### BEFORE THE

FEDERAL AVIATION ADMINISTRATION

___________________________________________________

Autel Robotics USA, LLC,

Petitioner. Docket No. FAA

- 2016

-

_____

AUTEL ROBOTICS USA, LLC PETITION FOR EXEMPTION FROM CERTAIN FEDERAL

AVIATION REGULATIONS TO OPERATE UNMANNED AIRCRAFT SYSTEMS (UAS) PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

Lisa Ellman Matthew Clark Hogan Lovells US LLP 555 13 th Street, N.W. Washington, DC 20004

Phone: 202

- 637

- 6934

Fax: 202

- 637

- 5910 lisa.ellman@hoganlovells.com matt.clark@hoganlovells.com

Counsel for Autel Robotics USA, LLC

DATE: February 15, 2016i TABLE OF CONTENTS

1. INTRODU CTION AND SUMMARY OF PROPOSED SMALL UAS OPERATIONS

................................ ................................ ................................ ......................... 1

2. BACKGROUND OF PETITI ONER

................................ ................................ ......................... 2

3. RELEVANT STATUTORY A UTHORITY

................................ ................................ ................ 2

4. AUTEL’S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECT ION 333 OF FMRA

................................ ................................ .... 3

4.1 Approval is warranted based on the UAS's size, weight,
sp eed, and operational capability

................................ ................................ ........... 3

4.2 Approval is warranted based on the proposed conditions and limitations

................................ ................................ ................................ ........... 4

5. REQUEST FOR DETE RMINATION UNDER SECT ION 333 OF FMRA

................................ 10

6. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A PETITION FOR EXEMPTI ON

................................ ................................ ................................ . 10

6.1 Con tact information:

................................ ................................ ................................ . 10

6.2 The specific section or sections of the FAR from which Autel seeks an exemption

................................ ................................ ........................ 11

6.3 The extent of reli ef sought and the reason relief is sought

................................ .. 12

6.4 Exemption request catch

- all provision

................................ ................................ ... 23

6.5 Reasons why granting the request wou ld be in the public interest

................................ ................................ ................................ ....................... 23

6.6 Reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which exemption is sought

................................ ................................ ................................ . 24

6.7 Summary that can be published in Federal Register, including the rule from which exemption is sought, and a brief description of the nature of th e exemption sought

................................ ...... 26

6.8 Additional information that supports request

................................ ........................ 27

6.9 Request to exercise the privileges of the exemption outside the U.S.

................................ ................................ ................................ ....................... 27

6.10 Attachments

................................ ................................ ................................ .............. 27

7. CONCLUSION

................................ ................................ ................................ ........................ 271 1. INTRODUCTION AND SUM MARY OF PROPOSED SM ALL UAS OPERATIONS

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”)

and 14 C.F.R. (“FAR”) Part 11, Autel Robotics USA, LLC (“Autel”) hereby applies for a

Summary Grant of Exemption from the Federal Aviation Regulations (“FAR ”) identified

below, to allow commercial operation of small unmanned aircraft systems ( i.e., “small

unmanned aircraft” or “UAS”) for aerial data collection, including outdoor research and

development testing of Autel’s UAS platforms, testing of newly refur bished UAS, product

demonstration and marketing flights, aerial photography / videography, aerial surveys,

inspections, and mapping activities. Autel also seeks an exemption which would permit

flights closer than 500 feet to, but not directly over, people directly participating in the

intended purposes of the operation, in a controlled access environment, similar to a closed

set, and consistent with the conditions and limitations imposed by the FAA in its recent Grant

of Amendment to Cape Productions, Inc. Exemption No. 11433A (December 29, 2015;

Docket FAA

- 2015

- 0223 (“ Amended Cape Exemption ”). Specifically, Autel requests that it be

allowed to operate three of its UAS models, including, the Autel Robotics X

- Star, X

- Star Go

and X

- Star Premium, as well as t he previously approved vehicles identified in Attachment 1

and Attachment 2 to the Amended Measure Exemption (and attached to this Petition as

Appendix A ). See

, e.g ., Exemption No. 12646A (November 19, 2015; Docket FAA

- 2015

-

1602) (“ Amended Measure Exempti on ”).

In addition to this Petition for Exemption, Autel will also submit a UAS Operations

Manual addressing the items as specified in limitation No. 28 of the Amended Cape

Exemption , and as proposed herein, for operations closer than 500 feet to, but no t directly

over, people directly participating in the intended purpose of the operation. Autel submits

this UAS Operations Manual as a confidential document under separate cover pursuant to

14 C.F.R. § 11.35(b), as the material contains confidential comme rcial and proprietary

information that Autel has not and will not share with others. The information contained in the2 UAS Operations Manual is not generally available to the public and is protected from release

under the Freedom of Information Act, 5 U.S.C . § 552 et seq

.
Autel respectfully submits that this Petition for Exemption qualifies for expedited

approval, as the FAA has previously issued grants of exemption in circumstances similar in

all material respects to those presented herein.

2. BACKGROUND OF PETITIONER

Autel Robotics USA, LLC, which was established in November, 2015 and is

headquartered in Bothell, Washington, is the North American sales and service subsidiary of

Autel Intelligent Technology Corp. in Shenzhen, China. Autel has been a leader in

automotive diagnostics hardware and software for over a decade and began developing

small UAS platforms in early 2014. Autel currently has a line of small camera

- carrying

consumer quadcopters (the X

- Star series), and is currently developing solutions t o extend

battery life utilizing vertical

- takeoff fixed

- wing products (the Kestrel series), that automatically

transition to forward flight after taking off. The core transitioning technology won second

place in the United Arab Emirates’ 2015 Drones for Goo d competition, and was developed in

cooperation with Quantum Systems and the Technische Universität München.

Autel USA's leadership team have worked in the UAS retail sector since 2013 and

during that period, have developed extensive customer education pro grams on the safe

operation, maintenance, and repair of multiple small UAS platforms from several leading

manufacturers. To meet growing customer demand and expand available services, Autel

seeks an exemption to allow commercial operation of small UAS. G iven that some aerial

data collection activities will need to occur within the customers’ presence, Autel also seeks

permission to conduct operations closer than 500 feet to, but not directly over, consenting

customers that are directly participating in th e intended purpose of the operation

3. RELEVANT STATUTORY A UTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of

FMRA. Congress has directed the FAA "to safely accelerate the integration of civil3 unmanned aircraf t systems into the national airspace system." Pursuant to Section 333 of

FMRA, the FAA Administrator is to permit unmanned aircraft systems to operate in the NAS

where it is safe to do so based on the following considerations:

• The UAS's size, weight, spee d and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from

the agency's safety regulations and minimum standards when the Administrator decides a

requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority

of the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions fr om §§ 44701(a), (b) and

§§ 44702

– 44716, et seq. ). A party requesting an exemption must explain the reasons why

the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect

safety (or how it would provide a level of safety a t least equal to the existing rules). See FAR

§ 11.81 (petitions for exemption).

4. AUTEL’S PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333 OF FM RA

Autel’s proposed operations in this Petition for Exemption qualify for expedited

approval via th e summary grant process pursuant to Section 333 of FMRA, as each of the

statutory criteria and relevant factors is satisfied, and the FAA has previously issued grants

of exemption in circumstances similar in all material respects to those presented in this

Petition for Exemption. See e.g.
, Amended Cape Exemption ; Exemption No. 12958

(September 22, 2015; Docket FAA

- 2015

- 2717) (“ Aeronautic Imagery Exemption ”);

Exemption No. 11692 (May 26, 2015; Docket FAA

- 2015

- 0220) (“ OpenSky Exemption ”).

4.1 Approval is warrant ed based on the UAS's size, weight, speed, and operational capability

All of the UAS vehicles chosen by Autel meet the requirements of Section 333 of

FMRA due to their weight, speed and operational capabilities. Autel intends to operate a

variety of sma ll, lightweight, battery

- powered UAS under the requested exemption, including4 those approved in previously granted exemptions and are set out in Attachment 1 and

Attachment 2 to the Amended Measure Exemption (and attached to this Petition as Appendix

A ). Autel also seeks to operate three proprietary micro

- size UAS platforms, including the

Autel Robotics X

- Star, X

- Star Go and X

- Star Premium. The following shared characteristics

of the Autel Robotics X

- Star, X

- Star Go and X

- Star Premium make them appropriat e for

aerial data collection activities and would warrant approval for a grant of exemption under

Section 333 of FMRA:

• They all weight less than 55 pounds including payload;

• They all have the capability to operate safely after experiencing certain in

- flight contingencies or failures and uses an auto

- pilot system to maintain UAS stability and control. The UAS is also able to respond to a loss of GPS or a lost

- link event with a
pre

- coordinated, predictable, automated flight maneuver. These safety feat ures provide an equivalent level of safety compared to a manned aircraft performing a similar operation and mitigate the risk of command and control link failures;

• T he radio frequencies used for operations and control of the UAS comply with the Federal Co mmunications Commission (FCC) and other appropriate government oversight agency requirements; and

• The UAS all operate at a speed of 87 knots or less.

