### September 17, 2015

Exemption No. 12892 Regulatory Docket No. FAA

−2015

−2637

Mr. Lawrence Bridges Owner Black Forest GunWurk, LLC dba SAS Defense dba Southern Air Services 101 Demorest Square Demorest, GA 30535 Dear Mr. Bridges: This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends. By letter dated May 22, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf ofBlack Forest GunWurk, LLC dba SAS Defense dba Southern Air Services (hereinafter petitioner or operator) for an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to conduct photogrammetry, aerial photography, mapping, and surveying

. See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner. Airworthiness Certification The UAS proposed by the petitioner are the DJI Phantom 2 Vision+ and DJI Inspire 1

. In accordance with the statutory criteria provided in Section 333 of Public Law 112

−95 in reference to 49 U

.S

.C

. § 44704, and in consideration of the size, weight, speed, and limited

### 2

operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates, and any associated noise certification and testing requirements of part 36, is not necessary. The Basis for Our Decision You have requested to use a UAS for aerial data collection1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA

−2014

−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;  The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

 A grant of exemption is in the public interest. Our Decision In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Southern Air Services is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.

### 3

Conditions and Limitations In this grant of exemption, Southern Air Services is hereafter referred to as the operator. Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption. 1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 Vision+ and DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

. 2. Operations for the purpose of closed

-set motion picture and television filming are not permitted. 3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual 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 airman medical certificate or U.S. driver’s license. 6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO 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 VO can perform the duties required of the VO. 7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents,

### 4

the conditions and limitations herein 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 or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents. 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 prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 10. Prior to each flight, the PIC must conduct a pre

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

-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. 11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

### 5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted 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 CFR § 91.119. 15. 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. 16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center ofthe airport symbol as denoted on the current FAA

-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request. 17. The UA may not be operated less than 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. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the private or controlled

-access property. 19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. 21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

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

.

### 6

22. All aircraft operated in accordance 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. 23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 25. The UAS may not be operated by the PIC from any moving device or vehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipating 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. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects 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. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. 27. All operations shall be conducted over private or controlled

-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted. 28. 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 to the FAA's 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 Web site: www.ntsb.gov

.

### 7

If this exemption permits operations for the purpose ofclosed

-set motion picture and television filming and production, the following additional conditions and limitations apply. 29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption. 30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

-day notification may be 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 operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on

-scene operation of the UAS; d. Make, model, and serial or N−Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained 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; and 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. 31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

### 8

This exemption terminates on September 30, 2017, unless sooner superseded or rescinded. Sincerely, /s/ John S. Duncan Director, Flight Standards Service

EnclosuresUNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No.

_____ _

IN THE MATTER OF THE PETITION FOREXEMPTION OF: LAWRENCE BRIDGES SOUTHERN AIR SERVICES 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. 91.15Hb). 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 VISION+ AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on May 22, 2015

Lawrence Bridges. Owner Black Forest GunWurk. LLC DBA: SAS Defense DBA: Southern Air Services 1

01 Demorest Square Demorest GA 30535 706-778-1440 Hereafter referred to as "SAS".TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS

............................................................................................................3 SUl\1Mr\RY

.........................................................................................................................4 INTRODUCTION AND INTERESTS OF PETITIONER.

................................................4 Bi-\CI(C1RC)lJND

................................................................................................................5 BASIS FOR PETITION

...........................................................................................................................S NAME AND ADDRESS OF PETITIONER

..........................................................7 TllE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SAS SEEKS EXEMPTI()N

..........................................................................................................8 THE EXTENT OF RELIEF SAS SEEKS AND THE REASON SAS SEEKS TI-lE RELIEF

...................................................................................11 THE REASONS WHY GRANTING SAS REQUEST WOULD BE IN THE PUBLIC INTEREST

................................................................................. 14 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

................................................................................................................ 17 CC)NCLtJSION

.................................................................................................................32AGL 

### AOI ATC 

### ATO AV 

### CFR COA FAA fAR GCS GPS LOL NAS 

### NOTAM 

### PJC Section 333 

## so SOP UA UAS 

### VFR VLOS 

### VMC VTOL GLOSSARY OF ABBREVIATIONS Above Ground Level Area oflnterest Air Traffic Control Air Traffic Organization Aerial Vehicle Code ofFederal Regulations Certificate ofAuthorization Federal Aviation Administration Federal Aviation Regulation Ground Control Station Global Positioning System Loss ofLink National Airspace System Notice to Airman Pilot In Command FAA Modernization and Reform Act of2012 (FMRA) Safety Observer Standard Operating Procedures Unmanned Aircraft Unmanned Aircraft System Visual Flight Rules Visual Line ofSite Visual Meteorological Conditions Vertical Takeoffand LandingSUMMARY SAS seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.12L 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). to operate an Unmanned Aircraft System pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit SAS to operate an Unmanned Aircraft System (UAS) for the commercial purpose ofconducting PI-IOTOGRAMMETRY, AERIAL PHOTOGRAPHY, MAPPING and SURVEYING

