July 30, 2015 

U.S. Department of Transportation, 

Docket Operations 

West Building, Ground Floor, Room 

W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Request for exemption from multiple regulatory provisions to allow the use of 

small unmanned aerial systems on land controlled by The Kansas City Southern 

Railway Company to assist in the safe evaluation of railroad infrastructure and 

operations, based on Exemption No. 11206 granted to BNSF Railway. 

Dear Sir or Madam: 

The Kansas City Southern Railway Company (KCS) respectfully requests an 

exemption from several provisions of Title 14 of the Code of Federal Regulations 

(C.F.R.) to permit the use of small unmanned aerial systems (sUAS) to assist in the 

evaluation of railroad infrastructure and operations. This request is motivated primarily 

by the desire to maximize safety in railroad operations. While an exemption would not 

eliminate the current need for in-person visual track inspection required by the Federal 

Railroad Administration, it would allow KCS to broadly evaluate assets and operations 

with sUAS, resulting in a safer and more efficient railroad network. Accordingly, the 

grant of an exemption is consistent with Congress' intent, reflected in Section 333 of the 

FAA Modernization and Reform Act of 2012 (Modernization Act), that safe systems be 

permitted in the national airspace prior to the issuance of final regulations governing 

general use of these systems. A summary of this request suitable for publication in the 

Federal Register is provided as Appendix A. 

Background Information 

KCS is a Class I freight railroad, as defined by the Surface Transportation Board. 

See 49 C.F.R. Part 1201. The current KCS rail system is the product of almost 100 

different railroads, which were merged or acquired over nearly 150 years. KCS 

conducts railroad operations in 10 states on more than 3000 miles of rail. The KCS rail 

network includes 1 ,300 bridges and more than 3,800 grade crossings. KCS either owns 

or possesses exclusive easements for the land over which it operates and has sole 

possessory rights to this land. 

427 W. 12'h Street, 411' Floor • Cathedra l Square • Kansas City, Missouri 64105 
and coal. KCS also moves categories offreight that are vital to communities across the 

United States. Given the volume and diversity of freight moved on the KCS network, 

any disruptions or delays - due to mudslides, derailments, floods, or the like - can have 

serious consequences for shippers and the general public. Accordingly, KCS invests 

enormous resources to ensure the safety and viability of its rail system. 

Indeed, nothing is more important to KCS than safety. KCS is constantly 

exploring additional ways in which it can improve safety for its 6,500 employees, its 

customers, and the public. KCS works hard and invests substantial resources to reduce 

the risk of grade-crossing incidents to protect its employees as well as the traveling 

public. 

Regulatory Basis for Exemption Request 

In addition to the waiver authority provided in §333 of the Modernization Act, the 

FAA may grant an exemption under 49 U.S.C. §44701 (f) if it has determined that such 

an exemption is in the public interest. The FAA has imposed a separate requirement in 

its procedural regulations, providing that the petitioner shall explain why granting the 

exemption would not adversely affect safety or how the exemption would provide at 

least an equivalent level of safety as compliance with the underlying regulation. In this 

case, approval of this exemption would advance the public interest by significantly 

enhancing the safety and efficiency of rail operations and by providing the FAA with 

valuable user experience on sUAS in a context with appreciable economic and societal 

benefits. As described more fully below, the requested exemption would permit the 

operation of sUAS under tightly controlled conditions, thus ensuring that operations will 

not have an adverse impact on safety. To the contrary, as explained below, KCS 

anticipates that use of sUAS will enhance safety in railroad operations. 

Granting an Exemption is in the Public Interest 

The safety and efficiency of railroad operations is heavily dependent upon 

constant analysis of trains, right-of-way, rail track, and other assets/facilities. There are 

a wide variety of factors that can affect track conditions and cause problems for trains. 

