flight operations. **2. The Public Will Benefit Fr**  **om T**  **he Safety And Efficien**  **cy Of The**  **DJI Phantom 3 UAS** 

**.** Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned aircraft, will greatl y benefit the public by drasticall y reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight oper ations. By using battery

power and electric motors, the DJIPhantom 3 UAS produce s no air pollution, and is the most viable environmentally

conscious alternati ve to the cabin class, six cylinder internal combustion engine aircraft that are t ypically utiliz ed for aerial video and photograph y, while burning approximately

20

- 30 gallons per hour of leaded aviation fuel. The DJ I Phantom 3 , while reducing the carbon footprint of aerial acquisitions, also elimin ates noise pollution, as the UA is propelled b y batte ry

powered electric motors, rather than an internal combustion engine. By using the DJ I Phantom 3 UAS to perform aerial acquisitions, the substantial risk to life and propert y in the air and on the ground, which is usually associated with traditional mann ed aircraft flight operations, will be substantially reduced or completely

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJ I Phantom 3 UA (weighing approximately

2 pounds 14 oz, at its maximum gross weight with len gth of 16 inches, width of 16 inches , and with no fuel on board), has less physical potential for collateral damage to life and propert y on the ground, and in the air, compared to the manned aircraft that ty picall y conduct similar operations (weighing appr oximately 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 Vi**  **deo and Photography Operations Wi**  **th The DJI Phan**  **tom 3 UAS Wi**  **ll Benefit**  **The Economy** 

**.** In addition to being safe and efficient, the DJ I Phanto m 3 UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJ I Phantom 3 UAS will allow United States based companie s to remain competitive and co ntribute to growth of the U.S. economy . Specifically

, with the rising cost of aviation fuel an d the Environmental Protection Agency (“EP A”) regulatory

actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technolog y i n order to remain competitive. Operating the battery power ed DJIPhantom 3 UAS is one such technology that not only

allows companies greater operational flexibility co mpared to manned aircraft, but provides such flexibility

without the high operational cost of a traditional manned aircraft. By operating the DJ I Phantom 3 UAS
, companies can remain competitive and profitable, and therefore, provide greater job stability to employ ees and contractors, which will ultimately contribute to growth of the U.S. ec onomy . Improved financial performance of U.S. companies, through commercial use of the DJ I Phantom 3 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. Ther**  **e Ar**  **e No Privacy Issues.** Similar to the manned aerial acquisition flight operation s that have been conducted for decades,SHELBY L MILLER proposed operation of th e D JIPhantom 3 UAS would not implicate any privacy issues. Specifically

, the D JIPhantom 3 UAS will be operated onl y in compliance with operat i ng documents (i.e., SHELBY L MILLER Aerial Operations Manual, Monthly Maintenance Lo g, and DJIPhantom 3 Instruction Manual) which requires propert y owne r involvement as well as local law enforcement notification, and in accordance with the Federal Av iation Regulations, including the minimum altitude requirements of 14 C.F .R. § 91.1 19.

**E. The Reasons**  **Why Granting The Exemption W**  **ould Not Adversely**  **Affect Safety , Or**  **How The**  **Exemption W**

**ould Pr ovide**  **A Level Of Safety**  **At Least Equal To**  **T hat Pr**  **ovided By The Rule**  **Fr om** **Which SHELBY**

**L MILLER**  **Seeks Exemption.**

**1. Reasons Why The**  **DJI Phantom 3 UA Meet**  **s The Condition**  **s Of The F AA**  **Modernization and Reform**  **Act of 2012 (FMRA) Section 333.** In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, SHELBY L MI LLER ’ operation of the DJ I Phantom 3 UAS meet s the conditions of FMRA Sectio n 333, and will not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Secti on 333 provides authority for a UAS to operate without airworthiness certificati on and sets forth requirements for considering whether a UAS will create a hazard to user s of the NAS or the public, or otherwise pose a threat to national security

. Specificall y, FMRA

Section 333 states the following, in part:

**a.** In General.

-- Notwithstanding an y other requirement of this s ubtitle, and not later than 180 day s after the date of enactment of this Act, the Sec retary of T ransportation shall determine if certain unmanned aircraft sy stems may operate s afely

in the national airspace sy stem before completion of the plan and rulemaki ng required b y section 332 of this Act or the guidance required b y section 334 of this Act. **b.** Assessment of Unmanned Aircraft S ys tems

. - - In making the determination under subsection (a), the Secretary shall determine, at a minimum

— **i.** Which ty

pes of unmanned ai rcraft s ys tems, 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

n ational airspace s ys tem or the public or pose a threat to national security ; and whether a certifi cate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft s ys tems identified under paragraph (1).

**c.** Requirements for Safe Operation

. - - If the Secretary determines under this section that certain unmanned aircraft sy stems may operate safely

in the national airspace s ys tem, the Secretary

shall establish requirements for the safe operation of such aircraft s ys tems in the national airspace sy stem.
In seeking this exemption, SHELBY L MILLER submits that the DJ I Phantom 3 UAS can operate safel y in the NAS pursuant to FMRA Section 333, as demonstrated by : (a) the characteristics of the DJI Phantom 3 UAS ; (b) the pilot certification requirement; and (c) the s pecific operating limitations. i. **The Specificat ions Of**  **The DJI Phantom 3 UAS Demonstrate**  **Its Safe Characteristics.**  The DJ I Phantom 3 UAS do es 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. **Te chnical Specifications Of**  **The DJI Phantom 3 UAS** 

**.** The DJ I Phantom 3 Specifications and Data Sheet, attached hereto as Appendix A , set the technical specifications of the DJ I Phantom 3 UAS f orth

. iii. **The DJI Phantom 3 UAS**  **Autonomous Flight And**  **Navigation Modes Enable**  **The UAS To**  **Remain Within A**  **Defined Operational Ar**  **ea.** The DJ I Phantom 3 UAS may be ope rated in both manual and full y a utonomous flight modes. A complete description of the flight and navigational modes of the DJIPhantom 3 UAS is provided at pages 25

- 35 of the DJ I Phantom 3 Use r Manual , attached hereto as Exhibit C

. iv. **The DJI Phantom 3**  **UAS is**  **Designed For A**  **utomatic Return**  **To Home Point**  **Or Hover**  **In The Event Of**  **Loss Of The Contr**  **ol Link Or Navigation.**  When the Control L i nk is lost, the DJIPhantom 3 UA will remain stationary
, in flight, for 3 seconds or more. If, after 3 seconds, the DJ I Phantom 3 UA does not reacquire contro l link data from the GCS, the UA will assume that the Control Link is lost and the UA 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 o f the DJ I Phantom 3 UAS are set forth at pages 27 through 29 of the DJ I Phantom User Manuals, attached hereto as Exhibit C

. v. **The DJI Phantom 3 GCS And It’**  **s Operation.** A complete description of the operation and specifications of the DJ I Phantom 3 GCS and fl ight control software is provided at pages 32 through 43 of the DJI Phantom 3 User Manual . DJI Phantom 3 User Manual is att ached hereto as Exhibits C

. vi. **Flight Operations Of DJI Phantom 3 UAS is**  **Limited To**  **The Line Of Sight Of**  **A Certificated Pilot in Co**  **mmand Wi**  **th A**  **Safety Observer**

**.** SHELBY L MILLER will only

utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PI C ) of the DJIPhantom 3 UAS

. Additionally , a safet y observer will assist all pilots d uring flight time. vii. **Flights Of DJI Phantom 3**  **UAS Wi**  **ll Be Conducted Pursu ant**  **To Specific**  **Operating Limitations.** In seeking this exemption, SHELBY L MILLER proposes to commercially operate DJ I Phantom 3 UAS for the special purpose of conducting aerial vide o and photograph y over certain areas of United States, pursuant to th e following specific operating limitations: 1. Operations authorized b y this grant of exemption wi ll be limited to the following aircraft described in the operating documents, rotorcraft UAS s weighing less than 55 pounds maximum gross weight: DJ I Phantom 3 Unmanned Aircraft Sy stems. Proposed operations of an y other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to c onducting 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 b y the procedures specified in the operating documents unless a special request is made and approved b y AT C. All altitudes reported to AT C must be in feet AGL

. 5. The UA must be operated within visual line of sight (VLOS) of the P ICat all times. This requires the P IC to be able to use human vision un aided by an y device other than corrective lenses, as specified on the PI C’ s FAA

- issued airman medical certificate. 6. The use of first person view (FPV) b y the PI C or safet y ob server (SO) is not permitted. 7. All operations must utilize a safet y observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC alway s maintains VLOS c apability

. The SO and PI C must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PI C must

ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO mu st not perform any other duties bey ond ass isting the PI C with seeing and avoiding other air traf fic and other ground based obstacles/obstru ctions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exe mption must be accessible during UAS operations and made available to the Administrator upon

re quest. If a discrepancy

exists between the conditions and limitations contained in the grant o f exemption and the procedures outlined in the operating documents, the conditions and limitat ions 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 ope rator 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 o f exemption. I f the operator determin es that any update or revision would af fect the basis upon which the F

AA granted the exe mption, then the operator must petition for amendment to its grant of exemption. The F AA’s UAS Integration Office (AFS

