Chris L Baker 303 Dry Creek Rd. Dubois, ID 83423 Tel. 208.709.4349 idahogeomentor@gmail.com U.S. Department of Transportation January 24, 2016 Docket Management System 1200 New Jersey Ave S.E. Washington, D.C. 20590

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Reg ulations from Certain Provisions of 14 C.F.R.

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Chris L Baker files this petition for exemption on behalf of Chris L Baker, an operator of Small Unmann ed Aircraft Systems (“UAs”) use for remote sensing to support (i) precision farming and other agri culture applications; (ii) asset management for utilities, government agencies, and private firms; (iii) construction and land manage ment; (iv) disaster response and search and rescue; and (v) conducting research flights tocollect data and establish and refine forensic processes, procedures, and tools for investigation of accidents and crimes involving UAs. Specifically, petitioner seeks an exemption from the Federal Aviation Regulations (“FARs”) listed in Appendix A to allow commercial operation of its UAs, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA in a g rant of this petition. This request is substantially similar to other data collection petitions previously approved, and should be considered under the expedited summary grant procedure. Approval of the exemption for petitioner will allow commercial operat ion of:(1 ) the DJI Phantom 3 Advanced , approved for commercial o perations in Exemption No. 12901 ; and

similar to 11062, 11112, 11324, and 11241. (2 ) the AGV6A+v2 , approved for similar commercial operations like agbot exemption No. 13752 and in Exemption No. 11062, 11109, 11112, 112133, 11223, and 1264 in Class G airspace or as otherwise prescribed in an ATO issued COA nationwide. The UA operations contemplated by this petition are in the public interest because they clearly satisfy the "Four D's" of exemplary uses of UAs: to replace work that is Dangerous, Difficult, Dull, or Dirty, and at the same time provide an equivalent or greater level of safety than alternative manned aircraft operations. The UAs covered by this petition are small battery powered craft, weighing no more than 1

- 55 lbs., inclusive of battery and payload. Operation of the UAs under the strict conditions proposed below will provide an equivalent level of safety, as Congress intended, while still allowing commercia l operations. Operations using these UAs are far safer than conventional operations conducted with helicopters and fixed

- wing aircraft that weigh thousands of pounds, carry highly flammable fuel, and operate in close proximity to the ground, trees, infrast ructure, and people.

## Table	of	Contents

I. Publishable Summary
................................ ................................ ................................ ................................ . 4 II. Petitioner’s Contact Information
................................ ................................ ................................ .............. 5 III. Proposed Operations
................................ ................................ ................................ ............................... 5 A. The UAs
................................ ................................ ................................ ................................ ................. 5 1. DJI Phantom 3 Advanced
................................ ................................ ................................ .................. 5 2. AGV6, and V8
................................ ................................ ................................ ................................ .... 6 B. The Crew
................................ ................................ ................................ ................................ ............... 7 C. Flight Conditio ns ................................ ................................ ................................ ................................ ... 7 D. Flight Operations
................................ ................................ ................................ ................................ .. 8 IV. Aircraft and Equivalent Level of Safety
................................ ................................ ................................ .... 8 V. Proposed Conditions of the Exemption
................................ ................................ ................................ .... 8 VI. Privacy
................................ ................................ ................................ ................................ .................... 13 VII. Public Interest and Safety
................................ ................................ ................................ ..................... 13 A. Precision Farming and Agriculture Applications
................................ ................................ ................. 13 B. Asset Management Applications
................................ ................................ ................................ ........ 15 C. Construction and Land Management Applications
................................ ................................ ............ 16 D. Disaster Response and Search and Rescue
................................ ................................ ........................ 17 E. Research and wildlife observation for Idaho Fish and Game.
................................ ............................ 17 VIII. Public Health and Safety Incidents involving Asset Management
................................ ...................... 18 A. Appendix A
................................ ................................ ................................ ................................ .......... 22 B. Exhibit 1
................................ ................................ ................................ ................................ .............. 25 DJI Phantom 3 Advanced Specs
................................ ................................ ................................ .......... 25 AG
-V6 and V8A UAV Sprayers
................................ ................................ ................................ ................. 28 C. Exhibit 2
................................ ................................ ................................ ................................ .............. 31 DJI Phantom 3 Advanced User Manual
................................ ................................ ................................ ... 31 D. Exhibit 3
................................ ................................ ................................ ................................ .............. 32 DJI Phantom 3 Advanced Training
................................ ................................ ................................ .......... 32 E. Exhibit 4

................................ ................................ ................................ ................................ ............. 33 AGV6

-V8 Training

................................ ................................ ................................ ................................ . 33

## I.	Publishable	Summary

Pursuant to 14 C.F.R. § 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Petitioner seeks an exemption from the following rules: 14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.113(b); 14 C.F.R. 91.119 (c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b) to operate commercially a small unmanned aircraft system (UA) (55 lbs. or less).

Approval of the exemption requested by petitioner will allow commercial operation of (1 ) the Dji Phantom ; and (2 ) the AGV6, and V8 system for remote sensing to support (i) precision farming and other agriculture applications; (ii) asset management for utilities, government agencies, and private firms; (iii) construction and land management; (iv) disaster response and search and rescue; as well as (v) conducting research flights to collect data and establish and refine forensic processes, procedures, and tools for investigation of accidents and crimes involving forestry, public lands, agricultural, wildlife, and vehicles. The requested exemption should be granted because operation of small UAs, weighing no more th an 55 lbs. (2.7 kg.), inclusive of battery and payload, conducted in the strict conditions outlined below, will provide an equivalent level of safety, while still allowing commercial operations. The lightweight aircraft covered by the exemption are far safer than convent ional operations conducted with helicopters and fixed

- wing aircraft weighing thousands of pounds and carrying highly flammable fuel, and operating in close proximity to the ground and people. The seven factors Congress directed the FAA to consider when app roving Section 333 exemption petitions

- size, weight, speed, operational capability, proximity to airports, proximity to populatedareas, and operation within visual line of sight
– each support the request. In particular, the aircraft are

small, and will operate at slow speeds, and close to the ground in order to more safely and efficiently conduct inspections that would otherwise involve a risk of death to the inspectors. The substantial increase of safety and decrease of risk to human life, coupled with the low risk use of UAs to conduct these operations, weigh heavily in favor of granting the exemption.