Details on the technical specifications and operating capabilities of the Autel

Robotics X

- Star, X

- Star Go and X

- Star Premium are attached as Appendix B

.

4.2 Approval is warranted based on the proposed conditions and limitations

To expedite the FAA’s safety assessment of Autel’s proposed UAS operations, Autel

will consent to conditions and limitations No.’s 2 through 29 of the Amended Cape

Exemption

. 1 Specifically, Autel will conducted the proposed operations in accordance with

the following conditions and limitations which will ensure that the proposed operations can be

conducted safely.

1. Operations author ized by the grant of exemption will be limited to the Autel Robotics X

Star

, Autel Robotics X

- Star Go, Autel Robotics X

- Star Premium, and the UAS approved

1 Limitation No. 1 of the Amended Cape Exemption addressed the specifi c small UAS model Cape Productions sought operate. All UAS operated by Autel will also weigh less than 55 pounds including payload and equipment.5 by the Secretary of the Department of Transportation under Section 333 ( Appendix A ) when weighing les s than 55 pounds including payload. Proposed operations of any other UAS will require a new petition or a petition to amend this exemption. 2

2. If operations under this exemption involve the use of foreign civil aircraft 3 the operator would need to obtain a Foreign Aircraft Permit pursuant to 14 CFR § 375.41 before conducting any commercial air operations under this authority. Application instructions are specified in 14 CFR §375.43. Applications should be submitted by electronic mail to the DOT Office of I nternational Aviation, Foreign Air Carrier Licensing Division. Additional information can be obtained via https://cms.dot.gov/policy/aviation

policy/licensing/foreign

- carr iers

.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The operator 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 airspeed s 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 level (AGL). Altitude must be reported in feet AGL. This limitation is in addition to a ny altitude restrictions that may be included in the applicable COA.

5. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA) . All operations must be conducted in accordance with an ATO

- issued COA. The exemption holder must apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA.

6. The PIC must have the capability to maintain visual line of sight (VLOS) at all times. This requires the PIC to be able to use human visio n unaided by any device other than corrective lenses, as specified on that individual’s FAA

- issued airman medical certificate or valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal Government, to see the UA.

7. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the VO at all times. The VO must use human vision unaided by any device other than corrective lenses to see t he UA. The VO and the PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

8. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this exemption, ar e hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption, t he applicable ATO

- issued COA, and the procedures outlined in the operating documents,

2 See Amended Measure Exemption Limitation No. 1.

3 Foreign civil aircraft means (a) an aircraft of foreig n registry that is not part of the armed forces of a foreign nation, or (b) a U.S.

- registered aircraft owned, controlled or operated by persons who are not citizens or permanent residents of the United States. 14 CFR §375.1.6 the most restrictive conditions, limitations, or procedures apply and must be followed. The operator may update or revise its operating documents as necessary. The operat or is responsible for tracking revisions and presenting updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its exemption. The FAA’s UAS Integration Office may be contacte d if questions arise regarding updates or revisions to the operating documents.

9. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights must be conducted by a PIC with a VO and other personnel required to conduct the functional flight test (such as a mechanic or technician) and must remain at least 500 feet from all other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

10. The operator is responsible for maintaining and inspecting the UAS to ensure that it i s in a condition for safe operation.

11. Prior to each flight, the PIC must conduct a pre

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

- flight inspection must account for all potential discrepancies, e.g. inoperable compon ents, 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 fli ght.

12. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. Each UAS operated under this exemption must comply with all manufacturer safety bull etins.

13. PIC certification : Under this exemption, a PIC 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 is sued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot cer tificate.

14. PIC qualifications : The PIC must demonstrate the ability to safely operate the UAS in a manner consistent with how it will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from per sons, vessels, vehicles and structures before operating non

- training, proficiency, or experience

- building flights under this exemption. PIC qualification flight hours and currency may be logged in a manner consistent with 14 CFR § 61.51(b), however UAS pil ots must not log this time in the same columns or categories as time accrued during manned flight. UAS flight time must not be recorded as part of total time.

Under all situations, the PIC is responsible for the safety of the operation. The PIC is also

re sponsible for meeting all applicable conditions and limitations as prescribed in this exemption and ATO

- issued COA, and operating in accordance with the operating documents. All training operations must be conducted during dedicated training sessions and m ay or may not be for compensation or hire. The operation must be conducted with a dedicated VO who is no collateral duties and is not the PIC during the flight. The VO7 must maintain visual sight of the aircraft at all times during flight operations without distraction in accordance with the conditions and limitations below. Furthermore, the PIC must operate the UA not closer than 500 feet to any nonparticipating person without exception.

15. UAS operations may not be conducted during night, as defined in 14 CF R § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cl oud or when visibility is less than 3 statute miles from the PIC.

17. For UAS operations where GPS signal is necessary to safely operate the UA, the PIC must immediately recover/land the UA upon loss of GPS signal.

18. If the PIC loses command or control link wi th the UA, the UA must follow a pre

determined route to either reestablish link or immediately recover or land.

19. The PIC must abort the flight operation if unpredicted circumstances or emergencies that could potentially degrade the safety of persons or pro perty arise. The PIC must terminate flight operations without causing undue hazard to persons or property in the air or on the ground.

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

21. All aircraft operated in accordance with this exemption must be identifi ed 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.

22. Documents used by the operator to ensure the safe operat ion and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or an y law enforcement official upon request.

23. The UA must remain clear of and give way to any manned aircraft at all times.

24. The UAS may not be operated by the PIC from any moving device or vehicle.

25. All flight operations must be conducted at least 500 feet fr om all persons, vessels, vehicles, and structures unless when operating:

a. Over or near people directly participating in the operation of the UAS . People directly participating in the operation of the UAS include the PIC, VO, and other consenting personnel that are directly participating in the safe operation of the UA.

b. Near but not over people directly participating in the intended purpose of the UAS operation . People directly participating in the intended purpose of the UAS8 includes [customers] 4 who must be briefed on the potential risks and acknowledge and consent to those risks. Operators must notify the local Flight Standards District Office (FSDO) with a plan of activities at least 24 hours prior to flight operations.

c. Near nonparticipating persons . Ex cept as provided in subsections (a) and (b) of this section, a UA may only be operated closer than 500 feet to a person when barriers or structures are present that sufficiently protect that person from the UA and/or debris or hazardous materials such as f uel or chemicals in the event of an accident. Under these conditions, the operator must ensure that the person remains under such protection for the duration of the operation. If a situation arises where the person leaves such protection and is within 500 feet of the UA, flight operations must cease immediately in a manner that does not cause undue hazard to persons.

d. Near vessels, vehicles and structures . Prior to conducting operations the operator must obtain permission from a person with the legal author ity over any vessels, vehicles or structures that will be within 500 feet of the UA during operations. The PIC must make a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

26. All oper ations shall be conducted over private or controlled

- access property with permission from a person with legal authority to grant access. Permission will be obtained for each flight to be conducted.

27. Any incident, accident, or flight operation that transgre sses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) in accordan ce with its UAS accident reporting requirements.

