Jennifer E. Trock Jennifer.trock@pillsburylaw.com

4818-7695-9274.v1 November 20, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Pursuant to Se ction 333 of the FAA Modernization and Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

On behalf of the River Islands Development, LLC (“River Islands”), pursuant to Section 333 of

the FAA Modernization and Reform Act of 2012 (the “Reform Act”) (“Section 333”), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, we request an exemption from the Federal Aviation Administration regulations listed below and discussed in Appendix A to allow River Islands to conduct commercial opera tions with the DJI Phantom 3 Professional (“Phantom”) 1 small unmanned aircraft system (“s UAS”) for aerial photography in connection

with residential and commercial real-estate c onstruction and developments of River Islands. 2

Conducting the requested sUAS operations — r eal-estate construction inspections, marketing material production, and research and developmen t — can be done safely in the National Airspace System (“NAS”) and is in the pub lic interest for several reasons, which are detailed further herein and include: (1) reducing the risks associated with performing real-estate construction inspections and marketing photography with pe rsons on elevated surfaces (i.e., rooftops) or manned aircraft, (2) offering homebuyers timely updates on cons truction and unique perspectives of real-estate developments, and (3) improving the efficiency of River Islands’ business operations, including a more environmentally friendly and cost ef fective alternative to manned aircraft.

1 The DJI Phantom 3 already has been approved for commercial use in similar contexts. See e.g., Exemption Nos.

13506, 13507, 13509, and 13517.

2 The FAA has granted similar exemptions. See e.g., Exemption Nos. 13509, 13513, and 13518. Pillsbury Winthrop Shaw Pittman LLP 1200 Seventeenth Street, NW | Washington, DC 20036 | tel 202.663.8000 | fax 202.663.8007November 20, 2015 Page 2

4818-7695-9274.v1 Applicant Information:

The name of the applicant: Ri ver Islands Development, LLC.

The primary contact for this application, with a copy to me at the address above and River Islands at the address below, is:

Susan Dell’Osso River Islands Development, LLC

73 West Stewart Road Lathrop, CA 95330

Exemptions Requested

River Islands requests exemptions from the following regulations:

14 C.F.R. 61.23(a) and (c); 14 C.F.R. 61.101(e)(4) and (5); 14 C.F.R. 61.113(a); 14 C.F.R. 61.315(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a)(1); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b).

Airworthiness of the sUAS

The Phantom is a quadcopter with a gimbal-mounted camera manufac tured by DJI, a market leader

in sUAS. The Phantom has been authorized to conduct commercial operations, including realestate construction inspections and marketing pho tography, under several Section 333 exemptions. 3

Technical specifications for the Phantom are summarized in the table below.

3 See e.g., Exemption Nos. 13506, 13509, 13518, and 13438.November 20, 2015 Page 3

4818-7695-9274.v1 DJI Phantom 3 Diagonal Size (including propellers) 590 mm (23.23 inches)

Total Weight 1280 g (2.82 lbs) Max Ascent Speed 5 m/s (9.72 knots) Max Descent Speed 3 m/s (5.83 knots) Max Flight Speed 16 m/s (31.10 knots) Controller Range 5 km (3.1 miles) Hover Accuracy:

Vertical / Horizontal 0.5 m / 1.5 m

Controller Frequency (Main Channel) 2.400 GHz – 2.483 GHz

Communications (Second Channel) 2.4 GHz ISM

DJI provides, and attached in Appendix C, a suite of user manuals and guidelines for the Phantom (“Phantom Documents”). 4 PICs will be required to comply with all maintenance and inspection procedures outlined in the Phantom Documents.

Operating Conditions

River Islands requests an exemption subject to the conditions listed in Appendix B, which are similar to the operating conditions required for th e FAA’s previous grants of exemptions under

Section 333. 5

In accordance with the conditions approved in pr evious exemption grants, River Islands is requesting authority to operate the Phantom within visual line of sight and below 400 feet AGL, except as provided by FAA Air Traffic Control via COA. These operating conditions, along with those listed in Appendix B, and the sUAS safe ty features listed below provide an equivalent level of safety.

4 The Phantom Documents are available at http://www.dji.com/product/phantom-3/download

. 5 If, and when, the FAA finds such conditions unnecessary for operations conducted pursuant to Section 333

exemptions, River Islands reserves the right to amend its operating conditions and request exemptions from the relevant regulations to operate without such conditions.November 20, 2015 Page 4

4818-7695-9274.v1 The following safety features are incorporated into the Phantom to ensure public safety and safe integration into the NAS:

• Stability Control with Auto-Takeoff and Auto -Land: The automated flight-control system can take off and land automatically, and the sy stem autocorrects the aircraft’s position to adjust for environment disturbances such as wind.

