Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 1 **Private and Confidential Denny**  **Ko -** **Wei Chang, Easton, PA -**  **Section 333 Exemption Petition** January 10, 2016 U. S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE W ashington, DC 20590 **Re** : Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1 ); 91.409(a) (2); 91.417(a)&(b) Dear Sir or Madam, I, Denny Ko - We i Chang, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Denny Ko - We i Chang, an owner and operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Denny Ko -We i Chang, may operate my small ultra lightweight unmanned aircraft system (“UAS”) in commercially regulated airspace by the Federal Avi ation Administration (“FAA”). Following exemption and approval by the FAA, I, Denny Ko - We i Chang, will primarily use my professionally built DJI Inspire 1, DJI Phantom 3 Professional, DJI Phantom 3 4K, DJI, Phantom 3 Advanced, 3DR Solo, Yuneec TyphoonQ500 4K, Yuneec Typhoon G, and Yuneec Typhoon Q500+ UAS equipped with cameras for the following applications : Aerial photography, videography, and inspection for real estate, architecture, land surveying, crop monitoring, aerial mapping, engineerin g, special events to include but not limited to weddings, private or public parties/events, business advertising, promotional events, geological surveying, utilities, television, cinematography, news gathering, residential and commercial infrastructure ins pection, utility inspections, search and rescue operations, national disaster, and UAS training. My, Denny Ko - We i Chang ’s, exemption request would permit the operation of ultra lightweight, unmanned (i.e. piloted by remote control) UAS’s for the d evelopme nt of community and government use videos, permissible within property boundaries for individual homeowners and within in tightly controlled, limited airspaces predetermined in areas away from the general public, airports, heliports and vehicular traffic. Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to pr event catastrophes . Furthermore, it is my intent to assist future FAA safety protocols and regulatio ns exclusive to lightweight UAS's for specific video and photography usage byDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 2

sharing information with the FAA as I, Denny Ko - We i Chang, record flight data and other pertinent information gained through permitted flight operations. In addition, granting my, Denny Ko - We i Chang ’s, exemption request will comply with the Secretary of Transportation’s (FAA Administrator’s) instructions to not only integrate UAS's into the national airspace system, but to “...establish requirements for the safe operation of suc h aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor purposes, educati onal videos, Search and Rescue, land/trusts inspections, agricultural field monitoring, film /video productions, motion picture film operations and television, and structure inspections, to aid state and local agencies

. Further I, Denny Ko - We i Chang, will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA. For the reasons stated below, I, Denny Ko -We i Chang, respectfully request the grant of an exemption allowing me to operate ultra lightweight, remote controlled UAS’s to aid academic community awareness, to benefit/stimulate attracti on, and to enhance pe rsonal and public video feeds. A grant that will ultimately allow UAS’s to play a more positive role in our local community by increasing employment opportunities, heightening security measures and decreasing government expenditures by reducing the need for heavier manned aircraft, containing co stly, combustible fuel ( a potential public hazard in and of itself )

. **I. Contact Information:**  Denny Ko -We i Chang 3701 Knollcroft St Easton, PA 18045 Phone: 314 - 662 - 1237 Email: bell206pilot@hotmail.com **II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which**  **Denny Ko**  **- Wei**  **Chang Requests Exemption are:**  14 CFR 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91, et seq 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b) **III .**  **The Extent of relief Denny**  **Ko -** **Wei Chang Seeks and the Reason He Seeks Such**  **Relief:** I, Denny Ko - We i Chang, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 331 - 334, seeking relief from any currently applicable FARs operating to prevent me, Denny Ko -We i Chang, contemplated commercial cinematic, academic and other flight operations within the national airspace system. The Reform Act in Section 332 provides for such integration o f civil unmanned aircraft systems into our national airspace system as it is in the public’s interestDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 3

to do so. My, Denny Ko - We i Chang ’s, ultra lightweight UAS meet s the definition of “small unmanned aircraft” as def ined in Section 331 and therefore the integration of my ultr a light we ight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra lightweight UAS prior to the time period by whi ch the Reform Act requires the FAA to promulgate rules governing such craft. Thereby, providing direct experience and valuable information for formal regulation that can be administered uniformly to all related UAS aerial video and photography. The Reform Act guides the Secretary in determining the types of UAS's that may operate safely in our national airspace system. Considerations include:  The weight, size, speed and overall capabilities of the UAS's  Wh ether the UAS will be operated near airports o r hea vily populated areas  Wh ether the UAS will be operated by line of sight. 112 P.L. 95 § 333 (a) Each of these items reflect in favor of an exemption for me, Denny Ko - We i Chang . M y UA S’s utilize eight or less rotating propellers for balance, control and sta bility. My UAS’s are equipped with the following via video and data telemetry: 1) Altimeter 2) Attitude indicator 3) Ground s peed indicator 4) Magnetic compass 5) Heading indicator 6) Vertical speed indicator 7) Course deviation indicator 8) Radio magnetic indicator 9) GPS location 10) Battery consumption and battery l eft with approximate time. 11) Loiter and circle mode 12) Auto safety or RTL ( Return To Launch) 13) Auto landing technology Eac h UAS weighing less than 55 pounds ; Including camera(s) with or without gimbal (a camera stabilizer). I, Denny Ko - We i Chang, considers safety as foremost with each flight. My small unmanned aircraft is designed to hover in place, circle in a specific place or loiter via GPS and can be operat ed in win ds up to 30.4 knots (35mph) . For safety, stability and fear of financial loss I will not fly in winds exceeding 21.7 knots (25 mph). Built in safety systems include a GPS mode that allows my UAS to hover/circle in place or land when radio controls are released. I , Denny Ko - We i Chang, will fly with the mode safest to complete the videos for aerial videography/photography and have the ability to choose the safest, most reliable and stable mode to prevent accident and hazard. Wh en pilot communicatio n from the radio control is lost, UAS is designed slowly descend to point of takeoff and or to land at point of launch after ascending to a pre - set altitude to ensure the UAS will clear any obstacles that may be between the takeoff point and the current po sition of the UAS.Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 4

