UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. ___

_______________ _

Docket Operations, M

- 30 U.S. Department of Transportation (DOT) 1200 New Jersey Avenue, SE

Room W12

- 140, West B uilding Ground Floor Washington, DC 20590

- 0001

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

AERIAL IMAGES AND VIDEO LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91 .7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), AND 91.417(a) & (b)

CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 2 AND DJI INSPIRE

1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA

MODERNIZATION AND REFORM ACT OF 2 012 (PUBLIC LAW 112

- 95)

Submitted on January 3, 201 6

AERIAL IMAGES AND VIDEO LLC

c/o DAVID R. HEATH , MANAGER

7 CASEY CIRCLE NASHUA, NEW HAMPSHIRE 03063

6 03.493.3385Page 2 of 26 TABLE OF CONTENTS Page

GLOSSARY OF A BBREVIATIONS

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

SUMMAR Y...................

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

INTRODUCT ION AND INTERESTS OF PETITIONER

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

BACK GRO UND

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

BASIS FOR P ETITION............................................................................................... 5

A. NAME AND ADDRESS OF PETITIONER

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

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

AERIAL IMAGES AND VIDEO LLC SEEKS EXEMPTION

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

C. THE EXTENT OF RELIEF AERIAL IMAGES AND VIDEO LLC

SEEKS AND THE REASON AERIAL IMAGES AND VIDEO LLC

SEEK S THE RELIE F

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

D. THE REASONS WHY GRANTING AERIAL IMAGES

AND VIDEO LLC ’S REQUEST WOULD BE IN THE

PUBLIC INTEREST

... .................................................... .................. .. 1 3

E. THE REASONS WHY GRANTING THE EXEMPTION

WOULD NOT ADVERSELY AFFECT SAFETY

................... . ............ 1 5

THE REASONS WHY GRANTING AN EXEMPTION

FROM THE REQUIREMENTS OF 61.113( A ) AND ( B )

WOULD NOT ADVERSELY AFFECT SAFETY...............

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

CO NCLUSION

.................................................... .... ................................................. 2 3

EXHIBITSPage 3 of 26 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organizat ion

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR F ederal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss o f Link

NAS National Airsp ace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

sUAS Small Unmanned Aircraft Sys tem (under 55 pounds Gross Weight)

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

DJI UAV manufacturer

ESC Electronic speed control

FPV First Person View

LI

- PO Lithium Polymer battery

RCV Radio Controlled vehiclePage 4 of 26 SUMMARY

AERIAL IMAGES AND VIDEO LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 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 an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit

AERIAL IMAGES AND VIDEO LLC to operate an Unmanned Aircraft System (U AS) for the commercial purpose of conducting aerial video and photography for marketing, film sets, real estate photography, commercials, special events, wedding cinematography, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is DAVID R. HEATH, a nd I am the Manager and co

- owner of AERIAL IMAGES

AND VIDEO LLC. I also hold a Commercial pilot certificate with Multi

- engine and instrument ratings, along with a 3 rd Class Medical Certificate.

DAVID R. HEATH is also a drone builder and operator (pilot) with expertise and knowledge in aspects of building

, programing and operating multiple types of UAS'S along with camera set up and operation. DAVID R. HEATH is also a n experienced professional photographer

who provides clients with the highest quality digi tal content for use in their commercial, personal, and non

- profit multimedia projects. DAVID R. HEATH is a member of the Academy of Model Aeronautics (“AMA”) and has 17 years of Radio Controlled aircraft experience including helicopters

. The objective of AERIAL IMAGES AND VIDEO LLC’s aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses, along with test ing of repaired drones for clients in a safe testing location away from all o bstacles and people at all times. AERIAL IMAGES AND VIDEO LLC will also provide knowledge of s UAS to others and promote safe s UAS operations.Page 5 of 26 BACKGROUND

Unmanned Aircraft Systems: DJI Phantom Vision 2 Plus, DJI Inspire 1

AERIAL IMAGES AND VIDEO LLC seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 2 Vision + and DJI Inspire I are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or sma rt phone systems. The DJI Phantom 2 Plus has a maximum gross weight of approximately 2 pounds 7 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Inspire 1 has a maximu m gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Phantom 2 and DJI Inspire l UA ’ s are equipped with four main rotors; driven by electric moto rs powered by a Lithium Polymer battery.