over certain areas ofthe United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER My name is Lawrence Bridges, I am the owner ofSAS. I hold an ATP MultiEngine Land. certificate #2737408, date ofissue 07 MAR 2008, with five (5) PIC Type Ratings. I have served as a Part 121 Air Carrier PIC with over 8000 hours and was a Part 135 Air Taxi ChiefPilot. Since there are no current UAV regulations on the booksjust yet, I am seeking exemptions pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012. The objective is to add services to my existing company in order to offer PHOTOGRAMMETRY, AERIAL PHOTOGRAPHY, MAPPING and SURVEYING

over certain areas ofthe United States for commercial purposes.BACKGROUND Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Inspire 1 UASs SAS seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 2 Vision+ and DJI Inspire 1 are vertical takeoffand landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2 Vision+ has a maximum gross weight ofapproximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of8 inches, and a maximum speed ofapproximately 29 knots. The OJI Inspire 1has a maximum gross weight of6 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 Vision+ and DJI Inspire 1 UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. The DJI Phantom 2 Vision+ and DJI Inspire 1UAs that will be operated by SAS will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as I4 C.F.R Part 47, Aircrqfi Registration, and marked in accordance with 14 C.F.R. Part 45, identification andRegistration Marking.

BASIS FOR PETITION Petitioner, SAS, pursuant to the provisions ofthe Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, S!xcialRulesfin· Certain UnmannedAircraftSystems, hereby petitions the Administrator to commercially operate the DJI Phantom 2 Vision+, DJI Inspire 1UASs in the National Airspace System (NAS), and for an 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). In consideration ofthe speed, weight, size, and limited operating area associatedIn consideration ofthe speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, SAS operation ofDJI Phantom 2 Vision+ and D.lllnspire 1 UASs meets the conditions ofFMRA Section 333 and therefore, will

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, SAS requests relieffrom Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. SAS submits that the requested reliefis proper since fi-n equivalent level ofsafety will be ensured. SAS will use experienced personnel or technicians to perform maintenance, alterations, orpreventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, SAS will document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1UASs. Relieffrom certain requirements ofSection 61.113(a) and (b), entitled

### Private pilotpriPileges 

### and limitations: Pilot in command, is requested by SAS to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. SAS seeks relieffrom Section 91.7(a), entitled 

### Civil aircraft airworthiness, because the D.II Phantom 2 Vision+ and DJI Inspire 1UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, SAS submits that he will ensure that the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs are in

an airworthy condition, prior to every flight, by determining that the UASs are incompliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe t1ight. '- SAS also seeks an exemption from the requirements ofSection 91.121, entitled AltimeterSe!lings, as the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude information ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring ofthe flight path. This altitude information, combined with SAS's operation ofthe DJI Phantom 2 Vision+ and DJI Inspire I UASs within visual line ofsight, at or below 400 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. Additionally, SAS seeks an exemption from the requirements ofSection 91.151 (b), entitled Fuel requirementsforflight in VFR conditions. SAS submits that safety will not be affected by operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration ofapproximately 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14 C.F.R. 

### § 11.81, SAS provides the following information in support ofits petition for exemption:

A. Name and Address ofthe Petitioner. The name and address ofthe Petitioner and point ofcontact is: Lawrence Bridges Southern Air Services I0I Demorest Smmre Demorest GA 30535 706-778-1440 captbridges@aol.comB. The Specific Sections of 14 C.F.R. From Which SAS Seeks Exemption. 1. SAS Seeks Exemption from the Requirements ofSection 61.113(a) and (b). Section 61.113, entitled Private pilot privileges and limitations: 

### Pilot 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) ofan aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation orhire, act as PIC ofan aircraft. (b) A Drivate pilot may, for compensation orhire, act as PIC ofan aircraft in connection with any business or employment if- (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. 2. SAS seeks Exemption from the Requirements ofSection 91.7(a). Section 91.7, entitled 

### Civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. SAS seeks Exemption from the Requirements ofSection 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person oDerating an aircraft shall maintain the cruising altitude or flight level ofthat aircraft, as the case may be, by reference to an altimeter that is set, when operating-- (l) Below 18,000 feet MSL, to-- (i) The current reDorted altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed inparagraph (a) (1) (i) ofthis section, the current reported altimeter setting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation of the departure aimort or an appropriate altimeter setting available before departure.4. SAS seeks Exemption from the Requirements ofSection 91.151(b). Section 91.151, entitled Fuel requirementsforflight in VFR conditions, subsection (b). states the following: (b) No oerson mav bezin aflizht in a rotorcraft under VFR conditions unless (considerinz vvindandforecast weather conditions) there is enouzhfuel to flv to the first ooint ofintendedlandinz and, assuming normal cruising speed, to jly C(/fer thatfor at least 20 minutes. 5. SAS seeks Exemption from the Requirement ofSection 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator ofan aircraft- (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter[.] 6. SAS seeks Exemption from the Requirements ofSection 91.407(a) (1) Section 91.407, entitled Operation after maintenance,preventive maintenance, rebuilding. or alteration, subsection (a) (1), states the following: (a) No person mav operate anv aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-- ( I) It has been approved for return to service by a person authorized under § 43.7 ofthis chapter[.] 7. SAS seeks Exemption from the Requirements ofSections 91.409(a) (1) and 91.409(a) (2). Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) ofthis section. no person mav operate an aircraft unless, within the preceding 12 calendar months, it has had-- (1) An annual insoection in accordance with oart 43 ofthis chaoter and has been aooroved for return to service by a person authorized by§ 43.7 of this chapter; or (2) An insoection for the issuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. 8. SAS seeks Exemption from the Requirements ofSections 91.417(a) and 91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with 

