UNITED STATES OF AMERICA DEPARTMENT OF
TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC Regulatory Docket No. ___________________

Docket Operations, M-30 U.S. Department of Transportation (DOT) 1200 New Jersey Avenue, SE Room W12-140, West Building Ground Floor Washington, DC
20590-0001

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:



### David Arnold AirbornePics

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), AND 91.417(a) & (b)
CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 2
AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS
PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on January 28, 2016

AirbornePics c/o David Arnold Owner

4 La Sinfonia, Rancho Santa Margarita, California 92688

949.525.1997

TABLE OF CONTENTS

GLOSSARY OF
ABBREVIATIONS ....................................................................... 3
SUMMARY.................................................................................... 4
INTRODUCTION AND INTERESTS OF
PETITIONER............................................................. 4BACKGROUND ..............................................................................5
BASIS FOR
PETITION........................................................................................ 5

**A.** NAME AND ADDRESS OF PETITIONER........................ 7

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

David Arnold and AirbornePics SEEKS EXEMPTION ............. 8

**C.** THE EXTENT OF RELIEF AND THE REASON DAVID ARNOLD
AND AIRBORNEPICS SEEKS THE RELIEF
............................................................................... 11

**D.** THE REASONS WHY GRANTING DAVID ARNOLD AND AIRBORNEPICS REQUEST WOULD BE IN THE
PUBLIC INTEREST ....................................................................... 13

**E.** THE REASONS WHY GRANTING THE EXEMPTION
WOULD NOT ADVERSELY AFFECT SAFETY........................... 15

THE REASONS WHY GRANTING AN EXEMPTION FROM THE REQUIREMENTS OF 61.113( A ) AND ( B )
WOULD NOT ADVERSELY AFFECT
SAFETY..................................................................... 22

CONCLUSION ............................................................................... 23

EXHIBITS

Page 2 of 26GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control ATO Air Traffic Organization Aerial Vehicle
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 Positioning System
LOL Loss of Link
NAS National Airspace System

PIC Pilot In Command Section 333 FAA Modernization and Reform Act of2012 (FMRA) SO Safety Observer SOP Standard Operating Procedure
DJI UAV manufacturer ESC Electronic speed control
FPV First Person View Li-Po Lithium Polymer batt ery

VTOL Vertical Takeoff and Landing

RCV Radio Controlled Vehicle

sUAS Small Unmanned Aircraft System -under 55 pounds Gross Weight

UAS Unmanned Aircraft System

Page 3 of 26**SUMMARY**

DAVID ARNOLD AND AIRBORNEPICS seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit DAVID ARNOLD AND AIRBORNEPICS to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography for marketing, film sets, real estate photography, commercials, special events, wedding cinematography, and landscape over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER**

My name is DAVID ARNOLD, and I am the Manager and Owner of AIRBORNEPICS I also hold a Private pilot certificate, along with a 3 rd

Class Medical Certificate.

DAVID ARNOLD is also a drone builder and operator (pilot) with expertise and knowledge in aspects of building, programing and operating multiple types of UAS'S along with camera set up and operation. DAVID ARNOLD is also an experienced professional photographer who provides clients with the highest quality digital content for use in their commercial, personal, and non-profit multimedia projects. DAVID ARNOLD is a member of the Academy of Model Aeronautics (“AMA”) and has 20 years of Radio Controlled aircraft experience including helicopters. The objective of DAVID ARNOLD AND AIRBORNEPICS, aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, andresidential uses, along with testing of repaired drones for clients in a safe testing location away from all obstacles and people at all times.

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**BACKGROUND**

Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire1

DAVID ARNOLD AND AIRBORNEPICS seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 3 and DJI Inspire1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom3 has a maximum gross weight of approximately 2 pounds 7 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Phantom 3 and DJI Inspire l UA’s are equipped with four main rotors; driven by electric motors powered by a Lithium Polymer battery.

The DJI Phantom 3 and DJI Inspire 1 sUAS’s that will be operated by DAVID ARNOLD AND AIRBORNEPICS will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Markings

.