I , Denny Ko - We i Chang, will not operate my UAS near airports, hospitals nor police heliports, and do not operate near areas where general public is within fifty to one hundred (50 - 100) yards depending on location, conditions and weathe r. I am constantly on alert for any manned aircraft (police/medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach nea r my location. My UAS’s are capable of vertical and horizontal operations, and are flown only within my line of sight, as the remote control pilot. My UAS's are also flown with a second operator who aids in watching for any obstacles, including manned airc raft, within the flight zone of the UAS. Utilizing battery power rather than combustible fuels, flights ge nerally last between three to twenty - five minutes, with an altitude under one - hundred and fifty feet. Smart Modes includes position hold, self- leveli ng, altitude command, GPS, return home feature, and safety control to return home or land in the event of communication interruption between RC transmitter and UAS. I, Denny Ko - We i Chang , utilize a fresh fully charged battery with each flight as a safety precaution; full flight time limi t for each battery is eight to thirty minutes as tested. I do not operate my UAS at or below manufacturer recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash, that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. I will clock numerous practi ce flights in remote areas simulating fl ights for future commercial use to gain familiarization with the characteristics of this specific UAS's performance under different temperature and weather conditions. I also practice computerized simulated flights to maintain adequate skills and response reflex time. All for the sake of safety. I , Denny Ko - We i Chang, am extremely cautious when operating my UAS/ultra lightweight unmanned aircraft and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system. Denny Ko - We i Chang ’s UAS has a demon s trable safety record and does not pose any threat to the general public or national security. **I V.**  **How Denny**  **Ko -** **Wei Chang**  **’s Request Will Benefit the Public A**  **s A Whole:**  Aerial videography for geographical awareness, education, search and rescue, land ma nagement, structure inspections and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget companies, average homeowners and property owners the expense of such aerial videography is c ost prohibitive. Onl y large companies and high end r ealtors or luxury homeowners can afford to absorb such expense; depriving non - luxury owners and lower budget companies from a valuable marketing tool. My, Denny Ko - We i Chang' s, UAS's size and lack of combustible fuel pose a lower risk to the public. Congress has already proclaimed that it is in the public’s interest to integrateDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 5

commercially flown UAS's into the national airspace system, hence the passing of the Reform Act. Grant ing my, Denny Ko - We i Chang, ’s, exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around the United States. M y ultra light weight UAS is battery powered and creates no emissions that can ha rm the environment. Permitting me , Denny Ko -We i Chang, to immediately fly within national air space furthers economic growth. Granting my exemption request substantially furthers the economic impact for the United States for companies looking to relocate o r build a s well as individuals looking to relocate for career advancement through academic and geographical awareness. Both of which serve as a stimulus to the community. **V. Reasons**  **Why Denny**  **Ko -** **Wei Chang**  **’s Exemption Will Not A** **dversely A**  **ffect Safety Or**  **How The Exemption Will Provide a Level of Safety**  **A t Least Equal To Existing Rule:**  My, Denny Ko - We i Chang ’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Denny Ko - We i Chang, to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet und iscovered safety protocols for r ealtors, land and structured owners. For d evelopment in cooperation with the FAA. In addition I, Denny Ko -We i Chang, submit the following representations of enhancements to current aerial videography and photography:  My UAS’s weigh less t han 55 pounds (maximum weight including an integrated ultra light weight camera)  I operate my UAS well below 200 feet  I operate m y UAS for a maximum of 30 minutes per flight  I land my UAS prior to manufacturer recommended minimum level of battery power  I pilot my UAS through remote control only by line of sight; and have live video feed for a secondary p ilot to monitor video recording  I receive a live telemetry feed from my UAS during all flights which include remaining battery voltage, distance, altitude, and any anomali es that may occur during flight  My UAS’s Command and Control utilizes spread spectrum 2.4Ghz - 2.485Ghz frequencies in accordance with CFR 47, Part 15 for model aircraft use My UAS’s have a GPS controlled flight controller- a flight safety feature whereby it hovers or circles and then lands at th e GPS takeoff point if communication with the remote control pilot is lost; I actively record and analyze flight data through flight controller app to constantly update and enhance safety protocols; I only operate in reasonably safe environment that are s trictly controlled, are away from power lines, elevated lights, airports and actively populated areas; I conduct extensive preflight inspections and protocol, during which safety carries primary importance; I always obtain all necessary perm issions prior t o operation; and I have procedures in place to abort flights in the event of safety breaches or potential danger. My, Denny Ko - We i Chang ’s , safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness , real estate, structured inspections, land management and search and rescue. UAS's carry n o people on board and I only operates my UAS in specific areas awayDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 6

from mass populations. There is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. The small size and extreme maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and safely. Given its small size and we ight, even when close enough to capture amazing images, my UAS need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom. Accordingly , my UAS has been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels. I, Denny Ko - wei Chang, propose to commercially operate UAS's pursuant to the following specific operation limitations: 1. The UAS must weigh less than 55 pounds (25 kg), including energy source(s) and equipment 2. The UAS may not be flown at a speed exceeding a ground speed of 85 knots. 3. Flights must be operated at an altitude of no m ore than 400 feet above ground level (AGL), as indicated by the procedures specified in the operator's manual. All altitudes reported to ATC must be in feet AGL. 4. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requ ires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's state driver’s license. 5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement, as lon g as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. 6. If a discrepancy exists between these limitations and any proce dure outlined elsewhere , the conditions and limitations herein take precedence a nd must be followed. 7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the ne cessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must be included in the preflight inspection. All maintenance and alterations must be properly documented in the airc raft records. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight in accordance with the operator's manual. Th e PIC who conducts the functional test flight must makeDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 7

an entry in the UAS aircraft records of the flight. \The operator must follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. W he n unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be established and identified in the operator's manual. At a minimum, the following must be included in the operator's manual: a. Actuators / Servos b. Transmission (single rotor) c. Powerplant (motors) d. Propellers e. Electronic speed controller f. Batteries g. Mechanical dynamic components (single rotor) h. Remote command and control i. Ground control station (if used) j. Any other components as determined by the operator 9. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a current state driver’s license. 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/her pilot certificate. 10. Prior to operations conducted for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours of to tal time as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requiremen t. Training, proficiency, and experience - building flights can also be conducted under this grant of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience - building flights, all persons not essential fo r flight operations are considered non - participants, and the PIC must operate the UAS with appropriate distance from non - participants in accordance with 14 CFR § 91.119. 11. Prior to operations conducted for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take - offs and three landings in the preceding 90 days. Training, proficiency, experience building, and take - off and landing currency flights can be conducted under this grantDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 8

