!! 

Submitted electronically

June 26, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

RE: Petition for Exemption from Certain Federal Aviation Regulations according 

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

Dear Sir or Madam: 

Guida Surveying, Inc. (GSI) is applying for an exemption from the Code of Federal 

Regulations as detailed below.

The exemption would permit commercial operation of a small unmanned aircraft 

system (UAS) in the national airspace (NAS) as regulated by the FAA for the 

following uses:

• Aerial topographical survey and mapping

• Aerial data collection for 3D modeling

• Aerial inspection of job sites, including home constructions sites, and 

equipment

• Aerial data collection for photogrammetry

All operations performed by GSI are cost effective and protect the public by reducing 

the size of the aircraft from one weighing up to several tons to one weighing less than 

55 pounds. In addition, the UA does not use flammable liquid fuel. Instead, it operates 

on high-energy batteries. The UA is flown in the lower strata of controlled and 

uncontrolled airspace, at 400 ft. AGL and below. GSI commercial operations will be 

performed according to FAA regulations or amended FAA regulations as permitted

under a Section 333 Grant of Exemption.
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 2

BACKGROUND AND REFERENCES

GSI is a full-service land survey company. The owners and staff of GSI have served 

their commercial clients and government contracts in California for more than 20 years. 

ALTA/ACSM title surveys, GPS surveys, topographic and subdivision mapping, aerial 

control surveys, and pre-construction video surveys are but a few of the services GSI 

provides.

Surveyors within the construction industry have traditionally relied on fueled, manned 

aircraft (fixed wing or helicopter), and in some instances blimps and balloons for aerial 

photography, photogrammetry, mapping and data collection. Due to their large size and 

the speed and force needed to keep them airborne, these manned aircraft are limited in

attempting any close-proximity maneuvers needed for structure inspection or data 

collection.

The survey company must contract labor and rent equipment not employed or owned 

by the company. Coordination of large, fueled aircraft for data collection is restricted to 

pre-planning and favorable weather. Unfavorable weather and market demand on 

equipment may increase costs and delay projects.

When a manned aircraft cannot be used to collect the necessary data, an “in-person” 

inspection or survey may be the only option left to a survey company. “In person” 

surveys and inspections expose the surveyor to safety risks. When a surveyor needs to 

inspect an acutely angled structure or geographic feature by climbing, falls may happen. 

In certain instances, the ground may be unstable and should not be traversed. The 

structure or geographic feature being surveyed is also at risk of damage by coming into 

physical contact with the surveyor. 

GSI wishes to increase its effectiveness with its clients and contracting government 

agencies, increase the safety level of its employees and contracted workers on survey 

sites remain competitive economically within California by employing a UAS during 

many of its operations. Therefore, GSI is submitting this 333 exemption petition.

In support of the petition and the FAA’s evaluation process, we reference previouslygranted 333 exemption petitions with same or similar stated purposes as follows:

• Aerial mapping, survey, and inspection of buildings exemption no. 

11677, geoResource Technologies, Inc.; exemption no. 11728, Alon 

Sicherman
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 3

• Aerial data collection for 3D modeling of buildings: exemption no. 

11519, M2 Flight Solutions LLC

• Aerial inspection of job sites and equipment, including home construction; 

exemption no. 11660, Lloyd & Associates; exemption no. 11728, Alon 

Sicherman

• Aerial data collection for photogrammetry: exemption no. 11624,

Vertical Information Services Inc

DESCRIPTION OF PETITIONER

Since 1988, GSI has provided top land surveying and mapping services throughout 

California. Currently, over fifty percent of Guida Surveying’s contracts are full-service 

projects, with land surveying as the core business. Providing on-call services is the 

cornerstone that built Guida Surveying into the firm it is today, with California offices in 

Orange County, San Diego County, and the San Francisco Bay area.

NAME OF PETITIONER

Guida Surveying, Inc.