**BASIS FOR PETITION**

Petitioner,DAVID ARNOLD AND AIRBORNEPICS, pursuant to the provisions of the Federal Aviation Regulations (14C.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 Administrator to commercially operate the DJI Phantom 2 and the DJI Inspire 1 sUAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.119, 91.121, 91.l51(b), 91.405(a), 91.407(a)(I), 91.409(a)(l) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, DAVID ARNOLD AND AIRBORNEPICS operation of DJI Phantom 3 and DJI Inspire 1 sUAS’s 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, DAVID ARNOLD AND AIRBORNEPICS requests relief from Sections 91.405(a), 91.407(a)(I), 91.409(a)(I) & (a)(2), and 91.417 (a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.

DAVID ARNOLD AND AIRBORNEPICS submits that the requested relief is proper since an equivalent level of safety will be ensured. DAVID ARNOLD AND AIRBORNEPICS will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the sUAS using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual). Furthermore, DAVID ARNOLD AND AIRBORNEPICS will
document and maintain all maintenance records for the DJI Phantom 3 and DJI Inspire 1 sUAS.

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Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by DAVID ARNOLD AND AIRBORNEPICS to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who hasdemonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 and DJI Inspire 1 sUAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

DAVID ARNOLD AND AIRBORNEPICS seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 2 and DJI Inspire 1 sUAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, DAVID
ARNOLD AND AIRBORNEPICS submits that he will ensure that the DJI Phantom 3 and DJI Inspire l sUAS are in an airworthy condition, prior to every flight, by determining that the sUAS are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight

. DAVID ARNOLD AND AIRBORNEPICS seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 3 and DJI Inspire 1 UAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2 and DJI Inspire 1 UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring of the flight path. This altitude information, combined with operation of the DJI Phantom 3 and DJI Inspire 1 sUAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, DAVID ARNOLD AND AIRBORNEPICS seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. DAVID ARNOLD AND AIRBORNEPICS submits that safety will not be affected by operation of the DJI Phantom 3 and DJI Inspire 1 sUAS’s during daylight hours in visual meteorological conditions under visual flight rules (VFR), with enough battery power to fly to point of intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.Page 6 of 26

In accordance with 14 C.F.R. § 11.81, DAVID ARNOLD AND AIRBORNEPICS 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 and point of contact is:

DAVID ARNOLD AND AIRBORNEPICS

4 La Sinfonia, Rancho Santa Margarita, CA 92688

rsmarnold@yahoo.com

949.525.1997

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**B. The Specific Sections Of 14 C.F.R. from Which AERIAL IMAGES AND VIDEO LLC Seeks Exemption.** 

**1. DAVID ARNOLD AND AIRBORNEPICS Seeks Exemption From The Requirements Of Section 61.1l3(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
aircraft.b. A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if-

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

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

**2. DAVID ARNOLD AND AIRBORNEPICS 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 condition.

**3. DAVID ARNOLD AND AIRBORNEPICS Seeks Exemption**  **From The Requirements Of Section 91.121.**

a. 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-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;

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

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

4. DAVID ARNOLD AND AIRBORNEPICS **Seeks Exemption From The Requirements Of Section 91.151(b).** 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and 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.

Page 8 of 26

5. DAVID ARNOLD AND AIRBORNEPICS **Seeks Exemption From The Requirement Of Section 91.405(a).** 

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

a. Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter

6. DAVID ARNOLD AND AIRBORNEPICS **Seeks Exemption From The Requirements Of Section 91.407(a)** 

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration;a. Subsection (a)(1), states the following: No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-- (1) It has been approved for return to service by a person authorized under §43.7 of this chapter

**7. DAVID ARNOLD AND AIRBORNEPICS Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).** 

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

i. Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it
has had –

. (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

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

**8. DAVID ARNOLD AND AIRBORNEPICS Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).** 

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

i. Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and 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(a) A description (or reference to data acceptable to the Administrator) of the work performed; and

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(b) The date of completion of the work performed; and

(c) The signature, and certificate number of the person approving the
aircraft for return to service.

Records containing the following information:

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

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

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

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

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

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

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

. (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other workor for I year after the work is performed.

. (2) The records specified in paragraph (a)(2) of this section shall
be retained and transferred with the aircraft at the time the aircraft
is sold.

. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

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**C. The Extent Of Relief DAVID ARNOLD AND AIRBORNEPICS**
**Seeks And The Reason DAVID ARNOLD AND AIRBORNEPICS**
**Seeks The Relief.**

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

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

and limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the 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, DAVID ARNOLD AND AIRBORNEPICS submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 UAS or DJI Inspire 1 UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with theoperations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, DAVID ARNOLD AND AIRBORNEPICS submits that all flights of the DJI Phantom 3 and DJI Inspire 1 sUAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to DAVID ARNOLD AND AIRBORNEPICS business; and (2) will not carry passengers or property for compensation or hire.

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b. Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow DAVID ARNOLD AND
AIRBORNEPICS to determine that the DJI Phantom 3 and DJI Inspire 1 sUAS are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., DAVID ARNOLD AND AIRBORNEPICS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual). DAVID ARNOLD AND AIRBORNEPICS seeks the requested relief because the DJI Phantom 3 and DJI Inspire 1 sUAS do not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Therefore, DAVID ARNOLD AND AIRBORNEPICS will ensure that the DJI Phantom 3 and DJI Inspire 1 sUAS are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 User Manuals; prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.Relief from Section 91.121,
entitled Altimeter settings , may be required to allow flight operations of the DJI Phantom 3 and DJI Inspire 1 sUAS, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC)in feet above ground level (AGL), DAVID ARNOLD AND AIRBORNEPICS seeks the requested relief because the DJI Phantom 3 and DJI Inspire 1 UAS altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 and DJI Inspire 1 UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads-up display of the GCS.

c. Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Phantom 2 and DJI Inspire 1 sUAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of approximately15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least
4.5 minutes. DAVID ARNOLD AND AIRBORNEPICS seeks the requested relief because without an exemption from Section 91.151 (b), the flight time duration of the battery powered DJI Phantom 3 and DJI Inspire 1 UAS will severely constrain the practicality of any aerial video or still photo flight operations that DAVID ARNOLD AND AIRBORNEPICS proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 3 and DJI Inspire 1 sUAS, the DJI Phantom 3 and DJI Inspire 1 operating documents, and the operating limitations proposed by DAVID ARNOLD AND AIRBORNEPICS, ensure that DAVID ARNOLD AND AIRBORNEPICS will safely operate the battery powered DJI Phantom 3 and DJI Inspire 1 sUAS during daylight hours in visualmeteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

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d. 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, DAVID ARNOLD AND AIRBORNEPICS requests relief from these Sections because the DJI Phantom 3 and DJI Inspire 1 sUAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 and DJI Inspire 1 sUAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, DAVID ARNOLD AND AIRBORNEPICS will use trained technicians to perform maintenance, alterations, or preventive maintenance on the sUAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., DAVID ARNOLD AND AIRBORNEPICS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual). Furthermore, DAVID ARNOLD AND AIRBORNEPICS will
document and maintain all maintenance records for the DJI Phantom 3 and DJI Inspire 1 sUAS.

**D. Would Be In The Public Interest: That Is, How It Would Benefit The** 
**Public As A Whole.**

**The Reasons Why Granting DAVID ARNOLD AND AIRBORNEPICS Request** 

Granting the present Petition will further the public interest by allowing DAVID ARNOLD AND AIRBORNEPICS safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States.Additionally, use of the DJI Phantom 3 and DJI Inspire 1 sUAS will decrease congestion of the NAS, reduce pollution, crashes and accidents caused by pilot error and provide significant benefits to the economy. Notably, the benefits of DAVID ARNOLD AND AIRBORNEPICS proposed operation of the DJI Phantom 3 and DJI Inspire 1 sUAS will be realized without conflicting with or violation of any privacy issues.

**1. The Public Will Benefit From Decreased Congestion Of The**
**NAS.** The DJI Phantom 3 and DJI Inspire 1 UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 or DJI Inspire 1 UAS 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 Phantom 3 and DJI Inspire 1 UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

**2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3**  **and DJI Inspire 1 sUAS.**

Page 13 of 26Conducting aerial media acquisitions with the DJI Phantom 3 and DJI Inspire 1 sUAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 3 and DJI Inspire 1 sUAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography which burn approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 and DJI Inspire 1 UAS, while reducing the carbon footprint of aerial acquisitions, also eliminate noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom 3 and DJI Inspire 1 sUAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional 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 Phantom 3 and DJI Inspire 1 UAS (weighing approximately 2 pounds 14 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

**3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 and DJI Inspire 1 sUAS Will Benefit The**  **Economy.** In addition to being safe and efficient, the DJI Phantom 3 and DJI Inspire 1 sUAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 and DJI Inspire 1 sUAS will allow United States based companies to remain competitive and contribute togrowth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 3 and DJI Inspire 1 sUAS utilizes technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 3 and DJI Inspire 1 sUAS, companies such as DAVID ARNOLD AND AIRBORNEPICS 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 financial performance of U.S. companies, through commercial use of the
DJI Phantom 3 and DJI Inspire 1 sUAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows 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.**

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Page 15 of 26

Similar to the manned aerial media acquisition flight operations that have been conducted for decades, DAVID ARNOLD AND AIRBORNEPICS proposed operation of the DJI Phantom 3 and DJI Inspire 1 sUAS would not implicate any privacy issues. Specifically, the DJI Phantom 3 and DJI Inspire 1 sUAS will be operated only in compliance with operating documents (i.e., DAVID ARNOLD AND AIRBORNEPICS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual) whichrequires 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 Granting 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 DAVID ARNOLD AND AIRBORNEPICS Seeks Exemption.** 

1. Reasons Why The DJI Phantom 3 and DJI Inspire 1 sUAV Meet
The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333:

2. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, DAVID ARNOLD AND AIRBORNEPICS operation of the DJI
Phantom 3 and DJI Inspire 1 sUAS 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 authority 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 states the following, in part:

a. In General. --Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rule making 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 shalldetermine, at a minimumi. Which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (J).

c. Requirements for Safe Operation. --If the Secretary 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 national airspace system.

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In seeking this exemption, DAVID ARNOLD AND AIRBORNEPICS submits that the DJI Phantom 3 and DJI Inspire 1 sUAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 and DJI Inspire 1 sUAS, (b) the pilot certification requirement and (c) the specific operating
limitations.

**i. The Specifications Of The DJI Phantom 3 and DJI Inspire 1**
**sUAS Demonstrate Its Safe Characteristics.**
The DJI Phantom 3 and DJI Inspire 1 sUAS do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.**ii. Technical Specifications Of The DJI Phantom 2 and DJI Inspire 1 sUAS.**  The DJI Phantom 3 and DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibits A and B, set the technical specifications of the DJI Phantom 3 and DJI Inspire 1 sUAS forth.

**iii. The DJI Phantom 3 and DJI Inspire 1 sUAS Autonomous Flight And Navigation Modes Enable The sUAS To Remain**  **Within A Defined Operational Area.** The DJI Phantom 3 and DJI Inspire 1 sUAS may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3 and DJI Inspire 1 sUAS is provided at pages 25-35 of
the DJI Phantom 3 and pages 12-16 and 45-50 of the DJI Inspire I User Manuals, attached hereto as Exhibit C and D.

**iv. The DJI Phantom 3 and DJI Inspire 1 sUAS Are Designed For**
**Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.**  When the Control Link is lost, the DJI Phantom 2 and DJI Inspire 1 UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 and DJI Inspire 1 UAS do not reacquire control link data from the GCS, the UAS will assume
that the Control Link is lost and the UAS will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI Phantom 2 UAS are set forth at pages 27 and 28 and for the DJI Inspire 1 at pages 13 through 15 of the DJI Phantom 2 along with complete DJI Inspire 1 User Manuals,
attached hereto as Exhibit C and D.**v. The DJI Phantom 3 and DJI Inspire 1 Ground Control Station (“GCS”) And It's Operation.**  A complete description of the operation and specifications of the DJI Phantom 3 and DJI Inspire 1 GCS and flight control software is provided at pages 32 through 44 of the DJI Phantom 3 User Manual and pages 23 through 33 of the DJI Inspire 1 User Manual. DJI Phantom 2 and DJI Inspire 1 User Manuals are attached hereto
as Exhibits C and D.

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vi. **Flight Operations Of DJI Phantom 3 and DJl Inspire 1 sUAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command**  **With A Safety Observer.**

vii. **AERIAL IMAGES AND VIDEO LLC** will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3 and DJI Inspire 1 sUAS. Additionally, a safety observer will assist all pilots during flight
time.

viii. **Flights Of DJI Phantom 3 and DJI Inspire 1 sUAS Will Be Conducted Pursuant To Specific**  **Operating Limitations.**

In seeking this exemption, **AERIAL IMAGES AND VIDEO LLC** proposes to commercially operate DJI Phantom 3 and DJI Inspire 1 UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating
limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft sUAS weighing less than 55 pounds maximum gross weight: DJI Phantom 3 and D JI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require anew petition or a petition to amend this grant.

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

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

4. The UAS must be operated at an altitude of no more than 4 00 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 UAS 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.

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 operatingdocuments.

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.

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9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating
documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition f or 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 hasbeen 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 operator 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 operating 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 sUAS 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 discovered between inspections.

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17. The PIC must possess at least a private pilot certificate and at least
a current third-class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator's qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including 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 training, proficiency, and experience- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. §91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR)
are not authorized.20. The UAS may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport's management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator's COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

21. The UAS 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 loses communications or loses its GPS signal, it must return to a pre-determined location within the planned operating area and land or be recovered in accordance with the operating
documents.

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

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

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not
more than 72 hoursPage 21 of 26

in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N-Number) markings in accordance with 14 C.F .R. part 45, Subpart C. Markings must be as large as practicable.

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

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203
must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

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

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operatortrainees or essential persons), vessels, vehicles, and structures
unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or;

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

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

32. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be
conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS IntegrationOffice (AFS-80)

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within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Website: www.ntsb.gov.

**Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.** 

DAVID ARNOLD AND AIRBORNEPICS submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 2 and DJI Inspire 1 sUAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering DAVID ARNOLD AND AIRBORNEPICS proposed area of operations, and the operating 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 Phantom 3 or DJI Inspire 1 UAS,
DAVID ARNOLD AND AIRBORNEPICS submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for DAVID ARNOLD AND AIRBORNEPICS specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). DAVID ARNOLD AND AIRBORNEPICS will not allow any PIC to operate the DJI Phantom 3 or DJI Inspire 1 UAS unless that PIC has demonstrated, by meetingminimum flight-hour requirements or the DJI Phantom 3 or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 or DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51 (b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062,11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during DAVID ARNOLD AND AIRBORNEPICS 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 including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a sUAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be
included in the 10 hours of multi-rotor time and the 10 hours may be

included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirement, the PIC must accomplish takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight hour requirement 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 findsthat 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 night time. During training, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14
C.F.R 91.119.

