## UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _____________________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

AERIAL PERSPECTIVE LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS
SECTIONS 61.113(a ), 91.7(a), 91.119(c), 91.121, 91.151(b ) , 91.405(a),
91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b)

CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 3,

DJI INSP IRE 1, DJI S1000+, SKYWALKER X8 FLYING WING

AND 3D ROBOTICS SOLO

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012
(PUBLIC LAW 112

- 95)

Submitted on August 7 , 2015

Jakee Stoltz , Co

- Founder

Aerial Perspective LLC Tel:(701) 290

- 5459

Email: jakee.stoltz@gmail.com2 TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS

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

SUMMARY

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

INTRODUCTION AND INTERESTS OF PETITIONER

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

AIRCRAFT MODELS IN THIS PETITION

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

BASIS FOR PETITION

................................ ................................ ................................ ............... 5

A. NAME AND ADDRESS OF PE TITIONER

................................ .............................. 7

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH AERIAL

PERSPECTIVE LLC SEEKS EXEMPTION

................................ ............................. 8

C. THE EXTENT OF RELIEF AERIAL PERSPECTIVE LLC SEEKS AND THE

REASO N AERIAL PERSPECTIVE LLC SEEKS THE RELIEF

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

D. THE REASONS WHY GRANTING AERIAL PERSPECTIVE LLC ’S REQUEST

W O ULD BE IN THE PUBLIC INTEREST

................................ .............................. 13

E. THE REASONS WHY GRANTING THE EXEMPTION WOUL D NOT

ADVERSELY AFFECT SAFETY

................................ ................................ ............. 15

F. SUMMARY THAT CAN BE PUBL ISHED IN THE FEDERAL REGISTER

......... 23

G. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVILABLE

TO SUPPORT AER IAL PERS PECTIVE LLC’S REQUEST

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

CONCLUSION

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

ATTACHMENTS

................................ ................................ ................................ ......................... 263 

### GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authoriz ation

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and La nding4 

### SUMMARY

Aerial Perspective LLC seeks exemption from the requirements of 14 C.F.R. §§
61.113(a) , 91.7(a), 91.119(c), 91 .121, 91.151( b ), 91.405(a), 91.407(a )(1), 91.409(a)(1) & (a)(2),

and 91.417(a) & (b) , to operate Unmanned Aircraft Systems pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Aerial Perspective

LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducti ng

p hotography , videography, infrastructure inspections, and mapping within the United States.



### INTRODUCTION AND INTERESTS OF THE PETITIONER

Aerial Perspective LLC is a business dedicated to providing professional UAS flight

service s and UAS consulting

. Aerial Perspective LLC created and maintains a Flight Operations
Manual which is attached to this request as Attachment A.

Aerial Perspective LLC is staffed with experienced, aviation professional with a
combined 9+ years of experience in both manned and unmann ed aviation. Company co

- founder,

Jakee Stoltz, is a Commercial Pilot and Flight Instructor with over 1000 hours in single engine
airplanes. He has OEM training and certification on the Trimble UX5, Aerovironment Qube and
Raven, and Draganflyer X4

- ES UAS’s and has accumulated over 150 flights and over 70 hours
on those platforms including time on various DJI and 3D Robotics platforms. Mr. Stoltz has
previously held jobs at the University of North Dakota Aerospace and the Northern Plains UAS

Test Site.

The o ther two members of Aerial Perspective LLC are also Commercial Pilots and Flight
Instructors and also have a wealth of experience flyin g manned and unmanned aircraft. Andrew
Regenhard coordinates unmanned aircraft projects at the University of North Dakota

. Trevor
Woods is the airspace manager at the Northern Plains UAS Test Site and has extensive
experience flying UAS and acquiring COA’s. We are dedicated to providing safe, efficient
operations of unmanned aircraft systems in the NAS.



### AIRCRAFT MODELS INCLU DED IN THIS PETITION

1. DJI Phantom 3

2. DJI Inspire 1

3. DJI S1000+

4. Skywalker X8 Flying Wing5 5. 3D Robotics Solo UAS

Aerial Perspective LLC seeks an exemption to operate DJI , Skywalker, and 3D Robotics
systems for compensation or hire within the NAS.