9241 Irvine Blvd.

Suite 100

Irvine, CA 92618

Telephone: (949) 777-2000

AGENT FOR GSI

For technical and administrative questions on this petition, please contact: 

Mr. Brian Dyer

Remote Pilot Systems

Telephone 484-680-7310 

Email: Brian.Dyer@RemotePilotSystems.com

Submitted separately as confidential documents under 14 CFR Section 11.35 (b) are:

A – Aibot X-6 User Manual

B – DJI Phantom 2 Vision + User Manual
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 4

C. – DJI Phantom 3 User Manual

D. – Yuneec Typhoon Q500 / Q500+ User Manual

E. – GSI Flight Operations Manual (GFOM)

These documents contain proprietary information that is not available to the public and 

are protected from release under the Freedom of Information Act 5 USC 552 et.seq.

Thank you for your time and attention.

Sincerely

Brian Dyer
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 5

DESCRIPTION OF UNMANNED AIRCRAFT SYSTEMS

GSI wishes to fly in its operations:

• The Aibot X6 

• The DJI Phantom 2 Vision +

• The DJI Phantom 3

• The Yuneec Typhoon Q500

as its survey aircraft.

The Aibot X6

The Aibot X6 is an electric multirotor aircraft configured as a hexacopter in a V-6 

designed for aerial survey and inspection. Aibotix in Germany has delivered more than 

200 aircraft since 2011. The flight control system used with the aircraft is designed and 

manufactured in Germany, has undergone continuous improvement and development, 

with all source code modules under company control.

Safety features include:

• Mitigation for loss of radio control link, through programmable emergency 

failsafe to controlled descent or, if GPS signal is sufficient, to return to point 

of takeoff.

• The pilot may override waypoint programming with manual stick control in 

case of emergency or route adjustment.

• Telemetry is displayed on the pilot’s handheld controller and maybe 

announced by voice.

• The X6 is optimized for aerial survey with safety features to reduce pilot 

workload, such as attitude stabilization, GPS satellite-assisted navigation, 

return to home and auto land.

The aircraft is less 1.2 meters, in diameter, is made of carbon-fiber reinforced polymer in 

a high visibility color, with protective blade guards surrounding the six rotors, and is 

designed for a maximum takeoff weight of of less than 15 pounds and a flight time of 

about 20 minutes with its dual-battery power. Maximum speed is about 55 MPH, but 
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 6

GSI treats this limitation as an emergency reserve, and plans no flying at greater than 25 

MPH. The aircraft carries no flammable liquid fuel.

Radio control and video transmission systems meet FCC requirements for operation in 

the unlicensed spectrum of the 2.4 and 5.8 GHz ranges. Manufacturer warnings about 

interference from devices operating at or near these frequencies or their harmonics are 

documented in the GSI Flight Operations Manual (GFOM), along with procedures to 

ensure radio safety with the UAS. 

The DJI Phantom Models 2 Vision + and 3

The DJI Phantom series are vertical takeoff and landing unmanned aircraft of quadcopter 

design. The Phantom 2 Vision + is manufactured by DJI out of Shenzhen, China. The 

Phantom 2 Vision + remote control operates at an operation frequency of 5.728 GHz

5.85 GHz meeting FCC requirements for operation in the unlicensed spectrum of 5.8 

GHz ranges. The DJI Phantom 2 Vision + dimensions are 12.5 x 8.1 x 17 inches 

Its takeoff weight is less than 2.75 lbs. Maximum speed is less than 30 knots. Safety 

features include a failsafe mode of operation for either loss of RC or GPS signal. Altitude 

can be limited by the onboard flight controller, with preprogramming of altitude. Flight

durations can be up to 25 minutes in length, but GFOM advises flights of less time to 

assure return of aircraft. Pilot in command is warned via telemetry on the flight controller 

with lighting cues before aircraft reaches a low battery state. Automatic termination of 

flight and landing is initiated by the operating system when the remainder of battery life is 

low. If the aircraft exceeds the control range of the remote control, ‘Return-to-Home’ 

will trigger, causing the Phantom 2 Vision+ to fly automatically back to its takeoff point 

and land safely.

The Yuneec Typhoon Q500/Q500 +

The Typhoon Q500 series are vertical takeoff and landing unmanned aircraft of 

quadcopter design. Manufactured by Yuneec International Co. Ltd., the Typhoon Q500 

has the world's first Smart Transmitter (the "ST-10 series Ground Station" with 10 

channels) combining a 2.4GHz radio control transmitter with a 5.8GHz digital video link.

It operates on a built-in Android touch screen. Safety features include Geo Fencing, 

Home Mode and Return Home. Geo Fencing prohibits the aircraft from exceeding a 

programmed permitted radius. When activated, Home Mode will automatically return the 

aircraft within a 10-foot radius of its starting point. Should the transmitter signal be lost
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 7

or visual line of sight with the aircraft impaired, upon signal, Return Home will 

automatically take control of the aircraft and return it to the operator/base station. 

Takeoff weight with manufacture provided camera and gimbal payload and battery is 3.75 

lbs.

The Typhoon Q500 dimensions are 16.5x16.5x8.3 inches with a diagonal of 22.2 inches 

without rotor blades attached. It can fly up to 25 minutes on its 5400mAh 3S 11.1V 

lithium polymer battery. Radio control and video transmission systems meet FCC 

requirements for operation in the unlicensed spectrum of 5.8 GHz ranges. The operating 

manual of the Typhoon Q500 warns against using the aircraft in areas where radio 

interference is possible, as does the GFOM.

EXTENT OF RELIEF SOUGHT AND WHY 

GSI asks for relief from regulations tabled below, which the authority of the FAA has 

previously granted in exemption certificates number 11062 along with six others 

described as “in commonality”, and in number 11109, which are for use of electric 

rotorcraft. The GFOM incorporates the conditions and limitations of these grants of 

exemption, and in some cases imposes stricter limits on its own operations. 
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 8

CFR CODE CITATIONS 

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

61.113 

(a) 

Private pilot 

privileges and 

limitations: pilot in 

command

Holder of private pilot 

certificate may not act as 

pilot in command (PIC) 

for compensation or hire. 

Flying for compensation 

on survey missions is 

central to purpose of 

exemption request. 

Characteristics of aircraft, VLOS, 

under 400 ft. AGL, trained visual 

observer in radio communication 

with pilot; remote site, 

construction industry safety 

protocols enhanced by GSI flight 

safety plan; PIC with airman’s 

certification, appropriate medical 

and vision qualification, currency 

in the aircraft listed on the 

certificate, pilot training, testing, 

proficiency with similar and same 

model UA; and 

inspection/maintenance are 

defined in the GFOM and will 

ensure equivalent levels of safety.

61.113 

(b) 

Private pilot 

privileges and 

limitations: Pilot in 

command

Holder of private pilot 

certificate may act as PIC 

for compensation or hire if 

flight is incidental to 

business or employment 

and does not carry 

passengers for 

compensation or hire. 

Flying for compensation 

on survey missions is 

central to purpose of 

exemption request, not 

incidental to business or 

employment. 

There is no passenger or pilot on 

board the UA, thus safety issues 

are different from a manned flight. 

GSI’s aircraft have programmable 

automated safety features and 

emergency responses, have preflight checks for safety beyond 

commercial manned aircraft, can 

be geographically restricted by 

operator with programmable 

control points, have 

communications with the PIC 

regarding fuel loss and other flight 

hazards. PIC will have ground 

school training certificate and 

additional 25 hours logged flight 

time and 25 hours classroom and 

field instruction as stated in 

GFOM.
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 9

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.119 

(c) 

Minimum safe 

altitudes over other 

than congested 

area 

Operating closer than 500 

feet to a person, vehicle, or 

structure may be necessary 

for survey and equipment 

inspection. 

People will not be allowed over, 

under or within 500 feet laterally 

of the aircraft in flight. Some 

flights may require the 

participation or guidance of 

industry personnel, positioned as 

close as 200 feet. GSI will brief 

them on safety and obtain 

necessary consent. Industry site 

safety rules will be followed. 

91.121 Altimeter settings Procedures to set and 

confirm altitude do not 

provide for operation of 

remote telemetry to UAS

pilot. 

An onboard air pressure sensor 

and software resolve height 

differences as small as one 

centimeter. Altitude is controlled 

by measuring air pressure and the 

z-axis accelerometer/GPS values. 

The starting point is a relative 

height measurement calculated by 

the flight controller. Altitude 

above ground is displayed on the 

pilot's handheld controller by 

telemetry, and alarms can signal 

conditions of interest. 400 feet 

AGL is the maximum permissible 

in the GFOM, which describes 

altimeter procedures. 
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 10

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.151 

(b) 

Fuel requirements 

for flight in VFR 

conditions

Rotorcraft under VFR 

must carry enough fuel to 

reach first landing point 

and then another 20 

minutes. The multirotor 

aircraft specified in this 

petition is designed to fly 

missions of 25 minute 

durations. 

On aircraft specified, battery 

voltage under load is displayed on 

the pilot's handheld controller 

during flight. Battery chemistry 

does not support adequate current 

discharge below about 3 v per cell. 

Circuitry in the onboard flight 

controller measures voltage and 

will start a failsafe procedure to 

land before summed minimums 

are reached. In the event that one 

or more cells fail, these minimums 

may be reached sooner than 

expected, due to rapid current 

drain against a smaller number of 

functioning cells. GSI pilots are 

trained to monitor voltage and 

recognize abnormal discharge in 

flight and to land sooner than 

forced. If 20 minutes of flight time 

or 25% of reserve voltage under 

load is reached, pilot must 

commence landing.

91.405 

(a) 

Maintenance 

required

Required inspections and 

discrepancies repaired 

between the required 

inspections pertain to 

certificated manned 

aircraft and procedures 

conducted by licensed 

maintenance personnel. In 

the absence of certification 

requirements for UAS and 

UAS maintenance 

personnel, reasonable 

alternatives must be 

developed to maintain 

equivalent levels of safety. 

GSI will document maintenance, 

overhaul, replacement and 

inspection requirements in the 

absence of manufacturer's 

requirements; will document and 

maintain maintenance records and 

technician qualification criteria in 

the GFOM. 
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 11

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.405 

(b) 

Maintenance 

records

Qualifications for 

maintenance personnel for 

UAS were not 

contemplated by these 

regulations, and a 

reasonable alternative must 

be developed to maintain

equivalent levels of safety. 

Qualifications, competence and 

testing for maintenance personnel 

are defined in the GFOM. 

91.407 

(a) (1) 

Operation after 

maintenance, 

preventive 

maintenance, 

rebuilding, or 

alteration

There is no authorization 

procedure for a person 

who can approve a return 

to service of an UAS, and 

a reasonable alternative 

must be developed to 

maintain equivalent levels 

of safety. 

Procedures for the PIC to test 

then approve a return to service 

after maintenance are defined in 

the GFOM. 

91.409 

(a) (1) 

Inspections Annuals conducted by a 

qualified inspector require 

authorization criteria for 

that inspector, not yet 

defined for UAS. A 

reasonable alternative must 

be developed to maintain 

equivalent levels of safety. 

Schedules for inspection and 

responsibilities of the PIC and 

qualified technician are described 

in the GFOM. 

91.409 

(a) (2) 

Inspections Issuance of airworthiness 

certificates for UAS under 

55 pounds operated VLOS 

is not contemplated by 

these regulations 

Airworthiness is the responsibility 

of the PIC and the technician as 

defined in the GFOM.
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 12

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.417 

(a) 

Maintenance 

records

Regulations do not 

contemplate requirements 

or approval processes for 

maintenance and 

inspection of 

uncertificated UAS, 

however a reasonable 

alternative must be 

developed to maintain 

equivalent levels of safety. 

The operator will maintain records 

according to the procedures 

specified in the GFOM. 

91.417 

(b) 

Maintenance 

records

Retaining and transferring 

records of maintenance 

and defects according to 

standards prescribed for 

authorized maintenance 

and inspection is not 

contemplated in the 

regulations for UAS. A 

reasonable alternative is 

necessary to maintain 

equivalent levels of safety. 

Records and documentation will 

be kept for all maintenance 

performed, defects, and for all 

components specified in the 

GFOM.

PILOT IN COMMAND AND CREW 

The pilot in command (PIC) must hold an airman’s certification recognized by the FAA 

such as an airline transport, commercial, private, recreational, sport pilot, or glider pilot 

(powered or non-powered) and must comply with the training and testing specified in the 

GFOM. The PIC must hold a current FAA airman medical certificate as required by the 

class of airman certification. In the case of the sport pilot certification, the PIC must 

possess a valid U.S. driver’s license issued by a State, the District of Colombia, Puerto 

Rico, a territory, a possession, or the Federal government. The PIC must comply with the 

training and testing specified in the operator’s manual. The PIC must remain in radio 

communication with a visual observer who complies with the training and testing 

specified in the operator’s manual. The pilot must be able to acquire the aircraft with his 
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 13

own vision according to eye standards for a third class airman medical certificate or valid 

driver’s license according to the issuing State. The PIC must operate within visual line of 

sight only, and be able to see the attitude and orientation of the aircraft by them self. If 

GPS or magnetometer is compromised, certain safety features may not operate, and the 

pilot must understand by their training and experience how to recover control. 

OPERATION OF THE UNMANNED AIRCRAFT 

The aircraft will be under the operational control of GSI. 

1. The aircraft used for survey operations by GSI will be the Aibot X6, the DJI 

Phantom 2 and 3 series, and the Yuneec Typhoon Q500 series as described in 

the GFOM, unless the FAA approves a further amendment to this petition. 

2. The PIC will hold a transport, commercial, private, recreational, sport pilot or 

glider (powered or non-powered) airman certificate, and must meet the 

medical and vision standards, as well as the flight review requirements, 

appropriate to that certificate, according to 14 CFR § 61.56. 

3. GSI pilots will operate at less than 400 feet AGL, in daylight hours only, and 

within visual line of sight of the PIC, five (5) nautical miles or more away 

from a airport reference point as denoted in the current FAA Airport / 

Facility Directory (AFD) or as denoted in the current FAA / facility directory 

published charts, and use a GFOM-qualified visual observer in radio 

communication with the PIC.

4. Manufacturer’s limitations of the aircraft will not be exceeded, and GSI’s 

operations will adhere to power reserves and lower operational limits 

described in the GFOM. 

5. Preflight inspection by the PIC, and inspection and maintenance procedures 

will be followed according to the GFOM, and will be properly documented 

and signed for by an authorized technician who has completed training 

specified in the GFOM. 

6. Test flights by the PIC in connection with maintenance requirements will be 

documented. 
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 14

7. Manufacturer systems and safety bulletins will be followed, and flight critical 

components will be monitored and replaced when specified in the GFOM. 

8. Discrepancies discovered between inspections will be documented by GSI

maintenance personnel. 

9. If visibility is less than three (3) statute miles from the PIC, the aircraft may 

not be operated less than 500 feet below a cloud, or less than 2000 feet 

horizontally from a cloud

10. The PIC must follow emergency procedures as described in the GFOM in 

event of lost link, degraded navigation signals, or appearance of unauthorized 

persons within the secure flight perimeter.

11. A commercial Certificate of Authorization (COA), if required by the FAA, 

will be obtained according to FAA’s designated procedure before any 

operations requiring such a COA are conducted, and Notices to Airmen will 

be filed in accordance with FAA requirements. 

12. An N-Number will be obtained for all aircraft operated.

13. RF spectrum will be used in compliance with FCC requirements.

14. Documents required by 14 CFR 91.9 and 91.203 will be available to the PIC 

at the point of flight and control, and will be produced upon request by any 

authority.

15. The aircraft will remain clear of and yield right of way to all manned aviation 

operations and activities at all times. 

16. The PIC will operate the aircraft from a stationary ground position and not 

from any moving device or vehicle. 

17. No operation over congested or densely populated areas is allowed, unless 

PIC follows procedures to obtain FAA permission if required. 

18. The safety of people and property is paramount, and no operations may be 

conducted within 500 feet of non-participants or their property unless 

conducted according to safety procedures in the GFOM, which are approved 

by the FAA. 
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 15

19. All operations will be conducted over controlled access property for which 

permission has been obtained prior to flight, and for which safety briefings 

have been completed according to the GFOM. 

20. All incidents, accidents, and transgressions of allowed flight boundaries will

be reported as required by FAA and NTSB. 

BENEFIT TO THE PUBLIC 

Approval of exemptions allowing GSI commercial operations of UASs will enhance 

safety by reducing risk. By removing the use of conventional jet fueled aircraft weighing 

in tons for lightweight, battery operated UAs in restricted areas for aerial inspection, geomapping and image and film capture, is more environmentally sound and safe. The use of 

battery powered UAs will provide a smaller environmental footprint, increase safety be 

decreasing manpower and separate the aircraft operators form the craft. The use of the 

specified UAs further protects the public by being used in restricted environments and 

reducing impact hazards.

REASONS WHY THE EXEMPTION WOULD NOT ADVERSELY AFFECT 

SAFETY 

The survey aircraft will be operated in accordance with safety protocols defined in the 

GFOM, for which we request approval by the FAA according to its authority granted by 

Congress in Section 333 of the FAA Modernization and Reform Act of 2012. 

The survey aircraft carries no person, cargo, or flammable liquid fuel. Its size and weight 

are a small fraction of any manned aircraft, and its safety systems reflect best design 

practices in the UAS industry. 

In addition, GSI will keep the approved GFOM at its ground control station. The PIC 

will have immediate access to it. Previous exemptions granted by the FAA concerning 

Section 91.9(b) establish that safety is not adversely affected when the approved Aircraft 

Flight Manual is kept at the ground control station of a UAS, where it can be immediately 

accessed by the PIC.
Guida"Surveying,"Inc."Section"333"Petition"for"Exemption" 16

When properly operated by trained pilots, a well-designed UAS can stay clear of people 

and property on the ground and in the air. Procedures, airmanship skills, training and 

testing requirements for UAS personnel in the GFOM will let the operator achieve safety 

levels in the NAS and on the ground that are equivalent to or greater than that in manned 

aviation 

SUMMARY FOR PUBLICATION 

The following summary may be published in the Federal Register: 

GSI requests an exemption from: 

14 CFR Parts 61.113 (a) and (b) 

14 CFR Parts 91.119 (c), 91.121, 91.151 (b), 91.405 (a) and (b), 91.407 (a) (1), 91.409 (a) 

(1), 91.409 (a) (2), 91.417 (a) 

in order to operate a small unmanned aircraft system (UAS) for purposes of aerial 

inspections and monitoring, aerial geo-mapping and aerial imaging and filming and aerial 

data collection. The PIC will be appropriately qualified with a current FAA approved 

pilot certificate for UAS operation and specialized training.

Aerial topographical survey and mapping, aerial data collection for 3D modeling of 

buildings, aerial inspection of job sites and equipment, including home construction, and 

aerial data collection for photogrammetry are conventionally done by manned aircraft 

operations which use jet fuel and weigh upwards of 5,000 lbs. These operations must fly 

the aircraft to and from the operation’s location. The use of the Aibot X6, the DJI 

Phantom 2 Vision + and / or the Yuneec Typhoon Q500, all of which weigh less than 15 

lbs. and are equipped with flight control and safety features that prevent flyaways, 

minimizes the risk from that of a manned aircraft to people and property allowed within 

and outside the zone of operations. 

Flight operations outside the secure areas are not allowed. There are no impacts to 

privacy.