The DJI Phantom 2 and DJI Inspire 1 s UA S ’ s that will be operated by AERIAL IMAGES

AND VIDEO 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 IMAGES AND VIDEO LLC , pursuant to the provisions of the F ederal Aviation Regulations (14 C.F.R. § 11.61) and th e FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmann ed Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Phantom 2 and the DJI Inspire 1

sUAS in the National Airspace System (NA S), and for an exemption from the r equirements of 14 C.F.R §§ 61.1 13(a) & (b), 91.7(a), 91.119, 91.121, 91.l51(b), 91.405(a), 91.407(a)(I), 91.409(a)(l) & (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 IMAGES AND VIDEO LLC operation of DJI

Phantom 2 and DJI Inspire 1 s UAS ’ s meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance wit h 14 C.F.R. Part 21, Subpart H.

Accordingly, AERIAL IMAGES AND VIDEO LLC requests relief from Sections 91.405(a), 91.407(a)(I), 91.409(a)(I) & (a)(2), and 91.417 (a) & (b), as these sections set forth requirements for maintenance that only apply to aircra ft with an airworthiness certificate.

AERIAL IMAGES AND VIDEO LLC submits that the requested relief is proper since an equivalent level of safety will be ensured. AERIAL IMAGES AND VIDEO LLC will use experienced personnel or technicians to perform mainten ance, alterations, or preventive

maintenance on the sUAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1

Ins truction Manual). Furthermore, AERIAL IMAGES AND VIDEO LLC will document and

maintain all maintenance records for the DJ I Phantom 2 and DJI Inspire 1 sUAS

.Page 6 of 26 Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is request ed by AERIAL IMAGES AND VIDEO LLC to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level

c ertificate, 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

DJI Phantom 2 and DJI Inspire 1 sUAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and st ructures.

AERIAL IMAGES AND VIDEO LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 2 and DJI Inspire 1 sUAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. A s such, AERIAL

IMAGES AND VIDEO LLC submits that he will ensure that the DJI Phantom 2 and DJI Inspire l sUAS are in an airworthy condition, prior to every flight, by determining that the

sUAS are in compliance with the operating documents (i.e., Monthly M aintenance Log, and

DJI Phantom 2 and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.

AERIAL IMAGES AND VIDEO LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 2 and DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI

Phantom 2 and DJI Inspire 1 UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio comm unications telemetry data link, which downlinks from the

UA to the GCS for active monitoring of the flight path. This altitude information, combined

with AERIAL IMAGES AND VIDEO LLC operation of the DJI Phantom 2 and DJI Inspire

1 sUAS within visual line o f sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, AERIAL IMAGES AND VIDEO LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. AERIAL IMAGES AND VIDEO LLC submits that safety will not be affected by operation

of the DJI Phantom 2 and DJI Inspire 1 s UA S ’s during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power

to fly for a total duration of approximately 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.Page 7 of 26 In accordance with 14 C.F.R. § 11.81, DAVID R. HEATH provides the following

in fo rma tion in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

AERIAL IMAGES AND VIDEO LLC David R. Heath, Manager 7 Casey Circle Nashua, New Hampshire 03063

603. 493.3385 drh916@me.comPage 8 of 26 B. The Specific Sections Of 14 C.F.R. from Which AERIAL IMAGES AND VIDEO

LLC Seeks Exemption.

1. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirements Of Section 61.1l3(a) a nd (b).

S ect ion 61.113, entitled Private pilot privileges and limitations: Pil ot in command, Subsections (a) and (b) prescribe the following, in relevant part:

a. No person who holds a private pilot certificate may act as a pilot in command (PIC)

of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

b. A private pilot may, for compensation or hire, a c t as PIC of an aircraft in connection with any business or employment if

i. The flight is only incidental to that business or employment; and

ii. The aircraft does not carry passengers or pro perty for compensation or hire.

2. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirements

Of Section 91.7(a).

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

3. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirements

Of Section 91.121.

a. Section 91.121, entitle d Altimeter settings, subsection (a), states the following, in

part:

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

- Bel ow 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;

(ii) If there is no station within the area prescribed in paragraph (a)(l)(i) of this section, the current reported altime ter setting of an appropriate available station;

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

4. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forec ast 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.Page 9 of 26 5. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirement Of

Section 91.40 5(a).