The DJI Phantom 3, DJI Inspire 1, DJI S1000+, and 3D Robotics Solo UAS’s are all

similar in speed, weight, size, and operational capability. All four of the se UAS are vertical
takeoff and landing (VTOL), battery powered, electric motor aircraft. All have similar f ail safes
that prevent loss of control and fly away scenarios. The table below highlights some key
specifications of each UAS.

Max Speed Max Weight Size Mission Time

DJI Phantom 3 36 mph 2.8 lbs 23 in x 23 in 23 minutes

DJI Inspire 1 49 mph 6.5 lbs 22 in x 23 in 18 minutes

DJI S1000+ 26 mph 24.2 lbs 41 in x 16 in 15 minutes

3D Robotics Solo 55 mph 3.3 lbs 18 in x 18 in 25 minutes

The Skywalker X8 Flying Wing is a fixed wing UAS that also fits within the speed,
weight, size, and operational capability for ex emption. The Skywalker X8 has an 83 in.
wingspan, a maximum takeoff weight of 7.7 pounds , and a top speed of 50 knots. The Skywalker

X8 is outfitte d with a 3D Robotics Pixhawk autopilot which provides the autonomous flight

features that are similar to the 3D Robotics Solo.

Operation Manuals with details for each UAS will be included with this request. All DJI,
Skywalkere, and 3D Robotics systems ope rated by Aerial Perspective 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
Markings

.


### BASIS FOR PETITION

Petitioner, Aerial Perspective LLC , pursuant to the provisions of the Federal Aviation
Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA),

Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the
Administrator to commercially operate the DJI , Skywalker, and 3D Robotics UAS’s in the6 National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R. §§
61.113(a) , 91.7(a), 91.119(c), 91.121, 91.151(a) (1), 91.405(a), 91.407(a )(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b)

. In consideration of the speed, weight, size, and limited operating area associated with the

unmanned aircraft and its operation, Aerial Perspective LLC ’s operation of the DJI , Skyw alker,

and 3D Robotics UAS’s meets the conditions of FMRA Section 333 and therefore, will not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Aerial Perspective LLC requests relief from Sections 91.405(a ),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements
for maintenance that only apply to aircraft with an airworthiness certificate.

Aerial Perspective LLC submits that the requested relief is proper since an equivalent
level of safety will be ensured. Aerial Perspective LLC will use experience personnel or
technicians to perform maintenance, alternations, or preventative maintenance on the UAS’s
using the m ethods, techniques, and practices prescribed in the operating documents (i.e., manual

names). Furthermore, Aerial Perspective LLC will document and maintain all maintenance

records for the UAS’s.

Relief from certain requiremen ts of Sections 61.113(a) , ent itled Private pilot privileges

and limitations: Pilot in command , is requested by Aerial Perspective LLC to the extent
necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as

well as an airman medical certificate , and who has demonstrated, by meeting minimum flight

hour and currency requirements, that the PIC is able to safely operate the UAS’s in a manner
consistent with this exemption, including normal procedures, abnormal procedures, emergency

procedures and ma intaining appropriate distances from people, vessels, vehicles, and structures.

Aerial Perspective LLC seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness , because the UAS’s do not require an airworthiness certificate in accordance w ith
14 C.F.R. Part 21, Subpart H. As such, Aerial Perspective LLC will ensure that the UAS’s are in
an airworthy condition, prior to every flight, by determining that the UAS’s are in compliance
with the operating documents (i.e., manual names), and that t he aircrafts are in a condition for
safe flight.7 Aerial Perspective LLC seeks relief from Section 91.119(c), entitled Minimum safe

altitudes: General , because the proposed UAS’s must fly lower than 500’ above the surface to

accomplish certain operations s uch as photography and infrastructure inspections. As such,
Aerial Perspective LLC will ensure that operations that occur less than 500’ above the surface

will remain at least 500’ away from all nonparticipating persons, vehicles, vessels, and structures
unless a barrier exists to shield nonparticipating persons or Aerial Perspective LLC has the
owner’s permission to operate near the vehicle, vessel, or structure.