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Exemption No. 11138 at page 15. Accordingly, DAVID ARNOLD AND

AIRBORNEPICS will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 or DJI Inspire 1 U AS unless the PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

CONCLUSION

DAVID ARNOLD AND AIRBORNEPICS 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 safe operations of the DJI Phantom 3 and DJI Inspire 1 UAS commercially, without an airworthiness certificate, for limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also**Page 24 of 26 EXHIBIT A** 

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

DAVID ARNOLD AND AIRBORNEPICS only utilizes safe and reliable sUAS. DJI is an industry leader in small UAS production. DJI sUAS are complete with leading edge and proven software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also he set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

DJI Phantom 3

1.1 Aircraft 1.1.1 Supported Battery -DJI 4480mAh 4S LiPo Battery 1.1.2 Weight (Battery & Propellers Included) -2 lbs 11.81 oz (1,242g) 1.1.3 Hover Accuracy (Ready to Fly) -Vertical: .8m; Horizontal: 2.5m 1.1.4 Max Yaw Angular Velocity 200°/s 1.1.5 Max Tilt Angel 35° 1.1.6 Max Ascent / Descent Speed: Ascent 6m/s Descent 2m/s 1.1.7 Max Flight Speed-15m/s (NOT RECOMMENDED)
1.2 Gimbal 1.2.1 Working Current -Static: 750mA; Dynamic: 900mA 1.2.2 Control Accuracy -±O.03° 1.2.3 Controllable Range -Pitch: 90° to 0° 1.2.4 Maximum Angular Speed Pitch: 90°/s
1.3 Camera 1.3. 1 Operating Temperature Range 32°F - 104°F (O°C to 40°C) 1.3.2
Sensor Size 1⁄2. 3 " 1.3.3 Effective Pixels: 14 Megapixels 1.3.4 Resolution 4384x3288px 1.3.5 HD Video Recording: 1080p 30 & nop 1.3.6 Recording Field of View: 110°/85°

Page 25 of 26**EXHIBIT B**

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

**DAVID ARNOLD AND AIRBORNEPICS** only utilizes safe and reliable sUAS. DJI is an industry leader in small UAS production. DJI sUAS are complete with leading edge and proven software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

DJI Inspire 1

1.1 Aircraft
1.1.1 Model -T600 1.1.2 Weight (Battery Included) -6 lbs 7.52910z (2,935g) 1.1.3 Hovering Accuracy (GPS Mode) -Vertical: 0.5m; Horizontal: 2.5m 1.1.4 Max Angular Velocity: Pitch: 300 °/s ; Yaw: 150 °/s 1.1.5 Max Tilt Angle: 35° 1.1.6 Max Ascent Speed: 5m/s 1.1.7 Max Descent Speed: 4m/s 1.1.8 Max Speed: 22m/s (ATTI mode, no wind-NOT RECOMMENDED) 1.1.9 Max Flight Altitude 4,500m MSL
1.1.10 Max Wind Resistance: 10m/s 1.1.11 Max Flight Time -Approximately 18 minutes
1.1.12 Motor Model: DJI 3510 1.1.13 Propeller Model: DJI 1345 1.1.14 Operating Temperature Range: 14 ° F to 104 ° F (-10 ° C to 40°C) 1.1.15
Dimensions 438x451x201 mm 17.25” x 17.76 " x 7.9"
1.2 Gimbal
1.2.1 Model: ZENMUSE X3 1.2.2 Output Power (with camera): Static: 9W; In Motion: 11 W 1.2.3 Operating Current -Static: 750mA; In Motion: 900mA 1.2.4 Angular Vibration Range -±0.03 ° 1.2.5 Mounting -Detachable 1.2.6 Controllable Range: Pitch: -90°to +30°; Pan: ±320°1.2.7 Mechanical Range: Pitch: -125°to +45°; Pan: ±330° 1.2.8 Max Controllable Speed: Pitch: 120°/s; Pan: 180°/s
1.3 Transmitter
1.3.1 Name-CI 1.3.2 Operating Frequency 5.728 to 5.850 GHz; 2.400-2.483GHz 1.3.3 Communicating Distance (unobstructed): 3.1 miles 1.3.4 Output Power -9W 1.3.5 Operating Temperature Range -14°F to 104°F (-10°C to 40°C) 1.3.6 Battery 4,500mAh 2S or optional 5,700mAh LiPo 2S

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