### && 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section: (1) Records ofthe maintenance, preventive maintenance, and alteration andrecords ofthe 1 00-hour. annuaL orogressive, and other required or aporoved insoections, as aporopriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor. (ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofall items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status ofthe aircraft including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safetydirective number and revision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by (3 43.9(d) ofthis chapter for each maior alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) ofthis section shall be retained unti1the work is repeated or superseded by other work or for 1year after the work is performed. (2) The records specified in paragraph (a) (2) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operator under (3 43.11 ofthis chaoter shall be retained until the defects are repaired and the aircraft is approved for return to service. C. The Extent ofReliefSAS Seeks and the Reason SAS Seeks the Relief. I. Extent ofReliefSAS Seeks and the Reason SAS Seeks Relieffrom Section 61.113(a) and (b). Relieffrom Section 61.113(a) and (b) entitled 

### Privatepilotprivileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding

a private pilot or higher level certificate, as well as a current and valid airman medicalcertificate, and who has met certain f1ight-hour and currency requirements, to conduct the proposed UAS t1ight operations for compensation or hire. This reliefis requested since the limitations set forth in Section 61.113(a) and (b)

state that a private pilot may, for compensation or hire, act as PIC ofan aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, SAS submits that an equivalent level ofsafety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ UAS or DJllnspire 1 UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 2 Vision+ or DJI Inspire 1UAS in a manner consistent with the operations specifications

as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, SAS submits that all flights ofthe DJI Phantom 2 Vision+ and DJI Inspire I UASs, conducted by the PIC pursuant to the grant ofthis Petition: (1) will be incidental to SAS's business; and (2) will not carry passengers or property for compensation or hire. 2. Extent ofReliefSAS Seeks and the Reason SAS Seeks Relieffrom Section 9l.7(a).

Relieffrom Section 91.7(a) entitled 

### Civil aircraft airworthiness, is requested to the extent required to allow SAS to determine that the DJI Phantom 2 Vision+ and DJI Inspire I UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the SAS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1Instruction Manual). SAS seeks the requested reliefbecause the DJI Phantom 2 Vision+ and DJIInspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 2I. Subpart H. Therefore, SAS will ensure that the DJI Phantom 2 Vision+ and DJI Inspire I UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire I Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe f1ight, as stated in the conditions and limitations below.

3. Extent ofReliefSAS Seeks and the Reason SAS Seeks Relieffrom Section 91.121.

Relieffrom Section 91.121, entitled Altimeter settings, may be required to allow f1ight operations ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs, 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), SAS seeks the requested reliefbecause the DJI Phantom 2 Vision+ 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 f1ight. Considering the limited altitude ofthe proposed operations, relieffrom 14 CFR 9I. I 2 I is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level ofsafety will be maintained since the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs are equipped with

a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides thePIC with altitude information ofthe UA on the heads-up display ofthe GCS.

4. Extent ofReliefSAS Seeks and the Reason SAS Seeks Relieffrom Section 91.151(b).Relieffrom Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow t1ights ofthe battery powered DJI Phantom 2 Vision+ and DJI Inspire 1UAs during daylight hours in visual meteorological conditions (VMC), under visual f1ight rules (VFR), for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. SAS seeks the requested reliefbecause without an exemption from Section 91.151 (b), the flight time duration ofthe battery powered DJI Phantom 2 Vision+ and DJI Inspire 1UAs will severely constrain the practicality ofany aerial video

or still photo flight operations that SAS proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs, the DJI Phantom 2 Vision+ and DJI Inspire 1 operating documents, and SAS proposed operating limitations, ensure that SAS will safely operate the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under visual f1ight rules (VFR), with enough battery power to f1y for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.



### 5. Extent ofReliefSAS Seeks and the Reason SAS Seeks Relieffrom Sections 91.405(a), 91.407(a) (1), 91.409(a) (1) & 

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

### (b).

Since Sections 9l.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, SAS requests relieffrom these Sections because the DJI Phantom 2 Vision+ and DJI Inspire 1UASs do not require airworthiness certificates. As set fmih more fully below, the DJI Phantom 2 Vision+ and DJI Inspire 1UASs meet the conditions ofFMRA Section 333 for operation without an airworthiness certificate. Accordingly, SAS will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the SASAerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and D.lI Inspire 1 Instruction Manual). Furthermore, SAS will document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1UASs.