of exemption to accomplish the required flight time and 90 day currency. During training, proficienc y, experience - building, and take - off and landing currency flights, all persons not essential for flight operations are considered non - participants, and the PIC must operate the UAS with appropriate distance from non - participants in accordance with 14 CFR § 91.119. 12. Prior to any flight operations authorized by this grant of exemption, the PIC and visual observer (VO) must have successfully completed a qualification process, as outlined in the operator’s manual. As this is a requirement stipulated by the opera tor, the test must be developed and implemented by a qualified person designated at the sole discretion of the operator. A record of completion of this qualification process must be documented and made available to the Administrator upon request. 13. Prior to operations conducted for the purpose of motion picture filming (or similar operations), a flight demonstration, administered by an operator- approved and - qualified pilot must be successfully completed and documented. This documentation must be available fo r review upon request by the Administrator. Because the knowledge and airmanship test qualifications have been developed by the operator, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval o f company designated examiners, the petitioner will conduct these tests in accordance with the operator’s manual. 14. The UAS may not be operated directly over any person, except authorized and consenting production personnel, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency. 15. Regarding the distance from participating persons, the operator’s manual has safety mitigations for authorized and consenting production personnel. At all times, th ose persons must be essential to the closed - set film operations. Because these procedures are specific to participating persons, no further FSDO or Aviation Safety Inspector (ASI) approval is necessary for reductions to the distances specified in the petit ioner’s manuals. This is consistent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1 Issue a Certificate of Waiver for Motion Picture and Television Filming

. 16. Regarding distance from non - participating persons, the operator must ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the filming production. This provision may be reduced to no less th an 200 feet if it would not adversely affect safety and the Administrator hasDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 9

approved it. For example, an equivalent level of safety may be determined by an aviation safety inspector’s evaluation of the filming production area to note terrain features, ob structions, buildings, safety barriers, etc. Such barriers may protect non participating persons (observers, the public, news media, etc.) from debris in the event of an accident. This is also consistent with the same FAA Order 8900.1, V3, C8, S1. 18. If t he UAS loses communications or loses its GPS signal, the UA must return to a pre - determined location within the security perimeter and land or be recovered in accordance with the operator’s manual. 17. If the UAS loses communications or loses its GPS signal, t he UA must return to a pre determined location within the security perimeter and land or be recovered in accordance with the operator’s manual. 18. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operat or’s manual. 19. Each UAS operation must be completed within 30 minutes flight time or with 25% battery power remaining, whichever occurs first. 20. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Wa iver or Authorization (COA) pri or to conducting any operations under this grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. 21. All aircraft operated in acco rdance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N - Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 22. The operator m ust develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures must be added to the operator ’s manual. 23. Each UAS operated under this exemption must comply with all manufacturer Safet y Bulletins. 24. The operator must develop UAS technician qualification criteria. These criteria must be added to the operator’s manual. 25. The preflight inspection section in the operator’s manual must be amended to include the following requirement: The preflight inspection must account for all discrepancies,Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 10

i.e. inoperable components, items, or equipment, not covered in the relevant prefli ght inspection sections of the operator’s manual. 26. Before conducting operations, the radio frequency spectrum used for operation and control of the UAS must comply with the Federal Communications Commission (FCC) or other appropriate government oversight ag ency requirements. 27. At least three days before scheduled filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed filming. The 3 - day notification may b e waived with the concurrence of the FSDO. The plan of activities must include at least the following: a. Dates and times for all flights b. Name and phone number of the person responsible for the UAS filming production under this grant of exemption c. Name and pho ne number of the person responsible for the on - scene operation of the UAS. d. Make, model and serial or N - number of the UAS to be used e. Name and certificate number of the UAS PIC's involved in the filming production event f. A statement that the operator has obt ained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request. g. Signature of exemption - holder or representative h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation 28. The documents required under 14 CFR § 91.9 and § 91.203 must be av ailable 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 any law enforcement official upon request. 29. The UAS must remain clear and yield the right of way t o all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 30. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 31. The UAS cannot be operated by the PIC from any moving device or vehicle. 32. The UAS may not be operated less th an 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 33. The UAS may not operate in Class B, C, or D airspace without written approval from the FAA. The UAS may not operate within 5 m iles of the geographic center of a non -Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 11

towered airport as denoted on a current FAA - published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required b y the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 34. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the Federal Aviation Administration’s (FAA) UAS Integration Office (AFS - 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB W eb site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed by AFS - 80 and authorization to resume operations is provided. **V I**  **. A**  **Summary The F**  **AA May**  **Publish in the Federal Register:**  The Specific Sections of Title 14 of the Code of Federal Regulation s from w hich Denny Ko -We i Chang requests e xemption include 14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. § 91.9 (b)(2 ); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C .F.R. §§ 91.417 (a) & (b)

. The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because my, Denny Ko - We i Chang ’s, UAS meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pi lots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 92 99, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certifica tes, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The size, weight and enclosed operational area of my, Denny Ko - We i Chang’s, UAS permits exemption from Part 21 because my UAS meets (an d exceeds) an equivalent level of safetyDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 12

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both p ieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My, Denny Ko - We i Chang,’s, curren t and projected UAS's meet or exceed each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is in applicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by ma intaining a safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor or controlled GPS “geofencing” 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft cer tifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, Denny Ko - We i Chang. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS can be marked with the appropriate “N” number once this “N” number has been given. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non - commercial operations. The UAS Pilot in Command must possess at least a sport pilot certificate and a driver's license. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in which the PIC is rated on his/her pilot certificate as outlined in 14 C.F.R. § 61. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than 200 feet AGL. I, Denny Ko -We i Chang, will operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, we ight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be achieved.Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 13

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The above - cited Regulations require, amongst other things, aircraft owners and operators to “have [the] aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except a s provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . .”These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to my, Denny Ko - We i Chang's , UAS. However, as a safety precaution I inspect my UAS before and after each flight. **In summary ,**  **Denny Ko**  **- Wei**  **Chang seeks an exemption from the following Regulations:**  14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C .F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Denny Ko - We i Chang 's, small unmanned vehicle/lightweight unmanned aircraft vehicle in community awareness, education, structural inspection , land management, search and rescue , and real estate ope rations

