### Rugged Sk **y Media Section 333** 

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Re form Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Rugged Sky Media , S Corp, (further referred to as “Rugged Sky Media”) , an operator of Small Unmanned Aircraft S ys t ems (sUASs ) for aerial image acquisition including but not limited to, th e following industries: motion picture and television, real estate, short range inspection, mapping & surveying , agriculture, and search & rescue, hereby applies for an exemption from the Federal Aviation Regulations (“FARs”) to allow commercial operation of its UASs. Rugged Sky Media ’s requested exempt ion would permit the operation of sUAS s under controlled and secure co nditions that are : (i) limited, (ii) predetermined, (iii) subject to controlled
ac cess, and (iv) provide greater safety in connection with aircraft ope rations. As established by the exemptions already granted b y the FAA, approval of Rugged Sky Media ’s exemption would enhance safety and fulfil l the Secretary of Transportation’s (the FAA Administrator’s)
res ponsibilities to “...establish requirements for the safe operation of such ai rcraft s ys tems in the national airspace s ys tem , ” Section 333(c) of the FAA’s Modernization and Reform Act of 2012 (FMRA)

.The name s and address of the applicant s is :

Rugged Sky Media , S C orp
. Phone: 571

- 465

- 0435 Email: ruggedskym edia@gmail.com Address: 907 Stonefield SQ NE Leesburg VA, 20176In seeking this exemption, Rugged Sky Media proposes to commerciall y operate the DJ I

Phantom Series, The DJ I In spire 1, and YUNEEC Q

- 500 UASs ( specifications for both s UASs can be found in the appendices section of this 333 request) for the special purpose of conducting aerial video and photograph y over certain areas of United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption are limited to the DJ I Phantom Series, the DJ I Inspire 1, and YUNEEC Q

- 500 Unmanned Aircraft S ys tems when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption. 2. Operations for the p urpose of closed

- set motion picture and television filming are not permitted. 3. The UA may

not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may

use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA must be operated at an altitude of no more than 400 feet above ground le vel (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line of sight (VLOS) of the PI C at all times. This requires the PIC to be able to use human vision unaided b y an y device other than corrective lenses, as specified on the PI C’s FAA

- issued airman medical certificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PI C and VO at all times. The VO may be used to satisf y the VLOS requirement as long as the PI C alway s maintains VLOS capability

. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PI C must be designated before the f light and cannot transfer his or her designation for the duration of the flight. The PI C must ensure that the VO can perform the duties required of the VO. 7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the administrator upon request. I f a d iscrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedure s as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track suchrevisions and present updated and revised documents to the Administrator or an y law

enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. I f 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 questions arise regarding updates or revisions to the operating documents. 8. 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 prior to conducting further operations under this exemption. Functional test flights may onl y be conducted b y a PI C 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. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PI C must conduct a pre

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

- flight inspection must account f or all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft 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. The operator must follow the UAS manufacturer’s maintenance; overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated un der this exemption must comply with all manufacturer safet y bulletins. 13. Under this grant of exemption, a PI C must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory , a possession, or the Federal Government. 14. The operator may

not permit any

PIC to operate unless the PI C demonstrates the ability to safel y operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures not participatin g in the operation. PI C qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency , and experience

- building) and determining the PIC’s ability to safel y operate the UAS in a manner consistent with howthe UAS will be operated under this exemption are permitted under the terms of this

exemption. However, training operations may only be conducted during dedicated training sessions . During training, proficiency , and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PI C must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.1 19. 15. UAS operations may

not be conducted during night, as defined in 14 CFR § 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 miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory

(AFD) or for airports not denoted with an ARP, the center of the airport s ymbol as denoted on the current FAA

- published aeronautica l chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or an y law enfo rcement official upon request. 17. The UA may

not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PI C.
18. If the UAS loses communications or loses its GPS si gnal, the UA must return to a pre - determined location within the private or controlled