Aerial Perspective LLC also seeks an exemption fr om the requirements of Section

91.121, entitled Altimeter Settings, as the UAS’s will not have a typical barometric altimeter
onboard. However, altitude information of the UAS’s will be provided to the PIC via Global

Positioning System (GPS) equipment and radio communications telemetry data link, which
downlinks from the UA to the GCS for active monitoring of the flight path. This altitude

information, combined with Aerial Perspective LLC ’s operation of the UAS’s within visual line
of sight, at or below 500 ’ AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Aerial Perspective LLC seeks an exemption from the r equirements of
Section 91.151(b ) , entitled Fuel requirements for flight in VFR conditions

. Aerial Perspective

LLC submits that safety will not be affected by operation of the UAS’s during daylight hours in
visual meteorological conditions (VMC) under visual flight rules (VFR), for a total duration not
greater than that recommended by the manufacturer.

In accordance with 14 C.F.R. § 11.81, Aerial Perspective LLC provides the following

information in support of its petition for exemption:

A. 

### Name and Address of the Petitioner.

The name and address of the Petitioner is: Aerial Perspective LLC

111 N 3 rd Street Unit 1003

Grand Forks, ND 58203

A point of contact for Aerial Perspective LLC is:

Jakee Stoltz

Tel: (701) 290

- 5459

Email: jakee.stoltz@gmail.com8 B. 

### The Specific Sections of 14 C.F.R. From Which Aerial Perspective LLC

Seeks Exemp tion.

1. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section

61.113(a)

. Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsection (a) pres cribes the following, in relevant part: (a ) 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.

2. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section

91.7(a)

. Section 91.7, entitled Civil aircraft airworthiness , subsection (a) prescribe s the following: (a ) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section

91.119(c).

Section 91.119, entitled Minimum safe altitudes: General , subsection (c) prescribes the following, in relevant part: (c ) Except when necessary for takeoff or landing, no person may operate an aircraft over other than congested areas below 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.

4. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section

91.121.

Section 91.121, entitled Altimeter settings , subsection (a) prescribes the following, in relevant part: (a ) Each person operating an aircraft shall maintain the cruising altitude or f light level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

–
(i) The current reported altimeter setting of a station along the route and
within 100 nautical miles of the aircraft;9 (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevatio n of the departure airport or an appropriate altimeter setting available before departure.

5. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section

91.151 (b)

. Section 91.7, entitled Fuel requirements for flight in VFR conditions , subsection (b) prescribes the following: (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 minutes.

6. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section

91.405(a).

Section 91.405, entitled Maintenance required , subsection (a) prescribes the following: Each owner or operator of an aircr aft

– (a ) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

7. Aeri al Perspective LLC Seeks Exemption From The Requirements Of Section

91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventative maintenance, rebuilding, or alteration, subsection (a)(1) prescribes the following: (a ) No person may operate any aircraft that has undergone maintenance, preventative maintenance, rebuilding, or alteration unless

– (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter [.]

8. Aerial Perspective LLC Seeks Exemption From The Req uirements Of Section

91.409(a)(1 ) and 91.409(a)(2)

.10 Section 91.409, entitled Inspections, subsection (a) prescribes the following: (a ) Except as provided in paragraph (c) of this section, no person may operate an
aircraft unles s, 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 issuanc e of an airworthiness certificate in accordance with part 21 of this chapter.

9. Aerial Perspective LLC Seeks Exemption From The Requirements Of Section

91.417(a) and 91.417(b).

Section 91.417, entitled Maintenance records, subsection (a) and (b) prescribes the following: (a ) E xcept for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive maintenance, and alteration and
records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The recor ds 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 fo r 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 insta lled on the
aircraft which are required to be overha uled on a specified time
basis.

(iv) The current inspection status of the aircraft, inc luding the time
since the last inspection requi r ed b y the inspection program un der
which the aircraft and its appliances are maintained.11 (v) The current status of applicable airworthin ess directives (AD) and safety directives including, for each, the method o f compliance, the AD or safety directive numb er and revision date.
If the A D 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 install ed

e ngines, rotors, propellers, and appliances.

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

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

C. 

### The Extent Of Relief Aerial Perspective LLC Seeks And The Reason Aerial

Perspective LLC Seeks The R elief.

1. Extent of Relief Aerial Perspective LLC Seeks And The Reason Aerial

Perspective LLC Seeks Relie f From Section 61.113(a)

. Relief from Section 61.113(a) entitled Private pilot privileges and limitations: Pilot
in command , is requested to the extent ne cessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain training and currency requirements, to conduct the proposed UAS flight operations for compensatio n or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as a PIC 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.