. Granting my, Denny Ko - We i Chang ’s, request for exemption will reduce current risk levels and thereby enhance safety. My UAS craft do not contain potentially explosive fuel, is smaller, ligh ter and more maneuverable than conventional video and photographic aircraft with much less flight time. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established airfields. I, Denny Ko - We i Chang , have been informally analyzing and recording flight information and will compile safety protocols and the implementation of a flight operations manual for usage that exceeds currently accepted means and methods for safe flight. Formal collectio n of information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. There are no personnel on board my, Denny Ko - We i Chang ’s, UAS. My, Denny Ko -We i Chang ’s, op eration of m y UAS, weighing less than 55 pounds and traveling at lower speeds within limited areas low to the ground will provide an equivalent level of safety as that achieved under current FARs. Accordingly I, Denny Ko -We i Chang , respectfully request tha t the FAA grant my exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned aircraft, and the general public at large. Respectfully submitted, Denny Ko -We i Chang 3701 Knollcroft St. Easton, PA 18045Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 14 

## Appendix A Make and Model DJI Inspire 1 Manual Link https://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_User_Manual_en_

v2.0_1218.pdf B Make and Model DJI Phantom 3 Professional Manual Link https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_

User_Manual__V1.6.pdf C Make and Model DJI Phantom 3 4K Manual Link https://dl.djicdn.com/downloads/phantom_3_4k/en/Phantom_3_4K_User_

Manual_en_1.8.pdf D Make and Model DJI Phantom 3 Advanced Manual Link https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Advanced_Us

er_Manual__V1.6.pdf E Make and Model 3DR Solo Manual Link https://3dr.com/wp - content/uploads/2016/01/v8_01_05_16.pdf F Make and Model Yuneec Typhoon Q500 4K Manual Link https://www.yuneec.com/download/manuals/Typhoon%20Q500%204k -

%20User%20Manual%20V12302015.pdf G Make and Model Yuneec Typhoon G Manual Link https://www.yuneec.com/download/manuals/Typhoon - G - ConnectorVersion - User- Manual - 0918.pdf H Make and Model Yuneec Typhoon Q500+ Manual Link https://www.yuneec.com/download/manuals/typhoon_q500plus_user_man

ual_v2.0.pdf I Personal Protocols j Record of Flight This Appendix includes links to UAS manufacturer's manuals, maintenance instructions, and illustrated parts catalogs. Information regarding design, aircraft performance, fail - safe features, operating limitations, normal and emergency procedures, and maintenance and inspection procedures is contained within the manuals and supplemental informati on documents listed.Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 15



### Ap **pendix A**  **AI RCRA**  **FT SPECS DJI Inspire 1**  Model T600 We ight (Battery Included) 2935 g Hovering Accuracy (GPS mode) Vertical: 0.5 m Horizontal: 2.5 m Max Angular Velocity Pitch: 300°/s Yaw: 150°/s Max Tilt Angle 35° Max Ascent Speed 5 m/s Max Descent Speed 4 m/s Max Speed 22 m/s (ATTI mode, no wind) Max Service Ceiling Above Sea Level 4500 m (Default altitude limit: 120 m above takeoff point) Max Wi nd Speed Resistance 10 m/s Max Flight Time Approximately 18 mi nutes Motor Model DJI 3510H Propeller Model DJI 1345T Indoor Hovering Enabled by default Operating Temperature Range - 10° to 40° C Diagonal Distance 559 to 581 mm Dim ensions 438x451x301 mm Power Spectral Density 9.06mW /MHz CAMERA Name X3 Model FC350 Total Pixels 12.76M Effective Pixels 12.4M Image Max Size 4000x3000 ISO Range 100 - 3200 (video) 100 - 1600 (photo) Electronic Shutter Speed 8s

- 1/8000s FOV (Field of View) 94° CMOS Son y EXMOR 1/2.3” Lens 20mm (35mm format equivalent)f/2.8 focus at ∞ 9 Elements in 9 groups Anti - distortion Still Photography Modes Single shoot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias Ti me - lapseDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 16

Video Recording Modes UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 FHD: 1920x1080p24/25/30/48/50/60 HD: 1280x720p24/25/30/48/50/60 Max Bitrate of Video Storage 60 Mbps Supported File Formats FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG - 4 AVC/H.264) Supported SD Card T yp es Micro SD Max capacity: 64 GB. Class 10 or UHS - 1 rating required. Operating Temperature Range 0° to 40° C CHARGER Model A14 - 100P1A Voltage 26.3 V Rated Power 100 W BATTERY (OPTIONAL) Name Intelligent Flight Batter y Model TB48 Capacity 5700 mAh Voltage 22.8 V Battery T ype LiPo 6S Energy 129.96 W h Net W eight 670 g Operating Temperature Range - 10° to 40° C Storage Temperature Range Less than 3 months: - 20 to 45° C More than 3 months: 22° to 28° C Charging Temperature Range 0° to 40° C Max Charging Power 180 W DJI GO APP Mobile Device System Requirements iOS 8.0 or later, Android 4.1.2 or later Supported Mobile Devices * Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air W i - Fi + Cellular, iPad mini 2, iPad mini 2 W i - Fi + Cellular, iPad Air 2, iPad Air 2 W i - Fi + Cellular, iPad mini 3, and iPad mini 3 Wi - Fi + Cellular. This app is optim iz ed for iPhone 5s, iPhone 6, and iPhone 6 Plus. * Compatible with Samsung tabs 705c, Samsung S6, Sam sung S5, Samsung NOTE4, Samsung NOTE3, Google Ne xus 9, Google Nexus 7 II, Ascend Mate7, Huawei P8 Max, Nubia Z7 mini,Sony Xperia Z3, MI 3, MI PAD, Smartisan T1. *Support for additional Android devices available as testing and development continues.Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 17

**Ap pendix**  **B AI**  **RCRA FT SPECS**  **DJI Phantom 3 Professional**  We ight (including battery and propellers) 1280 g Hover Accuracy · Vertical: +/ - 0.1 m (when Vision Positioning is active) or +/ - 0.5 m

· Horizontal: +/ - 1.5 m Diagonal size (including propellers) 590 mm Max Ascent Speed 5 m/s Max Descent Speed 3 m/s Max Speed 16 m/s (ATTI mode, no wind) Max Service Ceiling Above Sea Level 6000 m (Default altitude limit: 120 m above takeoff point) Operating Temperature 0°C to 40°C GPS Mode GPS/GLONASS CAMERA Sensor Son y EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M) Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞ ISO Range 100 - 3200 (video) 100 - 1600 (photo) Shutter Speed 8s - 1/8000s Image Max Size 4000 x 3000 Still Photography Modes · Single Shot

· Burst Shooting: 3/5/7 shots

· Auto Exposure Bracketing (AEB): 3/5

· Bracketed Frames at 0.7EV Bias

· Time - lapse Video Recording Modes Phantom 3 Advanced

· 2.7K: 2704 x1520p 24/25/30 (29.97)

· FHD: 1920x1080p 24/25/30/48/50/60

· HD: 1280x720p 24/25/30/48/50/60 Supported SD Card T yp es Micro SD Max capacity: 64 GB. Class 10 or UHS - 1 rating required Max Bitrate of Video Storage Phantom 3 Advanced 40 Mbps Supported File Formats · FAT32/exFAT

· Photo: JPEG, DNG

· Video: MP4, MOV (MPEG - 4 AVC/H.264)Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 18

Operating Temperature 0°C to 40°C BATTERY CHARGER Voltage 17.4 V Rated Power Phantom 3 Advanced

· 57 W GIMBAL Controllable Range Pitch - 90° to +30° Stabilization 3 - axis (pitch, roll, yaw) REMOTE CONTROLLER Operating Frequency 2.400 GHz - 2.483 GHz
Max Distance Up to 5 km or 3.1 miles (unobstructed, free of interference) when FCC compliant Up to 3.5 km or 2.1 miles (unobstructed, free of interference) when CE compliant Video Output Port USB Operating Temperature 0°C - 40°C Battery 6000 mAh LiPo 2S Mobile Device Holder For tablet or phone Receiver Sensitivity (1%PER) - 101 dBm ±2 dBm Transmitter Power (EIRP) · FCC: 20 dBm

· CE: 16 dBm Wo rk ing Voltage 1.2 A @7.4 V INTELLIGENT FLIGHT B ATTERY Capacity 4480 mAh Voltage 15.2 V Battery T ype LiPo 4S Energy 68 W h Net W eight 365 g Max Flight Time Approximately 23 minutes Operating Temperature - 10°C to 40°C Max Charging Power 100 W VISION POSITIONING Max Velocity Less than 8 m/s (when 2 m above ground) Altitude Range 50 cm - 300 cm Operating Range 50 cm - 300 cm Operating Environment Surface with clear pattern and adequate lighting (Lux > 15) APP / LIVE VIEW Mobile App DJI GO EIRP 100mWDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 19

Power Spectral Density 6.9mW /MHz Live View Wo rk ing Frequency 2.4GHz ISM Live View Quality 720P @ 30fps (depending on conditions and mobile device) Latency 220m s (depending on conditions and mobile device) Required Operating Systems · iOS 8.0 or later

· Android 4.1.2 or later

Recommended Devices · iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air W i - Fi + Cellular, iPad mini 2, iPad mini 2 W i - Fi + Cellular, iPad Air 2, iPad Air 2 Wi - Fi + Cellular, iPad mi ni 3, and iPad mini 3 W i - Fi + Cellular. This app is optim iz ed for iPhone 5s, iPhone 6, and iPhone 6 Plus.

· Android: Samsung tabs 705c, Samsung S6, Sam sung S5, Samsung NOTE4, Samsung NOTE3, Google Nexus 9, Google Nexus 7 II, Ascend Mate7, Huawei P8 Max, Nubia Z7 mini, Sony Xperia Z3, MI 3, MI PAD, Smartisan T1. *Support for additional Android devices av ailable as testing and development continues.Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 20

**Ap pendix**  **C AI**  **RCRA FT SPECS**  **DJI Phantom 3 4K** We ight (Including Battery And Propellers) 1280 g Hover Accuracy · Vertical: +/ - 0.1 m (when Vision Positioning is active); +/ - 0.5 m

· Horizontal : +/ - 1.5 m Diagonal Size (Including Propellers) 590 mm Max Asecnt Speed 5 m/s Max Descent Speed 3 m/s Max Speed 16 m/s (ATTI mode, no wind) Max Service Ceiling Above Sea Level 6000 m (Software altitude limit: 120 m above takeoff point) Operating Temperature 0°C to 40°C GPS Mode GPS CAMERA Sensor Son y EXMOR 1/2.3" CMOS Effective pixels 12.4M (total pixels: 12.76M) Lens · FOV 94° 20 mm (35 mm format equivalent) f/2.8

· Focus at ∞ ISO Range · 100 - 3200 (video)

· 100 - 1600 (photo) Shutter Speed 8s - 1/8000s Max Image Size 4000 x 3000 Still Photography Modes · Single Shot

· Burst Shots: 3/5/7 shots

· Auto Exposure Bracketing(AEB): 3/5 shots

· Bracket Frames at 0.7EV Bias

· Time - lapse Video Recording Modes · UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

· FHD: 1920x1080p 24/25/30/48/50/60

· HD: 1280x720p 24/25/30/48/50/60 Supported SD Card T yp es · Micro - SD

· Max capacity: 64 GB. Class 10 or UHS - 1 rating required Max Bitrate of Video Storage 60 Mbps Supported File Formats · FAT32/exFAT

· Photo: JPEG, DNGDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 21 · Video: MP4,MOV (MPEG - 4 AVC/H.264) Operating Temperature 0°C to 40°C BATTERY CHARGER Voltage 17.5 V Rated Power 57 W

GIMBAL Controllable Range Pitch - 90° to +30° Stabilization 3 - axis (pitch, roll, yaw) REMOTE CONTROLLER Operating Frequency · 5.725 GHz

– 5.825 GHz

· 922.7 MHz

– 927.7 MHz (Japan) Max Distance · FCC: 1200m

· CE: 500m ( unobstructed, free of interference , 120m above takeoff point) Operating Temperature 0°C - 40°C Battery 2600 mAh LiPo18650 2S Mobile Device Holder For tablet or phone (phone recommended) Transmitter Power (EIRP) · FCC: 19 dBm

· CE: 14 dBm Wo rk ing Voltage 300 mA @7.4 V INTELLIGENT FLIGHT B ATTERY Capacity 4480 mAh Voltage 15.2 V Battery T ype LiPo 4S Energy 68 W h Net W eight 365 g Max Flight Time Approximately 25 minutes Operating Temperature - 10°C to 40°C Max Charging Power 100 W VISION POSITIONING Max Velocity Less than 8 m/s (when 2 m above ground) Altitude Range 50 cm - 300 cm Operating Range 50 cm - 300 cm Operating Environment Surface with clear pattern and adequate lighting (Lux>15) APP / LIVE VIEW Mobile App DJI GO Live View Quality 480P @ 30fps Required Operating Systems · iOS 8.0 or laterDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 22 · Android 4.1.2 or later

Recommended Devices · ios: iPhone 5s 、 iPhone 6 、 iPhone 6 Plus 、 iPad Air 、 iPad Air W i - Fi + Cellular 、 iPad mini 2 、 iPad mini 2 W i - Fi + Cellular 、 iPad Air 2 、 iPad Air 2 W i - Fi + Cellular 、 iPad mini 3 及 iPad mini 3 W i - Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus

· Android: Samsung tabs 705c 、 Sam sung S6 、 Sam sung S5 、 Samsung NOTE4 、 Sam sung NOTE3 、 Google Nexus 9 、 Google Nexus 7 II 、 Ascend Mate7 、 Nubia Z7 mini 、 SONY Z3 EXPE 、 MI 3 、 MI PAD *Support for additional Android devices available as testing and development continues. WI - FI Operating Frequency 2.400 GHz - 2.483 GHz Max Distance · FCC: 1200m

· CE: 500m ( unobstructed, free of interference , 120m above takeoff point) Transmitter Power (EIRP) · FCC: 27 dBm

· CE: 20 dBmDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 23

**Ap pendix**  **D AI**  **RCRA FT SPECS**  **DJI Phantom 3 A** **dvanced** We ight (including battery and propellers) 1280 g Hover Accuracy · Vertical: +/ - 0.1 m (when Vision Positioning is active) or +/ - 0.5 m

· Horizontal: +/ - 1.5 m Diagonal size (including propellers) 590 mm Max Ascent Speed 5 m/s Max Descent Speed 3 m/s Max Speed 16 m/s (ATTI mode, no wind) Max Service Ceiling Above Sea Level 6000 m (Default altitude limit: 120 m above takeoff point) Operating Temperature 0°C to 40°C GPS Mode GPS/GLONASS CAMERA Sensor Son y EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M) Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞ ISO Range 100 - 3200 (video) 100 - 1600 (photo) Shutter Speed 8s - 1/8000s Image Max Size 4000 x 3000 Still Photography Modes · Single Shot

· Burst Shooting: 3/5/7 shots

· Auto Exposure Bracketing (AEB): 3/5

· Bracketed Frames at 0.7EV Bias

· Time - lapse Video Recording Modes Phantom 3 Advanced

· 2.7K: 2704 x1520p 24/25/30 (29.97)

· FHD: 1920x1080p 24/25/30/48/50/60

· HD: 1280x720p 24/25/30/48/50/60 Supported SD Card T yp es Micro SD Max capacity: 64 GB. Class 10 or UHS - 1 rating required Max Bitrate of Video Storage Phantom 3 Advanced 40 Mbps Supported File Formats · FAT32/exFATDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 24 · Photo: JPEG, DNG

· Video: MP4, MOV (MPEG - 4 AVC/H.264) Operating Temperature 0°C to 40°C BATTERY CHARGER Voltage 17.4 V Rated Power Phantom 3 Advanced

· 57 W GIMBAL Controllable Range Pitch - 90° to +30° Stabilization 3 - axis (pitch, roll, yaw) REMOTE CONTROLLER Operating Frequency 2.400 GHz - 2.483 GHz Max Distance Up to 5 km or 3.1 miles (unobstructed, free of interference) when FCC compliant Up to 3.5 km or 2.1 mi les (unobstructed, free of interference) when CE compliant Video Output Port USB Operating Temperature 0°C - 40°C Battery 6000 mAh LiPo 2S Mobile Device Holder For tablet or phone Receiver Sensitivity (1%PER) - 101 dBm ±2 dBm Transmitter Power (EIRP) · FCC: 20 dBm

· CE: 16 dBm Wo rk ing Voltage 1.2 A @7.4 V INTELLIGENT FLIGHT B ATTERY Capacity 4480 mAh Voltage 15.2 V Battery T ype LiPo 4S Energy 68 W h Net W eight 365 g Max Flight Time Approximately 23 minutes Operating Temperature - 10°C to 40°C Max Charging Power 100 W VISION POSITIONING Max Velocity Less than 8 m/s (when 2 m above ground) Altitude Range 50 cm - 300 cm Operating Range 50 cm - 300 cm Operating Environment Surface with clear pattern and adequate lighting (Lux > 15) APP / LIVE VIEWDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 25

Mobile App DJI GO EIRP 100mW Power Spectral Density 6.9mW /MHz Live View Wo rk ing Frequency 2.4GHz ISM Live View Quality 720P @ 30fps (depending on conditions and mobile device) Latency 220m s (depending on conditions and mobile device) Required Operating Systems · iOS 8.0 or later

· Android 4.1.2 or later

Recommended Devices · iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air W i - Fi + Cellular, iPad mini 2, iPad mini 2 W i - Fi + Cellular, iPad Air 2, iPad Air 2 Wi - Fi + Cellular, iPad mi ni 3, and iPad mini 3 W i - Fi + Cellular. This app is optim iz ed for iPhone 5s, iPhone 6, and iPhone 6 Plus.

· Android: Samsung tabs 705c, Samsung S6, Sam sung S5, Samsung NOTE4, Samsung NOTE3, Google Nexus 9, Google Nexus 7 II, Ascend Mate7, Huawei P8 Max, Nubia Z7 mini, Sony Xperia Z3, MI 3, MI PAD, Smartisan T1. *Support for additional Android devices av ailable as testing and development continues.Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 26