## II.	Petitioner’s	Contact	Information Chris L Baker 303 Dry Creek Rd. Dubois, ID 83423 (208) 709

- 4349


## III.	Proposed	Operations **A.	The	UAs** The requested exemption will permit petitioner to operate (1) the Dji Phantom; and (3 ) the AGV6, and V8 . This petition and Exhibits are hereinafter referred to as the “operating documents.” The specific conditions of the proposed exemption that relate to t he characteristics of the UAs are numbers 1, 5, and 16
- 20 in Section V below. Each has been adopted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

**1 .	DJI	Phantom**  **3	Advanced** The requested exemption will permit pet itioner to operate the Phantom 3 Advanced , with a max imum weight of approximately 2.8 lbs. , inclusive of batteries and technical payload. This rotorcraft operat es at a speed of no more than 31 knots and has the capability to hover and move in the vertical and horizontal planes simultaneously.

Please refer to Exhibits 2

- 4 for further information about the airframe, control system and transmitter. The FAA has previously reviewed these documents and approved exemptions for commercial use of the DJI Phantom i n Exemption Nos. 11138, 11189, and 11191.The UA will have the following specifications or equivalent:

Airframe: DJI Phantom 3 Advanced Dimensions: d iagonal motor

- motor distance 590 mm (approximately 23 inches) Flight Control System: DJI Naza

- M V2, which includes the GPS and GLONASS and the internal measurement unit (IMU), electronic speed controllers (ESC), Vision Positioning Sensor, Automatic Flight Logs, and containing a built

- in internal sensor and a barometric altimeter that measures both altitude
a nd attitude. Transmitter (Tx): 

### 2.400 GHz
- 2.483 GHz DJI Remote Control Receiver (Rx): 2.4 G Hz receiver built in to the DJI Phantom 3 Advanced Motor: electric DJI 2312 CCW Data Link: 2.4 GHz USB ground modem Video Link: 5.8 GHz OSD: DJI GO app, DJI Lightbrid ge, open on a dedicated mobile device, which allows live telemetry to be displayed to the visual observer, including the battery level and altitude
. Batteries: 

### 4480 mAh LiPo 4 S

**2 .**  **AGV6,	and	V8** The requested exemption will permit petitioner to operate the Event 38 E384, with a maxi mum weight of 5.9 lbs. inclusive of batteries and technical payload. This fixedwing aircraft operates at a speed of no more than 26 knots. The FAA has previously approved the AgBOT’s similar to AGV6

-V8 for commercial flight in Ex emption No. 11166. 

### The UA will have the following specifications or equivalent: Please see exhibit 3 for full description. Airframe: AGV6

-V8 x

- Frame Control System: Autopilot, Military grade redundancy : Dual Flight Controller and GPS Tx/RX : 2.4 GHz Control Radio Tx/Rx 14 Ch Motors: Brushless Motors 380RPM/V x8 OSD: Mission p lanner software, visible on a dedicated ground station laptop, which allows live telemetry to be displayed to the visual observer, including the battery level and altitude

. Batteries: 16000 mAh, 6S, 22.2v DC, Lithium

- Poly mer x4

### B.	The	Crew

The crew will consist of a pilot in command (PIC) and a visual observer (VO). The PIC will have, at minimum, a sport pilot’s license and a third class medical certificate or a U.S. drive r’s license. The PIC and VO will have been trained in operation of UAs generally and received up to
date information on the UAs to be operated pursuant to this grant. The PIC will have completed, at a minimum, 25 hours of UA flight training with the specific UAs prior to operations, and will be required to participate in annual training thereafter. The PIC will have completed the training programs provided by DJI, HSE
- UAV, or equivalency as approved by current and future FAA regulations
. The specifi c conditions of the proposed exemption that relate to the training and characteristics of the crew are numbers 3 and 6

- 9 in Section V below. Each has been adopted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions.



### C.	Fli **ght	Conditions** The UAs will be used for remote sensing to support (i) precision farming and other agriculture applications; (ii) asset management for utilities, government agencies, and private firms; (iii) construction and land management; (iv) disaster r esponse and search and rescue; and (v) conducting research flights to collect data and establish and refine forensic processes, procedures, and tools for investigation of accidents and crimes involving UAs. All flights will be in Class G airspace or as oth erwise prescribed in an ATO issued COA under 400 feet above ground level (“AGL”) and under controlled conditions. Petitioner will work with the local FSDO when planning operations. Petitioner will only operate its UAs in visual meteorological conditions (V MC). The UA will at all times be no less than 500 feet below and no less than 2,000 feet horizontally from a cloud, and petitioner will not conduct operations unless visibility is at least 3 statute miles from the PIC. The flight crew will always make a sa fety assessment of the risk of every operation, and will only operate when it is determined that no hazards are present. Flights will only be conducted away from any major population and never at public events or other areas where petitioner cannot control the area and observe the operational area.The specific conditions of the proposed exemption that relate to the flight conditions in

which the UA will be operated are numbers 2, 4, 16, and 28

- 29 in Section V below. Each has been adopted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions. 