As set forth more entirely below, Aerial Perspective LLC submits that an equivalent level of safety will be maintained because n o PIC will be allowed to operate a UAS unless that PIC has demonstrated, through OEM training and currency requirements, that the PIC is able to safely operate the aircraft in a manner consistent with the operations specifications as described in this exem ption including normal procedures,12 abnormal procedures, and emergency procedures to include evasive maneuvering and maintaining appropriate distances from people, vessels, vehicles, and structures.

Further, Aerial Perspective LLC submits that all flights of the UAS conducted by the PIC pursuant to the grant of this Petition (1) will be incidental to Aerial Perspective LLC’s business; and (2) will not carry passengers or property for compensation or
hire.

2. Extent of Relief Aerial Perspective LLC Seeks And The Reason Aerial

Perspective LLC Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a), entitled Civil aircraft airworthiness , is requested to the extent required to allow Aerial Perspective LLC to determine that the operations UAS
is in an airwo rthy condition prior to every flight by ensuring that the UAS is in compliance with the applicable operations and maintenance manuals, and that the UA
is in condition for safe flight. Copies of the manuals, which contain proprietary information, are attach ed hereto, and are to be held in a separate file pursuant to 14 C.F.R. Section 11.35(b).

Aerial Perspective LLC seeks the requested relief because the proposed sUAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H

. Therefore, Aerial Perspective LLC will ensure that the sUAS is in an airworthy condition based upon its compliance with the operating documents prior to every flight, and as stated in the conditions and limitations below.

3. Extent of Relief Aerial Perspec tive LLC Seeks And The Reason Aerial

Perspective LLC Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the proposed UAS, which utilize barometer and GPS equipment,

to en sure that a ground level pressure setting will be established prior to each flight, and in order to report altitude to the PIC.

Aerial Perspective LLC seeks the requested relief because the proposed UAS do not utilize a typical barometric altimeter that m ay be set as contemplated by Section 91.121. As more fully set forth below, an equivalent level of safety will be maintained since the sUAS are equipped with a barometer and GPS equipment, which will ensure that a ground level pressure setting will be esta blished prior to each flight, and provides the PIC with altitude information of the UA, above ground level (AGL),
on the heads

- up display of the GCS.

4. Extent of Relief Aerial Perspective LLC Seeks And The Reason Aerial

Perspective LLC Seeks Relief From Sec tion 91.151(b).

Relief from Section 91.151(b), entitled Fuel requirements for flight in VFR
conditions , is requested to the extent required to allow flights of the battery powered13 UA, during daylight hours in visual meteorological conditions under visual f light rules (VFR), to continue for a total duration not greater than that recommended by the manufacturer for safe operation.

Aerial Perspective LLC seeks the requested relief, because without an exemption from Section 91.151(b), the flight time duration of the battery powered UA will

sever e ly constrain the practicality of many of the operations Aerial Perspective LLC proposed to conduct pursuant to this Petition.

5. Extent of Relief Aerial Perspective LLC Seeks And The Reason Aerial

Perspective LLC Seeks Rel ief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Aerial Perspective LLC requests relief from these Sections because the sUAS do not require an airworthiness certificate. As set forth more fully below, the selected sUAS meet the conditions of Section 333 of the FMRA for operation with an airworthiness certificate. Accordingly, Aerial Perspective LLC will perform maintenance, alterations, or preventative maintenance on the UAS as prescribed by the manufacturers’
maintenance documentation where a pplicable, or by returning the aircraft to the manufacturer when operator maintenance is not recommended. Furthermore, Aerial Perspective LLC will maintain maintenance logbooks for each sUAS to document
and maintain all maintenance records for the aircraft used.

D. 

### Reasons Why Granting Aerial Perspective LLC’s Request Would Be In

The Public Interest.

Granting the present Petition will further the public interest by allowing Aerial Perspective LLC to safely, efficiently, and economically perform aerial photography, videography , infrastructure inspections, and mapping over areas of the United States.

Additionally, use of the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Aerial Perspective LLC’s proposed operation of sUAS’s will be realized without implicating any privacy issu es.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D
Robotics Solo UAS’s are battery powered and serve as a safe, efficient, and economical
alternative to the manne d aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, or 3D Roboti cs Solo UAS would reduce the amount of manned aircraft14 in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS

, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics
Solo UAS’s do not require an airport to takeoff or land. Likewise, a reduction o f manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, cruise, arrival, and landing phases of flight operations.