• Intelligent Flight Mode and Inertial Meas urement Unit (IMU): The Intelligent Flight Mode allows the operator to set different mo des to ensure a contro lled flight paths, including Course Lock (locking the current nose direction as the aircraft’s forward direction), Home Lock (returning the aircraft to its recorded home point when pulling the pitch stick backward), Waypoints (following a r ecorded flight path), Point of Interest (orbiting around a pre-de termined subject), and Follow Me (a virtual tether). The built-in

inertial sensor and barometric altimeter meas ures orientation and altitude, respectively,

and communicates this data back to the controller.

• Live Map with Failsafe & Battery Warnings: Th e controller displays a live map to show the aircraft’s recent flight path, headi ng, bearing and distance from “home” (a predetermined start location w ithin the boundaries of the pr ivately owned property) for complete situation awareness. It also illustrate s battery status and low-battery warnings to

alert the PIC and ensure that the aircraft does not power down unexpectedly during use.

• LED Flight Indicators: LED lights are mounted to the four rotor arms to visually indicate aircraft orientation (attitude) and status of the flight cont rol system, alerting the PIC of possible issues.

• Maximum Height and Radius Limits: Befo re beginning flight, the PIC may set a maximum altitude and distance that prevent the sUAS from exceeding altitude limits and

distance from “home.”

• Flight-limited Safety Zones: The sUAS flight software comes loaded with a list of restricted areas, including no-fly zones for sensitive national security areas such as the White House. Each restricted area is comp rised of a no-fly zone in which the sUAS cannot be operated and a warn ing zone surrounding the no-fly zone in which the PIC is alerted to the sUAS’ proximity to a restrict ed area. Additional details regarding the safety zones can be found in the Phantom User Manual, attached as Appendix C.

• Loss of link. The built-in GPS system that aids in stability control w ill automatically return

the sUAS to “home” if communication betwee n the controller and aircraft is lost. The system has three Return-to-Ho me (“RTH”) functions – Smart RTH, Low Battery RTH, and Failsafe RTH, bringing the sUAS back to the last recorded ho me point. Smart RTH isNovember 20, 2015 Page 5

4818-7695-9274.v1 commanded by the operator. The Low Battery RTH is triggered when th e battery system is depleted to a point that may a ffect the safe return of the aircraft. The Failsafe RTH is triggered when the remote signal is lost fo r more than 3 seconds. Additional details regarding the RTH functions can be found in th e Phantom manual, attach ed as Appendix C.

• Loss of GPS. If a loss of GPS occurs, the PI C maintains positive control of the aircraft and can either land the sUAS, hover in pl ace until GPS is reacquired, or continue the flight. Using the sensors built into the Phantom’s Vision Positioning System, automatically activated where GPS is unava ilable, the Phantom 3 can hover precisely. Additionally, the sUAS has the ability to ab ort a flight in the event of unpredicted obstacles or emergencies.

Operator Requirements

As a condition to the grant of the exemptions, Ri ver Islands will require that the PIC hold either an airline transport, commercial, private, recreati onal, or sport pilot certificate. The PIC will also

hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territor y, a possession, or the Federal government. The PIC will meet the flight review requirements speci fied in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

At the conclusion of PIC training, the PIC must demonstrate the ability to safely operate the

sUAS in a manner consistent with how th e sUAS will be operated under the requested exemption, including evasive and emergency mane uvers and maintaining appropriate distances from persons, vessels, vehicles, and structures. Training flights will be logged for each PIC in training in a manner consistent with 14 CFR § 61.51(b).

River Islands respectfully submits that the opera tor qualifications take into account the operating

conditions and characteristics of the sUAS.

Public Interest

River Islands respectfully submits that using sUAS to inspect construction sites and photograph real-estate in lieu of using construction inspectors on rooftops or other elevated positions or manned aircraft offers a net safety benefit and will achieve an enhanced level of safety, as mandated under Section 333(c) of the Reform Act. Approval of this appli cation also will benefit the public interest by providing faster and more cost-efficient real-estate construction inspections and marketing.

Inspection and photography operations over resi dential real-estate developments with conventional manned aircraft involve very heavy aircraft, transiting to the operational location,November 20, 2015 Page 6

4818-7695-9274.v1 carrying significant quantities of combustible fuels, and a multi-person crew in piloting and observation roles. By contrast , the sUAS weighs less than three pounds, uses a battery for power, is carried to and from the area of activ ity, removes the need fo r airborne pilots and observers, and poses less risk to people and infr astructure on the ground, as well as other aircraft.