For operations conducted closer than 500 feet to people directly participating in the intended purpose of the operation, not protected by barriers, the following additional conditions and limitations apply:

28. The operator must have an operations manual that contains at least the following items, although it is not restricted to these items.

a. Operator name, address, and telephone number.

b. Distribution and Revision. Procedures for revising and distributing the operations manual to ensure that it is kept current. Revisions must comply with the applicable conditions and limitations in this exemption.

c. Persons Authorized. Specify criteria for designating individuals as directly participating in the safe operation o f the UAS. The operations manual must

4 In Limitation No. 25(b) of th e Amended Cape Exemption , people directly participating in the intended purpose of the UAS operation included “athletes.” Consistent with the FAA’s analysis contained therein and in the Amended Kansas State Exemption , the risk posed to participating custom ers within 500 feet of the operation is similar to the risk posed to athletes in the Amended Cape Exemption , as well as the observing KSU students in the Amended Kansas State Exemption

. See Amended Cape Exemption at 5.9 include procedures to ensure that all operations are conducted at distances from persons in accordance with the conditions and limitations of the exemption.

d. Plan of Activities. The operations manual must include proce dures for the submission of a written plan of activities.

e. Permission to Operate. The operations manual shall specify requirements and procedures that the operator will use to obtain permission to operate over property or near vessels, vehicles, and struct ures in accordance with this exemption.

f. Security. The manual must specify the method of security that will be used to ensure the safety of nonparticipating persons. This should also include procedures that will be used to stop activities when unauthorized persons, vehicles, or aircraft enter the operations area, or for any other reason, in the interest of safety.

g. Briefing of persons directly participating in the intended operation. Procedures must be included to brief personnel and participating persons o n the risks involved, emergency procedures, and safeguards to be followed during the operation.

h. Personnel directly participating in the safe operation of the UAS Minimum Requirements. In accordance with this exemption, the operator must specify the minimu m requirements for all flight personnel in the operating manual. The PIC at a minimum will be required to meet the certification standards specified in this exemption.

i. Communications. The operations manual must contain procedures to provide communications capability with participants during the operation. The operator can use oral, visual, or radio communications as along as the participants are apprised of the current status of the operation.

j. Accident Notification. The operations manual must contain proc edures for notification and reporting of accidents in accordance with this exemption.

In accordance with this exemption, the operating manual and all other operating documents must be accessible to the PIC during UAS operations.

29. At least 24 hours prior t o operations, the operator must submit a written Plan of Activities to the local Flight Standards District Office having jurisdiction over the proposed operating area.

The Plan of Activities must include at least the following:

a. Dates and times for all fl ights. For seasonal or long

- term operations, this can include the beginning and end dates of the timeframe, the approximate frequency (e.g. daily, every weekend, etc.), and what times of the day operations will occur. A new plan of activities must be submi tted prior to each season or period of operations. b. Name and phone number of the on

- site person responsible for the operation.

c. Make, model, and serial or N

- Number of each UAS to be used. d. Name and certificate number of each UAS PIC involved in the operations

.10 e. A statement that the operator has obtained permission from property owners. Upon request, the operator will make available a list of those who gave permission. f. Signature of exemption holder or representative stating the plan is accurate.
g. A description of the flight activity, including maps or diagrams of the area over which operations will be conducted and the altitudes essential to accomplish the operation

In accordance with this exemption, the Plan of Activities and all other operating documents must b e accessible to the PIC during UAS operations. A new Plan of Activities must be submitted should there be any changes to items (a) through (g).

The above conditions and limitations are the same as those contained in the

Amended Cape Exemption . Collectivel y, these conditions and limitations, in combination with

requirements in Autel’s UAS Operations Manual, and the manufacturer’s manuals for the

selected UAS, ensure that the proposed UAS operations will not adversely affect safety and

will provide at least an equivalent level of safety to the rules from which exemption is sought.

5. REQUEST FOR DETERMIN ATION UNDER SECTION 333 OF FMRA

In accordance with FMRA Section 333, Autel requests that the Secretary of

Transportation determine that its proposed small UAS op erations (i) do not create a hazard

to users of the National Airspace System or the public, and (ii) do not pose a threat to

national security. Autel further requests that, based on the Secretary’s determination, the

FAA determine

– as it did in the Amend ed Cape Exemption

, Aeronautic Imagery Exemption

and the OpenSky Drones Exemption

– that relief from FAR Part 21 and any associated noise

certification and testing requirements of FAR Part 36 is not necessary for the UAS operations

proposed in this Petition

.

6. INFORMATION REQUIRED BY 14 C.F.R. § 11.81 TO SUPPORT A PETITIO N FOR
EXEMPTION

As required by FAR § 11.81, Autel provides the following information in support of

this Petition:

6.1 Contact information:

_____________ Name : Autel submits this Pet ition for Exemption, through counsel, Lisa Ellman and Matthew Clark.

_____________ Mailing address : Lisa Ellman11 Counsel for Autel Robotics USA, LLC Hogan Lovells US LLP 555 13 th Street, NW Washington, DC 20004

Telephone number : 202

- 637

- 6934 (Ellman) 703

- 610

- 6154 (Clark)

Facsimile number : 202

- 637

- 5910

E

- mail addresses : lisa.ellman@hoganlovells.com matt.clark@hoganlovells.com

6.2 The specific section or sections of the FAR from which Autel seeks an exemption:

FAR Description

§ 61.23(a) and (c) Medical certificates: Requirement and Duration.

§ 61. 101(e)(4) and (5) Recreational pilot privileges and limitations.

§ 61.113(a) and (b) Private pilot privileges and limitations: Pilot in command.

§ 61.315(a), (c)(2), and (c)(3) What are the privileges and limits of my sport pilot certificate?

§ 91.7 (a) Civil aircraft airworthiness.

§ 91.119(c), (d) Minimum safe altitudes: General.

§ 91.121 Altimeter settings.

§ 91.151 Fuel requirements for flight in VFR conditions.

§ 91.405(a) Maintenance required.

§ 91.407(a)(1) Operation after maintenance , preventive maintenance, rebuilding, and inspections.

§ 91.409(a)(1) and (2) Inspections.

91.417(a) and (b) Maintenance records.12 6.3 The extent of relief sought and the reason relief is sought:

Autel intends to conduct aerial data collection by operati ng the small UAS models

described herein. If granted, the proposed operations would allow Autel to conduct aerial

data collection, including outdoor research and development testing of Autel’s UAS

platforms, testing of newly refurbished UAS, product demon stration and marketing flights,

aerial photography / videography, aerial surveys, inspections, and mapping activities. The

proposed operations would also allow Autel to conduct UAS flights closer than 500 feet to,

but not directly over, people directly pa rticipating in the intended purposes of the operation,

in a controlled access environment, similar to a closed

- set, and consistent with the conditions

and limitations imposed by the FAA in the Amended Cape Exemption . Autel petitions the

FAA, pursuant to F AR §§ 11.61(b), 11.63(a), and 11.81(b), for an exemption from the

following FAR sections for the reasons noted:

FAR § 61.23(a) and (c)

- – Medical certificates: Requirement and Duration.

FAR § 61.101(e)(4) and (5)

– Recreational pilot privileges and limita tions.

The regulation states, in relevant part:

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

—

(4) For compensation or hire;

(5) In furtherance of a business; . .

. .
FAR § 61.113(a) and (b)

– Private pilot privileges and limitations: Pilot in command.

The regulation states, in relevant part:

(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 any business or employment if:
(1) The flight is only incidental to that business or employment; and
(2) The aircraft does not carry passengers or property for compensation or

____________ - hire.13 (c) ****.

FAR § 61.315(a) and (c)(2), (c)(3)

– What are the privileges and limitations of my sport pilot certificate?

The regulation states, in relevant part:

(a) If you hold a sport pilot certificate you may act as pilot in command of a light

- sport aircra ft, except as specified in paragraph (c) of this section. . . .

. . . .
(2) For compensation or hire.

(3) In furtherance of a business. . . .

Autel requests an exemption from these regulations to the extent necessary to permit

Autel to conduct UAS o perations using PICs who hold (i) an FAA private pilot, recreational

pilot, or a sport pilot certificate, and (ii) an FAA airman medical certificate or a state driver’s

license. While Autel recognizes that the FAA normally requires a PIC to hold a commerci al

pilot certificate where there is compensation either to the pilot or for the operation, Autel

requests that the FAA exempt Autel and its PICs from this requirement since the use of at

least a sport pilot as the PIC for the UAS operations under this exem ption will be more safe

than the use of a commercial pilot for manned aircraft operations. Unlike conventional

aircraft, Autel’s UAS are lightweight, remotely controlled, battery

- powered (not fuel/gas), and

carry no crew or passengers. The fulfillment of the additional requirements for a sport,

recreational or private pilot to become qualified as a commercial pilot would not lead to any

additional safety benefits when UAS operations are involved.

The differences between the aeronautical knowledge and ae ronautical experience

requirements for sport pilots and for commercial pilots are significant in the traditional world

of manned aircraft. However, no aspect of this incremental additional knowledge or

aeronautical experience is significant for the daytim e, VMC, low

- altitude, VLOS, small UAS

operations over private or controlled access properties with property owner/controller

permission as proposed in this Petition. Put another way, there are stark and fundamental

differences between the type of experien ce and aeronautical knowledge that the PIC of a14 commercial manned aircraft with passengers and property should have, versus the type of

experience and aeronautical knowledge that the PIC of a small UAS should have, in order to

avoid imperiling passengers o r property. In Autel’s case, the small amount of property

carried aboard the UA will be Autel’s property. While the PIC will be compensated, all risk of

damage to the property (in fact to the UAS itself) will be borne by Autel. There is no

expectation o r need for the PIC of the small UA to have the type of experience or

aeronautical knowledge that a commercial pilot for a manned aircraft would have. Similarly,

the differences between the flight proficiency requirements for sport pilots and commercial

pi lots are not substantively significant here where the operations will be conducted strictly

during daylight VMC conditions, within VLOS, at altitudes no higher than 400 feet AGL.