2. The Public Will B enefit From The Safety And Efficiency Of The DJI Phantom 3,

DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, And 3D Robotics Solo

UAS’s.

Conducting aerial acquisitions with the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s , instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial photography, videography, inspection, and mapping flight operations. By using battery power and electric motors, the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 10

- 20 gal lons per hour of
leaded aviation fuel. The DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s , while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA’s are propelle d by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s to perform aerial acquisitions, the substantial risk to life and p roperty in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI
P hantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UA’s (all weighing less than 10 pounds at their maximum gross weights and with no fuel on board) has less physical potential for collateral damage to life and property on t he ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing 3000

- 6000 pounds and carrying 50

- 100 gallons of fuel).

3. Performing Aerial Image Acquisitions With The DJI Phantom 3, DJI Inspire 1,

DJI S1000+, S kywalker X8 Flying Wing, And 3D Robotics Solo UAS’s Will

Benefit The Economy.15 In addition to being safe and efficient, the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s are also an economical
alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s will allow United States based companies, like Aerial Perspective LLC, to r emain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must a dopt new and alternative technology in order to maintain competitive. Operating the battery powered DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned
aircraft.

By operating the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Sol o UAS’s, companies such as Aerial Perspective LLC can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performan ce of U.S. companies, through commercial use of the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s provides a stable workforce that increases consumer spending, improves tax revenues, and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, Aerial Perspective LLC’s p roposed operations of the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s will not implicate any privacy issues. Specifically, the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotics Solo UAS’s will be operated only in compliance with limitations set forth in the Granting of this Petition and operating documents (i.e. Aerial Perspecti ve LLC Flight Operations Manual ) which guides operations around persons and property

, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. Section 91.119.

E. 

### Reasons Why Granting Aerial Perspective LLC’s Request Would Not

Adversely Affect Safety.

1. Reasons Why The DJI Phantom 3, DJI I nspire 1, DJI S1000+, Skywalker X8

Flying Wing, And 3D Robotics Solo UAS’s Meet The Conditions Of The FAA

Modernization and Reform Act of 2012 (FRMA) Section 333.16 In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and their operation, Aerial Perspective LLC’s operations of the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Robotic s Solo UAS’s meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness
certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.

– Notwithstanding any other requir ement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the pl an and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.

– In making the determination under subsection (a), the Secretary shall determine, at a minimum

— (1) Which type s of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system

o r the public or pose a threat to national security; and (2) Whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft

sy stems identified under paragraph (1). (c) Requirements for Safe Operation.

– If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements fo r the safe operation of such aircraft systems in the national airspace system.

In seeking this exemption, Aerial Perspective LLC submits that the included UAS’s can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a)
the charact eristics of these UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

A. DJI Phantom 3, DJI Inspire 1, DJI S1000

i. Safety Features

Although a degredation or loss of control link, and/or degradation or loss of the source of navigation is unlikely, it is a situation that is well planned for and therefore, a benign event.17 In the event of a loss of link, the aircraft will follow a user

- selected procedure.
The aircraft will proceed to the “home” position, which is set by the PIC prior to flight and can be changed in flight if necessary, at a set altitude. If link is not regained, the aircraft will initiate a decent and land at the designated “home” position.

If the GPS solution is lost during flight, the PIC will still have full control of the aircraft and can maneuver it back to “home” for a safe landing. As the PIC always flies the UAS in visual line of sight, it is immediately apparent if this
situation occurs

. DJI Intelligent Flight Batteries have many built in safeguards to prevent battery failures in flight. These include battery level displays, electronic monitors to monitor things like temperature and amperage, and battery history
information. These featu res in addition to electrical safeguards on the aircraft like Low Battery Return To Home ensure an aircraft will never lose electrical power in flight.

A complete description of the operation and specifications of DJI Phantom 3, DJI Inspire 1, and DJI S10 00+ is provided in the Operator Manuals included with this petition.

B. 3 D Robotics Solo and Skywalker X8 Flying Wing

i. Safety Features

The 3D Robotics Solo and Skywalker X8 Flying Wing UA also have many safety features to mitigate events like loss of link and loss of navigational capability.

Although a degredation or loss of control link, and/or degradation or loss of the source of navigation is unlikely, it is a situation that is well planned for and therefore, a benign event.