- 80) may be c ontacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ens ure that it is in a condition f

or safe flight. If the inspection reveals a condition that af fects the safe operat ion of the UAS, the aircraft is prohibited 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 an d alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that af fect the UA S operation or flight characteristics, e.g. replacement of a flight

cr itical component, must undergo a functional test flight. The PIC who conducts the functional tes t flight must make an entry in the a ircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered i n the

re levant sections of the operating documents.13. The operator must follow the UAS manufacturer ’s aircraft/component, maintenance, overhaul, replacement, inspectio n, and life limit requirements. 14. The operator must carry out its maintenance, i nspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspec tion, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, descri ption of work accompli shed, and the signature of the authorized perso n returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safet y Bulletins. 16. The authorized person must make an entry in the air craft recor d of the corrective action taken against discrepancies discovered between inspections. 17. The PI C must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The operator may

not permit any

PI C to operate unles s the PI C meets the operator ’s qualification criteria and demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and e mergency maneuvers and maintaining appropriate di stances f rom persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F .R. § 61.51(b). Flights for the purposes of training the operator ’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency , and ex perience

building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must o perate the UA with appropriate distance from nonparticipants in accord ance with 14 C.F .R. § 91.1 19. 19. UAS operations may

not be conducted during night, as defined in 14 C.F .R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the F AA of fi ce closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA

may not operate within 5 nautical miles of an airport reference point as denoted on a current F AA

- published aeronautical chart unless a letter of agreement with that airport’ s management is obtained, and the operation is conduc ted in accordance with a NOT AM as required b y the operator ’s COA. The l etter of agreement with the airport managem ent must be made available to the Administrator upon request. 21. 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 f rom the PI C. 22. If the UA

loses communications or loses its GPS s ignal, it must return to a pre

- determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PI C must abort the flight in the eve nt of unpredicte d obstacles oremergencies in accordance with the operating documents. 24. The PI C is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fl y at normal cruising speed to the int ended landing point and land the UA with 25% battery power remaining. 25. The operator must obtain an Air T raf fic Organizati on (A

TO) issued Certificate of Wa iver or Authorization (COA) prior to conducting an y operations under the grant of exemption. This COA will also require the operator to requ est a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the AT O issued CO A inc luding class of airspace, altitude level and potential transponder requirements. 26. All aircraft operated in accordance with the exemptio n must be identified by serial number, registered in accordance with 14 C.F .R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F .R. part 45, Subpart C . Markings must be as large as practicable. 27. Before conducting operations, the radio frequency s pectrum used for operation and control of the UA must compl y with the Federal Communicat ions Commission (FCC) or other appropriate government oversight agency

requirements. 28. 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 an y time the UAS is operating. These do cuments must be made available to the Administrator or an y law enforcement official upon request. 29. The UA

must remain clear and yield the right of way to all manned aviation operation s and activities at all times. 30. The UAS may

not be operated b y the PIC f rom any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all

nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehic les, and structures unless:

a. Barriers or struc tures are present that suf ficiently pr otect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protectio n. If a situation arises where nonparticipating pe rsons leave such protection and are within 500 feet of the UA, flight 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 per

mission and th e PI C has made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PI C, SO, operator traine es or essential persons do not present an undu e hazard to those persons per § 91.1 19(a). 32. All operations shall be conducted over private or c ontrolled

- access propert y with permission from the land owner/controller or authorized repres entative. Permission from land owner/controller or authorizedreprese ntative will be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicab le COA must be reported to the FAA's UAS Integratio n Of fice (AFS

- 80) within 24 hours. Acc idents must be reported to the National Tr ansportation Safet y Board (NTSB) per instructions containe d on the NTSB W eb site: www.ntsb.gov

. **2. Reasons Why**  **An Exemption Fr om**  **The Requir eme**  **nts Of Section 61.1 13(a)**  **And (b) W**  **ou ld**  **Not Adversely**  **Affect Safety**

**.** SHELBY L MILLER submits that the equivalent level of safety established by

Section 61.1 13(a) and (b) will be maintained because no PIC will be allowed to operate the DJ I Phantom 3 UAS unless that PI C has de monstrated, by me eting minimum flight

- hour and currency requirements, that the PI C is able to sa fely operate the DJ I Phant om 3 UAS in a manner consistent with the ex emption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessel s , vehicles and structures. Considering SHELBY

L MI LLER ’ proposed area of operations, and the operating limitations set forth

- above; the parallel nature of privat e pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 1 1062); and the airmanship skills necessary to safel y operate the DJ I Phantom 3 UAS, SHEL BY L MILLER submits that the additional manned airmanshi p experience of a commercially certificated pilot would not correlate to the airmanship s kills n ecessary for SHELBY

L MILLER ’ specific proposed flight operations. The F AA has previously

granted relief from Section 61.1 13(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11 062, 1 1063, 1 1064, 1 1065, 1 1066, 1 1067, 1 1080, 1 11 09, 1 111 0, 1 111 2, 1 11 36, 1 11 38, 1 11 50, 111 53, 1 11 56, 1 11 58, 1 11 59, 111 60, 1 11 61). SHELBY L MILLER will not allow an y P IC to operate the DJ I Phantom 3 UAS unless that PI C has demonstrated, by meeting minimum flight

hour requi rements or the DJIPhantom 3 UAS training and currency requirements, that the PI C is able to safel y operate the DJ I Phantom 3 UAS in a manner consistent with this exemption, including e vasive and emergency maneuvers and maintaining appro priate distances from people, vess els, 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 the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeof fs and landings in the preceding 90 day s (for currency

purposes). As in E xemption Nos. 1 1062, 1 11 38, and 1 11 53, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent leve l of safet y during SHELBY

L MILLER’ proposed operations. The Administrator has held that pr ior documented flight experience that was obtained in compliance with applicable regulations would ensure safe o perations, stating as follows: In Exemption No. 1 1062, the F AA required that prior to conducting operations for the purpose of motion picture fi lming (or similar operations), the PI C 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 operat ions under Exemption No. 1 1062, the PI C must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the F AA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10hours 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 PI C must accomplish 3 takeof fs and landings in the preceding 90 day s (for currency purposes). The F

AA finds that at a minimum, the flight hour requirements in Exemption No. 1 1062 are appropriate to practice and build proficiency

in the skills necessary to safel y 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. Tr aining, proficiency , and experience

building fl ights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency , and experience

- building flights the PI C is required to operate the UA

with appropriate distances in acc ordance with 14 C.F .R 91.1 19.

Exemption No. 1 11 38 at page 15. Accordingly

, SHELBY

L MILLER will ensure safe operations b y not allowing an y P IC to operate the DJ I Phantom 3 UAS unless that PI C has demonstrated, by meeting minimum flight

hour and currency

requirements, that the PI C is able to safel y operate the DJI Phantom 3 UAS in a manner consistent with th e exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

**CONCLUSION** SHELBY L MILLER seeks an exemption pursuant to 14 C.F .R. § 1 1.61 and Section 333 of the F

AA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJ I Phantom 3 UAS commerci ally , without an airworthiness certificate, for the li mited purpose of conducting coverage of events, film sets, news, scripted and unscripted television sets and landscape, search and rescue, structural inspections of bridges, pipelines, wells, power lines, cell towers, agricultural fields, enhanced real estate list ings, and other building or structural inspections. . By granting this Petition, the F AA A dministrator will be fulfilling the Congressional mandate of the F AA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowin g SHELBY

L MILLER to safely

, efficiently

, and economically

operate the DJ I Phantom 3 UA S commercially within the NAS. WHEREFORE, in accordance with the Federal Av iation Regulations and the F AA Modernization and Reform Act of 2012, Sect ion 333, SHELBY L MIL LER respectfull y requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F .R Sections 61.1 13(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit SH ELBY L M ILLER to operate the DJ I Phantom 3 UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: NOVEMBER 23 , 2015 Submitted by Shelby L Mille r**APPENDIX**

**– A**  DJIPHANT OM 3 TECHNI CAL SPECIFICA

TI ONS

SHELBY L MILLER only

utilizes safe and reliable UASs. DJ I is an industry leader in small UAS production. DJ I UASs are loaded with ground breaking 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, DJ I software provides real

- time altitude and location information to the PI C via the linked monitor (smart phone/t ablet devices)

DJIPhantom 3 1.1 Aircraft 1.1.1 Supported Battery

– DJ I 6000AH L iPo Battery 1.1.2 We ight (Battery

& Propellers Included)

– 2lbs 1 1.810oz (1242g) 1.1.3 Hover Accuracy

(Ready to Fly)

– Ve rtical: .8m; Horizontal: 2.5m 1.1.4 M ax Yaw Angular Ve locity

- 200/s 1.1.5 Max Ti lt Angel

- 35 1.1.1.6 Max Ascent Speed

– 6m/s 1.1.6 Max Descent Speed

– 2m/s 1.1.7 Max Flight S peed

– 15m/s (NOTRECOMMENDED)1.2 Gimbal

1.2.1 Wo rking Current

– Static: 750mA; Dy namic: 900mA 1.2.2 Control Accuracy

- ±0.03 1.2.3 Controllable Range

– Pi tch:

- 90

- 0 1.2.4 Maximum Angu lar Speed

– Pitch: 90/s 1.3 Camera 1.3.1 Operating Temperature Range

- 32F

- 104F (0C

- 40C) 1.3.2 Sensor Size

– 1/2.3” 1.3.3 Ef fective Pixels

– 14M 1.3.4 Resolution

– 4384x3288 1.3.5 HD V

ide o Recording

– 1080p30 & 720p 1.3.6 Recording Field of V iew

- 11 0/85