Section 91.405, entitled Mainte nance required, subsection (a) states the following: Each owner or operator of an aircraft :

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

6. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirements Of Section 91.407(a)

Section 91.407, entitled Operation after maintenance, pr eventive maintenance, rebuilding, or alteration ;

a. Subsection (a)(1 ), states the following: No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

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

7. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirements

Of Sections 91.409(a)( 1 ) And 91.409(a)(2).

a. Section 91.409, entitled Inspections, subsection (a), states the following:

i. Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, 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 pe rson authorized by § 43.7 of this chapter;

or

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

8. AERIAL IMAGES AND VIDEO LLC Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b)

.

a. Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

i. Except 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 i n paragraph (b) of this section:

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

records of the 1 00 hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) an d each engine, propeller, rotor, and appliance of an aircraft. The records must

include

(a) A description (or reference to data acceptable to the Administra tor) of the work performed; andPage 10 of 26 (b) The date of completion of the work performed; and

(c) The signature, and ce rtificate number of the person approving the

aircraft for r eturn to service.

Records contai ning the following information:

(i) The total time in service of the airframe, each engine, each propeller,

and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

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

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

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the air frame and currently installed engines, rotors, propellers, and appliances.

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

(1) The records s pecified in paragraph (a)(1 ) of this section shall be retained

until the work is repeated or superseded by other work or for I year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished t o a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for retur n to service.Page 11 of 26 C. The Extent Of Relief AERIAL IMAGES AND VIDEO LLC Seeks And The Reason

AERIAL IMAGES AND VIDEO LLC Seeks The Relief.

1. Relief From Section 61.113(a) And (b) :

a. Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations:

Pilot in command , is requested to the extent necessary to allow a PIC holding a private pilot or hi gher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested

since the lim itations set f orth in Section 61.1 13(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to t hat business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, AERIAL IMAGES AND

VIDEO LLC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 UAS or DJI Inspire 1 UAS unless that PIC has met certain flight

- hour and curren c y requirements, demonstrating

that the P I C is able to safely operate either the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with the operations specifications a s described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, AERIAL

IMAGES AND VIDEO LLC submits that all flights of the DJI Phantom 2 and DJI Inspire 1 sUAS , conducted by the PIC pursuant to the grant of this Petition: (1) will

be incidental to AERIAL IMAGES AND VIDEO LLC ’s business; and (2) will not carry passengers or property for compensation or hire

.Page 12 of 26 b. Relief from Section 91.7(a) entitled Civ il aircraft airworthiness , is requested to the extent required to allow AERIAL IMAGES AND VIDEO LLC to determine that

the DJI Phantom 2 and DJI Inspire 1 sUAS are in airworthy condition prior to ever y flight by ensuring that the U AS is in compliance with t he operating documents (i.e.,

AERIAL IMAGES AND VIDEO LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual).

AERIAL IMAGES AND VIDEO LLC seeks the requested relief because the DJI

Phantom 2 and DJI I nspire 1 sUAS do not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Therefore, AERIAL IMAGES AND

VIDEO LLC will ensure that the DJI Phantom 2 and DJI Inspire 1 sUAS are in airworthy condition based upon its complianc e with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 User Manual s; prior to every flight, and further, determine that the aircraft are in condition for safe flight,

as stated in the co nditions and limitations b elow

. Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the DJI Phantom 2 and DJI Inspire 1 sUAS , which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), AERIAL IM AGES AND VIDEO

LLC seeks the requested relief because the DJI Phantom 2 and DJI Inspire 1 UA's altimeter may be set on the ground to zero feet AGL, rather than the local barometric

pressure or field altitude, before each fl ight. Considering the limited alt itude of the proposed operation s, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable co nditions and limitations stated below. As more fully set forth herein, an equivalent level of safe ty will be maintained since the DJI Phantom 2 and DJI Inspire 1 UAs are equipped with a bar ometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be

established prior to each flight, and provides the PIC with altitude information of the

UA on the heads

- up display of the GCS.

c. Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to a ll ow flights of the battery powered

DJ I Phantom 2 and DJI Inspire 1 s UA S during da ylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration

of approximately 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minute s. AERIAL IMAGES