In the event of a loss of link, the aircraft will follow a user

- selected procedure. The aircraft will proceed to the “home” position, which is set by the PIC prior to flight and can be changed in flight if necessary, at a set altitude. If link is not regained, the aircraft will initiate a decent and land at the designated “home” position.

If the GPS solution is lost during flight, the PIC will still have full control of
the aircraft and can maneuver it back to “home” for a saf e landing. As the PIC always flies the UAS in visual line of sight, it is immediately apparent if this
situation occurs.

The 3D Robotics Solo Controller has many built in alerts and safety features as well. Five features; pause, regain manual control, ret urn home, land, and18 motor shutoff are available in case of emergency. The motor shutoff feature is

a two

- step procedure to prevent inadvertent motor shutoff.

A complete description of the operation and specifications of the 3D Robotics Solo and Skywalker X 8 Flying Wing are provided in the Operator Manuals, included with this petition.

2. Flight Operations Of The DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker

X8 Flying Wing , A nd 3D Robotics Solo UAS’s Are Limited To The Line Of Sight

Of A Certificated Pilot In Command With A Visual Observer.

Aerial Perspective LLC will only utilize pilots who meet the following criteria:

x Possess and meet currency requirements for at least a sport pilot certificate

x Possess a valid third class or better FAA airman medical certificate

x Successfully complete OEM training on the UA being flown and demonstrate proficiency on that UA

Aerial Perspective LLC will only utilize visual observers who are trained on the appropriate FAA rules and regulations required to perform their du ties. The Aerial Perspective LLC Flight Operations Manual describes how visual observers will be
trained. Training records, flight time totals, and applicable flight currency records will be maintained by the Aerial Perspective LLC Chief Pilot.

3. Flights Of The DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying

Wing , And 3D Robotics Solo UAS’s Will Be Conducted Pursu ant To Specific

Operating Limitations.
In seeking this exemption, Aerial Perspective LLC proposes to commercially operate the specifi ed sUAS for the special purpose of conducting photography , videography, infrastructure inspections, and mapping in the United States, pursuant to the following specific operating limitations: 1) Operations authorized by the grant of this exemption will be lim ited to the following aircraft described in the operating documents, which are vertical takeoff and landing, unmanned aircraft weighing less than 55 pounds maximum gross weight: DJI Phantom 3, DJI Inspire 1, DJI S1000+, Skywalker X8 Flying Wing, and 3D Rob otics Solo. Proposed operation of any other aircraft will require a new petition or a petition to amend this exemption. 2) Operations for the purpose of closed

- set motion picture and television filming are not permitted. 3) The UA may not be operated at a speed exceeding 87 knots. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4) The UA must be operated at an altitude of no more than 400 feet above ground level.19 5) The UA must be operated within visual line of sight of the PIC at all times. 6) All operations must utilize a visual observer. 7) Operating documents, to include an exemption if granted and UAS operating manuals, will be accessible during UAS operations and made available to the Administrator upon request. 8) Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics must undergo a functional test flight prior to conducting further operations under this request. Functional test flights will be
conducted with a PIC and VO and will remain at least 500 feet from other people. 9) Aerial Perspective LLC will be responsible for maintaining and inspecting the UAS to ensure that is in a condition for safe operation. 10) Prior to each flight, the PIC will conduct a pre

- flight inspection to determine the UAS is in a condition for safe flight. 11) Aerial Perspective LLC will follow UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft
and airc raft components. 12) Each UAS operated under this request will comply with all manufacturer safety bulletins. 13) All PIC will hold at a minimum a sport pilot certificate. All PIC will also hold a current FAA airman medical certificate. All PIC will meet the fligh t review requirements specified in 14 C.F.R. Section 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 14) Aerial Perspective LLC will not permit any PIC to operate UAS’s unless the PIC demonstrates the ability to safely operate t he UAS in a manner consistent with how the UAS will be operated under this request. 15) Operations will be conducted in day light hours under VMC conditions. 16) Aerial Perspective LLC will not operate UA’s within 5 nautical miles of an airport reference point, u nless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to Aerial Perspective LLC. 17) UAS’s will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibilit y is less than 3 statute miles from
the PIC. 18) If a UAS loses communications or loses its GPS signal, the UA will be able to return to a pre