- access propert y. 19. The PI C must abort the flight in the event of unpredicted obstacles or emergencies.
20. The PI C is prohibited from beginning a flight unless (cons idering 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 b y the manufacturer if greater.
21. Air Traff

ic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may

appl y for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

**−**Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.
23. Documents used b y the operator to ensure the safe operation and flight of the UAS and an y documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PI C at the Ground Control S tation of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcementofficial upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may

not be operated b y the PIC from any moving device or vehicle without prior FAA coordination. 26. All flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unl ess: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arise s where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safet y of nonparticipating persons.
b. The owner/controller of an y vessels, vehicles or structures has granted permission for operating closer to those objects and the PI C 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 essential pers ons are not considered non

- participating persons under this exemption. 27. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable CO A must 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

. of nonparticipating persons; and b. the owner/controller of an y vessels, vehicles or structures has granted permission for operating closer to those objects and the 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.**Regulations from which the exemption is requested :** 

14 C.F.R. Part 21 ; 14 C.F.R 45.23 (b) ; 14 C

. F

. R 61.113(a) and (b) ; 14 C.F.R. 91.7 (a) ; 14 CFR 91.9(b)(2) ; 14 C.F.R. 91.103 ; 14 CFR 91.109; 14 C.F. R. 91.119 ; 14 C.F.R. 91.12 1 ; 114 CFR 91.151(a) ; 14 C.F.R 91.203 (a) and (b ) ; 14 C

. F

. R 91.405(a) ; 14 C

. F

. R 407(a) (1) ; 14 C.F.R. 91.409 (2) ; 14 C

. F

. R 417(a) and (b)

SUASs operated b y Rugged Sky Media weigh less than 55 pounds, including the payload (i.e. camera, lens , and gimbal). They operate at speeds of no more than 50 knots, can hove r, and can simultaneously

move vertically

and horizontally

. Rugged Sky Media will only operate its sUASs in line of sight and will operate onl y wi thin the secure area described in the FOPM. Such operations will insure th at the sUAS will “not create a hazard to users of the national airspace sy stem or the public.”

Given the small size of Rugged Sky Media ’s sUASs and the restricted secure environment within which they

will operate, Rugge d Sky Media ’s sUAS operations adh ere to the Reform Act’s safet y requirements. Additionally , due to the size of the sUASs, permission from relevant propert y owners or other applicable parties, and the limited areas in which they will operate, approval of th is ap plication presents no national securit y issues. Based on the substantial leve l of safet y surrounding the proposed operations, and the significant pub lic benefit (enhanced safet y) , reduction in environmental impacts (red uced emissions and noise), the grant of the requested exemption is in the public interest. Accordingl y, Rugged Sky Media respectfully r equests that the FAA grant the requested exemption.

**Aircraft a nd Equivalent Level o**  **f Safety** The operating limitations proposed b y Rugged Sky Media prov ide for at least an equivalent or higher level of saf

et y because operations further enhance safet y of aerial image collecti on using conventional aircraft.

The limitations and conditions include:

 The sUASs used b y Rugged Sky Media will weigh less than 55 pounds.

 Flights will be operated within line of sight of a pilot and observer.

 Flights will be terminated at no less than 25% battery power reserve or manufacturer’s operating limitations.

 Flights will be operated at an altitude below 400 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer,

and the Camera Operator.

 A sUAS pilot will be an FAA licensed ai rman with at least a sport pilot’s certificate, and third class medical or valid US or Canadian driver’s license.

 A sUAS pilot will be Pilot in Command (PI C).

 The sUAS will only

operate within a confined secure area as defined in the FOPM.

**14 C.F.R. Par t 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)**  Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act ( 49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability , and proximity to airports and pop ulated areas of the particular UAS. In all cases, an anal ys is of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The sUAS s to be operated hereunder are less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the Manual’s requirements, and under the requirements and in compliance with local public safety requirements, to provide securit y for the area of operation as is now done with conventional filming. The FAA will have advance notice of all operations. These safet y enhancements provide a greater degree of safet y to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastl y, application of these s ame criteria demonstrates that there is no credible threat to national securit y posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial extern al load.
**14 C.F.R 45.23 (b) Marking of the Aircraft** The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provision ally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited,""restricted," "light

- sport," "experi mental," or "provisional," as applicable. Even though the UAS

will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAS , two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).The equivalent level of safety will be provided b y having the sUAS marked on its fuselage as required b y §45.29 (f) where the pilot, observer and others working with the sUAS will see the identification of the UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.
**14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.**  Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the UAS will not carry

a pilot or passengers, the proposed operations can achieve the equivalent lev el of safet y of current operations by requiring the PI C operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the s UAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safety provided by th e requirements included in th e m anual exceeds that provided b y a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operat ions contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PI C exceeds the present level of safet y achieved b y 14 C.F.R. 61.113 (a) and (b).
**14 C.F.R. 91.7 (a) civil**  **aircraft airworthiness.** Th e regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determ ining airworthiness. Given the size of the aircraft and the requirements contained in the DJ I Owner’s Manual for maintenance and use of safet y check lists prior to each flight, an equivalent level of safety will be provided.
**14 C.F.R. § 91.9 (b) (2): Civi l Aircraft Flight Manual in the Aircraft.**  Section 91.9 (b) (2) provides: No person may

operate a U.S.

- registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required b y §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any comb ination thereof. The sUAS, given its size and configuration has no ability or place to carry

such a flight manual on the aircraft, notonly

because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607 , 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

**14 C.F.R. 91.103 Preflight**  **A ctions** 
**.** This regulation requires each pilot in command to take certain actions before flight to insure the safet y of flight. As FAA approved rotorc raft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth in DJ I Phantom Owner’s manual along with the applicant’s 20+ years of experience flying radio controlled airc raft without incident. The PI C will take all actions including reviewing weather, flight battery

requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

**14 C.F.R. 91.109: Flight instruction:**  Section 91.103 pr ovides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has full y functioning dual controls.

sUASs and remotel y piloted aircraft, b y their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety provided by

the fact that neither a pilot nor passengers will be carried in the aircraft and b y the size and speed of the aircraft.
**14 C.F. R. 91.119 Minimum safe altitudes**  Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL , an exemption may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the Manual, the UAS will never operate at higher than 400 AGL. Itwill however be operated in a restricted area with securit y perimeter, where buildings and people will not be exp osed to operations without their pre

- obtained consent. The sUASs are equipped with telemetry back to the operator. Telemetry includes altitude, vertical and horizontal ground speed, direction and distance from operator.The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well

as the location where it is operated. No flight will be taken without the permission of the propert y owner or local officials. Because of the advance notice to the property owner and participant s in the filming activity , all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, an y ris k associated with these operations is far less than those presentl y presented with conventional aircraft used in photograph y for Real Estate and Business. In addition, the low

- altitude operations of the sUAS will ensure separation between these small

- UAS o perations and the operations of conventional aircraft that must comply with Section 91.119.
**14 C.F.R. 91.121 Altimeter Settings**  This regulation requires each person operating an aircraft to maintain cruising altitude b y reference to an altimeter that is se t “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safet y will be achieved b y the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

**14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions** Section 91 .151 (a) 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 cruising speed

– (1) During the day , to fly after that for at least 30 minutes; or (2) At night, to fl y after that for at least 45 minutes.” The battery powering the sUAS provides approximately 25 minutes of powered flight. Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and propert y owners or official representatives who have s igned waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Similar exemptions have been granted to other operatio ns, including Exemptions 2689F, 5745, 10673, and 10808

.**14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration**

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil ai rcraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . . (b) No person may

operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight auth orization issued under §91.715 is display ed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry

certification and registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by

keeping these documents at the ground control point where the pilot fl yi ng the sUAS will have immediate access to them; to the e xtent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 CFR 91.405(a)

**14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections**  These regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply onl y to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the manufacturer’s flight manual and operating handbook. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate onl y in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AG L. As provided in the Owner’s Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the a ircraft in an airworth y condition to provide the equivalent level of safety.**APPENDICES**

**Glossary:** Above Ground Level (AGL) Airworthiness D irectives (AD) Federal Aviation Administration (FAA) Federal Aviation Regulations (FAR) Flight Operations Procedures Manual (FOMP) National Airspace S ys tem (NAS) Pilot in Command (PI C) Unmanned Aerial Sy stem (UAS) Small Unmanned Aerial Sy stem (sUAS) Visual Flight Rules (VFR)

**sUASs specifications proposed for commercial**  **use YUNEEC**  **Q500 TYPHOON AIRCRAFT**  Flight Time Up to 25 Minutes Height 240mm (9.45 in) Width 420mm (16.54 in) Diagonal Length Without Rotor Blades 565mm (22.2 in) Propeller/Main Rotor Diameter 330mm (13.0 in) Weight Without Battery & Payload 1130g (40.0 oz) Battery 5400mAh 3S 11.1V LiPo Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter Transmitter 10

- channel 2.4GHz with 5.8GHz video dow nlink 3 Flight Modes Smart, Angle and Home Modes Maximum Flying Height Default 400 Feet Above Ground Level Maximum Rotational Velocity 65°/s Maximum Bank Angle 35° Maximum Climb Rate in Smart & Angle mode 3m/s M aximum Descent Rate in Smart & Angle mode 2m/s Radio Control Frequency Band 2.4GHz Takeoff Weight With Battery and CGO2

- GB 1700g
CGO2

- GB Camera Gimbal Sy stem Focusing System Aerial Optimized Fixed Focus Video Resolution FULL HD 1080p

- Adjustable 60, 50 or 48 FPS Photo Resolution 12 MegapixelsField of View 155°

ST10 Personal Ground Station Operating System AndroidTM Number of Channels 10 Control Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) Robust Radio Control Modulation Yuneec Protocol Video link Frequency Band 5.8GHz Video Transmission Distance/Range (Optimum Conditions) FC C Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) Flight Systems Telemetry Data On Screen Display (OSD) Yes LED Backlit LCD Screen Capacitive Multi

Touch 4.5” Tactile (Vibrating) & Audible Feedback Yes Built

- In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh Charger Auto

- Charge Mode via Micro

- B USB Cable with AC to 5V DC USB Pow er Supply (Included) **DJI Inspire 1 Model T600** Weight (Battery Included) 2935 g Hovering Accuracy (GPS mode) Vertical: 0.5 m Horizontal: 2.5 m Max Angular Velocity Pitch: 300°/s Yaw: 150°/s Max Tilt Angle 35° Max Ascent Speed 5 m/s Max Descent Speed 4 m/s Max Speed 22 m/s (ATTI mode, no wind) Max Flight Altitude 4500 m Max Wind Speed Resistance 10 m/s Max Flight Time Approximately 18 minutes Motor Model DJI 3510 Propeller Model DJI 1345 Indoor Hovering Enabled by default Operating Temperature Range

- 10° to 40° C Diagonal Distance 559 to 581 mm Dimensions 438x451x301 mm Power Spectral Density 9.06mW/MHz
Remote Controller Name C1 Operating Frequency 922.7~927.7 MHz (Japan Only) 5.725~5.825 GHz 2.400~2.483 GHz Transmitting Distance (outdoor and unobstructed) 2 km EIRP 10dBm @900m , 13dBm@5.8G, 20dBm@2.4G Video Output Port USB, mini

- HDMI Power Supply Built

- in battery Charging DJI charger Dual User Capability Host

- and

- Slave connectionMobile Device Holder Tablet or Phone

Max Mobile Device Width 170mm Output Power 9 W Operating Temperature Range

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

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

- 40° C Battery 6000 mAh LiPo 2S

**FAA Regulations from which the exemption is requested:**
14 C.F.R. Part 21
**45.23 (b)**  Display of marks; general (b) When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally

certificated aircraft, the operator must also display on that aircraft near each entrance to the cabi n, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.

**14 CFR 61.113(a) and (b)** Private pilot privileges and limitations: Pilot in command. (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property

for compensation or hire ; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may , for compensation or hire, act as pilot in command of an aircraft in connection with an y business or employment if: (1) The flight is only

inci dental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire.
**14 C.F.R. 91.7 (a)** C ivil aircraft airworthiness. (a) No person may

operate a civil aircraft unless it is in an airworthy condition. (b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when un

- airworthy

mechanical, electrical, or structural conditions occur.**14 C.F.R. 91.103**

Preflight action. Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— (a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delay s of which the pilot in command has been advised b y ATC; (b) For an y flight, runway lengths at ai rports of intended use, and the following takeoff and landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and
runw ay slope, aircraft gross weight, and wind and temperature.

**14 C.F.R. 91.109:** Flight instruction; simulated instrument flight and certain flight tests. (a) No person may

operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction may be given in an airplane that is equipped with a single, functioning throw over control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when

— (1) The instructor has determined that the flight can be conducted safel y; and (2) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings. (b) An airplane eq

uipped with a single, functioning throw over control wheel that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review required b y§ 61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency check required by

§ 61.57 when

— (1) The airplane is equipped with operable rudder pedals at both pilot stations; (2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the entire flight; (3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of§ 61.195(b), and has logged at least 25 hours of pilot

- in

- command flight time in the make and model of airplane; and (4) Th e pilot in command and the instructor have determined the flight can be conducted safel y.(c) No person may operate a civil aircraft in simulated instrument flight unless

— (1) The other control seat is occupied b y a safet y pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown. (2) The safet y pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequatel y supplements the vision of the safet y pilot; and (3) Except in the case of lighter

- than

- air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single

- engine airplane, equipped with a single, functioni ng, throw over control wheel, in place of fixed, dual controls of the elevator and ailerons, when

— (i) The safet y pilot has determined that the flight can be conducted safel y; and (ii) The person manipulating the controls has at least a private pilot certi ficate with appropriate category and class ratings. (d) No person may

operate a civil aircraft that is being used for a flight test for an airline transport pilot certificate or a class or typ e rating on that certificate, or for apart 121 proficiency

flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully

qualified to act as pilot in command of the aircraft.

**14 C.F. R. 91.119** Minimum safe altitudes: General. Except when necessary

for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over an y congested area of a cit y , town, or settlement, or over an y open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsel y populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight

-shift

- control aircraft. If the operati on is conducted without hazard to persons or property on the surface

— (1) A helicopter may

be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specificall y prescribed for helicopters b y the FAA; and (2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.**14 C.F.R. 91.121**

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

— (1) Below 18,000 feet MSL , to

— (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a) ( 1 ) ( i) of this section, the current reported altimeter setting of an appropriate available station; or (ii i) 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; or (2) At or above 18,000 feet MSL , to 29.92 ′′ Hg.
**14 CFR 91.151(a)** Fuel requirements for flight in VFR conditions. (a) No person may

begin 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 cruising speed

— (1) D uring the day , to fly after that for at least 30 minutes; or (2) At night, to fl y after that for at least 45 minutes.
**14 CFR 91.203 (a) (1)** Civil aircraft: Certifications required. (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of the applicable operations specifications i ssued under§ 21.197(c) of this chapter, appropriate sections of the air carrier manual required b y parts 121 and 135 of this chapter containing that portion of the operations specifications issued under § 21.197(c), or an authorization under § 91.611) must have on it the registration number assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not have on it an assigned special identification number before 10 day s after that number is first affixed to the aircra ft. A revised airworthiness certificate having on it an assigned special identification number, which has been affixed to an aircraft, may onl y be obtained upon application to an FAA Flight Standards district office.**14 CFR 91.405(a)**

Maintenance required. Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as presc ribed in part 43 of this chapter.
**14 C.F.R. 91.409(a) (1) and (2)** Inspections (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

— (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service b y a person authoriz ed by §43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

**14 C.F.R. 91**  **.9 (b) (2)**  Civil Aircraft Flight Manual in the Aircraft (b) No person may

operate a U.S.

- registered civil aircraft

— (2) For which an Airplane or Rotorcraft Flight Manual is not required b y§ 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.
**14 CFR 407(a) (1)** Operation after maintenance, preventive maintenance, rebuilding, or alteration. (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 under§ 43.7 of this chapter; and
**14 CFR 417(a) and (b)** Maintenance records. (a) Except for work performed in accordance with§§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive mainten ance, 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 appliance of an aircraft. The records must include

—(i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and applianc e. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the ins pection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safet y directives including, for each, the method of compliance, the AD or safet y directive number and revisi on date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed b y§ 43.9(d) of this chapter for each major alteration to the airframe and currentl y installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this 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. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or op erator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.