Even relatively small objects on the rails or minor track failures can lead to derailments 

or other incidents. Extreme weather events can lead to track flooding or overheating 

(track can buckle or distort in high heat). Earthquakes, landslides, and abandoned 

vehicles at grade crossings can block track. The potential for sabotage and terrorism, or 

even just trespassing, are also among the many risks that modern railroads face. 

Vigilance is always the best defense against these hazards. 

427 W. 12'" Street, 411' Floor • Cathedral Square • Ka nsas City, Missouri 64 105 

2 
rail equipment, or in rail-mounted hi

rail vehicles. This is often a labor

intensive and 

sometimes arduous job. While the railroad does all it can to make these inspections as 

safe as possible, there is an irreducible element of risk involved whenever employees 

are required to go out on track and rail structures. Employees may need to climb over or 

onto track structures, which can be slippery, rough, and/or exposed to the elements. 

Some structures, such as bridges, are high above the ground. Trains moving through 

inspection zones can increase risk as well, especially in high-traffic areas. While the use 

of sUAS for supplemental track, infrastructure, and general asset evaluation would not 

eliminate these risks entirely (as it is an additive safety measure), it would reduce the 

risks to railroad employees by allowing for remote aerial review. 

Additionally, the sheer amount of KCS assets and the widely dispersed locations 

(in many instances far from sizeable population centers) means that visual inspection in 

all instances by company personnel can be inefficient. Aerial analysis by traditional 

fixed wing aircraft is impractical because the required altitudes for safe flight reduce 

track visibility below meaningful levels. It is simply not possible to see all asset 

anomalies from such heights. By using sUAS for supplemental asset evaluation, KCS 

will be able to substantially upgrade its capacity to detect and address issues with the 

right-of-way and other assets before they become a problem for train operations. Thus, 

the use of sUAS has the potential to improve efficiency, resulting in faster and safer 

delivery of goods vital to the U.S. economy 

Granting an Exemption will not Adversely Affect Safety 

KCS notes that there is no applicable standard for an equivalency determination. 

Some have argued that the appropriate standard is that for model aircraft, noting that 

their operations, if conducted for recreational purposes, would fall completely within the 

allowable operations for model aircraft. We believe it is difficult to argue that there is 

sufficient correlation between model operations controlled by the Academy of Model 

Aeronautics and the ones contemplated by KCS. At the same time, it is clear that 

equivalency cannot be established for traditional, manned civil aircraft because the 

design and use profiles between traditional aircraft and sUAS are simply too different. 

As such, we believe it makes more sense to focus on why the contemplated operations 

would not adversely affect safety, which is all that §11.81 (e) requires. 

Granting an exemption will not adversely affect safety. KCS contemplates 

conducting sUAS operations over KCS owned or controlled land, solely during daylight 

hours, at altitudes well below that which would pose a risk to other aircraft. In general, 

sUAS operations are intended to be conducted in areas distant from both congested 

areas and airports. Moreover, because of the inherent risks presented by standard train 

427 W. l2'h Street, 4'h Floor o Cathedral Square o Ka nsas City, Missouri 64105 

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the sUAS be flown at relatively low altitudes and relatively low speeds. KCS expects 

that in most instances, the sUAS will be flown less than 75 feet from the highest 

structure along the path of the sUAS. Accordingly, the risk of interference with another 

aircraft is minimal. KCS also plans to conduct sUAS operations at least three miles 

from any public airports (including heliports). In the event an operation needs to be 

conducted closer to an airport, KCS will inform the airport operator and airport air traffic 

control tower of the contemplated operation and will comply with any directions issued 

by air traffic control at that airport. 

KCS initially intends to use a dedicated person for sUAS operations. All 

operations will be within visual line-of-sight (i.e., no more than approximately 0.5 miles 

from the manipulator of the controls, or pilot in command (PIC). The PIC will have a 

private pilot's license and a valid third-class medical certificate. Each PIC will conduct 

at least three take-offs and landings with the sUAS on which he or she is trained every 

90 days. Depending on the type of operation, additional ground-based visual observers 

may be employed as well. These observers will be within constant visual line of sight 

and in constant contact with the PIC. The visual observers will assist the PIC in avoiding 

objects near the sUAS. 

KCS intends to use the DJI Phantom 3 in its sUAS operations, a description of 

which is attached as Appendix B. 

Support for Petition for Exemption 

In accordance with the procedural requirements of 14 C.F.R. §11.81, KCS 

provides the following information: 

Contact Information 

Mark Nolte, Real Estate Manager 

The Kansas City Southern Railway Company 

427 West 121h Street 

Kansas City, MO 64105 (816)-983-1270 

MNolte@KCSouthern.com 

Regulatory Provisions from which KCS seeks an Exemption 

KCS believes it may need an exemption from the following provisions to conduct 

the contemplated operations. In some instances, relief is needed because relief from 

another provision renders compliance with the regulation at hand infeasible. 

427 W. 12'" Street, 4'" Floor • Cathedral Square • Ka nsas City, Missouri 64105 

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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 

14 C.F.R. §91.203(a) and (b) 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a) 

KCS believes an exemption is only needed from the above-listed regulatory 

provisions. 

To the extent that the FAA believes that additional relief is required for KCS to 

conduct the operations described here, we request an exemption from any such 

regulatory provisions as well. 

The Extent of Requested Relief and the Reasons Relief is Needed 

14 C.F.R. §61.113(a) and (b) 

§61.113 Private pilot privileges and limitations: Pilot in command. 

(a) Except as provided in paragraphs (b) through (h) of this section, no person who 

holds a private pilot certificate may act as pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, 

for compensation or hire, act as pilot in command of an aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command 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. 

KCS anticipates initially using one trained staff member to conduct the sUAS 

operations. While this individual will have a private pilot license, he will not hold a 

commercial pilot license. The sUAS will not carry property for compensation or hire 

since they will be used solely to assist in evaluation of the railway, trains, right-of-way, 

427 W. 12'h Street, 4'h Floor • Cathed ra l Square • Kansas City, Misso uri 64105 

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certificate under §61.133. However, the risk associated with the contemplated 

operations is less than the risk posed by a traditional aircraft. The sUAS will fly at 

altitudes well below the permissible limits for other civil aircraft, eliminating the risk to 

other aircraft, and within a geographical envelope under the sole control of KCS. 

Accordingly, the risk would be limited to KCS personnel, who will be appropriately 

outfitted in safety gear, and KCS property on the ground. Requiring a commercial pilot 

certificate would provide no appreciable safety benefit and would needlessly impose 

additional cost on KCS. Because the contemplated operations would not comply with 

§61 .113(b )(1) and none of the other exceptions to paragraph (a) apply, relief is needed 

from both paragraphs (a) and (b). 

14 C.F.R. 91.7(a) 

§91.7 Civil aircraft airworthiness. 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. The 

pilot in command of a civil aircraft is responsible for determining whether that 

aircraft is in condition for safe flight. The pilot in command shall discontinue the 

flight when unairworthy mechanical, electrical, or structural conditions occur. 

There is no clear definition of "airworthy," and the term has been defined in 

various ways depending on the circumstances. In all instances, it appears that the 

concept includes a requirement that the airplane 1) conforms to the aircraft's type 

design or its type certificate, as modified by supplemental type certificates and 

airworthiness directives, and 2) be in condition for safe operations. The sUAS will not 

have a type design or type certificate, as the FAA has not developed standards 

applicable to sUAS. As discussed later in this document, the types of operations 

contemplated by KCS will not qualify the sUAS for an experimental airworthiness 

certificate. Accordingly, relief from §91.7(a) is required . Should the FAA include 

airworthiness requirements as a condition of exercising the exemption, KCS will assure 

the continued airworthiness of the sUAS. Regardless, KCS believes that it can meet 

the requirements of §91. ?(b) and is not requesting an exemption from that provision. 

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

§91.9 Civil aircraft flight manual, marking, and placard requirements. 

*** 

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

*** 

427 W. 12'" Street, 4'" Floor • Cn thcdrnl Square • Knnsns City, Missouri 64105 

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The sUAS comes with access to online manuals that provide instructions for the 

safe operation and maintenance of the aircraft. Compliance with this regulatory 

provision is not possible because this information has not been, and cannot be, 

approved by the FAA since there are no applicable standards established by the FAA 

against which to evaluate it. Additionally, the sUAS is too small to carry a printed 

manual. Since, by definition, there will never be a person aboard the sUAS, KCS 

submits that there is no need to require the manual to be placed on the sUAS and an 

exemption is appropriate. Safety will be maintained by keeping the flight manual at the 

ground control point where the PIC will have immediate access to it. 

14 C.F.R. 91.109 

§91.1 09 Flight instruction; Simulated instrument flight and certain flight tests. 

(a) No person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual 

controls . . . Small UASs, by their design, do 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. 

14.F.R. 91.119 

§91.119 Minimum safe altitudes: General. 

Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: 

  

(c) Over other than congested areas. An altitude of 500 feet above the 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. 

** *** 

KCS submits that the only relief it requires from §91.119 is from the minimum 

altitudes listed in paragraph (c). Relief is required from paragraph (c) for fixed wing 

operations because asset evaluation conducted at 500 feet or higher is insufficiently 

distinct to be meaningful. Since operations at this altitude also pose a heightened risk of 

collision with another aircraft, safety can only be assured through the grant of an 

exemption. The anticipated rotorcraft operations should be adequately addressed by 

427 W. 1211' Street, 4'" Floor • Cnthedrnl Square • Knnsns City, Misso uri 64105 

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the sUAS will be operated, and public access is restricted. It also has exclusive use of 

significant portions of land adjacent to the track, trains, and structures that will be the 

objects of evaluation and analysis. We tightly control access to our land and have the 

ability to assure that no individuals unassociated with the planned operations are on the 

affected land. KCS personnel are already required to wear mandatory safety equipment, 

including hard hats, safety glasses, and steel-toe boots whenever dispatched to a work 

site. As such, the risk of injury is minimal. 

KCS does not contemplate conducting operations over congested areas, so relief 

is not requested from paragraph (b). 

14 C.F.R. 91.151 

§91.151 Fuel requirements for flight in VFR conditions. 

(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. 

(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. 

Operating the sUAS in a pre-defined area with less than 30 minutes of reserve 

fuel does not raise the type of risk contemplated by §91.151, i.e., that an aircraft could 

run out of fuel in the event it has to be flown to an alternate airport or circle the planned 

airport in the event of unanticipated conditions. KCS does not intend to use the sUAS 

for point-to-point flights and will not operate the sUAS beyond visual line of sight. Nor 

will the sUAS require an airport in order to land. Rather, KCS will operate the sUAS 

using pre-planned flight paths (taking into account weather conditions) designed to 

allow the sUAS to fly to the point of intended landing. As such, there is no need for a 

time-based excess fuel requirement. Rather it should be sufficient to require only as 

much additional excess flight capacity as necessary to safely land the sUAS. We 

believe that a 20% battery reserve is more than sufficient to meet this objective. 

14 C.F.R. 91.203(a) and (b) 

§ 91.203 Civil Aircraft: Certifications required. 

427 ·w. 121h Street, 411' Floor • Cathedral Square • Kansas City, Missouri 64105 

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(2) An effective U.S. registration certificate issued to its owner or, for operations 

within the United States, the second copy of the Aircraft Registration 

Application as provided for in §47.31(c), or a registration certification issued 

under the laws of a foreign country. 

(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 sUAS that KCS intends to operate will not qualify for an airworthiness 

certificate unless the FAA chooses to issue them a restricted category certificate. This is 

because the sUAS do not meet the current conditions for either a standard 

airworthiness certificate or an experimental airworthiness certificate. Notably, under 14 

C.F.R. §21.191, experimental airworthiness certificates are only available for research 

and development, showing compliance with regulations, crew training, exhibitions, air 

racing, market surveys, operating amateur-built aircraft, operating primary kit-built 

aircraft, and operating light-sport aircraft. Until such time as the FAA develops 

airworthiness standards applicable to sUAS for non-recreational and non-experimental 

use, KCS submits that the FAA should consider exemptions to the requirements of 

§91.203(a). The absence of such exemptions hinders the development of sUAS and 

applicable uniform standards since it is only through the development of the aircraft that 

the FAA can reliably evaluate them and determine appropriate design standards. 

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from 

the requirement for an airworthiness certificate based on a consideration of the size, 

weight, speed, operational capability of the particular UAS, as well as its proximity to 

airports and populated areas. An analysis of these criteria demonstrates that the sUAS 

operated without an airworthiness certificate in the areas and under the conditions 

contemplated by KCS will be at least as safe, or safer, than a conventional aircraft (fixed 

wing or rotorcraft) operating with an airworthiness certificate without the conditions 

proposed in this request. The sUAS is less than 55 lbs. fully loaded and carries neither 

a pilot nor passenger. Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by the operator and observer. Operations will be 

conducted in compliance with the FAA and with local public safety requirements to 

provide security for the area of operation as is now done with conventional train, track, 

bridge, and out building evaluation. These safety enhancements provide an expanded 

degree of safety to the railway inspectors over conventional operations. Lastly, 

427 \V. 1211' Street, 4'" Floor • Ca thedral Square • Kansas City, Missouri 64105 

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If the FAA waives the requirements of paragraph (a) (1 ), then it is technically 

impossible to comply with paragraph (b), so an exemption is merited there as well. 

14 C.F.R. 91.405(a), 91.407(a) (1) and 14 C.F.R. 91.409(a) 

§91.405 Maintenance required. 

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; 

***** 

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or 

alteration. 

(a) No person may operate any aircraft that has undergone 

maintenance, rebuilding, or alteration unless-

(1) It has been approved for return to service by a person authorized under 

§43. 7 of this chapter; 

***** 

§91.409 Inspections. 

(a) 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. 

***** 

KCS believes that an exemption from these three maintenance requirements is 

appropriate because the FAA has not developed maintenance standards that would allow an operator to meet the part 91 maintenance requirements. In particular, there are 

no individuals authorized by the FAA to approve a sUAS for return to service under 

§91.407(a) or to conduct the initial airworthiness and annual return to service 

inspections required by §91.409(a). KCS will maintain the aircraft as instructed in the 

427 W. 12'" Street, 411' Floor • Cnthcdrnl Square • Knnsns City, Missouri 64105 

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Please do not hesitate to contact me at the phone number or via the e-mail 

address provided above should you have any questions or concerns. 

Respectfully submitted, ~tv~ 

Mark W. Nolte 

Real Estate Manager 

enclosures 

427 W. 1211 ' Street, 411' Floor • Cathedral Square • Kansas City, Missouri 64105 

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Federal Register should the FAA determine that publication is needed. 

Petitioner: Kansas City Southern Railway Company (KCS) 

Sections of 14 C.F.R. Affected: 

14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §91. 7(a) 14 C.F.R. §91.9(b) (2) 14 C.F.R. §91.1 09(a) 14C.F.R. §91.119 14 C.F.R. §91 .151 

14 C.F.R. §91.203(a) and (b) 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a) 

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. 

§§45.29, 61.113(a)&(b), 91.7(a), 91.9(b)(2), 91.119, 91.121(a), 91.151, 91.203(a) &(b), 

91.405(a), 91.407(a), and 91.409(a) to conduct sUAS operations over KCS owned or 

controlled land, solely during daylight hours, to assist in the safe evaluation and analysis 

of railroad infrastructure and operations. In general, sUAS operations are intended to 

be conducted in areas remote from both congested areas and airports. The nature of 

operations anticipated by KCS requires that the sUAS be flown at relatively low 

altitudes. KCS expects that in most instances, the sUAS will be flown less than 75 feet 

from the highest structure along the path of the sUAS and in no instances will be flown 

higher than 400 feet above the ground. Accordingly, the risk of interference with other 

aircraft is minimal. 

427 W. 12'" Street, 41" Floor • Cathedral Squm·e • Kansas City, Missouri 64105 

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Aircraft 

Camera 

1280 g 

Diagonal Size (Including Propellers) 

590 mm 

Max Ascent Speed 

5 m/s 

Max Descent Speed 

3 m/s 

Hover Accuracy 

Vertical: +/- 0.1 m (when Vision Positioning is active) or+/- 0.5 m 

Horizontal: +/- 1.5 m 

Max Speed 

16 m/s (A TTl mode, no wind) 

Max Altitude Above Sea Level 

6000 m 

Operating Temperatnre 

ooc to 40°C 

GPS Mode 

GPS/GLONASS 

Sensor 

Sony EXMOR 1 /2.3" Effective pixels: 12.4 M (total pixels: 12.76 M) 

Lens 

FOV 94° 20 mm (35 mm format equivalent) f/2.8, focu s at oo 

ISO Range 

100-3200 (video) 100-1600 (photo) 

Shutter Spee.d 

8s -1/8000s 

Image Max Size 

4000 X 3000 

Still Photography Modes 

Single Shot 

Burst Shooting: 3/5/7 shots 

Auto Exposure Bracketing (AEB): 3/5 

Bracketed Frames at 0.7EV Bias 

Time-lapse 

Video Recording Modes 

Phantom 3 Professional 

UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 

427 W. 12'" Street, 4'" Floor • Cathedral Square • Kansas City, Missoul"i 64105 

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Gimbal 

Vision Positioning 

Remote Controller 

FHD: 1920x1 080p 24/25/30/48/50/60 

HD: 1280x720p 24/25/30/48/50/60 

Supported SD Card Types 

Micro SD Max capacity: 64 GB. Class 10 or UHS-1 rating required 

Max Bitrate Of Video Storage 

Phantom 3 Professional 

60 Mbps 

Phantom 3 Advanced 

40 Mbps 

Supported File Formats 

FAT32/exFAT 

Photo: JPEG, DNG 

Video: MP4, MOV (MPEG-4 AVC/H.264) 

Operating Temperature 

ooc to 40°C 

Controllable Range 

Pitch -90° to +30° 

Stabilization 

3-axis (pitch, roll, yaw) 

Max Velocity 

Less than 8 m/s (when 2m above ground) 

Altitude Range 

30 cm-300 em 

Operating Range 

30 cm-300 em 

Operating Environment 

Surface with clear pattern and adequate lighting (Lux > 15) 

Operating Frequency 

2.400 GHz-2.483 GHz 

Max Distance 

2000m (outdoors and unobstructed) 

Video Output Port 

USB 

Operating Temperature 

427 W. 12'" Street, 4'" Floor • Cathedral Square • Kansas City, Missouri 64105 

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Battery Charger 

Intelligent Flight Battery 

Receiver Sensitivity (1 %PER) 

-101 dBm ±2 dBm Transmitter Power (EIRP) 

FCC: 20 dBm 

CE: 16 dBm 

Working Voltage 

1.2A@7.4V 

Voltage 

17.4 v 

Rated Power Phantom 3 Professional 

100 w 

Phantom 3 Advanced 

57W 

Capacity 

4480 mAh 

Voltage 

15.2 v 

Battery Type 

LiPo 4S 

Energy 

68Wh 

Net Weight 

365 g 

Max Flight Time 

Approximately 23 minutes 

Operating Temperature 

-1 ooc to 40°C 

Max Charging Power 

100W 

427 W. 12'" Street, 4'" Floor • Cathedral Square • Kansas City, Missouri 64105 

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