### D.	Flight	Operations The purpose of every UA flight will be to safely, accurately, and efficiently support: (i) precision farming and other agriculture applications; (ii) asset management for utilities, government agencies, and private firms; (iii) construction and land management; (iv) disaster response and search and rescue; as well as (v) research flights to develop proce sses, procedures, and tools for accident and crime investigations of UAs. Every UA flight will use at minimum a two person flight crew: a PIC and a VO. 

## IV.	Aircraft	and	Equivalent	Level	of	Safety Petitioner proposes that the exemption apply to UAs that ha ve the characteristics and that operate with the limitations proposed herein. These limitations provide for a level of safety at least an equivalent to or higher than manned aircraft operations under the current regulatory structure. Section V below identi fies the limitations and conditions to which petitioner agrees to be bound when conducting commercial operations under a grant of this petition. Appendix A contains matrix connecting (i) the specific proposed condition with (ii) the FAR provision for which it provides equivalent level of safety and (iii) one or more recent Section 333 exemption grants in which the FAA recognized this equivalent level of safety. Approval of the commercial operations outlined in this petition presents no national security iss ue. The PIC will possess, at minimum, a sport pilot’s certificate, so he or she will have been subject to security screenings by the Department of Homeland Security. 

## V.	Proposed	Conditions	of	the	Exemption 1. T he UAs will weigh no more than 55 lbs., inclus ive of battery and payload. 2. UA operations under this exemption will be limited to conducting operations for the purpose of providing (i) precision farming and other agriculture applications; (ii) asset management for utilities, government agencies, and private firms; (iii) construction and land management; (iv) disaster response and search and rescue; and (v) conducting research flights to collectdata and establish and refine forensic processes, procedures, and tools for investigation of

accidents and crimes involving UAs in Class G airspace nationwide, unless otherwise prescribed in an ATO

- issued COA. 3. Flights will be operated within line of sight of a pilot and visual observer. 4. Flights will be operated at an altitude of no more than 400 feet AGL, as indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be in feet AGL. 5. The UA will not be flown at an indicated airspeed exceeding 87 knots (100 mph). 6. Minimum flight crew for each operation will consist of the UA pilot in command (PIC) and a visual observer (VO). 7. The PIC will have, at minimum, a sport pilot license and a third class medical certificate or a U.S. driver’s license. 8. The petitioner will not permit any PIC to operate unless the P IC meets its qualification criteria and demonstrates the ability to safely operate the UA in a manner consistent with how the UA will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from per sons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). A record of the PIC training will be documented and made available upon request by the Administrator. Training operations will only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations will be considered nonparticipants, and the PIC will operate the UA with a ppropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 9. The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions, and will not be permi tted to operate the camera or other instruments. 10. The PIC will be designated before the flight and will not be allowed to transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the functions prescribed in these conditions and the operating documents. 11. A briefing will be conducted in regard to the planned UA operations prior to each day’s activities. It will be mandatory that all personnel who will be performing duties in connection with th e operations be present for this briefing.12. Prior to each flight, the PIC will inspect the UA, including the Ground Control Station, to

ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UA, the PIC will not operate the UA until the necessary maintenance has been performed and the UA is found to be in a condition for safe flight. All maintenance and alterations will be properly documented in the aircraft records. 13. Petitioner will c onduct a functional flight test on any UA that has undergone maintenance or alterations that affect the UA operation or flight characteristics, e.g. replacement of a flight critical component. The PIC who conducts the functional test flight will make an en try in the aircraft records. 14. The petitioner will carry out its maintenance, inspections, and record keeping requirements, in accordance with the UA manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requir ements set forth in the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts will be noted in the aircraft records, including total time in service, description of work accomplished, and the signatur e of the authorized person returning the UA to service. The authorized person will make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 15. The UA will be operated within visual line of s ight (VLOS) of the PIC and VO at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses. PIC and VO will at all times be able to communicate verbally. They will not be permitted to use electronic messaging or texting to communicate during flight operations. 16. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and prepare to land each UA with 20% battery life remaining. 17. Actual total flight time for each operational flight will result in no less than a 20% battery
reserve. 18. The UA will have the capability to abort a flight in case of unexpected obstacles or emergenci es. 19. The UA will be programmed so that if it loses communications or loses its GPS signal, it will return to a pre
- determined location within the planned operating area and land or be recovered in accordance with the operating documents20. If the UA an d its radio control link disconnect during flight, the system’s failsafe protection

will be triggered and the multirotor will return to home and land automatically, rather than flying off uncontrollably or landing at an unknown location. 21. The operating documents required under 14 CFR §§ 91.9 and 91.203 will be maintained and available to the PIC at the Ground Control Station of the UA any time the UA is operating. These documents will be made available to the Administrator or any law enforcement official upon request. If a discrepancy exists between the conditions and limitations in the exemption grant and the procedures outlined in the operating documents, the grant conditions and limitations will take precedence and will be followed. Otherwise, the peti tioner will follow the procedures outlined in its operating documents. If it updates or revises its operating documents, it will present updated and revised documents to the Administrator upon request. If the petitioner determines that any update or revisi on would affect the basis upon which the FAA granted the exemption, then the Petitioner will petition for an amendment to the grant of exemption. 22. Petitioner will obtain written and/or oral permission from the landowners/authorized agents of the landown ers over which flights will be conducted. 23. Petitioner will obtain all required permissions and permits from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 24. UA opera tions will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC). Flights will not be conducted under special visual flight rules (SVFR). 25. The petitioner will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. Petitioner will request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 h ours prior to the operation. All operations will be conducted in accordance with airspace requirements in the ATO issued COA, including class of airspace, altitude level and potential transponder requirements. 26. The UA will not be operated within 5 nauti cal miles of an airport reference point as denoted on a current FAA
- published aeronautical chart unless a letter of agreement with that airport’s management has been obtained, and the operation is conducted in accordance with a NOTAM as required by the ope rator’s COA. Any letter of agreement with the airportmanagement will be made available to the Administrator upon request.