**Ap pendix E**  **AI RCRA**  **FT SPECS 3DR Solo**  Cameras: Compatible with GoPro® HERO3, 3+ and 4; optimized for HERO3+ and 4 Streaming video quality: 720p Flight time: 25 minutes; 20 minutes with payload* Range: .5 miles** (.8 km) Max speed: 55 mph (89 km/h) Max ascent speed: 10 m/s in stabilize mode; 5 m/s in “fly” mode Max descent speed: ditto Max payload: 420 g Max altitude: 400 ft per FAA regulation, user adjustable (122 m) Motors: 880 kV Propellers: 10 ′′ diameter 4.5′′ pitch self- tightening (24 cm diameter 144 cm pitch); glass - reinforced nylon Autopilot: Pixhawk 2 Software: APM:Copter Communication: 3DR Link secure Wi Fi network Frequenc y: 2.4 GHz We ight: 3.3 lbs. (1.5 kg) / 3.9 lbs. (1.8 kg) with GoPro® and Solo Gimbal Dim ensions: 10 in. tall (25 cm), 18 in. (46 cm) motor - to - mo tor Flight batter y: Lithium polymer 5200 mAh 14.8 Vdc Battery charge time: ~1.5 hours Controller battery: 2600 mAh 7.2 Vdc rechargeable lithium ion App requirements: iOS 8.0 or later / Android 4.3 or later *Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style and pilot skill. Listed flight time applies to elevations less than 2,000 ft above sea level. **Depending on environmental conditions; controller is expandable, allowing us or third parties to amp up the range in the future. Solo Smart Battery: Rechargeable lithium polymer (Li - Po) 5200 mAh 14.8 Vdc We ight: 1 lb. (.5 kg) Solo Gimbal: Three - axis stabilization Fully compatible with 3DR Solo and GoPro HERO3+ and HERO4; camera charging and stabilization only with HERO3 HDMI video output Wi reless software upgrade through Solo Controllable range: 0° to - 90° pitchDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 27

**Ap pendix**  **F AI**  **RCRA FT SPECS**  **Yuneec Typhoon Q500 4K** Flight Time up to 25 minutes We ight with Batter y and Payload 60.0 oz (1700g) We ight without Batter y and Payload 40.0 oz (1130g) Battery 5400m Ah 3S 11.1V LiPo (included) Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included) Transmitter 10 - channel 2.4GHz with 5.8GHz video downlink (included) 3 Flight Modes Sm art (Follow Me and W atch Me), Angle and Home Maximum Flying Height Default 122m (400ft) above Ground Level (Adjustable via the T yphoon GUI) Maximum Rotation Rate 65°/s Maximum Roll Angle 35° Operating Temperature Range − 5°C to 80°C Radio Control Frequency Band 2.4GHz Max. Descent Speed 2m /s Max. Flight Speed 17m ph / 27 kph (Angle Mode), 22mph / 35 kph (Fo llow Me/W atch Me) Gimbal Camera Ty pe CGO3 We ight 6.9oz (195g) Focusing System Aerial Optimized Fixed Focus Field of View 115° Video Transmission Range FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) with ST10 Video Resolution UHD: 4K at 30FPS, 2.7K at 30FPS, 2.5K at 30FPS

— FULL HD: 1080p at 24/25/30/48/50/60/120FPS Photo Resolution 12 Megapixels Storage (memory ) mi croSD Class 10 ~ 4 to 128 GB Control Angle Accuracy ±0.02° Wh ite Balance Autom atic or manual settings Transmission Band 5.8GHz. Input/Operating Voltage 12VDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 28

Wo rk ing Temperature − 10°C

– 50°C Storage Temperature − 20°C

– 60°C Angular Vibration Range ±0.02° Control Range Pitch: between −90° and 0° Microphone Yes Camera Lens 14mm f/2.8

– No distortion Sensor 1/2.3 ′′ CMOS Personal Ground Station Dim ensions Ty pe ST10+ Operating System AndroidTM Number of Channels 10 Control Transmission Range (Optimum Conditions) FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) Wa rning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times Robust Radio Control Modulation Yuneec Protocol Video Link Frequency Band 5.8GHz Video Transmission Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) Wa rning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times Flight Systems Telemetry Data On Screen Display Yes LED Backlit LCD Screen Capacitive Multi - touch 5 .5 ′′ Tactile (Vibrating) and Audible Feedback Yes Built - in LiPo Batter y Voltage / Capacity 3.6V/5200mAh 18.72W h Screen Resolution 854 × 480px Camera Settings Wh ite balance, light exposure, ISO, shutter speed, video resolution, FPS, record video, take pi ctures CGO Steadygrip V3 Dim ensions We ight (without camera and gimbal) 13.9 oz (395g) Compatible camera CGO2GB / CGO2+ / CGO3Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 29

**Ap pendix**  **G AI**  **RCRA FT SPECS**  **Yuneec Typhoon G** Flight Time up to 25 minutes We ight with Batter y and Payload 60.0 oz (1700g) We ight without Batter y and Payload 40.0 oz (1130g) Battery 5400m Ah 3S 11.1V LiPo (included) Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included) Transmitter 10 - channel 2.4GHz with 5.8GHz video downlink (included) 3 Flight Modes Sm art (Follow Me and W atch Me), Angle and Home Maximum Flying Height Default 122m (400ft) above Ground Level (Adjustable via the T yphoon GUI) Maximum Rotation Rate 65°/s Maximum Roll Angle 35° Operating Temperature Range − 5°C to 80°C Radio Control Frequency Band 2.4GHz Max. Descent Speed 2m /s Max. Flight Speed 8m /s GB203 Gimbal Dim ensions We ight 8.1 oz (230g) Pitch mechanical range - 120° ~ +60° Yaw mechanical range - 45° ~ +45° Roll mechanical range - 45° ~ +45° MK58 Digital Video Downlink Dim ensions (without antenna) We ight 1.27oz (36g) Compatible Camera Hero 3 , Hero 3+ , Hero 4 black/silver Wo rk ing Voltage 5V (±0.5V) Wo rk ing Current 1A Personal Ground Station Dim ensions Ty pe ST10+ Operating System AndroidTMDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 30

Number of Channels 10 Control Transmission Range (Optimum Conditions) FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) Wa rning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times Robust Radio Control Modulation Yuneec Protocol Video Link Frequency Band 5.8GHz Video Transmission Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) Wa rning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times Flight Systems Telemetry Data On Screen Display Yes LED Backlit LCD Screen Capacitive Multi - touch 5.5 ′′ Tactile (Vibrating) and Audible Feedback Yes Built - in LiPo Batter y Voltage / Capacity 3.6V/5200mAh 18.7 2W h Screen Resolution 854 × 480px Camera Settings Wh ite balance, light exposure, ISO, shutter speed, video resolution, FPS, record video, take pictures SteadyGrip Dim ensions We ight (without camera and gimbal) 13.9 oz (395g) GoPro® Hero 3/Hero 3+/Hero 4 black/silverDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 31