- determined location. 19) The PIC will abort a flight in the event of unpredicted obstacles or emergencies. 20) The PIC will n ot begin a flight unless 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.20 21) All operations will be conducted in accordance with an Air Traffic Organization

- issued COA. 22) All aircraft will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification markings in accordance with 14 CFR part 45, Subpart C. Markings will be as l arge as practicable. 23) Documents used by Aerial Perspective LLC to ensure the safe operation and flight of the UAs and any documents required under 14 CFR Sections 91.9
and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. 24) UA’s will remain clear and give way to all manned aviation operations and
activities at all times. 25) UAS will not be operated from any moving device or vehicle. 26) All Flight Operations will be conducted at least 500 feet from all

no nparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an
accident.
b. The owner/controller of any vessel, vehicle, or s tructure has granted permission for operating closer to those objects and the PIC has determined the operation is safe. 27) All operations will be conducted over private or controlled

- access property with permission from the property owner/controller or author ized representative. 28) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration Office within 24 hours.
Accidents w ill be reported to the National Transportation Safety Board per
instructions on the NTSB website.
4. Reasons Why An Exemption From The Requirements Of Section 61.113(a)

Would Not Adversely Affect Safety

. Aerial Perspective LLC submits that an equivalent level of safety established by Section 61.113(a) will be maintained because no PIC will be allowed to operate the UAS unless that PIC has demonstrated, through the proper UAS training and currency requirements, that the PIC is able to safely operate the UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures.

Considering Aerial Perspective LLC’s proposed area of operations and the operating
limi tations set forth above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No 11062); and the airmanship skills necessary to safely operate the UAS, Aerial Perspective
LLC subm its that the additional manned airmanship experience of a commercially21 certificated pilot would not correlate to the airmanship skills necessary for Aerial Perspective LLC’s specific proposed flight operations.

Additionally, the FAA has previously granted relief from Section 61.113(a) specific to UAS, in circumstance similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138).

As in Exemption No. 11109, Aerial Perspective LLC will not allow any PIC to operate the UAS unless that PIC has demonstrated through the UAS training and currency requirements that the PIC is able to safely operate the UAS in a manner consistent with this exemption, including evasi ve and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures.

5. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would

Not Adversely Affect Safety.

The level of safety established by Sectio n 91.7(a) will be maintained because prior to every flight, Aerial Perspective LLC will ensure that the UAS is in an airworthy condition and safe for flight based upon the UAS’s compliance with its operating
documents and as stated in the conditions and li mitations herin.

Additionally, the FAA has previously granted relief from Section 91.7(a), specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138).

6. Reasons Why An Exemption From The Requirements Of Section 91.119(c)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.119(c) will be maintained given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the required local and ATC coordination. Due to the advance notice to the property owner and participants in the aerial activity,
all affected individuals will be awar e of the planned sUAS flight operations.

Additionally, the FAA has previously granted relief from Section 91.119 (c) , specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 1 1065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138).

7. Reasons Why An Exemption From The Requirements Of Section 91.121 Would

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained
because all t he UAS Aerial Perspective LLC proposes to operate are equipped with a22 digitally encoded barometric altimeter and GPS triangulation equipment, with a zero altitude initiation point being established prior to each flight. As such, the PIC on the UAS is provi ded the altitude of the UA above ground level (AGL) via a heads

- up display of the ground control station (GCS).

Additionally, the FAA has previously granted relief from Section 91.121, specific to UAS, in circumstances similar, in all material respects, t o those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138).

8. Reasons Why An Exemption From The Requirements Of Section 91.151(b)

Would Not Adversely Affect Safety.

The equivalent level o f safety established by Section 91.151(b) will be maintained because the operator will always have detailed information on the charge and state of the battery, and preset battery failsafe’s will prevent any loss of flight control due to power loss.

The gr ound control station (GCS) for each UAS provides a battery indicator on the
heads

- up display, which indicates the UA’s current remaining battery power measure in volts, and thus provides the PIC with constant awareness of the real

- time battery voltage duri ng a flight.

Additionally, the FAA has previously granted relief from Section 91.15 1 (b) , specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11064, 11065, 11 066, 11067, 11080, 11109, 11110, 11136, 11138 ). These previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are
considered.

9. Reasons Why An Exemption From The Re quirements Of Section 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a) (2), And 91.417(a) & (b) Would Not Adversely

Affect Safety.