Additionally, no national security issue is raised by the grant of the requ ested exemption due to the sUAS’ small size and load-carrying capacity, as well as its operational limitations and lack of

flammable fuel. All PICs will have been scr eened by the Department of Homeland Security.

The grant of the requested exemption is in the public interest based on the clear direction in Section 333 and 49 U.S.C. § 44701(f), 6 the equivalent and enhanced level of safety of the proposed operations, and the significan t public benefit, and cost saving s to be realized as a result

of the use of sUAS for aerial in spections. Accordingly, the applic ant respectfully requests that the FAA grant the requested exemption without delay.

Privacy Concerns

The proposed operations will take place only over private or controlled-access property and only after obtaining written or verbal consent from the individual who owns or controls the property or is the property owner’s authorized representa tive before each flight. No privacy issues are raised by this application.

Federal Register Summary

Pursuant to 14 C.F.R. § 11.81(f), the following summary is provided for publication in the Federal Register, should the FAA dete rmine that publication is needed:

Docket No.: No. FAA-2015-____

Petitioner: River Isla nds Development, LLC Section of 14 CFR: § 61.23(a) and (c), § 61.101(e)(4) and (5), § 61.113(a), § 61.315(a), § 91.7(a), § 91.119(c), § 91.121, § 91.151(a), § 91.405(a), § 91.407(a)(1), § 91.409(a)(1) and (2), and §91.417(a) and (b). Description of Relief Sought: Ri ver Islands seeks an exemption to conduct residential and commercial real-estate inspections and ma rketing operations using a small unmanned aircraft (55 pounds or less).

6 Pursuant to 49 U.S.C. § 44701(f), the “Administrator ma y grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702- 44716 of this title if the Administrator finds the exemption is in the public interest.”November 20, 2015 Page 7

4818-7695-9274.v1 Sincerely,

Jennifer E. Trock

cc: Lisa Freilicher, River Islands Development, LLCNovember 20, 2015 Page 8

4818-7695-9274.v1 APPENDIX A

EXEMPTION REQUEST AND EQUI VALENT LEVEL OF SAFETY

SHOWINGS UNDER APPLICABLE RU LES SUBJECT TO EXEMPTION

River Islands requests an exemption from the following regulations as well as any additional regulations that the FAA deems necessary to th e operation of the DJI Phantom 3 Professional

sUAS:

14 C.F.R. § 61.23 (a) & (c)

Section 61.23(a) requires a person exercising the priv ileges of a transport p ilot certificat e to hold a first-class medical certificate, the privileges of a commercial pilot certificate to hold a secondclass medical certificate, and the privileges of a private or recreational pilot certificate to hold a

third-class medical certificate. Section 61.23(c) requires a person to hold a medical certificate or U.S. driver’s license when exercising the privileg es of a sport pilot certificate in a light-sport

aircraft other than a glider or balloon.

The operations proposed herein will provide an equivalent level of safety by complying with the conditions and limitations of this exemption. The FAA has found that these conditions and limitations provide an equivalent level of safety in numerous previous exemptions, including but not limited to Exemptions 13506, 13507, 13509, and 13517.

14 C.F.R. § 61.101 (e)(4) & (5): Re creation Pilot Privilege a nd Limitations; 14 C.F.R. § 61.315(a): What are the privileges and limits of my sport pilot certificate

Section 61.101(e)(4) prohibits a recreational pilot from acting as pilot in command of an aircraft for compensation or hire. Section 61.101(e)(5) prohi bits a recreational pilo t from acting as pilot

in command of an aircraft in furtherance of a business. Section 61.315(a) authorizes persons holding a sport pilot certificate to act as pilot in command of a light-sport aircraft.

As with previous Section 333 exemptions, 7 an equivalent level of safety is established because (1) the aeronautical knowledge requirements that would be applicable to UAS operations for a recreational pilot and sport pilot certificate were s ubstantially similar as those for a private pilot certificate; (2) holders of recreati onal and sport pilot certificates are subject to security screening

7 See, e.g., Exemption Nos. 13506, 13507, 13509, and 13517.November 20, 2015 Page 9

4818-7695-9274.v1 by the Department of Homeland Security; and (3) risk was mitigated through conditions and limitations regarding PIC training.