27. The UA will not be operated less than 500 feet below, or less than 2,000 feet horizontally from, a cloud or when visibility is le ss than 3 statute miles from the PIC. 28. All operations shall be conducted in Class G airspace or as otherwise prescribed in an ATO issued COA. 29. All aircraft operated in accordance with this exemption will 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 will be as large as practicable. 30. Before conducting operations, petitioner will ensure that the radio frequency spectrum u sed for operation and control of the UA complies with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 31. The UA will remain clear and yield the right of way to all manned aviation operations and
a ctivities at all times. 32. The UA will not be operated by the PIC from any moving device or vehicle. 33. Petitioner will conduct all flight operations at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless one of the following three conditions is met: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The petitioner will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, the PIC will ensure that flight operations cease immediately. b. The aircraft is operated near vessels, veh icles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard. c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 34. Petitioner will report any incident, accident, or flight operation that transgresses the lateral or vertical b oundaries of the operational area as defined by the applicable COA to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Petitioner will report accidents to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

## VI.	Privacy

Chris Baker will follow the Association of Unmanned Vehicles Systems International’s Code of Conduct, available at http://www.auvsi.org/conduct. When conducting search and rescue operations, the images received will be turne d over to the incident commander (the individual in charge of the disaster or search) and the GIS staff on hand, who are almost always law enforcement personnel. This is a similar privacy protocol to when taking pictures on the ground for disaster response and search and rescue operations. 

## VII.	Public	Interest	and	Safety The planned UA use will increase ground safety for (i) precision farming and other agriculture applications; (ii) asset management for utilities, government agencies, and private firms; (iii) construction and land management; (iv) disaster response and search and rescue; and (v) Wildlife monitoring . The enhanced safety and reduced environmental impact achieved using a UA with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UA operation enabled by this exemption is in the public interest. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012
– size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security
– provide more than adequate justificat ion for the grant of the requested exemption allowing commercial operation of petitioner’s UAs, pursuant to Chris L Baker’s rules of operation and imposed by FAA in decision.


### A.	Precision	Farming	and	Agriculture	Applications The planned UA use will increa se ground safety in the precision agriculture industry. The enhanced safety and reduced environmental impact achieved using a UA with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of signif icantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UA operation enabled by this exemption is in the public interest. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012
– size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security
– provide more than adequate justification for thegrant of the requested exemption allowing comme rcial operation of petitioner’s UA for precision

agriculture operations, pursuant to petitioner’s rules of operation. Use of UA technology to assist in precision agriculture is a benefit not only to farmers, but to the public as a whole, and to the environ ment. Farmers will have greater analytical tools at their disposal for managing crops, leading to decreased use of resources. This will result in both reduction of cost and increase in quality
– benefits that will be passed on to the public. Additionally, using less water and chemicals during commercial farming operations will reduce the impact that the operation has on the environment. As Jeff Vanderwerff testified on behalf of the American Farm Bureau Federation before members of the Senate Committee on C ommerce, Science, & Transportation on March 24, 2015: [The benefit of UA comes from] their ability to provide detailed scouting information on weed emergence, insect infestations and potential nutrient shortages. This valuable information allows the farmer to catch these threats before they develop into significant and catastrophic problems. By addressing threats quickly, the farmer has a greater likelihood of being able to respond appropriately so as to optimize yields.
The imagery from UAS also allows th e farmer to spot

-treat sections of the fields as opposed to watering or spraying the entire field. The quicker a farmer can discover a potential threat, the quicker the farmer can address the issue. Images from UAS allow the farmer to identify the specific location where a specific treatment – be it fertilizer, water, pesticides, or herbicides is necessary; in doing so, the farmer can eliminate the need to use these applications more broadly across the entire field. By spot

-treating threats to the crop, the farmer not only lowers the cost of treatment but also has the potential of lowering the environmental impact by minimizing application.” (emphasis added) The FAA has previously determined that commercial UA use for the precision farming industry is within the public interest. It has approved the E384 for precision farming and agriculture applications in Exemption No. 11166.
Additionally, the FAA has previously approved a variety of other UAs for commercial precision farming and agriculture applications in Exemption Nos.: 11110 (precision aerial surveys); 11136 (photogrammetry and crop scouting in order to perform precision agriculture); 11167 (high

- resolution aerial imagery in support of biomass analysis and estimati on, yield monitoring, leaf area indexing and reporting of geographical data and overall crophealth to a domestic agricultural seed company);

11170 (precision agriculture operations); 11177 (commercial precision agriculture surveys); 11192 (aerial photogra phy and 3D mapping for the agriculture industry); 11193 (precision photogrammetry and crop scouting for precision agriculture); 11195 (aerial photography for agriculture); 11222 (collect high quality, actionable data for use by agronomists, crop consultant s, and forestry professionals); 11223 (precision agriculture survey and inspection operations); 11226 (precision aerial surveys); 11228 (aerial acquisition and research in support of the agriculture industry); and 11229 (aerial acquisition and research in support of the agriculture industry). 1 Unmanned Aircraft Systems: Key Considerations Regarding Safety, Innovation, Economic Impact, and Privacy Before the S. Comm. On Commerce, Science, & Transportation, 114th Cong. 1 (2015) (written statement of Jeff Van derwerff on behalf of the American Farm Bureau Federation).