AND VIDEO LLC seeks the requested relief because without an exemption from Section 91.151 (b), the flight time duration of the battery powered DJI Phantom 2 and DJI Inspire 1 UAs will severely constrain the practicality of any aerial video or still photo flight operations that AERIAL IMAGES AND VIDEO LLC proposes to conduct pursuant to this Petition. S ignificantly, as set forth below, the technical specifications of the DJI Phantom 2 and DJI Inspire 1 sUAS , the DJI Phantom 2 and DJI Inspir e 1 operating documents, and the operating limitations proposed by

AERIAL IMAGES AND VIDEO LLC , ensure that AERIAL IMAGES AND

VIDEO LLC will safely operate the battery powered DJI Phantom 2 and DJI Inspire

1 s UA S during daylight hours in visual meteorologi cal conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5Page 13 of 26 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

d. Sections 9 1.405(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 IMAGES AND VIDEO

LLC requests relief from these Sections because the DJI Phantom 2 and DJ I Inspire 1

sUAS do not require air worthiness certificates. As set forth more fully below, the DJI

Phantom 2 and DJI Inspire 1 sUAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, AERIAL IMAGES

AND VIDEO LLC will use trained technicia ns to perform maintenance, alterations, or preventive maintenance on the sUAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., AERIAL IMAGES AND VIDEO

LLC Aerial Operations Manual, Monthly Maintenance Log, and D JI Phantom 2 and

DJI Inspire 1 Instruction Manua l ). Furthermore, AERIAL IMAGES AND VIDEO

LLC will document and maintain all maintenance records for the DJI Phantom 2 and

DJI Inspire 1 sUAS

.

D. The Reasons Why Granting AERIAL IMAGES AND VIDEO LLC Request Would Be In The Public Interest: That Is, How I t Would Benefit The Pu blic As A

Whole.

Granting the present Petition will further the public interest by allowing

AERIAL IMAGES AND VIDEO LLC to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape

over certain areas of the United States.

Additionally, use of the DJI Phantom 2 and DJI Inspire 1 sUAS will decrease congestion of the NAS, reduce pollution, crashes and accidents caused by pi lot error and provide significant benefits to the economy. Notably, the benefits of AERIAL IMAGES

AND VIDEO LLC ’s proposed operation of the DJI Phantom 2 and DJI Inspire 1 sUAS will

be realized without conflicting with or violation of any privacy i ssues.

1. T he Public Will Benefi t From Decreased Congestion Of The NAS.

The DJ I Phantom 2 and DJI Inspire 1 U As are battery powered and serve as a safe, efficient, and economical alternative to the manned 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 2 or DJI Inspire

1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase t he 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

reduc ed. The DJI Phantom 2 and DJI Inspir e 1 UAs do not require an airport to takeoff or land. Likewise, a reduction of 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 , arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2

and DJI Inspire 1 sUAS

.Page 14 of 26 Conducting aerial media acquisitions with the DJI Phantom 2 and DJI I nspire 1

s U AS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors,

the DJI Phantom 2 and DJI Inspire 1 sUAS 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

which burn approximatel y 20

- 30 gallons per hour of leaded aviation fuel. The DJI

Phantom 2 and DJI Inspire 1 UAs, while reducing the carbon footprint of aeri al acquisitions, also eliminate noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI

Phantom 2 and DJI Inspire 1 sUAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with

traditional m ann ed aircraft flight ope rations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 2 and DJI Inspire 1 UAs (weighing approximately 2 pounds 14 ounces and 6 pounds 7.5 ounces respectivel y, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, an d in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Ph otography Operations With The DJI Phantom 2

and DJI Inspire 1 sUAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 and DJ I Inspire 1 sUAS are also an economical alternative to using manned aircraft to conduct similar a erial operations. As such, operation of the DJI Phantom 2 and DJI Inspire 1 sUAS will allow United States based companies, such as AERIAL IMAGES AND VIDEO

