### THE 

### KANSAS

CI Y SOUTHERN RAILWAY 

### COMPANY MAILING AODAESS:

P 0 BOX

2 1 9335

• KANSAS

C

I TY MO 64

1 2Hl335 July 30, 2015 U.S. Department

of Transportation, Docket Operations West Building, Ground Floor, Room W12

- 140 1200 New Jersey Avenue,

S E Washington

, DC 20590

W"''W.kC!!jO

Ut he

r n

. com MARK W. NOLT
E Real
E state Manager 8 1 6-983-1270 (Direct) 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

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e • Ka n s a s Cit y, M
i sso uri 64 10 5Hundreds

of shippers use the KCS system every day. The railroad moves thousands

of car loads every year, including agricultural products, consumer products (intermodal containers), industrial products (such as crude oil, stone

, and chemicals) 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.

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e • Ka n sas Cit y, M i ss ouri 64 10 5 2As a result, pursuant

to F RA regulations and company policy, KCS track and bridge maintenance employees routinely inspect the tracks and the underlying infrastructure, such as bridges, tunnels

, support structures, and signals.
At present, this work
is done primarily
by company personnel

in motor vehicles,
on foot,
in specialized rail equipment,

or in rail

- mounted hi-rail vehicles. This
is often

a labor

- intens

i ve 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.

E mployees 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, espec

i ally 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 4 27 W. l2' h S tre e t, 4' h Floor

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6 4 10 5 3operations, KCS has already taken steps to secure
its property against unauthorized public access. For example

, substantial stretches

of KCS's track are fenced, elevated, or otherwise secured

to prevent access. Other long stretches

of track are, as noted above,

in very remote areas. The nature
of operations anticipated

by KCS requires that 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 12
1 h 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.

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6 4 10 5 414 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. §91.109(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 limitation

s : P ilot 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

, 4 27 W

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6 4 10 5 5assets, bridges, tunnels and out

- buildings

in furtherance

of KCS's primary business, the successful operation

of a railroad; however, the employees' operation

of the sUAS will not be incidental

to their employment with KCS

, and they will be compensated

for such work. Without
an exemption

, the pilot would be required

to hold
a commercial pilot 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 pl a c a rd
r e quirement

s . *** (b) No person may operate

a U.S.

- registered civil aircraft- ***

427 W

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i ss ouri 64 10 5 6(2) F or which an Airplane
or Rotorcraft

F light Manual

is not required
by §21.5 of this chapter unless there

is available

in the aircraft

a current, approved manual material

, markings, and placards,
or any combination thereof. ***** 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;

S imulated

in s trument flight and certain flight

t e st s . (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:

G ener
a l. 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

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(d) (1 ). Additionally, relief should not be needed from paragraph
(a) because an emergency landing
of the aircraft due to a power failure will not create an undue hazard
to persons
or property
on the surface. As noted

in the explanation

of why an exemption will not adversely affect safety, KCS has exclusive use of the land over which 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. 4 2 7


### · w . 1 2 1 h S treet

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S quar

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s ouri 64105 8(a) E xcept as provided

in §91.715

, no person may operate

a civil aircraft unless

it has within

it the following: (1) An appropriate and current airworthiness certificate. *** (2) An effective U.S. registration certi

f icate 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

l bs. 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

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i sso uri 64 10 5 9applicationofthesesamecriteriademonstratesthatthereisnocrediblethreattonationalsecurityposedbythesUAS,duetoitssize,speedofoperation,locationofoperation,lackofexplosivematerials,andinabilitytocarryasubstantialexternalload.IftheFAAwaivestherequirementsofparagraph(a)(1),thenitistechnicallyimpossibletocomplywithparagraph(b),soanexemptionismeritedthereaswell.14C.F.R.91.405(a),91.407(a)(1)and14C.F.R.91.409(a)§91.405Maintenancerequired.Eachowneroroperatorofanaircraft-(a)ShallhavethataircraftinspectedasprescribedinsubpartEofthispartandshallbetweenrequiredinspections,exceptasprovidedinparagraph(c)ofthissection,havediscrepanciesrepairedasprescribedinpart43ofthischapter;*****§91.407Operationaftermaintenance,preventivemaintenance,rebuilding,oralteration.(a)Nopersonmayoperateanyaircraftthathasundergonemaintenance,rebuilding,oralterationunless-(1)Ithasbeenapprovedforreturntoservicebyapersonauthorizedunder§43.7ofthischapter;*****§91.409Inspections.(a)Exceptasprovidedinparagraph(c)ofthissection,nopersonmayoperateanaircraftunless,withinthepreceding12calendarmonths,ithashad(1)Anannualinspectioninaccordancewithpart43ofthischapterandhasbeenapprovedforreturntoservicebyapersonauthorizedby§43.7ofthischapter;or(2)Aninspectionfortheissuanceofanairworthinesscertificateinaccordancewithpart21ofthischapter.*****KCSbelievesthatanexemptionfromthesethreemaintenancerequirementsisappropriatebecausetheFAAhasnotdevelopedmaintenancestandardsthatwouldallowanoperatortomeetthepart91maintenancerequirements.Inparticular,therearenoindividualsauthorizedbytheFAAtoapprove asUASforreturntoserviceunder§91.407(a)ortoconducttheinitialairworthinessandannualreturntoserviceinspectionsrequiredby§91.409(a).KCSwillmaintaintheaircraftasinstructedinthe427W.12'"Street,411'Floor•CnthcdrnlSquare•KnnsnsCity,Missouri6410510owner's manual and will not operate the aircraft until

it has reasonably determined that any needed repairs have been made. However, because

of the technical impossibility

of meeting the requirements

of §§91.405(a), 407(a), and 409(a), we believe an exemption from these provisions

is appropriate. 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

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• Kansas City

, Missouri 64105 11AppendixASummaryforFederalRegisterPublicationPursuantto14C.F.R.Part11,thefollowingsummaryisprovidedforpublicationintheFederalRegistershouldtheFAAdeterminethatpublicationisneeded.Petitioner:KansasCitySouthernRailwayCompany(KCS)Sectionsof14C.F.R.Affected:14C.F.R.§61.113(a)and(b)14C.F.R.§91.7(a)14C.F.R.§91.9(b)(2)14C.F.R.§91.109(a)14C.F.R.§91.11914C.F.R.§91.15114C.F.R.§91.203(a)and(b)14C.F.R.§91.405(a)14C.F.R.§91.407(a)14C.F.R.§91.409(a)DescriptionofReliefSought:Petitionerseeksrelieffromtherequirementsof14C.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),and91.409(a)toconductsUASoperationsoverKCSownedorcontrolledland,solelyduringdaylighthours,toassistinthesafeevaluationandanalysisofrailroadinfrastructureandoperations.Ingeneral,sUASoperationsareintendedtobeconductedinareasremotefrombothcongestedareasandairports.ThenatureofoperationsanticipatedbyKCSrequiresthatthesUASbeflownatrelativelylowaltitudes.KCSexpectsthatinmostinstances,thesUASwillbeflownlessthan75feetfromthehigheststructurealongthepathofthesUASandinnoinstanceswillbeflownhigherthan400feetabovetheground.Accordingly,theriskofinterferencewithotheraircraftisminimal.427W.12'"Street,41"Floor•CathedralSqum·e•KansasCity,Missouri6410512AircraftCameraAppendixBDJIPhantom3SpecificationsWeight(IncludingBatteryAndPropellers)1280gDiagonalSize(IncludingPropellers)590mmMaxAscentSpeed5m/sMaxDescentSpeed3m/sHoverAccuracyVertical:+/-0.1m(whenVisionPositioningisactive)or+/-0.5mHorizontal:+/-1.5mMaxSpeed16m/s(ATTlmode,nowind)MaxAltitudeAboveSeaLevel6000mOperatingTemperatnreoocto40°CGPSModeGPS/GLONASSSensorSonyEXMOR1/2.3"Effectivepixels:12.4M(totalpixels:12.76M)LensFOV94°20mm(35mmformatequivalent)f/2.8,focusatooISORange100-3200(video)100-1600(photo)ShutterSpee.d8s-1/8000sImageMaxSize4000X3000StillPhotographyModesSingleShotBurstShooting:3/5/7shotsAutoExposureBracketing(AEB):3/5BracketedFramesat0.7EVBiasTime-lapseVideoRecordingModesPhantom3ProfessionalUHD:4096x2160p24/25,3840x2160p24/25/30427W.12'"Street,4'"Floor•CathedralSquare•KansasCity,Missoul"i6410513GimbalVisionPositioningRemoteControllerFHD:1920x1080p24/25/30/48/50/60HD:1280x720p24/25/30/48/50/60Phantom3AdvancedFHD:1920x1080p24/25/30/48/50/60HD:1280x720p24/25/30/48/50/60SupportedSDCardTypesMicroSDMaxcapacity:64GB.Class10orUHS-1ratingrequiredMaxBitrateOfVideoStoragePhantom3Professional60MbpsPhantom3Advanced40MbpsSupportedFileFormatsFAT32/exFATPhoto:JPEG,DNGVideo:MP4,MOV(MPEG-4AVC/H.264)OperatingTemperatureoocto40°CControllableRangePitch-90°to+30°Stabilization3-axis(pitch,roll,yaw)MaxVelocityLessthan8m/s(when2maboveground)AltitudeRange30cm-300emOperatingRange30cm-300emOperatingEnvironmentSurfacewithclearpatternandadequatelighting(Lux>15)OperatingFrequency2.400GHz-2.483GHzMaxDistance2000m(outdoorsandunobstructed)VideoOutputPortUSBOperatingTemperature427W.12'"Street,4'"Floor•CathedralSquare•KansasCity,Missouri6410514BatteryChargerIntelligentFlightBatteryooc-40°CBattery6000mAhLiPo2SMobileDeviceHolderFortabletorphoneReceiverSensitivity(1%PER)-101dBm±2dBmTransmitterPower(EIRP)FCC:20dBmCE:16dBmWorkingVoltage1.2A@7.4VVoltage17.4vRatedPowerPhantom3Professional100wPhantom3Advanced57WCapacity4480mAhVoltage15.2vBatteryTypeLiPo4SEnergy68WhNetWeight365gMaxFlightTimeApproximately23minutesOperatingTemperature-1oocto40°CMaxChargingPower100W427W.12'"Street,4'"Floor•CathedralSquare•KansasCity,Missouri6410515