### B.	Asset	Management	Applications Petitioner proposes utilizing its UAs for asset management applications including wind farm, power transmission system, and pipeline inspections. Chris was in the oilfield for over a year and worked under and with high pressures and gases in the field and aware of the many disasters that may be prevented or lessened by using more advanced technology to keep workers and the environment safe. Chris L Baker, personall y watched one fatality and one major injury involving high pressure . UA’s are a tool for better management in a new era of increasing technology to assist in dangerous fields of employment and inspections that would otherwise be dangerous if a human must enter a disaster. The UA’s can be sent to observe and allow for managers to make decisions to aid in stopping a failed well head or pipeline Idaho has increased its wind farm industry for California consumption and created other hazards for our service te chnicians.
Currently, many wind farm inspections are conducted by people in harnesses, dangling from each individual tower, and power transmission system and pipeline inspections are conducted by individuals in manned aircraft. Both wind farm and power t ransmission systems inspections involve a serious risk offalls. Wind farm inspectors often conduct inspections of towers and blades from the structure and are at

risk of falling, sometimes over 100 feet or more.
Similarly, inspectors of power transmission systems have a similar risk of falling, which is augmented by the danger of being near electrical wires. There have been several instances in recent years in which inspectors and crew members lost their lives performing these inspections.



### C. **Construction	and	Land	Management	Applications** Use of a UA for construction and land management applications will provide a greater level of safety than what is currently available. The construction industry has traditionally been very dangerous for workers , both based on the working conditions and equipment used, including helicopters and cranes. Currently, aerial inspections are not done on many construction projects. Instead, inspections are conducted from the ground, or from within the structure being
co nstructed, giving a limited view of the project. OSHA reports that in 2013, 20.3% of worker fatalities in private industry were related to construction, and the leading cause of those fatalities were falls, with 294 o ut of the 796 total fatalities. This li mits the capabilities of architects and construction crews examining the work that has been done, and could lead to misidentification or failure to identify flaws in the construction. Those projects that do incorporate aerial inspections must rely upon man ned helicopters or other types of aircraft, devices that can pose a great risk to those piloting and those on the ground below, without providing the most accurate results. Similarly, land management applications are limited to either expensive and dangero us manned flights, or ground

- level inspections that do not capture the full wealth of knowledge available. Alternatively, using a UA to videotape and photograph these areas will allow the construction crew to gain a better vantage point of the structure. S afety concerns can be better identified and fixed, and the inspectors will be able to gain a more thorough understanding of construction progress. This UA will be able to provide a quick and cost effective aerial inspection of an entire jobsite, something that is much more difficult to perform without this technology. The device can be used to check the progress of the project and provide visual information on hard

-to
- reach areas that may not be adequately inspected otherwise without putting people in dange r. UAs can be equipped with specialized cameras and sensors that provide enhanced detection of other concerns, such as gas leaks and lack of structural integrity. United States Department of labor, Occupational Safety & Health Administration CommonlyUsed Statistics, https://www.osha.gov/oshstats/commonstats.html

The FAA has previously determined that using a UA will provide an equivalent or greater level of safety than manned flight when inspecting construction sites and has approved Exemption Nos. 11109 (monitor and ensure safety of construction sites), 11204 (aerial photography for the architectural, engineering, and construction industry sites), and 11286 (aerial imaging of construction sites). 

### D.	Disaster	Response	and	Search	and	Rescue Petitioner wishe s to use its UAs when conducting disaster response and search and rescue operations. Although petitioner will not be conducting this sort of operation for profit, because petitioner is a commercial UA operator in other respects, petitioner has included thi s sort of operation in this petition. Petitioner wishes to conduct these operations under the auspices of the FAA. The owner Chris Baker, is an experienced Facilities, Base Camp, and Federal Land manger and spent over 11 years in the US. Forest Service in wildland fire and disaster response as well as remote search and rescue wilderness operations and integrating remote sensing to enhance land management decisions
. The major benefit to conducting disaster response and search and rescue operations with a UA rather than a manned aircraft is cost. Government agencies across the country have turned to UAs as a possible source for assistance during emergency situations. The Washington State Department of Transportation has conducted research on using UAs and dete rmined that they would be useful for both search and rescue and disaster response operations, including avalanche response. The department has previously paid $800 an hour for manned helicopters for search and response operations.8 The Mesa County, Colorad o Sherriff’s Office uses a UA equipped with infrared sensors for search and rescue operations, and has projected that a UA costs $25 an hour to operate, compared with manned aircraft, which cost between $400 and $1,200 an hour to operate. 

### E. **Research	and wildlife	observation	for	Idaho	Fish	and	Game.**  Finally, the petitioner wishes to conduct commercial UA operations for the purpose of conducting research flights to collect data and establish and refine wildlife research, poaching crimes and mortality rates , procedures, and tools for investigation of crimes involving UA’s in poaching and use of UA’s in violations of federal or state wildlife laws
.Unfortunately, the past year in manned aviation has demonstrated the importance of

having a wealth of informa tion regarding airplane crashed while in research or wildlife monitoring and control
. Most of these incidents have involved fixed wing aircraft while searching , control, or monitoring for problem wolves, coyotes, and Grizzly Bears. The National Transportation and Safety Board (NTSB) has a database covering civil manned aviation accidents that dates back to 1962. No such record exists for UAs, where the technology is rapidly developing. It is imperative for the safe integration of UAs into the NAS that th is type of research occur.


## VIII.	Public		Health	and	Safety	Incidents	involving	Asset	Management 1. Three people were killed in an accident in Silt, Colorado in January 2014. The helicopter struck the power line and crashed, quickly killing all those on board .3 Two people lost their lives in a similar situation in August 2014 in Alabama.4 In Texas, in 2013, two transmission line inspectors that were suspended from the helicopter by large cables were killed when the cables struck the power line and snapped.5 Mo reover, especially in populated areas, the use of manned helicopters to conduct these inspections creates a substantial risk of injury or death for individuals on the ground. Additionally, people involved in pipeline inspection must walk along the pipeline with sensor equipment. This can be time consuming, due to the length of pipelines. Inspectors may also have to traverse lengths of the pipeline in adverse weather and geographic conditions. Furthermore, inspectors may be exposed to hazardous materials, su ch as crude oil and natural gas. 2. According to the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA), in 2014, there were 29 serious pipeline incidents, and an additional 268 significant pipeline incidents, with 19 fatalities and 96 injuries. 3. United States Department of Energy, Occupational Safety & Hazard Administration, Green Job Hazards: Wind Energy
– Falls, https://www.osha.gov/dep/greenjobs/windenergy_falls.html. 4. Br ian Hernandez, 3 Killed in Crash When Helicopter Hits Power Lines Near Silt in Western Colorado, ABC7 NEWS DENVER Jan. 27, 2014, http://www.thedenverchannel.com/news/localnews/ 3
- killed

- in

- helicopter

- crash

- near- silt012720145. Power

- line

- inspection Copter C rashes in Alabama; 2 Killed, COLUMBUS DISPATCH, Aug. 20,2014, http://www.dispatch.com/content/stories/national_world/2014/08/20/power

- lineinspection

copter
- crashes

- 2
- killed.html 5. Sabra Stafford, Turlock Man Killed in Power Line Accident, TURLOCK JOURNAL (Texas), Aug. 8, 2013, http://www.turlockjournal.com/archives/21204/The PHMSA defines “serious incidents” as those including a fatality or injury requiring inpatient hospitalization, but this data excludes first far incidents, which are gas distributi on incidents with a cause of “other outside force damages” and sub

cause of “nearby fire/explosion” as the primary cause of incident. “Significant incidents” include any of the following conditions, excluding first fire incidents: (1) fatality or injury re quiring in

- patient hospitalization; (2) $50,000 or more in total costs, measured in 1984 dollars; (3) highly volatile liquid releases of 5 barrels or more or other liquid releases of 50 barrels or more; or (4) liquid releases resulting in an unintentional fire or explosion. 6. The Henry County, Indiana Office of Emergency Management (“HCOEM”) determined that owning an emergency response manned aircraft could cost $800,000, not including personnel costs, compared to the one

-time purchase price of $1,700 to pur chase their UA, and concluded that investing in a manned aircraft for emergency management would not happen: “The cost to Henry County to use manned aerial services is something that

has and most likely will not be budgeted for.” 10 (emphasis added).

7. Add itionally, operators of UAs are able respond much more quickly in an emergency than the pilot of a manned aircraft. They can be launched from an area close to the scene of an emergency, compared to a manned aircraft which would depart from an airport, pote ntially 8. Edward D. McCormack, Use of Small Unmanned Aircraft by the Washington State Department of Transportation, 14 (June, 2008) available at http://www.wsdot.wa.gov/research/reports/fullreports/703.1.pdf. 9. Sheriff Rebecca Spiess, MSCO Unmanned Aircraft Systems Team, Frequently Asked Questions, available at http://sheriff.mesacounty.us/uav. 10. Henry County Office of Emergency Management, Standard Operating Procedures and Standard Operating Guidelines for Unmanned Aircraft Systems (UAS), 8 (December 4, 2014), available at http://www.henrycoema.org/forms/HCOEM%20Aerial%20Equipment%20Standard%20Operati ng%20Procedures%20and%20Guidlines%20Ver%201

-3.pdf.The FAA has previously approved disaster response operations in Exemption No. 11283

and search and rescue oper ations in Exemption No. 11282.
Conversely, all three types of asset management inspection can be easily, quickly, and much more safely, conducted by operators controlling UAs from the ground. Human inspectors will not be at risk of falls from great height s or onto electrical wires, and will not be subjected to the risks associated with manned flight. The FAA has previously determined that commercial UA use for asset management is within the public interest. It has approved commercial UA asset management ap plications in Exemption Nos.: 11184 (inspection of towers and structures); 11185 (electric transmission and distribution utility system monitoring, inspections, and damage assessments); 11217 (aerial inspections of wind turbine blades and towers); 11224 (i nspections of energy infrastructure); 11225 (safety inspections and aerial surveying); 11228 (research in support of Government entities, utility companies, local infrastructure) 11229 (research in support of Government entities, utility companies, local i nfrastructure) 11230 (tower inspections and mapping operations to an existing tower structure); 11238 (aerial inspections of electric and gas facilities); and 11239 (utility, power line inspections).