### D. The Reasons Whv Grantin2: SAS Reuuest Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing SAS safely, efficiently, and economically perform PHOTOGRAMMETRY, AERIAL Pl-IOTOCiRAPHY, MAPPING and SURVEYING over certain areas ofthe United States. Additionally, use ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs will decrease congestion ofthe NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits ofSAS's proposed operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs will be realized without implicating any privacy issues. 1. The Public Will Benefit From Decreased Congestion OfThe NAS. The DJI Phantom 2 Vision+ and DJI Inspire 1UAs are battery powered and serve

as a safe, ef1icient, and economical alternative to the mmmed aircraft traditionally utilized

Lo obtain aerial imagery. By reducing the amount ofmmmed aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa DJI Phantom 2 Vision+ or DJI Inspire I UAS would reduce the amount ofmmmed aircraft in the NAS, reduce noise and air pollution, as well as increase the safety oflife and property in the air and on the ground.Furthermore, by reducing the number ofmanned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The OJI Phantom 2 Vision+ and DJI Inspire 1 UAs do not require an airport to takeoffor land. Likewise, a reduction ofmanned 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 offlight operations.2. The Public Will Benefit From The Safetv And Efficiency OfThe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, instead ofmanned aircraft, will greatly benefitthe public by drastically reducing the levels ofair and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour ofleaded aviation fuel. The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom 2 Vision+ and DJI Inspire 1UASs to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack offlight crew members located onboard the aircraft, the DJI Phantom 2 Vision+ and DJI Inspire 1UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, 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, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet, a length of34 feet, and a fuel capacity of 180 gallons).3. Performin!! Aerial Video and Photo!!raohv Ooerations With The DJI Phantom 2 Vision+ and DJI Inspire 1UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision+ and DJI Inspire I UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will allow United States based companies, like SAS, to remain competitive and contribute to growth ofthe U.S. economy. Specifically, with the rising cost ofaviation 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 powered DJI Phantom 2 Vision+ and DJI Inspire 1 UASs is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost ofa traditional mmmed aircraft. By operating the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, companies such

as SAS, can remain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improved financial performm1ce ofU.S. companies, through commercial

use ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allovv·s companies to invest in research and development in order to remain competitive both in the United States and abroad. 4. The1·e Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, SAS's proposed operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+ andDJI Inspire 1 UASs will be operated only in compliance with operating documents (i.e., the SAS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1Instruction 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.

E. The Reasons Whv Grantine: The Exemotion Would Not Adverselv Affect Safety, Or How The Exemotion Would Provide A Level OfSafetv At Least Equal To That P1·ovided By The Rule From Which SAS Seeks Exemption. 1. Reasons Whv The DJI Phantom 2 Vision+ and DJI Insoire 1 UAs Meet The Conditions OfThe FAA Modernization and Reform Act of2012 (FMRA) Section 333.

In consideration ofthe size, weight, speed, and limited operating area associated \Vith the unmanned aircraft and its operation, SAS's operation ofthe DJI Phantom 2 Vision+ and OJI Inspire 1UASs meet the conditions ofFMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (o) in General. --Notwithstandinf! anv other reauirement of this subtitle. andnot later than 180 davs after the date of enactment of thisAct. the Secretarv of Tranmortation shall determine if certain unmannedaircraft svstems mav ooerate safelv in the national airsvace svstem before comvletion of the olan and rulemakinz reauired by section 332 of thisActor the guidance required by section 334 of thisAct. (b) Assessment ofUnmannedAircraftSvstems.--In makinf! the determination under subsection (a), the Secretary shalldetermine, at a minimum-- (!) which tvves of unmannedaircraftsvstems. if anv. as a result of their size. weidtt. sveed. overational cavabilitv. vroximitv to aimorts and vovulatedareas. andoveration within visual line of sif!ht do not create ·a hazardto users of the national airspace system. or thepublic orpose a threat to national security; and (2) ·whether a certificate of waiver, certificate of authorization, orairworthiness certification under section 44704 of title 49. United States Code. is reouiredfor the overation of unmannedaircrqft systems identified underparagraph (1). (c) Reouirementsfor Safe Overation.--Jfthe Secretarv determines under this section that certain unmannedaircraft svstems mav overate safelv in the national airsvace svstem. the Secretarv shall establish reouirementsfor the safe operation of such aircraft systems in the national airspace system.



### In seeking this exemption, SAS submits that the DJI Phantom 2 Vision+ and DJI Inspire IUASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations. a. The Snecifications OfThe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision+ and DJI Inspire 1UASs do not create a hazard to

users ofthe NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. i. Technical Snecifications OfThe DJI Phantom 2 Vision+ and DJI

Inspire 1 UASs.

The technical specifications ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs are set forth by the DJI Phantom 2 Vision+ and DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and B. ii. The DJI Phantom 2 Vision+ and DJI Insnire 1 UASs Autonomous Fli2:ht And Navi2:ation Modes Enable The UASs To Remain Within A Defined OperationalArea.

The DJI Phantom 2 Vision+ and DJI Inspire 1UASs may be operated in both manual and fully autonomous flight modes. A complete description ofthe flight and navigational modes ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs is provided at pages 25-35 ofthe DJI Phantom 2 Vision+ and pages 12-16 and 45-50 ofthe DJI Inspire I User Manuals, attached hereto as Exhibit C and D. iii. The DJI Phantom 2 Vision+ and DJI Insnire 1 UASs Are Desi2:ned For Automatic Return To Home Point OrHover In The Event Of Loss OfThe Control Link OrNavigation.When the Control Link is lost, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+ and DJI Inspire 1UAs do not reacquire control link data from the GCS, 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 takeoffposition and shutdown. A complete description ofthe Failsafe Functions ofthe DJI Phantom 2 Vision+ UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 ofthe DJI Phantom 2 Vision+ and DJI Inspire 1User Manuals, attached hereto as Exhibit C and D. iv. The DJI Phantom 2 Vision+ and DJI Inspire 1 GCS and Its Operation.