**Ap pendix**  **H AI**  **RCRA FT SPECS**  **Yuneec Typhoon Q500+** Flight Time Up to 25 Minutes Dim ension 16.5x16.5x8.3in (420x420x210mm) Diagonal Length W ithout Rotor Blades 22.2in (565mm) Propeller/Main Rotor Diameter 13.0in (330mm) We ight W ithout Battery and Payload 40.0oz (1130g) Battery 5400m Ah 3S 11.1V LiPo (included) Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included) Transmitter 10 - channel 2.4GHz with 5.8GHz video downlink (included) 3 Flight Modes Sm art, Angle and Home Modes Maximum Flying Height Default 122m (400ft) Above Ground Level (Adjustable via the Q500 GUI) Maximum Rotation Rate 65°/s Maximum Roll Angle 35° Operating Temperature Range

- 5 °C to 80 °C Camera Gimbal System Dim ension 4.5x1.4x2.9in (115x135x74mm) We ight 6.5oz (185g Focusing System Aerial Optimized Fixed Focus Field of View 130° Video Transmission Range FCC Compliance: Up to 600m (1968.5 ft) Video Transmission Range CE Compliance: Up to 300m (984.25 ft) with ST10 Video Resolution FULL HD 1080p - Adjustable 60, 50 or 48 FPS Photo Resolution 16 Megapixels Storage (memory ) mi croSD Class 10, 4 to 128GB Control Angle Accuracy ±0.02° Wh ite Balance Autom atic Wh ite Balance Transmission Band 5.8GHz Input/Operating Voltage 7.0V to 14.0V DC Wo rk ing Temperature 0°C - 50°C Storage Temperature - 20 °C to 60 °C Angular Vibration Range ±0.02° Control Range Pitch: between - 90° and 0°Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 32

Personal Ground Station Control Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) Robust Radio Control Modulation Yuneec Protocol Video link Frequency Band 5.8GHz Video Transmission Distance/Ran ge (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) Flight Systems Telemetry Data On Screen Display (OSD) Yes LED Backlit LCD Screen Capacitive Multi - Touch 5.5” Tactile (Vibrating) and Audible Feedback Yes Built - In LiPo Batter y Voltage / Capacity 3.6V/5200mAh 18.72W h Charger Auto - Charge Mode via Micro - B USB Cable with AC to 5V DC USB Power Supply (Included)Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 33

**Ap pendix I**  **Personal Protocols** Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. As such, safety protocols and controls must be implemented through pre - flight pre paration and during flight. **Pre -**  **Flight Protocol:**  Check batteries with voltage meter to insure fully charged and ready for use.  Inspect batteries for damage or leakage that may affect proper operation.  Inspect propellers for cracks, chips or damage that may cause sudden loss of propuls ion or unmanageable/uncontrolled flight.  Check all GPS and Telemetry connections prior to flight.  Check weather forecasts for wind advisory or other conditions that my impact flight.  Consult Sky Vector aeronautical Charts (Skyvector.com) for airport vici nity and flight paths of possible air traffic.  Contact respective airport to advise of estimated flight time, estimated flight duration, estimated elevation of flight, and any other pertinent information.  Inspect flight area for o Vicinity of public safety helipads/heliports o Vicinity of medical helipads/heliports o Vicinity of light poles vicinity or utility wires o Vicinity of trees flocks of birds that may cause interference and potential flight impact Vicinity of any elevated obstructions that may pose pot ential flight hazard o Vicinity of roadways with moderate to heavy traffic that can be distracted public Gatherings that may attract viewers optional point of control for best visual site of UAS while in flight o Emergency landing areas  Takeoff and landing o Inspect area for best and safest point of takeoff and landing o If in a subdivision or area that is within 150 feet of a residential street, post warning s ign(s)/stand(s) "Attention Aerial Photography In Progress. Remain Back 150 Feet " **Flight Protocol:**  T ak eof

f and land from same location ( have alternate landing areas in case of emergencies) remain alert to birds, sound or aircraft, curious public, and approaching vehicles do not allow anyone to engage in conversation or distract the remote control pilo t restrict flight to minimal elevation sufficient to acquire desired results remained prepared for emergency landing at all times pay attention to flight time

– warning meter for low voltage.  Set voltage meter alarm for low voltage and flight timer as a s afety alert land UAS and shut down propulsion immediately following landing

– priority of disconnecting batteriesDenny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 34

**Post F light**  **Protocol :**   Disconnect battery to prevent accidental activation of propulsion system  Secure UAS in a safe location  Remove all wa rning signs from public access areas **Emergency**

**or Suspected Hazard:**  Immediately land UAS at safest and closet ground location in the event : o Manned aircraft is heard or seen in vicinity of flight o There is a public gathering within established safety bo undary wanting to observe flight o Pilot is being distracted from focusing on flight and safety o Sudden change in weather (wind bursts) o Sudden increase in vehicular traffic in vicinity of flight o Birds enter into proximity of flight o Any sudden unsafe even t that can cause collision, distraction or interruption of control Safety for public on the ground as well as manned aircraft above is an essential and utmost consideration for aerial videos and photography. Ma intaining a record of safe flight for FAA request and for determining future UAS safety protocols is imperative.
Additional Operation/Maintaining Before each flight:  Check all hardware to ensure it is securely tightened.  Check that the motor is level and locked in place.  Check the propeller to ensure it is tight and there are no visible signs of cracks, stress,  Check all wiring to motors, motor controllers, batteries, and flight controller for signs of chafing and/ or cracking.  Check all navigational lighting fo r security and prope r operation. After 45 hours of flight  Remove and check all motors and motor mounts for signs of wear and tear. Replace as necessary.  Remove motor controllers and visually inspect and check for damage. Replace as necessary.  Remove flight controllers and visually inspect and check for damage. Replace as necessary.  Remove propellers and visually inspect for damage and/or chips. Replace if propeller is questionable.  Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.  Check for updates to flight controller firmware. If available, install and perform a minimum of 15 test flights before conducting commercial work.Denny Ko -We i Chang, Easton, PA - Section 333 Exemption Petition 35

**Ap pendix J**  **Record of Flight** Date: Location: Mission: P re - f light Inspection: YES NO Comment: We ather: Proximity to airport: (see attached map pinpointing approximate location of flight) Airport notified: YES NO Date: Time: Phone Number: Contact Name: Nearest major intersection: Proximity to medium traffic road: Proximity to heavily traveled roadway road: Proximity to congested population:
We ather : Good Fair Poor Comment : Visibility: Good Fair Poor Comment : Wi nd Direction: Wi nd Speed (mph): Comment : Approx. takeoff time (local): Approx. Landing Time (local): Estimated Elevation Safety Concerns: Additional Comments: