Alberto Haber
President
ACERES AER I AL RECORD
P.O. Box. 29267 San Juan, Puerto Rico 00929

- 0267

October 19 , 2015

U.S. Department of Transportation Docket Management System 1200New Jersey Ave., SE Washington DC 20590

Re: : Request for exemption from multiple regulatory provisions to allow the use of small unmanned aerial systems on land controlled by Aceres Aerial Record (AAR) to assist in the safe evaluation of infrastructure and operations for our clients.

To whom it m ay concern:

Aceres Aerial Record (AAR) respectfully request an exemption from several provision of Title 14 of the Code of Federal Regulations (CFR) to permit the use of small unmanned aerial system (sUAS) to assist in the evaluation of infrastructure and operations for our
clients. This request is motivated primarily by the desire to maximize safety in infrastructure and operations. While an exemption would not eliminate the current need
for in

- person visual inspection required by various federal regulato ry departments, it would allow AAR to broadly evaluate assets and operations with sUAS, resulting in a
safer and more efficient infrastructure network.

The requested exemption would permit AAR to pursue his commercial interests in providing services to clients using a small advanced sUAV in the following areas:

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land surveys, engineering and other related professional needs.

2. Aerial inspection/photography of residential/commercial structures under contract with the owners or local government authority.

3. Aerial video/photography or providing live video feed and thermal capabilities to assist
with ins pections, search and rescue operations as requested by local authorities.4. Closed

- set filming for the motion picture and television industry.

As described fully below, the requested exemption would permit the operation of small
UAS under controlled conditi ons in the NAS that would be limited , controlled, predetermined and will provide safety enhancements to the already safe operations in the industry presently using conventional aircraft

Personal Information:

Name: Alberto Haber Phone: ( 787 ) 754

- 6748 Fax: (787) 200

- 5695
Email: aceres uavrecord@prmail.net
Postal Address: P.O. Box 29267 San Juan P.R. 00929

- 0267 Physical Address: Road P.R.887, Km. 3.1, Bo. San Anton, Carolina, PR 00984

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H 14 CFR 45.23 (b) 14 CFR 61.113(a) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a) (2) 14 CFR 91.417 (a) & (b)

## EXEMPTION SOUGHT BY AAR AND REASONS FOR THE REQUESTED RELIEF

SECTIONS

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular small UAS. In all cases, an analysis of these criteria demonstrates that the small UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) opera ting with an airworthiness certificate without the restrictions and conditions proposed.

The small UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fu els, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public sa fety requirements. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the small UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantia l external load.14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experiment al or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable.

Even though the small UAS will have no airworthiness certificate, an exemption may be needed as the small UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the small UAS, two

- inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the small UAS marked on its fuselage as required by §45.29 (f) where the pilo t, observer and others working with the small UAS will see the identification of the small UAS as “Experimental.”

14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a), no person who holds a priv ate pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire. Our small UAS do not carry any pilots or passengers nor property therefore I am seeking an exemption to 14 CFR 61.113(a). A lthough helpful, a pilot’s license will not ensure remote control piloting skills. The risks attendant to the operation of small UAS is
far less than the risk levels inherent in the commercial activities outlined in 14 CFR 61. I feel the operation and limi tations set forth in the FOM will equate to the safe operation of
the small UAS.

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy
condition. As there will be n o airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety checklists prior to each flight an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The small UAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no p ilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalentlevel of safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the small UAS will have immedia te access to it.

14 C.F.R. § 91.103: Preflight Action

.
This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft a n exemption will be needed. The OPERATOR will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight Instruction

.

Secti on 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. Small UAS and remotely piloted aircraft, by their design do no t have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the aircraft.

Section 14 C.F .R. §91.119: Minimum Safe Altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complie s with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a small UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the small UAS will never operate at higher than 400 AGL with the exception that in circumstances where the small UAS is used to survey or photograph a struc ture whose height exceeds 400 feet AGL, the small UAS will not be operated more than 100' above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the small UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presentedwith conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude

op erations of the small UAS will ensure separation between these small

- UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings.

This regulation requires each person operating a n aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the small UAS may not have a barometric altimeter, but inste ad a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of the launch site shown
on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather condition s) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering th e small UAS provides approximately 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, small UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the small UAS’s proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting small UAS flights to 10 minutes would greatly

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulat ion provides in pertinent part :( a ) except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. . . .(b) No person may operate a civil aircraft un less the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.The small UAS fully loaded weigh s no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the small UAS.

An equivalent level of safety will be achieved by keeping these d ocuments at the ground control point where the pilot flying the small UAS will have immediate access to them; to the extent they are applicable to the small UAS.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

.

Thes e regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the ap plicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the small UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the small UAS is in working order prior to initiating flig ht, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety

.
An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the small UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual (AOM). As provided in the FOM, the operator will ensure that the small UAS is in working order prior to initiating flight and perform required maintenance needed.

# Granting an Exemption will not adversely affect Safety

AAR contemplates conducting sUAS operations over client owned or controlled land, solely during daylight hours, at altitudes well below that which would pose a risk to other aircraft. In general, sUAS operations are intended to be conducted in areas distant from both congested areas and airports. Moreover, because of the inherent risks presented by standard infrastructure operations, our clients have already taken steps to secure property against unauthorized public access. For example, substantial st retches of pipeline,
utilities and oil production sites are fenced, elevated, or otherwise secured to prevent access. Other long stretches of infrastructure are, as noted above, in very remote wilderness areas. The nature of operations anticipated by AAR requires that the sUAS be flown at rela tively low altitudes and relatively low speeds. AAR expects that in most instances, the sUAS will be flown less than 75 feet from the highest structure along the path of the sUAS. Accordingly, the risk of interference with another aircraft is minimal.
AAR also plans to conduct sUAS operations at least three miles from any public airports (including heliports). Approval of exemptions allowing commercial operations of sUASs in the infrastructure aerial inspection industry will enhance safety by reducing ris k. Conventional operations, using jet or piston power aircraft, operate at extremely low altitudes just feet from the subject being inspected and in extreme proximity to people and structures; and present
the risks associated with heavy vehicles, carrying large amounts of jet A or other fuel

. Such aircraft must fly to and from the inspection site. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the
reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the inspection site. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

The operation of small UASs, conducted in the strict con ditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including 333 Aircraft Exemption Status exempting the applicant from conventional aircraft requirements and allowing commercial oper ations. These lightweight aircraft operate at slow speeds, close to the ground, and in a controlled environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and p eople.The safety of those on the ground is protected by the fact that no one will be allowed into the area without the permission of the company. Security will be established for the flight area as part of the pre

- flight control. Each individual within the secure area will be briefed prior to flight and will consent to being in the area. All others will be excluded
from the area.



# OPERATOR RESPONSIBILITIES

1. Operations authorized by this grant of exemption are limited to the sUAS when weighing less th an 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 ma y 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 operat ions 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

mu st 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 4 limitations in this exemption and the proced ures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, theoperator 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 petition s 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. Th e 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 peo ple. 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 follo w 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 g rant 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 distanc es 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 experi ence

- 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 dur ing 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 i n 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 au thorized. 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 of the airport symbol as denoted on the cur rent 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 comm unications 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 b eginning 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 manufa cturer 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 op erations 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) mark ings 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 avia tion 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 aris es 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 structu res 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 pro perty 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.

# SMALL UAS D ESCRIPTION

TAROT 960 ENDEVOURE TAROT 680P DJI PHANTON 2

RTF WEIGHT (POUND) 16 18 8 2.74 TIME FLIGHT (MIN) 15 15 20 25
MOTOR QTY 6 8 6 4

FRAME CARBON FIBER CARBON FIBER CARBON FIBER COMPOSITE MAT. PROPELLER DIAMETER (INCH) 16 28 12 9

CONTROLLER A2DJI A2DJI NAZAMV2 NAZAMV2

ESC CASTLE - 35A FOXTECH - 60A CASTLE - 35A DJIPHV BATTERY CAPACITY (mAh) 22,000 `44000 8,000 5,200 FREQUENCY FLIGHT (GHz) 2.4 2.4 2.4 2.4

CAMARA ZONY NEXT 7 RED SCARLAT GO PRO 384 DJI

VIDEO FORMAT NTSC NTSC NTSC NTSC
FREQUENCY VIDEO (GHz) 5.8 5.8 5.8 5.8 LONG RANGE TRANSMITTER A/V TX (mW) 600 600 600 25 - 125

TELEMETRY IOSD MARK II DJI MARK II DJI MINI DJI MINI MAX SPEED (ft/s) 55 65 52 45 FLIGHT HEIGHT (FEET) 300 300 300 300 TRANSMITTING DISTANCE (METERS) 500 500 500 500

FALL SAFETY RETURN TO HOME RETURN TO HOME RETURN TO HOME RETURN TO HOME SYSTEM VOLTAGE (VOLTS) 22.2 22.2 22.2 11.1 

# ACERES AERIAL RECORD

EQUIPMENT SPECIFICATION