A complete description ofthe operation and specifications ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 GCS and flight control software is provided at pages 32 through 43 ofthe DJI Phantom 2 Vision+ User Manual and pages 40 through 47 ofthe DJI Inspire 1User Manual. DJI Phantom 2 Vision+ and DJI Inspire 1 User Manuals are attached hereto as Exhibits C and D. b.**Fli~ht** Ooerations OfDJI Phantom 2 Vision+ and DJI Insoire 1UASs Are Limited To The Line OfSight OfA Certificated Pilot in Command With A Safety Observer. SAS will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight time.

c.**Fli~hts** ofDJI Phantom 2 Vision+ and DJI Insoire 1UASs Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, SAS proposes to commercially operate DJI Phantom 2 Vision+ and DJI Inspire 1 UASs for the special purpose ofconducting aerial video and photography over certain areas ofUnited States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant ofexemption will be limited to thefollowing aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 2 Vision+ and 

### DJI Insnire 1 Unmanned Aircraft Systems. Proposed operations ofany other aircraft will require a new petition or a petition to amend this grant. 2. t!AS onerations undet: this_ exemntion will be limited to conducting operations for the purpose ofaenal vrdeo and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be ODerated at an altitude ofno more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special rec.lUest is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be ODerated within visual line ofsight (VLOS) ofthe PIC at all times. This rec.lUires 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 airman medical certificate. 6. The use offirst person view (FPV) by the PIC or safety observer (SO) is not permitted. 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 caoability. 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 ofthe flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.**~-** The SO must not nerform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The ooerating documents and the grant ofexemption must be accessible during UAS onerations and made available to the Administrator upon request. Ifa discreDancy exists between the conditions and limitations contained in the grant ofexemntion and the txocedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its ODerating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track suchrevisions and present updated and revised documents to the Administrator upon request. The onerator must also present updated and revised documents ifit petitions for extension or amendment to the grant ofexen11Jtion. Ifthe operator determines that any undate or revision would affect the basis upon which the FAA granted the exemDtion. then the oDerator must netition for amendment to its grant ofexemntion. The FAA's UAS Integration Office (AFS-80) maY be contacted ifquestions 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 for safe f1ight. Ifthe inspection reveals a condition that affects thesafe cmeration ofthe UAS, the aircraft is orohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the oreflight insnection. 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 ooeration or flight characteristics, e.g. replacement ofa flight critical comnonent must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The m·e-flight inspection must account for all potential discrepancies, e.g. inonerable components, items, or equipment not already covered in the relevant sections ofthe operating documents. 13. The onerator must follow the UAS manufacturer's aircraft/component maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The onerator must carry out its maintenance, inspections, and record keeping recmirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status ofreplacement/overhaul componentparts must be noted in the aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a private pilot certificate and at least a current third- class medical certificate. 18. The onerator may not nennit any PIC to operate unless the PIC meets the ooerator'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 evasive and emergency maneuvers and maintaining aonrooriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R.**~** 61.51(b). Flights for the purposes oftraining the operator's PICs are oermitted under the terms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. During training, oroficiency, and experience-building flights, all persons not essential for fliQ;ht ooerations 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 cmerations may not be conducted during night as defined in 14 C.F.R.**~** 1.1. All operations must be conducted under visual meteorological conditions (VMC). Ifflight at night is required, a special request will be made at the FAA office closest to proposed area ofoperations. Flights under special visual flight rules (SVFR) are not authorized.20. The UA may not ooerate within 5 nautical miles ofan airoort reference ooint as denoted on a current FAA-oublished aeronautical chart unless a letter of agreement with that airoort's management is obtained, and the ooeration is conducted in accordance with a NOT AM as required by the ooerator's COA. The letter ofagreement with the airport management mustbe made available to the Administrator upon request. 21. The UA may not be ooerated less than 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. 22. Ifthe UA loses communications or loses its GPS signaL it must return to a nre- determined location within the olanned ooerating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event ofunoredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is orohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough oowerto fly at normal cruising**soeec~** 

## t? the intended landing point and land the UA with 25% battery power remammg. 25. The cmerator must obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) orior to conducting any onerations under the grant ofexemotion. This COA will also require the onerator to request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours orior to the ooeration. All ooerations shall be conducted in accordance with airsoace requirements in the ATO issued COA including class ofairspace, altitude level and potential transponder requirements. 26. All aircraft onerated in accordance with the exemotion must be identified by serial number, registered in accordance with 14 C.F.R. oart 47, and have identification (N- Number) markings in accordance with 14 C.F.R. part45, Subpart C. Markings must be as large as practicable. 27. Before conducting ooerations, the radio frequency soectrum used for oneration and control ofthe UA must comolY 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 ofthe UAS any time the UAS is ooerating. These documents must be made available to the Administrator or any law enforcement official upon request. 29. The UA must remain clear and yield the right ofway 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 onerations must be conducted at least 500 feet from all nonoarticipating persons (persons other than the PIC, SO, operator trainees or essentialpersons), vessels, vehicles, and structures unless:

a. Barriers or structures are oresent that sufficiently protect nonnarticinating nersons fi-om the UA and/or debris in the event ofan 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 ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller ofsuch vessels, vehicles or structures has granted nermission and the PIC has made a safety assessment ofthe risk of onerating closer to those objects and determined that it does not present an undue hazard, and;

c. Onerations nearer to the PIC SO, operator trainees or essential persons do not present an undue hazard to those persons per§ 91.119(a). 32. All onerations shall be conducted over private or controlled-access property with Dermission from the land owner/controller or authorized reDresentative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Anv incident accident or flight operation that transgresses the lateral or vertical boundaries ofthe ODerational area as defined by the applicable COA must be reDorted to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be renorted to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: WWlN.ntsb.rrov. 2. Reasons Whv an Exemotion from the Reouirements ofSection 61.113(a) and (b) Would Not Adversely Affect Safety. SAS submits that the equivalent level ofsafety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum l1ight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering SAS's proposed area ofoperations, and the operating limitations set forth-above; the parallel nature ofprivate pilot aeronautical knowledge requirements to those ofcommercial pilot requirements (See Exemption No. 11062); and the airmanship skilis necessary to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS, SASsubmits that the additional manned airmanship experience ofa commercially certificated pilot would not correlate to the airmanship skills necessary for SAS's specific proposed f1ight operations. The FAA has previously granted relieffrom 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). SAS will not allow any PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire I UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements

or the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ 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. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F. R. § 61.51 (b), 25 hours oftotal time as a UAS rotorcraft pilot (with a minimum of5 hours ofthose hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings inthe preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level ofsafety during SAS's proposed operations. The Administratorhas held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemotion No. 11062, the FAA required that orior to conducting ooerations for the ouroose ofmotion oicture filming (or similar ooerations), the PIC musthave accumulated and logged, in a manner consistent with 14 CFR 61.5l(b), 25 hours oftotal time as a UAS rotorcraft oilot including at least 10 hours logged as a UAS oilot with a multi-rotor UAS. Prior to ooerations under ExemotionNo. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UAS pilotonerating the same make and model ofUAS to be used for operations under the exemntion. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive: i.e. 5 hours make and model time mav be included in the 10 hours ofmulti-rotor time and the 10 hours may be included in the total25 hours ofUAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 davs (for currency purnoses). The FAA finds that at a minimum, the flighthour reouirements in Exemntion No. 11062 are appropriate to practice and build nroficiencv in the skills necessary to safely conduct the petitioner's proposed onerations. The FAA also finds that prior documented f1ight experience that was obtained in comnliance with applicable regulations would satisfy this requirement. Training, nroficiency, and experience-building f1ights can also be conducted under the grant ofexemption to accomplish the required f1ight time. During training, nroficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, SAS will ensure safe operations by not allowing any PIC to operate the 0.11 Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum f1ight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

### 3. Reasons Whv an Exenmtion from the Requirements ofSection 91.7(a) Would Not Adversely Affect Safety. The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every f1ight, SAS will ensure that the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS's compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relieffrom Section 91.7(a) specific

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, I 1 1 1 2, 1I 1 36, 1 1138, 11150, 1 1153, 11156, 11157, 11158, 11159, 11160, 11161). 

### 4. Reasons Whv an Exemotion from the Requirements ofSection 91.121 Would Not Adversely Affect Safety.

The equivalent level ofsafety established by Section 91.121 will be maintainedbecause the altitude information ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring ofthe flight path and altitude. This altitude information, combined with SAS's operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UAs within visual line ofsight, at or below 400 feet AGL, will ensure a level ofsafety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a

zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relieffrom Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,11063,11064,11065,11066,11067,11080,11109,11112,11136,11138, 11150,11153,11156,11157,11158,11159,11160, 11161).

5. Reasons Whv an Exemotion from the Requirements ofSection 91.15l(b) Would Not Adversely Affect Safety. A grant ofthis exemption would ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b) as a result of(1) the technical specifications ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs; (2) the limitations onthe proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, SAS will

ensure that it will safely operate the battery powered DJI Phantom 2 Vision+ and DJI Inspire IUAs during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications ofthe DJI Phantom 2 Vision+ and DJllnspire 1 UASs; the limitations on the proposed flight operations; and the location ofthe proposed operations, will ensure an equivalent level ofsafety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs provide audible and visual warnings tothe PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom Vision+ and DJI Inspire 1 UASs \vill descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Reliefhas been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted reiieffrom Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 8811, 10808, 10673, 11042, 11062,11063,11064,11065,11066,11067,11080,11109,11110,11136,11138,11150, 11153, 11156,11157,11158,11159,11160, 11161).

6. Reasons Whv An Exemotion From The Reauirements OfSections 9l.405(a). 91.407(a) (1). 91.409(a) (1) & (a) (2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, SAS submits that the equivalent level ofsafety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)( 1 ), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because SAS will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the SAS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, SAS will document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. Since the DJI Phantom 2 Vision+ and DJI Inspire 1UASs will be inspected as prescribed by the operating documents, SAS will maintain the equivalent level ofsafetyestablished by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy ofthe DJI Phantom 2 Vision+ and DJI Inspire 1User Manuals are attached hereto as Exhibit C and D; a copy ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UAS Maintenance LOG will be an android based digital app that will be downloaded on a monthly basis to a hard paper copy. Likewise, the exemption sought will not adversely affect safety because SAS will

use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would maintain an equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe D.JI Phantom 2 Vision+ and DJI Inspire 1UASs will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. In consideration ofSAS's proposed operating limitations, the operating documents, and the technical aspects ofthe DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. SAS submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted reliefspecific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11062, 11063, 11064,11065,11066,11067.11080,11109,11110,11112,11136,11138,11150,11153, 11156,11157,11158,11159,11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.In accordance with Section 333 ofthe 

### P AA Modernization and Reform Act of 2012 (FMRA) and 14 C.P.R. § 21.16 entitled Special Conditions, SAS requests that the FAA prescribe special conditions for the intended operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.P.R §§ 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). Such special conditions will permit safe operation ofthe UAs for the limited purpose of conducting aerial video and photography over certain areas ofthe United States for compensation or hire. PMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that mustbe established for the safe operation ofthe UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs, since the airworthiness regulations of 14 C.P.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features ofthe aircraft. Section 21.16, entitled Special Conditions, states the following: Ifthe FAA finds that the airworthiness regulations ofthis subchapter do not contain adecmate or annronriate safety standards for an aircraft aircraft engine, or orcmeller because ofa novel or unusual design feature ofthe aircraft aircraft engine or oroneller. he orescribes soecial conditions and amendments thereto for the nroduct. The snecial conditions are issued in accordance with Part 11 ofthis chanter and contain such safety standards for the aircraft aircraft engine or nroneller as the P AA finds necessary to establish a level ofsafety equivalent to that established in the regulations.

See 14 C.P.R.§ 21.16.Theref()re, in accordance with FMRA Section333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for SAS's intended operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs, which contain such safety standards that the Administrator finds necessary to establish a level ofsafety equivalent to that established by 14 C.F.R. Part 21, Subpmi H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). • A Summarv That Can Be Published In The Federal Register, stating: The Rules From Which SAS Seeks Exemption: S'AS seeks exemotion kom the reauirements o(]4 C.F.R Sections 61.1JJ(a)&(b), 9!. 7(a). 9!. J 21. 91.15J (b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 9J .4!7(a) & (b). A BriefDescription ofthe Nature ofthe Exemption SAS Seeks: This exemvtion**~will** vermitSAS to commerciallv overate an UnmannedAircraft Svstem (UAS) 

### for the vurvose of conducting aerial video and photography over certain areas o/the UnitedStates.

• Anv Additional Information, Views, or Arguments Available to Support 

### SAS's Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine if certain UAS may operate safely in the NAS. As such, SAS's request for exemption may be granted pursuant to the authority ofFMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS \viii create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, SAS will operate the DJI Phantom 2 Vision+ and DJl Inspire 1 UASs safely in the NAS, without creating a hazard to users ofthe NAS, or the public, or otherwise pose a threat to national securityCONCLUSION As set forth herein, SAS seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation ofthe DJI Phantom 2 Vision+ and DJI Inspire 1UASs commercially, without an airworthiness certificate, for the limited purpose ofconducting aerial video and photography over certain areas ofthe United States. By granting this Petition, the FAA Administrator will be fultllling the Congressional mandate ofthe FAA Modernization and Reform Act of2012, while also advancing the interests ofthe public, by allowing SAS to safely, efficiently, and economically operate the DJI Phantom 2 Vision+ and DJI Inspire 1UASs commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, Section 333, SAS respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(J) & (a)(2), and 91.417(a) & (b), and permit SAS to operate the DJI Phantom 2 Vision+ and DJI Inspire 1UASs commercially for the purpose ofconducting aerial video and photography over certain areas ofthe United States. Dated: May 22,2015 Respectfully submitted, Lawrence Bridges

# Lawr~ri~ Lawrence Bridges Black Forest GunWurks, LLC DBA: SAS Defense DBA: Southern Air Services 101 Demorest Square Demorest GA 30535 706-778-1440Appendices: A- OJ! Phantom 2 Vision+ Soecifications Data Sheet B

- OJ l Insoire 1 Soecifications Data Sheet C --OJ! Phantom 2 Vision+ User Manual 0

- OJ 1Inspire 1 User Manual

APPENDIX-A DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS SAS onlv utilizes safe and reliable UASs. DJI is an industry leader in small UAS oroduction. OJI UASs are loaded with ground breaking software enabling the user to set oarameters which will not allow flight into controlled airsoace. Parameters can also be set to limit flight to no higher than a oredetermined and set altitude as well as limit flight to a oredetermined and set distance. In addition, DJI software movides real-time altitude and location information to the PIC via the linked monitor (smartphone/tablet devices) 1.1 

### DJI Phantom 2 Vision+ I . I . I Aircraft I.1.1. I Suooorted Battery- DJI 5200mAH LiPo Battery 1. I. 1.2 Weight (Battery & Prooellers Included)- 2lbs 11.810oz (1242g) 1.1.1.3 Hover Accuracy (Readv to Flv)- Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity- 2000/s I.1.1.5 Max Tilt Angel- 35 0 I.1.1.6 Max Ascent Soeed- 6m/s I. I. I.7 Max Descent Sneed- 2m/s I. I.1.8 Max Flight Speed- 15m/s (NOT RECOMMENDED) 1.1.2 Gimbal 1.1.2.1 Working Current- Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy- ±0.030 1.1.2.3 Controllable Range- Pitch: -900

- 00 1.1.2.4 Maximum Angular Speed- Pitch: 900/s 1.1.3 Camera I. 1.3.1 Ooerating Temoerature Range- 320F- 1040F (OOC- 400C) I.1.3.2 Sensor Size- 1/2.3" I. I.3.3 Effective Pixels- 14M I. I.3.4 Resolution- 4384x3288 4. 1.3.5 HD Video Recording- 1080o30 & 720p 4. I.3 .6 Recording Field ofView- 1100/850 I. I.4 Transmitter 1.1.4.1 Ooerating Frequency- 5.728GHz- 5.85GHz I. I.4.2 Communication Distance (unobstructed)- FCC Compliance: 800m 1.1.4.3 Receiver Sensitivity (1 %PER)

- -93dBm1.1.4.4 Transmitter Power- FCC Compliance: 1OOmW 1.1.4.5 Working Voltage- 120mA@3.7V 1.1 .5 Range Extender 1.1.5.1 Onerating Frequency- 2412-2462MHz 1.1.5.2 Communication Distance (unobstructed)- 500-700m 1.1.5.3 Transmitter Power- 20dBm 1.1.5.4 Power Consumption- 2W

APPENDIX-B DJI INSPIRE 1 TECHNICAL SPECIFICATIONS SAS onlv utilizes safe and reliable UASs. DJI is an industry leader in small UAS nroduction. DJI UASs are loaded with ground breaking software enabling the user to set narameters which will not allow flight into controlled airspace. Parameters can also be set to limit llir.d1t to no higher than a nredetermined and set altitude as well as limit flight to a ])redetermined and set distance. In addition, DJI software nrovides real-time altitude and location information to the PIC via the linked monitor (smartphone/tablet devices) 2.2 DJI Inspire 1 2.2.1 Aircraft 2.2.1.1 Model- T600 2.2.1.2 Weight (Batterv Included)- 61bs 7.5291oz (2935g) 2.2.1.3 Hovering Accuracv (GPS Mode)- Vertical: 0.5m: Horizontal: 2.5m 2.2.1.4 Max Angular Velocity- Pitch: 300°/s; Yaw: 150°/s 2.2.1.5 Max Tilt Angle- 35° 2.2.1.6 Max Ascent Speed- 5m/s 2.2.1.7 Max Descent Speed -4m/s 2.2.1.8 Max Speed- 22m/s (ATTl mode, no wind- NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude- 4500m 2.2.1.10 Max Wind Resistance- 10m/s 2.2.1.11 Max Flight Time- Approximately 18 minutes 2.2.1.12 Motor Model- DJI 3510 2.2.1.13 Propeller Model- DJI1345 2.2.1.14 Operating Temperature Range -14°F to 104°F (-10°C to 40°C) 2.2.1.15 Dimensions -17 

### W' x 17 %" x 12" 2.2.2 Gimbal 2.2.2.1 Model- ZEN MUSE X3 2.2.2.2 Output Power (with camera)- Static: 9W: In Motion: 11W 2.2.2.3 Operating Current- Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration Range- ±0.03° 2.2.2.5 Mounting- Detachable 2.2.2.6 Controllable Range- Pitch: -90° to +30°: Pan: ±320° 2.2.2.7 Mechanical Range- Pitch: -125°to 45°: Pan: ±330° 2.2.2.8 Max Controllable Speed- Pitch: 120°/s; Pan: 180°/s 2.2.3 Camera 2.2.3.1 Name- X3 2.2.3.2 Model- FC350 2.2.3.3 Total Pixels -12.76M2.2.3 Camera 2.2.3.1 Name -X3 2.2.3.2 Model- FC350 2.2.3.3 Total Pixels -12.76M 2.2.3.4 Effective Pixels -12.4M 2.2.3.5 Image Max Size- 4000x3000 2.2.3.6 ISO Range -100-3200 2.2.3.7 Field ofView- 94° 2.2.3.8 CMOS- Sony EXMOR 1/2.3" 2.2.3.9 HD Video Recording- UHD (4K): 4096x2160p24/25. 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range- 32°F -104°F (0°C- 40°C) 2.2.4 Transmitter 2.2.4.1 Name- C1 2.2.4.2 Operating Frequency- 5.728-5.850GHz; 2.400-2.483GHz 2.2.4.3 Communicating Distance (unobstructed)- 2000m 2.2.4.4 Output Power- 9W 2.2.4.5 Operating Temperature Range- 14°F to 104°F (-10°C to 40°C) 2.2.4.6 Battery- 600mAh LiPo 2S