LLC to remain 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 adopt new and alternative technology in order to remain competitive. Operating the battery p owered DJI Phantom 2 and DJI Inspire 1 sUAS

utilizes 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 2 and DJI Inspire 1 sUAS , companies such as AERIAL IMAGES AND VIDEO LLC can remain competitive and profitable, and therefore, provide gre ater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commerci al

use of the DJI Phantom 2 and DJI Inspire 1 sUAS , provides a stab le workforce that increases consumer spending; improves local, state, and federal tax revenues; and

al lows 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.Page 15 of 26 Similar to the manned aerial media acquisition fli ght operations that have been conducted for decades, A ERIAL IMAGES AND VIDEO LLC proposed operation

of the DJI Phantom 2 and DJI Inspire 1 sUAS would not implicate any privacy issues. Specifically, the DJI Phantom 2 and DJI Inspire 1 sUAS will be operated only in compliance with operating documents (i.e., AER IAL IMAGES AND VIDEO LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.Page 16 of 26 E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That

P rovided B y The Rule From Which AERIAL IMAGES AND VIDEO LLC Seeks Exemption.

1. Reasons Why The DJI Phantom 2 and DJI Inspire 1 sUAV Meet The Conditions Of

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

2. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, AERIAL IMAGES AND VIDEO LLC ’s operation of the DJI Phantom 2 and DJI Inspire 1 sUAS meet the conditions of FMRA Section 333, and will not require an airworthiness certifica te 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 cr eate a hazard to users of the N AS 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 requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Sec retary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of thi s Act.

b. Assessment of Unmanned Aircraft Systems.

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

i. Which types of un manned aircraft systems, if any, as a result of their size, weight, speed, operational capabi lity, 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 or the public or pose a threat to national security; and 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 systems identified under paragraph (J).

c. Requirements for Safe Operation.

-- If the Secretary determine s under this

section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.Page 17 of 26 In seeking this exemption, AERIAL IMAGES AND VIDEO LLC submits that the DJI

Phantom 2 and DJI Inspire 1 sUAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 and DJI Inspire 1

sUAS

, (b) the pi lot certification requirement and (c) the specific operating limitations.

i. The Specifications Of The DJI Phantom 2 and DJI Inspire 1 sUAS

Demonstrate Its Safe Characteristics.

The DJI Phantom 2 and DJI Inspire 1 sUAS do not create a hazard to u sers of the

NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

ii. Technical Specifications Of The DJI Phantom 2 and DJI Inspire 1 sUAS

.

The DJI Phantom 2 and DJI Inspire 1 Specifications and Data Sheet, attached

hereto as Exhibits A and B, set the technical specifications of the DJI Phantom 2 and DJI Inspire 1 sUAS forth.

iii. The DJI Phantom 2 and DJI Inspire 1 sUAS Autonomous Flight And Navigation Modes Enable The sUAS To Remain Within A Defined Operational Area.

The DJI Phantom 2 and DJI Inspire 1 sUAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 2 and DJI Inspire 1 sUAS is provided at pages 25

- 3 5 of the DJI Phantom 2 and pages 12

- 16 and 45

- 50 of the DJI Inspire I User Manuals, attached hereto as Exhibit C and D.

iv. The DJI Phantom 2 and DJI Inspire 1 sUAS Are Designed For Automatic

Return To Home Point Or Hover In The Event Of Loss Of The Control L ink Or Navigation.

When the Control Link is lost, the DJI Phantom 2 and DJI Inspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI

Phantom 2 and DJI Inspire 1 UAs do not reacquire control link data from the

GC S, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the

DJI Phantom 2 UA S are set forth at pages 27 and 28 and for the DJI Inspire 1 at pages 13 through 15 of the DJI Phantom 2 a long with complete DJI Inspire 1 User Manuals, attached hereto as Exhibit C and D.

v. The DJI Phantom 2 and DJI Inspire 1 Ground Control Station (“ GCS ”) And It's Operation.

A complete description of the operation and specifications of the DJI Phantom 2 and DJI Inspire 1 GCS and flight control software is provided at pages 32 through

4 4 of the DJI Phantom 2 User Manual and pages 23 through 33 of the DJI In spire

1 User Manual. DJI Phantom 2 and DJI Inspire 1 User Manuals are attached

hereto as Exhibits C and D.Page 18 of 26 vi. Flight Operations Of DJI Phantom 2 and DJl Inspire 1 sUAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety

Observe r.

vii. AERIAL IMAGES AND VIDEO LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2 and DJI Inspire 1 sUAS . Additionally, a safety

observer will assist all pilots during flight time.

viii. Flights Of DJI Phantom 2 and DJI Inspire 1 sUAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, AERIAL IMAGES AND VIDEO LLC proposes to commercially operate D JI Phantom 2 and D JI Inspire 1 U A s for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following airc raft described in the operating documents, rotorcraft sUAS weighing less than 55 pounds maximum gross weight: DJI Phantom 2 and OJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

3. The U As may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special re quest is made and approved by

A TC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visua l line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's

FAA

- issued a irman medical certificate.