In seeking this exemption, Aerial Perspective LLC submits that an equivalent level of safety w ith regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), And 91.417(a) & (b) will be met because Aerial Perspective LLC and the manufacturers of each aircraft, will use tr ained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the manufacturer’s maintenance manual. Furthermore, Aerial Perspective LLC will document and maintain all maintenance records for each of the
individual aircraft.23 Since each UAS will be inspected as prescribed by the manufacturer’s maintenance manual, Aerial Perspective LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.4 09 (a)(1), and 91.409(a)(2). A copy of each aircraft’s Operator’s Manual, which contain descriptions and procedures for all maintenance of the system, are included with this request

. Additionally, the FAA has previously granted relief from Section 91.15 1 (b) , specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138 ). These previous exemptions granted by the FAA concerning Section
91. 151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered.

F. 

### Summary That Can Be Published In The Federal Register.

The Rules From Which Aerial Perspective LLC Seeks Exemption:

Aerial Perspective LLC seeks exemption from the requirements of 14 C.F.R. Sections 61.113(a), 91.7(a), 91.119(c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)( 1) & (a)(2), and 91.417(a) & (b.

A Brief Description Of The Nature Of The Exemption Aeri al Perspective LLC
Seeks:

This exemption will permit Aerial Perspective LLC to commercially operate Unmanned Aircraft Systems for the purpose of conducting photography , videography, infrastructure inspections, and mapping within the United States

.

G. 

### Any Add itional Information, Views, Or Arguments Available To Support
Aerial Perspective LLC’s Request.

This Petition is made pursuant to the FAA modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Aerial Perspective LLC’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth
above.

FMRA Section 333 sets forth the requirements for con sidering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security, and further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, A erial Perspective will operate the specified UAS safely in the NAS without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.24 

### CONCLUSION

As set forth herein, Aerial Perspective LLC seeks an exemption pursuant to 14 C.F.R.

Section 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA),
which will permit safe operation of the DJI Phantom 3, DJI Inspire 1, DJI S1000+, Sky walker
X8 Flying Wing, and 3D Robotics Solo UAS’s commercially, without an airworthiness
certificate, for the limited purpose of conducting photography, videography, infrastructure
inspection, and mapping within the stated operational guidelines. By granti ng this Petition, the
FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and
Reform Act of 2012, while also advancing the interests of the public, by allowing Aerial
Perspective LLC to safely, efficiently, and economica lly operate these UAS commercially within

the NAS.25 WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA
Modernization and Reform Act of 2012, Section 333, Aerial Perspective LLC respectfully
requests that the Administrator grant thi s Petition for an exemption from the requirements of 14

C.F.R. Sections 61.113(a) , 91.7(a), 91.119(c), 91 .121, 91.151(b), 91.405(a), 91.407(a )(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b) , and permit Aerial Perspective LLC to operate the
specified UAS fo r the purpose of conducting photography , videography, infrastructure

inspections, and mapping within the United States

.

Dated: August 7 , 2015

Respectfully submitted,

AERIAL PERSPECTIVE LLC

___________________________________

JAKEE STOLTZ

111 N 3 rd Street Unit 1003

Grand Forks, ND 58203 Tel: (701) 290

- 5459

Attachment A: Aerial Perspective LLC Flight Operations Manual Attachment B: DJI Phantom 3 Attachment C: DJI Inspire Attachment D: DJI S1000+ Attachment E: Skywalker X8 Flying Wing Attachment F : 3D Robotics Solo26 ATTACHMENT A

Aerial Perspective LLC Flight Operations Manual

This document is withheld as proprietary and confidential and is subject to non

- disclosure under Freedom of Information Act, 5 U.S.C. Section 522 et seq.27 ATTACHMENT B

DJI Phantom 3

See Attached Manual : Phantom_3_Professional_User_Manual_v1.228 ATTACHMENT C

DJI Inspire 1

See Attached Manual s: Inspire_1_User_Manual_v1.2_en Inspire_1_Maintenance_ManualV1.0_en29 ATTACHMENT D

DJI S1000+

See Attached Manual : S1000_Plus_User_Manual_v1.230 ATTACHMENT E

Skywalker X8 Flying Wing

See Attached Manual : 3DR Pixhawk Manual31 ATTACHMENT F

3D Robotics Solo

See Attached Manual s: 3D Robotics Solo User Manual