14 C.F.R. §§ 61.113(a): Private Pilot Privileges

Sections 61.113(a) limits private pilots to non -commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the UAS are remotely controlled with no passengers or property of others on board. The ar ea of operation is contro lled and restricted, and all flights are planned and coordinated in advan ce as set forth in the Phantom Documents. In conjunction with the PIC’s requi red training, the level of safe ty provided by the procedures

included in the Phantom Documents meets or exceed s that level of safety provided by a single individual holding a commercial pilot certificate operating a conve ntional aircraft. The proposed operations will achieve at least an equivalent level of safety.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Section 91.7(a) prohibits an indivi dual from operating a civil aircra ft unless it is in an airworthy

condition. No FAA standard exists for determ ining an aircraft’s airworthiness when an

airworthiness certificate is not issued. As th e FAA has done with previous exemption grants, 8
airworthiness will be ensured and an equivalent level of safety will be achieved by use of the procedures in the Phantom Docu ments prior to every flight.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for oper ation of civil aircraft . Specifically, Section 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sp arsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehi cle, or structure. Because the aerial photography and videography wo rk must be accomplished at altitudes less than 500 feet AGL an exemption is required.

The equivalent level of safety will be ach ieved given the sUAS’ size, weight, speed, and proposed operating conditions. sUAS operations will be conducted over private or controlledaccess property with consent granted by th e property owner/contro ller or authorized representative prior to each operation.

8 Exemption Nos. 11156, 11158, 11159.November 20, 2015 Page 10

4818-7695-9274.v1 14 C.F.R. § 91.121: Altimeter Setting

Section 91.121 requires each person operating an ai rcraft to maintain cruising altitude by reference to an altimeter that is set “to the elevation of the departure airport or an appropriate altimeter setting available before departure.” The Phantom’s Inertial Measurement Units has a barometric altimeters, but it cannot be set to th e elevation of the departure location. Rather, upon initialization, the sUAS calibrate their positions without user input and transmit a single altitude measurement to the ground station. Thus, an ex emption is required. An equivalent level of safety will be achieved by th e operator, pursuant to the Ph antom Documents’ procedures, confirming the altitude of the launch site show n on the altitude indicator before flight.

14 C.F.R. § 91.151(a)(1): Fuel Requiremen ts for Flight in VFR Conditions

This regulation prohibits an individual from beginning “a flight in an airplane 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 cruisi ng speed – (1) During the day, to fly after that for at least 30 minutes.”

The Phantom’s batteries provide approximately 23 minutes of powered flight. Without an exemption from 14 C.F.R. § 91.151, the sUAS f lights would not be allowed. Given the limitations on its proposed operations, allowing the sUAS to operate without the required reserve fuel is reasonable and is consistent with prior exemptions. 9 An equivalent level of safety will be achieved because operating the sUAS without 30 minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was meant to prevent given th e size and speed at which the sUAS operate. In the unlikely event that a sUAS should run out of battery power, it would simply land. Given the sUAS’s weight and cons truction material, the risks are less than contemplated by the current regulation. River Islands will require the UAS to return home and land when the battery has 5 remaining minutes of flight.

14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) & (b): Maintenance Inspections

Section 91.405(a) requires that an ai rcraft operator or owner “shall ha ve 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 discrepancie s repaired as prescribed in part 43 of this

9 Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)); see also

Exemptions 2689F, 5745, 10673 and 10808.November 20, 2015 Page 11

4818-7695-9274.v1 chapter.” Section 91.407 simila rly makes reference to requirements in Part 43. Section 91.409(a)(2) requires an annual inspection for the i ssuance of an air worthiness certificate. Section 91.417(a) requires the owner or operator to keep records showi ng certain maintenance work that has been accomplished by certificated m echanics, under Part 43, or licensed pilots and records of approval of the aircra ft for return to service.

An equivalent level of safety will be achie ved by complying with the Phantom Documents’ maintenance and inspection procedures because the sUAS will carry no external payload, will operate only in restricted predeter mined areas. In addition, the PIC will ensure that the sUAS is in working order prior to initiating flight, perf orm required maintenance, and keep a log of any maintenance that is performed. Moreover, the PI C is the person most familiar with the aircraft

and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety.November 20, 2015 Page 12

4818-7695-9274.v1 APPENDIX B

RIVER ISLANDS OPERATING LIMITATIONS

1) Operations authorized by this grant of exemption are limited to the DJI Phantom 3 when weighing less than 55 pounds includ ing payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

2) Operations for the purpose of closed-set motion picture and television filming are not permitted.

3) The Phantom shall not be flown at a speed exceeding 87 knots (100 miles per hour). River Islands may either use groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restrict ion. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4) The sUAS will not be operated at an altit ude more than 400 feet above ground level (“AGL”). Altitudes reported to ATC shall be in feet AGL.

5) The sUAS 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 lenses, as specifie d on the PIC’s FAA-issued airman medical

certificate or U.S. driver’s license.

6) All operations must use a visu al observer (“VO”). The UA must be operated within

VLOS of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always ma intains VLOS capability. The VO and PIC

must be able to communicate verbally at all times; electr onic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation fo r the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7) This exemption and all documents need ed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter re ferred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists be tween the conditions and limitations in this exemption and the proced ures outlined in the operating documents,

the conditions and limitations herein ta ke precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revi se its operating docum ents. It is theNovember 20, 2015 Page 13

4818-7695-9274.v1 operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement offi cial upon request. The operator must also present updated and revise d documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) may be contacted if questi ons arise regarding updates or revisions to the operating documents.

8) River Islands is responsible fo r maintaining and inspecting th e UAS to ensure that it is in a condition for safe operation.

9) 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 prio r to conducting further opera tions under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

10) Prior to each flight, the PIC must conduct a pre-flight inspecti on and determine the UAS is in a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable co mponents, items, or equipment. If the inspection reveals a condition th at affects the safe operation 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.

11) River Islands must follow DJI’s aircra ft/component, maintenance, overhaul, replacement, inspection, a nd life limit requirements.

12) The sUAS operated under this exemption must comply with all manufacturer Safety

Bulletins.

13) The PIC must hold either an airline transpor t, commercial, private, recreational, or sport pilot certificate. The PIC must al so hold a current FAA airman medical

certificate or a valid U.S. driver’s license is sued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements speci fied in 14 CFR § 61.56 in an aircraft in

which the PIC is rated on his or her pilot ce rtificate.

14) River Islands shall not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a ma nner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers andNovember 20, 2015 Page 14

4818-7695-9274.v1 maintaining appropriate distances from pers ons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner c onsistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and e xperience-building) and determ ining the PIC’s ability to safely operate the UAS in a manner consis tent with how the UAS will be operated under this exemption are permitted under th e terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and expe rience-building flights, a ll persons not essential for flight operations are consid ered nonparticipants, and th e PIC must operate the UA with appropriate distance from nonpartici pants in accordance with 14 CFR § 91.119.

15) Operations may not be conduc ted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (“VMC”). Flights under special visual flight rules (“SVFR”) are not authorized.

16) The UA may not operate within 5 nautical m iles of an airport reference point (“ARP”) as denoted in the current FAA Airport/Facil ity Directory (“AFD”) or for airports not denoted with an ARP, the center of the ai rport symbol as denoted on the current FAApublished aeronautical chart, unless a lett er of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the ai rport management must be made available to the Administrator or any law en forcement official upon request.

17) The sUAS 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.

18) If the sUAS loses communications or loses it s GPS signal, the sUAS must return to a pre-determined location within the pr ivate or controlled-access property.

19) The PIC must abort the flight in the even t of unpredicted obstacles or emergencies.

20) The PIC is prohibited from beginning a fli ght unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

21) All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted unde r the terms of the attached COA.

22) All aircraft operated in accordance with the requested exemption must be identified by serial number, registered in accordance with 14 C.F.R. Part 47, and have identificationNovember 20, 2015 Page 15

4818-7695-9274.v1 (N-Number) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings shall be as large as practicable.

23) The documents required under 14 C.F.R. §§ 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the sU AS any time the aircraft is operating.

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

24) The sUAS must remain clear and yield the ri ght of way to all other manned operations

and activities at all times.

25) The sUAS may not be operated from any moving device or vehicle.

26) Flight operations must be conducted at least 500 feet from all nonpart icipating persons, vessels, vehicles, struct ures, and public access roads unless:

a. Barriers or structures are present th at sufficiently protect nonparticipating persons from the sUAS 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 s UAS, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and/or

b. The owner/controller of any vessels, ve hicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees, or es sential persons are not considered nonparticipating persons.

27) All operations must be conducted over priv ate or controlled-ac cess property with permission from the property owner/contro ller or authorized representative. Permission from the property owner/controlle r or authorized representative will be obtained for each flight conducted.

28) Any incident, accident, or fli ght operation that transgress es the lateral or vertical boundaries of the operati onal area as defined by the app licable COA shall be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.4818-7695-9274.v1 APPENDIX C

DJI Phantom Documents