6. The use of first person view (F PV) by the PIC or safety observer (SO) is

not pe rm itted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can p erform the functions prescribed in the operating

documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not pe rm itted to operate the came ra or other

instruments.Page 19 of 26 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the gran t of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon req u est. The operator must also present updated and revise d documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its g rant of exemption. The FAA's UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a

condition f or safe fli gh t. If the inspection reveals a c ondition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenan ce has been performed and the U AS is found to be in a condition for safe flight. The Ground Contro l Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

11. 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. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g.

i noperable components, items, or equipment, not already covered in the

relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirem ents.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the airc raft records, including total time in service, description of work accomplished, and the signature of the

au thorized person returning the U AS to service.

15. Each sUAS operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The auth orized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.Page 20 of 26 17. The PIC must possess at least a private pilot certificate and at least a

current third

- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasiv e and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a

ma nn er consistent with 14 C.F.R. § 61.51 (b). Flights for the purposes of training the operat or's PICs are permitted under the terms of the exemption. However, training operations may only be c onducted during dedicated training sessions. During training, proficiency, and experience

building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be co nducted under visual meteorological conditions (V MC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not

authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a

letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator's COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when vi sibility is less than 3 statute miles

from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a

pre

- determined location within the planned operating area and land or be recovered in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power t o fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operation s under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hoursPage 21 of 26 in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspac e requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. pa rt 47, and have identification (N

- Number) markings in accordance with 14 C.F .R. part 45, Subpart C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be

available to the PIC at the Ground Control Station of the UAS any time

the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

29. The U A must remain clear and yield the right of way to all manned aviation operations and activities at all times.

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

vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential 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. The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential pers ons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/contro ller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported t o the FAA's UAS Integration Office (AFS

- 80)Page 22 of 26 within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Website: www.ntsb.gov.Page 23 of 26 Reasons Why An Exemption From The Requirements Of Secti on 61.113(a) And (b) Wou ld Not Adversely Affect Safety.

AERIAL IMAGES AND VIDEO LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 2 and DJI Inspire 1 sUAS unless that PIC has demonstrated, by meeting minimum flight

- hour and c u rrency requirements, that the PIC is able to safely operate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emerge ncy maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering AERIAL IMAGES AND VIDEO LLC ’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot

ae ronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI

Phantom 2 or DJI Inspire 1 UAS, AERIAL IMAGES AND VIDEO LLC submits

that the additional man ned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for AERIAL IMAGES AND

VIDEO LLC ’s specific proposed flight operations. The FAA has previously granted

relief from Section 61.113(a) and (b ) 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, 11150, 11153, 11156, 11158, 11159, 11160, 11161). AERI AL IMAGES AND VIDEO

LLC will not allow any PIC to operate the DJI Phantom 2 or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or

the DJI Phantom 2 or DJI Inspire 1 UAS training and currency requirements, tha t the PIC is able to safely operate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifical ly, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51 (b), 25 hours of total time as a UAS rotorcraft pilot (with a

minimum of 5 hours of those hours as a UAS pilot operating the same make and

model of UAS to be used f or operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062,11138, and 11153, prior

documented f light experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during AERIAL IMAGES AND

VIDEO LLC ’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance w ith applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and

l ogged, in a manner consistent with 14 CFR 61.51 (b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a

multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also

have ac c umulate d and logged a minimum of 5 hours as a s UAS pilot operating the

same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hour s make and model time may be included in the 10Page 25 of 26 EXHIBIT A

DJI PHANTOM 2 VISION +

TECHNICAL SPECIFICA TI ONS

AERIAL IMAGES AND VIDEO LLC only utilizes safe and reli able sUAS . DJI is an industry leader in small UAS production. DJI sUAS are complete with leading edge and proven software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also he set to limit flight t o no higher than a predetermined and set altitude as well as limit flight to a predete rmin ed and set distance. In addition, DJI software provides

real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

DJ I Phantom 2

1.1 Aircraft 1.1.1 Supported Battery

- DJI 5,200m A h 2S LiPo Battery 1.1.2 Weight (Battery & Pr opellers Included)

- 2 lbs 11.81 oz (1

, 242g) 1.1.3 Hover Accuracy (Ready to Fly)

- Vertical: .8m; Horizontal: 2.5m 1.1.4 Max Yaw Angular Velocity 20 0 ° /s 1.1.5 Max Tilt Ange l 35 °

1 .1.6 Max Ascent / Descent Speed: Ascent 6m/s Descent 2m / s 1.1.7 Max Flight Speed

- 15m/s (NOT RECOMMENDED)

1.2 Gimbal 1.2.1 Working Current

- Static: 750mA; Dynamic: 900mA 1.2.2 Control Accuracy

- ±O.03 °

1. 2.3 Controllable Range

- Pitch: 90 ° to 0 ° 1.2.4 Maximum Angular Speed Pitch: 90 ° /s

1.3 Camera

1.3. 1 Operating Temperature Range 32 ° F

- 104 ° F (O ° C to 40 ° C)

1.3.2 Sensor Size 1⁄2

. 3 "

1.3.3 Effective Pixels : 14 M eg a pixels

1.3.4 Resolution 4384x3288 px 1.3.5 HD Video Recor ding: 1080p 30 & nop 1.3.6 Recording Field of View: 110 ° /85 °Page 26 of 26 EXHIBIT B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

AERIAL IMAGES AND VIDEO LLC only utilizes safe and reliable sUAS. DJI is an industry leader in small UAS production. DJI sUAS are complete wit h leading edge and proven software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predeter mined and set distance. In addition, DJI software provides

real

- time altitude and location information to the PIC via the linked monitor (smart phone / tablet devices)

DJI Inspire 1

1.1 Aircraft

1.1.1 Model

- T600

1.1 .2 Weight (Battery Included)

- 6 l bs 7. 52910z (2

, 935g) 1.1.3 Hovering Accuracy (GPS Mode)

- Vertical: 0.5m; Horizontal: 2.5m 1.1.4 Max Angular Velocity: Pitch: 300 °/s ; Yaw: 150 °/s 1.1.5 Max Tilt Angle: 35° 1.1.6 Max Ascent Spe ed: 5m / s 1.1.7 Max Descent Speed: 4m/s 1.1.8 Max Speed: 22m/ s (AT TI mode, no wind

- NOT RECOMMENDED) 1.1.9 Max Flight Altitude 4

, 500m MSL

1.1.10 Max Wind Resistance: 10m / s 1.1.11 Max Flight Time

- Approximately 18 minutes

1.1.12 Motor M odel: DJI 3510 1.1.13 Propeller Model: DJI 1345 1.1.14 Operating Temper ature Range : 14 ° F to 104 ° F (

- 1 0 ° C to 40°C)

1.1.15 Dimensions 438x451x201 mm 17.25” x 17 .76 " x 7.9 "

1.2 Gimbal

1.2.1 Model: ZENMUSE X3 1.2.2 Output Power (with camera) : Static: 9W; In Motion: 11 W 1.2.3 Operating Current

- Static: 750mA; In Motion: 900mA

1.2.4 An gular Vibration Range

- ±0.03 ° 1.2.5 Mounting

- Detachable

1. 2.6 Controllable Range: Pitch:

- 90 ° to +30°; Pan: ±320 ° 1.2.7 Mechanical Range: Pitch:

- 125 ° to + 45°; Pan: ±330 ° 1.2.8 Max Controllable Speed: Pitch: 120 ° /s; Pan: 180 ° /s

1.3 Transmitter

1.3. 1 Name

- CI 1.3.2 Operating Frequency 5.728 to 5.850 GHz; 2.400

- 2.483GHz 1.3.3 Communicating Distance (unobst ructed ): 3.1 miles 1.3.4 Output Power

- 9W 1.3.5 Operating Temperat ure Range

- 14 ° F to 104 ° F (

- 10°C to 40°C)

1.3 .6 Battery 4,500mAh 2S or optional 5,70 0mAh LiPo 2S

All specifications can be found in the attached user m anual or at https://dl.djicdn.com/downloads/inspire_1/en/Inspire%20_1_User_Manual__V1.8.p df