Accordingly, there is no reason to require the UAS PIC to have more aeronaut ical

knowledge, experience, and flight proficiency than that required for a sport pilot certificate.

Given that Autel plans to operate its UAS over private or controlled

- access property

and at low altitudes during daytime in VMC, the parallel nature of spo rt pilot aeronautical

knowledge requirements to those of commercial requirements, the limited airmanship skills

necessary to operate this small UAS, and the lack of additional safety benefits for the

proposed UAS operations here resulting from commercial p ilot experience, the PIC under

this exemption should only be required to hold, at most, a sport pilot certificate. Such a

condition would be consistent with the certificate requirements imposed on the PIC in the

Amended Cape Exemption

, Aeronautic Imagery Exemption and the OpenSky Drones

Exemption

.
For these reasons, and consistent with recent summary grant exemptions, Autel

requests that the FAA grant an exemption to permit Autel to use as PIC of its proposed UAS

operations pilots who hold at least a sport pilot certificate and either an FAA third

- class

airman medical certificate or a state driver’s license, so long as they satisfy the conditions

and limitations proposed in this Petition, including the PIC qualification and training

requirements.15 FAR § 91.7 (a)

– Civil aircraft airworthiness.

The regulation states in relevant part:

(a) No person may operate a civil aircraft unless it is in an airworthy condition. . . .

To the extent necessary for the proposed operations in this Petition, Autel requests

an e xemption from this provision. 5 The UAS will not require an airworthiness certificate

under FAR Part 21, Subpart H, and thus relief is requested from this regulation. See

Exemption No. 11110 (December 10, 2014; Docket FAA

- 2014

- 0367) (“ Trimble Exemption ”),

at 16. An exemption is warranted because Autel understands that, notwithstanding the lack

of an airworthiness certificate, the FAA will consider its “compliance with [Autel’s Manuals] to

be sufficient means for determining an airworthy condition” and tha t Autel must still

determine the UA’s airworthiness prior to each flight based on compliance with such

Manuals. Trimble Exemption , at 16.

FAR § 91.119(c) and (d)(1)

– Minimum safe altitudes: General.

The regulation states:

Except when necessary for take off or landing, no person may operate an aircraft below the following altitudes:

... (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obst acle 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 sparsely 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 operation 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 specifically prescribed for helicopters by the FAA; and

...

5 Autel requests exempti on from FAR § 91.7(a) based on the relief granted in the Trimble Exemption , at 16, 21. However, Autel notes that the FAA determined that no such exemption was needed in Exemption No. 11062 (September 25, 2014; Docket FAA

- 2014

- 0352) (“ Astraeus Exemption ”) at 19, 22.16 Autel requests an exemption from this reg ulation to the extent necessary to permit it

to conduct UAS operations at altitudes lower than those permitted by FAR § 91.119, since

the ability to operate at those altitudes are one of the key benefits of using small UAS for

these flights. Even at these low altitudes, Autel’s UAS operations will be conducted at a level

of safety at least equal to that which would be achieved if larger manned aircraft were to be

used at the altitudes required by FAR § 91.119.

With respect to paragraph (a), Autel intends to comply with this requirement to the

same extent as would a manned aircraft, meaning that the UA must operate at an altitude

such that the loss of a single power unit aboard the UA or used by the UAS would still permit

an emergency landing “without undue hazard to persons or property on the surface.” Autel

agrees with the FAA’s reasoning on this issue in the Astraeus Exemption , at 20, and

therefore does not believe that relief is required from paragraph (a).

Regarding paragraph (b), Autel plans to oper ate these small UAS over properties

that Autel owns or controls and other private or controlled

- access properties (with

owner/controller permission) in areas that are not congested or densely populated.

Accordingly, Autel does not believe that an exemptio n is necessary from this paragraph (b)

covering “congested areas”.

Finally, with respect to paragraph (c), Autel requests an exemption to allow UAS

operations down to the surface, both in sparsely populated areas and in “ other than

congested ” areas. Aut el’s UAS operations require lower

- level flying, but have a number of

self

- imposed restrictions to ensure at least an equivalent level of safety.

Even with a grant of this exemption, the UAS operations will be at least as safe as

operations by manned aircr aft that comply with this paragraph. Flying a manned aircraft,

given its weight, size, speed, and fuel load, would pose a significant risk relative to the use of

a small UA, with a much smaller size and lighter weight, operating at much slower speeds,

wit h batteries rather than a significant fuel load, at all times within VLOS of the PIC on the

ground who has a wide view. Accordingly, as the FAA determined in the Trimble Exemption

,17 at 17

- 18, relief is warranted here provided that Autel adheres to its Manu als and the

conditions and limitations proposed herein. For these reasons, Autel requests relief from the

entirety of paragraph (c), as was recently granted in the Aeronautic Imagery Exemption , at 2,

and the OpenSky Drones Exemption , at 2.

To the extent n ecessary, Autel also requests relief from paragraph (d)(1), which

applies only to helicopters and allows operation at lower altitudes only if on a prescribed

helicopter route. Flying a manned helicopter would pose a significantly greater risk than

using a small UA for the proposed operations, even if the helicopter is on a specific route or

at a specific low altitude prescribed by the FAA. A manned helicopter is much heavier,

larger, and faster than a small UA. Moreover, unlike Autel’s small UA, the heli copter has

people on

- board and a fuel load. The operation of a small UA at all times within the VLOS of

the PIC on the ground would be at least as safe as a manned helicopter operation operating

in conformity with the requirements of paragraph (d)(1), and therefore an exemption from

Section 91.119(d)(1) is warranted.

FAR § 91.121

– Altimeter settings.

The regulation states, in relevant part:

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

—

(1) Below 18,000 feet MSL, to

—

(ii) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no statio n within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an ap propriate altimeter setting available before departure; or

(2) At or above 18,000 feet MSL, to 29.92 ′′ Hg.

(b) * * * *.18 To the extent necessary to conduct the proposed operations, Autel requests an

exemption from the altimeter setting requirements of FAR § 91.121. Autel recognizes the

critical importance of ensuring that any UA it operates maintains altitude to an accurate

reference point. The PIC will check the UA altitude reading prior to each takeoff, and will

effectively zero the UA’s altitude a t the point of takeoff, to ensure that measurements of the

UA’s altitude are as accurate as possible relative to the local elevation. To the extent that

this methodology does not satisfy FAR § 91.121 or any other regulation, Autel requests an

exemption to permit UAS operations using this methodology.

FAR § 91.151

– Fuel requirements for flight in VFR conditions.

The regulation states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather condit ions) 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 fly after that for at least 45 minutes.

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 min utes.

Autel requests an exemption from FAR § 91.151’s fuel requirements for flight in VFR

conditions. Technological and durational limitations on UAS battery power means that no

meaningful flight operations can be conducted while still maintaining a 30

- minute battery

reserve. An exemption from the fuel requirements of FAR § 91.151 is therefore required.

The FAA has previously granted relief from the fuel requirements of § 91.151(a) for flight in

daytime VFR conditions in circumstances similar to those presented in this Petition for

Exemption. See e.g.
, Aeronautic Imagery Exemption Limitation No. 20 and OpenSky Drones

Exemption Limitation No. 20.

In the OpenSky Drones Exemption , the FAA determined that a requirement

prohibiting the PIC from beginning a UAS flight unless (considering wind and forecast

weather conditions) there was enough available power for UAS to operate for the intended19 operational time and to operate after that for at least five minutes or with the reserve power

recommended by the manu facturer if greater, would ensure an equivalent level of safety to

the fuel requirements of FAR § 91.151. Autel will adhere to the same reserve power

condition and limitation and an exemption from FAR § 91.151’s fuel requirements for flight in

VFR conditi ons is therefore appropriate.

FAR § 91.405(a)

– Maintenance required.

The regulation states, in relevant part:

Each owner or operator of an aircraft

—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between re quired inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter;

(b) ****.

Autel requests an exemption from the maintenance and inspection requirements of

FAR § 91.405(a). In the Astraeus Exemption and the Trimble Exemption

, the FAA

determined that the proposed UAS operations required exemption from FAR § 91.405(a),

and that the achievement of an adequate level of safety required certain conditions and

limitations. Autel has p roposed several conditions and limitations related to maintenance

and inspections which it believes provide a level of safety at least equivalent to that provided

by FAR § 91.405(a). For this reason, and consistent with the exemptions granted from this

se ction in the Aeronautic Imagery Exemption and the OpenSky Drones Exemption , Autel

requests an exemption from FAR § 91.405(a) to permit Autel to conduct UAS operations as

proposed in this Petition, subject to the conditions and limitations proposed above, w ithout

having to perform the inspections and discrepancy repairs required by FAR § 91.405(a).

Autel does not believe that an exemption from the remaining paragraphs of FAR §

91.405 is required, since Autel will make appropriate logbook entries in aircraft maintenance

records in accordance with paragraph (b), appropriately mark any inoperative instrument or

item of equipment for which maintenance has been properly deferred in compliance with20 paragraph (c), and appropriately placard listed discrepancies that include inoperative

instruments or equipment in compliance with paragraph (d).

FAR § 91.407(a)(1)

– Operation after maintenance, preventive maintenance, rebuilding or alteration.

The regulation states:

(a) No person may operate any aircraft that has un dergone maintenance, preventive maintenance, rebuilding, or alteration unless

—

(1) It has been approved for return to service by a person authorized under §43.7 of this chapter; and

(2) The maintenance record entry required by §43.9 or §43.11, as appli cable, of this chapter has been made.

. . . .
Autel requests an exemption from FAR § 91.407(a)(1) to allow the proposed

operations without having to have the UAS approved for return to service by a person

authorized under FAR § 43.7. In the Astraeus Ex emption

, the FAA determined that the

proposed UAS operations required exemption from FAR § 91.407(a)(1), subject to certain

conditions and limitations

. Autel has proposed in this Petition maintenance

- related

conditions and limitations which it believes pr ovide a level of safety at least equivalent to that

provided by FAR § 91.407(a)(1). For this reason, and consistent with the exemptions

granted from this section in the Aeronautic Imagery Exemption and the OpenSky Drones

Exemption , Autel requests an exemp tion from FAR § 91.407(a)(1) to permit Autel to conduct

UAS operations as proposed in this Petition, subject to the proposed conditions and

limitations, without having to have the UAS approved for return to service by a person

authorized under FAR § 43.7.

Autel does not believe that an exemption from the remaining paragraphs of FAR §

91.407 is required, since Autel will require that maintenance record entries are made as

required, in compliance with paragraph (a)(2), and since no persons will be carried fol lowing

maintenance performed on the UAS, making paragraphs (b) and (c) moot.21 FAR § 91.409(a)(1) and (2)

– Inspections.

The regulation states, in relevant part:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft un less, 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 by a person authorized by §43.7 of this chapter; or

(2) An inspection for the iss uance of an airworthiness certificate in accordance with part 21 of this chapter.

No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records.

(b)  .

Autel requests an exemption from the inspection requirements of FAR § 91.409(a)(1)

and (2). In the Astraeus Exemption , the FAA determine d that the proposed UAS operations

required exemption from FAR § 91.409(a)(1) and (2), and that achieving an adequate level of

safety required certain conditions and limitations. Autel has proposed in this Petition

maintenance and inspection

- related condi tions and limitations which it believes provide a

level of safety at least equivalent to that provided by FAR § 91.409(a)(1) and (2). For this

reason, and consistent with the exemptions granted from this section in the Aeronautic

Imagery Exemption and the OpenSky Drones Exemption , Autel requests an exemption to

permit Autel to conduct UAS operations as proposed in this Petition, subject to the conditions

and limitations outlined herein, without having to comply with the inspection requirements in

FAR § 91. 409(a)(1) and (2).

FAR § 91.417(a) and (b)

– Maintenance records.

The regulation states, in relevant part:

(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 p eriods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (inc luding the airframe) and22 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 appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basi s.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness direct ives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision 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 by §43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

______ prescribe d:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year 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 operator under §43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

(c) ** **.23 Autel requests an exemption from the maintenance record requirements in FAR §

91.417(a) and (b). The FAA determined in the Astraeus Exemption that the proposed UAS

operations required exemption from FAR § 91.417(a) and (b), and that an adequate level of

safety required certain conditions and limitations. Autel has proposed in this Petition

maintenance, inspection, and records

- related conditions and limitations which it believes

provide a level of safety at least equivalent to that provided by FAR § 91.417(a) and (b). For

this reason, and consistent with the exemptions granted from this section in the Aeronautic

Imagery Exemption and the OpenSky Drones Exemption , Autel requests an exemption from

FAR § 91.417(a) and (b) to al low the proposed operations, subject to the conditions and

limitations outlined herein, without having to keep the records described in FAR § 91.417(a)

and (b).

6.4 Exemption request catch

- all provision

This Petition does not seek exemption from certain reg ulations based on the

reasoning and analysis in prior FAA grants of exemption. To the extent that the FAA

concludes that an exemption from one or more other provisions of the FAR would be

required to allow the proposed operations in this Petition, Autel a lso seeks an exemption

from those FAR provisions.

6.5 Reasons why granting the request would be in the public interest:

The public interest will be served in several ways by granting Autel’s Petition. First,

Congress has established a national policy that favors early integration of UAS into the

National Airspace System in controlled, safe working environments such as those proposed

in this Petition. Granting this Petition helps fulfill Congress’ goal in passing Section 333(a)

through (c) of the FMRA; namel y, the FAA Administrator's assessment of whether certain

UAS may operate safely in the NAS before completion of the rulemaking required under

Section 332 of the FMRA.

The proposed UAS operations in this Petition will also improve safety and reduce risk

by reducing the public’s exposure to danger associated with aerial data collection activities24 utilizing full

- size fixed

- wing aircraft and rotorcraft. Most of the UAS Autel intends to use for

the proposed operations are battery

- powered and create no emissions , as compared to the

much faster, larger, and fuel

- powered manned aircraft. Any accident involving Autel’s

lightweight UAS will present significantly less danger to the pilot and other individuals on the

ground than one involving a full

- size helicopter or fixed

- wing aircraft.

6.6 Reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which exemption is sought:

Throughout this Petition, Autel has discussed how it will ensure the safety of other

manned aircraft and persons and property on the ground if the FAA grants the requested

exemption. Consistent with the FAA’s findings in previously granted exemptions, the

conditions and limitations propose d in this Petition, coupled with the operational protocols for

the selected UAS platforms, and, when applicable, the requirements of Autel’s UAS

Operations Manual, ensure a level of safety that is equal to or better than that provided by

the rules from whi ch exemption is sought.

In general, the risks of any small UAS operation proposed in this Petition interfering

with a manned aircraft would be minimized by numerous factors, including but not limited to:

• the low altitude at which the UAS would operate;

• the locations at which the UAS would operate (e.g., remote areas; private or controlled access property; away from airports);

• the small size, light weight, and relatively slow speed of Autel’s UAS;

• the restriction on UAS operations to VMC and daytime c onditions; and

• the requirement for the UA to be operated within VLOS of the PIC and VO at all times.

Moreover, Autel’s UAS have the capability to operate safely after experiencing

certain in

- flight contingencies or failures, and they use an auto

- pilot system to maintain UAS

stability and control. The UAS are also able to respond to a loss of GPS or a lost

- link event

with a pre

- coordinated, predictable, automated flight maneuver. These safety features25 provide an equivalent level of safety compared to a manned aircraft performing a similar

operation and mitigate the risk of command and control link failures.

The risks to persons or property on the ground would be substantially mitigated

– if

not eliminated

– by these same factors, as well as the 500

- foot set

- off from non

- participating

persons, vehicles, and structures absent additional safeguards. Per the conditions and

limitations proposed in this Petition, (i) the PIC will suspend/abort the UAS operation and UA

flight in the event of unpredicted obstacl es or emergencies in accordance with the Manuals;

and (ii) Autel will coordinate extensively, as warranted, with the FAA, with local airports, and

with property owners to ensure that all UAS operations under the exemption are at least as

safe as would be m anned aircraft operations used for similar purposes.

Consistent with the FAA’s findings and analysis in the Amended Cape Exemption

,
the operational safety measures required by Autel’s UAS Operations Manual will mitigate the

risks associated with operating UAS closer than 500 feet to, but not over, consenting Autel

customers who are directly participating in the intended purposes of the operation. 6 These

6 The proposed operations are also consistent with the FAA’s Grant of Amendment to Kansas State University, Exemption No. 13465A (November 20, 2015; Docket FAA

- 2014

- 1088 (“ Amended Kansas State Exemption ”):

“Additionally, the FAA recognizes that there are additional risks when operating a UA close to people, whether for the purpose of closed

- set filming or otherwise. As such the FAA has determined that when conducting these types of operations, the operator must have an operations manual addressi ng the items as specified in the conditions and limitations below. Unmanned aircraft operations conducted in close proximity to people (less than 500 feet) invoke added safety risks. Regardless of the operation type (closed set film

- making or other operati on types), the operations manual requirement helps ensure that safety will not be adversely affected because the operator must document and address operational safety practices relevant to its operation . An operations manual must include items such as; the operator’s contact information, distribution and revision information, persons authorized, plan of activities, permission to operate, security methodology, briefing instructions, essential flight personnel minimum requirements, communications information, and accident notification plan. Documented operational safety practices and procedures help ensure a safe and repeatable process for conducting flight operations. Formal procedures ensure adequate safety guidelines are available and adhered to in normal o perational environments, but also during emergency circumstances. The operations manual is considered part of the operating documents and must be accessible to the PIC during operations. This operations manual is based on the requirement in previous exempt ions for a MPTOM for closed

- set filming. (emphasis added)” Amended Kansas State Exemption at 13.26 flights will occur in a controlled access environment, similar to a closed

- set, which prevents

unauthor ized people from entering the flight / filming area. As required by proposed

condition and limitation no. 28, Autel’s UAS Operations Manual includes, among other

things, requirements to develop a written Plan of Activities, a security plan to ensure the

s afety of nonparticipating persons, communication procedures for participants, and briefing

procedures for persons directly participating in the intended purpose of the operation.

The conditions and limitations proposed in this Petition, which are identi cal to those

imposed in the Amended Cape Exemption , the operational safety features of the selected

UAS platforms, and the requirements of Autel’s UAS Operations Manual ensure that the

proposed operations will not interfere with manned aircraft and will en sure the safety of

persons and property on the ground. For these reasons, granting an exemption from each

section of the FAR from which relief is sought would not adversely affect safety, and would

provide a level of safety at least equal to, or greater th an, that provided by the rule from

which exemption is sought.

6.7 Summary that can be published in Federal Register, including the rule from which exemption is sought, and a brief description of the nature of the exemption sought:

Autel proposes that the FAA use the following as the summary:

Docket No. : FAA

- 2016

-

______

Petitioner: Autel Robotics USA, LLC

Sections of 14 CFR: 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.315(a), (c)(2), and (c)(3), 91.7(a), 91.119(c) and (d)(1), 91.121, 91.1 51, 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b).

Description of Relief Sought: Petitioner seeks an exemption to conduct small UAS operations for aerial data collection.27 6.8 Additional information that supports request:

Autel is prep ared to provide additional information that the FAA might find helpful, or

to answer questions in response to any FAA requests.

6.9 Request to exercise the privileges of the exemption outside the U.S.:

Autel does not request to exercise the privileges of th is exemption outside the United

States.

6.10 Attachments:

A list of previously approved vehicles from Attachment 1 and Attachment 2 of the

Amended Measure Exemption that Autel may operate under the requested exemption is

attached as Appendix A . Details on spec ifications and operating capabilities of the Autel

Robotics X

- Star, X

- Star Go and X

- Star Premium as Appendix B . Autel will also submit UAS

Operations Manual as a confidential document under separate cover pursuant to 14 C.F.R. §

11.35(b), as the material contain confidential commercial and proprietary information that

Autel has not and will not share with others. The information contained in the Operations

Manual is not generally available to the public and is protected from release under the

Freedom of In formation Act, 5 U.S.C. § 552 et seq

.

7. CONCLUSION

For the foregoing reasons, Autel respectfully requests that the FAA grant this Petition

for Exemption. Should you have any questions, or if you need additional information to

support the Autel’s Petition fo r Exemption, please do hesitate to contact the undersigned.

Respectfully submitted,

Lisa Ellman Matthew J. Clark 7

7 Matthew Clark is only licensed to practice law in the Commonwealth of Virginia and his practice is limited consistent with Rule 49(c) of the D.C. Court of Appeals.28 Hogan Lovells US LLP

Counsel for Autel Robotics USA, LLC29 Appendix A



### Attachment 1

1. 3D Robotics Aero

- M or Aero

- M 2. 3D Robotics Iris
3. 3D Robotics Iris+ 4. 3D Robotics X8
1. 3DRobotics Fixed Wing 2. 3DRobotics Multirotor
3. 3DRobotics Quadrotor 4. 3DRobotics Spektre or 3D Robotics Spektre Industrial Multi

- Rotor Aerial Vehicle
5. 3D Robotics Solo or 3DR Solo 6. 3DRobotics X8+
7. 3D Robotics X8

- M or X8

- M 8. 3D Robotics Y6
9. Aerial Mob Heavy Lifter 10. Aerial Mob Light Lifter
11. Aerial Remote Mineral Detection System (ARMDS) 12. Aerialtronics Altura Zenith ATX8 or Aerialtronics Zenith with integrated Airware system 13. Aerigon
14. Aerobo 15. AeroCine Kopterworx Hammer X12 or Kopt erworx Hammer X12 16. AeroLogix GeoStar 17. Aeromao AeroMapper 300 18. Aeromao Talon 19. Aeromao Aeromapper EV

- 2 20. AeroVironment Shrike or Shrike 21. AeroVironment Puma or Puma AE DDL
22. Aerovironment Qube 23. Aeronavics X4 Titanium
24. Aervonics Sky Jib 25. Aeryon Scout 26. Aeryon SkyRanger or A eryon Sky Ranger 27. AgEagle
28. AgEagle Robotic 29. AgScout 30. AgScout Mini 31. Agribotix Hornet Drone
32. Agribotix Enduro Quad 33. AgriView VK Ranger EX or Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX or VK

- Ranger EX

- SAR Fixed Wing UAS 34. Aibotix Aibot X

- 6 or Aibot
35. Ai r Rover AR

- 300 36. AirCover QR

- 425s30 

### 37. AirRobot AR 180
38. AirRobot AR 100 39. AirRobot AR200
40. Air

- X 41. Align M690
42. Altavian Nova F6500 43. Altavian Nova R8400
44. Altus X

- 4 45. Altus X

- 8 46. American Drones, LLC Eagle 47. Apprentice
48. Arch Aerial OCTO multi

- rotor UAS 49. Arris hexacoper
50. AR

- 960 Hex Rotor 51. AR

- 540 Quad Rotor
52. ARF

- MikroKopter OktoXL 53. ARF

- MikroKopter OktoXL 6S12
54. ArrowLite
55. AscTec Falcon 8 or AscTec Falcon
56. Astraeus Aerial Cinema System V.3CS
57. Atlantic RC Aircraft LC047
58. Auburn War Eagle 59. Auburn EasyStar
60. AV44 61. Birdseyeview Firefly 6 or Fire Fly 6
62. Blade 350QX 63. Bixler 2
64. Boomerang Carbon Fiber Frame 65. Bormatec Maja UAV
66. BOSH Technologies Super Swiper 67. Bumblebee

- S 68. C

- Astral Bramor gEO 69. CarbonCore Octocopter 1000
70. Carbon Core Cortex Quadcopter 71. CCO w/Wkm M
72. Cinestar 6 73. Cinestar X8
74. Cinestar 8
75. Cinestar 8 HL
76. Cinestar 8 Okto XL
77. Coaxial Quad Multirotor VAO1

- V1 78. Coaxial Quad Multirotor VAO2

- V2 79. CopelandRED LLC Delta Wing Aircraft
80. CyberQuad Maxi31 

### 81. DJI Flame Wheel F450 or DJI F

- 450
82. DJI Flame Wheel F550 83. DAx8 84. DJI Inspire 85. DJI Inspire 1or DJI Inspire T600 or Q1
86. DJI Inspire 2 87. DJI Phantom
88. DJI Phantom 1 89. DJI Phantom 2
90. DJI Phantom 2+ 91. DJI Phantom 2 Vision
92. DJI Phantom 2 Vision+ 93. DJI Phantom Vision +
94. DJI Phantom 3 95. DJI Phantom FC40
96. DJI Spreading Wings S900 97. DJI Spreading Wings S1000
98. DJI Spreading Wings S1000+ 99. DJI S800 100. DJI S800 EVO 101. Draganfly er Guardian
102. Draganflyer X4ES 103. Draganflyer X4P
104. Draganflyer X6 105. DT

- 18 106. DYS D800

- X8 107. Eagle VTOL
108. E

- Flite Apprentice 109. Event 38 E384 110. Falcon VTOL 111. First Aerial Responder

- Sight
112. Flame Wheel G4 7.8 Skycrane or Multirotor G4 7.8 Skycrane 113. Flying

- Cam 3.0 SARAH 114. Foxtech Krak en 130 V2 or K130 Octocopter 115. FreeFly Systems ALTA RTF
116. G4 Eagle 117. GerMAP G220 118. GerMAP G180 119. goFarm GF

- 1 120. Gryphon Dynamics X8 121. GT80X 122. Harris 18 HL 123. HEFF 124. Helios 96032 

### 125. HexaCrafter HC

- 1100
126. HexaCrafter HO

- 1250 127. HH Blade 350QX2 AP
128. Hobbyking “Bixler” Fixed Wing Trainer 129. Hon eyComb AgDrone
130. Hoverfly LiveSky 131. Hoverfly BigSky 60
132. Hoverfly H

- Frame 133. Hubsan X4 micro drone
134. HVP 14301 Multi Rotor 135. InovalDrone:Inova One
136. InspecTools X

- 8 or ITX8 137. InstantEye Mk

- 2 138. InstantEye Mk

- 2 Gen2 139. Intuitive Aerial Aeragon
140. KongCopter X8 141. Latitude HQ

- 4 Hybrid M ultirotor
142. LB700 143. Leading Edge Precision Vision 10
144. Leptron Avenger 145. Lewis Realty Associates Hexacopter 650
146. Liberty 1 147. Lockheed Martin Desert Hawk III
148. Lockheed Martin Indago or Indago 149. MaxFlight
150. MD4

- 200 151. MD4

- 1000 or Frame Ronin Edition Microdrones:MD4

- 1000 152. Mikrok opter 2.5 153. MLB Company Super Bat 154. MU

- 1H 155. Multirotor G4 7.8 Skycrane
156. Nighthawk VTOL or Nighthawk 157. PAG X4 158. Parkzone Radian RTF 159. Parrot Bebop drone
160. Parrot PF 725100 Bebop Drone 14MP 161. Patriot X4
162. Patriot X8 163. Finwing Penguin V2
164. Phoenix VTOL or Phoenix 165. Phoenix 60
166. Phoenix 60LE 167. Pinnacl X Chameleon Pro
168. Precision Drone Pacesetter33 

### 169. PrecisionHawk
170. PrecisionHawk Hawkeye Mk

- III or Hawkeye Mk

- III 171. PrecisionHawk Lancaster
172. Precision Lancaster MK3 173. Prioria Hex
174. Prioria’s Maveric 175. Pulse Aerospace, PA 01 Vapor
176. Pulse Aerospace Pulse Vapor 3 5 177. Pulse Vapor
178. PV 14817 Multi Rotor 179. PV HL1 180. PV HL2 181. Quadcopter LLC MikroKopter
182. Quiet UAV 183. R/C Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & Octo Heavy Lift Prof. Multi Rotor 184. RCTimer Hexacopter
185. RDASS 186. REHawk 500
187. REHawk 680 188. Roboflight RF

- 70 189. Riegl RiCo pter 190. RITEWING Z3 Spade 47”
191. Ritewing Drake 60” 192. RITEWING Z3 Spade 70”
193. RITEWING Z4 Spade 52” 194. Rotomotion SR

- 15 195. RV Jet 196. Scout X4 197. SD02 198. Seahawk 1.2
199. SelectTech Geospacial’s EH

- 4 200. SenseFly eBee
201. SenseFly eBee RTK 202. SenseFly eXom
203. Sensurion Magpie MP

- 1 204. Service

- Drone Recon One 205. Service

- Drone Blackbird 206. SH 900 207. ShadowHawk 208. Sirius
209. SkyCatch 210. SkyJib 8 v.2 Heavy Lifter
211. SkyPhilly M134 

### 212. Skywalker Aero
213. Skywalker Flying Wing X8 214. SnapRoll Media SUAS
215. Solutions Phoenix 30 216. SteadiDrone
217. Steadidrone QU4D 218. Steadidrone Mavrik
219. SuperX/P2 Multirotor 220. Sw ift Radioplanes Lynx
221. Tali 500 222. Talon 120LE
223. Tarot FY690S Hexacopter 224. Tarot quadcopter
225. Tarot 680pro 226. Tarot 690 227. Tarot 900 228. Tarot 960 229. Tarot T

- 15 or Tarot T15 C/F Folding Octocopter 230. Tarot T18 UAV 231. Tarot T810 232. Tarsier Systems MoAC
233. Tayzu Robotics Titan X8 234. Team Black Sh eep Discovery Pro or TBS Discovery Pro
235. T

- Rex 700E F3C 236. TREX 800E DFC PRO 237. Trimble UX5 238. Trimble UX5 hp
239. Trimble ZX5 240. Turnigy Talon 500
241. TUP X8

- 800 242. Turbo Ace CINEWING 6
243. TurboAce Matrix

- G quadcopter 244. Turbo Ace matrix

- E 245. Turbo Ace MATRIX

- 1 246. UAV Solutions Phoenix 60
247. Uni verseye Penguin 248. Unmanned Flying Rolling Orb “UFRO”
249. US2 GreenHawk 250. VA03

- v1 251. VA04

- v1 252. VA07

- v1 253. Viking UAS Multicopter (VTOL) 254. Viking UAS FF

- X4/X8 or VK

- Patriot X4/X8 or Viking VK

- FF

- X4 255. VK

- Patriot X4/X835 

### 256. Viking UAS Patriot X4/X8 Multirotor
257. Viking UAS X6 Model 800 258. Viking UAS Viking ONE
259. VK

- 450 260. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX
261. Viking VK

- FF

- X4 262. Volantex Raptor
263. Volt Aerial Robotics Octane 264. Vulcan frame controlled by a DJI A2 flight controller
265. Vulcan Mantis 266. Vulcan Raven
267. Walkera TALI H500 or Tali 5 00 268. Walkera Scout X4 or Scout X4
269. Wookong DJI 5800 270. xCel Drones XD550CDR
271. xFold Cinema 272. XFold Rig with four configurations: Quadcopter, Hexcopter, Octocopter and x12 Copter36 

### Attachment 2

1. A2Tech RV

- 02 2. Adaptive Flight, Inc. Hornet Maxi 3. Advanced UAV Technology AT

- 100 4. Aero Composites Innovations R^2 / AS 20
5. Aero Composites Innovations V 250
6. Aerocon Inspector

- 201
7. Aerocon Inspector

- 301 8. Aeroland UAV, Inc. AL

- 4 9. Aeronautics Defense Systems Orbiter I
10. Aeronautics Defense Systems Orbiter II 11. AeroTactix Ltd. Skyzer 100
12. AeroT actix Ltd. Skyzer 450 13. Aerotekniikka UAV Oy M

- 011 14. Aeroterrascan Indonesia Ai

- 450 15. AeroVironment RQ

- 11A Raven 16. AeroVironment RQ

- 11B Raven 17. AeroVironment RQ

- 14A DragonEye 18. AGX Tecnologia Ltda Tiriba 19. AiDrones, GmbH AiD

- H14 20. Airbus Defence and Space DVF 2000 (aka CA RD) 21. Airbus Defence and Space Tracker (formerly DRAC)
22. Albatross Applied Aeronautics 23. Alcore Technologies Azimut 2
24. Alcore Technologies Biodrone 25. Allied Drones AW1 EOS
26. Alpha Unmanned Systems Commando 27. Alpi Aviation Strix
28. Altavian, Inc. Condor 29. Altavian, Inc. Nova Block III
30. Applewhite Aero Jago B 31. Applewhite Aero MILO
32. Applied Research, Inc. Mantra Bihrle 33. ARCTURUS UAV T

- 15e (JUMP 15)
34. AttoPilot, LLC Devil Ray 35. AttoPilot, LLC Jackaroo
36. AttoPilot, LLC Mini Devil Ray 37. AttoPilot, LLC. Foamaroo
38. Aurora Flight Sciences Corporat ion Skate SUAS 39. Aurora Integrated Systems Urban View
40. Autonomous Flight Technologies HIRRUS 41. Baykar Makina Malazgirt
42. Beijing Always Flying Technology Co., Ltd Free Bird37 

### 43. Beijing Always Flying Technology Co., Ltd Single Soldier I
44. Beijing Chunyi Aviation Techn ology Co., Ltd. CY

- 01H Huaying 45. Beijing Chunyi Aviation Technology Co., Ltd. CY

- 01V Huaying 46. Beijing Chunyi Aviation Technology Co., Ltd. CY

- 04 Raven 47. Beijing Creaton Tech Co., Ltd.T10 Hornet 48. Beijing Creaton Tech Co., Ltd.T10S
49. Beijing Creaton Tech Co., Ltd.T1 5 50. Beijing Creaton Tech Co., Ltd.T20 51. Beijing Creaton Tech Co., Ltd.T

- EZ 52. Beijing Pilotless UAV Technology Co., Ltd PLT05. 53. BlueBird Aero Systems MicroB
54. BlueBird Aero Systems SpyLite
55. BlueBird Aero Systems WanderB
56. Bonn Hungary Electronics Ltd. BXAP15
57. Bormatec M AJA 58. BOSH Technologies Condor/Condor A 59. BOSH Technologies Swiper
60. Brandebury Tool Company, Inc. Scythe 61. Brican Flight Systems, Inc. TD100E
62. Brock Technologies, Inc. BT20 EEL 63. Brock Technologies, Inc. SPEAR
64. Carbon

- Based Technology, Inc. Avian 65. C

- ASTRAL, Inc. Bramo r C4EYE 66. CATUAV Argos Electric 67. CATUAV Atmos

- 6 68. Chuguev Aircraft Repair Plant Strepet

- LK 69. CiS GmbH Ikarus
70. Codarra Advanced Systems AVATAR 71. Composites Technology Research Malaysia Sdn. Bhd ALUDRA SR

- 08 72. Cranfield Aerospace Cassius 73. CyberFlight CyberEye I
74. CyberFlig ht E

- Swift Eye
75. CyberFlight Zygo
76. Defence Research and Development Organisation Imperial Eagle
77. Defence Research and Development Organisation Slybird A
78. Defence Research and Development Organisation Slybird B 79. Delair

- Tech DT

- 26 80. Dragonfly Pictures, Inc.DP

- 6XT Wh isper 81. Drone America, Inc. Muninn
82. Drone Aviation Corp WATT

- 200 83. DroneMetrex Pty, Ltd.TopoDrone

- 100 84. Dronetech, LLC.AV

- 2 Pelican 85. Dutch Space BV Man

- Portable Aerial Terrain Explorer (MATE)
86. Echar 20A XMobots Robotics Systems38 

### 87. Ejercito de Chile Lascar
88. Elbit Syst ems Skylark 1

- LE 89. ELIMCO E100 90. ELIMCO E200 Scan 91. ELIMCO E300 Viewer
92. Embention W200 93. ENICS JSC T10E "Eleron

- 10" 94. ENICS JSC T23E "Eleron

- 3" 95. EXPACE SHEPHERD 96. EXPACE SHEPHERD

- MIL 97. Falcon UAV Falcon UAV
98. Fiberflight Systems S.L.Victor Mk II 99. Fiberflight Systems S.L.Vict or Mk III
100. Fibre Flight Ltd. SENTINEL 101. Flying Production, Ltd.Da Vinci
102. Fly

- N

- Sense Seeker 1300 103. FlyTop Srl FlyMax
104. FlyTop Srl FlySecur 105. Fuji Imvac Inc. D

- 5 106. GeoScan GeoScan 101 107. GeoScan GeoScan 201 108. GeoScan GeoScan 401 109. Global Flight Systems Eos

- alpha
110. Global Flight Systems Eos

- beta 111. Global Teknik Havacilik GLOBIHA
112. GreenX Bald Eagle 113. Guangzhou Walkera Technology Co. LTD QR X800
114. Guided Systems Technologies, Inc.SiCX

- 12 115. Hanseatic Aviation Solutions GmbH S180Mk.2
116. Hawkeye UAV RQ

- 84Z AreoHawk 117. Hobby UAV Techpod
118. Autels Aerial Technologies KIWITWide 119. Ideon BSK Defense
120. IDETEC Unmanned Systems Stardust II 121. IDS Ingegneria Dei Sistemi S.p.A. IA

- 17C Manta 122. INDRA SISTEMAS SA Mantis 123. Ingenieurgesellschaft ALADIN EMT
124. Innocon MicroFalcon LP 125. Innocon Spider
126. Instytut Techniczny Wojsk Lotniczyc h Nietoperz

- 3L (Bat

- 3L) 127. Integrated Dynamics Spirit
128. Irkut Irkut

- 2M 129. Irkut Irkut

- 3 130. Israel Aerospace Industries Bird Eye 40039 

### 131. Israel Aerospace Industries Bird Eye 650
132. Kadet Defence Systems FireBee 133. KWT

- X6L 134. Lockheed Martin Corporation Stalker 135. Lockheed Martin Co rporation Stalker XE (eXtreme Endurance)
136. Luch Design Bureau / KB Lutch Swallow 137. Marcus UAV Zephyr 2
138. Maryland Aerospace, Inc.VectorWing 100 139. MAVTech Microhawk MH850
140. Mission Technology Systems, LLC. Blacklight (E

- BUSTER) 141. MKU Pvt. Ltd. TERP

- 2 142. NELK Lapwing 143. North ern Virginia OmniVersatile Solutions NVOS UAV (N

- Cognito)
144. Nostromo Defensa Cabure 145. Nostromo Defensa Centinela
146. Nostromo Defensa Yagua 147. OJSC Grusha Izhmash
148. OM UAV Systems Baaz 149. Optimum Solutions Condor 300
150. Oto Melara SPA Oto

- Horus 151. Patria Oy MASS Mini

- UAV 152. QuestU AV Ltd.QuestUAV 300 153. Raytheon Company Coyote
154. Reference Technologies, Inc. HUMMINGBIRD I 155. RoboFlight Systems, Inc.RF70
156. Robota, LLC. Supernova 157. Robota, LLC. Triton
158. Rotomotion, LLC SR 20 159. RP Flight Systems Spectra SkyCamo
160. Santos Lab Orbis 161. Selex ES S.p.A Crex

- B 162. Se nsintel Silver Fox 163. Sierra Pacific Innocations E2 Micro

- UAV 164. Silent Falcon UAS Technologies Silent Falcon 165. Singapore Technologies Aerospace Skyblade III
166. Siralab Robotics S.r.l. H3 167. Skycam UAV NZ Limited Kahu
168. SmartPlanes AB Personal Area Mapping System (PAMS) 169. S martPlanes AB SmartOneC
170. Surveillance and Target Unmanned Aircraft Stingray 171. Surveillance and Target Unmanned Aircraft Stingray
172. SurVoyeur mk

- II 173. Swallow Systems Skimmer MK

- I 174. Swallow Systems Skimmer MK

- II40 

### 175. System Consultancy Services AGAS 2.0
176. Tasuma (UK) Ltd. CSV

- 15 177. Tasuma (UK) Ltd. Hawkeye II
178. Tasuma (UK) Ltd. Hawkeye III 179. TATA Advanced Systems Limited Aquilon
180. TEKEVER AR1 Blue Ray 181. TEKEVER AR2 Carcará (formerly AR2 Power Ray)
182. TEKEVER AR4 Light Ray 183. Threod Systems, Ltd. EOS
184. Threod Systems, Ltd. X8 185. Top I Vision Cas per 250 186. Trigger Composites Pteryx 187. UAS Europe AB Spy Owl 100
188. UAS Europe AB Spy Owl 200 (formerly mX

- Sight) 189. UAV Factory, Ltd. Penguin BE
190. UAV Inc. E950 Challis Heliplane 191. UAV Research Lab. Silhouette
192. UAV Solutions, Inc. Talon 120 193. UAVision WINGO S
194. Uconsystem Re moEye

- 002B 195. Uconsystem RemoEye

- 006 196. Ukrspecexport Sokil

- 2 197. Universal Target Systems Ltd Vigilant (Spotter)
198. University of Colorado at Boulder DataHawk 199. Unmanned Systems Pioneer
200. Unmanned Systems Supercam S350 / Photobot 201. Utah State University Minion
202. Utah State Un iversity Titan 203. UTC Aerospace Systems Option
204. UTC Aerospace Systems Vireo 205. Vestel Defence Industries EFE
206. Volt Aerial Robotics WaveSight 207. VTOL Technologies Urban Eagle
208. WB Electronics S.A.FlyEye 209. Wide Autels Aerial Technologies
210. Wildau Bully/ATISS TFH 211. Wuhan AI Bir d UAV Co., Ltd KC

- 09 212. Wuhan AI Bird UAV Co., Ltd KC

- 1600 Sky Hawk 213. Xi'an ASN Technology Group ASN

- 217 214. Zala Aero Group ZALA 421

- 04M 215. Zala Aero Group ZALA 421

- 04M2F 216. Zala Aero Group ZALA 421

- 08 217. Zala Aero Group ZALA 421

- 08M / ZALA 421

- 08F 218. Zala Aero Group ZALA 421

- 16E40 

### 219. Zala Aero Group ZALA 421

- 16EM 220. Zero UAV (Beijing) Intelligence Technology Co. Ltd. ZERO160041 Appendix B4243444546