Integra Tower, LLC   |   11771 Spruce Run Dr, San Diego, CA 92131   |   www.integratower.com    1

June 10, 2015

Attn: Nia Daniels, ARM‐108

Federal Aviation Administration

Office of Rulemaking, Airmen & Airspace Rules Division

800 Independence Avenue, SW

Washington, DC 20591

Re: Petition for Exemption: Integra Tower, LLC (Docket No. FAA‐2015‐0327)

Dear Nia:

This document is provided in response to your email request for further information dated May 28,

2015 and detailing the following:

Describe the aircraft make, model, and type (i.e. ‐ fixed‐wing, rotorcraft, lighter‐than‐air)

for the proposed UAS operation.  The description should include the maximum weight

(including payload).  This information can be located in the aircraft manual.

Aircraft to be used

We are planning to use the following rotorcraft for commercial purposes:

1. DJI Phantom 2 Vision+

2. DJI Inspire 1

3. SteadiDrone MAVRIK X8

Each aircraft that will be operated by Integra Tower, LLC will be registered in accordance with 49 U.S.C.

44103, Registration of Aircraft, as well as 14 C.F.R. Part 47, Aircraft Registration, and marked in accordance

with 14 C.F.R. Part 45, Identification and Registration Marking.

Additionally, Integra Tower, LLC will keep up‐to‐date with all vendor software ensuring non‐operation

in “No Flight Zones.”   

A basic overview addressing each area of this request for additional information is provided here, with

further details provided within the addendums of which are a part of this response.  In the event we opt to

utilize alternative aircraft, Integra Tower, LLC will provide a detailed proposal seeking modification to this

request for exemption.

   
Integra Tower, LLC   |   11771 Spruce Run Dr, San Diego, CA 92131   |   www.integratower.com    2

DJI Phantom 2 Vision+

The DJI Phantom 2 Vision+ is a VTOL (Vertical Takeoff and Landing) UAV (Unmanned Aerial Vehicle)

controlled by a Ground Control Station utilizing a remote control, tablet, remote control system, or

smartphone.  It has a maximum gross weight of approximately 2 lbs. 11 ounces, with a length of 16 inches by

16 inches wide by 8 inches tall.  It has a maximum speed of approximately 29 knots.  The DJI Phantom 2 Vision+

is equipped with four main rotors (thereby a “quadcopter” rotorcraft) and is powered by lithium polymer

battery‐powered electric motors.

The DJI Phantom 2 Vision+ may be operated in both manual and fully autonomous flight modes.  A

complete description of the flight and navigational modes of the DJI Phantom 2 Vision+ is provided in pages

25‐35 of the User Manual.  

Additional technical specifications of the DJI Phantom 2 Vision+ are provided in Exhibit A: Phantom 2

Vision Plus User Manual v1.8.

DJI Inspire 1

The DJI Inspire 1 is a VTOL (Vertical Takeoff and Landing) UAV (Unmanned Aerial Vehicle) controlled

by a Ground Control Station utilizing a remote control, tablet, remote control system, or smartphone.  It has a

maximum gross weight, with payload, of approximately 7.5 lbs., with a length of 17.2 inches by 17.8 inches

wide by 11.9 inches tall.  It has a maximum speed of approximately 42.8 knots.  The DJI Inspire 1 is equipped

with four main rotors (thereby a “quadcopter” rotorcraft) and is powered by lithium polymer battery‐powered

electric motors.

The DJI Inspire 1 may be operated in both manual and fully autonomous flight modes.  A complete

description of the flight and navigational modes of the DJI Inspire 1 is provided in pages 12‐22 of the User

Manual.  

Additional technicalspecifications of the DJI Inspire 1 are provided in Exhibit B: Inspire 1 User Manual

v1.2.

SteadiDrone MAVRIK X8

The SteadiDrone MAVRIK X8 is a VTOL (Vertical Takeoff and Landing) UAV (Unmanned Aerial

Vehicle) Multirotor Aircraft controlled by a Ground Control Station utilizing a remote control, tablet, remote

control system, or smartphone.  Utilizing the “X8” format for redundancy and increased payload, the

MAVRIK features a Rapid Deploy Frame, and an integrated gimbal for a variety of payloads.    

The SteadiDrone MAVRIK X8 has a maximum gross weight, with payload, of approximately 10.9

lbs., with a length of 19.7 inches by 30.5 inches wide by 8 inches tall.  The SteadiDrone MAVRIK X8 is

equipped with 8 engines in the X8 configuration, meaning that there are four pairs of engines/propellers

providing complimentary thrust at each position.  This configuration enables a great degree of

redundancy in the event of a failure thereby improving overall safety.

Additional technical specifications of the SteadiDrone MAVRIK X8 are provided in Exhibit C:

SteadiDrone MAVRIK X8 Features and Specifications.
Integra Tower, LLC   |   11771 Spruce Run Dr, San Diego, CA 92131   |   www.integratower.com    3

   

Conclusion

In the event additional information is required, please let me know so that we have the

opportunity to address any questions or concerns.

Sincerely,

Eric DaVersa

CEO

Integra Tower, LLC

eric@integratower.com