1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF :

SKYWARD, LTD. FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(a)(1)(b) , 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPER ATION OF THE DJI SPREADING WINGS S1000+, DJI INSPIRE 1, 3DR X8
- M,

AND 3DR IRIS+ UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112
- 95)

Submitted on June 16 , 2015
Dan iel C. Cyphers Statutory Agent 5717 Huberville Ave, Suite 300 Dayton, OH 45431

- 1217 Tel: (937) 252

- 2710, ext. 1022 TABLE OF CONTENTS Page GLOSSARY OF ABBREVIATIONS...................................................................................3
SUMMARY...................................................................................................................... .....4
INTRODUCTION AND INTERESTS OF PETITIONER....................................................4
BACKGROUND................

........................................................................ ............................6 BASIS FOR PETITION.......................................................................... ...............................7 NAME AND ADDRESS OF PETITIONER.............................. ...............................10
THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SKYWARD LTD SEEKS EXEMPTION.................................................................

............................................ 10
THE EXTENT OF RELIEF SKYWARD LTD SEEKS AND THE REASON SKYWARD LTD SEEKS THE RELIEF.........................

...................................... 14
THE REASONS WHY GRANTING SKYWARD LTD’s REQUEST WOULD BE IN THE PU BLIC INTEREST ......................................................... .............................18
THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY..........................................................................

.......... .................21
SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...... .36 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT SKYWARD LTD’ s REQUEST.........

.................... ................................37
CONCLUSION........

............................................................................................................ .37 APPENDICES........................................................................................ .403 GLOSSARY OF ABBREVIATIONS
AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Posi tioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 SUMMARY Skyward, Ltd. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(a)(1)(b) , 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate Unmanned Aerial System s (UASs) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exempti on will permit Skyward, Ltd. To operate UAS s to conduct commercial collection of aerial data for the purposes of photography and videography, hazardous materials incident mitigation , fire management , and search and

rescu e/recovery activities within the geographic boundaries of the United States . This exemption will also permit Skyward, Ltd. to conduct commercial collection of aerial data for the purposes of planning and training activities related to photography and videography , hazardous materials incident mitigation , fire management , and search and rescue/recovery activities

. Skyward was previously exempted under exemption No. 13085, Regulatory Docket No. FAA

- 2015

- 2310 for the same UAS platforms.

INTRODUCTION AND INTERESTS OF THE PETITIONER
Skyward, Lt d. (hereinafter referred to as “Skyward”) is focused on providing customers with timely, accurate, and comprehensive data collected from a variety of sensors that are mounted on small UASs . Skyward provides customers with expertise in engineering analysis; test & evaluation planning, data collection, and reporting; data synthesis and analysis; modeling & simulation; weapon system analysis; and technology research and development. Skyward’s technical staff is composed almost entirely of engineers with BS de grees at accredited universities and 50 % of the staff has MS degrees. Skyward’s staff averages over 25 years of experience with subject matter experts (SMEs) averaging over 35 years of experience in specialized areas.5

Skyward core expertise is survivability/vulnerability; ballistic test & evaluation, including Live Fire Test & Evaluation; vulnerability and scientific modeling & simulation, including vulnerability analysis, fire analysis, and design of experiments analysis; weapon system vulnera

bility reduction focusing on fire protection development, including Skyward’s patented Enhanced Powder Panel; maintenance, specializing in battle damage assessment and repair; combat data analysis; reverse engineering and 3D design, including the utilizati on of in

house scanning equipment; munition/warhead characterization/lethality; instrumentation; high

speed video; air vehicle performance; and documentation and program management support. Recent experie nce includes Intelligence, Surveillance, and Reconn aissance (ISR) aircraft, sensor, and primary mission equipment integration; operational data collection, processing, and analysis (including analysis of image

- based data for search and rescue) ; Federal Aviation Administration (F AA) and requirements complia nce; mission performance; validation/verification; and experimental testing. Our expertise encompasses ground, sea, and rotary and fixed

- wing air vehicle systems (manned and unmanned).
Of note, Skyward’s UAS lead also functions as the Director of Imagery Operations for the Down East Emergency Management Institute (DEEMI) on a volunteer basis. The Federal Aviation Administration (FAA) approved the first
- ever exemption (Exemption No. 11282 Regulatory Docket No. FAA−2014−0977 ) for search and rescue to DEEMI i n April of 2015
. The objective of Skward’s aerial data collection operation is to provide high quality data for a variety of commercial, public, and residential uses, specifically targeting:

 Detection and monitoring of incidences, materials, and natu ral occurrences harmful to natural resources
.6  Oil and Gas Pipeline Infrastructure Management

.

 Oil and Gas Incident Response and Hazardous Materials C lean

- up
.

 Emergency Response and Wildfire Management Operations.

 Search and Rescue Operations.

 Motion Picture Fi lming

.

 Interior and Exterior three

- dimensional modeling and inspection of public and private structures.

 Increase public knowledge of UAS and promote safe UAS operations. BACKGROUND Unmanned Aerial Systems: DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UAS s Skyward seeks an exemption to operate the DJI Inspire 1, DJI Spreading Wings s1000+,
3DR X8

- M, and 3DR Iris+ UASs for compensation or hire within the National Airspace System ( NAS )

. All UAS aircraft will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R. Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. The DJI Inspire 1, DJI Spreadin g Wings s1000+, 3DR X8

- M, and 3DR Iris+ are vertical takeoff and landing (VTOL) UA Ss with Ground Control Station s (GCS) also utilizing electronic tablet or smart phone systems. All four VTOL UAS platforms weigh less than 25lbs. maximum gross takeoff weight and have built

- in capability to limit flight elevation and distance fro m the Pilot in Command. All four UAS vehicles also have the built

- in capability to return to the launching point if the wireless control link is interrupted or if the operator attempts to exceed any of the pre - programmed height, radius, or airspace limitations. All four UAS platforms will be7

operated in airspace under 200ft AGL and within Line of Sight, and will not fly within 3 miles of a landing strip. The FAA has granted section 333 exemptions for the DJI Inspire 1, DJI Spreading Wings s1000+ in First Flight Photography, LLC, Exemption No. 11260, Regulatory Docket No. FAA−2014−0736 (as amended 14 April 2015) (DJI Spre ading Wings S1000; DJI Inspire); and the 3DR X8

- M in Aerial Precisio n Survey, Exemption No. 11617, Regulatory Docket No. FAA

2015

- 0549 (as amended 19 May 2015)(3D Robotic s X8+); and the 3DR Iris+ in Counsel for The Travelers Companies, Inc., Exemption No. 11490, Regulatory Docket No. FAA

- 2015

- 0307 (as amended 5 May 2015)( 3DR IRIS+). The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UA S s that will be operated by Skyward will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. BASIS FOR PETITION Petitioner, Skyward, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administ rator to commercially operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs i n the NAS , and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(a)(1)(b) , 91.405(a), 91.407(a)(1), 91.4 09(a)(1) & (a)(2), and 91.417(a) & (b). In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Skyward’s operation of the DJI Inspire 1, DJI Spreading8

Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Skyward requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Skyward submits that the requested relief is proper since an equivalent level of safety will be ensured. Skyward will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Ins pire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs Instruction Manual s ). Furthermore, Skyward will document and maintain all maintenance records for the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs

. Relief from cer tain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by Skyward to the extent necessary to allow a Pilot in Command (PIC) holding either an airline transport, commercial, private, recreational, or sport pilot certificate , as well as an airman medical certificate or valid U.S. driver’s license issued by a state , and who has demonstra ted, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.9

Skyward seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness , because the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Skyward submits that Skyward will ensure that the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating do cuments (i.e., Monthly Maintenance Log, and DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs Instruction Manual), and that the aircraft are in a condition for safe flight. Skyward also seeks an exemption from the requirements of Sec tion 91.121, entitled Altimeter Settings , as t he altitude reporting equipment of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs will be set to zero feet above ground level (AGL), rather than the local barometric pressure or field altitude, before each flight. The altitude information of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+
UASs is provided to the P IC v ia Global Positioning System (GPS) equipment, and a radio communications telemetry data link, which downlinks from the UA S to the GCS for active monitoring of the flight path. An equivalent level of safety will be achieved by the operator, pursuant to the Manual, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. Additionally, Skyward will operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs within visual line of sight (VLOS), at or below 200 feet AGL. This altitude information combined with Skyward’s operation of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs within visual line of sight, at or below 200 feet AGL, will ensure a level of safety equivalen t to Section 91.121. The FAA issued an exemption to this regulation for UAS operations in Exemption Nos. 11136 and 11138.10

Additionally, Skyward seeks an exemption from the requirements of Section 91.151(a)(1)(b) , entitled Fuel requirements for flight in VFR conditions

. Section 91.151(a)(1)(b) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes....” An exemption is needed because the UAS have a maximum flight time of less than 30 minutes and thus cannot meet the 30

- minute reserve requirement. Given the ch aracteristics of the UAS, including their small size, low weight and speed, limited range, ability to land very quickly, operation within visual line of sight, restricted operating area, and the fact that they do not carry persons or any explosive or flamm able materials, grant of the exemption is justified. An equivalent level of safety can be achieved by terminating flights at 25% battery power reserve, which will occur before the 22 minute flight duration for the 3DR Iris +, and 18 minute flight duration for the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M. The FAA issued an exemption to this regulation for UAS operations in Exemption Nos. 11062, 10673, 11136 and
11138. In accordance with 14 C.F.R. § 11.81, Skyward provides the following information in support of its petition for exemption: A. Name and Address Of The Petitioner. The name and address of the Petitioner is: Daniel Cyphers Statutory Agent Skyward, Ltd. 5717 Huberville Ave, Suite 300 Dayton, OH 45431

- 121711

B. The Specific Sections Of 14 C.F.R. From Which Skyward Seeks Exemption. 1. Skyward Seeks Exemption From The Requirements Of Section 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) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an airc raft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. 2. Skyward Seeks Exemption From The Requirements Of Section 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

con dition. 3. Skyward Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings , subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or

flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

—
(1) Below 18,000 feet MSL, to

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;12 (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an a ppropriate altimeter setting available before departure.
4. Skyward Seeks Exemption From The Requirements Of Section 91.151(a)(1)(b) . Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection s (a ) (1)(b), state the following:
(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

— (1) During the day, to fly after that for at least 30 minutes; or (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.
5. Skyward Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Maintenance required , subsec tion (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as p rescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]
6. Skyward Seeks Exemption From The Requirements Of Secti on 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 may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]13 7. Skyward Seeks Exemptio n From The Requirements Of Sections 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) of this section, no person may operate an aircraft unless, within the p receding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airwo rthiness certificate in accordance with part 21 of this chapter.
8. Skyward Seeks Exemption From The Requirements Of Sections 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) of this section: (1) Records of the maintenance, preventive maintenance, a nd alteration and records of the 100

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

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor.14 (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and applianc e. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the i nspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and rev ision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed eng ines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)( 2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and t he aircraft is approved for return to service. C. The Extent Of Relief Skyward Seeks And The Reason Skyward Seeks The Relief. 1. Extent Of Relief Skyward Seeks And The Reason Skyward Seeks Relief From Section 61.113(a) And (b). Relief from Section 61.113 (a) and (b) entitled Private pilot privileges and limitations: Pilot in command , is requested to the extent necessary to allow a Pilot in Command (PIC) holding either an airline transport, commercial, private, recreational, or sport pilot certificate, as

w ell as an airman medical certificate or valid U.S. driver’s license issued by a state , and who has15

met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since th e limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, Skyward submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1, DJI Spreadi ng Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs in a manne r 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, Skyward submits that all flights of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs , conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Skyward’s business; and (2) will not carry passengers or
pro perty for compensation or hire. 2. Extent Of Relief Skyward Seeks And The Reason Skyward Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Skyward to determine that the DJI Inspire 1, DJI Spreading Wings s1000+,
3DR X8

- M, and 3DR Iris+ UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Skyward Aerial Operations16

Manual, Monthly Maintenance Log, and DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs Instruction Manual). Skyward seeks the requested relief because the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Skyward will ensure that the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly M aintenance Log, and DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations be low. 3. Extent Of Relief Skyward Seeks And The Reason Skyward Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs because before each flight, the altitude reporting equipment will be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude. The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs utilize GPS equipment and radio communications telemetry data links to downlink altitude information from the UAS to the PIC at the ground control station (GCS).
Considering the limited altitude of the proposed operations, relief from 14 C.F.R. § 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. Section 91.121 requires each person operating an aircraft to maintain cruising altitude by ref

erence to an altimeter that is set “to the elevation of the departure airport or an appropriate altimeter setting available before departure.” An exemption may be needed because17

the UAS do not have a barometric altimeter, but instead have a GPS altitude re ad

- out. An equivalent level of safety will be achieved by the operator, pursuant to the Manual, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. Additionally, Skyward will operate the DJI Inspire 1, DJI Spreadin g Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs within visual lin e of sight (VLOS), at or below 200 feet AGL. The FAA issued an exemption to this regulation for UAS operati ons in Exemption Nos. 11136, 11138 , and 13085

. 4. Extent Of Relief Skyward Seeks And The Reason Skyward Se eks Relief From Section 91.151(a)(1)(b) . Relief from Section 91.151(a)(1)(b) entitled Fuel requirements for flight in VFR conditions , is requested to the extent required to allow flights of the battery powered DJI Inspire 1, DJI S pre ading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VF R). An exemption is needed because the UAS have a maximum flight time of less than 30 minutes and thus cannot meet the 30

- minute reserve requirement. Given the characteristics of the UAS, including their small size, low weight and speed, limited range, ability to land very quickly, operation within visual line of sight, restricted operating area, and the fact that they do not carry persons or any explosive or flammable materials, grant of the exemption is justified. An equivalent level of safety can be achieved by terminating flights at 25% battery power reserve, which will occur before the 22 minute flight duratio n for the 3DR Iris +, and 18 minute flight duration for the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M. The FAA issued an exemption to this regulation for UAS operations in Exe mption Nos. 11062, 10673, 11136, 11138, and 13085

. Skyward seeks the re quested relief because without an exemption from Section 91.151(a)(1)(b) , the flight time duration of the battery powered DJI Inspire 1, DJI S preading18

Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs will severely constrain the practicality of any aerial data co llection flight operations that Skyward proposes to conduct pursuant to this Petition. 5. Extent Of Relief Skyward Seeks And The Reason Skyward Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Skyward requests relief from these Sections because the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3D R Iris+ UASs do not require airworthiness certificates. As set forth more fully below, the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. A ccordingly, Skyward 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 Skyward aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs Instruction Manual). Furthermore, Skyward will document and maintain all maintenance records for the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, a nd 3DR Iris+ UASs

. D. The Reasons Why Granting Skyward’s Request 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 Skyward to safely, efficiently, and economically operate UASs to conduct commercial collection of aerial data for the purposes of photography and videography, hazardous materials incident mitigation, fire management, and search and rescue/recovery activities within the geographic boundaries of the United States. This exemption will also permit Skyward, Ltd. to con duct commercial collection of aerial data for the purposes of planning and training activities related to19

photography and videography, hazardous materials incident mitigation, fire management, and search and rescue/recovery activities. Additionally, use of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Skyward’s proposed operation of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs will be realized without implicating any privacy issues. 1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Inspire 1, DJI Sp reading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial data . By reducing the amount of manned aircraft needed to perfo rm aerial acquisitions, an exemption allowing the use of a DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial data collection missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8
- M, and 3DR Iris+ UASs .20

Conduc ting aerial data acquisitions with the DJI Inspire 1, DJI Spreading Wings s1000+,
3DR X8

- M, and 3DR Iris+ UASs , instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during tradi tional aerial data collection flight operations. By using battery power and electric motors, the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs produce no air pollution, and are the most viable environmentally conscious alternative to the fuel

- powered aircraft that are typically utilized for aerial data collection . The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs , while reducing the carbon footprint of aeri al acquisitions, also eliminate noise pollution, as the UA S s are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+
UASs to perform a erial data 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 of flight crew members located onboard the aircraft, the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M , and 3DR Iris+ UASs (weighing under 25lbs. at maximum gross takeoff weight , under three feet in diameter, and carrying no fuel on board) have 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 (wei ghing approximately 6,000 lbs with a wingspan of approximately 42 feet, a lengt h of 34 feet, and a fuel capacity of 180 gallons). 3. Performing Aerial Data Collection Operations With The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8
- M, and 3DR Iris+ UASs Will Benefit The Economy.21

In addition to being safe and efficient, the DJI Inspire 1, DJI Spreading Wings s1000+,
3DR X8

- M, and 3DR Iris+ UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs will allow United States based companies, like Skyward , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions p hasing 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 Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ 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 of a traditional manned aircraft. By operating the DJI Inspire 1, DJI Spreading Wings s1 000+, 3DR X8

- M, and 3DR Iris+
UASs , companies such as Skyward , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financ ial performance of U.S. companies, through commercial use of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+
UASs , provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and all ows companies to invest in research and development in order to remain competitive both in the United States and abroad. 4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Skyward’s proposed operation of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR22

X8

- M, and 3DR Iris+ UASs will not implicate any privacy issues. Specifically, the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs will be operated on ly in compliance with operating documents (i.e., the Skyward Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+
UASs Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. E. The Reasons Why Gra nting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Skyward Seeks Exemption. 1. Reasons Why The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8
- M, and 3DR Iris+ UASs Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Skyward’s op eration of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authori ty for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section
333 st ates the following, in part: (a) In General.

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

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

--23 (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capab ility, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Sa

fe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the natio nal airspace system. In seeking this exemption, Skyward submits that the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of th e DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs ; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8
- M, and 3DR Iris+ UASs Demonstrate Safe Characteristics. The DJI Inspire 1, DJI Spreading Wings s1 000+, 3DR X8

- M, and 3DR Iris+ UAS s do not create a hazard to users of the NAS or the public, or otherwise pose a threat to n ational security considering the size, weight, sp eed, and operational capability of each.

i. Technical Specifications Of The DJI Inspire 1, DJI Spreading Wings s1 000+, 3DR X8
- M, and 3DR Iris+ UASs . The technical specification of the DJI Inspire 1 UAS is set forth by the DJI Inspire 1 Specifications and Data Sheet, at tach ed hereto as Exhibit A

. The technical specification of the DJI Spreading Wings s1000+ UAS is set forth by the DJI Spreading Wings s1000+ Specifications and Data Sheet, attached hereto as Exhibit B.24

The technical speci fication of the 3DR X8

- M UAS is set forth by the 3DR X8

- M Specifications and Data Sheet, attached hereto as Exhibit C. The technical specification of the 3DR Iris+ UAS is set forth by the 3DR Iris+ Specifications and Data Sheet, attached hereto as Exhibit D.

ii. The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8
- M, and 3DR Iris+ UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area. The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs may be operated in both manual and fully autonomous flight modes. The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs may be operated in both semi and fully

a ut onomous flight modes. The autonomous features include the following: a GPS Position and Altitude Ho ld when initiated by the GCS; Return To Home (RTH) function s ; and Flight Limits (i.e., pre - set limitations that restrict the distance and height of UAS fligh t operations). A complete description of the flight and navigational modes of the DJI Inspire 1 UAS is provided in the user ’s manual a ttached hereto as Exhibit E

. A complete description of the flight and navigational modes of the DJI Spreading Wings
s1000+ UAS i s provided in the user ’s manual a ttached hereto as Exhibit F

. A complete description of the flight and navigational modes of the 3DR X8

- M UAS is provided in the user ’s manual attached hereto as Exhibit G. A complete description of the flight and navigational modes of the 3DR Iris+ UAS is provided in the user ’s manual attached hereto as Exhibit H.

iii. The DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8
- M, and 3DR Iris+ UASs Are Designed For Automatic Retu rn To Home Point Or Hover Or Auto
- Land In The Event Of Loss Of The Control Link Or Navigation.25

A complete description of the failsafe functions of the DJI Inspire 1 UAS is provided in the user ’s manual attached hereto as Exhibit E. A complete description of the failsafe functions of the DJI Spreading Wings s1000+ UAS is provided in the user’s manual attached hereto as Exhibit F. A complete description of the failsafe functions of the 3DR X8

- M UAS is provided in the user’s manual attached hereto as Exhibit G. A complete description of the failsafe functions of the 3DR Iris+ UAS is provided in the user’s manual attached hereto as Exhibit H.

b. Flight Operations Of DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8
- M, and 3DR Iris+ UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. Skyward will only utilize pilots who meet FAA certification requirements to act as a pilot in command (PIC) of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs . Additionally, a safety observer will assist all pilots during flight time, and all flights will remain within line of site of the PIC. Skyward’s Pilot in Command (PIC) will hold either an airline transport, commercial, private, r ecreational, or sport pilot certificate, as well as an airman medical certificate or valid U.S. driver’s license issued by a state, and will demonstrate, by meeting minimum flight

- hour and currency requirements, the ability to safely operate the DJI Inspir e 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

c. Flights Of DJI Inspi re 1, DJI Spreading Wings s1000+, 3DR X8
- M, and 3DR Iris+ UASs Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, Skyward proposes to commercially operate DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs for the special purpose of26

conducting aerial data collection within the geographical boundaries of the United States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant of exemption will be limited t o the following aircraft described in the operating documents, UASs weighing less than 55 pounds maximum gross weight: Rotocraft DJI Inspire 1, DJI Spreading Wings s1000+, and 3DR X8

- M, and 3DR Iris+ UAS s. Proposed operations of any other aircraft will req uire a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial data collection. 3. The UA S s may not be flown at an indicated airspeed exceeding 49 knots. 4. The UA Ss must be operated at an altitude of no more than 200 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UA S s 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 devi ce other than corrective lenses

. 6. The use of first 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 capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating docume nts. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documen ts and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in t he operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise it s operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or am endment to the grant of exemption. If the27 operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Of fice (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the 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 preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 13. The operato r must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the op erating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the 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 of the corrective action taken against discrepancies disc overed between inspections. 17. The PIC must meet all FAA pilot certification requirements

. 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate 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 of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must28 operate the UA S with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. U AS operations 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). If flight at night is required, a special request will be made at the FAA office closest to propo sed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA S may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOT AM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 21. The UA S may not be operated less than 5 00 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. If the UA S loses communications or loses its GPS signal, it must return to a pre

determined location within the planned operating area and land or be recovered in accordance with the ope rating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditi ons) there is enough power to fly at normal cruising speed to the intended landing point and land the UA S with 20 % battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a NOTAM not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder re quirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Mar kings must be as large as practicable. 27. T he radio frequency spectrum used for operation and control of the UA S must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agenc y requirements before conducting operations.29

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforc ement official upon request. 29. The UA S must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31 . Flight operations mu st be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA S 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 S , flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 9 1.119(a). 32 . All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained fo r each flight to be conducted.
33 . Any incident, accident, or flight operation that trans gresses 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) with in 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. Skyward submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs unless that PIC has demonstrated,30

by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X 8

- M, and 3DR Iris+ UASs in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Skyward’s proposed area of operations, and the op erating limitations set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements ( See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+
UASs , Skyward submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Skyward’s specific proposed flight operat ions. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161 , 13085 ). Skyward will not allow any PIC to operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs training and currency requirements, that the PIC is able to safely operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs in a ma nner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.31

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14
C.F. R. § 61.51(b), 25 hours of total time as a UAS pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomp lish 3 takeoffs and landings in the 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 of safety during Skyward’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

“ In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot includin g at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for opera tions under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in t he total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

building flights the PIC is requi red to operate the UA with appropriate distances in a ccordance with 14 C.F.R 91.119.” See Exemption No. 11138 at page 15. Accordingly, Skyward will ensure safe operations by not allowing any PIC to operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs unless that PIC32

has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UAS s in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
3. Reasons Why An Exemption From The Requirements Of Section 9 1.7(a) Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Skyward will ensure that the DJI Inspire 1, DJI Spreading Wings s1000+,
3DR X8

- M, and 3DR Iris+ UASs are 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 relief from Section 91.7(a) specific to
UAS s , 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, 11157, 11158, 11159, 11160, 11161 , 11166, 11167, 11170, 11171, 11172 , 11174, 11177, 11178, 11185, 11188 , 13085 ). 4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety. An equivalent level of safety will be achieved by the operator, pursuant to the 91.121, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. Additionally, Skyward will operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs within visual line of sight (VLOS), at or below 200 feet AGL , and will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring of the flight path and altitude. This altitude information combined with Skyward’s operation of the DJI Inspire 1, DJI Spreading33

Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs within visual line of sight, at or below 200 feet AGL, will ensure a level of safety 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
i nitiation point will be established for the UASs at ground level. The FAA has previously granted relief from 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, 111 57, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 11174, 11176, 11177, 11178, 11185, 11188 , 13085 )

. 5. Reasons Why An Exemption From The Requirements Of Section 91.151(a)(1)(b) Would Not Adversely Affect Safety. A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(a)(1)(b) as a result of (1) the technical specifications of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs ; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Sky ward will ensure that it will safely operate the battery powered UASs only during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power for the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M UASs to fly for a total duration of 13 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes, and for the 3DR Iris+ UAS t o fly for a total duration of 18 minutes to the first point of intended landing and, assuming normal cruising speed, t o fly after that for at least 5 minutes. Here, as established by previous Grants of Exemption concerning the DJI Inspire 1 and DJI Spreading Wings s1000+ UAS s ; as in Exemption No. 11260 , the technical specifications of34

the DJI Inspire 1 and DJI Spreading Wings s1000+ UASs ; and Grants of Exemption concerning the 3DR X8

- M UAS, as in Exemption No. 11617, the technical specifications of the 3DR X8

- M; and the 3DR Iris+ as in Exemption No. 11490, the technic al specifications of the 3DR Iris+ ; and the location of the proposed operations, will ensure an equivalent level of safety establish ed by 14 C.F.R. Section 91.151(a)(1)(b) . Furthermore, safety will be ensured as the DJI Inspire 1, DJI Spreading Wings s1000 +, 3DR X8

- M, and 3DR Iris+ UASs provide audible and visual warnings to the PIC at the GCS when the UASs experiences low battery voltage . At the critically low battery level, the DJI Inspire 1, DJI Sp reading Wings s1000+, 3DR X8

- M, and 3DR Iris+ will descend and land automatically.

Likewise , previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has be en 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 relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170,
1 1171, 11172, 11174, 11176, 11177, 11178, 11185, 11188 , 13085 ).
6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. In seeking this exemption, Skyward submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections35

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met bec ause all maintenance, alterations, or preventive maintenance of the UAS performed by Skyward will be in accordance with the methods, techniques, and practices prescribed in the operating documents (i.e., the Extended User Manual, Maintenance Procedures, Tr aining Documentation, and Justification of Airworthiness and Safety Assessments). Furthermore, only the Original Equipment Manufacturer (OEM) or qualified OEM maintainers will perform higher

- level inspections and maintenance per the operating documents and OEM standards. Skyward will document and maintain all maintenance records for the UAS.

Since the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs will be inspected as prescribed by the operating documents, Skyward will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2)

. Copies of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs user

m anuals are a ttached hereto as Exhibit E, F, G, and H ; copies of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs Maintenance Logs are attached hereto as
Exhibit I

. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & ( a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS s are considered.
7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Secti on 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Skyward requests that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1, DJI Spreading Wings36

s1000+, 3DR X8

- M, and 3DR Iris+ UASs , which contain such safety standards that the

a dministrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(a)(1)(b) , 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs for the limited purpose of conducting ae rial data collection over the geographic boundaries of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.
Likewise, the Administrator m ay prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs , since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate saf

ety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions , states the following:
If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate saf ety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are iss ued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.
See 14 C.F.R. § 21.16.37

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Skyward’s intended operation of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs , which contai n such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(a)(1)(b) , 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Skyward Seeks Exemption: Skyward, Ltd. seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 9 1.121, 91.151(a)(1)(b ), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). A Brief Description Of The Nature Of The Exemption Skyward Seeks: This exemption will permit Skyward, Ltd. to commercially operate Unmanned Aircraft System s (UAS s ) for the purpose of conducting aerial data collection within the National Airpspace System (NAS). G. Any Additional Information, Views, Or Arguments Available To Support Skyward ’s Request.
This Petition is made pursuant to the FAA Moder nization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Skyward’s request for exemption may be granted pursuant to the authority of FMRA Section 3 33 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the aut hority for such UAS to operate without airworthiness certification.38

As discussed in detail above, Skyward will operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION As set forth herein, Skyward, Ltd. seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit s afe operation of the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iris+ UASs commercially, without an airworthiness certificate, for the limited purpose of conducting aerial data acquisitions withi n the NAS . By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the public interests, by allowing Skyward to safely, efficiently, and economically operate UAS commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Skyward 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, 91.151(a)(1)(b) , 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Skyward to operate the DJI Inspire 1, DJI Spreading Wings s1000+, 3DR X8

- M, and 3DR Iri s+ UASs commercially for the purpose of conducting aerial data collection within the NAS.39

Dated: June 16 , 2015
Respectfully submitted, Skyward, Ltd. /S/ Dan iel C. Cyphers Statutory Agent

_________________________ Dan iel C. Cyphers Statutory Agent 5717 Huberville Ave, Suite 300 Dayton, OH 45431

- 1217 Tel: (937) 252

- 2710, ext. 102

Appendices (In this Document) : A

– DJI Inspire 1 UAS Specifications Data Sheet B

– DJI Spreading Wings s1000+ Specifications Data Sheet C

– 3DR X8

- M Specifications Data Sheet D

– 3DR Iris+ Specifications Data Sheet E

– Monthly Maintenance Log Appendices (In Separate Documents) : F

– DJI Inspire 1 UAS Manufacturer’s User Manual G

– DJI Spreading Wings s1000+ Manufacturer’s User Manual H

– 3DR X8

- M Manu facturer’s User Manual I

– 3DR Iris+ Manufacturer’s User Manual40 APPENDIX

– A DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

1.1. DJI Inspire 1

1.1.1. Aircraft 1.1.1.1.1. Model: T600 1.1.1.1.2. Weight (Battery Include d): 6lbs 7.5291oz (2935g) 1.1.1.1.3. Hovering Accuracy (GPS Mode) : Vertical: 0.5m; Horizontal: 2.5m 1.1.1.1.4. Max Angular Velocity : Pitch: 300 0 /s; Yaw: 150 0 /s 1.1.1.1.5. Max Tilt Angle: 35 0 1.1.1.1.6. Max Ascent Speed: 5m/s 1.1.1.1.7. Max Descent Speed: 4m/s 1.1.1.1.8. Max Speed: 22m/s (ATTI mode, no wind

– NOT RECOMMENDED) 1.1.1.1.9. Max Flight Altitude: 4500m 1.1.1.1.10. Max Wind Resistance: 10m/s 1.1.1.1.11. Max Flight Time: Approximately 18 minutes 1.1.1.1.12. Motor Model: DJI 3510 1.1.1.1.13. Propeller Model: DJI 1345 1.1.1.1.14. Operating Temperature Range: 14 0 F to 104 0 F (

- 10 0 C to 40 0 C) 1.1.1.1.15. Dimensions: 17 1⁄4” x 17 3⁄4” x 12” 1.1.2. Gimbal 1.1.2.1.1. Model: ZENMUSE X3 1.1.2.1.2. Output Power (with camera): Static: 9W; In M otion: 11W 1.1.2.1.3. Operating Current: Static: 750mA; In Motion: 900mA 1.1.2.1.4. Angular Vibra tion Range: ±0.03 0 1.1.2.1.5. Mounting: Detachable 1.1.2.1.6. Controllable Range: Pitch:

- 90 0 to +30 0 ; Pan: ±320 0 1.1.2.1.7. Mechanical Range: Pitch:

- 125 0 to 45 0 ; Pan: ±330 0 1.1.2.1.8. Max Controllable Speed: Pitch: 120 0 /s; Pan: 180 0 /s 1.1.3. Camera 1.1.3.1.1. Name : X3 1.1.3.1.2. Model: FC350 1.1.3.1.3. Total Pixels: 12.76M 1.1.3.1.4. Effective Pixels: 12.4M 1.1.3.1.5. Image Max Size: 4000x300041 1.1.3.1.6. ISO Range: 100

- 3200 1.1.3.1.7. Field of View: 94 0 1.1.3.1.8. CMOS: Sony EXMOR 1/2.3” 1.1.3.1.9. HD Video Recording: UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 1.1.3.1.10. Operating Temperature Range: 32 0 F

- 104 0 F (0 0 C

- 40 0 C) 1.1.4. Transmitter 1.1.4.1.1. Name: C1 1.1.4.1.2. Operating Frequency: 5.728

- 5.850GHz; 2.400

- 2.483GHz 1.1.4.1.3. Communic ating Distance (unobstructed): 2000m 1.1.4.1.4. Output Power: 9W 1.1.4.1.5. Operat ing Temperature Range: 14 0 F to 104 0 F (

- 10 0 C to 40 0 C) 1.1.4.1.6. Battery: 600mAh LiPo 2S42 APPENDIX

– B DJI SPREADING WINGS S1000+ TECHNICAL SPECIFICATIONS

1. DJI Spreading Wings s1000+

1.1. Frame 1.1.1. Diagonal Wheelbase: 1045mm 1.1.2. Frame Arm Length: 386mm 1.1.3. Frame Arm Weight (Including Motor, ESC, Propeller): 325g 1.1.4. Center Frame Diameter: 337.5mm 1.1.5. Center Frame Weight (With Landing Gear Mounting Base, Servos): 1330g 1.1.6. Landing Gear Size: 460mm (Length) ×511mm (Width) ×305mm (Height), (Top width: 155 mm) 1.2. Motor 1.2.1. Stator S ize: 41×14mm 1.2.2. KV: 400rpm/V 1.2.3. Max Power: 500W 1.2.4. Weight(With Cooling Fan): 158g 1.3. ESC 1.3.1. Working Current: 40A 1.3.2. Working Voltage: 6S LiPo 1.3.3. Signal Frequency 30Hz ~ 450Hz 1.3.4. Drive PWM Frequency: 8KHz 1.3.5. Weight(With Radiators): 35g 1.4. Foldable Propeller (1552/1552R) 1.4.1. Material: High strength performance engineered plastics 1.4.2. Size: 15×5.2inch 1.4.3. Weight: 13g 1.5. Flight Parameters 1.5.1. Takeoff Weight: 6.0Kg ~ 11.0Kg 1.5.2. Total Weight: 4.2Kg 1.5.3. Power Battery: LiPo (6S 、 10000mAh~20000mAh 、 15C(Min)) 1.5.4. Max Power Consumption: 4000W 1.5.5. Hover Power Consumption: 1500W (@9.5Kg Takeoff Weight) 1.5.6. Hover Time: 15min (@15000mAh & 9.5Kg Takeoff Weight) 1.5.7. Working Environment Temperature:

- 10 °C ~ +40 °C 1.6. Gain Value Settings 1.6.1. For A2 Flight Controller Basic: Roll 120%, Pitch 120%, Yaw 120%; Attitude: Roll 170%, Pitch 170%, Vertical 12 0% 1.6.2. For WooKong

- M Flight Controller Basic: Roll 180%, Pitch 180%, Yaw 120%; Attitude: Roll 180%, Pitch 180%, Vertical 120%43 APPENDIX

– C 3D ROBOTICS (3DR) X8
- M TECHNICAL SPECIFICATIONS

1. 3DR X8

- M

1.1. Software 1.1.1. Autopilot: 3DR Pixhawk V2.4.5 1.2. Airframe 1.2.1. Firmware: ArduCopter 3.2 1.2.2. GPS: 3DR u

- blox GPS with Compass (LEA

- 6H module, 5 Hz update) 1.2.3. Telemetry radio: 3DR Radio v2 (915 mHz or 433 mHz) 1.2.4. Motors: SunnySky V2216

- 12 800 kV II 1.2.5. Frame: X 1.2.6. Propellers: APC 11X4.7 SFP (4), APC 11X4.7 SF (4) 1.2.7. Aircraft weight (with battery): 7 .7 lbs (3.5 kg) 1.2.8. Aircraft dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 30 cm) 1.2.9. Payload capacity: .4 lbs (200 g) 1.2.10. Radio range: .6 miles* (1 km) 1.2.11. Flight time: 14 min* 1.2.12. Maximum operational wind speed: 25 mph (11 m/s) 1.2.13. Landing accuracy: 8.2 ft (2.5 m) 1.2.14. Re commended flight speed: 11 mph (5 m/s) 1.3. Battery 1.3.1. Battery: 4S 10000 mAh 10C lithium polymer 1.4. Camera 1.4.1. Camera: Canon SX260 12.1 megapixel 1.4.2. Camera software: 3DR EAI 1.0 1.4.3. Area coverage (single flight): 25 acres* (0.1 km2) 1.4.4. Orthomosaic accuracy: 3

- 16 ft (1

- 5 m) 1.4.5. Ground sampling distance: .7 inches per pixel* (2 cm per pixel) 1.4.6. Image processing software: Pix4Dmapper LT 3DR Edition (Windows only)44 APPENDIX

– D 3DR IRIS+ TECHNICAL SPECIFICATIONS
1. 3DR Iris+

1.1. Software 1.1.1. Autopilot: Pixhawk v2.4.5 1.2. Airframe 1.2.1. Firmware: ArduCopter 3.2 1.2.2. GPS: 3DR uBlox GPS with Compass (LEA

- 6H module, 5 Hz update) 1.2.3. Telemetry radio: 3DR Radio Telemetry v2 (915 mHz or 433 mHz) 1.2.4. Motors: 920 kV 1.2.5. Frame type: V 1.2.6. Propellers: 9.5 x 4.5 T

- Motor multirotor self

- tightening counterclockwise (2) 1.2.7. 9.5 x 4.5 T

- Motor mult irotor self

- tightening clockwise (2) 1.2.8. Radio range: up to 1 km (.6 miles) 1.2.9. Flight time: 16

- 22 minutes, depending on payload 1.3. Battery: 3S 5.1 Ah 8C lithium polymer 1.3.1. Low battery voltage: 10.5 V 1.3.2. Maximum voltage: 12.6 V 1.3.3. Battery cell limit: 3S ( IRIS is compatible wi th 3S lithium polymer batteries only. 1.3.4. Using a 4S battery can cause permanent damage to the gimbal electronics and will void the warranty .) 1.3.5. Payload capacity: 400 g (.8 lbs)45 APPENDIX

– E SKYWARD MONTHLY MAINTENANCE LOG

Year : ______ / Month :

_______ UAS Type & Tail # : _____________________________________________________________________

Date Issue Discovered Date Issue

Addressed Issue Description & Type Maintenance Conducted Maintenance Performed By: (Print & Sign)
Software (Updates)

Airframe

Engines

Propellers

Camera / Gimbal

Landing Gear

Vibration (Dampening)

Other: