### ProFly Aerial Page 1 March 5, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Re: Request amendment to Exemption 11482 Section 333

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernizati on and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, ProFly Aerial (Unmanned Aerial Imaging and Data Collection), the operator of Unmanned Aircraft System (“UAS”), seeks an exemption from th e Federal Aviation Regulations (“FARs”) listed below.

The Department of Boating and Waterways of Califor nia has a very sensitive issue that needs to be addressed, There is a very invasive species of v egetation known as Water Hyacinth that is clogging Boating waterways, harbors, and water supply channels in Northern California, It is such a problem that it has become a threat security of commercial shipping lanes, a real problem to local commerce harbors and farming water supply. There is no eradication of Water Hyacinth only control the spread by monitoring the growth and spraying herbicides to kill it temporarily until the next growing season. The Department of Boating and Waterways has tasked us to assist them in the tactical response and integration of UAVs in the controllin g Water Hyacinth threatening the infr astructure of the Port of Stockton and the Delta Waterways. With hundreds of miles and thousands of acres of waterway s to monitor this vegetation it is not efficient or cost effective to do so with VLOS at a mile at a time with the vegetation doubling or tripling in mass in 72 hrs.

(1) The requested exemption would permit ProFly Aerial to operate UAS listed in Appendix B (Page 13) BLOS (Beyond Line of Sight), which weighs less than 55 lbs for commercial precision aerial surveys and data collections, via remote sensing and measuring by an instrument(s) aboard the UAS. Examples include imagery (photography, vi deo, infrared, etc.), electronic measurement (precision surveying, RF analysis, LIDAR and etc.)

The operation BLOS would be under 400 Ft. AGL in rural areas over water in sparse concentrations of population. BLOS automated by computer software such as Autoflight’s Autopilot, UgCS or Precisionhawk’s LATAS system. The UAV will be operat ed under controlled condit ions with the guidance of the Pathfinders Program and the NAS.

The UAV uses an onboard camera or other sensors to capture high quality digital images of the surveyed area. Use of the UAV for aerial surveys reduces the need to operate conventional aircraft for the same purpose and provides very high quality imagery at a fraction of the cost. These savings result in enhanced efficiency and productivity for the affected activities, as well as environmental benefits.

Department of Boating and Waterways is responsible for maintaining control of Water Hyacinth in the waterways. This is an aggressive vegetation that ther e is no eradication of this vegetation only controlling the growth during the growing season from March to October doubling in mass every 3 days. Water Hyacinth is clogging the waterways hindering shipping, local commerce in the harbors and water supplies for drinking water and irrigation.

### ProFly Aerial Page 2 (2) The requested exemption would permit ProFly Aerial to operate UAS to conduct commercial agricultural aircraft operations spraying herbici de on the vegetation clogging the waterways.

ProFly Aerial is requesting exemption from the following FAR;

Section 137.19(d) prescribes, in pertinent part, that the applicant for an agricultural aircraft operator certificate must have at least one certificated and airworthy aircraft, equi pped for agricultu ral operation.

Sections 137.19(e)(2)(ii), (iii), and (v) prescribe, in pe rtinent part, the tests of skill for agricultural aircraft operations that must be demonstrated by the applicant in the areas of (ii) approaches to the working area, (iii) flare-outs, and (v) pull ups and turnarounds.

Section 137.31(a) prescribes, in pertinent part, that no person may operate an aircraft unless that aircraft meets the requirements of Sec. 137.19(d).

Section 137.31(b) prescribes, in pertinent part, that no person may operate an aircraft unless that aircraft is equipped with a suitable and properly installe d shoulder harness for use by each pilot.

Section 137.33(a) prescribes, in pertinent part, that no person may operate an aircraft unless a facsimile of the agricultural aircraft operator ce rtificate, under which the operati on is conducted, is carried on that aircraft.

Section 137.42 prescribes, in pertinent part, that no person may operate an aircraft in operations required to be conducted under part 137 without a safety bel t and shoulder harness properly secured about that
person.

ProFly Aerial proposes to operate a UAVs lis ted in Appendix C (Page 13) to conduct commercial agricultural related services in the United States. ProFly Aerial also intends to conduct commercial agricultural UAV operations as described in 14 CFR, part 137. The UAV Sprayer is capable of providing a wide array of essential agricultural spraying servic es, including watering, fertilizers, pesticides, and herbicides. The UAV Sprayer can also be equipped with sensors and equipment to detect and monitor agricultural areas that require irri gation, fertilization, or other treat ments. The UAV is capable of doing these tasks with a greater degree of safety with no over spray of other surrounding agriculture or surrounding homes and people. A UAV can provide a more efficient and better application rate. With the use of a UAV there are no carbon emissions or possibility of fuel contamination.

Operations under the exemption will be subject to strict operating requirement s and conditions to ensure at least an equivalent level of safety to current ly authorized operations using manned aircraft and under conditions as modified by the FAA as required by Section 333.

As described more fully below, the requested exempt ion would authorize commercial agricultural aircraft operations using the UAV, which at under 55 lbs, is small in size

• Operated by an individual who possess a current Commercial Pilot License

• Maximum altitude of 400 Ft. AGL and will normally be flown at altitudes of 20 Ft. AGL or less over that is limited in scope.

• It will have automated control features.

• ProFly Aerial will be offering aer ial spraying operation as a service.

• The airspace in which the UAS will operate will be logged for FAA inspection.

1) Manually - We know doing it manually is slow and time consuming. 2) Tractor - Driving your tracto r to treat the area destroys their crops and compacts the soil. 3) Conventional Aircraft - To treat only 50 acres would be cost prohibitive. 4) UAV - Fully autonomous sprayer. Just keep the tanks filled and the batteries charged. Save time, chemicals and reduce operator exposure. As Ken Giles, U.C. Davis said, 'UAV''s are very specific,

### ProFly Aerial Page 3 very targeted, very precise

. .. And it also allows that chemical to be placed exactly where we want it and just the area that we need it without over spraying adjacent areas.'

ProFly Aerial respectfully submits t hat because this small, unmanned aer ial vehicle will be used in lieu of comparatively hazardou s operations now condu cted with fixed wing and rota ry conventional aircraft, the FAA can have confidence that the operations will achiev e at least an equivalent level or greater level of safety. Approval of this exemption would ther eby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsib ilities under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft systems in the national airspace system.”

The regulations from which the exem ption is requested are as follows:

14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 91.7(b); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a).

Appendix A (Page 6) discusses each rule listed abov e and explains why exemptions pursuant to the proposal set forth in this letter are appropriate, pr ovide an equivalent level of safety, and are in the public interest.

THE APPLICABLE LEGAL STA NDARD UNDER SECTION 333

ProFly Aerial submits that grant of this exemption application for use of the UAV listed in Appendix B (Page 13) will advance the Congressional mandate in Se ction 333 of the Reform Act to accelerate the introduction of UAS’s into the national airspace syst em (“NAS”) if it can be accomplished safely. This law directs the Secretary of Transportation to consider whether certain UASs may operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determi ne which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close prox imity to airports and populated areas;

• Operation of the UAS beyond vis ual line of sight of the operator.

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c).

The Federal Aviation Act expressly grants the FAA t he authority to issue exemptions. This statutory authority, by its terms, in cludes exempting civil aircraft, as the te rm is defined under §40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service:

### ProFly Aerial Page 4 The grant of the requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings associated with transitioning to UAS’s for aerial survey photography and agriculture. Accordingly, the applic ant respectfully requests that the FAA grant the requested exemption without delay as these are services desp erately needed in the California area due to the obstruction of critical infrastructure by this vegetation and the threat to local commerce.

Grant of the exemption to ProFly Aerial will be subj ect to the following mandatory conditions, which are based upon operating conditions set forth for operation of UAS by public entities pursuant to Certificates of Authorization, with additional restrictions:

• All operations to occur in Class G airspace

• Operations to avoid congested or populated ar eas, which are depicted in yellow on VFR charts

• Operations to be conducted over private or controlled-access property

• Permission from land owner/controller required before commencing any flight

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC)

• Operations to occur during daylight hours

• Above Ground Level (AGL) alti tude to be restricted to 400 feet

• All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runway centerline measur ed from runway thresholds

• All required permissions and permits will be obtai ned from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies

Operator Requirements

ProFly Aerial respectfully proposes that operator requirements should take into account the characteristics of the particular UAS. Certain UASs, such as the ProFly Aerial UAVs, are characterized by a high degree of pre-programmed control and va rious built-in technical capabilities that limit the potential for operation outside of t he operating conditions set forth above.

The UAVs has a semi-autonomous navigation and co ntrol system comprised of a Ground Control Station (GCS), GPS stabilization and auto-pilot syst em. In the case of unplanned events, the operator can allow the aircraft to follow the pre-programmed evasive maneuvers from the control unit or enable assisted steering for direct control. Pre-programmed maneuvers include initiation of holding at present position; suspension of mission; fl y back to launch point; fly to point and hold; abort mission and land; and emergency power cut off and land (Flight Termination System).

Additional automated safety functions and safety enhan cing features of the UAVs listed in Appendix B (Page 13) include the following:

• Detection of lost GPS for 2 seconds will initiate a right hand orbit, allowing the operator time to enter “Altitude” control mode. After 20 seconds, if the operator elects to do nothing, the aircraft will begin an auto land.

• If the auto-pilot detects a lost-link to the GCS for longer than 5 seconds, the aircraft will orbit return to the designated “HOME” point, land and shut down.

• Low power on the aircraft triggers an alarm on GCS at 12% (15 minutes left)

• On-board failsafe limits aircraft descent speed to a maximum of approximately 5 m/s

• The aircraft, weighing less than 55 lb s, fully loaded, is constructed of high impact plastic or similar material which is intended to absorb impact energy.

• The motor is driven by a pulse width modulated signal, not an analog signal.

### ProFly Aerial Page 5 In summary, applicant seeks an exemption from t he FARs set forth above and in Appendix A (Page 6) to allow commercial operations of a small unmanned vehicle.

Approval of the exemption allowing commercial o perations of the sUAV listed in Appendix B will enhance safety by reducing risk. Conventional operat ions, using jet or piston-powered aircraft present risks associated with vehicles that weigh in the nei ghborhood of 5,000 to 7,000 lbs, carry large quantities of fuel, passengers, and, in some ca ses, cargo. Such aircraft must fly to and from the survey location. In contrast, a UAV weighing less than 55 lbs and powere d by batteries eliminates a portion of that risk given the reduced mass and lack of combustible fuel carried on board. The UAV is carried to the location, not flown there. The UAV will carry no pass engers or crew and, therefore, will not expose any individuals to the risks associated with manned aircraft flights.

The operation of the UAV, weighing less than 55 lbs, for precision surveys in accordance with the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including exempting Pr oFly Aerial from the requirements of Part 21.

The UAVs satisfaction of the criteria set forth in Section 333 of the Reform Act—size, weight, speed, operating capabilities, lack of proximity to airports and populated areas, operation beyond visual line of sight, and national security—and its showing of an equivalent level of safety as it may relate to the requirement for a pilot’s license, provide more than a dequate justification for the grant of the requested exemptions allowing commercial operation of the lis ted UAVs in Appendix B (Page13) in the commercial operations.

Very truly yours, Pilots

Daniel J. Austin Timothy Nelson CFI # 3189381

Chief Executive Officer at ProFly Aerial Daniel J. Austin CFI # 27223122

6609 Brook Ct.

Fair Oaks, CA 95628

### ProFly Aerial Page 6 APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER
APPLICABLE RULES SUBJECT TO EXEMPTION

ProFly Aerial requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the UAV:

14 C.F.R. § 45.23(b): Marking of the Aircraft

The regulation provides:

When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

The UAV has no entrance to the cabin, cockpit, or pilot station on which the word “provisional” can be placed. Given the size of the UAV, two- inch lettering will be impossible. The “Serial Number” will be placed on the forward fuselage as large as the fuselage will allow in compliance with § 45.29(f).

The equivalent level of safety will be achieved by having the UAV marked on its underside fuselage as required by § 45.29(f) where the pilot, observer, and others working with the UAV
will see the identification of the UAS.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 CFR § 91.203(a)(1)

### ProFly Aerial Page 7 Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a)(1). Given the size of the aircraft (under 55 lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and
Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the UAS involved.

In this case, an analysis of these criteria demonstrates that the UAV operated without an airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The UAV weighs less than 55 lbs. fully loaded. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate exclusively within an area pre-disclosed and in compliance with conditions set forth herein. Operations under this exemption will be tightly controlled and monitored by both the operator, pursuant to the conditions set forth above, and by local public safety requirements. Receipt of the prior permission of the land owner, the size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not flown there all establish the equivalent level of safety. The UAV construction with absorbent material provides at least an equivalent level of safety to that of such operations being conducted with conventional aircraft that would be orders-of-magnitude larger and would be carrying passengers, cargo, and flammable fuel.

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the UAV without an airworthiness certificate, no standard will exist for airworthiness of the UAV. Given the size of the aircraft and the requirements that have already been met with the aircraft’s COA approval and military history, an equivalent level of safety will be achieved by ensuring compliance with the ProFly Aerial manuals prior to each flight.

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

### ProFly Aerial Page 8 The regulation provides:

No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

Given the size and configuration of the UAV, it has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be achieved by keeping the flight manual (see Attachment 1) at the ground control point where the pilot flying the UAS will have immediate access to it. The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide that no person ma y operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. The UAV is a remotely piloted aircra ft and by design, does not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for oper ation of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the

### ProFly Aerial Page 9 surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the UAV will never operate at higher than 400 feet AGL. It will, however, be operated to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. Because aerial survey work must be accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed.

The equivalent level of safety will be achieved given the size, weight, speed, and material with which the UAV is built. Also, no flight will be taken without the permission of the land owner or those who control the land. Because of the advance notice to the landowner, all affected individuals will be aware of the survey flights. Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far more than 55 lbs. and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the low-altitude operations of the UAS will maintain separation between these small-UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

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

This regulation 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; or (2) At night, to fly after that for at least 45 minutes.”

The UAV batteries provide approximately 25 minutes of powered flight. Without an exemption from § 14 CFR 91.151, the limitations proposed would greatly reduce its utility. Given the type of operation, as well as the rural location of those proposed operations, a longer time frame for flight in daylight VFR conditions is reas onable. Additionally, given the proposed VLOS restriction, the aircraft would always be well within 5 minutes of its landing position. Furthermore, in the unlikely event that the UAV should run out of fuel before returning, it would simply automatically land at its current position at a safe speed. Finally, recognizing its weight and construction material, the risks are less th an contemplated by the current regulation.

ProFly Aerial believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate

### ProFly Aerial Page 10 without compliance with 91.151(a)). Operating the small UAS, without 30 minutes of reserve fuel does not engender the type of risks that Sect ion 91.151(a) was meant to prevent given the size and speed at which the UAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its safety.

ProFly Aerial believes that an equivalent level of safety can be achieved by maintaining 10 minutes of reserve fuel, which would be more than adequate to return the UAS to its planned landing zone from anywhere in its operating area.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration1

This regulation provides as follows:

(a) . . . no person may operate a civil aircraft unless it has . . . an appropriate
and current airworthiness certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAV fully loaded weighs no more than 55 lbs. As such, there is no ability or place to carry certification and registration documents or to display them on the UAS. In addition, there is no pilot on board the aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation. A repr esentative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

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

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter . . . .” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service.

### ProFly Aerial Page 11 Maintenance of the UAV components outlined in the manual will be accomplished by a trained and certified Pro Fly Drones technician. An equivalent level of safety will be achieved because the UAS is small in size, will carry no exte rnal payload, will operate only in restricted predetermined areas and is not a complex mechanical device. As provided in the UAV Checklist (Attachment 1), the operator of UAV will also ensure that the UAS is in working order prior to initiating flight, and keep a log of any maintenance that is performed on the aircraft. Moreover, the operator is the person most familiar with the aircraft and is best suited to ensure that the aircraft is in an airworthy condition and to guarantee an equivalent level of safety.

ProFly Aerial will be putting our UAV aircraft through a routine, but rigorous, inspection of the airframe and components every 50 flights. Likewise, we will replace the servos, motor, and speed controller every 300 flights. This will ensure an equivalent level of safety to the maintenance requirements in Part 91.

APPENDIX A: SUMMARY OF PROFLY AERIAL SECTION 333 EXEMPTION REQUEST

ProFly Aerial hereby provides pursuant to Part 11 a summary of its exemption application to allow commercial operation of the UAV unmanned aircraft in precision aerial survey and agriculture work. An exemption is requested from the following regulations:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) & (b);

14 C.F.R. 61.133(a);

14 C.F.R. 91.7(b);

14 C.F.R. 91.9(b)(2);

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);



### 14 C.F.R. 91.417(a).

### ProFly Aerial Page 12

### ProFly Aerial Page 13 

## Appendix B

ProFly Aerial requests that the FAA accept the sUAS listed to ProFly Aerial’s Exemption allowing operation as set forth therein.

Aircraft

DJI Technology Co., Ltd Inspire 1

DJI Technology Co., Ltd Matrice 100

DJI Technology Co., Ltd Phantom 2

DJI Technology Co., Ltd Phantom 3

DJI Technology Co., Ltd S1000

Freefly Systems Alta

Sensfly Ltd. Ebee

XactSense XS-MAX8-PXHK V1.2

PrecisionHawk Lancaster UAV



## Appendix C

DJI Technology Co., Ltd Agras MG-1

Homeland Surveillance & Electronics LLC AG-VA Sprayer

Pulse Aerospace, llc. VAPOR 55