### A.	Appendix	A : FARs as to which Chris Baker wishes the same determination to be

made as has been made previously. 21(h) 1, 2, 3, 4, 5, 15, 24, 27, 28, 33 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11111, 11110, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11189, 11191, 11192, 11193, 11195 43.7 13, 14 No. 11208 43.11 12 No. 11208 45.11 29 No. 11208 45.27 29 No. 11188 45.29 29 Nos. 11136, 11157, 11170, 11185, 111 93 91.7(a) 12 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11177, 11178, 11184, 11185, 11188, 11189, 11191, 11192, 11193, 11195, 11204 91.9(b)(2) 22 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11174, 11177, 11178, 11184, 11185, 11189, 11192, 11193, 11195 91.9(c) Nos. 11136, 11170, 11171, 11174, 11185 91.103(b)(2) 3, 9, 15, 16, 17, 18, 19, 20, 27 No. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11138, 11150, 1115 3, 11156, 11158, 11160, 11161, 11166, 11167, 11171, 11172, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 1120491.105 6 No. 11185 91.109 7, 8 Nos. 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11110, 11112, 1 1136, 11138, 11150, 11153, 11156, 11157, 11166, 11167, 11170, 11171, 11174, 11177, 11184, 11185, 11189, 11191, 11192, 11193, 11194, 11195, 11206, 11208 91.113(b) 3, 31 No. 11238 91.119(c ) 4, 33 Nos. 11162, 11163, 11164, 11165, 11166, 111080, 111109, 11110 , 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193 91.121 4 Nos. 11162, 11163, 11164, 11165, 11166, 111080, 111109, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193 91.151(a) 16, 17 Nos. 11110, 11153, 11156, 11161; 111109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 11172 , 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193 91.203 (a and b) 21 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195 91.215 25, 26 Nos. 11185, 11195 91.403 12, 13, 14 No. 11185 91.405(a) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11 153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189,11191, 11192, 11193, 11195, 11204

91.407(a)(1) 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204 91.409(a)(1) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189,

### B. **Exhibit	1**

**DJI	Phantom	3	Advanced	Specs** 

### AIRCRAFT Weight (including battery and propellers) 1280 g (2.8lbs) Diagonal size (including propellers) 590 mm Max Ascent Speed 5 m/s Max Descent Speed 3 m/s Hover Accuracy Vertical: +/

- 0.1 m (when Vision Positioning is active) or +/

- 0.5 m Horizontal: +/

- 1.5 m Max Speed 16 m/s (ATTI mode, no wind) Max Service Ceiling Above Sea Level 6000 m (Default altitude limit: 120 m above takeoff point) Operating Temperature 0°C to 40°C GPS Mode GPS/GLONASS **CAMERA** Sensor Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M) Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞ ISO Range 100

- 3200 (video) 100

- 1600 (photo) Shutter Speed 8s

- 1/8000s Image Max Size 4000 x 3000 Still Photography Modes Single Shot Burst Shooting: 3/5/7 shots Auto Exposure Bracketing (AEB): 3/5 Bracketed Frames at 0.7EV Bias Time

- lapse

### Video Recording Modes **Phantom 3 Advanced** 2.7K: 2704 x1520p 24/25/30 (29.97) FHD: 1920x1080p 24/25/30/48/50/60 HD: 1280x720p 24/25/30/48/50/60 Supported SD Card Ty

pes Micro SD

Max capacity : 64 GB. Class 10 or UHS

- 1 rating required Max Bitrate of Video Storage **Phantom 3 Advanced** 40 Mbps Supported File Formats FAT32/exFAT Photo: JPEG, DNG Video: MP4, MOV (MPEG

- 4 AVC/H.264) Operating Temperature 0°C to 40°C **VISION POSITIONING**  Max Velocity Less than 8 m/s (when 2 m above ground) Altitude Range 50 cm

- 300 cm Operating Range 50 cm

- 300 cm Operating Environment Surface with clear pattern and adequate lighting (Lux > 15) **REMOTE CONTROLLER** Operating Frequency 2.400 GHz

- 2.483 GHz Max Distance Up to 5 km or 3.1 miles (unobstructed, free of interference) when FCC compliant Up to 3.5 km or 2.1 miles (unobstructed, free of interference) when CE compliant Video Output Port USB Operating Temperature 0°C

- 40°C Battery 6000 mAh LiPo 2S

### Mobile Device Holder For tablet or phone

Receiver Sensitivity

(1%PER)

- 101 dBm ±2 dBm Transmitter Power (EIRP) FCC: 20 dBm CE: 16 dBm Working Voltage 1.2 A @7.4 V **INTELLIGENT FLIGHT BATTERY**  Capacity 4480 mAh Voltage 15.2 V Battery Ty pe LiPo 4S Energy 68 Wh Net Weight 365 g Max Flight Time Approximately 23 minutes Operating Temperature

- 10°C to 40°C Max Charging Power 100 W **APP / LIVE VIEW** Mobile App DJIGO EIRP 100mW Power Spectral Density 6.9mW/MHz Live View Working Frequency 2.4GHz I SM Live View Quality 720P @ 30fps (depending on conditions and mobile device) Latency 220ms (depending on conditions and mobile device) Required Operating S ystems iOS 8.0 or later Android 4.1.2 or later

### AG **- V6	and**  **V8 A**  **UAV	Sprayers**

PROPUL SION MOTORS

 

### Brushless Motors 380RPM/V x8 ELECTRONIC SPEED CONTROLLERS

 

### Ty pe: 60A
 

### Drive PWM Frequency 400Hz POWER SOURCES

 

### 16000 mAh, 6S, 22.2v DC, Lithium

- Poly mer x4
 

### Max Power: 1200W PROPELLERS

 

### 18.55in wingspan, carbon fiber STRUCTURES FRAME

 

### Current Configuration: Octocopter (8 Motors) V6 (6 Motors)
 

### X

- frame design
 

### Diagonal wheel base 1060 mm + The traditional “oct” style design of AG

- V8A drones allows for peak performance. Power consumption is minimal re lative to other design options such as “Hex” and “Quad” copter styl es. The “Oct” design also provides maximal stability, especially over other design op6ons such as the “Tri” copter styl e.  

### Li ghtweight aluminum and carbon fiber construction allows for heavi er payload options. ENDURANCE **+ Operation:**

 

### Operating Altitude: 1200m AGL(Above Ground Level)
 

### Maximum Launch Altitude: 8000m AMSL(Above Mean Sea Level)
 

### Range of Operation: 5000 line of sight operation
 

### Weight of drone without payload: 5.7 KG
 

### + Maximum Payl oad Weight: 8.7

- 15 KG
 

### Flight Range: 3

– 25 km depending on mission requirement
 

### + Maximum Takeoff Weight: 30.3 KG
 

### Takeoff Clearing 5m x 5m

### + Safety:

 

### Return home /Land on low battery
 

### Multiple Flight Controller for failure redundancy
 

### Multiple GPS for GPS failure redundancy
 

### Motor

- Fail Protection Function keeps altitude under control even with any 1 motor failure
 

### Geo Fencing to prevent the aircraft from flying above the legal height limits or flying in restricted airspace. **+ Temperature:**

 

### Rated up to 65 C
 

### Functionality

in the cold

- 20 C **+ Wind:**

 

### Optimally

functional in up to 20

- 40 km/h cross winds
 

### R&D underway

for functionality

in 50

- 60 km/h cross winds **+ Rain:**

 

### Vital components sealed for functionality in wet conditions (Water resistant)* **AVIONICS CONTROL**

 

### Autop ilot
 

### Configuration Supported: +4,x4,+6,x6,y6,+8,x8
 

### Military

grade redundancy : Dual Flight Controller and GPS
 

### S

- Bus receiver technology
 

### Operating voltage: 5.7V
 

### Position hold accuracy : vertical +/

- 0.5 m, horizontal +/

- 1.5m
 

### Maximum Tilt: 35 degrees
 

### Maximum cruise speed: 43.2 km/hr
 

### Maximum crosswinds: 30.1 km/hr
 

### Mass: Autopilot module: 119 gram (each x2) GPS: 37 gram (each x2)
 

### Dimension: Autopilot module: 70.5mm X 41mm X 25 mm (each x2) GPS: 55mm(diameter) X 11mm (each x2) LED: 17mm X 17mm X 5.5mm

**COMMUNICATION** 

### + 2.4 GHz Control Radio Tx/Rx 14 Ch

 

### + Proprietary

Communication Radio Algorithm **GROUND SUBSYSTEMS** Ground subsystems encompass all major areas of the system that operate on the ground. Listed component amounts are relative to one operating product unit. **GROUND STATION**

 

### Digital video transmission
 

### Anti

- jamming
 

### Secure AES encry

ption
 

### Can serve as No

- line of sight communication relay
 

### Auto power mode selection
 

### Auto forward error correction
 

### Retains memory

when th ere is sudden power loss
 

### High receiving sensitivity, single antenna

- 92dBm, **TRANSMITTER AND RECEIVER**

 

### Operating voltage: DC7V

– 16.8V
 

### Operating current: < 1A @ 12V
 

### Operating frequency : 425 MHz ~ 445 MHz
 

### Drift from central frequency : +/

- 40 Hz
 

### Radio frequency

bandwidth: 1.25/2.5 MHz or 6/7/8 Mhz
 

### Output power: > 27 dBm
 

### Carrier to Noise: > 28 dBm @ 28 dBm
 

### Modulation scheme: COFDM
 

### Digital modulation scheme: QPSK/16QAM @ 1.25/2.5 MHz, QPSK/16QAM/64QAM @ 6/7/8 MHz
 

### Forward Error Correction Bit Rate: 1 /3, 2/3, @ 1.25/2/5 MHz 1⁄2, 2/3, 3⁄4, 5/6, 7/8 @ 6/7/8 MHz
 

### Carrier Mode: 2K
 

### Guard Interval: 1/8, 1/16, @ 1/25/2.5 MHz 1⁄4, 1/8, 1/16, 1/32, @ 6/7/8 MHz

# C. **Exhibit	2**

**DJI	Phantom	3	Advanced	User	Manual**

# D. **Exhibit	3**

**DJI	Phantom	3	Advanced Training** 

### E. **Exhibit 4 AGV6**  **- V8**  **Training**

UAV Pilot Training Course is designed for Commercial users of UAV s ystems for inspections, mining operations, geological mapping, aerial photography, agriculture. real estate, surveys, construction, utilities, pipeline, telecomm, railroads, maritime, news media, farming, ranching, forestry, land management, and more. **Course Topics** 1. **Advanced Safety** 1. Airspace Management 2. Temporary

Flight Restrictions 3. Area Awareness 4. Emergency

Landing and Awareness 5. GPS Off awareness and situation review 2. **RDASS Training** 1. Takeoff, Landing and Shutdowns 2. Maneuvering and positioning 3. Simple Photo and Payload Management with Gimbal movement and setup 4. Advanced Maneuvering and positioning 5. No GPS Flying and usage 6. Autopilot Mission Flying with interrupt and continue 7. Photo management with Autopilot and "Lawn Mowing" configuration 8. Custom Payload management 9. R/C Autopilot 10. Basic Helicopter maintenance, storage and setup 11. Battery

maintenance 12. Photo Gimbal setup and Camera usage 4. **Ground Station Mission Setup** 1. Full PC Mission Setup and planning 2. Map Calibration and Way Point Management 3. Downloading and customization of missions to and from UAV 5. **Hands On** 1. All aspects of previous topics in real situations and practical usage with RDASS Trainers 6. **Advanced Software** 1. Photo Stitching 2. 3

- D Rendering of Photos 3. Archeological Photo Mapping 4. Construction Photo Mapping